USCIS Policy Memo: Hold and Review of Applications from High-Risk Countries

U.S. Department of Homeland Security U.S. Citizenship and Immigration Services www.uscis.gov U.S. Citizenship and Im migration Services Office of the Director Camp Springs, MD 20588-000 9 January 1, 2026 PM -602-0194 Policy Memorandum SUBJECT: Hold and Review o f USCIS Ben efit Applicat ions Filed by A liens from A dditional High -Risk Countries 1 Purpose Effective im mediately, t his memoran dum directs U.S. Citizen ship and Immig ration Services (USCIS) per sonnel to: 1. Place a hold 2 on all pending benefit applications, for aliens 3 listed 4 in Presidentia l Proclamation (PP) 10998, Restricting and Limiting the Entry of Foreign Nationals To Protect the Security of the United States, 5 pending a comprehensive review, regardless of entry date; 6 2. Conduct a comprehensive review of all policies, procedures, and screening and vetting processes for benefit req uests for aliens from cou ntries listed in PP 10998; and 3. Conduct a comprehensive re- review of approved benefi t requests implicated in PP 10998 that were approved on or after January 20, 2021. 1 On December 16, 2025, the P reside nt issue d Presi dential Procl amatio n (PP) 10998, Restr icting and Limiting the Entry of Forei gn Nat ionals T o Prot ect the S ecurit y of the Unite d States. Exercis ing auth ority u nder INA 2 12(f), the proclamation continu es the full restrictions and entry limitations of nationals from the origin al high - risk countries established und er PP 10949, Restricting the Entry of Foreign Nationals To Protect th e United States From Foreign Terrorist s and Othe r Natio nal Securi ty and Publ ic Safet y Threat s (June 4, 2025), and imposes restr ictions, limitations, and exce ptions on additional high - risk countrie s. Unde r INA 212(f), t he Pre sident m ay susp end or restr ict the entry o f any aliens deemed detrimental to U.S. in terests. 2 A “hold” allow s a case to proceed through processing, up to final adj udica tion. A “final adjudication” refers to the issuance of a final decision on a case, such as an approval, denial, or dismissal. 3 The term "alien" means any person not a citizen or na tional of the United States. See INA 101(a)(3) and 8 U.S.C. 1101(a)(3). 4 This refers t o alie ns with a nati onality, c ount ry of bi rth, o r aliens who ha ve acqui red Ci tizenshi p by I nvestme nt (CBI) listed in PP 10998. “ A s a n example, a foreign national from a country that is subje ct to travel restrictions could purchase CBI f rom a sec ond c ountry t hat is n ot subje ct to t ravel restrictions, obtain a pas sport in the citizenship of that second c ountry, and su bsequent ly appl y for a United States visa for travel to the United States, thus evading the travel restrict ions on his or her first countr y. ” Further, this includes aliens with varying nationalities b ut are traveling on a Palestinian - Authority - iss ued doc ument. 5 This applies to aliens who list one of th e high - risk countries as their Country of Birth or Country of Citizenship. 6 I mmigrant visas for family members of individu als in the United States will no longer be automatically or br oadly exempt from PP 10949 and PP 109 98 restrictions or requirements. F amily - bas ed immi grant vi sa ap plicat ions are now subject to the same review, restriction s, or additional scrutiny as other benefit requests.

PM-602-0194: Hold and R eview of USC IS Benefit Applica tions Filed by Aliens f rom Additiona l High -Risk Countries Page: 2 This memorandum specifies which cases are su bject to the adjudicative h old, identifie s exemptions, and outlines the factors to consider when assessing benefit eligibility during the re- review, interview, or re - intervie w of affected aliens. USCIS p ersonnel are in structed to p rioriti ze national security and public safety concerns and ensure compliance with applicable laws and regulations during the adjudication process. All findings must be documented in accordance with established protocols to support any subsequent determinations or actions. This memorandum does not supersede the guidan ce in Policy Memorandum, Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High- Risk Countries on December 1, 2025 7 except as specified un der the “Exceptions to the Adjudication Hold” outlined in this memorandum. Background On January 20, 2025, the President issued Executive Order (EO) 14161, titled Protecting the United States From Foreign Terrorist s and O ther National Security and Public Safety Threats. This order aim ed to safeguard U.S. cit izens from aliens wh o may seek to commit ter rorist acts, pose threats to national sec urity, promo te hateful id eologies, or exploit imm igration la ws for malicio us purposes. EO 14161 underscores the importance of vig ilance during the visa issuan ce process to ensure th at individuals approved for admission into the Unit ed States do not intend to harm Ameri cans or compromise U.S. national in terests. Accordingly, through PP 10949 and PP 10998, the President restricted th e entry of fo reign nation als from countries lacking adequate screening and vetting information to safeguard the national security and public safety of the United States and its citizens. The proclamations also instructed the United States Government to promptly engage with the countries identified, outlining the necessary steps to meet U.S. screening, vetting, immigration, and security standards. However, despite those efforts, most of t he countries named in PP 10949 and PP 10998 – and others – continue to demonstrate significant deficiencies in screening, vetting, and information sharing. In addition to PP 10949, PP 10998 emphasizes that “it is the policy o f the United S tates to prot ect its ci tizens from foreign nationals w ho intend to commit terr orist attacks, threaten ou r national se curity and public safet y, incite hat e crimes, or otherwise e xploit the i mmigration laws for ma levolent purpos es. ” Following the continued review since the issuance of PP 10949, as well as the responses of foreign countries to that proclamation, the United States Government has identified additional countries that are unab le to meet basic c riteria for identif ying their nationals and residents who may pose national sec urity and pu blic safety ri sks, or for s haring neces sary informa tion with th e United States. It is paramount t hat the United States G overnment ensure aliens in the United States do n ot intend to threaten its citizens or undermine or destabilize its c ulture, government, institutions, or 7 USCIS issued a public - facing ver sion on December 2, 2 025. See Pol icy Mem orandum, Hold and Review of all Pending Asylum Applica tions and all USCIS Benefit Applications Filed by Aliens from High -Risk Countries, December 2, 202 5 (PM - 602 - 0192).

PM-602-0194: Hold and R eview of USC IS Benefit Applica tions Filed by Aliens f rom Additiona l High -Risk Countries Page: 3 founding principles. Entry will not be granted to aliens who advocate for, aid, or support designated foreign terro rists or oth er threats to o ur national s ecurity or pu blic safety. As a result of these rev iews and considerations, t he President has dete rmined to maintain and ad just the restrictions outlined in sections 2 and 3 of PP 10949 regarding the entry of certain classes of foreign nati onals into th e United Sta tes. Additio nally, furth er limitat ions have be en imposed on the entry of aliens from additional hi gh -r isk countries in PP 10998. Considering identified concerns and the threat to the American people, USCIS has determined a comprehensive re - revi ew, potential interview, and re - inte rview of all a liens from h igh - risk countries of concern who entered the United States on or after January 20, 2021, is necessary. 8 USCIS remains dedicated to ensuring aliens from high-risk countries of concern who have entered the United States do not pose risks to national security or public safety. To faithfully uphold United States immigrat ion law, the f low of aliens from countries with high overstay rates, signific ant fraud, or both must stop. To address potential vulnerabilities, USCIS will place an adjudicative hold on all pending benefit requests submitted by or for alie ns from the high- risk co untries iden tified in PP 10998, allowing for a thorough case-by- case review. This h old will rem ain in effect until lifted o r modified by the USCIS Director through a subsequent memorandum or memorandum attachment. Any requests to lift the hold due to litigation or other extraordinary circumstances must receive approv al from the USC IS Director or D eputy Directo r. Guidance USCIS has determined t he operational necessi ty to ensure all alien s from high -risk countries of concern who entered the United States do not pose a threat to national security or public safety. This effort e nsures USC IS exercises its full author ity to inve s tigate immigration benefi t requests filed by or for aliens who may pose risks to the national security and public safety o f the United States, as outlined in DH S Delegation of Authority 0150.1, issued June 5, 2003. USCIS will conduct a thorough review on a case-by- case basis to assess b enefit eligibility including whether: 1. The alien is listed in the Terrorist Screening D ataset (TSDS) as a Know n or Suspected Terrorist un der Tier 1 or T ier 2 classifi cations or is included in Tier 3 of the TSDS with significant d erogatory informa tion related to the alien. 2. The alien is connected to prior, current, or planned involvement in, or association with, an activity, ind ividual, o r organization described in sections 2 12(a)(3)(A), (B), or (F), o r 237(a)(4)(A) or (B) of th e Immigration and Nationa lity Act (INA). 3. The alien is linked to prior, current, or planned involvement in, or association with, an activity, individual, or organization that may pose a risk of serious harm or danger to the community, including criminal co nduct desc ribed in INA 1 01(a)(43), 212 (a)(1)(A)(iii), 212(a)(2), 2 37(a)(2), or 237(a)(4)(A)(ii). 8 Additio nally, USCIS m ay, whe n appr opriat e, exte nd this review a nd re - i ntervi ew proce ss to al iens who ente red the United States outside of this timefr ame.

PM-602-0194: Hold and R eview of USC IS Benefit Applica tions Filed by Aliens f rom Additiona l High -Risk Countries Page: 4 4. The alien is unable to establish their identity as outlined in PP 10949 and PP 10998. 9 M any of these restricted high- risk countries experience widespread corruption, unreliable or fraudulent civil documents and criminal records, and lack effective birth registration systems, which systematically hinder ac curate vetting and id entity verif ication. O fficers must con sider thes e country-specific factors when conducting security and background checks, and when reviewing civil documents such as passports, marriage and divorce certificates, and birth certificates, as we ll as criminal history info rmat ion. Officers must follow established policies to ensure proper screening and vetting procedures are conducted, and that any derogatory information is thoroughly evaluated and appropriately resolved. This process ensures that USCIS exercises its ful l authority to protect nat ional security an d public safety while adhering to the provisions of the INA and applicable laws. USCIS has considered that this direction may result in delay to the adjudication of some pending applications and has weighed that consequence against the urgent need for the agency to ensure that aliens are vetted and screened to the maximum deg ree possible. Ultim ately, USCIS has deter mined the burden of processing delays which will fal l on some aliens is necessary and appropriate, when weighed against the agency’s obligation to protect and preserve our national security. Exceptions to the Adjudication Hold 10 Exceptions to the adjudication hold for cases with identified national security, public safety, or fraud - relate d derogatory information still requir e the adjud icative direc torate or p rogram office to coordinate with U.S. Immig ration and Customs Enfo rcement (ICE) in accordance with current policies and procedures before f inal adjudication. The following are exceptions to the adj udication hold: 1. Form I -90, Application to Replace Permanent Resident Card (Green Card); 11 2. Form N -565, Applic ation for Re placement N aturaliza tion/Citizen ship Documen t; 3. Form N - 600, A pplication for Certifi cate of Citiz enship; 12 9 See USCIS Policy Manual, Volume 1, General P olicies and Procedures, Part E, Adjudications, Chapter 8, Discretionary An alysis [1 USCIS - PM E.8 ]. 10 Any req uest for an exe mption t o the a djudi cative h old mu st be c oordinat ed wit h the U SCIS Of fice o f Policy a nd Strategy (OP&S). OP&S will track and record all the hold lifts. OP&S will issue additional guidance within 7 days of issuing this memor andum. 11 Lawful permanent r esidents are entitled to evid ence of status in the United States. Lawf ul perma nent r esident s are eligible for replacement of their Perma nent Resident Card if they meet certain requ irement s. See USCIS Policy Manual, Volume 11, Tra vel and Identi ty Doc uments, Part B, Perman ent Resi dent C ards, C hapter 2, Repla cement of Per manent Resident Card [11 USCIS - PM B.2 ]. 12 Except Yemen a nd Soma lia. Ye men an d Somal ia are not incl uded i n this particul ar exce ption due to s ecurit y and document ary conc erns s pecifi c to th ose cou ntries as docum ented on the D epartme nt of S tate Visa Rec iprocit y Schedule s for t hese co untries.

PM-602-0194: Hold and R eview of USC IS Benefit Applica tions Filed by Aliens f rom Additiona l High -Risk Countries Page: 5 4. Form I - 765, Application for Employment Authorization filed under the (c)(8), 13 limited (c)(11), 14 and limited (c)(1 4) 15 categor ies; 5. Form I -910, Application for Civil Surgeon Designation (only for physicians that are citizens or nationals of the United States); 6. Benefit requests filed by a ny alien who is an a thlete or me mber of an athle tic team, including the coaches, p ersons performing a necessary su pport role, and immed iate relatives for the purpose of participating in the World Cup, Olympics, or other major sporting event as determine d by the Sec retary of Sta te; 7. Benefit requ ests that are a priority fo r law enforc ement and w here ICE has re quested U SCIS take adjudicative action to uphold public safety or national security; 8. Benefit requests filed by aliens whose entry woul d serve a United States n ational interest; 16 9. B enefit request s, as well as the as sociated underlying benef its, for any programs that are terminated o r discontinu ed as a resul t of an Executiv e Order, P roclamatio n, Federal Register Notice, or Directive issued by the President, the Secretary of Homeland Security, or the USCIS Director; and 10. A utomatic term ination d ecisions for an cillary or related bene fit requests when an alien is granted Legal Permanent R esident status or beco mes a naturalized citizen. 17 Within 90 days of this memorandu m issuance, and in consultation with OP&S and the Fraud Detection an d National S ecurity Dire ctorate, USC IS will prio ritize a list for review, interv iew, and re - interview, and issue operational gu idance. Use This policy memorandum is intended solely for the guidance of USCIS personnel in the performance of their offi cial duties, but it doe s not remove th eir discre tion in making adjudicato ry decisions. It may not be relied upon to create any right or benefit, substantive or procedural, enforceable under law or by any individual or other party in removal proceedings, in litigation with the United States, or in any other form or manner. 13 See 8 CFR 274a.12(c)(8). Only applies to initial (c)(8) filings. Asylumworks v. Mayorkas requires USC IS to proce ss all initial For m I - 765 filed under the (c)(8) categ ory withi n 30 days. 14 See 8 CFR 274a.1 2(c)(11). Form I - 765 filed under t he (c)(11) cate gory e xceptio ns only apply when t he reques t comes from law enforcement because the alien is assistin g law enforcement. 15 See 8 CFR 274a.1 2(c)(14). Form I - 76 5 filed under t he (c)(14) cate gory e xceptio ns only appl y when t he reque st comes from law enforcement because the alien is assistin g law enforcement. 16 For example, a benefit reque st filed by an alien whose ent ry int o the Uni ted St ates w ould pr ovide si gnifi cant benefit to the United States may includ e, but is not limited to, a scientist or medical researcher working on a critical public health project, a n engineer with specialized skills needed for a key infrastructure initiative, or someone with uni que experti se supp orting U.S. nat ional s ecurit y or ec onomic interes ts. This is a case - by - case determination and requires approval from the hea dquarte rs of t he adju dicat ive direc torat e or pro gram of fice. 17 For exam ple, whe n USC IS appr oves an i ndivi dual’s F orm I - 4 85, any associ ated or under lying a pplica tions, suc h as Form I - 765, will be a utomati call y terminat ed, a s the benefit provide d by t he ancil lary f orm is no longe r necess ary.