Immigration

United States | Reports indicate Trump administration to issue travel ban

Summary

Over the past two weeks, several news reports have been circulating that the Trump administration plans to issue a travel ban that will impact noncitizens from numerous countries. While the administration has not publicly announced that a ban will be issued nor is there an official date, several news outlets are reporting that an announcement is imminent.

The detail

According to several news reports, the Trump administration is considering issuing a sweeping travel ban that could impact noncitizens from 43 countries. News outlets have reported viewing an internal memo that outlines proposed parameters on restricting the issuance of visas and on admission to the United States by noncitizens of certain defined countries. It is unclear when the draft will be finalized and issued, but it could be issued by the end of this week.

The internal memo lists a total of 43 impacted countries divided into three separate groups. The first group (Group 1) includes Afghanistan, Bhutan, Cuba, Iran, Libya, North Korea, Somalia, Sudan, Syria, Venezuela, and Yemen. This group would be set for a full visa suspension, meaning noncitizens from these countries would not be allowed to enter the United States, regardless of their visa status. It is unclear if noncitizens from these countries, who hold US green cards, would also be impacted by the proposed ban.

Group 2 includes Belarus, Eritrea, Haiti, Laos, Myanmar, Pakistan, Russia, Sierra Leone, South Sudan, and Turkmenistan. Noncitizens from this group of countries would face partial suspension that would impact tourist visas, student visas and some immigrant visas.

For both groups, it is unclear whether a process for exceptions or waivers will be implemented that would be similar to a waiver process developed for travel bans issued during the first Trump administration.

Finally, Group 3 will include the following countries: Angola, Antigua and Barbuda, Benin, Burkina Faso, Cambodia, Cameroon, Cape Verde, Chad, Republic of Congo, Democratic Republic of Congo, Dominica, Equatorial Guinea, Gambia, Liberia, Malawi, Mali, Mauritania, St. Kitts and Nevis, St. Lucia, São Tomé and Príncipe, Vanuatu, and Zimbabwe. For this group, the administration is providing the identified countries with 60 days to address deficiencies related to security and screening of their citizens. If the Trump administration is dissatisfied with the security measures taken by these countries, their citizens may be subject to a visa suspension at a future date.

It has also been reported that the list of countries has not been finalized and could change prior to issuance.

Context behind proposed travel ban

If the Trump administration issues an Executive Order restricting visa issuance and limiting admission to the United States, it will be a result of the January 20, 2025 Executive Order 14161, “ The United States From Foreign Terrorists And Other National Security And Public Safety Threats”, which directed the Secretary of State, the Attorney General, the Secretary of Homeland Security, and the Director of National Intelligence to jointly submit a recommendation list of high-risk countries within 60 days (March 21, 2025; an earlier deadline of March 12th was later reported).

Specifically, Executive Order 14161 directed the agencies to: (1) identify countries “for which vetting and screening information is so deficient as to warrant a partial or full suspension on the admission of nationals from those countries pursuant to section 212(f)” of the Immigration and Nationality Act (INA) (8 USC § 111182(f)) and (2) identify “how many nationals from those countries have entered or have been admitted to the United States on or since January 20, 2021”.

What this means

If the travel bans are implemented, it will impact the ability of noncitizens from those countries to travel to or leave the United States. Vialto will provide further information once the administration officially announces the issuance of any travel bans in the coming weeks. In the meantime, companies with noncitizens that could be impacted by the proposed travel ban should consider advising their employees to limit international travel or return to the US if currently abroad.

In addition, companies should consider how to frame any messaging for leadership and whether contingency planning is needed. This will be dependent on the nationalities of employees who already live and work in the US or are due to travel soon. If you employ/expect to employ nationals of these countries you should consider the following:

1. Identify potentially impacted employees and decide whether leadership needs to be briefed on the risk that future employee travel may lead to a ban from returning to the US.
2. For Groups 1 and 2, no further action at this stage, but your messaging might include the need to send or relocate employees to other jurisdictions, where there is a business need. You may wish to begin that planning now, if you have a high number of potentially impacted employees.
3. Nationals of Groups 1 and 2 should also be advised not to leave the US in the near future. Those who are already outside of the US should be advised to return immediately.
4. If/when the ban takes effect you will need to update your business travel processes and policies.

Vialto will be hosting a webinar to help you navigate the latest changes in US immigration, including the issuance of any travel bans. The webinar will be on Wednesday, March 26th at 12:30 EDT and you can register here.

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Manish Daftari
Partner

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