She can, as a manager of an essential function. The test is whether she sets policy and exercises discretion over the dispatch and freight function at a senior level, not whether the people beneath her hold degrees.
Function management does not depend on the staff's credentials
The regulation defines managerial capacity in two ways: managing the organization or a department and supervising professional, supervisory or managerial staff with hiring authority, or managing an essential function at a senior level with discretion over its daily operations. A carrier's dispatch and freight-acceptance function is plainly essential, and a manager who decides which loads are taken, negotiates owner-operator contracts, sets rates and controls the function's budget is managing it, even though the dispatchers are clerical employees and the drivers are contractors. What defeats the case is a record showing that she spends most of her day dispatching loads herself; that is performing the function, not managing it.
The petition should quantify her time, list decisions made without referral upward and show a year of that work abroad in the last three years. The U.S. role must also be primarily managerial, which requires a terminal with people or a function for her to direct.