- within Law Department Performance, Accounting and Audit and Law Practice Management topic(s)
Effective immediately, USCIS has issued a new national-security guidance suspending the processing of a broad range of immigration benefits for individuals from 19 "high-risk" countries identified in the 2025 travel ban and listed below. The freeze on adjudications of pending applications applies regardless of when the individual entered the United States. Previously approved cases will be reviewed and can be readjudicated for those who entered the United States on or after January 20, 2021.
On December 5, 2025, USCIS also announced the establishment of a USCIS Vetting Center to be headquartered in Atlanta. This center will be responsible for "conducting reviews of pending applications as well as a more holistic review of already-approved applications" and "will prioritize applications from presidentially designated countries of concern."
In addition, on December 4, 2025, USCIS announced that the maximum validity period of certain categories of employment authorization documents would be reduced. For asylum applicants and for applicants for adjustment of status, that maximum period is now reduced from five years to 18 months.
Key Developments
- USCIS has paused adjudication of all immigration benefits filed by nationals of the affected countries, including applications for adjustment of status, green-card replacements, travel documents, removal of conditions, naturalization-related filings and other pending benefits.
- All asylum applications (Form I-589)—for all nationalities—are also on hold.
- USCIS will conduct a comprehensive rereview of
previously approved benefits for nationals of the listed countries
who entered the U.S. on or after January 20, 2021.
USCIS is expected to produce a list of priority cases within 90
days, and the review may involve:
- New or repeated interviews (interviews for this population cannot be waived);
- Enhanced terrorism- and criminal-inadmissibility vetting; and
- Potential referral to Immigration and Custom Enforcement or law-enforcement agencies, as appropriate.
Countries Affected by Freeze on Adjudications
The 19 countries listed for the adjudication freeze are Afghanistan, Myanmar (Burma), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan and Venezuela.
As mentioned above, asylum applications by nationals of all countries are also currently on hold.
Which Application Types Are Affected
A broad range of pending and approved USCIS filings may be paused or reexamined, including but not limited to:
- Form I-485: Adjustment of status/green card applications
- Form I-90: Green card replacement
- Form I-131: Travel documents/advance parole
- Form I-751: Removal of conditions
- Form N-470: Preservation of residence for naturalization
- Form I-589: Asylum and all other pending benefit requests from impacted nationals
USCIS has stated that interviews for nationals of the 19 countries identified cannot be waived under any circumstance.
Implications for Employers and Foreign Nationals
- Significant delays and uncertainty can be expected, even for long-pending or already approved cases. Clients should anticipate extended processing times and possible revetting.
- Disruptions to employment and global mobility employer-sponsored petitions, transfers and green-card processes for affected nationals now involve heightened risk and unpredictability.
- Postponement of naturalization and oath ceremonies will affect individuals close to becoming U.S. citizens, who may face indefinite delays.
- Heightened compliance exposure will include mandatory interviews, stricter documentation requirements and potential referral to law enforcement if "inadmissibility" concerns arise.
- There will be a broad impact on humanitarian and business immigration as all asylum filings are frozen, and the administration may expand the list of restricted countries.
- Possible expansion to additional visa categories may occur as the Department of Homeland Security evaluates broader national-security screening protocols.
If there is indeed a large-scale readjudication of already approved applications, that would represent a substantial shift in both policy and resources. This will create further significant uncertainty for impacted foreign nationals and their employers.
For More Information
If you have any questions about this Alert, please contact Ted J. Chiappari, M. Alejandra Vargas, Katharyn Ivera Christian Voit, Isabella Castellon Lebron, any of the attorneys in our Immigration Law Group or the attorney in the firm with whom you are regularly in contact.
Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.
