The Petitioner, an accounting and finance manager, proposed to continue providing financial management, accounting, and investment planning services to U.S. companies, including his employer, a Florida-based produce import and distribution company.

Prong 1 — national importancenot established

“merely working in the fields of accounting and finance or providing financial management services to individual U.S. companies is insufficient to establish the national importance of the proposed endeavor”

“The industry reports and articles submitted do not discuss any projected U.S. economic impact or job creation specifically attributable to the Petitioner's proposed endeavor.”

“the Petitioner has not offered sufficient information and evidence based on these recommendation letters to demonstrate the prospective impact of his proposed endeavor will rise to the level of national importance”

“Neither of the opinions focus on the Petitioner's specific endeavor and it having a potential prospective impact on the U.S. economy”

AAO decision text

Prong 2 — well positionednot established

“the letters here primarily discuss the Petitioner's contributions to his employer and his ability to provide fundamental financial management services, rather than discussing a past record of success”

“he has not shown that his academic accomplishments by themselves are sufficient to demonstrate that he is well positioned to advance his proposed endeavor”

“the letters contain conclusory statements or characterizations about the Petitioner and his work that are not sufficiently supported by specifics”

“The Petitioner's attainment of a financial manager position with a U.S. company after the filing date cannot retroactively establish eligibility”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “such attestations relate to the second prong of the Dhanasar framework”

  AAO decision text
• other · discounted

  “the advisory opinions are of little probative value as they do not meaningfully address the details of the proposed endeavor”

  AAO decision text
• resume experience · discounted

  “such evidence of his past experience and accomplishments does not rise to the level of rendering him well positioned to advance the proposed endeavor”

  AAO decision text
• certification membership · discounted
• degree · discounted

  “education is merely one factor among many that may contribute to such a finding”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• 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
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

AAO explicitly rejected the Petitioner's STEM-field argument, finding that even if accounting/finance involves mathematics, the Petitioner failed to show his endeavor related to critical and emerging technologies or national security per USCIS Policy Manual F.5(D)(2). Also notable: post-filing employment with a new company could not retroactively establish prong 2 eligibility.

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)(1)
• 8 C.F.R. 103.3
• Matter of E-M-
• Matter of L-A-C-
• Poursina v. USCIS
• USCIS Policy Manual F.5(D)(1)
• USCIS Policy Manual F.5(D)(2)

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