No. The official transfer terms include a new DHS background check, and the new person’s applicable eligibility, admissibility and visa availability still matter.
Do not transfer an eligibility conclusion between people
The FAQ permits the prior corporate gift to serve as a basis for a new sponsorship without another US$2 million gift under its process. That financial feature is not approval of the new employee. Successful cases use EB-1 or EB-2. Preserve the actual corporate and applicant records, and avoid promising that a replacement with the same job title will necessarily receive the same decision.
A first review should produce a short eligibility map that marks facts already proved, facts needing a primary record, and facts that cannot be solved by a job title. Keep the program distinct from a conventional visa: the applicant makes the payment to the U.S. government, and the remaining immigration analysis proceeds through EB-1 or EB-2. A sponsor’s preference cannot replace the applicant’s own category evidence. Hypothetical example: a creator of educational board games assumes a corporate sponsor’s interest replaces the proof needed for the immigrant category.
The decision is to resolve any missing eligibility fact before presenting the role as settled.