Recent news that the Pennsylvania Turnpike Commission is looking to raise $200 million through a U.S. immigration program that gives foreign investors green cards for their investments has some questioning whether the deal gives immigrants easy access to permanent residency.

But immigration lawyers who work on these complex deals say it’s just the opposite, with the foreign investors taking the bulk of the risk and the real room for malfeasance found in the U.S. regional centers that serve as the middle man between foreign investors and U.S.-based entities looking for financing.