NOT FOR PUBLICATION
MEMORANDUM*
Nguyen Chan Nguyen's petition for an EB-5 immigrant visa was denied by United States Citizenship and Immigration Services ("USCIS") because he failed to show that his qualifying investment, derived from a third-party currency swap, came from a lawful source. Nguyen and three similarly situated plaintiffs (collectively, "Nguyen") sued, alleging violations of the Administrative Procedure...
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