How can we escrow the EB-5 investment after the I-526 approval?

The money will need to be invested into the project to get the I-526 approval.

EB-5 approvals are taking at least two years and USCIS wants to see the money deployed into job creating activities. Escrowing only after approval does not seem to be consistent with the focus of this program.

The project investment documents will determine this.

You can either release the money at I-526 filing or have escrow set up to release the full amount by no later than I-526 approval.

I assume you are running a project as opposed to being an investor. You should be working with an escrow agent to demonstrate you have proper release procedures for the funds that also meet your record keeping requirements for the EB-5 program. In order to avoid being afoul of investment adviser regulation, your investments should be limited to money market instruments under Section 2(a)(51) of the Investment Company Act. If you wish to have a more complex cash management program that meets certain duration objectives, you should speak with a professional institutional bond management firm directly to do these things. You also need to be sensitive to tax issues, which may well complicate things.