JUL102025_01B2203Decided 2025-07-10I-140

A banking and fintech executive from Uzbekistan failed to meet the minimum three evidentiary criteria for an EB-1A…

Dismissed Useful for: avoid these mistakes
EB-1AField: banking and finance, particularly as a financial technologist in the 'fintech' sectorOrigin: Uzbekistan
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to meet at least three of the required ten evidentiary criteria. He satisfied only one criterion (high salary) out of the four he claimed, falling short of the required minimum of three.

1 / 3 criteria needed Need 2 more

2 more criteria would trigger a full merits review.

In plain English

The petitioner, a Uzbekistan-based banking and fintech executive, sought EB-1A classification by claiming four evidentiary criteria. SCOPS denied the petition finding only the high salary criterion met, and the AAO affirmed on appeal. Three online articles failed the published material criterion because they lacked required author information, did not discuss the petitioner's work, or were promotional materials. Three support letters for the original contributions criterion were found conclusory and lacking specifics on broader industry impact, with one letter's foundership claim contradicted by public records. Because the petitioner met only one of the required three criteria, the AAO dismissed the appeal without reaching a final merits determination.

What worked & what failed

What worked: High salary criterion (8 C.F.R. § 204.5(h)(3)(ix)) was found met by SCOPS based on remuneration evidence and was not disturbed by the AAO.

What failed: Published material criterion failed because submitted articles lacked required author information, did not discuss the petitioner or his work, and no objective evidence showed the outlets qualified as major media. Original contributions criterion failed because support letters were conclusory, lacked specific details on broader industry impact, and no corroborating objective evidence was provided; one letter's claim that petitioner founded a company was contradicted by publicly available information.

Takeaway: For the published material criterion, petitioners must submit articles that specifically discuss them and their work, include author attribution, and provide objective circulation/readership data proving the outlet qualifies as major media. For original contributions, support letters must go beyond praise and provide concrete, verifiable details about how the petitioner's specific work influenced the broader field — and all factual claims in letters should be corroborated by independent documentary evidence.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-1A criteria.

Evidence that moved the needle

  • High salary criterion (8 C.F.R
  • § 204.5(h)(3)(ix)) was found met by SCOPS based on remuneration evidence and was not disturbed by the AAO.

Evidence that wasn't enough alone

  • Published material criterion failed because submitted articles lacked required author information, did not discuss the petitioner or his work, and no objective evidence showed the outlets qualified as major media
  • Original contributions criterion failed because support letters were conclusory, lacked specific details on broader industry impact, and no corroborating objective evidence was provided
  • one letter's claim that petitioner founded a company was contradicted by publicly available information.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Published material about the person

Not met

Three online articles failed: one did not mention the petitioner, one lacked an author and was about a company launch with only a passing mention of petitioner, and one discussed a company product without discussing the petitioner's work. No objective evidence submitted that any outlet qualified as a professional or major trade publication or major media.

Original contributions of major significance

Not met

Support letters were conclusory and lacked specific detail about the petitioner's individual contributions and their broader industry impact. One letter's claim that petitioner founded a company contradicted publicly available sources. No objective corroborating evidence of major significance beyond employer and clients in Uzbekistan.

High salary or other significantly high remuneration

Met

SCOPS found this criterion met; petitioner erroneously argued on appeal that SCOPS denied it. AAO did not disturb this finding.

Evidence that persuaded the AAO

Evidence of high salary or significantly high remuneration (criterion IX) — found sufficient by SCOPS and undisturbed by AAO

Where the evidence fell short

2017 online article: did not list an author, did not mention the petitioner or his work

2018 online article (company launch): lacked an author, only briefly mentioned petitioner in passing, characterized as promotional/marketing material

2018 online article (fraud-detecting payment system): listed an author and included petitioner's photo but discussed company product, not petitioner's individual work

2024 online articles submitted in response to RFE: filed after petition date, given no evidentiary weight

Support letter from Z-Z-: conclusory praise without specific detail on how petitioner's contributions impacted the field

Support letter from T-K-A-: lacked specifics on industry impact beyond company and clients; claim that petitioner founded the company contradicted by publicly available sources

Support letter from E-T-U-: praised petitioner as a former employee but lacked detail on broader banking industry impact

Counsel's unsubstantiated assertions that article outlets were 'reputable' and 'widely read' — statements of counsel are not evidence

Officer errors the AAO found

No legal errors found by the AAO in the lower decision; AAO affirmed SCOPS findings on criteria III and V and noted petitioner incorrectly asserted SCOPS denied criterion IX (high salary) when SCOPS had actually found it met.

How the case moved

Completed

I-140 filed

Banking and finance executive; former bank branch general manager and director of fintech companies developing electronic payment systems in Uzbekistan

Completed

SCOPS — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2025-07-10

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to meet at least three of the required ten evidentiary criteria. He satisfied only one criterion (high salary) out of the four he claimed, falling short of the required minimum of three.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

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Authorities the office relied on
8 C.F.R. § 204.5(h)(2)8 C.F.R. § 204.5(h)(3)8 C.F.R. § 204.5(h)(3)(i)-(x)8 C.F.R. § 204.5(h)(3)(iii)8 C.F.R. § 204.5(h)(3)(v)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 204.5(h)(3)(ix)8 C.F.R. §§ 103.2(b)(1)8 C.F.R. §§ 103.2(b)(12)8 C.F.R. § 103.5(a)(1)(iv)
Christo'sAAO reviews appeals de novo
ChawathePetitioner must establish eligibility by a preponderance of the evidence
KazarianEstablishes two-step review: first count qualifying criteria, then conduct final merits determination if threshold met
VisinscaiaSupports the Kazarian two-part analysis framework
RijalSupports the Kazarian two-part analysis framework
ObaigbenaStatements of counsel are not evidence and must be supported by independent evidence
JafarovTestimonial letters consisting mostly of conclusory statements about significance of work and potential are insufficient
KatigbakEligibility must be established at time of filing; actions taken after filing do not cure initial deficiency
IzummiSupports the rule that eligibility is determined at time of filing
BagamasbadAgencies are not required to reach issues unnecessary to the ultimate decision
NagaiahThe regulatory criteria establish a necessary, not sufficient, evidentiary requirement for extraordinary ability visa