Petitioners Charles Liu and Xin (Lisa) Wang defrauded foreign investors of nearly $27 million through use of the EB-5 Program, which incentivizes investment in "approved [U.S.] commercial enterprises" by permitting noncitizen investors in such enterprises to apply for permanent residence in the U.S. Rather than channeling the nearly $27 million into a cancer-treatment center as they represented would occur, Liu and Wang redirected nearly $20 million into "ostensible marketing expenses and salaries," and deposited "additional funds to personal accounts and to a company under Wang's control." In sum, a slim margin of investments went to the intended cancer-treatment center, and the SEC brought a civil action for violation of securities laws.