How does a bank provide escrow services in the EB-5 program?

There are no special registration requirements for a bank to participate in the EB-5 program as an escrow holder.

Your bank can set up an escrow account for EB-5 investors. A law firm which has experience with EB-5 escrow accounts can assist in advising you of best practices and how the EB-5 process operates.

As far as I know, if you are a duly licensed bank you may hold escrow funds for EB-5. The EB-5 program has no special forms or requirements for the bank.

Escrow is one of those aspects of EB-5 that is not a requirement, but is commonly used. In years past, when I-526 petitions took just a few months to get approved; money was held in escrow until the approval. This allowed for investors to comply with the "money invested or in the process of being invested" requirement. Today, escrow accounts are used to hold money until the filing of completion of subscription procedures (and still, in some cases, until I-526 approval). From my understanding, other than an escrow agreement that should be reviewed by immigration counsel, there are no special registration requirements to be an escrow agent for EB-5 deals.