The Gold Card

9/19/2025

Action Summary

  • Purpose: Reverse prior administration’s immigration policies that allowed unchecked illegal entry, compromising public safety, national security, and the rule of law; realign federal immigration policy to prioritize individuals who benefit the Nation.
  • The Gold Card Program:
    • Objective: Expedite immigrant visas for aliens who make a significant financial gift to the United States.
    • Criteria: $1 million donation by an individual or $2 million by a corporation/similar entity.
    • Benefits: Gift treated as evidence for eligibility under exceptional business ability, national benefit, and national-interest waiver provisions.
  • Implementation Measures:
    • Establish an application process and expedited adjudication for visa issuance and status adjustment.
    • Define the timeline for when gift submissions may begin.
    • Create procedures for transferring Gold Card status for those sponsored by corporations or similar entities.
    • Set up administrative fees for expedited processing and maintenance/transfer fees for corporate sponsors.
    • Consider expanding program eligibility under additional visa categories.
  • Financial Management: Gifts are to be deposited into a separate Treasury fund managed by the Department of Commerce and used to promote commerce and American industry.
  • Legal Provisions:
    • Severability: If any provision is found invalid, the remainder of the order remains effective.
    • General Provisions: Ensure that the order does not impair the authority of executive departments or agencies; implementation subject to appropriations and applicable law.
    • No enforceable rights are created for any party against the United States or its officials.
    • The cost for publication of the order is assigned to the Department of Commerce.

Risks & Considerations

  • The introduction of the Gold Card visa program could lead to increased scrutiny and potential changes in immigration policy, which may affect international students and faculty at Vanderbilt University. This could impact the university’s ability to attract and retain top talent from abroad.
  • The focus on financial contributions as a criterion for immigration may shift the landscape of international collaboration and partnerships, potentially affecting research funding and opportunities for joint ventures with foreign institutions.
  • There is a risk that the expedited visa process for wealthy individuals could create perceptions of inequality and favoritism, which may affect the university’s reputation and its commitment to diversity and inclusion.
  • The implementation of this program may lead to changes in federal funding priorities, which could impact grants and financial support for research and development at Vanderbilt University.

Impacted Programs

  • Vanderbilt’s International Student and Scholar Services may need to adjust its support and advisory services to accommodate changes in immigration policy and ensure compliance with new regulations.
  • The Office of Research might need to explore new funding avenues and partnerships to mitigate potential impacts on research funding due to shifts in federal priorities.
  • Vanderbilt’s Business School could see opportunities to engage with international entrepreneurs and investors who are part of the Gold Card program, potentially leading to new collaborations and initiatives.
  • The Office of Diversity and Inclusion may need to address concerns related to equity and access, ensuring that the university’s values are upheld in light of the new immigration policies.

Financial Impact

  • The Gold Card program’s emphasis on financial contributions could lead to increased competition for resources and funding, potentially affecting Vanderbilt’s financial aid strategies and scholarship offerings.
  • Changes in immigration policy may influence the demographics of the student body, impacting tuition revenue and the allocation of financial aid resources.
  • Vanderbilt University might need to invest in additional resources to support international students and faculty affected by the new visa program, including legal and advisory services.
  • There may be opportunities for Vanderbilt to engage with wealthy international donors and investors through the Gold Card program, potentially leading to new funding and development initiatives.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of programs.)

Key Actions

  • Vanderbilt’s Office of Federal Relations should monitor the implementation of the Gold Card visa program to assess potential impacts on international student recruitment and partnerships. Understanding the criteria and processes involved can help the university align its strategies to attract talented international students and researchers who may benefit from this program.
  • Vanderbilt’s Business School could explore opportunities to engage with international entrepreneurs and investors who qualify for the Gold Card program. By offering specialized programs or partnerships, the university can enhance its global business network and attract high-caliber individuals to its academic and research initiatives.
  • The Office of International Student and Scholar Services should prepare to provide guidance and support to potential Gold Card applicants within the Vanderbilt community. This includes understanding the expedited visa process and assisting eligible individuals in navigating the application requirements.
  • Vanderbilt’s Development and Alumni Relations could consider leveraging the Gold Card program to engage with international alumni and donors. By highlighting the program’s benefits, the university can encourage philanthropic contributions that align with the program’s objectives and support Vanderbilt’s mission.

Opportunities

  • The Gold Card program presents an opportunity for Vanderbilt’s Innovation Center to collaborate with international entrepreneurs and investors. By fostering innovation and entrepreneurship, the center can attract global talent and investment, enhancing Vanderbilt’s reputation as a hub for cutting-edge research and development.
  • Vanderbilt can capitalize on the Gold Card program by developing new academic and research partnerships with international institutions and businesses. This could include joint ventures, exchange programs, and collaborative research projects that leverage the expertise and resources of Gold Card holders.
  • The emphasis on attracting individuals who contribute to national interests aligns with Vanderbilt’s commitment to impactful research and education. The university can position itself as a leader in addressing global challenges by engaging with Gold Card holders who bring unique skills and perspectives to its academic community.

Relevance Score: 3 (The Gold Card program requires some adjustments to processes and procedures to align with new opportunities for international engagement and collaboration.)

Average Relevance Score: 3.2

Timeline for Implementation

Within 90 days of September 19, 2025, to implement the Gold Card program.

Relevance Score: 2

Impacted Government Organizations

  • Department of Commerce: Oversees the Gold Card program, manages the collection and allocation of significant financial gifts to promote commerce and American industry, and is responsible for depositing contributions into a dedicated Treasury fund.
  • Department of State: Collaborates in the expedited adjudication of visa applications under the Gold Card program and reviews eligibility as evidence of exceptional business ability and national benefit.
  • Department of Homeland Security: Works with the Department of State in processing and screening visa applications to ensure public safety and national security while facilitating expedited visa adjudication for Gold Card applicants.
  • Department of the Treasury: Receives and manages the deposits from the Gold Card financial contributions, channeling funds to promote commerce and support the statutory objectives of the Department of Commerce.

Relevance Score: 2 (A moderate number of Federal Agencies—four in total—are directly implicated in implementing and administering the Gold Card program.)

Responsible Officials

  • Secretary of Commerce – Responsible for establishing and implementing the Gold Card visa program, including setting up the application process, depositing donated funds into a designated Treasury fund, and managing overall program compliance.
  • Secretary of State – Tasked with coordinating with the Secretary of Commerce and the Secretary of Homeland Security to expedite visa adjudication processes and apply the Gold Card gift as evidence for eligibility under immigration laws.
  • Secretary of Homeland Security – Charged with working alongside the Secretary of Commerce and the Secretary of State to ensure that the expedited adjudication process meets public safety and national security standards.

Relevance Score: 5 (Directives affect Cabinet-level officials who are responsible for critical national policy implementation).