It could be possible, as you must be in the process of investing or have invested in the EB-5 project to qualify. Counting the required jobs that have been and will be created will be important.
The first step is to retain an experienced EB-5 attorney. We will have to determine if the winery is already in existence and to what extent is operating. Please note EB-5 funds can be committed to a new winery already in existence or a winery which is not operating and needs refurbishment. You can use the EB-5 funds for construction and/or operations if the winery but will have to show the required job creation as a result of the EB-5 investment.