On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum placing a temporary hold on certain immigration benefit applications filed by individuals connected to newly designated “high-risk” countries. This policy follows Presidential Proclamation 10998 and expands existing national security-related review measures.

What the New Policy Does

Under this memorandum, USCIS officers are required to place an adjudicative hold on all pending immigration benefit applications filed by individuals associated with countries listed in Presidential Proclamation 10998. While USCIS may continue processing these cases, final decisions—such as approvals or denials—cannot be issued until the hold is lifted.

USCIS will also conduct a re-review of certain approved applications, specifically those approved on or after January 20, 2021, if the applicant falls within the scope of the proclamation. In addition, the agency is reviewing its overall screening and vetting procedures for applicants from these countries.

Importantly, family-based immigrant visa applications are no longer broadly exempt and are now subject to the same heightened scrutiny as other benefit requests.

Why USCIS Implemented This Policy

USCIS states that this policy is driven by national security and public safety concerns. According to the agency, some countries identified in the proclamation lack reliable systems for identity verification, criminal background documentation, and information sharing with U.S. authorities.

As a result, USCIS has determined that enhanced review—and the resulting processing delays—are necessary to ensure applicants are thoroughly vetted and that immigration benefits are granted in compliance with U.S. law.

How Applications Will Be Reviewed

Cases subject to the hold will be reviewed on a case-by-case basis and may involve additional scrutiny, interviews, or re-interviews. USCIS officers are instructed to consider factors such as:

• Whether the applicant appears in terrorism-related screening databases

• Any connections to criminal, terrorist, or dangerous organizations

• Serious criminal history or public safety concerns

• The applicant's ability to reliably establish identity using civil documents

Cases may remain on hold until USCIS issues further guidance lifting or modifying the policy.

Limited Exceptions to the Hold

Although the policy is broad, USCIS has identified narrow exceptions that may proceed despite the hold. These include, among others:

• Certain document replacement applications, such as green card or citizenship document replacements

• Limited employment authorization categories, including specific asylum-related filings

• Applications related to major international athletic events

• Cases determined to serve a U.S. national interest or prioritized by law enforcement

Each exception is applied narrowly and may require additional coordination or approval.

What This Means for Applicants

This policy does not automatically result in denial of an application. However, affected individuals should expect:

• Longer processing times

• Increased scrutiny of documentation and background information

• Possible requests for additional evidence or interviews

• Re-examination of some previously approved cases

Applicants should be prepared for delays and uncertainty while USCIS conducts these reviews.

How Our Firm Can Help

Immigration cases involving heightened security review can be complex and stressful. Our firm closely monitors USCIS policy developments and assists clients in understanding how new guidance may affect their applications. We help clients prepare for additional scrutiny, respond to USCIS requests, and evaluate options when cases are delayed or placed on hold.

If you believe this policy may impact you or a family member, we encourage you to consult with an experienced immigration attorney to discuss your situation.