The official page describes the processing fee as nonrefundable, and the gift is described as due after successful vetting rather than before. The company should read the current terms for any exception and should not pay the gift ahead of the stage at which it is required.
Nonrefundable fee first; gift only after vetting
As stated on the official page checked on 2026-09-07, the US$15,000 processing fee per person is nonrefundable, and the gift—US$1 million for an individual or US$2 million under the corporate route—is presented as payable after successful vetting. The ordering matters for a Kent employer: the amount exposed if vetting fails should be the processing fee, not the gift, provided the company pays each sum only at the stage the official instructions require. A company that transfers the gift early to an intermediary or to any account not identified by the official process has no protection the program describes.
Ask, in writing and through the official channel, whether any circumstance permits a refund of the gift after payment, and record the answer. Do not compare these amounts with EB-5's investment threshold as if they were alternatives of the same kind: EB-5 capital is placed in a business and may be returned commercially, while the gift is a donation to the U.S. government.