NOV242020_02B2203Decided 2020-11-24I-140

A finance executive and minority business coach's EB-1A appeal was dismissed after meeting only 2 of the required 3…

Dismissed Useful for: avoid these mistakes
EB-1AField: finance minority business coach
The outcome

This appeal was not successful at this stage

The appeal was dismissed because the petitioner met only two of the ten evidentiary criteria (judging and leading role), falling short of the required three. The record did not establish sustained national or international acclaim consistent with extraordinary ability.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

The petitioner, a former Finance Director at a large multinational corporation who transitioned to minority business coaching, sought EB-1A classification but satisfied only two of the ten required criteria — judging and leading role. The AAO agreed with the Director that her employer awards lacked national or international recognition in the field, the organizations she belonged to did not require outstanding achievements for membership, and the published materials submitted were about employers or events rather than about her. Her salary, while above the average for directors in her country, was not demonstrated to be 'significantly high' relative to others at the top of her field. Because the petitioner failed to meet the initial three-criterion threshold, the AAO did not conduct a final merits determination and dismissed the appeal.

What worked & what failed

What worked: Petitioner successfully established the judging criterion through performance reviews she completed for subordinate managers. She also established the leading role criterion through her Finance Director position at a well-known multinational corporation with a distinguished reputation.

What failed: Awards from her employer were internal and not publicly recognized in the finance field. Published materials were about her employer or broader events, not specifically about her or her work. Salary evidence, while showing above-average compensation, lacked the full range of comparative data needed to prove it was 'significantly high.' Membership in professional associations did not show those groups required outstanding achievements for admission.

Takeaway: For EB-1A petitions, employer-internal awards and company achievements must be clearly linked to recognition within the broader professional field — not just within the organization. Salary comparisons require peer-level data from the same country and time period, including a full distribution range, not just an average.

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

  • Petitioner successfully established the judging criterion through performance reviews she completed for subordinate managers
  • She also established the leading role criterion through her Finance Director position at a well-known multinational corporation with a distinguished reputation.

Evidence that wasn't enough alone

  • Awards from her employer were internal and not publicly recognized in the finance field
  • Published materials were about her employer or broader events, not specifically about her or her work
  • Salary evidence, while showing above-average compensation, lacked the full range of comparative data needed to prove it was 'significantly high.' Membership in professional associations did not show those groups required outstanding achievements for admission.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Lesser nationally or internationally recognized prizes or awards

Not met

RSU awards from multinational employer lacked national/international recognition in the field; service pins and certificate not awards for excellence; university GPA award not recognized at national/international level.

Membership in associations requiring outstanding achievement

Not met

None of the three associations (Controllers Group, Economists Association, Chamber of Commerce committee) were shown to require outstanding achievements as judged by recognized national or international experts.

Published material about the person

Not met

Articles were about employer events or graduation ceremonies, not about the petitioner; no circulation figures provided; radio interview lacked evidence of qualifying medium; billboards/posters did not identify or discuss her work.

Judging the work of others

Met

Performance reviews she completed for subordinate managers while serving as Finance Director satisfied this criterion; AAO agreed with Director.

Original contributions of major significance

Not met

Contributions (SOX compliance, ERP implementations, dividend approval) demonstrated importance to employer but not major significance to the broader field of finance or business coaching.

Leading or critical role for distinguished organizations

Met

Petitioner held Finance Director role at a large multinational with distinguished reputation and played critical role in financial controls and strategic advisory; AAO agreed with Director.

High salary or other significantly high remuneration

Not met

Total compensation was approximately 138% of average for directors in large companies but not shown to be 'significantly high'; comparison data incomplete and several salary surveys were not relevant to her country or time period.

How the case moved

Completed

I-140 filed

Finance executive and small business consultant specializing in minority-owned businesses

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2020-11-24

AAO decision — Dismissed

The appeal was dismissed because the petitioner met only two of the ten evidentiary criteria (judging and leading role), falling short of the required three. The record did not establish sustained national or international acclaim consistent with extraordinary ability.

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.

Authorities the office relied on
KazarianEstablished the two-step framework: first count qualifying criteria, then conduct a final merits determination of sustained national or international acclaim.
VisinscaiaSupports the Kazarian two-part review; also holds that 'contributions of major significance' means work that has significantly impacted the field.
RijalSupports the Kazarian two-part review framework.
Negro-PlumpeArticles about a show or event are not 'about' the individual performer who is merely mentioned.
Matter of PriceSalary comparison must be to others performing similar work at the top of the same field; even major-league-level performance does not automatically meet extraordinary ability standard.
GrimsonSalary must be compared to others in the same specific occupational role.
MuniSalary comparison must be to others in the same specific role and sport position.
SepulvedaClaims not raised on appeal are considered abandoned.
HristovClaims not raised on appeal to the AAO are considered abandoned.