USCIS has issued a memorandum clarifying that agents can file O-1 and P-1 petitions on behalf of clients and listing the type of evidence that is needed. The application needs to include a lot of specific details on the client’s itinerary and documentation that the agent is genuinely in that business.
The memo also notes that P-1s can be filed by US organizations who are not the employers of the P-1 applicant.