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On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum implementing significant holds on and re-reviews of immigration benefits for individuals who are citizens of or were born in one of the 19 travel ban countries listed in Presidential Proclamation (PP) 10949: Afghanistan, Burma, Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.
Specifically, effective immediately, USCIS personnel were directed to take the following steps:
- Hold adjudication of all pending benefit requests (including
but not limited to petitions for or to extend H-1B, O-1, or L-1
status, immigrant visa petitions, employment authorization document
applications, and adjustment of status applications) filed by
individuals from travel ban countries, regardless of the
applicant's date of entry into the United States.
- Conduct a comprehensive re-review of previously approved
benefit requests for individuals from travel ban countries who
entered the United States on or after January 20, 2021.
- Hold adjudication of all Form I-589 applications (Application for Asylum and for Withholding of Removal), regardless of the applicant's country of nationality, pending a comprehensive review.
Accordingly, affected individuals should be aware of the following:
- International travel risks: Because there are
anecdotal reports that U.S. Customs and Border Protection (CBP) has
interpreted the policy memorandum expansively, affected individuals
should avoid international travel until further clarification is
issued by CBP. This applies even to individuals with dual
nationality that includes one of the travel ban countries, and
those who were born in a travel ban country but are nationals of a
non-travel ban country (e.g., a Canadian national who was born in
Iran). This is a troubling development as the original travel ban
did not cover these individuals.
- Increased scrutiny and RFEs: Individuals with
pending USCIS applications or who are the beneficiaries of
petitions filed by their employers, or those planning to file
within the next six months, should expect delays from the holds
USCIS is placing on their cases, as well as heightened scrutiny.
USCIS may issue Requests for Evidence (RFEs) seeking proof of
community ties and good moral character, such as reference letters
from friends, neighbors, coworkers, or community leaders, as well
as evidence of volunteer or nonprofit involvement. It is prudent to
proactively prepare these documents.
- Re-review of previously approved benefits: Individuals from travel ban countries who entered the United States on or after January 20, 2021, including lawful permanent residents (i.e., green card holders) and potentially even naturalized U.S. citizens, may have previously approved USCIS benefits re-reviewed over the 90-day period following the December 2, 2025 effective date of the policy memorandum. Cases may be reopened, and individuals may receive RFEs or be scheduled for interviews.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
