Yes, provided the partnership agreement gives them the rights and duties of limited partners. USCIS accepts that level of participation as engagement in management or policy formulation; a purely passive arrangement with no rights would not qualify.
Limited-partner rights satisfy the engagement rule
Hypothetical example: The EB-5 regulations require the investor to be engaged in the new commercial enterprise through day-to-day management or through policy formulation. For investors in a regional-center project structured as a limited partnership, the regulation states that a limited partner with the rights, powers and duties normally granted under the applicable partnership statute is sufficiently engaged. Nora and Tom therefore do not need to move to the project's city or take an operating role. What they do need is a partnership agreement that actually grants those rights: voting on specified matters, access to books and records, and the ability to remove the general partner in defined circumstances. An agreement that strips limited partners of every right in exchange for a fixed return can be attacked as not meeting the engagement requirement, and also as looking more like a loan than an at-risk investment. Have the agreement read for both points before subscribing.
Hypothetical example: A family selling an independent pharmacy is considering a regional-center subscription. An opening file check should contrast the partnership agreement with the offering memorandum and identify the limited-partner rights that demonstrate policy participation. The subscription documents settle what rights are actually granted, while the economic report addresses how jobs are counted. A fixed repayment promise should be referred for legal review because it can conflict with the capital-at-risk requirement even if the project’s marketing is reassuring.