Potentially, but the applicant must actually manage the essential function at a senior level with the required discretion. A small team is neither automatic approval nor automatic refusal.
Identify who does the underlying work
Show how routine purchasing, data entry and supplier follow-up are performed so the proposed manager can primarily manage. Explain the function’s place in the organization and provide examples of policy or discretionary decisions. Merely calling one employee indispensable does not demonstrate managerial capacity. The corporate relationship and qualifying foreign year remain independent requirements even when the function evidence is strong.
An entity that keeps an office, a bank account and a corporate registration but supplies nothing is not doing business in the sense the rule intends, and neither is one that exists only as an agent for the American side. Personnel management is measured by the character of the employees supervised, so a general manager with a large but non-professional crew can fall outside it while a director with three analysts falls inside. The rule asks for one continuous year of qualifying employment abroad within the three years before the petition, so a break during the intended year is a problem, though a different unbroken twelve months inside the three-year window may qualify instead.