Signaling a shift of focus toward increased enforcement, USCIS has appointed Nicolas Colucci as EB-5 chief.

Colucci comes from an executive posting at of the Department of Treasury Financial Crimes Enforcement Network (FinCEN). FinCEN’s overall mission is to increase transparency in the US financial system to detect money laundering, terrorist financing and other economic crimes. FinCEN is responsible for overseeing the terrorist financing provisions of the Patriot Act. As associate director of FinCEN’s Analysis and Liaison Division, Colucci supervised teams responsible for fusing Bank Secrecy Act data with all-source information, producing analytic evidence and tools used by federal, state, and local law enforcement, as well as the intelligence community, in conducting financial investigations.

Colucci has 17 years of experience with the federal government, all in enforcement. He arrived at FinCEN in March 2009 from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), where he served as deputy assistant director in the Office of Public and Government Affairs. While at ATF, Colucci also held positions as chief of field management staff and deputy division chief of the Firearms Programs Division.

Colucci’s background verifies that USCIS has increased attention to financial matters and the sources of EB-5 investors’ funds, including self-investors. This trend, apparent from recent government reports and USCIS officials’ comments at stakeholder meetings, will in all likelihood escalate as Colucci brings extensive experience in understanding and evaluating financial transactions. A more detailed review of I-829 applications for removal of conditional residence and the documentation of deployment of investment funds is projected.