Not by itself. Tenure can be part of the context, but the file still needs to identify the specific knowledge involved and connect it to the applicable legal standard through concrete evidence.
Ask what the employee actually knows that the business depends on
Identify the specific process, product, or procedure at issue and document how the employee acquired and applies that knowledge, rather than describing general loyalty or years of service as the qualifying fact.
Documentation of the system or procedures themselves, the employee's project and implementation history, internal training records, and any organizational material showing how the knowledge is distributed within the group. The legal inquiry concerns special knowledge of the company’s products, services, research, equipment, techniques, management, or other interests and their application in international markets, or advanced knowledge of company processes, not how much the employer spent on a course. The requirement is one continuous year of qualifying employment with the qualifying organization outside the United States in the three years before the petition, and a qualifying parent, branch, subsidiary or affiliate abroad may satisfy it.