USCIS Restricts Processing of Asylum Applications and Immigration Benefits for People from “High-Risk” Countries
On December 2, 2025, USCIS issued a policy memo impacting a broad range of immigration benefits. The memo instructs USCIS personnel to take the following actions, effective immediately:
- Place a hold on all Forms I-589 Applications for Asylum and for Withholding of Removal, regardless of the alien’s country of nationality, pending a comprehensive review.
- Place a hold on pending benefit requests for aliens from countries listed in Presidential Proclamation (PP) 10949, Restricting the Entry of Foreign Nationals, pending a comprehensive review, regardless of entry date. See list of 19 countries below.
- 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.
The memo mandates that “all aliens meeting these criteria undergo a thorough re-review process, including a potential interview and, if necessary, a re-interview, to fully assess all national security and public safety threats along with any other related grounds of inadmissibility or ineligibility.”
The benefit requests impacted include but are not limited to: Forms I-589 (Applications for Asylum and for Withholding of Removal), 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). Employer-sponsored petitions requesting benefits for foreign nationals from these countries may also be impacted.
The memo does not provide a timeframe for when the hold will be lifted, but does provide that, “Within 90 days of issuance of this memorandum, 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.”
High-Risk Countries
The December 2nd memo impacts foreign nationals born in or citizens of any of the 19 “high-risk” countries listed in Presidential Proclamation 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.
The new policy impacts a much broader category of people than those subject to the travel ban because it halts processing of benefits requests for anyone whose country of birth or country of citizenship is on the list of countries subject to the travel ban.
Policy Memo Issued November 27, 2025
Citing Presidential Proclamation 10949, USCIS also issued new guidance that would enhance the scrutiny applied to discretionary benefit applications filed on or after November 27, 2025 and consider country-specific facts and circumstances, such as those outlined in the Proclamation, when adjudicating benefits. The memo provides that, “with certain exceptions, USCIS considers any relevant country-specific factors such as those specified in PP 10949 as significant negative factors in the adjudication of discretionary benefit requests.” The guidance states that “[t]he mere fact that an individual is from a country subject to [restrictions] on entry or admission, however, is not by itself a significant negative factor.” In line with this policy, USCIS may issue requests for additional evidence in these cases.
We will continue to monitor how these policies are implemented and the scope of benefits impacted. If you have any questions about your case or require specific legal advice, please consult with your Van Der Hout representative.