No. Length of service is context, not qualification. The knowledge has to be special to this employer’s product, service, equipment, techniques or procedures, or advanced knowledge of its processes.
Ask what would be lost if this person did not go
A useful diagnostic is to ask what the U.S. site would fail to do if a competent outside hire took the role instead. If the honest answer is that it would take a few weeks of ordinary onboarding, the claim is weak no matter how long the employee has been with the company. If the answer is that a validated in-house process, an unusual equipment configuration or a customer specification developed here would have to be reverse-engineered, the claim has substance and can be documented. Twelve years matters only insofar as it explains how the knowledge was acquired. Write the petition around the thing that is unusual about this employer, and use the service history as evidence of exposure to it rather than as the claim itself.
Hypothetical example: a precision-optics calibration specialist knows an employer's internal tolerance protocol but spends most of the proposed U.S. assignment doing routine repairs. The first review asks which task requires the company-specific knowledge and whether that task is genuinely central to the placement. It should produce a defined project, the controlled materials involved, and named witnesses who can explain the employee's unusual preparation. The company must also verify the continuous year of qualifying employment abroad in the three-year period before filing. If ordinary repair work dominates, lengthening the resume does not turn the job into a specialized-knowledge assignment.