The Petitioner, currently head of customer onboarding and KYC at a financial services company, proposed to leave that job to work independently as a KYC/AML strategies consultant and entrepreneur, developing KYC compliance strategies for the finance and banking industry and potentially the sports betting industry.

Prong 1 — national importancenot established · dispositive

“The Petitioner, however, did not clearly explain his proposed endeavor, instead providing general, broad statements.”

“the growth and importance of an industry or working in a field with an expected demand for workers are not sufficient to meet the national importance requirement”

“rather than benefiting his prospective employers and his proposed clients, the Petitioner has not demonstrated by a preponderance of the evidence that his proposed endeavor is of national importance”

“The articles submitted do not discuss his endeavor having the claimed broader impact to his field, or the claimed economic or national security impacts specifically attributable to his proposed endeavor.”

AAO decision text

How the evidence was treated

• media · discounted

  “The articles submitted do not discuss his endeavor having the claimed broader impact to his field”

  AAO decision text
• recommendation letter · discounted

  “The letters do not discuss his proposed endeavor or show its national importance, but instead relate to the second prong”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor

Notable

AAO noted the Director found the Petitioner met prong 2 but provided no explanation or analysis for that finding; AAO declined to reach prongs 2 and 3 since prong 1 failure was dispositive.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

• 8 C.F.R. 103.3
• Flores v. Garland
• INA 203(b)(2)
• Matter of E-M-

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