Best Practices

IIUSA Industry Best Practices

IIUSA and its members are committed to ethical business practices and our curated Best Practices documents are recommendations for all those operating in the EB-5 space to consider and heed while conducting business. These documents are reviewed from time to time by the IIUSA Best Practices Committee to be edited and updated as needed. The committee also considers new topic areas in which new Best Practices should be developed as the industry evolves.

Code of Conduct

This Code of Conduct (our “Code”) is our commitment to conduct EB-5 business with high ethical standards. Our commitment goes beyond technical Code interpretation. Where unspecific, our Code’s virtuous spirit prevails. IIUSA members and everyone working on IIUSA’s behalf, including its board of directors, officers, committee members, and employees are bound by our Code. When working with non-members, you should provide our Code and ask that they abide. Our Code is no substitute for sound judgment. When in doubt, ask: (1) Is this consistent with our Code? (2) Would I take responsibility? (3) Is this good for our EB-5 community? Be integrity’s voice. Hold each other accountable.

Best Practices for Regional Centers

The IIUSA Best Practices Committee was charged with developing a list of best practices to provide guidance to regional centers seeking to conduct business in a manner that will foster the growth and success of the EB-5 program. IIUSA believes that a set of best practices would be useful both because of the relative youth of the regional center EB-5 program and because of the complexity of the concepts and principles that govern regional center activity under the auspices of multiple government agencies and under the laws and practices of multiple countries.

Engaging with Sales Intermediaries

This document is intended to provide IIUSA members with guidance regarding best practices for engaging with intermediaries who will introduce such members’ EB-5 investment products to individual foreign investors or otherwise assist in the offer and sale of these investment products. Such intermediaries can take many forms. At one end of the spectrum, some are sophisticated, professional sales organizations, such as U.S. broker-dealers. At the opposite end of the spectrum, an IIUSA member might work with an individual contact who simply refers a friend.

Anti-Money Laundering and Customer Information Requirements

This document is intended to provide IIUSA members with guidance regarding anti-money laundering (AML), including Customer Identification (CI), best practices.

In drafting this document, the IIUSA Best Practices Committee (Committee) focused on provisions that the Committee believes are likely to be generally – but not universally – applicable to IIUSA members. The Committee recognizes that not all IIUSA members play a role in EB-5 transactions that involves, for example, evaluating customer data and/or handling funds. Accordingly, each of these provisions is labeled as a “Consideration”. The Committee encourages each IIUSA member to carefully evaluate the applicability of each Consideration to its business with the assistance of qualified counsel, if necessary.

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