EB-5 regional center audit preparation
Dimov Audit, an independent CPA firm, prepares centers for an EB-5 regional center audit. U.S. Citizenship and Immigration Services (USCIS) conducts the audit itself.
- Gap report with fixes. Dimov Audit reports each gap to the center with a recommended fix.
- Funds and project companies. Auditors review each fund and project company in the agreed scope.
- The center keeps its books. The center's staff make each correction.
500+
Completed audits
50
States served
AICPA
Peer-reviewed
PCAOB
On the register
EB-5 audit services for regional centers and funds
Dimov Audit works with regional centers and EB-5 fund managers to find record gaps before USCIS does. USCIS must terminate the designation of a center that refuses its audit or deliberately attempts to impede it (8 U.S.C. 1153(b)(5)(E)(vii)).
How often does USCIS run a regional center audit?
USCIS must audit each designated regional center at least once every five years under the EB-5 Reform and Integrity Act of 2022. In each audit, USCIS reviews the records the center must keep and the flow of investor capital into each project.
Site visits.
USCIS can visit a regional center no sooner than 24 hours after giving notice, and may treat a refused audit site visit as refusing the audit.
Audit standard.
Since April 23, 2024, USCIS has generally audited centers under the Yellow Book, or Generally Accepted Government Auditing Standards (GAGAS). Dimov Audit also runs Yellow Book audits, so its auditors know that standard.
EB-5 regional center sanctions
USCIS can sanction a center that fails to submit Form I-956G, its annual statement, or that knowingly submits or causes the submission of materially false information. A center that acts inconsistently with its designation faces the same sanctions, which USCIS grades by severity:
Fines.
Up to 10 percent of the total capital investors put into the funds or project companies directly involved in the violation. The center may not pay the fine from investor funds.
Suspension.
A temporary suspension from the program.
Bar or termination.
A permanent program bar for associated individuals or business entities, or termination of the center's designation.
USCIS may also use audit findings to judge whether a center keeps its designation.
How do regional centers prepare for a USCIS audit?
Centers prepare by testing their records, controls and documents. Dimov Audit offers that testing as EB-5 compliance services:
Financial record reviews.
A CPA traces investor capital from fund ledgers to bank statements.
Compliance assessments.
Auditors test the records against the EB-5 recordkeeping and annual statement rules.
Internal control evaluations.
Dimov Audit reviews how the fund approves payments, as part of its internal audit services.
Documentation checks.
The audit team matches transactions in scope to their documents and lists any gaps.
Audit readiness support.
Dimov Audit indexes the records USCIS can request and prepares staff for walkthroughs and interviews during an in-person or virtual site visit.
EB-5 audit readiness review
Book the review before USCIS sends an audit notice. Dimov Audit keeps the review confidential.
Book the readiness reviewEB-5 flow of funds and the records kept at each step
Investor
Bank record of the transfer to the fund
New commercial enterprise
(the EB-5 fund)
Fund books, ledgers and bank statements
Job-creating entity
(the project company)
Project company books, ledgers and bank statements
Capital investment project
Records of project spending
Which records must an EB-5 regional center keep?
Each regional center keeps the records behind Form I-956G for itself, its new commercial enterprises (EB-5 funds) and its job-creating entities (project companies), under the EB-5 regional center requirements.
The center files the form with an accounting of all investor capital in those entities.
Centers with records across several funds can start with the documentation check.
EB-5 fund administration or an annual fund audit
Each new commercial enterprise must retain a fund administrator under 8 U.S.C. 1153(b)(5)(Q), unless it qualifies for a waiver.
The Secretary of Homeland Security must waive that requirement for a fund that commissions an annual independent financial audit of itself or its project company. The auditor works under Generally Accepted Auditing Standards (GAAS), and the fund provides the audit to the Secretary and all its investors.
Dimov Audit performs that financial statement audit without keeping the fund's books.
EB-5 audit preparation cost
Dimov Audit sets the fee after a first look at the records, from:
Entities.The number of funds and project companies.
Years.The fiscal years under review.
Records.Whether the center has reconciled its ledgers to bank statements.
Services.The services chosen, plus any fund audit.
A center with one fund and reconciled books pays at the light end. These are the factors, not a quote.
They truly exceeded our expectations, and we'll definitely be working with them again in the future! The team impressed us with their professionalism, attention to detail, and thorough approach. They took the time to understand the business and provided clear insights that went beyond the typical audit findings.
Reviewed by George Dimov, CPA. Dimov Audit prepares EB-5 regional centers for USCIS audits and audits EB-5 fund financial statements across all 50 states. George brings 20+ years of accounting and consulting experience.
Help after a USCIS audit notice or data request
A center that already holds a notice for its regional center audit can share it in confidence. A CPA replies with the preparation work and a quote. USCIS starts the audit on the notice date and sends its request for information in the same letter.
Dimov Audit provides general information, current to November 2, 2026. Each center should check its own position with counsel and a CPA before acting.
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