Immigration

United States | USCIS expands hold on all pending immigration benefit requests from designated countries 

Summary

US Citizenship and Immigration Services (USCIS) issued a Policy Memorandum PM-602-0194 effective January 1, 2026, expanding its hold-and review policy for certain pending and approved immigration benefit applications tied to “high-risk” countries. The memorandum adds countries designated in Presidential Proclamation 10998 to the existing restrictive adjudication framework, directs expanded holds on pending benefit requests, and mandates re-review of some previously approved benefits for nationals or birth-country nationals of these countries. The policy also reinforces the pause on asylum application processing, subject to comprehensive review.

The detail

USCIS’s expanded policy aligns with the US government’s travel ban framework, now encompassing a larger set of “high-risk” countries identified in Presidential Proclamation 10998 (issued Dec. 16, 2025). The policy builds on an earlier December 2, 2025 memo that placed holds and reviews on benefit applications for nationals from 19 designated countries. The latest Proclamation broadens the list to include countries newly added under the expanded travel ban and provides updated procedural guidance.

A total of 39 countries are included in the newly expanded list: Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Republic of Congo, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, The Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe. In addition, foreign nationals who seek to travel to the United States using Palestinian Authority-issued or endorsed travel documents are subject to the travel ban and to any travel ban-related USCIS policies.

Key policy actions

• Adjudicative hold on pending benefit applications: USCIS will place a hold on all pending immigration benefit requests filed by or for foreign nationals who were born in or are citizens of the expanded list of high-risk countries. Cases may be reviewed internally, but no final approval, denial, or dismissal will be issued while the hold remains in effect. USCIS may continue non-final processing steps such as issuing RFEs or NOIDs.
• Re-review of previously approved benefits: Benefit requests for individuals from the expanded high-risk list that were approved on or after January 20, 2021 are subject to comprehensive re-review, potentially including interviews and further compliance checks. USCIS may extend review beyond this timeframe when appropriate. It is important to note that the January 1 memorandum calls for a re-review of approved benefit requests if the approval occurred on or after January 20, 2021, whereas the USCIS’s December 2025 memorandum relating to the earlier June travel ban (which remains in effect) requires review of approved cases if the foreign national entered the country on or after January 20, 2021.
• Asylum processing paused: The earlier policy placing all pending Form I-589 (asylum and withholding of removal) applications on hold regardless of nationality is maintained, and asylum adjudication remains paused pending review.

Exceptions to the adjudicative hold

The expanded memorandum lists specific exceptions where the adjudicative hold does not apply. These include, but are not limited to:

• Form I-90 (replacement of permanent resident cards)
• Form N-565 and certain N-600 applications (with limited exceptions for specific countries)
• Some I-765 categories (e.g., (c)(8) asylum-based, limited (c)(11) and (c)(14) categories)
• Civil surgeon designation applications (I-910)
• Benefit requests tied to national interest
• Cases prioritized by law enforcement authorities
• Individuals participating in certain international sporting events and support roles

Implementation and operational guidance

USCIS will implement the expanded hold-and-review processes immediately. Within 90 days of the memorandum’s issuance, the agency will prioritize lists for review, interview, or re-interview and issue further operational guidance in consultation with internal security directorates.

The Impact and considerations

Affected applicants and petitioners including those awaiting adjudication of employment-based petitions, change of status requests, work authorizations (e.g., OPT/STEM OPT), and other benefit categories should anticipate extended processing times, potential additional vetting, and re-evaluate filing strategies. Employers, counsel, and applicants should monitor forthcoming operational guidance for procedural and timing details. Vialto will continue to monitor the impact of the new USCIS guidance and will provide further information as it becomes available.

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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