USCIS Concludes Audits of All 13 Civitas-Affiliated Regional Centers
Civitas Capital Group announced that U.S. Citizenship and Immigration Services (USCIS) has concluded its audits of all 13 Civitas-affiliated EB-5 regional centers, completing the audit process mandated by the EB-5 Reform and Integrity Act of 2022 (RIA).
The RIA established a compliance framework for regional centers built on heightened operational standards, detailed annual reporting, annual integrity fees, and periodic audits – the statute directs USCIS to review each designated regional center at least once every five years.
These reviews are substantive rather than procedural. They include, but are not limited to, ownership, management, and governance structure; the movement of investor capital into the new commercial enterprises and through to the job-creating entities; USCIS filings and the evidence submitted in support of them; financial statements and bank records; the policies and internal controls used to monitor projects; promoter and marketing practices; the systems that track investor data and the controls protecting them – access provisioning and revocation, restrictions on investor personally identifiable information, encryption and network safeguards, audit logging, data storage and backup arrangements, incident response procedures, and training for staff who handle sensitive investor information; and communications with securities regulators, among other areas.
USCIS’ Immigrant Investor Program Office (IPO), the division that administers the EB-5 program, issued its requests to Civitas in three rounds spanning the 13 regional centers – a practical consequence of operating more than a dozen designated regional centers rather than one. Each audit covered both pre-RIA and post-RIA operations.
Meeting requests of that breadth, on a federal timetable and across 13 regional centers, drew on work from across the firm and beyond it. Civitas teams worked the requests in parallel, alongside external counsel and professional partners. The audit process was a working one. Auditors met with Civitas teams in person and virtually, examining the firm’s operating practices as they function day to day – how oversight decisions are made and documented, where controls are applied within each process, and who is accountable at each stage. Questions were addressed as they came, with the supporting records available throughout. The IPO audit teams were well prepared and specific about what they needed, which kept a demanding process an orderly one. Civitas is grateful for the professionalism and rigor they brought to each of these reviews. USCIS closed each of the 13 audits without requiring any subsequent action from Civitas.
The RIA placed integrity at the heart of the EB-5 program by design. In practice, that means records kept as the statute requires, certifications made accurately, integrity fees paid on time, diligence performed on those associated with each regional center, and ongoing oversight of the entities through which investor capital moves. Civitas regards these as continuing obligations owed to its investors rather than periodic filings. In the EB-5 program, designation and compliance are not earned once. They are standards met continuously – and Civitas is committed to meeting them.
About Civitas Capital Group
Civitas Capital Group is a leading EB-5 regional center operator and trusted real estate capital partner. Since 2009, Civitas has invested in over 50 real estate development projects with a 100% USCIS approval rate, always anchored by the firm’s core values of Focused Creativity, Institutional Stewardship, and Respect & Grace. On behalf of thousands of EB-5 investors and their families, the firm digs deeper to uncover opportunities that others miss, combining decades of underwriting experience with flexible structuring and uncompromising integrity. The result: Civitas is trusted by EB-5 investors and real estate innovators to deliver creative solutions, disciplined execution, and enduring commitment.
Civitas Capital Group
