No. The contribution is publicly described as a gift to the U.S. government together with a separate nonrefundable processing fee, not as capital invested and placed at risk in a commercial enterprise. EB-5 capital is invested, must be sustained, and is tied to a job-creation requirement; a gift is none of those things.
Two very different things that are frequently compared badly
The comparison people make is between two large numbers, and that framing hides the more important difference. EB-5 capital goes into a business, can in principle produce a return, is exposed to loss, and is examined again later to confirm it was sustained and that employment was created. The described Gold Card contribution leaves permanently and is associated with background vetting and eligibility for lawful permanent residence through EB-1 or EB-2 rather than with an enterprise.
Anyone weighing the two should model the outcome where the filing does not succeed, since that scenario separates them sharply. Because the program is administratively implemented and its terms may change, verify the current official description before relying on any of this, and take advice from a licensed U.S. immigration attorney.
Hypothetical example: Hadi owns a timber-frame manufacturer and is considering an individual Gold Card application after a planned sale. Begin with a checklist for the official program terms, eligibility for the immigrant classification, admissibility, visa availability and the funds trail. The current official instructions settle the payment sequence; sale records and bank evidence settle the source of the applicant’s money.
Sequence the commercial sale on its merits, then apply only when the applicant can satisfy the program’s required steps. An eligibility error is assuming a contribution substitutes for category eligibility. Official instructions require the applicant to pay the U.S.
government, and the program uses existing immigrant classifications rather than creating a conventional visa category.