On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum, PM-602-0192, "Hold and Review of All Pending Asylum Applications and All USCIS Benefits Filed by Aliens from High-Risk Countries." The memo instructs USCIS personnel to pause, re-review and re-interview certain benefit requests. Specifically, the memo:
- Places on hold all pending immigration benefit requests for applicants who are nationals or were born in one of the 19 countries listed in President Donald Trump’s June 2025 travel ban;
- Orders re-review of already approved immigration benefit requests for nationals from these countries who entered the U.S. on or after January 20, 2021; and,
- Halts processing of all pending asylum and withholding of removal applications before USCIS.
The policy memo states that for all three of the above directives, affected foreign nationals and their applications will require case-by-case vetting to review again for benefit eligibility and national security concerns. In a footnote, the memo lists certain “benefit requests” that USCIS will pause adjudication of or revisit, including the Form I-485, Adjustment of Status Applications; Form I-90, Applications to Replace Green Cards; Form I-131, Advance Parole and Travel Document Applications; Form I-751, Applications to Preserve Residence for Naturalization; and Form N-470, Applications to Preserve Residence.
In follow-up communications and in practice, USCIS has clarified that this list is not intended to be exhaustive and that “benefit requests” to be paused additionally include the Form I-129, Petition for a Nonimmigrant Worker; Form I-539, Application to Extend or Change Nonimmigrant Status; Form I-140, Immigrant Petition for Noncitizen Worker; and Form I-765, Application for Employment Authorization.
Importantly, aside from the directive to pause adjudication of all pending asylum and withholding of removal applications, the memo applies to foreign nationals who were either (1) born in or (2) are nationals of one of the 19 countries listed in the June 2025 travel ban, which USCIS considers “high-risk”: Afghanistan, Burundi, Chad, Cuba, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Myanmar, Republic of the Congo, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela and Yemen. Inclusion in this memo of foreign nationals who were born in a country listed but may no longer hold citizenship there (i.e., “nationals”) is notably broader than the travel ban itself which only applied to nationals.
Individuals who are nationals or were born in one of the 19 listed countries should not depart the United States or apply for any benefits without first consulting with immigration counsel regarding the impact of the memo on their immigration status in the United States.
Fredrikson’s Immigration Team is closely monitoring the implementation of this policy memo and will provide further information as details become available.
