Customers are only part of the evidence. Review the actual operating history, qualifying relationship, employee’s foreign year and proposed role before fixing the immigration schedule.
Assess new-office rules when relevant
A U.S. new office involves less than one year of doing business and additional L-1A requirements, including a managerial or executive foreign year, sufficient premises and support for the qualifying role within one year of approval. Initial new-office approval is limited to one year.
Update the real support plan and reassess the applicant’s actual duties. Customers on both sides show commercial activity, but the immigration standard for doing business asks whether each organization is actually operating as an employer in multiple countries, not merely whether it has buyers or an office address. Maintaining a registered office or a local agent by itself does not satisfy that standard, and neither does a customer list without evidence of ongoing operations behind it. Outside the limited new-office period, that operating requirement continues for the whole duration of the stay, so the timing question is not only about when the initial sale happens but about whether the arrangement remains a genuine ongoing operation afterward. Ask what staffing, premises, and management structure exist behind the customer relationships on each side, since evidence of real operations, not transaction volume, is what supports the classification going forward. Treat the appearance of commercial traction as a useful sign worth documenting, not as a substitute for that operating evidence.