On Jan. 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a new policy memorandum—PM-602-0194: Hold and Review of USCIS Benefit Applications Filed by Aliens From Additional High-Risk Countries—that has had wide-ranging effects on immigration benefit processing. This guidance builds on the expanded travel restrictions under Presidential Proclamation 10998 (PP 10998), Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States, signed on Dec. 16, 2025, and effective Jan. 1, 2026.
PM-602-0194 directs USCIS officers to take three main actions:
- Place a holdon all pending benefit applications, subject to certain exceptions and regardless of entry date, for nationals of the countries listed in PP 10998, pending a comprehensive review;
- Conduct a comprehensive review of all policies, procedures, and screening and vetting processes for benefits requests for nationals of countries listed in PP 10998; and
- Conduct a comprehensive re-review of approved benefit requests for nationals of countries listed in PP 10998 that were approved on or after Jan. 20, 2021.
Now that almost 60 days have passed since the announcement, applicants may be seeing the effects of the policy in delayed applications, and in some cases requests for additional evidence that USCIS might consider in determining whether to exercise favorable discretion.
Who Is Impacted?
The hold and comprehensive review now apply to nationals of all countries listed in PP 10998. This expanded list includes (among others):
- Afghanistan
- Angola
- Antigua and Barbuda
- Benin
- Burkina Faso
- Burma (Myanmar)
- Chad
- Côte 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
- Zimbabwe
Individuals with Palestinian Authority–issued or endorsed travel documents are also included. This means the policy applies based on nationality, country of birth, or citizenship acquired through Citizenship-by-Investment (CBI) programs.
Exceptions
PM-602-0194 allows USCIS to continue adjudicating certain categories of benefit requests, including:
- Individuals with a pending Form I-90, Form N-565, and Form N-600;
- "Benefit requests that are a priority for law enforcement and where [Immigration and Customs Enforcement] has requested that USCIS take adjudicative action to uphold public safety or national security;"
- Form I-765, categories(c)(11) for an alien paroled into the United States in the public interest or temporarily for emergency reasons and (c)(14) for an alien granted deferred action only when the request comes from law enforcement because the noncitizen is assisting law enforcement;
- Initial Form I-765, category (c)(8) for an asylum applicant (with a pending asylum application) who filed for asylum on or after Jan. 4, 1995;
- Benefit requests for individuals whose entry would serve a United States national interest;
- Benefit requests for athletes or members of an athletic team, including the coaches, persons performing a necessary support role, and immediate relatives for the purpose of participating in the World Cup, Olympics, or other major sporting event as determined by the secretary of state;
- Benefit requests, or associated underlying benefits, for any programs that are terminated or discontinued as a result of an executive order, proclamation, Federal Register notice, or directive issued by the president, the secretary of homeland security, or the USCIS director; and
- Decisions to automatically terminate automatic or ancillary benefit requests related to when an individual is granted legal permanent resident status or becomes a naturalized citizen.
The exceptions to the policy are limited and may not apply to many applicants. Moreover, almost 60 days have passed since this policy was announced and there are no further updates as to when these applications may go back into normal processing. Without any meaningful update from USCIS, applicants from the affected countries may continue to experience significant delays and/or additional USCIS scrutiny in the adjudication of their cases, irrespective of whether the applicant or beneficiary is inside or outside the United States.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
