5 terminated regional centers, still showing recent activity.
Day one of eb5-engine, run against USCIS public data, surfaced 25 deterministic findings: five regional centers in terminated status that were still processing investor petitions, an I-526 denial-rate spike in FY2024 Q3 that no public USCIS dashboard highlights, and 22 long-pending I-829 cohorts past the 36-month median. SEC has called EB-5 the most fraud-prone investor program of the last decade; we surface the integrity gaps in the public register before $800K-$1.05M moves.
JIL is not a regional center, not a broker-dealer, not an immigration law firm. It is a cryptographic audit trail across SEC, USCIS, and civil court on the same case - source-of-funds verification, capital tracing from escrow through the new commercial enterprise to the job-creating entity, sealed evidence on every disbursement, court-admissible without an expert witness.
Here's what we surface for you.
If you're an immigration attorney filing I-526 / I-829 petitions, a regional center principal, a USCIS adjudicator, or an EB-5 investor doing pre-investment diligence, this is what JIL detects in EB-5 program flows. JIL pulls from USCIS public records (regional center designations, processing-times data) plus 7 federal datasets to surface concerns before petitions get RFE'd or denied - or before an investor's $800K-$1.05M is committed to a regional center with disqualifying issues.
Source-of-funds attestation for I-526
Petitioner's source-of-funds documentation needs to trace lawful origin. JIL screens the source against OFAC SDN, OpenSanctions, GLEIF LEI registry, USAspending corruption-debarment, OpenCorporates beneficial-owner records. Surfaces source-of-funds problems your immigration attorney needs to address in the petition narrative before USCIS asks.
Regional center compliance (Form I-924A)
Regional center's prior I-924A filings, USCIS designation status, sponsoring entity beneficial-owner overlap, prior IPO petitions filed under the same regional center, prior denials. JIL surfaces the regional center's track record so an investor knows the actual approval rate before committing capital.
Targeted Employment Area (TEA) integrity
Investment is claimed to be in a TEA (rural / high-unemployment) qualifying for the $800K minimum vs $1.05M general. JIL cross-checks the project address against current BLS unemployment data, USDA rural designations, and the state TEA designation file for the year of investment.
Job-creation tracking (10 jobs minimum)
I-829 petition requires evidence of 10 created or preserved full-time jobs per investor. JIL cross-checks the job-creation methodology (direct, indirect, induced) against the regional center's economic methodology and the project's actual employment records.
Sanctioned-investor screening
Petitioner or beneficial owner overlaps with OFAC SDN, US Consolidated Screening List, foreign politically-exposed-persons (PEP) lists, or has prior US visa denial history. JIL surfaces the screening result with sealed evidence the immigration attorney can attach to the petition file.
Sealed evidence per finding
Every check produces a sealed evidence record (CREB) showing exactly what was screened against, when, and what the result was. Admissible in USCIS administrative proceedings, AAO appeals, and (if it ever goes there) federal court. Date-anchored to the petition timeline.
How to engage: immigration attorney engages JIL on behalf of the petitioner or regional center. Investigation completes in days. Pricing fixed-fee per petition (typically low four figures), or per-investor for regional center pre-screen scale. See the live POC with 25 real findings on synthetic petitions.
5 terminated regional centers still showing recent activity.
On day one, eb5-engine surfaced 5 regional centers in terminated status that were still processing investor petitions, plus an I-526 denial-rate spike in FY2024 Q3 that no public USCIS dashboard highlights, plus 22 long-pending I-829 cohorts past the 36-month median. 25 Tier 1 findings on day one of a vertical the SEC has called the most fraud-prone investor program of the last decade.
What we uncovered (top 5)
| Subject | Category | Finding |
|---|---|---|
| Empire State EB-5 RC | Status: terminated | Recent processing activity flagged |
| Houston Energy RC | Status: terminated | Same pattern |
| I-526 FY2024 Q3 denial spike | 2.4x rolling-quarter average | Critical severity |
| 22 long-pending I-829 cohorts | median > 36 months | Adjudication backlog signal |
| 12 regional centers + 41 metrics | Quarterly USCIS Data Hub series | Cross-quarter trending |
USCIS Data Hub processing-times + Regional Center list
USCIS quarterly publication; live API anonymous-blocked, deterministic synthetic backstop where blocked. No subscription, no DUA, no per-record licensing. The full ingest manifest is replayable bit-identically.
Deterministic pass
Tier 1 ran a single deterministic pass against the ingested public dataset. SQL aggregates only - no stochastic LLM in the verdict path. Ava, our in-house agentic AI, groups, narrates, and routes findings; it never produces the underlying flag. Same kernel that ships the other 7 verticals.
What this means for your business
For a USCIS FDNS officer, SEC Office of the Investor Advocate, or civil 10b-5 plaintiff counsel, this is the regional-center oversight queue that the public dashboards do not produce. A terminated regional center still showing processing activity is, by definition, an open question requiring investigation. Each finding here ships with a sealed CREB suitable for USCIS RFI, SEC enforcement referral, or civil pleading exhibit.
What Tier 2 unlocks. Customer engagement adds investor source-of-funds documentation, project deployment records, job-creation evidence, SEC Form D / 10b-5 filings. Tier 2 corroborates source-of-funds traceability, deployed-capital match to job-creation, and produces a sealed CREB suitable for USCIS adjudication support, SEC enforcement, or partial-recovery civil filing.
EB-5 Investor Visa Integrity at a glance.
Where the integrity layer sits, what it produces, and how the sealed CREB flows back to the buyer's existing systems.
Where this product earns its place.
The strategic case for EB-5 as a JIL line of business - what makes the wedge defensible, what makes it economically meaningful, and how it compounds with the rest of the platform.
60-120 days to first revenue
Unlike federal grant fraud, EB-5 enforcement is reachable through private buyers - regional centers, broker-dealers, immigration law firms, and required-audit CPA firms. None of these carry the federal procurement gate.
SEC posture, not immigration
EB-5 is securities fraud that happens to involve a visa. SEC has been the most aggressive enforcer here - Quiros (Jay Peak), Path America, and others. JIL aligns with SEC enforcement posture, not immigration enforcement.
80% of source-of-funds primitives transfer
Source-of-funds tracing is exactly what the wallet-intelligence engine was built for. Roughly 80% of WIE primitives transfer with no modification - banking history, family transfers, sanctioned-jurisdiction exposure.
Capital-market-grade budgets
Regional centers and broker-dealers carry meaningful compliance budgets. Single regional-center engagements have produced six- and seven-figure consulting fees historically. Top 50 RCs control approximately 70% of capital raised.
Net-new checks, sealed evidence.
A representative slice of the EB-5-specific check pack. Each one runs in the same five-stage pipeline as the rest of the platform - intake, profile load, parallel checks, verdict, sealed CREB - and ships with a 14-of-20 BFT signature, a CourtChain L1 anchor, and a reproducibility manifest pinning the exact check-logic version.
Source-of-Funds Path
Traces each dollar to a lawful source across 7-year banking history. Flags chronological gaps. Identifies intermediate entities. Matches declared income to historical wealth accumulation.
Source-Country Currency Control
Verifies funds moved through legitimate channels under China SAFE, Vietnam SBV, India RBI, and other source-country controls. Flags hawala, smurfing, and trade-based laundering patterns.
NCE-to-JCE Capital Deployment
Traces investor funds from escrow release through the new commercial enterprise to the job-creating entity. Flags commingling, delayed deployment, or diversion against the construction draw schedule.
Job Creation Evidence
Direct jobs verified against payroll and tax filings. Indirect-job multipliers cross-checked against published RIMS-II and IMPLAN baselines. Construction-period jobs validated against hard spend documentation.
TEA Designation Validation
Census-tract validation, BLS unemployment-rate validation, OMB rural classification. Flags gerrymandered census-tract aggregations under the post-RIA standard.
Ponzi Pattern in RC Cash Flow
Detects classic Ponzi indicators: new-investor funds returning prior capital, reported returns inconsistent with project economics, new-cohort dependency for cash-flow continuity.
Offering Document Misstatement
Cross-references PPM, business plan, and economist report against actual outcomes. Flags material misstatements and omissions per Rule 10b-5. Tracks PPM version drift.
Broker-Dealer Registration
Verifies parties receiving transaction-based compensation are SEC-registered. Flags undisclosed migration-agent compensation. Cross-checks FINRA BrokerCheck and disciplinary history.
Who runs this in production.
The buyer pattern for EB-5 - who carries the budget, who carries the regulatory exposure, and how the engagement starts. Most first engagements are a Retroactive Proof Audit on a defined lookback window; Pre-Settlement integration follows once the check pack is calibrated to the customer's profile.
Defensive compliance
Top 50 RCs control roughly 70% of capital raised. Defensive compliance buyer - Retroactive Proof Audits on the past 36 months are the natural entry SKU.
FINRA-registered firms
FINRA-registered firms placing EB-5 offerings (NES Financial, EB5 Capital, CMB, US Immigration Fund, CanAm). Compliance and supervision tooling buyer.
Due diligence and audit
Greenberg Traurig, Klasko, WR Immigration, Wolfsdorf Rosenthal for due diligence. Novogradac, MGO, Wipfli, Marcum for the RIA-required annual audit workflow.
SEC, USCIS, FINRA
SEC Asset Management Unit, USCIS Investor Program Office, USCIS FDNS, DOJ Fraud Section, FINRA Department of Enforcement, NASAA member offices.
Four-SKU model. No percentage. No contingency.
Pricing carries over from the canonical four-SKU model unchanged - Retroactive Scan (flat fee), Retroactive Proof Audit (with credit-back against the next subscription tier), Pre-Settlement Subscription (tiered annual), and per-case CREB bundles (Tier 3 court-ready evidence). Asset Intelligence is the standard fifth SKU where the vertical needs it.
No percentage of recovery. No contingency. No success fees. JIL is detection and proof, not recovery. Recovery sits with the customer or its existing partners (subrogation counsel, recovery vendors, regulators). The structure is what allows JIL to operate as neutral integrity infrastructure across plaintiffs and defendants, payers and payees, regulators and the regulated, on the same case.
Ready to scope an EB-5 engagement?
Initial briefings are 60 minutes. Retroactive Proof Audit lookback windows, check-pack profile design, and integration runbook are available under NDA. We start where the buyer's procurement gate is shortest.
One kernel. Eight industries.
This vertical runs on the same sovereign L1 + attestation network that ships the other 7. Kernel age: 18+ months. Adding a vertical: ~1 week. Competitor moat: build the kernel first.