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MEMORANDUM *

The Hawaii Saeronam Presbyterian Church (“HSPC”) seeks a “special immigrant religious worker” visa for its minister, Kwang Tae Kim. The California Service Center of the U.S. Citizenship and Immigration Services denied HSPC’s petition; the Administrative Appeals Office (“AAO”) dismissed HSPC’s appeal; and the district court affirmed. In this appeal, HSPC contends that it was error for the AAO to require the church to prove that Kim had worked full time as a minister during the two years immediately preceding the visa petition. HSPC further contends that, even if the AAO’s interpretation of the law is proper, the church produced sufficient evidence of Kim’s full-time employment.

Our review focuses on the AAO’s decision, which we analyze “from the same position as the district court.” W. Radio Servs. Co. v. Espy, 79 F.3d 896 , 900 (9th Cir.1996). We may reverse that decision only if it is “arbitrary, capricious, an abuse *226 of discretion, or otherwise not in accordance with law” or is “unsupported by substantial evidence.” 5 U.S.C. § 706 (2)(A), (E).

By statute, a minister may qualify for a special immigrant religious worker visa only if he (1) has been a member of…