Does the L-1 apply to workers who provide services to external clients?

As a general rule, no. The L-1 was created for the internal transfer of executives, managers, and professionals with specialized knowledge within the same multinational organization, from an overseas unit to an affiliated entity in the United States. The essence of the visa is movement within the corporate group itself.

For this reason, it is not intended for situations where the employee is, in practice, placed to provide services to external clients, under the control and direction of a third party outside the group. When the work becomes, in essence, labor for another company, it falls outside the intracompany transfer logic that underpins the L-1.

The legitimate focus of the L-1 is to strengthen and expand the company’s own internal operations in the U.S., with the professional remaining tied to the parent company or an affiliate. The employment relationship and subordination must stay within the group.

• The L-1 covers internal movement within the same corporate group.
• It was not designed to place the employee in service of an external client.
• The employment relationship and control must remain with the transferring company.

Since each arrangement has its own particularities, especially when work is performed at a third-party location, it is worth analyzing the placement structure with a specialist and verifying updated requirements on the USCIS website before filing.

About the author

Victoria Harper

Editor-in-Chief

Meet the author

As a journalist and lead editor at Visto n’ Visa, Victoria helps ensure that immigration topics are covered in a clear, trustworthy, and easy-to-understand way. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.