On December 2, 2025, the U.S. Citizenship and Immigration Services (USCIS) issued a Policy Memorandum to hold and review all pending Asylum applications and all USCIS Benefit applications “filed by aliens from high-risk countries.”
Policy Memorandum Details
Effective immediately, this memorandum directs USCIS personnel to:
- 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;
- Place a hold on pending benefit requests for applicants from countries listed in Presidential Proclamation (PP) 10949, Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, pending a comprehensive review, regardless of entry date; and
- Conduct a comprehensive re-review of approved benefit requests for applicants from countries listed in PP 10949 who entered the United States on or after January 20, 2021.
Source: USCIS Policy Memorandum PM-602-0192
Countries listed in Presidential Proclamation 10949
On June 4, 2025, President Trump issued a proclamation restricting citizens from the following countries from entering the United States.
Fully restricted:
- Afghanistan
- Chad
- Republic of the Congo
- Equatorial Guinea
- Eritrea
- Haiti
- Iran
- Libya
- Myanmar
- Somalia
- Sudan
- Yemen
Partially restricted:
- Burundi
- Cuba
- Laos
- Sierra Leone
- Togo
- Turkmenistan
- Venezuela
These are the 19 countries referred to in this Policy Memorandum.
Additional Considerations for H-1B and H-4
The U.S. Department of State also issued an announcement regarding additional screening and vetting for H-1B and dependent H-4 visa applications. Starting on December 15, 2025, all H-1B applicants and their dependents will be subject to an “online presence review.” All social media profiles must be set to “public” to facilitate this.
This will be in addition to the students and exchange visitors already subject to this review.
Additional Considerations for Employment Authorizations
In addition to the Policy Memorandum and announcement detailed above, USCIS has also updated its Policy Manual to reduce the maximum validity period for Employment Authorization Documents (EAD) for certain categories of applicants.
This will result in more frequent vetting of applicants who apply for authorization to work in the United States.
The maximum validity period for initial and renewal EADs will be changed from 5 years back to 18 months for several categories of applicants:
- Applicants admitted as refugees;
- Applicants granted asylum;
- Applicants granted withholding of deportation or removal;
- Applicants with pending applications for asylum or withholding of removal;
- Applicants with pending applications for adjustment of status under INA 245; and
- Applicants with pending applications for suspension of deportation, cancellation of removal, or relief under the Nicaraguan Adjustment and Central American Relief Act.
This change affects those with applications for employment authorization that are pending or filed on or after Dec. 5, 2025, and based on any of the above categories.
What this means for employers and applicants
- Anticipate extended timelines: Expect more extensive background and security checks.
- Gather additional documentation: There may be requests for additional documents or clarification about eligibility.
- Expect lengthier interviews: Prepare for follow-up interviews or re-interviews from USCIS.
- Consult counsel: Before international travel, consult counsel especially where advanced parole or re-entry permits are on hold.
- Facilitate additional processes: If you are an H-1B applicant or dependent, ensure your social media accounts are publicly viewable.
- Monitor USCIS updates: USCIS is expected to issue further guidance in the coming weeks that may clarify exemptions and implementation details.
We recommend that employers and applicants monitor updates from immigration agencies.
We are here to help
If you would like assistance assessing how this may affect your immigration matters – including filing strategies, compliance planning, or addressing urgent deadlines – please contact the KLF immigration professional with whom your normally work or call us on our main line at (212) 495-9245 or email us at info@klugfirm.com.
Disclaimer: This Client Alert is for general information purposes only; it does not constitute legal advice. Actual application of laws and policies may vary based on your specific facts.