USCIS Orders Adjudicative Hold on Cases for Nationals of 39 “High-Risk” Countries, Expands Security Re-Review
Key Takeaways
- USCIS (U.S. Citizenship and Immigration Services) issued Policy Memorandum PM-602-0194 directing an adjudicative hold on pending immigration benefit applications for nationals of countries named in Presidential Proclamation (PP) 10998.
- While cases may continue to be processed, no approvals, denials, or dismissals will be issued until the hold is lifted; previously approved cases dating back to Jan. 20, 2021 will be re-reviewed for security and identity concerns.
- Coverage includes people listing a designated country as birth or citizenship, certain Citizenship by Investment (CBI) passport holders originally from those countries, and travelers on Palestinian Authority documents; family-based cases are now subject to the same scrutiny.
- The 39-country list spans both full and partial entry suspensions; the USCIS hold applies regardless of the degree of entry ban.
- Limited exceptions include certain green card and citizenship document replacements, some employment authorization cases, and narrow event-based or case-by-case waivers.
What changed
USCIS has implemented a sweeping adjudicative hold under Policy Memorandum PM-602-0194, effective Jan. 1, 2026, covering all pending benefit applications filed by or on behalf of nationals of countries named in PP 10998, “Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States.” The hold allows routine steps—such as biometrics, interviews, and requests for evidence (RFEs)—to proceed, but bars final decisions until the hold is lifted. The agency will also conduct a comprehensive re-review of benefit requests that were approved on or after Jan. 20, 2021, applying case-by-case assessments focused on national security/public safety indicators, terrorist watchlist hits, criminal history, and the ability to verify identity through reliable civil documents. For applicants and petitioners, this signals added screening and potentially prolonged timelines across a wide range of filings.
Who is affected
The policy applies broadly to any individual who lists a PP 10998-designated country as country of birth or citizenship. It also reaches individuals who acquired a non-restricted passport through a Citizenship by Investment (CBI) program if they originate from a listed country, and those traveling on documents issued or endorsed by the Palestinian Authority. Notably, family-based immigrant cases—which had previously been treated more leniently under earlier policies—are no longer automatically exempt and now face the same heightened scrutiny as employment-based and other benefit requests. For people in the system now, that means expect delays on petitions (e.g., employment- or family-based), applications to adjust or change/extend status, and potentially naturalization, with increased likelihood of RFEs, interviews, and identity verification checks.
Scope of the proclamations and country list
PP 10998, signed Dec. 16, 2025, builds on PP 10949 (June 4, 2025) to identify 39 countries whose nationals are subject to entry restrictions—and, by extension, the USCIS adjudicative hold. Full suspensions of entry for both immigrants and nonimmigrants apply to nationals of Afghanistan, Burkina Faso, Burma, Chad, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Mali, Niger, Republic of the Congo, Sierra Leone, Somalia, South Sudan, Sudan, Syria, and Yemen, as well as individuals traveling on Palestinian Authority documents. Partial suspensions—limiting immigrant visas and nonimmigrant B-1/B-2 (visitors), F/M (students), and J (exchange visitors)—apply to Angola, Antigua and Barbuda, Benin, Burundi, Côte d’Ivoire, Cuba, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Togo, Tonga, Venezuela, Zambia, and Zimbabwe. Turkmenistan faces a partial suspension limited to immigrant visas. Regardless of whether a country is under a full or partial ban, the USCIS hold applies to its nationals’ pending benefit applications.
Limited exceptions and what to do now
USCIS has carved out narrow exceptions, including Form I-90 (replacement of Permanent Resident Card), Form N-565 (replacement citizenship documents), certain employment authorization applications required by court order or requested by law enforcement, and select event-based filings for athletes (e.g., World Cup or Olympics). Some case-by-case exemptions may also be available where U.S. interests warrant. For affected applicants and petitioners, the practical steps now are clear: anticipate longer processing times; prepare thorough identity and civil documentation; respond promptly to RFEs; maintain lawful status where applicable; and consult counsel on eligibility for any exceptions or on strategies to mitigate disruption while the hold remains in effect.
Source: Original Article