The Petitioner, a Digital Analytics Manager at a bank, proposed to advance the financial services sector by developing advanced analytics frameworks and real-time alerting systems to improve regulatory compliance and consumer protection.

Prong 1 — national importancenot established · dispositive

“While the Petitioner's proposed endeavor may improve business operations for his current or future employers and services for their customers, he has not provided evidence demonstrating that his proposed consumer protection and banking projects would affect the U.S. financial services sector on such a scale as to rise to a level of national importance.”

“The issue here, however, is not the national importance of the profession or industry in which the individual will work; instead, we focus on the "the specific endeavor that the foreign national proposes to undertake."”

“As for the job creation and economic effects that the Petitioner asserts his proposed endeavor will offer, the record does not contain sufficient supporting evidence.”

“It is insufficient to claim an endeavor has national importance or would create a broad impact without providing evidence to substantiate such claims.”

“Here, we conclude the Petitioner has not shown that his proposed endeavor stands to sufficiently extend beyond his employer and its customers to impact his field, the financial services industry, our country's national security, or the U.S. economy more broadly at a level commensurate with national importance.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “do not contain sufficient information and explanation, nor does the record include adequate corroborating evidence”

  AAO decision text
• other · discounted

  “none of the aforementioned articles mention the Petitioner or his planned projects, or otherwise speak to the potential prospective impact of his specific proposed endeavor”

  AAO decision text
• resume experience · ignored

  “relate to the second prong of the Dhanasar framework, which "shifts the focus from the proposed endeavor to the foreign national"”

  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

Petitioner invoked the January 2022 USCIS policy update on STEM advanced-degree NIWs, but AAO held this did not relieve him of meeting the three Dhanasar prongs. AAO also addressed a professor's advisory letter that conflated importance of the petitioner's generic occupation/industry with the specific endeavor's national importance, and separately noted proposed mentorship activities did not meet national importance because impact was limited to mentees, citing Dhanasar's own teaching-activity analysis.

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.

• Flores v. Garland

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