Policy Updates

The policy emphasizes sharing information with 'trusted allies.' Given the lack of diplomatic reciprocity and data sharing between the U.S. and Iran, EB-1C applicants from Iran may face extreme delays or denials if their criminal history cannot be verified through the new DHS/DOJ integrated systems.

The fee increase raises the cost for Iranian multinational managers seeking expedited processing. While Iranian applicants may face other administrative hurdles, this specific change is a standard fee increase.

Section 2(h) continues the full suspension of entry for Iranian nationals as immigrants. While the proclamation provides a specific exception for ethnic and religious minorities facing persecution, standard EB-1C applicants are barred from entry, effectively freezing this green card category for them.

In addition to standard EB-1C requirements, Iranian applicants will likely face intensified administrative processing as USCIS vets corporate structures for compliance with broader regulatory frameworks. This will significantly delay petition outcomes.

While Iranian applicants face unique administrative processing hurdles, the I-140 fee increase is a standard adjustment. It does not specifically change the security screening or visa issuance protocols for Iranian nationals.

Despite additional vetting processes for Iranian nationals, the stay on the 2024 fee rule ensures that the base filing costs do not increase. This provides some financial predictability for their sponsoring U.S. employers.

While the US petitioner typically pays the fee, electronic systems often trigger automated sanctions screening and banking flags. This may lead to increased scrutiny or administrative delays for multinational managers transferring from entities with Iranian ties.

The increased scrutiny on EB-1C petitions will likely compound with existing administrative processing requirements for Iranian nationals. This will result in significantly longer adjudication periods for multinational manager visas.

Iranian applicants already face significant hurdles; the introduction of special agents will likely result in exhaustive investigations into corporate ownership to ensure compliance with OFAC and other security regulations, significantly slowing the EB-1C process.

While Iranian applicants face unique vetting processes, the modernization of fee payments provides a more standardized and efficient method for submitting I-140 filing fees. This helps prevent administrative delays at the point of filing.

Verifying the authenticity of an Iranian parent company is challenging for USCIS. This policy may lead to higher denial rates if the 'authenticity' of the foreign role cannot be verified through independent third-party sources or official records.

Due to the absence of diplomatic relations and existing sanctions, any perceived 'Anti-American' sentiment will be heavily penalized. This policy creates a significant qualitative barrier for the few EB-1C applicants originating from Iran.

While Iranian applicants face various vetting hurdles, the EB-1 category itself is usually current. This CSPA update ensures that if a backlog does develop, children's ages are protected sooner.

While Iranian nationals may face additional administrative processing, the I-140 fee increase is a standard update. The EB-1C pathway remains a viable route for Iranian managers, though they must now account for the higher filing costs mandated by H.R. 1.

Given the complex vetting processes often associated with certain nationalities, this guidance ensures that any derogatory information found must be disclosed to the petitioner for rebuttal.

Iranian applicants frequently undergo extended background checks (administrative processing). Indefinite I-693 validity is particularly helpful here, as these checks can often exceed the previous two-year medical validity window.

Iranian nationals often face complex administrative processing; removing the COVID-19 vaccination requirement simplifies one aspect of their Adjustment of Status. This reduces the overall documentation burden for Iranian managers seeking permanent residency.

Iranian nationals must ensure their multinational manager petitions are filed according to the new USCIS protocols. While other security-related processing may apply to Iranian nationals, this specific update is a general administrative change to filing locations.

Iranian nationals undergoing the adjustment of status process for EB-1C will face a minor delay. This administrative closure affects the final steps of the green card process, specifically for those with appointments on the closure date.

Visa Bulletin Advancement: EB-1 Rest of World (2023-10)

The Department of State advanced the EB-1 Final Action Date for Rest of World chargeability to Current in the 2023-10 bulletin. Applicants in this category can now file or have their cases adjudicated without priority date restrictions.