We recently encountered several inquiries from clients concerned about how high-profile security incidents involving naturalized citizens might affect their immigration applications, particularly for L-1 intracompany transfers and EB-1C multinational executive petitions. While these events understandably raise questions, from our perspective as practitioners with extensive experience handling hundreds of corporate immigration cases, the key takeaway is to focus on thorough compliance and risk management rather than worry about broad policy shifts.
Specifically, USCIS and DHS have intensified background checks and security vetting in recent years, a trend accelerated but not fundamentally changed by isolated incidents. For our client base—Chinese executives applying for L-1 or EB-1C visas—this means that preparation of evidence verifying the legitimacy of the corporate structure, employment history, and security clearances is more important than ever. For example, under 8 CFR §214.2(l)(1)(ii), the petitioner must clearly demonstrate the qualifying relationship between the foreign and U.S. entities, and failure to provide robust proof can lead to Requests for Evidence (RFEs) or denials.
In one case last quarter, a fintech client’s L-1B petition faced an unexpected RFE citing insufficient documentation of the executive’s continuous employment abroad. By promptly supplementing with detailed organizational charts, payroll records, and affidavits, we secured approval within 60 days. This underscores the need to anticipate USCIS’s heightened scrutiny and proactively compile comprehensive evidence.
In summary, this development means that clients should not delay their applications but rather enhance their petition quality and evidence. We continue to support clients through these evolving dynamics with tailored strategies to minimize risk and optimize approval chances.
