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On December 2, 2025, USCIS issued a Policy Memorandum (PM-602-0192) in response to the shootings of two National Guard members last week in Washington, D.C. USCIS has placed a hold on immigration benefits for individuals from high-risk countries designated in the Presidential Proclamation 10949 (June 2025 travel ban), Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, issued on June 4, 2025. Those countries are Afghanistan, Burma, Burundi, Chad, Republic of Congo, Cuba, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela, and Yemen. As detailed below, the hold on pending immigration benefit requests in USCIS's Policy Memorandum is broader than the June 2025 travel ban in that it covers foreign nationals based on both country of birth and country of citizenship.
Specifically, the USCIS Memorandum instructs USCIS personnel to:
- Place a hold on pending immigration benefit requests for foreign nationals who were born in or are a citizen of one of the 19 countries listed in President Trump's June 2025 travel ban;
- Place a hold on all Forms I-589 applications for Asylum and Withholding of Removal, regardless of the foreign national's place of birth or citizenship pending a comprehensive review; and
- Conduct a comprehensive re-review of approved immigration benefits for foreign nationals from one of the 19 countries in the June 2025 travel ban who entered the United States on or after January 20, 2021.
What This Means:
The USCIS will pause the adjudication of the following applications filed by individuals from the impacted countries:
- Form I-485 (Application to Register Permanent Residence or Adjust Status)
- Form I-90 (Application to Replace Permanent Resident Card (Green Card))
- Form N-470 (Application to Preserve Residence for Naturalization Purposes)
- Form I-751, (Petition to Remove Conditions on Residence)
- Form I-131 (Application for Travel Documents, Parole Documents, and Arrival/Departure Records).
This list is not exhaustive, and the hold may apply to other applications such as I-129 petitions on behalf of foreign workers.
The intended purpose of the holds and re-review of immigration benefits requests is to ensure those "who entered the United States do not pose a threat to national security or public safety." It is important for employers and individuals to be aware that pending and future applications for individuals from one of the 19 countries will likely result in adjudication delays that may require an interview or re-interview, biometrics, and/or further background checks. Moreover, previously approved applications for individuals from one of these 19 countries that will be re-reviewed may include an interview to fully assess all national security and public safety threats along with any other related grounds of inadmissibility or ineligibility.
We remind clients that the pause and re-review of immigrant benefits requests and approvals is a fluid situation that could be subject to change and additional countries may be added to the list with no notice. We will continue to monitor the situation closely and employers should consult their Pryor Cashman attorney with any questions or concerns about the latest available information.
Associate Evan D. Hey was a contributing author to this client alert.
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