There is no universal requirement for an intermediate personal-account stop. The evidence must show your lawful entitlement, the source of the money and its actual path into the qualifying investment. A direct trust disbursement needs a clear client ledger, authority to pay and proof of receipt; it does not avoid those requirements. Ask instead what a reviewer would be unable to answer from the file as it stands. Usually it is one of three things: where the money came from, whose it was at each step, and what the investor received in exchange. A direct disbursement changes none of those questions; it only changes how the second one is proved.
Assess the transaction that actually happened
For example, the closing lawyer may distribute sale proceeds directly to an escrow agent under your signed direction. Record both account holders and the purpose of that payment. Review whether the escrow terms and your remaining obligations support an investment or active-investment claim.
The fact that a regulated professional transmitted the wire does not establish every EB-5 element. The exchange side deserves as much attention as the source side. Capital must be at risk in a new commercial enterprise, so a document showing a guaranteed return, a redemption right exercisable at will, or repayment secured against the enterprise’s assets can undermine the whole claim.
Have the subscription documents read against that requirement before the money moves, since a signed guarantee is not easily unsigned.