USCIS Hold and Review of Benefit Applications for Nationals of High-Risk Countries

On January 1, 2026, the United States Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0194, directing all agency personnel to place an adjudicative hold on pending benefit applications filed by or for nationals of countries listed in Presidential Proclamation (PP) 10998, Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States. This memorandum significantly expands the scope of prior restrictions and carries immediate consequences for a range of immigration cases.

What the Memorandum Requires

The memorandum directs USCIS to place a hold on all pending benefit applications for affected individuals, regardless of their date of entry into the United States. The hold allows cases to continue processing, but stops short of a final decision, which means no approvals, denials, or dismissals will be issued until the hold is lifted. USCIS will also conduct a comprehensive re-review of benefit requests that were approved on or after 20.Jan.2021, for nationals of the designated countries. This includes a case-by-case assessment of whether an applicant poses national security or public safety concerns, with particular attention to terrorist watchlist entries, criminal history, and the ability to establish identity through reliable civil documents.

Who is Affected

The hold applies to any individual who lists a high-risk country identified in PP 10998, as their country of birth or country of citizenship. It also extends to individuals who acquired citizenship through a Citizenship by Investment (CBI) program in a non-restricted country if they are originally from a restricted country, as well as individuals traveling on Palestinian-Authority-issued documents. Notably, family-based immigrant visa applications are no longer automatically exempt and now are subject to the same scrutiny as all other benefit requests.

Presidential Proclamation 10998, signed 16.Dec.2025, builds upon and expands the restrictions originally established by Presidential Proclamation 10949, issued 04.Jun.2025. Together, the two proclamations identify 39 countries whose nationals are subject to entry restrictions and, by extension, the USCIS adjudicative hold. The countries subject to a full suspension of entry for both immigrants and nonimmigrants are Afghanistan, Burkina Faso, Burma, Chad, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Mali, Niger, Republic of the Congo, Sierra Leone, Somalia, South Sudan, Sudan, Syria, and Yemen, as well as individuals traveling on documents issued or endorsed by the Palestinian Authority.

The countries subject to a partial suspension, which restricts immigrant visas and nonimmigrant B-1/B-2, F, M, and J visas, are Angola, Antigua and Barbuda, Benin, Burundi, Côte d’Ivoire, Cuba, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Togo, Tonga, Venezuela, Zambia, and Zimbabwe. Turkmenistan also is partially restricted, with a suspension limited to immigrant visa issuance. Because the USCIS adjudicative hold applies to nationals from all designated countries regardless of whether they fall under a full or partial ban, applicants from any of these 39 countries, as well as Palestinian Authority document holders, should be prepared for processing delays and heightened scrutiny of their pending or recently approved benefit requests.

Limited Exceptions

Certain filings are exempt from the hold. These include Form I-90 applications to replace a Permanent Resident Card, Form N-565 replacement citizenship document applications, certain employment authorization applications required by court order or requested by law enforcement, and benefit requests filed by athletes participating in events such as the World Cup or Olympics. Requests also may be exempt on a case-by-case basis where an individual’s entry would serve a United States national interest.

Conclusion

This memorandum represents a substantial expansion of USCIS adjudicative holds and may result in significant processing delays for affected applicants. Individuals from the designated countries who have pending, or recently approved benefit requests should be aware that their cases may be subject to additional review, interview, or re-interview. We strongly encourage anyone impacted by this policy to consult with an immigration attorney to understand how these changes may affect their case and to explore all available legal options. For questions or assistance, please contact the Murthy Law Firm.

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