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USCIS, May 5, 2020
"This policy memorandum (PM) designates the attached decision of the Administrative Appeals Office (AAO) in Matter of F-M- Co. as an Adopted Decision. Accordingly, this adopted decision establishes policy guidance that applies and shall be used to guide determinations by all U.S. Citizenship and Immigration Services (USCIS) employees. USCIS personnel are directed to follow the reasoning in this decision in similar cases. Matter of F-M- Co. clarifies that for first preference multinational executives or managers, a petitioner must have a qualifying relationship with the beneficiary’s foreign employer at the time the petition is filed and must maintain that relationship until the petition is adjudicated. Matter of F-M- Co. also clarifies that in the event a corporate restructuring affecting the foreign entity occurs prior to the filing of the petition, a petitioner may establish that the beneficiary’s qualifying foreign employer continues to exist and do business through a valid successor entity."