Qualifying for a Blanket L Status

The Blanket L classification can be a convenient option when a company has a frequent need to transfer employees from its foreign office to a US office. A Blanket L approval is continuing approval of the petitioner and listed parent, subsidiaries, branches, and affiliates as qualifying organizations for L-1 visa purposes. A Blanket L approval enables frequent users of the L-1 visa category and large corporations to obtain one approval from USCIS for all managers, executives, and specialized knowledge professionals. To be eligible for Blanket L approval, a U.S. company must meet the following criteria:

  1. All qualifying entities within the international organization must be engaged in commercial trade or services;
  2. The petitioner must have an office in the US that is engaged in business for at least one year;
  3. The petitioner must have at least three US or foreign branches, subsidiaries, or affiliates; and
  4. Within all of the qualifying entities, at least one of the following criteria must be met:
  • at least 10 L-1 approvals for managers, executives, or specialized   knowledge professionals
  • within the past 12 months;
  • US sales of at least $25 million; OR
  • US work force of at least 1,000 employees.

All managers, executives, and specialized knowledge professionals can benefit through the the Blanket L classification. Remember not all specialized knowledge employees will be eligible to use the Blanket L approval. The specialized knowledge employee has to be a professional. In US immigration terms, a professional is defined as “someone having at least a Bachelor’s degree or foreign equivalent in the area related to the job”. A specialized knowledge employee who does not have at least a Bachelor-level degree in a field related to the job will still have need to have an individual L-1 petition submitted on his/her behalf. Likewise, a specialized knowledge employee having a Bachelor’s degree in a field unrelated to the job will not be eligible to use the Blanket L category. Non professional specialized knowledge employees transferred in the last 12 months cannot be counted in determining whether there enough transfers during that time to qualify for Blanket L category.

Requesting Blanket L Status

Similar to an individual L-1 petition, Blanket L-1 approval is requested by filing Form I-129, Supplement L, and supporting documentation with the USCIS. The Blanket L petition is filed in duplicate with the USCIS Service Center having jurisdiction over the petitioner’s place where the business is conducted. Supporting documentation for the Blanket L will include documentation to evidence each of the four requirements. For most large corporations, the annual report and Form 10-K will be sufficient to evidence the active commercial trade or service business of each qualifying entity, US business in operation for at least one year, the minimum three branches/subsidiaries/affiliates around the world, and US sales revenue.

With a Blanket L petition, there is no actual need for a company support letter because the eligibility requirements can be directly shown through the supporting documentation. A letter can be included if the petitioner feels a need to explain items within the supporting documents or a letter can be used as a table of contents, guiding the USCIS officer through the supporting documents and summarizing the company’s eligibility for the Blanket L program.

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