Editorial note: The EB-5 Immigrant Investor Program has undergone significant legislative changes since this article was originally published, including the EB-5 Reform and Integrity Act of 2022. Investment minimums, TEA designation rules, priority date backlogs, and regional centre requirements have all changed materially. Circa Resort & Casino is now open and operational; the project details below reflect the investment prospectus as it stood at the time of writing. Verify all current EB-5 programme requirements with USCIS and consult a licensed immigration attorney before making any investment decision. Past job creation projections and programme timelines described here may not reflect current conditions.
Project Overview
Circa Resort & Casino (the "Project"), sponsored by the Pacific Casino & Entertainment Group Regional Center, was a 1.3-million-square-foot resort and casino development occupying an entire city block on the Old Downtown Strip of Las Vegas. At the time of its development, it was the first ground-up casino resort to be built in downtown Las Vegas since 1980.
The project was situated on prime frontage along the Fremont Street Experience (FSE) — one of the most visited tourist destinations in the United States, with over 19 million annual visitors. The completed development comprises 35 floors including 510 hotel rooms, 59 luxury suites, 85,000 square feet of gaming space, a two-level casino with 1,400 gaming machines and 49 tables, a 17,000-square-foot stadium-style sportsbook, a state-of-the-art rooftop pool and entertainment area featuring a 128-by-36-foot LED screen, 7,000 square feet of retail space, a health and fitness centre, and an eight-level parking garage with 1,038 spaces.
EB-5 Programme Highlights
The project received exemplar approval from the US Citizenship & Immigration Service (USCIS) on September 25, 2018 — meaning USCIS reviewed and approved the project's investment structure prior to investor applications being filed, providing an additional layer of programme certainty.
According to a Targeted Employment Area (TEA) letter issued by Impact DataSource dated November 2019, the project was located within a qualifying TEA under the EB-5 rules then in effect, meaning the minimum qualifying investment was reduced from the standard threshold.
The project's economist estimated total job creation of approximately 8,943 positions — equating to more than 80 jobs per EB-5 investor, or a 700% premium above the statutory minimum requirement of 10 jobs per investor. An interim jobs report confirmed that 2,837 jobs had already been created as of September 30, 2019, meaning the 10-job requirement for all 111 EB-5 investors in the initial tranche had already been met before additional EB-5 capital was committed.
What is the EB-5 programme?
The EB-5 Immigrant Investor Program was established by the US Congress in 1990 to stimulate economic growth through foreign direct investment and job creation. Qualifying investors and their immediate family members (spouse and unmarried children under 21) are eligible for US permanent residency (a "green card") in exchange for a qualifying capital investment in a job-creating enterprise.
The programme operates through two channels: direct investment in a business, or investment through a USCIS-designated Regional Center. Regional Center investments — such as the Circa project — pool capital from multiple investors into larger commercial developments and allow job creation to be counted across a broader economic footprint.
The EB-5 Reform and Integrity Act of 2022 made the most significant changes to the programme in three decades, including raising investment minimums, modifying TEA designation rules, and introducing new investor protections. Anyone considering an EB-5 investment should review current programme requirements with a qualified US immigration attorney before committing capital.