December 2, 2025 USCIS Policy Memorandum: Hold/Pause of all Pending USCIS Benefit Applications Filed by Aliens from High-Risk Countries

On December 2, 2025, USCIS Policy Memorandum (PM-602-0192) titled: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries, was published.
The Policy had three (3) Goals:
- Place a hold on all Forms I-589 (Application for Asylum and for Withholding of Removal),
- Place a hold on pending benefit requests for aliens from countries listed in Presidential Proclamation (PP) 10949
- Conduct a comprehensive re-review of approved benefit requests for aliens from countries listed in PP 10949 who entered the United States on or after January 20, 2021.
38 Countries are directly affected by this policy pause, and the list is as follows:
- Afghanistan
- Angola
- Antigua and Barbuda
- Benin
- Burma (Myanmar)
- Burkina Faso
- Burundi
- Chad
- Cuba
- Cote d'Ivoire
- Republic of the Congo
- Dominica
- Equatorial Guinea
- Eritrea
- Gabon
- The Gambia
- Haiti
- Iran
- Laos
- Libya
- Mali
- Malawi
- Mauritania
- Niger
- Nigeria
- Sierra Leone
- Somalia
- South Sudan
- Sudan
- Syria
- Senegal
- Tanzania
- Togo
- Tonga
- Venezuela
- Yemen
- Zambia
- Zimbabwe
This Policy Memo Directly affects:
- Form I-485 (Application to Register Permanent Residence or Adjust Status),
- Form I-90 (Application to Replace Permanent Resident Card (Green Card)),
- Form N-470 (Application to Preserve Residence for Naturalization Purposes),
- Form I-751, (Petition to Remove Conditions on Residence), and
- Form I-131 (Application for Travel Documents, Parole Documents, and Arrival/Departure Records).
Additionally, if pausing Green Card-related functions, Naturalization and Citizenship Benefits may also be slightly affected, as they build on lawful permanent residence and Aliens naturalizing in 2026 may have entered after January 20, 2021.
This Policy Memo is only "active" for a 90-day period, and set to expire around the end of February. The Memo states:
USCIS will prioritize a list for review, interview, re-interview, and referral to ICE and other law enforcement agencies as appropriate, and, in consultation with the Office of Policy and Strategy and the Fraud Detection and National Security Directorate, issue operational guidance.
The USCIS Policy Memo can be seen here for reference:
Disclaimer: This Blog is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. By using this blog site you understand that there is no attorney-client relationship between you and the Blog/Web Site publisher. The Blog should not be used as a substitute for competent legal advice from a licensed professional attorney in your state.












