Trump’s $5 Million ‘Gold Card’ Visa: A Gateway for Financial Crime?

President Donald Trump’s proposal to replace the existing EB-5 visa program with a streamlined $5 million 'gold card' residency system has raised serious financial crime concerns. Whilst investment-based immigration programs have historically contributed to economic growth, selling US residency outright increases risks of money laundering, corruption, and illicit financial flows. Without stringent safeguards, this program could undermine US national security and financial integrity.

A Loophole for Financial Criminals

Financial watchdogs, including the Financial Action Task Force (FATF), have long warned that investment-for-residency schemes present high risks for money laundering and tax evasion. Unlike the EB-5 program, which mandates economic investment and job creation, a direct cash-for-residency model removes essential due diligence layers. Without robust Know Your Customer (KYC) and Source of Funds (SOF) verification, individuals with illicit wealth could use this system to gain access to the US financial network, bypassing anti-money laundering (AML) safeguards.

Exploitation by Corrupt & Sanctioned Individuals

The absence of clear vetting mechanisms raises the risk that politically exposed persons (PEPs), corrupt officials, and sanctioned individuals could misuse the program. Those seeking to evade international sanctions or launder illicit funds could leverage the 'gold card' to gain legitimacy and US banking access, undermining the credibility of US sanctions enforcement.

No Economic Benefit or Job Creation

Unlike the EB-5 visa, which channels investments into US businesses, the proposed 'gold card' system provides no economic contribution beyond an upfront payment. This transaction-based model removes any requirement to engage in lawful business activities, creating an appealing avenue for those seeking to shield wealth rather than contribute to economic development.

The Russian Oligarch Factor

Concerns escalated further when President Trump suggested that Russian oligarchs could apply for the program. During a public appearance, he stated “Hey, I know some Russian oligarchs that are very nice people,” before joking, “They are not as wealthy as they used to be; I think they can afford $5 million.”

Given the sanctions imposed on many Russian oligarchs, granting them US residency through this scheme would create severe legal and reputational risks for the US government, financial institutions, regulators, and the broader business community. The US government could face diplomatic fallout. Regulatory agencies, including the Office of Foreign Assets Control (OFAC), Securities & Exchange Commission (SEC), and Financial Crimes Enforcement Network (FinCEN), could be criticised for inadequate oversight, and US businesses engaging with these individuals could risk legal exposure and reputational harm. If sanctioned individuals exploit this program, financial institutions could face heightened compliance burdens and potential violations of international sanctions laws.

A Money Laundering & Tax Evasion Risk

The ability to obtain US residency with a single, unverified payment makes the program attractive for individuals seeking to clean illicit funds. Without strict AML and SOF checks, the US risks becoming a haven for dirty money. Moreover, the US tax system, which applies worldwide taxation to residents, could inadvertently facilitate tax evasion if individuals manipulate residency status to obscure offshore financial activities.

Regulatory Oversight, Political Influence & Russian Alignment

Another critical concern is the potential for political interference in financial regulation. The Trump administration’s executive order requiring independent agencies to submit draft regulations for White House review raises fears that financial crime enforcement could be weakened. Greater White House control over regulators such as the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and SEC could lead to inconsistent enforcement of AML and sanctions policies.

Moreover, Trump’s broader agenda appears to favour policies that align with Russian interests, including deregulation, the weakening of financial oversight, and the concentration of unprecedented authority within the executive branch. This creates an environment where financial regulations designed to prevent illicit finance could be selectively enforced or overlooked altogether. Such moves could benefit individuals linked to Russian financial networks and others seeking to exploit weak regulatory frameworks.

Industry experts warn that if financial regulators prioritise political objectives over financial integrity, the oversight of high-risk transactions—such as those enabled by the ‘gold card’ visa—could become less stringent. This creates a dangerous precedent where residency-for-investment schemes could be exploited more easily by individuals seeking to evade financial scrutiny. If enforcement efforts weaken, financial institutions may struggle to comply with shifting regulatory expectations, increasing the likelihood of illicit financial activity slipping through the cracks.

The Impact on Global Financial Crime Compliance

If the US proceeds with a direct cash-for-residency model while simultaneously weakening financial regulatory independence, it risks damaging its status as a global leader in financial crime compliance. Residency-by-investment programs worldwide have come under scrutiny, with the European Union tightening regulations on 'golden visa' schemes due to concerns over financial crime and limited economic benefits. The US risks falling behind in international AML efforts if transparency and oversight measures are not strengthened.

Conclusion: A High-Risk Policy with Far-Reaching Consequences

Trump’s $5 million ‘gold card’ visa plan poses significant financial crime risks. By eliminating economic investment requirements, weakening due diligence, and potentially allowing sanctioned individuals to obtain US residency, the program could facilitate money laundering, tax evasion, and illicit financial activities. The potential for political influence over financial regulators exacerbates these concerns, particularly given Trump’s broader agenda that appears to favour deregulation and policies beneficial to Russian financial interests. Unless strong safeguards and regulatory oversight are implemented, this policy could become a major vulnerability in the US financial system. Policymakers must prioritise financial integrity and national security over short-term revenue gains.