This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.
The Petitioner, a compliance manager, proposed to continue working in financial compliance and anti-money laundering, though her filings shifted between working as a Compliance Manager for U.S. financial institutions and founding/leading her own AML consultancy company as CEO.
Field: financial compliance / anti-money laundering · Read the decision (uscis.gov)
EB-2 threshold — addressed
Director found Petitioner qualifies as advanced degree professional; not disputed on appeal.
Prong 1 — national importancenot established · dispositive
“The Petitioner has not provided information sufficient to illustrate how she will realize her goal of offering her expertise to companies in the United States”
“The Director determined that the Petitioner did not establish that the proposed endeavor would have impact beyond a single employer, client, or project”
“the business plan does not provide sufficient explanation for the basis of these projections”
“the relevant question is not the importance of the industry, sector, or profession in which the individual will work”
AAO decision text
How the evidence was treated
- business plan · discounted
“the business plan does not provide sufficient explanation for the basis of these projections”
AAO decision text - resume experience · ignored
- recommendation letter · ignored
- other · discounted
“the relevant question is not the importance of the industry, sector, or profession in which the individual will work”
AAO decision text
Where this case turned
- Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
- 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
- Local, not national scope · p1 — impact confined to clients / a region
Notable
Petitioner shifted her proposed endeavor between the initial filing (working as a Compliance Manager for U.S. financial institutions) and RFE response (founding/leading an AML consultancy company as CEO); AAO found this shift contributed to the endeavor being insufficiently specific, and cited the requirement that eligibility be established at time of filing under 8 C.F.R. 103.2(b)(12).
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. 103.2(b)(12)
- 8 C.F.R. 103.3
- Flores v. Garland
- Matter of L-A-C-
- USCIS Policy Manual F.5(D)(1)
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