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 calls 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 the 19 countries listed in the preexisting Travel Ban (Presidential Proclamation 10949 — see below), and (3) comprehensive re-review of all 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.

This is a rapidly developing situation. While the Policy Memorandum is clear as to its applicability to specific cases, ambiguities do exist as to the extent of case processes this halt applies to. These gaps are discussed further below.

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 previous Presidential Proclamation (10949) are having processing of their applications frozen and may be subject to additional scrutiny, including potentially mandatory interviews, even after their benefit has been approved.

View the complete law bulletin here for additional analysis.