The Petitioner, a retired police colonel, proposed to provide consulting and advisory services to public and private entities on money laundering and drug trafficking, and to train teams to implement BASC (Business Alliance for Secure Commerce) standards addressing illicit financing of transnational crime.

Prong 1 — national importancenot established · dispositive

“the record does not indicate that he developed the BASC standards or that his proposed endeavor will result in significant contributions to those standards that have national or even global implications in his field”

“the Petitioner does not specify how his consultancy and advice would extend beyond individual entities to impact this cooperation or his field more broadly on a level commensurate with national importance”

“The Petitioner does not indicate that he would employ U.S. workers and he does not demonstrate how his work with individual companies would otherwise extend beyond their businesses to have substantial positive economic effects”

“Neither M-V-O- nor M-G-C- discuss the Petitioner's proposed endeavor or otherwise indicate that his training on BASC standards would extend beyond his work with individual clients to impact his field more broadly”

“our assessment of national importance does not focus on the importance of issues to a field in general”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “Neither M-V-O- nor M-G-C- discuss the Petitioner's proposed endeavor or otherwise indicate that his training on BASC standards would extend beyond his work with individual clients”

  AAO decision text
• media · discounted

  “none of the articles mention the Petitioner, or otherwise address the potential prospective impact of his proposed endeavor”

  AAO decision text
• certification membership · discounted

  “the record does not indicate that he developed the BASC standards or that his proposed endeavor will result in significant contributions to those standards”

  AAO decision text
• degree · credited
• resume experience · credited

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
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Letters not independent · p1 — letters come from employers and close collaborators, not independent experts
• Local, not national scope · p1 — impact confined to clients / a region

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 L-A-C-

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