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On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) released a significant new policy memorandumPM-602-0192, titled"Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries."The memorandum implements one of the most far-reaching adjudication holds in recent years and directs immediate, agency-wide changes affecting asylum seekers and applicants from 19 countries designated as "high-risk" underPresidential Proclamation (PP) 10949, which was issued in June and banned nationals from 12 countries from entering the United States while partially restricting entry for those from seven other countries.
This new policy memorandum is one of a string of initiatives aimed at increasing national security screening and background checks in response to the shooting of National Guard members by an Afghani national last week. Other recent actions include shortening validity periods for certain employment authorization documents (EADs) and subjecting H-1B and H-4 visa applicants to social media reviews.
The impacts will be widespread: asylum applicants from every country, as well as applicants for a broad range of immigration benefits from the designated countries, will now face mandatory holds, additional vetting and in some cases mandatory interviews or re-interviews before any adjudication moves forward.
Below is a breakdown of the key changes, who is affected, and what individuals and employers should expect:
- A Complete Hold on All Pending Asylum Applications
Effective immediately, every pending Form I-589 asylum application, regardless of the applicant's nationality, is placed on hold.
USCIS states that this halt is necessary to allow the agency to conduct a comprehensive review of its screening, vetting, and adjudication procedures. No asylum case currently pending with USCIS will move forward until further notice, unless specifically authorized by the USCIS Director.
The agency has not indicated a projected timeline for lifting the hold.
- A Hold on All Pending USCIS Benefits for Nationals of 19 High-Risk Countries
USCIS also ordered an immediate adjudication hold on all pending benefit requests filed by individuals who list one of the 19 countries identified in PP 10949 as their country of birth or citizenship, including cases already in line for approval.
These benefit types include, but are not limited to:
- Form I-485(Adjustment of Status/Green Card applications)
- Form I-90(Green Card renewal/replacement)
- Form N-470(Preserving residence for naturalization)
- Form I-751(Removal of conditions)
- Form I-131(Advance parole/travel documents)
Importantly, this hold applies regardless of when the individual entered the United States, unless later modified by the Director. This does not apply to certain screening procedures, such as credible fear or reasonable fear determinations.
The current 19 countries affected are the following countries deemed "high risk" under the President's June travel ban (PP 10949). However, as recently as this morning, December 5, Secretary Noemannouncedthat the travel ban would soon be extended to nationals of more than 30 countries. She indicated that there is no fixed number of countries that will be subject to the ban, and the list continues to be under review. Today's announcement comes days after Secretary Noemstatedon social media that she would be recommending a full travel ban "on every damn country that's been flooding our nation with killers, leeches, and entitlement junkies."
Countries with FULL Suspension of Entry (Immigrant + Nonimmigrant) under PP 10949 include:
- Afghanistan
- Burma (Myanmar)
- Chad
- Republic of the Congo
- Equatorial Guinea
- Eritrea
- Haiti
- Iran
- Libya
- Somalia
- Sudan
- Yemen
Countries with PARTIAL Suspension of Entry under PP 10949 include:
(Immigrants + B-1, B-2, B-1/B-2, F, M, J visa holders only)
- Burundi
- Cuba
- Laos
- Sierra Leone
- Togo
- Turkmenistan
- Venezuela
- Mandatory Re-Review and Possible Re-Interview for Previously Approved Cases
Perhaps the most consequential aspect of the memo is its retroactive reach. USCIS will conduct a comprehensive re-review of already-approved immigration benefits for nationals of the 19 high-risk countries who entered the U.S. on or after January 20, 2021. This includes those admitted, inspected, paroled, or those who entered without inspection.
Key points:
- All individuals in this group must undergo a new security and eligibility review.
- Interviews cannot be waived.
- Even if a past benefit did not require an interview, USCIS may now require the applicant to appear.
- If concerning information is discovered, cases may be referred to ICE or other law enforcement agencies.
USCIS also reserves the discretion to extend this process to individuals who entered before January 20, 2021.
- Focus on Security Vetting and Identity Verification
The memo requires adjudicators to assess whether affected applicants:
- Are listed in the Terrorist Screening Dataset (TSDS)
- Are associated with activity described in INA §§ 212(a)(3) or 237(a)(4)
- Are linked to conduct posing "serious harm" under criminal or security-related grounds of inadmissibility
- Cannot establish identity to the standards of PP 10949
This signals a heightened scrutiny of identity, background checks, and national-security-related inadmissibility grounds.
- Delays Are Expected—And USCIS Acknowledges Them
USCIS openly states that these actions will cause significant delays but asserts that the security risks outweigh the operational burden and impact on applicants. The memorandum remains in effect until rescinded by the USCIS Director.
- What Applicants and Employers Should Expect
Nationals of the 19 PP 10949 Countries
- Expect a freeze on nearly all pending USCIS benefits.
- Expect requests for additional evidence, interviews or re-interviews.
- Naturalization-related filings and green card renewals are included in the hold.
Employers
- Foreign national employees from the 19 listed countries may see delays in adjustment of status, employment authorization extensions tied to I-485s and other immigration benefits.
- This may impact onboarding, continued employment, or travel planning.
Asylum Applicants
- Expect longer waits, regardless of nationality.
- Interviews will not be scheduled until the hold is lifted.
- Cases already scheduled may be postponed.
Those With Past Approvals
- Approved benefits (e.g., past adjustments, parole, or travel documents) may still be re-examined.
- Individuals may receive notices to appear for new interviews.
Conclusion
PM-602-0192 represents one of the most sweeping pauses in USCIS adjudications in nearly a decade, affecting hundreds of thousands of asylum applicants and individuals from the 19 high-risk countries listed in PP 10949, which – if expanded – may apply to individuals from more than 30 countries. While USCIS frames the policy as a national security measure, the memo expressly acknowledges that it will slow down many cases and create significant processing backlogs.
Applicants and employers should prepare for delays, heightened scrutiny, and expanded interview requirements.
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.
