*BREAKING NEWS* USCIS Orders Immediate Hold on All Pending Applications Filed for Applicants in the U.S. Who were Born in or Have Citizenship of "19 High-Risk" Countries

On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a Policy Memorandum directing officers nationwide to place an immediate decision hold on all pending “benefit requests” (in other words, applications) filed by individuals connected to countries designated under Presidential Proclamation 10949 who are currently in the United States.

Which 19 Countries Are Covered by Presidential Proclamation 10949?

USCIS’s new policy memorandum ties its “benefit request” hold to nationals of 19 countries identified in Presidential Proclamation 10949, Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats.

Under that proclamation and related government summaries, the 19 countries fall into two groups: twelve subject to a full suspension of entry and seven subject to partial restrictions. 
Countries subject to full suspension (12):

• Afghanistan
• Burma (Myanmar)
  
• Chad
• Republic of the Congo
• Equatorial Guinea
• Eritrea
• Haiti
• Iran
• Libya
• Somalia
• Sudan
• Yemen

Countries subject to partial restrictions (7):

• Burundi
• Cuba
• Laos
• Sierra Leone
• Togo
• Turkmenistan
• Venezuela

!! NOTE: A case is affected if either the applicant’s country of birth or country of citizenship is one of the 19 designated countries and the applicant has a pending USCIS benefit request (in other words, application). This means the policy is not based only on current citizenship. For example, if you are now a citizen of Canada (or any other non-listed country), but you were born in one of the 19 listed countries, your USCIS application is still subject to the hold.

What USCIS Means by “Benefit Requests” 

The memorandum uses the formal USCIS term “benefit request.” The document states that a benefit request includes all USCIS-adjudicated applications, meaning applications for people that are currently in the United States. This is a USCIS-specific policy, meaning the policy changes do NOT affect applications that are currently going through consular processing abroad. In other words, if you are seeking a visa at an embassy abroad, this new policy does not apply to your case. 

Who Is Subject to the Benefit Request Hold

The benefit-request hold applies to individuals who:

• List one of the 19 countries designated in Presidential Proclamation 10949
• Are identified by country of birth OR country of citizenship
• Have any pending USCIS benefit request
• Regardless of date of entry
• Regardless of current immigration status

The memo also confirms that “entry” includes:

• Admission
• Inspection
• Parole
• Entry without inspection

Lawful presence alone does not remove a case from the hold.

Again, this is a USCIS-specific policy, meaning the policy changes do NOT affect applications that are currently going through consular processing abroad. In other words, if you are seeking a visa at an embassy abroad, this new policy does not apply to your case. 

Approved Applications Are Also Being Re-Reviewed

In addition to holding pending cases, USCIS is required to re-review previously approved applications for covered individuals who entered the United States on or after January 20, 2021.

This re-review process may include:

• Mandatory interviews or re-interviews
• Full re-screening for inadmissibility
• National-security-based eligibility review

The memo explicitly states that interview waivers are not permitted for this population.
 
Duration of This Widespread Hold

The memorandum states that:

• The hold remains in effect indefinitely
• It can only be lifted by the USCIS Director
• Any exception request must receive Director-level or Deputy Director approval
• Litigation alone does not automatically lift the hold -- However, a judge's order can stop this. 
• No public timeline is provided

 
USCIS Acknowledges Processing Delays Are a Known Consequence

USCIS explicitly acknowledges that this policy will cause adjudication delays, but states that such delays are considered necessary and appropriate when weighed against national security objectives.

This means:

• No guaranteed processing window
• No routine expedite relief
• Potential multi-month or longer delays

 
Legal Impact on Immigration Stability

Because this policy affects all pending applications, it directly impacts:

• Adjustment of status applicants
• Lawful permanent residents renewing documentation
• Conditional residents awaiting I-751 approval
• Individuals relying on travel documents
• Residents preserving continuity for future citizenship

What Affected Applicants Should Do Now

If you are in the United States and have any pending USCIS application that falls within this policy’s scope, immediate legal planning is critical:

1. Do not depart the United States without legal review
2. Prepare for possible USCIS interview or re-interview
3. Secure identity, travel, and prior immigration records
4. Avoid additional filings without strategic legal advice
5. Request a formal risk assessment of your case

How Our Law Firm Is Responding

Our office is actively:

• Reviewing pending benefit cases for policy exposure
• Preparing clients for re-interview procedures
• Managing prolonged adjudication delay strategies
• Advising on travel and status-preservation risks
• Monitoring internal USCIS operational guidance as it is issued

 
Final Takeaway

This USCIS directive is not a limited form-specific pause. It is an agency-wide adjudicative hold on all pending applications for individuals meeting the memorandum’s criteria, combined with retroactive re-review authority over prior approvals. 
 
Need Immediate Legal Review?
If you currently have any pending application with USCIS and may be impacted by this policy, please contact us. 

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​Najmeh Mahmoudjafari, Esq.
Najmeh is the Founder and Lead Immigration Attorney at ImmigraTrust Law, an immigration law practice in Orange County, California, representing individual and corporate clients in all 50 U.S. States and internationally. Najmeh can be reached at [email protected].

DISCLAIMER: This article is for general information purposes only. It is not intended and does not constitute legal advice. This article does not create an attorney/client relationship and does not provide an attorney/client privilege. For legal advice about your specific case, please contact an attorney.