At a Glance:

On Dec. 2, 2025, the United States Citizenship and Immigration Service (USCIS) issued a Policy Memorandum titled, “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries.”

The memorandum is calling for the immediate (1) pause of processing of Form I-589 Application for Asylum and for Withholding of Removal for all individuals regardless of their country of nationality, (2) pause of processing for pending benefit requests for individuals from countries listed in the Presidential Proclamation 10949 (see below), and (3) comprehensive re-review of any approved benefits requests for foreign nationals from countries listed in the Presidential Proclamation 10949 who entered the United States on or after Jan. 20, 2021.

The Policy Memorandum became effective immediately as of the publishing date of Dec. 2, 2025.

Key Takeaways:

All pending I-589 Asylum and Withholding of Removal Applications will be placed on hold until a more comprehensive review is completed.

Individuals from countries listed in the Presidential Proclamation 10949 may be subject to additional scrutiny, including potentially mandatory interviews, regardless of whether the benefit has been approved or is still currently pending.

Details:

Citing national security and public safety, the USCIS has (1) halted all asylum decisions regardless of immigrant nationality, as well as (2) placed a hold on pending benefit requests for individuals from travel ban countries who entered the United States on or after Jan. 20, 2021. The travel ban countries, as outlined in the Presidential Proclamation 10949 are as follows:

• Afghanistan.
• Burma.
• Chad.
• Republic of the Congo.
• Equatorial Guinea.
• Eritrea.
• Haiti.
• Iran.
• Libya.
• Somalia.
• Sudan.
• Yemen.
• Burundi.
• Cuba.
• Laos.
• Sierra Leone.
• Togo.
• Turkmenistan.
• Venezuela.

The Policy Memorandum mandates that individuals meeting either of the above criteria undergo a thorough re-review process, including potentially additional interviews, to fully assess all national security and public safety threats. This screening will be completed on a case-by-case basis. It is expected that the recently issued USCIS guidance on Adjudication of Discretionary Benefits will weigh into the re-review process – the guidance calling for the consideration of country-specific information as a “significant negative factor” during vetting of individuals from the travel ban countries. If an additional interview is required, it shall not be waivable under any circumstances.

Within 90 days of the issuance of this memorandum, USCIS will create a priority list of cases for review, interview, re-interview, and adjudication.

What We Know:

• All pending I-589 Asylum and Withholding of Removal Applications will be placed on hold until subsequent review has taken place, therefore no new grants of asylum through USCIS are expected in the interim.
• The travel ban country list applies to individuals not only with one of these countries as their country of citizenship but also their country of birth.
• The pause on benefits for individuals from travel ban countries specifically enumerated in the guidance includes: I-485 Adjustment of Status, I-90 Application to Replace Permanent Resident Card, Form N-470 Application to Preserve Residence for Naturalization, Form I-751 Petition to Remove Conditions, and Form I-131 Application for Travel Documents.
• Naturalization Oath Ceremonies have already been cancelled for individuals from travel ban countries and green card interviews have either been cancelled or instructed a final decision cannot be rendered in their case.

What We Need Further Confirmation On:

• To what extent the pause on adjudicating cases filed by those from travel ban countries extends to case types not specifically enumerated in the memorandum is unknown. For example, the title of the memorandum denotes “all USCIS Benefit Applications” which could include extension of nonimmigrant status, change of nonimmigrant status, and many employment-based authorization applications for individuals from travel ban countries.
• How individuals will be notified of required additional processing, potential interview dates, etc.

Employers with individual workers from this list of countries seeking advice pertaining to this guidance should contact the Taft Immigration team for further details. This is a rapidly developing situation.