Immigration Benefits Processing Hold for 19 Countries

Last Updated 12/04/2025

On June 4, 2025, the Trump administration announced a travel ban that fully suspends entry from 12 countries and applies a partial travel ban to 7 additional countries, with some exceptions.

U.S. Citizenship and Immigration Services (USCIS) subsequently issued policy memoranda on both November 27, 2025 and December 2, 2025 regarding how benefits applications will be processed for individuals from those same 19 countries who are filing applications for immigration benefits in the United States. Importantly, persons who are processing applications in the United States are not subject to a full ban on approval of immigration benefits applications.  Instead, the memos provide for additional screening for security purposes, which will result in longer processing times, but still allow for filing and approval of benefits applications for eligible applicants from the 19 countries.

This blog will be updated as new information comes to light, so please make sure and revisit it.

Who Is Affected?

Persons who list one of the following 19 countries as either their Country of Birth or Country of Citizenship are affected by the new policy memoranda:

• Afghanistan, Burma (Myanmar), Burundi, Chad, Republic of Congo, Cuba, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela, and Yemen

Which Types of Benefit Applications Are Affected by the December 2, 2025 Policy Memorandum Regarding Processing Holds?

The December 2, 2025 policy memorandum directs USCIS personnel to:

• Place a hold on pending immigration benefit requests for foreign nationals who were born in or are a citizen of one of the 19 countries in order to conduct a case-by-case review for national security or public safety concerns;
• Conduct a comprehensive re-review of approved benefits requests for foreign nationals from one of the 19 countries who entered the United States on or after January 20, 2021; and
• Place a hold on all Forms I-589 applications for asylum and withholding of removal, regardless of the foreign national’s place of birth or nationality, pending a comprehensive review.

Affected benefits applications include the following: Form I-485 adjustment of status applications; Form I-90 applications to renew/replace lawful permanent resident cards; Form I-131 advance parole and travel document applications; Form I-751 petitions to remove conditions on permanent residence; and Form N-470 applications to preserve residence for naturalization (see footnote 4).

The memorandum does not specify whether the processing hold will apply to other types of benefit applications, such as employment-based nonimmigrant petitions, other nonimmigrant petitions, or naturalization applications.  We will update this blog as more information becomes available.

What Happens During the Processing Hold?

For affected benefits applications, USCIS will conduct a thorough review on a case-by-case basis to assess benefit eligibility including whether:

1. The individual is listed in the Terrorist Screening Dataset (TSDS) as a Known or Suspected Terrorist (KST) under Tier 1 or Tier 2 classifications or is included in Tier 3 or Tier 4 of the TSDS with significant derogatory information related to the individual.
2. The individual is connected to prior, current, or planned involvement in or association with an activity, individual, or organization associated with terrorist activities, espionage, or other unlawful activities.
3. The individual is linked to prior, current, or planned involvement in or association with an activity, individual, or organization that may pose a risk of serious harm or danger to the community, including criminal conduct.
4. The individual is unable to establish their identity as outlined in the June 2025 travel ban.

Which Types of Benefit Applications Are Affected by the November 27, 2025 Policy Memorandum Regarding Discretionary Determinations?

The November 27, 2025 Memorandum directs USCIS personnel to consider relevant country-specific facts and circumstances, such as those outlined in the June 2025 travel ban, as part of its adjudication of discretionary benefit requests.  The November 27, 2025 Policy Memorandum applies to applications that are pending or filed on or after November 27, 2025.

Discretionary benefit requests that USCIS adjudicates include, but are not limited to, certain adjustment of status applications, extensions of nonimmigrant stay, and changes of nonimmigrant status.  The USCIS Policy Manual provides a table and additional guidance regarding which applications are discretionary and which are not.

USCIS considers information such as whether the country has a “competent or central authority for issuing passports and civil documents” in order to allow USCIS to determine identity and assess discretion, high rates of overstay from certain countries (in the context of nonimmigrant visa applications), whether the individual has promoted anti-American views or the views of terrorist organizations, and other factors.  For more information, see the “Country-Specific Facts and Circumstances” section in the USCIS Policy Manual, Volume 1, Part E, Chapter 8.

What Should You Do Now?

If you have a pending application that is affected by the new policy memoranda, expect longer processing times, and we are available to help if you have questions about how your application is affected or how to prepare for an immigration interview.  If your application is unreasonably delayed, Vrapi Weeks attorneys are also experienced in filing mandamus petitions in federal court to seek to speed up immigration adjudications.

If you have not yet filed, we are happy to talk with you about how new policies under the Trump administration affect your application and to make a plan for the best timing and strategy in your case.

How Can Vrapi Weeks Immigration Attorneys Help?

Vrapi Weeks immigration attorneys have a dedicated team of professionals with expertise in immigration matters filed for family members, immigration matters filed by employers, and immigration matters filed by individuals. We handle many types of immigration matters and can assist you with green card applications, work permits, waivers, employment-based visas, and family-based visas. If you have questions or would like for our local attorneys to evaluate your options, please schedule a consultation with our experienced team of immigration lawyers at Vrapi Weeks today.