INA 212

L-1 Visa Denied

L-1 Visa Denial Lawyer

L-1 Visa Denied? Identify Whether the Problem Is the Corporate Relationship, Foreign Employment, Executive Duties, Specialized Knowledge, New Office, Petition Verification, or Inadmissibility

L-1 permits a qualifying international organization to transfer an executive or manager under L-1A, or an employee with specialized knowledge under L-1B, from a foreign operation to a related U.S. operation. An approved individual or blanket petition is a prerequisite, but petition approval does not guarantee visa issuance.

L visa cases may be refused because the foreign and U.S. entities do not have the required relationship, the one-year foreign-employment period is not established, the duties are primarily operational, specialized knowledge is not proven, a new office cannot support the proposed role, the approved petition no longer matches current facts, or the applicant has a separate fraud, criminal, security, removal, or immigration-history issue.

L-1 Eligibility Framework

The Classification Requires an International Organization, Qualifying Employment, and Qualifying U.S. Duties

A strong role cannot cure a missing corporate relationship, and a qualifying multinational structure cannot cure primarily operational duties.

Qualifying Organization

The U.S. petitioner and foreign employer generally must be the same employer or qualifying parent, branch, subsidiary, or affiliate and must satisfy the applicable doing-business requirements.

One Continuous Year Abroad

The beneficiary generally must have been employed abroad continuously for one year by a qualifying organization within the relevant three-year period before admission or petition filing, subject to applicable rules.

Qualifying Foreign Role

The foreign employment must support the requested classification and factual history. The capacity abroad and the proposed U.S. capacity need not always be identical, but both must satisfy the statutory framework.

Qualifying U.S. Role

The beneficiary must be coming to serve in executive, managerial, or specialized-knowledge capacity rather than merely perform ordinary operational work.

Temporary Transfer

L classification is nonimmigrant, but L applicants benefit from statutory dual-intent treatment and do not have to maintain a foreign residence they have no intention of abandoning.

Approved Petition

An individual petition or qualifying blanket petition must be approved, verified, and valid for the intended employment and entry.

Qualifying Corporate Relationship

Ownership and Control Must Establish the Required Parent, Branch, Subsidiary, or Affiliate Relationship

Parent and Subsidiary

Stock ownership, voting rights, operating agreements, control provisions, capitalization, and changes in ownership should establish the legal and practical relationship.

Affiliate

Affiliate relationships may arise through common ownership and control by the same parent, individual, or group in approximately the same proportions, subject to the governing rules.

Branch

A branch should be an operating division or office of the same organization rather than a separate unrelated enterprise using a similar name.

Ultimate Beneficial Ownership

When trusts, holding companies, partnerships, nominees, or layered entities are involved, trace ownership and control through every layer.

Joint Ventures

A joint venture does not automatically qualify. The documents must establish the required ownership and control relationship rather than only commercial cooperation.

Merger or Restructuring

Acquisitions, reorganizations, spin-offs, stock sales, dilution, or entity conversions can preserve or destroy the qualifying relationship and may require an amended or new petition.

Matching names are not proof of affiliation. The petition should establish legal ownership and control with formation documents, stock records, tax filings, financial statements, agreements, and a clear corporate chart.

Doing Business

The Qualifying Organization Must Conduct Regular, Systematic, and Continuous Business

Active Foreign Operation

The foreign organization should generally continue providing goods or services and remain more than a nominal entity maintained only to support immigration.

Active U.S. Operation

Except for qualifying new-office treatment, the U.S. organization should have actual business activity supported by premises, customers, contracts, payroll, financials, and operational evidence.

Ownership Alone Is Insufficient

Holding assets, maintaining registration, or owning a dormant company does not necessarily establish regular, systematic, and continuous provision of goods or services.

Separate Locations Can Qualify

The related entities do not need identical products or services, but the corporate relationship and active international organization must be established.

Changes After Approval

Closure, reduced operations, bankruptcy, sale, loss of staff, or dissolution can affect petition validity even after USCIS approval.

Public Records Must Match

Government registries, websites, tax filings, professional profiles, and corporate reports should not show that a claimed operating entity is inactive or unrelated.

One-Year Foreign Employment

The Employment Abroad Must Be Continuous, Qualifying, and Properly Timed

Relevant Three-Year Period

The petition should calculate the applicable three-year lookback carefully, including whether the beneficiary is abroad, already working for the qualifying organization in the United States, or subject to another timing rule.

Continuous Employment

Payroll, tax, social-insurance, contracts, personnel files, bank deposits, leave records, and work product should show one continuous qualifying year rather than nominal or intermittent affiliation.

Full-Time Employment

The record should establish actual employment by the qualifying foreign organization. Consulting, independent contracting, ownership alone, or part-time arrangements require careful analysis.

Trips to the United States

Brief trips may not necessarily interrupt the qualifying period, but time spent in the United States generally does not count toward the required year abroad.

Predecessor or Successor Employers

Corporate restructuring may allow continuity in some cases, but the legal relationship, transfer of employment, operations, and records should be documented.

Foreign Role Evidence

Job title alone is insufficient. Use organizational charts, subordinates, decisions, projects, specialized knowledge, performance records, and detailed duties.

L-1A Executive Capacity

The Executive Must Primarily Direct Rather Than Perform the Enterprise’s Work

Directs Management

The beneficiary should primarily direct the management of the organization or a major component or function rather than personally perform routine operational tasks.

Establishes Goals and Policies

Evidence may include strategic plans, budgets, governance, policy decisions, market entry, organizational design, capital allocation, and high-level contracting authority.

Wide Decision-Making Latitude

The executive should exercise broad discretion over significant matters, subject only to general supervision by higher executives, a board, or owners.

Receives General Supervision

Frequent detailed direction from another manager or owner may undermine an executive-capacity claim, depending on the organizational structure.

Primarily Executive Duties

Senior title, ownership, salary, and signing authority do not compensate for a duty record dominated by sales, customer work, production, administration, or technical services.

Staffing Supports the Role

Organization charts, payroll, subordinate duties, departments, contractors, and delegated functions should show who performs day-to-day operations.

L-1A Managerial Capacity

Personnel Managers and Function Managers Require Different Proof

Personnel Manager

The beneficiary may primarily manage an organization, department, subdivision, or component and supervise and control the work of qualifying professional, supervisory, or managerial employees.

Authority Over Personnel

Hiring, firing, promotion, leave, compensation, performance, discipline, and other personnel authority can support managerial capacity when exercised at the appropriate level.

Function Manager

A beneficiary may manage an essential function rather than direct subordinates, but must operate at a senior level and primarily manage the function instead of performing it.

Essential Function Defined

The petition should identify the function precisely, explain why it is core to the organization, and show the beneficiary’s authority, discretion, and management of its performance.

Operational Work Delegated

Employees, contractors, or other organizational components should perform the function’s daily work. The beneficiary should allocate resources, set policy, coordinate, and monitor results.

First-Line Supervisors

Supervising nonprofessional employees at a first-line level generally does not establish managerial capacity merely because the beneficiary may hire or fire them.

“Manage,” “Oversee,” and “Responsible For” Are Conclusions—not Duties

The record should identify decisions, frequency, percentages, subordinate roles, budgets, authority, reporting lines, policies, projects, and examples. Generic executive language often fails when the organization chart and staffing suggest that the beneficiary must perform operations personally.

L-1B Specialized Knowledge

The Knowledge Must Be Special or Advanced in Relation to the Organization

Special Knowledge

The beneficiary may possess distinct or uncommon knowledge of the petitioning organization’s products, services, research, equipment, techniques, management, or other interests and their application in international markets.

Advanced Knowledge

The beneficiary may possess knowledge or expertise in the organization’s processes and procedures that is greatly developed or further along than that ordinarily found within the organization.

Not Merely Skilled or Experienced

Length of employment, technical ability, or industry experience alone does not necessarily establish specialized knowledge. The evidence should compare the beneficiary with relevant workers.

Organization-Specific Value

Proprietary systems, uncommon combinations of knowledge, costly training, international implementation, critical client knowledge, and difficulty of replacement can be relevant.

Knowledge Need Not Be Unique

The beneficiary need not be the only employee with the knowledge, but the record should show why the knowledge satisfies the special or advanced standard.

Proposed U.S. Duties Must Use It

The U.S. role should require and apply the specialized knowledge rather than consist primarily of ordinary work that similarly situated employees could perform.

Comparative Evidence

Use workforce numbers, training duration, internal levels, certifications, projects, responsibilities, access, performance, and comparison with peers.

Training U.S. Workers

A transfer to implement systems or train personnel can support L-1B when the beneficiary’s knowledge and planned duties are documented beyond a generic trainer description.

Compensation Is Not Determinative

Salary can be relevant context but does not independently establish or disprove specialized knowledge.

Third-Party Worksites

Off-Site L-1B Placement Requires Control and Organization-Specific Work

Petitioner Control

The L petitioner should retain supervision and control over the beneficiary rather than allowing an unaffiliated client to control the work as its own employee.

Not Labor for Hire

The placement should not principally provide ordinary labor to the third party. The work should remain connected to the petitioner’s specialized product, process, service, or proprietary interest.

Detailed Contracts

Statements of work, master agreements, project plans, reporting lines, deliverables, supervision, intellectual property, and work locations should define the relationship.

Project-Specific Need

Explain why the beneficiary’s specialized knowledge is required at the client site and why the petitioner—not the client—directs the assignment.

End-Client Verification

Inconsistent client letters, missing contracts, changed locations, unknown supervisors, or vague projects may trigger §221(g) or petition concerns.

Material Changes

A new client, project, worksite, employer structure, or substantially changed duties may require petition review before visa issuance or admission.

L-1A New Office

A New Office Must Be Positioned to Support an Executive or Manager Within One Year

Sufficient Physical Premises

The petitioner should secure premises appropriate to the business model, staffing, operations, and expected growth rather than merely a mailing address.

Financial Ability

Capitalization, bank records, budgets, parent support, contracts, and projections should show ability to remunerate the beneficiary and commence doing business.

Foreign Entity Continues Doing Business

The qualifying foreign operation should remain active while the U.S. office develops.

Credible Staffing Plan

The petition should identify positions, hiring dates, wages, departments, contractors, and functions that will relieve the beneficiary from operational duties.

Business Plan and Market Evidence

Products, services, customers, competitors, pricing, licensing, premises, capitalization, projected revenue, payroll, and milestones should be specific and supportable.

Role at the End of Year One

The decisive question is whether the intended operation will support a primarily executive or managerial position within one year—not whether the beneficiary has an executive title on day one.

Limited Initial Approval

New-office L-1 approval is generally limited initially, and extension evidence must show actual progress, operations, staffing, finances, and qualifying duties.

Startup Operational Duties

Some initial involvement may occur, but a plan requiring the beneficiary to remain the primary salesperson, technician, administrator, or service provider is vulnerable.

Changed Launch Conditions

Delays, lost funding, failed contracts, smaller premises, reduced hiring, or a changed business model can undermine visa issuance or later extension even after petition approval.

Individual Versus Blanket L

The Consular Officer’s Role Differs Under the Two Procedures

Individual Petition

USCIS approves Form I-129 for the specific beneficiary. The consular officer verifies the petition and reviews identity, current petition facts, visa eligibility, and admissibility.

Approval does not prevent §221(g), verification, or return to USCIS when qualifying new derogatory information or material inconsistency arises.

Blanket Petition

USCIS approves the qualifying multinational organization’s blanket petition, but the consular officer determines whether the individual applicant and proposed role qualify under the blanket.

The applicant generally presents Form I-129S and supporting evidence and may owe the blanket L fraud-prevention fee and any other applicable statutory or reciprocity charge.

Blanket L Issues

Blanket Approval Does Not Automatically Qualify Every Employee

Organization Must Remain Eligible

The petitioner should continue satisfying the size, structure, office, commercial, and approval requirements supporting blanket eligibility.

Applicant Still Must Qualify

The individual must establish the one-year foreign employment, qualifying relationship, and qualifying managerial, executive, or specialized-knowledge-professional role.

L-1B Blanket Professional Requirement

A specialized-knowledge employee applying under a blanket generally must also qualify as a professional, making education and occupation evidence important.

Form I-129S Accuracy

Dates, entities, worksite, salary, duties, foreign role, U.S. role, petition validity, and blanket receipt information should match the DS-160 and corporate record.

Fees

The current petition-based visa application fee applies, and a principal blanket L applicant generally pays a $500 fraud-prevention fee, plus any applicable additional statutory or reciprocity fee.

Consular Refusal Under the Blanket

When the officer finds the individual unqualified, the case may be refused without invalidating the entire blanket petition. The company should preserve the precise reason.

Petition Verification and Return

USCIS Approval Does Not Guarantee the L Visa

Petition Must Be Verified

The consular post verifies the approved petition through the authorized systems and confirms validity for the applicant, employer, classification, and proposed entry.

Current Facts Must Match

Ownership, employer, worksite, role, compensation, staffing, foreign entity, business operations, and dates should remain consistent with the approved filing.

Material Change May Require New Filing

A different entity, substantially changed duties, new worksite structure, merger, reduced operations, or altered corporate relationship may require an amendment or new petition.

Qualifying Derogatory Information

New evidence unavailable to USCIS may cause the post to suspend processing and return the petition with a recommendation for review or revocation.

USCIS Reaffirmation

The petitioner may receive an opportunity to address the consular concerns through USCIS. Reaffirmation can return the case to the post, but substantial new evidence may still require further action.

Preserve the Consular Record

Record the interview, requested evidence, stated discrepancies, refusal provision, petition status, and all communications so the petitioner can answer the actual concern.

Do not file a new visa application while ignoring a returned petition. The petitioner may need to respond to USCIS, obtain reaffirmation, amend or refile the petition, or correct the underlying business and employment facts first.

Common Visa Refusal Grounds

How L Visa Cases Are Refused or Delayed

Refusal or issueWhat it may meanTypical response
INA §221(g)Petition verification, corporate documents, staffing, duties, client records, questionnaires, criminal documents, or administrative processing remains outstanding.Complete the existing case through the post’s required process and determine whether the petition remains at post or was returned.
Petition returned to USCISThe post developed qualifying information calling petition eligibility into question.Prepare for reaffirmation, NOIR, revocation, amendment, or refiling based on the actual return issue.
INA §212(a)(6)(C)(i)The government alleges a willful material misrepresentation about employment, ownership, duties, entities, prior work, travel, education, or another fact.Test the elements, correct source records, and evaluate INA §212(d)(3) where appropriate.
Other INA §212 groundsCrime, unlawful presence, removal, smuggling, health, security, sanctions, or another statutory ground applies independently of the petition.Challenge the ground, establish an exception, wait out a bar, or seek available waiver or consent relief.
Blanket applicant not qualifiedThe organization has blanket approval, but the individual does not establish the qualifying role, professional status where required, or foreign employment.Reapply only after materially strengthening the individual case or pursue an individual petition.
Petition expired or facts changedThe approved validity dates or petition facts no longer cover the intended employment and entry.Obtain an extension, amendment, or new petition before expecting issuance.
Fraud and Inconsistency Risk

Corporate and Employment Discrepancies Can Become INA §212 Issues

Inflated Executive Duties

The petition describes strategy and policy while emails, interviews, job postings, or actual staffing show sales, technical work, customer service, or administration.

False Foreign Employment

Payroll, tax, travel, company, or personnel records may not support the claimed one-year employment or may show employment by a different entity.

Undisclosed Ownership Changes

Stock sales, beneficial owners, mergers, side agreements, or control arrangements may contradict the claimed qualifying relationship.

Client Worksite Discrepancy

The applicant identifies a client supervisor, different project, unknown worksite, or duties inconsistent with the petition.

Public Profile Conflicts

LinkedIn, company websites, biographies, press releases, and filings may show a different employer, title, location, tenure, or role.

Analyze Before Conceding

An inconsistency is not automatically statutory fraud. Review the actual statement, falsity, willfulness, materiality, procurement, knowledge, translation, and documentary record.

Evidence Strategy

Build the L Case Around the Exact Eligibility Element

Corporate Relationship

Use formation records, stock registers, operating agreements, tax returns, audited statements, acquisitions, voting rights, and ultimate-ownership charts.

Doing Business

Provide contracts, invoices, customers, payroll, bank activity, tax filings, licenses, premises, employees, vendors, and work product for both organizations.

Foreign Employment

Use payroll, taxes, social insurance, personnel records, bank deposits, leave, promotion, travel, performance, and detailed duty evidence.

Organization Charts

Identify names, titles, departments, locations, reporting lines, education where relevant, employee status, vacancies, and the operational work performed below the beneficiary.

Duty Allocation

Use percentages, frequency, decisions, authority, budgets, policies, projects, subordinates, and examples rather than repeating statutory language.

Specialized-Knowledge Comparison

Compare training, access, tenure, projects, certifications, internal levels, replacement time, international experience, and similarly situated employees.

New Office

Document premises, capitalization, contracts, market, hiring, payroll, organizational growth, revenue, expenses, and how the operation will support the role within one year.

Third-Party Placement

Provide contracts, work orders, petitioner control, reporting, supervision, intellectual property, specialized need, location, and client confirmation.

Consistency Audit

Compare the petition, DS-160, résumé, public profiles, prior visas, prior petitions, I-94 records, CBP statements, and actual employment history.

Reapplication and Recovery

What Makes the Next L Visa Case Materially Stronger?

Complete §221(g)

Submit the exact corporate, employment, client, court, or questionnaire evidence requested while confirming whether the petition remains at the post.

Correct Petition Data

Resolve PIMS or petition-system errors, beneficiary details, employer names, classifications, validity dates, and amended filings.

Obtain Reaffirmation

When the petition is returned, address the consular memorandum and new evidence through USCIS rather than merely repeating the visa application.

Amend or Refile

Use a new petition when ownership, employer, worksite, duties, corporate structure, business stage, or other material facts have changed.

Strengthen the Role Evidence

Add staffing, operational delegation, decision examples, comparative knowledge evidence, contracts, work product, and updated organization charts.

Use Individual Petition After Blanket Refusal

An individual petition may provide USCIS review of a complex role, but it should resolve—not merely repackage—the weakness identified under the blanket.

Correct Prior Statements

Explain inaccurate employment, duty, ownership, education, worksite, or travel answers. Silent changes can deepen credibility concerns.

Resolve INA §212

Obtain criminal, CBP, court, medical, or other records and evaluate record correction, exceptions, waiting periods, or INA §212(d)(3) relief.

Consider Another Category

E-2, O-1, H-1B, B-1, EB-1C, EB-1A, EB-2 NIW, or another route may fit when the L relationship, foreign employment, or duties cannot be established.

Dual Intent and Maximum Stay

Immigrant Plans Are Permitted, but L Status Has Time Limits

Dual Intent

L applicants are not subject to the ordinary §214(b) requirement to maintain a foreign residence they do not intend to abandon and may pursue permanent residence while maintaining L eligibility.

L-1A Maximum Period

The general maximum period in L-1A classification is seven years, subject to recapture, intermittent-employment exceptions, and other applicable rules.

L-1B Maximum Period

The general maximum period in L-1B classification is five years, subject to applicable recapture and exception rules.

Time in H or L May Combine

Prior periods in related H or L classifications can affect the remaining maximum stay and should be calculated before filing or travel.

Intermittent Employment

Certain employees who reside abroad and work in the United States only intermittently may qualify for an exception, but the facts and family residence require careful documentation.

Permanent Route

A qualifying L-1A executive or manager may have an EB-1C pathway, but the immigrant petition has separate corporate, employment, and permanent-position requirements.

Current Consular Procedure

Application Location, Fees, and Petition Timing Affect the Visa Case

Country of Nationality or Residence

Current Department guidance generally directs nonimmigrant applicants to apply in the country of nationality or residence, or at the designated processing post for the applicant’s nationality.

Residence Must Be Demonstrated

An applicant filing based on residence should be prepared to establish it. Third-country processing may be more difficult and involve longer appointment waits.

Current MRV Fee

The Department currently lists a $205 nonimmigrant visa application fee for petition-based temporary-worker categories including L.

Blanket Fraud Fee

A principal applicant under an L blanket generally pays a $500 fraud-prevention and detection fee, with possible additional statutory and reciprocity charges.

Petition Validity

Confirm approval dates, intended entry, employer, worksite, classification, maximum stay, passport validity, and whether the petition remains valid after corporate changes.

Administrative Processing

Corporate, petition, identity, security, technology, criminal, sanctions, and prior immigration information may require additional review after interview.

L-2 Family and Admission

Visa Issuance Does Not End the Compliance Analysis

Spouse and Children

A qualifying spouse and unmarried children under 21 may seek L-2 classification to accompany or join the principal.

L-2 Spouse Employment

An L-2 spouse admitted with the proper L-2S notation is generally employment authorized incident to status under current DHS rules.

Children Do Not Receive Work Authorization

L-2 children may study but generally are not employment authorized solely through derivative status.

CBP Admission

A visa permits travel to seek admission. CBP independently reviews petition validity, employer, duties, worksite, admissibility, and classification.

Review the I-94

The electronic I-94 controls the classification and authorized stay. Confirm L-1A, L-1B, L-2S, or L-2 notation and expiration after every entry.

Maintain Petition Compliance

The beneficiary should work for the authorized qualifying organization in the approved role and address material corporate, worksite, or duty changes before they create status or travel problems.

Strategy

Seven Steps After an L-1 Visa Denial

Identify the precise procedural posture

Determine whether the case is under §221(g), remains at post, was refused under INA §212, or was returned to USCIS.

Audit the qualifying relationship and doing business

Trace ownership and control and prove active foreign and U.S. operations through current corporate and commercial evidence.

Verify the one-year foreign employment

Calculate the qualifying period and assemble payroll, tax, personnel, travel, and duty evidence.

Rebuild the qualifying role

For L-1A, distinguish high-level management from operations. For L-1B, prove special or advanced knowledge comparatively.

Address new-office or client-site vulnerabilities

Prove premises, funding, staffing, year-one support, petitioner control, contracts, worksite, and specialized project need.

Resolve petition and admissibility issues

Complete §221(g), obtain reaffirmation, amend or refile, correct records, or address fraud, crime, removal, security, and waiver questions.

Prepare one consistent filing and interview record

The petition, DS-160, résumé, public profiles, employer records, interview, travel history, and CBP explanation should describe the same employment.

Frequently Asked Questions

L-1 Visa Denial FAQ

Why was my L-1 visa denied after USCIS approved the petition?

Petition approval does not guarantee visa issuance. The consulate may require verification, identify changed facts or new evidence, question individual blanket eligibility, conduct administrative processing, or find a separate INA §212 issue.

Can a consular officer overturn an approved L-1 petition?

The consular officer does not ordinarily revoke the petition directly but may suspend visa processing and return an individual petition to USCIS with qualifying new information for reaffirmation or revocation review.

What is the one-year foreign-employment requirement?

The beneficiary generally must have worked abroad continuously for one year for a qualifying organization within the relevant three-year period. The precise calculation depends on the person’s location and immigration history.

What is the difference between L-1A and L-1B?

L-1A covers qualifying executives and managers. L-1B covers employees with special or advanced knowledge of the organization and a U.S. role that uses that knowledge.

Can a small company support an L-1A manager?

Possibly, but the company must show that the beneficiary primarily manages or directs rather than personally performs operational work. Staffing, contractors, business nature, and function-manager evidence matter.

What is a function manager?

A function manager manages an essential function at a senior level without necessarily supervising employees. The beneficiary must manage the function rather than perform its day-to-day work.

What qualifies as specialized knowledge for L-1B?

The beneficiary must possess special knowledge of the organization’s interests and application in international markets, advanced knowledge of its processes and procedures, or both. Ordinary skill or industry experience is insufficient by itself.

Can an L-1B employee work at a client site?

Potentially, if the petitioner retains control and the placement is principally connected to the petitioner’s specialized product, process, or service rather than ordinary labor for hire.

Why are L-1 new-office cases difficult?

The petitioner must show suitable premises, active foreign operations, sufficient financing, a credible business and staffing plan, and that the U.S. operation will support an executive or managerial role within one year.

What is the difference between individual and blanket L petitions?

An individual petition is approved for a specific beneficiary. A blanket petition qualifies the organization, but the consular officer still decides whether the individual applicant and proposed role satisfy blanket L requirements.

Can INA §212(d)(3) waive an L visa problem?

It may waive many statutory inadmissibility grounds temporarily, but it cannot cure a missing qualifying relationship, invalid petition, insufficient foreign employment, unqualified duties, or incomplete §221(g) processing.

Does an L visa guarantee entry or employment authorization?

No. CBP independently decides admission, and the beneficiary may work only for the qualifying organization and within the authorized role and period shown by the petition and I-94.

National L-1 Visa Representation

Resolve the Exact Corporate, Employment, Petition, or Admissibility Issue Before Reapplying

A successful L case connects the qualifying organization, one-year foreign employment, executive or managerial duties, specialized knowledge, current petition facts, truthful applications, and admissibility. Petition approval is the beginning of consular review—not a guarantee of issuance.

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