No. Their actual occupations, the work’s professional nature and the applicant’s primarily managerial duties need assessment.
Explain the jobs rather than counting degrees
Show what the employees do and what qualifications the positions require. A degree held by an employee does not automatically make every role professional.
The regulations define managerial capacity to include an employee who manages an essential function within the organization, exercises discretion over its day-to-day operations and works at a senior level in the hierarchy. Ownership may help explain the corporate relationship, but the qualifying foreign employment, the organizations' business activity, and the proposed managerial or executive role must still be independently established. Qualifying employment abroad is generally one continuous year within the relevant preceding three-year period, and the assessment looks at the work performed rather than only the final title. The first review should produce an eligibility map separating related-company proof, foreign employment, and primary U.S. managerial or executive duties.; each conclusion should point to the record that settles it. Negotiating policy or directing an essential function may support L-1A, whereas personally delivering routine sales or installation work may weigh against a role that must be primarily managerial or executive. If the subordinates are not the petitioner's employees, the case must be built as a function manager with genuine discretion over an essential function, or the structure must be changed so supervisors are on the subsidiary's payroll.