- The U.S. consular bond pilot now covers additional nationalities, including Mali, Mauritania, São Tomé & Príncipe, and Tanzania, with bond obligations activated for certain B‑1/B‑2 applicants as of October 2025 additions under a 12‑month pilot window.
- Only some B‑1/B‑2 visitor visa applicants from designated countries are asked to post a refundable US visa bond of $5,000, $10,000, or $15,000, set at interview by a consular officer.
- Bonds are paid via DHS Form I‑352 through Pay.gov after consular instruction; refunds depend on timely departure and full compliance with visa terms.
- Policy rationale focuses on high‑overstay cohorts and certain citizenship‑by‑investment (CBI) countries; RBI/CBI passport holders should expect enhanced scrutiny and budget for bond amounts and timelines.
- Firms should update nationality screening, intake questions (ability to post bond), evidence-of-ties strategies, and contingency plans for refunds and travel changes.
The United States has expanded its consular bond pilot, introducing new US visa bond obligations for select B‑1/B‑2 applicants from additional countries. This move matters to residence‑by‑investment (RBI) clients and short‑term business visitors who must now plan for bond posting, stricter evidence of ties, and compliance to avoid forfeiture.
Below is a concise, practice‑ready guide for counsel and compliance teams on the consular bond pilot, with actionable checklists for intake and interview preparation.
Table of Contents
- Pilot expansion: new nationalities
- Scope and timeline (Oct 2025 additions and 12‑month pilot)
- Which applicants are affected: B‑1/B‑2 visitors
- High‑overstay cohorts
- CBI/RBI passport holders
- Bond mechanics and amounts: $5k/$10k/$15k tiers
- Consular determination
- I‑352/Pay.gov payment process
Pilot expansion: new nationalities
The State Department has added more countries to the consular bond pilot. As reported, Mali, Mauritania, São Tomé & Príncipe, and Tanzania are among the new additions listed by the U.S. as of an October announcement; affected B‑1/B‑2 applicants from these nationalities may be required to post a bond if instructed by the consular officer.
Scope and timeline (Oct 2025 additions and 12‑month pilot)
The consular bond initiative is structured as a limited-duration pilot. Official guidance describes a 12‑month pilot framework under which designated B‑1/B‑2 applicants may be asked to post refundable bonds, with consular posts implementing instructions in line with Department policy. The October 2025 update introduced additional countries to coverage, signaling continued enforcement attention to short‑term visitor compliance.
Which applicants are affected: B‑1/B‑2 visitors
The bond applies only to B‑1/B‑2 visitor visa applicants from designated countries and only when a consular officer instructs the applicant to post a bond. Not every applicant from a listed country will be required to post; the requirement is discretionary and set during the visa process. Other visa categories are not within scope of this pilot.
High‑overstay cohorts
The policy rationale centers on managing overstay risk. Public reporting links the pilot to overstay patterns, citing that nonimmigrant overstays reached an estimated 565,000 in FY2023, underscoring the enforcement focus on compliance at departure. Country‑level data points also show elevated rates in some markets—for example, Malawi's reported U.S. overstay rate at 5.27% in 2023—informing consular risk assessments and targeting.
In this context, consulates may emphasize stronger documentary evidence of home‑country ties, credible itineraries, and realistic trip duration to mitigate perceived overstay risk.
CBI/RBI passport holders
The pilot also references applicants from certain citizenship‑by‑investment (CBI) countries, particularly those with no residency requirements, as part of its risk focus. Holders of CBI passports can therefore encounter bond requirements when applying for U.S. B‑1/B‑2 visas under the pilot.
Compliance implications for RBI clients and frequent short‑term entrants include:
- Nationality screening: identify all current passports and place of habitual residence to anticipate consular treatment.
- Budgeting for bond: confirm liquidity for a potential $5k–$15k bond and timing of refund.
- Evidence of ties: strengthen documentation of residence, employment/business, assets, and family links to the home base.
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Compliance checklist for law firms (intake and case planning)
- Collect all nationalities/passports; note CBI/RBI status and residence history.
- Ask about ability to post $5k/$10k/$15k bond; discuss refund timing/risks.
- Screen for high‑overstay risk factors; ensure robust evidence of ties and detailed travel purpose.
- Build a departure‑compliance plan and document retention for refund claims.
Bond mechanics and amounts: $5k/$10k/$15k tiers
When a consular officer imposes a bond requirement, the US visa bond amount is set in one of three tiers and communicated to the applicant during processing. Payment and refund are tied to strict compliance, including timely departure.
| Bond tier | Who sets it | Refund condition | Forfeiture risk examples |
|---|---|---|---|
| $5,000 | Consular officer at B‑1/B‑2 interview | Depart on time; follow visa terms | Overstay, status violations; certain asylum filings can trigger forfeiture |
| $10,000 | Consular officer | Same refund standards | Non‑compliance risks apply |
| $15,000 | Consular officer | Refund if all conditions met | Forfeiture if conditions breached |
Consular determination
Consular officers decide whether a bond applies and at what tier during the visa process, based on State Department guidelines for the pilot. Applicants should be prepared to address purpose of travel, stay duration, and ties to their home base in the interview.
Consular preparation checklist (B‑1/B‑2 with possible bond)
- Purpose evidence: detailed business agenda or visit plan; invitation letters where applicable.
- Itinerary: expected travel dates, accommodation details, and planned activities consistent with B‑1/B‑2 rules.
- Ties to home base: employment letter or business registration; recent tax filings; property/lease; family ties.
- Financials: proof of funds for travel and ability to post bond if required.
- Compliance plan: return ticket strategy; calendar reminders; document retention for refund claims.
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I‑352/Pay.gov payment process
Do not attempt to pay a bond until the consular officer instructs you. When required, the process uses DHS Form I‑352 and the U.S. Treasury's Pay.gov portal.
Payment process steps:
- Attend your B‑1/B‑2 interview. If instructed, note the bond tier and follow the embassy/consulate's written guidance.
- Complete DHS Form I‑352 as directed and submit payment through Pay.gov only; beware of third‑party or unofficial payment requests.
- Keep all receipts and copies. Travel and comply with B‑1/B‑2 terms; depart on time to preserve refund eligibility.
- Follow refund instructions after departure, retaining proof of exit and compliance as needed.
Common pitfalls include paying before instruction, using non‑official links, and failing to document departure. These errors can delay travel or jeopardize refund prospects.
Bottom line: the expanded consular bond pilot increases scrutiny on high‑overstay cohorts, CBI/RBI passport holders, and short‑term business visitors. With sound US visa bond planning—nationality screening, budgeting, and evidence of ties—clients can minimize overstay risk and protect refunds. For cross‑border structuring or Armenia‑based residency and investment solutions that complement your mobility strategy, contact our team.
