On Dec. 2, 2025, USCIS issued a policy memorandum PM-602-0192 directing officers to place an adjudicative hold on
- all pending asylum applications (Form I-589), regardless of nationality, and;
- most pending immigration benefit requests – such as green cards, adjustment of status, travel documents, naturalization, etc. – filed by nationals of 19 countries designated as "high risk," regardless of the entry date.
For nationals from above-mentioned 19 "high-risk" countries, the memorandum also mandates a comprehensive re-review of certain previously approved or pending cases if the applicant entered the United States on or after Jan. 20, 2021. This may include re-interviews, additional vetting, identity verification, or further security-based screenings.
The 19 "high risk" countries include: Afghanistan, Burma, Chad, Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.
This policy is grounded in Presidential Proclamation 10949 (June 4, 2025), Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, as known as the "travel ban," and Executive Order 14161 (Jan. 20, 2025), Protecting the United States from Foreign Terrorist and Other National Security and Public Safety Threats, both of which emphasize enhanced national security review of foreign nationals from certain jurisdictions.
Why the Administration Implemented this Policy
The Memorandum cites two recent incidents involving foreign nationals accused of planning and attempting terrorist activity after entering the United States. USCIS notes that gaps in prior screening measures necessitate a broad reassessment of individuals from certain regions.
Impact on Affected Applicants
USCIS acknowledges that the hold and re-review requirements will slow adjudications, even significantly, but asserts that the delay is justified given the national security rationale. Applicants who have pending immigration benefits request may expect delays. The Memorandum also allows USCIS to require interviews for applicants who ordinarily would not need one. Though this policy does not automatically deny applications, adjudications will not resume until USCIS completes its review and issues implementing guidance. Applicants should also be aware that identity-related issues will receive heightened scrutiny. Inability to establish identity or inconsistent documentation may independently trigger ineligibility under the Immigration and Nationality Act (INA).
Practical Considerations for Affected Applicants
Nationals of the 19 "high-risk" countries may wish to:
- Prepare for extended adjudication timelines;
- Expect possible requests for re-interviews or additional evidence;
- Ensure identity documents are complete and consistent; and
- Consult counsel before international travel, especially where advance parole or re-entry permits are on hold.
Asylum applicants of any nationality should:
- Monitor for updated operational guidance, which USCIS states will be issues within 90 days; and
- Acknowledge that no asylum applications will move forward until USCIS lifts the hold.
Takeaways
This Memorandum represents the broadest national-security-based pause on immigration benefits since the "travel ban era." USCIS states that the hold will remain in effect until lifted by a superseding directive from the USCIS director. It also emphasizes that this policy does not create individual rights or enforceable benefits. Given the scope of the pause, the enhanced security vetting it requires, and its overlap with prior travel ban, this policy may influence adjudications for a considerable period. USCIS has committed to issuing additional operational guidance within 90 days, which will determine how these reviews are implemented in practice and how quickly any movement on pending cases may resume.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
