Updated on 13.09.2022
Our group of companies and thus also the previous German headquarters with the affiliated companies worldwide (including the USA) were bought by another group.
What happens now with the existing L-Blanket Visa of our employees? Do the visas lose their validity and have to be reissued?
In order to provide an assessment of whether the new ownership structure has any impact on the existing L-Blanket registration of your group of companies, and therefore on the existing L-Blanket visas, it would be necessary to examine exactly what has changed in detail.
Case 1:Company structure unchanged with new owner of previous headquarters
For example, if your group of companies has been acquired by another group, but the previous organizational structure otherwise remains unchanged, then this might not have any impact at all.
If it was stated in the L-Blanket registration that your German headquarters is the ultimate parent and all other listed locations are at least 50% owned by that parent and only the previous parent now has new ownership, then presumably there is no need to notify the authority (which would be tantamount to a new application in the case of L-Blanket registration), nor would anything need to be done with regard to the existing L-Visa.
Case 2: New ownership structure
However, if the new ownership structure is accompanied by more far-reaching changes, a so-called L-Blanket Registration Amendment process may need to be conducted with the USCIS to update the L-Blanket registration.
So-called "material changes" must be reported to the US authority. It would therefore be necessary to check what the organizational structure was like at the time of the last blanket registration application and what it will look like in the future or after the restructuring. Only in this way can a binding statement be made. If in fact the previous holding company is no longer the majority owner of individual listed companies, it may well be that an update would first have to be carried out or a general check would have to be made as to whether all the necessary access requirements for the continued use of the L-Blanket registration still exist.
As a first step, a thorough review of the changes associated with the acquisition must take place. Based on this, a decision must then be made as to whether a notification must be made to the USCIS for an existing L-Blanket registration (amendment), whether a new L-Blanket registration will be necessary or (worst case) whether the group of companies no longer qualifies for an L-Blanket registration.
The update or renewal of the L-Blanket registration can be quite time-consuming, depending on the scope of the previous registration. Unfortunately, this is a completely new application procedure, which can usually take about 2-4 months until the new approval of the updated L-Blanket registration.
Depending on the type of change, it can then be checked whether there are effects on existing L-blanket visas, or whether new visas are required here for the persons concerned (then on the basis of the new blanket registration). In the best case there is no need for action, but it is also possible that the L-blanket visas would have to be renewed in the consular procedure or (in case of discontinuation of an existing L-blanket registration) new L-1 individual visas would have to be submitted for all persons concerned (in the regular application procedure).
By the way: If your group of companies also has an e-registration in parallel with the L-blanket registration, it would also have to be checked here whether all access requirements are still met after the change of ownership.
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