U.S. Sen. John Cornyn has been one of the most consistent Republican defenders of the EB-5 investor visa program over the past several years — advocating for its reauthorization, intervening in its implementation, and signaling support for preserving it even amid President Donald Trump’s proposed “Gold Card” alternative.
During much of that same period, Cornyn’s daughter, Haley Cornyn, worked at Greenberg Traurig, a global law and lobbying firm that has structured billions of dollars in EB-5 investment deals and lobbied on matters related to the program.
The overlap between Cornyn’s legislative advocacy and the financial interests of his daughter’s employer raises questions about political optics and potential conflicts of interest — particularly given the scale of EB-5 activity at the firm and ongoing concerns surrounding the visa program.
Cornyn’s Record on EB-5
The EB-5 program, created in 1990, allows foreign nationals to obtain lawful permanent residency by investing $800,000 to $1,050,000 in U.S. commercial enterprises that create at least 10 full-time American jobs.
When the EB-5 Regional Center Program was set to expire in 2021, Cornyn publicly defended it on the Senate floor.
“EB-5 investments are an economic driver in Texas,” Cornyn said. “I’m a supporter of the EB-5 program… we need to strengthen this program and reauthorize it.”
He joined Sen. Chuck Grassley in offering legislation to reauthorize and reform the program, describing it as necessary to protect Texas job creators while improving integrity and oversight.
Industry trade group IIUSA publicly thanked Senators Leahy, Grassley, and Cornyn for their leadership on S. 831, stating they were the only senators to introduce legislation to reauthorize the program at that time.
In March 2022, Cornyn voted for the legislative vehicle that ultimately included the EB-5 Reform and Integrity Act of 2022, reauthorizing the regional center program through 2027.
Following the enactment of the reforms, Cornyn continued engaging in the program’s implementation. In a January 24, 2023, letter to Department of Homeland Security Secretary Alejandro Mayorkas, Cornyn called the EB-5 Reform and Integrity Act “a significant legislative accomplishment” and urged U.S. Citizenship and Immigration Services (USCIS) to interpret new sustainment requirements in a manner consistent with congressional intent.
In that letter, Cornyn expressed concern that USCIS remarks could effectively shorten the period investors must keep capital “at risk,” writing that such a reading “would be inconsistent with the text and purpose of the RIA.”
He also signed onto a bipartisan letter in 2022 — alongside Senate Majority Leader Chuck Schumer and House Judiciary Chairman Jerrold Nadler — arguing that USCIS should not require existing regional centers to undergo full redesignation, stating such a requirement “is not required under the EB-5 Reform and Integrity Act of 2022 and will put an immense burden on the agency.”
More recently, as the Trump administration floated replacing EB-5 with a $5 million “Gold Card” visa, Cornyn indicated he wanted the new program added “on top” of EB-5, not in lieu of it.
“There’s an EB-5 visa program that I’ve been working on for many years… that would be something that would be added on top, not in lieu, of the EB-5,” Cornyn said in April.
Meanwhile, Commerce Secretary Howard Lutnick described the existing EB-5 program as “full of nonsense,” “make-believe,” and “fraud” while promoting the proposed Gold Card alternative. Despite those criticisms, Cornyn has continued to signal support for preserving the existing EB-5 framework.
Taken together, the record shows sustained involvement in preserving and shaping the program.
Greenberg Traurig’s EB-5 Footprint
During much of this period, Haley Cornyn worked at Greenberg Traurig.
Greenberg Traurig’s Immigration & Compliance practice publicly describes itself as a “go-to industry leader for EB-5 applications.” According to firm materials, attorneys in its New York, New Jersey, and Philadelphia offices alone have represented clients in EB-5 matters involving close to $12 billion in deal structuring. The firm has also stated that in 2014, its EB-5 team managed more than $5 billion worth of EB-5 deals in a single year.
The firm maintains an EB-5 Insights blog and has regularly published commentary on EB-5 regulatory changes and implementation matters.
Federal lobbying disclosures show Greenberg Traurig reported lobbying activity on EB-5-related legislation, including S. 831, the EB-5 Reform and Integrity Act of 2021, on behalf of the EB-5 Investment Coalition.
In one 2022 EB-5 industry publication covering litigation over USCIS redesignation guidance, a Greenberg Traurig partner said, “We are very pleased that Congress is providing guidance to the agency on the implementation of the EB-5 legislation.”
EB-5 and “Sharia-Compliant” Investment Marketing
In addition to structuring billions in EB-5 investment deals, industry publications have discussed how certain EB-5 projects may be structured as “Sharia-compliant” investments to appeal to Muslim investors, particularly in the Middle East.
A 2023 article in EB5Investors.com titled “Are Sharia-compliant EB-5 investments a new trend?” quoted immigration attorneys explaining that some regional center projects could qualify as Sharia-compliant depending on how the investment is structured. Attorney Farah Abbas said that following the enactment of the EB-5 Reform and Integrity Act of 2022, regional centers could seek Sharia certification to expand marketing to regions that had not previously shown strong participation in the program.
Another immigration attorney, Rana Jazayerli, stated that many equity-based EB-5 projects are “very likely” already Sharia-compliant because they do not involve interest-based lending structures.
Separately, Greenberg Traurig has publicly promoted Islamic finance and Sharia-compliant investment structures in other areas of its international practice, including advising on Sukuk issuances and Islamic banking transactions.
There is no public evidence that Sen. Cornyn personally promoted or used the “Sharia-compliant” framing in reference to the EB-5 program.
2025 Texas Lobbying Registrations
In 2025, Haley Cornyn registered as a lobbyist in Texas on behalf of a range of clients, including Alibaba and Citigroup Washington Inc.
Citigroup has publicly promoted bridge financing structures associated with EB-5 regional center projects. Alibaba is a Chinese multinational technology company.
The Texas filing does not specify issue areas, and there is no public evidence in the filing itself that either client retained her specifically for EB-5 matters.
National Security and Integrity Concerns
The EB-5 program has faced scrutiny over the years.
A 2013 internal Homeland Security Investigations memorandum, later referenced publicly, raised concerns about potential abuse of the program by Iranian operatives. In 2018, the U.S. Department of Justice filed a civil forfeiture complaint seeking to seize $500,000 in EB-5 investment funds from a Chinese national whose companies had been sanctioned for supplying U.S.-origin items to Iranian entities.
According to recently released Department of State data, Chinese nationals continue to account for a large share of EB-5 visas issued annually.
More than 9,500 of the nearly 15,000 EB-5 visas issued in fiscal year 2024 went to Chinese investors, according to industry analysis of State Department data.
The 2022 Reform and Integrity Act included enhanced oversight provisions, including integrity measures and funding mechanisms designed to detect fraud and abuse.
Cornyn has consistently framed his support for EB-5 as tied to strengthening those safeguards, not weakening them.
Cornyn’s office did not respond to a request for comment before publication.