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USCIS Imposing Significant Additional Processing Restrictions on Various USCIS Benefits Applications

December 2, 2025

In light of the recent National Guard member shooting, the Trump administration has implemented several significant immigration related restrictions.   USCIS released  its official policy guidance on December 2, 2025.

The guidance includes the following:

• USCIS will place a hold on all Forms I-589 (Application for Asylum and for Withholding of Removal), regardless of the applicant’s country of nationality, pending a comprehensive review;
• USCIS will place a hold on pending benefit requests for foreign nationals from countries listed in the Presidential Proclamation (PP) 10949 travel ban, including anyone born in one of those countries, pending a “comprehensive review” and regardless of entry date.   These countries include: Afghanistan, Burma, Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan and Venezuela.
• USCIS will conduct a comprehensive re-review of approved benefit requests for foreign nationals from countries  listed in PP 10949  who entered the United States on or after January 20, 2021.

Importantly, USCIS indicates in the memorandum that the “pending benefit requests” include the following:

• Form I-485 (Application to Register Permanent Residence or Adjust Status),
• Form I-90 (Application to Replace Permanent Resident Card (Green Card)),
• Form N-470 (Application to Preserve Residence for Naturalization
  Purposes),
• Form I-751, (Petition to Remove Conditions on Residence), and
• Form I-131 (Application for Travel
  Documents, Parole Documents, and Arrival/Departure Records).

USCIS has indicated in internal guidance that the pause should be inferred as including but not limited to the above listed applications.  As such, it is possible that the pause will extend to employment based I-129 and I-140 petitions as well as all I-765 employment authorization document applications.

USCIS has halted decision making on all benefits applications for nationals of the countries included in the travel ban, including anyone born in but no longer a citizen of one of the 19 banned countries.

Pursuant to this memorandum, any impacted foreign nationals meeting this criteria “will undergo a thorough re-review process, including a potential interview and, if necessary, a re-interview, to fully assess all national security and public safety threats along with any other related grounds of inadmissibility or ineligibility.   An individualized, case-by-case review and assessment will be done of all relevant information and facts.”

USCIS stated that the hold on these applications will remain in effect until lifted by the USCIS Director through a subsequent memorandum.

We will be closely following these recent restrictions and providing updates as they become available.

To discuss what this may mean for your case, please contact the attorney at LHSCD working on your case. Alternatively, you may set up a consultation with one of our attorneys by filling out our Consultation Request Form.