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EB-5 Insights

Where Government Policies and Business Realities Converge

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Administrative Appeals Office

In-Depth: The AAO Decision Which Re-interpreted the Definition of “Capital” in EB-5Greenberg Traurig Attorney Kate Kalmykov Featured in Law360 Article on Tough AAO Odds Potentially Pushing More Immigration Fights To Court

Awards & Recognitions

Greenberg Traurig Attorneys Named to Lawdragon’s 2022 Leading Corporate Employment Lawyers of America ListGT Immigration Attorneys Recognized in Legal 500 U.S. 2021 Guide15 Greenberg Traurig Attorneys Recognized as Lawdragon 500 U.S. Corporate Employment Lawyers

Brexit

GTM Alert - Brexit: Immigration and EmigrationGTM Alert – Brexit: The TimelineThe UK Votes to Leave the European Union

Chambers Global

Greenberg Traurig Attorneys, Practices Recognized by Prestigious Chambers Global 2019 Guide

China

Biden Administration Lifts Travel Restrictions to Allow Vaccinated Travelers into United StatesMay 2021 Visa Bulletin Update & Predictions for Remainder of FY 2021Senate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5

Chinese New Year

Important Update on Immigration Issues Related to U.S. Permanent Residents Unable to Travel Back to U.S. Due to Coronavirus Outbreak in ChinaGreenberg Traurig Wishes Our Clients a Very Happy and Healthy Year of the Rat!Greenberg Traurig Wishes Our Clients a Very Happy and Healthy Year of the Pig!

Comprehensive Immigration Reform

USCIS to Hold EB-5 Reform Listening Session May 25美国十七州“扣动扳机”——于联邦法庭起诉寻求禁止奥巴马政府“暂缓遣返”程序17 States Pull the Trigger and File an Action in Federal Court to Enjoin the Obama Administration’s Deferred Action Program

Conrad 30 Waiver Program

Congress Passes and the President Signs the Continuing Resolution Keeping Government and Vital Programs such as EB-5 and E-Verify Operational Thru Dec. 11, 2020 – New Premium Processing DirectiveCongress Passes Continuing Resolution Opening Government and Vital Programs such as EB-5 and E-VerifySenate Passes Continuing Resolution Funding Government; Bill Goes to House

Continuing Resolution (CR)

Congress Passes Omnibus Bill and Continuing Resolution Keeping Government and Vital Programs Such as EB-5 and E-Verify OperationalCongress Passes and the President Signs the Continuing Resolution Keeping Government and Vital Programs such as EB-5 and E-Verify Operational Thru Dec. 11, 2020 – New Premium Processing DirectiveHouse Introduces Continuing Resolution Funding Government, Including Vital programs such as EB-5

DACA

U.S. Businesses Urge Congress to act on a Solution for the Dreamer/DACA RecipientsAttorney General Jeff Sessions Announces the Rescission of DACA

Denials

USCIS Issues Two New Policy Memoranda on Notices to Appear and Denials in Lieu of RFEs and NOIDs – What This Means for You

Department of Homeland Security

Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE ProgramWhy the COVID-19 Pandemic Has Exacerbated USCIS Backlogs and Processing DelaysFederal Court Decision Strikes Down $900,000 EB-5 Investment Threshold

Department of State

US Embassy in Ho Chi Minh City Temporarily Suspends ProcessingMay 2021 Visa Bulletin Update & Predictions for Remainder of FY 2021Updates to Visa Reciprocity for Mexican Nationals

E-Verify

Congress Passes and the President Signs the Continuing Resolution Keeping Government and Vital Programs such as EB-5 and E-Verify Operational Thru Dec. 11, 2020 – New Premium Processing DirectivePresident Signs Appropriations Legislation Extending EB-5 and More Government FunctionsCongress Passes Continuing Resolution Opening Government and Vital Programs such as EB-5 and E-Verify

E-Visa

Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE ProgramUpdates to Visa Reciprocity for Mexican NationalsIsrael to Join Countries Qualified for E-2 Treaty Investor Visa

E-visa Process

Updates to Visa Reciprocity for Mexican Nationalse-Passport Mandatory for the Visa Waiver Program

EB-3

Senate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5Congress Passes and the President Signs the Continuing Resolution Keeping Government and Vital Programs such as EB-5 and E-Verify Operational Thru Dec. 11, 2020 – New Premium Processing DirectiveThe Department of State (DOS) December 2019 Visa Bulletin Released

EB-5

Existing EB-5 Adjudications ResumeUSCIS to Hold EB-5 Reform Listening Session May 25Kate Kalmykov and Jennifer Hermansky Present on Understanding the EB-5 Immigrant Investor Program

EB-5 Business Plan

Biden Executive Order Affirms Deference Policy Including EB-5 CasesEB-5 Regulations SummaryOMB Completes Review of Obama-Era EB-5 Regulations

EB-5 Immigrant Investor Program

Kate Kalmykov and Jennifer Hermansky Present on Understanding the EB-5 Immigrant Investor ProgramEB-5 Regional Center Extension: Stakeholders Can Urge Congress to ReauthorizeFederal Court Decision Strikes Down $900,000 EB-5 Investment Threshold

EB-5 Industry stakeholder groups

EB-5 Regional Center Extension: Stakeholders Can Urge Congress to ReauthorizeEB-5 Regulations SummaryNew EB-5 Regulations: Winners and Losers

EB-5 Investment

Existing EB-5 Adjudications ResumeUSCIS Starts Issuing 24-Month I-829 Petition Receipt NoticesEB-5 Investor Q&A – Regional Center Program Sunset

EB-5 Job Creation

U.S. Senator Paul Seeks to Overturn Recent Obama-Era EB-5 RegulationsEB-5 Regulations SummaryNew EB-5 Regulations: Winners and Losers

EB-5 Legislation

March 18: Policy Update on EB-5 ProgramEB-5 Regional Center Extension: Stakeholders Can Urge Congress to ReauthorizeEB-5 Investor Q&A – Regional Center Program Sunset

EB-5 Modernization Rule

EB-5 Final Rule Challenged in U.S. Federal District CourtComprehensive EB-5 Modernization Legislation Introduced in the U.S. SenateU.S. Senator Paul Seeks to Overturn Recent Obama-Era EB-5 Regulations

EB-5 Processing Times

USCIS Announces Significant Change to EB-5 Adjudications ProcessingNew EB-5 Regulations: Winners and LosersCurrent EB-5 Processing Times

EB-5 Program

Existing EB-5 Adjudications ResumeGreenberg Traurig and Visa Franchise to Present on 'Choosing the Optimal Path for Permanent Residency in the US: Understanding the Direct EB-5'What Does the New I-956 EB-5 Regional Center Designation Process Mean for Regional Center Investors?

EB-5 Project

Biden Executive Order Affirms Deference Policy Including EB-5 CasesEB-5 Regulations SummaryNew EB-5 Regulations: Winners and Losers

Eb-5 Regional Center

WEBINAR | The Right Time is Now: Succeeding with EB-5 in 2022Challenge to USCIS Agency Interpretation of EB-5 Legislation in Federal District CourtCongress Passes Continuing Resolution through March 11

Econometric Report

Third Quarter Updates from USCIS on EB-5 ProgramExecutive Summary and Clarifications from May 1, 2012 EB-5 Stakeholders Meeting with USCISUSCIS Announces Engagement with EB-5 Economists

Emerging Technology

Greenberg Traurig’s Emerging Technology Group Presents “Start-Up Law” Series to Harvard Law School Students

Events

Kate Kalmykov to Moderate and Host Event Focusing on Portuguese Golden Visa ProgramGreenberg Traurig and Visa Franchise to Present on 'Choosing the Optimal Path for Permanent Residency in the US: Understanding the Direct EB-5'USCIS to Hold EB-5 Reform Listening Session May 25

Executive Order

USCIS Updates Policies to Improve Immigration ServicesBiden Executive Order Affirms Deference Policy Including EB-5 CasesPresident Biden Signs Presidential Proclamation Suspending Entry of Certain Persons Entering US from India

Firm News

Greenberg Traurig’s Immigration and Compliance Team Wishes Our Clients and Colleagues Happy Holidays and a Happy New Year15 Greenberg Traurig Attorneys Recognized as Lawdragon 500 U.S. Corporate Employment LawyersGreenberg Traurig Elevates Kristen W. Ng to Shareholder and Agnes Cha Rudinsky to Of Counsel in Northern Virginia

For I-924A

USCIS Discusses Guidance on Form I-924A for FY 2017

Foreign Exchange Management Law

Central Bank of Myanmar Revokes Foreign Exchange Licenses

General

Greenberg Traurig Elevates Kristen W. Ng to Shareholder and Agnes Cha Rudinsky to Of Counsel in Northern VirginiaGreenberg Traurig Wishes Our Clients a Very Happy and Healthy Year of the Pig!Greenberg Traurig’s EB-5 Team Wishes our Clients and Colleagues a Happy New Year

Government Accountability Office (GAO)

Government Accountability Office Agrees to Investigate Immigration Case Backlog at USCIS as EB-5 Adjudication Times Dramatically IncreaseSummary of GAO report - Immigrant Investor Program: Proposed Project Investments in Targeted Employment AreasPending EB-5 Legislation Provides a Comprehensive Response to the GAO

Government Shutdown

Congress Passes Omnibus Bill and Continuing Resolution Keeping Government and Vital Programs Such as EB-5 and E-Verify OperationalPresident Trump Signs Appropriation Packages Extending Vital Programs Like EB-5 and Preventing a Government ShutdownCongress Releases 12-Bill Funding Package to Extend Vital Programs Such as EB-5 and to Prevent a Government Shutdown

Green Cards

I-751 Petition Receipt Notices and I-829 Petition Receipt Notices Now Valid for 24 Months as Proof of StatusCOVID-19 Vaccine Added To Requirements For Green Card Processing, Effective Oct. 1Important Update on Immigration Issues Related to U.S. Permanent Residents Unable to Travel Back to U.S. Due to Coronavirus Outbreak in China

GT Alert

US Ends COVID-19 Testing Requirement for Inbound Air TravelersPost Offering Obligations for EB-5 Issuers: “You Closed, Now What?”U.S. District Court for District of Columbia Issues Important Decision in Favor of EB-5 Investors

GT Start-Up Law

Greenberg Traurig’s Emerging Technology Group Presents “Start-Up Law” Series to Harvard Law School Students

H-1B

Senate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5Changes in H and L Visa Processing in China

H-1B Cap

Senate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5New Trump Administration Policy in Support of Buy American, Hire American Toughens Visa Extension ProcessPresident Trump Signs New Executive Order: “Buy American and Hire American”

HR 6157

President Trump Signs Continuing Resolution into Law

I-526

District Court Orders USCIS to Process New I-526 Petitions Throughout Previously Authorized Regional CentersExisting EB-5 Adjudications ResumeUSCIS to Hold EB-5 Reform Listening Session May 25

I-829

WEBINAR – New Issues in I-829 Adjudications: A Reexamination of Source of Funds Issues Post I-526 ApprovalBiden Executive Order Affirms Deference Policy Including EB-5 CasesUpdate – Processing Times for EB-5 Related Petitions

I-924

New EB-5 Regulations: Winners and LosersUSCIS Holds EB-5 Stakeholder Engagement in New York City Field OfficeForm I-924 Average Processing Time Reaches Greater than 20 Months

Immigrant Green Card

SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC RulingCOVID-19 Executive Order: EB-5 FAQUSCIS Announces Significant Change to EB-5 Adjudications Processing

Immigrant Investor

Kate Kalmykov and Jennifer Hermansky Present on Understanding the EB-5 Immigrant Investor ProgramUSCIS Starts Issuing 24-Month I-829 Petition Receipt NoticesFederal Court Decision Strikes Down $900,000 EB-5 Investment Threshold

Immigrant Visa

Existing EB-5 Adjudications ResumeCongress Set to Pass EB-5 Reform and Reauthorize EB-5 Regional Center Program through Sept. 30, 2027Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE Program

Immigration

Congress Set to Pass EB-5 Reform and Reauthorize EB-5 Regional Center Program through Sept. 30, 2027Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE ProgramCongress Passes Continuing Resolution through March 11

Immigration Law

Greenberg Traurig Attorneys Named to Lawdragon’s 2022 Leading Corporate Employment Lawyers of America ListImmigration Changes and Considerations in a Nearing Post-COVID-19 WorldJuly Visa Bulletin Advances EB-5 Vietnam Visa Backlog Significantly

Immigration Reform

Biden Administration Revokes Trump’s 'Green Card Ban' In Another Step Towards Restoring the Functioning of the U.S. Immigration SystemNew Biden Immigration Bill Announced on Day One of AdministrationCongress Passes Omnibus Bill and Continuing Resolution Keeping Government and Vital Programs Such as EB-5 and E-Verify Operational

India

Biden Administration Lifts Travel Restrictions to Allow Vaccinated Travelers into United StatesPresident Biden Signs Presidential Proclamation Suspending Entry of Certain Persons Entering US from IndiaUS Immigration and COVID-19-Related Travel Considerations: Update on Travel to the United States from India

Inspector General

Investigation into Employee Complaints about Management of USCIS' EB-5 ProgramThe Office of the Inspector General Releases Report Critical of the USCIS Administration of the EB-5 Regional Center ProgramSenate Confirms USCIS Director Mayorkas for DHS Deputy Position and President Obama Announces His Pick to Replace Him

Investment

Greenberg Traurig and Visa Franchise to Present on 'Choosing the Optimal Path for Permanent Residency in the US: Understanding the Direct EB-5'What Does the New I-956 EB-5 Regional Center Designation Process Mean for Regional Center Investors?OMB Publishes Fall 2018 Unified Agenda with EB-5 Regulatory Updates

L visa

Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE ProgramChanges in H and L Visa Processing in ChinaThe Trump Administration Contemplates an Executive Order Affecting Advance Parole

Legislation

EB-5 Regional Center Extension: Stakeholders Can Urge Congress to ReauthorizeSenate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5Court Again Allows Use of Form I-944

Marketing

Greenberg Traurig to Host International EB-5 Finance Seminar in Mexico City on February 18thKate Kalmykov to Serve as Co-Panelist at "Putting Together the Pieces of EB-5"GT Immigration Practice Ranks Tier One in The U.S. News-Best Lawyers 2014 Best Law Firm Rankings

Migration Agents

Greenberg Traurig Announces New Package of EB-5 Services for Overseas Migration Agents

National Visa Center

National Visa Center (NVC) Confirms it is Working To Restore Cases Affected by October 2016 Retrogression: Notice on Employment 5th Preference Cases at NVCNational Visa Center Confirms it is Working To Restore Cases Affected by October 2016 Retrogression: Notice on Employment 5th Preference Cases at NVC

NOID

EB-5 Regional Center Program Expires June 30, 2021USCIS Updates Policies to Improve Immigration ServicesEB-5 Processing During the Government Shutdown

Non-Regional Center

2.5 Year Rule Stifles Economic Benefits of the EB-5 ProgramAILA Issues Helpful Tips for Korean EB-5 CasesJoin Us In Dallas for the National EB-5 Finance Seminar Tour

Notices to Appear

USCIS Issues Two New Policy Memoranda on Notices to Appear and Denials in Lieu of RFEs and NOIDs – What This Means for You

NTAs

UPDATE: USCIS Postpones Implementation of New Policy Memoranda on Notices to Appear

Office of Management

USCIS moves EB-5 Modernization Rule to OMB

OMB

OMB Completes Review of Obama-Era EB-5 RegulationsOMB Releases Spring Unified Regulatory Agenda; Provides Update on EB-5 and Other Pending RegulationsUSCIS moves EB-5 Modernization Rule to OMB

Omnibus Appropriations Act

Congress Releases 12-Bill Funding Package to Extend Vital Programs Such as EB-5 and to Prevent a Government ShutdownOmnibus Appropriation Legislation with EB-5 Extension Becomes Law

Posts in Chinese

Significant Advancement in the EB-5 Category – March 2020 Visa Bulletin Update & Use of Chart B for Filing Adjustment of Status ApplicationsAlert – U.S. Embassy and Consulates in China Cancel Immigrant and Nonimmigrant Visa Interviews for the Week of Feb. 3 通知:美国驻华大使馆和领事馆取消2月3日一周的移民类和非移民类签证面试Greenberg Traurig EB-5团队祝愿尊敬的客户和各位同事节日快乐!新年快乐!

President Trump's Administration

Biden Administration Revokes Trump’s 'Green Card Ban' In Another Step Towards Restoring the Functioning of the U.S. Immigration SystemHong Kong Executive Order – July 14, 2020U.S. Supreme Court Lifts Temporary Injunctions on Public Charge Rule

Privacy Act notice

USCIS Discusses Guidance on Form I-924A for FY 2017

Proposed Rule

OMB Publishes Fall 2018 Unified Agenda with EB-5 Regulatory UpdatesProposed Immigration Rule – Inadmissibility on Public Charge Grounds

Reform and Reauthorization of the EB-5 Regional Center Program

EB-5 Industry Stakeholders Unveil Consensus Principles to Reform and Reauthorize the EB-5 Program

Refugee

GT Alert: New Executive Order Impacts Entry to the United States, Visa Issuance, Refugee, and Screening Procedures

Regional Center

WEBINAR | The Right Time is Now: Succeeding with EB-5 in 2022Congress Set to Pass EB-5 Reform and Reauthorize EB-5 Regional Center Program through Sept. 30, 2027Consular Processing Uses Tiered Approach to Triage EB-5 Applications

Retrogression

India EB-5 Retrogression Has ArrivedUpdate on Vietnam RetrogressionWhat Every Vietnamese EB-5 Applicant and Agent Need to Know About Retrogression

RFE

EB-5 Regional Center Program Expires June 30, 2021USCIS Updates Policies to Improve Immigration ServicesEB-5 Processing During the Government Shutdown

RIN 1615-AC07

USCIS moves EB-5 Modernization Rule to OMB

Screening Procedures

GT Alert - President Trump’s Executive Order (EO) “Protecting the Nation from Foreign Terrorist Entry into the United States”: Q&ASummary of Executive Order: Protecting the Nation from Terrorist Attacks by Foreign NationalsGT Alert: New Executive Order Impacts Entry to the United States, Visa Issuance, Refugee, and Screening Procedures

Securities Law

What Does the New I-956 EB-5 Regional Center Designation Process Mean for Regional Center Investors?SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC RulingFINRA Plans Major Changes to Expungement Rules

shutdown

Existing EB-5 Adjudications ResumeUS Embassy in Ho Chi Minh City Temporarily Suspends ProcessingUPDATE: Government Lapse of Appropriations and Shutdown Status

Speaking Engagement

Visa Options and Issues for StudentsGreenberg Traurig Presents at the American Immigration Lawyers Association (AILA) Philadelphia ChapterGreenberg Traurig Attorney Presents at The University of Michigan on Post-Graduate Visa Options

State Department

COVID-19 Vaccine Added To Requirements For Green Card Processing, Effective Oct. 1July Visa Bulletin Advances EB-5 Vietnam Visa Backlog SignificantlyBiden Administration Revokes Trump’s 'Green Card Ban' In Another Step Towards Restoring the Functioning of the U.S. Immigration System

Targeted Employment Area

What Does the New I-956 EB-5 Regional Center Designation Process Mean for Regional Center Investors?Federal Court Decision Strikes Down $900,000 EB-5 Investment ThresholdImmigration Through Investment: A Comparison of the U.S. EB-5 Program vs. the Quebec Immigrant Investor Program

Tax Considerations

Maintaining Eligibility for Permanent Residence for EB-5 Investors: Criminal Issues and TaxesIRS Proposes Rules for Tax on Gifts From ExpatriatesNon-Resident U.S. Citizens and Green Card Holders Afforded a Streamlined Tax Compliance Program

TEA

What Does the New I-956 EB-5 Regional Center Designation Process Mean for Regional Center Investors?Federal Court Decision Strikes Down $900,000 EB-5 Investment ThresholdBiden Executive Order Affirms Deference Policy Including EB-5 Cases

Temporary Restraining Order

Two Temporary Restraining Orders Issued for the Executive Order on the Travel BanU.S. Court of Appeals Declines to Stay Temporary Restraining Order in connection with Executive OrderCourt Issues Temporary Restraining Order Against Enforcement of January 27, 2017 Executive Order; Agencies Cooperating

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Travel

US Ends COVID-19 Testing Requirement for Inbound Air TravelersRussian Suspension of Visa Processing Effective May 12, 2021President Biden Signs Presidential Proclamation Suspending Entry of Certain Persons Entering US from India

U.S. Court of Appeals for the Ninth Circuit

U.S. Court of Appeals Declines to Stay Temporary Restraining Order in connection with Executive Order

U.S. Customs and Border Protection (CBP)

Immigration Issues for Chinese Travelers to the United States During the Coronavirus OutbreakDHS Issues New Rules for Searching Electronic Devices at the BorderBREAKING – Supreme Court of the United States Partially Lifts Injunctions Barring President Trump’s Travel Ban But Agrees to Hear Case in Fall of 2017

U.S. Customs and Border Protections

Important Update on Immigration Issues Related to U.S. Permanent Residents Unable to Travel Back to U.S. Due to Coronavirus Outbreak in ChinaMaintaining Eligibility for Permanent Residence for EB-5 Investors: Termination of CPR StatusCourt Issues Temporary Restraining Order Against Enforcement of January 27, 2017 Executive Order; Agencies Cooperating

U.S. State Department

Consular Processing Uses Tiered Approach to Triage EB-5 ApplicationsImportant Update on Visa Rescheduling Due to the CoronavirusChanges in H and L Visa Processing in China

Uncategorized

Senate Passes Per-Country Cap Elimination Bill that Affects Employment-Based Visa Programs Such as EB-5USCIS Announces Significant Change to EB-5 Adjudications ProcessingNew EB-5 Regulations: Winners and Losers

USCIS

District Court Orders USCIS to Process New I-526 Petitions Throughout Previously Authorized Regional CentersExisting EB-5 Adjudications ResumeUSCIS to Hold EB-5 Reform Listening Session May 25

USCIS Public Engagement

OMB Publishes Fall 2018 Unified Agenda with EB-5 Regulatory Updates美国移民局有关2016年10月排期的说明USCIS Changes Policy on the Use of Loan Proceeds as a Source of Funds

Vietnam Retrogression

July Visa Bulletin Advances EB-5 Vietnam Visa Backlog SignificantlyUSCIS Announces Significant Change to EB-5 Adjudications ProcessingUpdate on Vietnam Retrogression

Vietnamese

US Embassy in Ho Chi Minh City Temporarily Suspends ProcessingJuly Visa Bulletin Advances EB-5 Vietnam Visa Backlog SignificantlyMay 2021 Visa Bulletin Update & Predictions for Remainder of FY 2021

Visa

Congress Set to Pass EB-5 Reform and Reauthorize EB-5 Regional Center Program through Sept. 30, 2027Jennifer Hermansky and Kate Kalmykov to Present at Celesq CLE ProgramBiden Administration Lifts Travel Restrictions to Allow Vaccinated Travelers into United States

Visa Bulletin

July Visa Bulletin Advances EB-5 Vietnam Visa Backlog SignificantlyMay 2021 Visa Bulletin Update & Predictions for Remainder of FY 2021Returning Resident Visas and COVID-19 Travel

Visa Issuance

Existing EB-5 Adjudications ResumeRussian Suspension of Visa Processing Effective May 12, 2021Biden Administration Revokes Trump’s 'Green Card Ban' In Another Step Towards Restoring the Functioning of the U.S. Immigration System

Visa Waiver Program

Trump Administration Nominates Poland for U.S. Visa Waiver Programe-Passport Mandatory for the Visa Waiver Program

Webinar

Greenberg Traurig and Visa Franchise to Present on 'Choosing the Optimal Path for Permanent Residency in the US: Understanding the Direct EB-5'Kate Kalmykov and Jennifer Hermansky Present on Understanding the EB-5 Immigrant Investor ProgramWEBINAR | The Right Time is Now: Succeeding with EB-5 in 2022

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