If a new commercial enterprise (NCE) does not conduct an independent annual financial audit, it must appoint a qualified fund administrator — a licensed public accountant, attorney, broker-dealer, or investment advisor registered with the Securities and Exchange Commission. As a designated co-signatory on the investment project's bank account, the administrator approves all advances of EB-5 funds to the project, ensuring compliance with regulatory requirements and investment terms. Other responsibilities include: handling client inquiries; adhering to anti-money laundering requirements; issuing financial reports to shareholders regarding the use of EB-5 funds and job creation; and processing dividend payments. Some administrators now use blockchain technology for transparent tracking of the EB-5 capital.
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