USCIS Pauses Benefit Requests for Nationals From ‘High-Risk’ Countries and Halts Asylum Adjudications

Quick Hits

• Effective immediately, USCIS is pausing review of all immigration benefit request from individuals who were born in or hold citizenship from one of the nineteen countries identified as “high-risk” in Presidential Proclamation 10949.
• USCIS is pausing the adjudication of all pending asylum and withholding of removal applications regardless of the country of birth or nationality.
• Approved benefit requests for individuals born in or holding citizenship of the nineteen identified countries who entered the United States on or after January 20, 2021, are now subject to a comprehensive re-review process.

USCIS announced the policy memorandum “[i]n light of identified concerns and the threat to the American people,” following the shooting of two National Guard members in Washington, D.C., on November 26, 2025. The memorandum is aligned with Executive Order 14161, which directed a cross‑agency tightening of immigration vetting and screening, and Presidential Proclamation 10949, which implemented country-specific entry restrictions barring entry for nationals of Afghanistan, Burma, Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, and Yemen, and partially barring entry for nationals of Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.

USCIS will be conducting a thorough national security and public safety review on a case-by-case basis to assess benefit eligibility including whether:

1. The individual is listed in the Terrorist Screening Dataset (TSDS) in higher-risk categories or has serious negative information connected to lower tiers.
2. The individual has been involved with, plans to be involved with, or is associated with activities, people, or groups tied to terrorism or other national security concerns as outlined under specific immigration laws.
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 certain criminal conduct.
4. The individual is unable to establish his or her identity as outlined in USCIS policy and Presidential Proclamation 10949.

USCIS clarified that individuals in the affected group will need to attend interviews in any situation where an interview is normally required. For benefit categories that typically do not require an interview, officers will decide on a case-by-case basis whether an in-person appearance is needed after reviewing the file. USCIS also noted that follow-up interviews may be scheduled if additional verification is necessary—such as confirming identity, evaluating eligibility, or addressing any national security or public safety concerns. The agency acknowledges that the initiative may result in processing delays.

Within ninety days of issuance of the memorandum, USCIS will prioritize a list for review, interview, re-interview, and referral to Immigration and Customs Enforcement (ICE) and other law enforcement agencies as appropriate, and, in consultation with the Office of Policy and Strategy and the Fraud Detection and National Security Directorate, issue operational guidance.

As a result of the directive, individuals with pending asylum or withholding of removal applications should expect a pause in the processing of their cases. Similarly, individuals who were born in or are a citizen of one of the enumerated nineteen high-risk countries should anticipate delays in processing and may be required to present additional documentation to confirm security or background information. Applicants with prior approved benefit requests who entered the United States on or after January 20, 2021, may also receive similar requests as part of the re-review initiative.

Key Takeaways

This latest USCIS directive is consistent with the administration’s broader focus on national security outlined in recent executive orders and presidential proclamations. The policy memorandum does not expressly indicate that the submission of new benefit applications for impacted applicants will be restricted. The halt on adjudicating benefit requests of nationals from the nineteen “high-risk” countries, and all pending asylum cases, regardless of nationality, will remain in place until the USCIS director lifts the hold in a subsequent memorandum. Applicants should expect delays in processing, additional identity/background requests, interview notices, and potential gaps in employment authorization due to operational delays.

Ogletree Deakins’ Immigration Practice Group will continue to monitor developments with respect to this program and other changes and will provide updates on the Immigration blog as additional information becomes available.

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