Treat them as separate spending unless the applicable rules and the enterprise's actual accounting say otherwise. Paying a professional from the same account does not, by that fact alone, settle any part of the capital requirement. Ask each provider for a written quote so the two ledgers stay distinct.
Assess costs against the contribution actually claimed
Appraisers, customs brokers, riggers and translators all invoice separately, and totals vary too much to publish a single figure. Written professional quotes are available, so gather them before committing. Where an account is labelled administrative, the label alone proves nothing about qualifying capital — what governs is the legal requirement and the documented use of the money once it reaches the enterprise.
EB-5 is a multi-stage process and the costs arrive over years. EB-5 costs arrive in three stages and should be tallied that way. Keep each vendor payment on its own line in a running log that records the purpose, the paying account and the date the invoice was settled, since a blended wire that mixes a vendor payment with the capital contribution can obscure the source-of-funds trail later. Ask the enterprise administrator to confirm in writing which internal account receives each payment, rather than assuming a single deposit covers both the contribution and incidental services. Request that vendors invoice the correct payer directly instead of routing a bill through the enterprise, so the ledger for qualifying capital never absorbs an unrelated charge.