Yes, but politics, and the Iranian Transaction Regulations make investing by Iranians in the EB-5 Program difficult -- not impossible. Iranians and the Regional Center, generally, must apply for OFAC licenses before funds are transferred from Iran. OFAC is the Office of Foreign Assets Control of the U.S. Treasury Department. There is a list of prohibited banks in an annex to the Iranian Transactions Regulations. Money from those prohibited banks may not be transferred to the United States for any reason, not just for investment through the EB-5 Program.
Yes. Iranian citizens are eligible for the EB-5 program, however all Iranians bringing investment capital from Iran must have an OFAC license.