Anshoo R. Sethi pitched investors that they would be financing construction of the "World's First Zero Carbon Emission Platinum LEED certified" hotel and conference center near Chicago's O'Hare Airport. Sethi told investors that their funding would help build "a convention center and hotel complex, including convention and meeting space, five upscale hotels, and amenities including restaurants, lounges, bars, and entertainment facilities."

Unfortunately, many of Sethi's claims were outright lies. Sethi falsely told investors that three major hotel chains—Hyatt, Intercontinental Hotel Group, and Starwood Hotels—were involved in the project. He also provided falsified documents to U.S. Customs and Immigration Services in initial attempts to secure the agency's preliminary approval of the project and investors’ provisional visas. Further, Sethi misrepresented to investors that he had "over fifteen years of experience in real estate development and management, specifically in the lodging area," experience which would require that Sethi started developing real estate when he was fourteen years of age.

Sethi collected a minimum of $500,000 plus a $41,500 "administrative fee" per investor. Sethi spent more than 90% of the administrative fees and directed more than $2.5 million of investors' funds to his personal bank account.

Despite returning $146 million after the SEC filed suit against him, Sethi lost over $10 million of investors' money. Some of that money was spent on expenses completely unrelated to the EB-5 program, such as cosmetic surgery for Sethi's girlfriend.