Match the genuine instructions and actual payments to the relevant beneficiaries.
Keep individual records traceable within the group
Distinguish processing payments, later instructed gifts and private expenses. A company-wide total should not conceal whether a particular applicant’s required step has actually occurred.
Use a beneficiary-by-beneficiary ledger rather than a single corporate total. For each employee, retain the online application receipt, proof of the US$15,000 nonrefundable DHS processing payment, USCIS prompt, filed Form I-140G, vetting communications, and the later official gift instruction with matching transfer evidence. The program runs through EB-1 or EB-2 classification, so keep each person’s supporting eligibility and admissibility records separate as well. The individual framework describes a US$1 million gift after vetting; a corporate employee case must also document the distinct published corporate amount addressed on this page. Do not label any gift as EB-5 capital or use an investment subscription agreement to describe it. Recheck the official instructions immediately before every payment. A spreadsheet without underlying receipts and beneficiary identifiers is the usual traceability failure.
Hypothetical example: A specialty-timber exporter in the Ferland-et-Boilleau area prepares sponsorship for two employees. Its controller assigns separate reference fields to application fees, requested gifts, and private travel expenses, then reconciles each bank confirmation to one I-140G file rather than allocating an unexplained lump sum across both people.