No. Derivative beneficiaries are limited to the investor's spouse and unmarried children under 21, with age assessed under the Child Status Protection Act. An adult daughter has her own immigration status and cannot be included in her parents' EB-5 case.
Derivatives are defined by age and marital status, not by family closeness
The EB-5 classification extends to the investor's spouse and to unmarried children who are under 21, and the Child Status Protection Act can freeze a child's age at certain points in the process. It does not extend upward or sideways: an adult child, a married child, a parent or a sibling cannot be included. Once Bohdan and Iryna become permanent residents, any petition they might file for her as an adult child would be a separate family-based case with its own waiting period.
If the couple have a younger child who is still under 21, that child can be included, and the family should watch the timeline closely, because processing delays interact with the age rules in ways an adviser must calculate. Both spouses can be included on one petition, with Bohdan or Iryna as the principal investor; the choice of principal can matter if one spouse's funds are easier to document than the other's. Hypothetical example: Lena is the principal investor and her spouse Omar has a twenty-year-old child from an earlier marriage.
Before filing, they should obtain civil records, check whether the child is unmarried and calculate the age-protection issue against the actual filing and visa timeline. The birth certificate and marriage records settle relationship questions; a family tree does not. If the child cannot qualify as a derivative, decide early whether a separate route is realistic.
The family also needs to understand that permanent residence first arrives with conditions, tied to capital remaining at risk and the required employment creation being shown later.