On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum directing officers to pause and re-evaluate thousands of pending immigration benefit requests. This sweeping measure follows Presidential Proclamation 10949, which imposes restrictions on foreign nationals from 19 “high-risk” countries identified as potential national security threats.

While national security remains a top U.S. government priority, this new policy is likely to cause significant delays for affected applicants, including those who have already submitted petitions or have been granted certain immigration benefits.

What the Policy Says: Under the new guidance, USCIS officers must:

1. Pause all pending asylum applications (Form I-589), regardless of the applicant’s country of origin;

2. Place a hold on all pending immigration benefit requests for individuals from the 19 designated countries, including applications for green card renewals (Form I-90), adjustment of status (Form I-485), travel documents (Form I-131), and others;

3. Conduct a re-review of previously approved benefit requests for individuals from those same countries who entered the U.S. on or after January 20, 2021.

This policy not only affects current filings but also opens the door to re-evaluating previously approved cases. Applicants may be called for interviews or re-interviews, even in cases where an interview would typically be waived.

Who Does This Impact? This policy has far-reaching implications for individuals from the 19 countries designated in Presidential Proclamation 10949. Specifically, it affects:

• Asylum seekers with pending applications (Form I-589), regardless of nationality. All asylum applications are subject to a hold and comprehensive re-review.

• Applicants for Adjustment of Status. Conditional Permanent Residents and Permanent Residents from any of the 19 listed countries below, based on either country of citizenship or country of birth. This can include:

• Applicants with pending immigration benefit applications with USCIS that involve the use of Forms I-485, I-90, I-131, I-751, or N-470.

• Permanent and Conditional Permanent Residents who have an already approved benefit and entered the U.S. on or after January 20, 2021. These cases will be subject to re-review, and possibly a re-interview.

• Applicants who previously passed initial security checks, but whose cases are now being revisited in light of updated national security priorities. It’s important to note that even those with no history of criminal activity or national security concerns may still experience delays or be required to attend additional interviews.

• This specific policy does not impact non-immigrant holders like H-1B, L-1, O-1, etc.

USCIS has emphasized that this is a case-by-case process, but no exemptions are currently available based on personal circumstances alone.

The 19 Countries Impacted: Nationals of the following countries, whether by citizenship or place of birth, are subject to the new screening measures and adjudication holds:

1. Afghanistan

2. Myanmar (Burma)

3. Chad

4. Republic of the Congo

5. Equatorial Guinea

6. Eritrea

7. Haiti

8. Iran

9. Libya

10. Somalia

11. Sudan

12. Yemen

13. Burundi

14. Cuba

15. Laos

16. Sierra Leone

17. Togo

18. Turkmenistan

19. Venezuela

Applicants from any of these countries may experience increased scrutiny, delayed processing, or additional interview requirements as part of USCIS’s heightened security review.

What Applicants Should Expect: If you are from one of the 19 listed countries or have filed a benefit request with USCIS while residing in the U.S., you may experience:

• Extended delays in processing asylum or other immigration applications;

• Notices to appear for interviews, even if your case was initially progressing without one;

• Potential reopening or re-review of previously approved applications;

• Increased scrutiny of background, identity documents, and national security risk factors.

USCIS officers are required to conduct individualized, case-by-case reviews to determine eligibility and assess any potential risks.

Why the Policy Was Issued: The policy builds on Executive Order 14161, signed in January 2025, which aims to prevent terrorist threats and other national security risks posed by foreign actors. Recent incidents involving Afghan nationals who entered the U.S. and later carried out or attempted acts of terrorism heightened the urgency behind the policy shift. USCIS cited these cases as evidence of the need for more robust vetting processes.

The agency stated its intent to ensure that benefit applicants do not pose a threat to national security or public safety. This includes reviewing whether an applicant is listed in the Terrorist Screening Dataset, has criminal affiliations, or has failed to establish their identity in accordance with USCIS standards.

Will This Hold Be Permanent? The policy states that the adjudicative hold will remain in effect until formally lifted by the USCIS Director. Any request to lift a case-specific hold due to litigation or other urgent circumstances must receive direct approval from top USCIS leadership.

Within 90 days of the policy’s release, USCIS plans to issue further operational guidance, including prioritization criteria for which cases will be reviewed first.

Legal Considerations and Next Steps: This policy does not create any new legal rights or benefits for applicants and cannot be used to challenge a removal or denial on its own. However, it significantly changes how USCIS processes specific categories of cases. Even individuals with no criminal record or known risk factors may be impacted by processing delays or enhanced vetting.

This new USCIS policy reflects a broader federal initiative to tighten immigration screening in the interest of national security. While it does not automatically trigger denials or removals, it imposes higher scrutiny on nationals of 19 specified countries. For applicants from these regions, patience and careful preparation will be critical in navigating the months ahead.

If you or your family are affected by this policy, our firm can help you assess your options and guide you through the evolving landscape of U.S. immigration law.