On December 2, 2025, USCIS published a Policy Memorandum (“PM”) placing on hold all pending asylum applications regardless of the applicant's nationality, as well as most USCIS benefit applications for individuals whether born in or holding citizenship from 19 countries considered “high risk.” The policy memorandum took effect on December 2, 2025, and, at this time, it has no specified expiration date.

The 19 countries in question, were identified as lacking adequate security vetting procedures in Presidential Proclamation 10949, issued on June 4, 2025, and titled “Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats.” This PM, in conjunction with the aforementioned Proclamation, show the efforts made by the current administration in escalating immigration enforcement and expanding restrictions on immigration benefits applications.

The complete list of affected countries is as follows: Afghanistan, Burma, Burundi, Chad, Cuba, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela, and Yemen.

What Does the Policy Memorandum Require?

The PM specifically instructs USCIS personnel to:

• Hold all adjudications of Asylum applications (Form I-589), regardless of the applicant's nationality, pending a comprehensive review;
• Hold most benefit requests for individuals from the 19 listed countries, regardless of when they entered the U.S., pending a comprehensive review; and
• Conduct a comprehensive re-review of all previously approved benefit requests for individuals from the 19 listed countries who entered the U.S. on or after January 20, 2021. This includes anyone who entered the country by any means, whether admitted on a visa, inspected at ports of entry, granted parole, or entered without inspection.

What Are the Practical Implications of This PM?

People impacted by this new PM will undergo a thorough re-review process, which may include being re-interviewed to determine whether they pose a threat to public safety or national security.

Officers are specifically instructed to conduct secondary reviews on a case-by-case basis, to determine whether: (1) the applicant appears on terrorism watchlists; (2) the applicant has connections to terrorist organizations – including past, current, or planned involvement – as designated by the U.S. Department of Homeland Security; (3) the applicant has been involved in serious criminal activity, including crimes classified as “aggravated felonies,” crimes involving moral turpitude or drug offenses; and (4) the applicant can properly establish their identity.

The immigration benefits that will be halted and re-evaluated, as explicitly listed in the PM, include:

• Form I-589, Application for Asylum or Withholding of Removal;
• Form I-485, Application to Adjust Status to Permanent Resident;
• Form I-90, Application to Replace Green Card;
• Form N-470, Application to Preserve Residence for Naturalization;
• Form I-751, Petition to Remove Conditions on Residence; and
• Form I-131, Application for Travel Documents and Parole.

What Should You Do If You Are Affected by This PM?

If you or someone you know is affected by this new policy, either by having a pending asylum application with USCIS or by being from one of the 19 countries with approved or pending benefit requests with USCIS, your case will be placed on hold until further notice.

During this time, it is important to keep all documents up to date, including proof of identity, travel history, and records demonstrating you do not pose a security risk, and consult with an experienced immigration attorney who can help you navigate these changes and represent your interests throughout this process.

While this policy creates significant uncertainty and delays for thousands of applicants, it is important to remember that each case will be reviewed individually. Having proper documentation and legal representation can make a great difference in the outcome of your application. To discuss your specific situation, please schedule a consultation with a lawyer at CTM Legal Group and we will be happy to assist.