Not on the official terms as they stood at review. EB-5 covers the investor, spouse and children under 21 with one investment; the Gold Card, per its FAQ, applies a separate fee and gift to each family member. Re-verify both before deciding.
Compare per household, not per headline
At the time of this review the official page described a processing fee of US$15,000 and a gift of US$1 million for an individual applicant, with each accompanying spouse or child under 21 subject to an additional fee and gift of the same amounts. For a family of three that is three fees and three gifts. An EB-5 investment of US$800,000 in a targeted employment area or US$1,050,000 elsewhere covers the investor, spouse and unmarried children under 21 as derivatives for one investment, plus government filing fees per person set out in the USCIS fee schedule.
The comparison is not only arithmetic: EB-5 capital is at risk but may be returned, and the investor must prove source of funds and job creation; the gift is not returned and carries no job-creation obligation. For a single applicant the Gold Card's total may be the lower figure; for a family, EB-5 usually is. Confirm current amounts on both official sources before relying on this.