USCIS (U.S. Citizenship and Immigration Services) issued a policy memorandum on December 2, 2025, and, effective immediately, directed USCIS personnel to implement the following actions:
Processing Hold: Pending benefit requests from nationals of the 19 countries in the June 2025 travel ban will be put on hold pending a comprehensive review, regardless of the individual’s entry date to the U.S.
Re-review of Approved Benefits: Immigration benefits approved for nationals from travel ban countries who entered the U.S. since January 20, 2021, will be re-reviewed.
Asylum Applications Paused: Processing of all Form I-589 applications, regardless of the applicant’s country of citizenship, is suspended.
Additional Details
- The processing hold on benefit applications (regardless of entry date) and re-review of approved benefits (for those who entered the U.S. since January 20, 2021) outlined in the memo applies explicitly to individuals who are citizens of or born in the following countries: Afghanistan, Burma, Burundi, Chad, Republic of Congo, Cuba, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela, and Yemen.
- The pause on asylum applications applies to all cases regardless of country of citizenship or country of birth.
- For all three USCIS action categories mentioned above, affected foreign nationals and their applications will be re-evaluated for eligibility and admissibility, potentially requiring an interview or re-interview. According to USCIS, these re-evaluations will prioritize identifying potential security or public safety threats and any security-related ineligibility grounds.
- The memorandum does not define the full scope of what is meant by “benefit applications.” Regarding the processing hold on pending benefit applications, footnote 4 includes:
- Form I-485 for adjustment of status,
- Form I-90 for replacing green cards,
- Form I-751 for removing conditions on permanent residency,
- Form I-131 for travel documents and advance parole, and
- Form N-470 for preserving residence for naturalization.
- Please note that this list is not exhaustive, and other benefit applications, such as applications for work authorization (I-765) and employer-sponsored petitions (H-1B, O-1, E-3, and TN) on behalf of nationals from any of the 19 listed countries, could also be impacted. At this time, we are unsure whether these additional benefit applications will be affected or if the impact will be limited to the benefit applications specified above. We are trying to learn more and will provide updates and clarifications as they become available.
- USCIS may extend the review beyond the travel ban criteria to broader birth or citizenship circumstances and/or to pre-January 20, 2021, entrants.
What to Expect Next
Affected individuals should prepare for additional scrutiny, evidence requests, and potential interviews. If you are a student or scholar who was born in or is a citizen of one of the 19 countries listed above and have questions about your pending or upcoming potential benefit applications, please get in touch with your designated OISS adviser for further guidance. We will provide updates as soon as we have them.
