December 05, 2025
Important Update – USCIS “Hold and Review” Memo Affects Asylum & Benefit Applications for “High-Risk Countries” (and may impact naturalization applications)
On December 2, 2025, USCIS issued Policy Memorandum PM-602-0192 — titled “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries.”
What does the memo do
- It places an immediate hold on all pending asylum applications (Form I-589) — irrespective of the applicant’s nationality.
- It orders a hold on all pending benefit applications filed by individuals from the 19 “high-risk” countries identified under 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.”
- For individuals from those “high-risk” countries whose benefit requests already were approved, and who entered the U.S. on or after January 20, 2021, the memo mandates a comprehensive review of previous approvals, including possible re-interviews.
- The “high risk” countries are Afghanistan, Burma (Myanmar), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.
- It is possible that additional countries will be added to this list.
Potentially affected filings
The memo explicitly refers to “USCIS benefit applications” and specifically names the following forms: I-485 adjustment of status, I-90 green-card renewals, N-470 application to preserve residence for naturalization purposes), I-751residency-condition removal petitions, and I-131 travel authorizations.
There are also reports that naturalization interviews or swearing in ceremonies for individuals from the affected countries were canceled earlier this week.
What this may mean for you or your family
- If you or a family member has a pending asylum application — expect indefinite delays.
- If you have a pending benefit request and you are from one of the “high-risk” countries — your application is likely on hold.
- If you (or a family member) submitted or plan to submit a naturalization application — there is a strong chance that USCIS will pause or delay processing under this broader hold, if the applicant is from a high-risk country.
- Even previously approved benefits for individuals from the affected countries may be subject to re-review or re-interview — which could jeopardize approvals or trigger additional scrutiny.
What you should do now
- For clients from “high-risk” countries, gather and organize all relevant documentation (identity, address history, background checks, travel, etc.) in anticipation of possible re-interviews or evidentiary requests.
- If you are a citizen or national of one of the “high risk” countries and considering filing new immigration applications — it may be prudent to consult with an attorney before doing so.
Bottom line: PM-602-0192 represents a sweeping and unexpected freeze on asylum and many benefit filings, and — according to public reporting — may impact naturalization applications from individuals from affected countries. If you or any family member may be affected, please contact us so that we can advise tailored next steps.