USCIS hold on immigration applications and Re-Reviews Immigration Benefit Applications for Nationals of Additional High-Risk Countries
- rottierlawoffice

- 2 days ago
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On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum titled “Hold and Review of USCIS Benefit Applications Filed by Immigrants From Additional High-Risk Countries.” USCIS hold on immigration applications expands the adjudications pause previously tied to Presidential Proclamation 10998, issued on December 16, 2025, which restricts and limits the entry of certain foreign nationals based on national security concerns.
Under this new guidance, USCIS has expanded the pause on adjudicating immigration benefit applications beyond the original 19 travel ban countries and has initiated a broad review of both pending and recently approved cases.
What the USCIS Memo Does
Effective immediately, USCIS officers are instructed to:
Place a hold on all pending immigration benefit applications filed by nationals of countries listed in Presidential Proclamation 10998, regardless of the applicant’s date of entry, subject to limited exceptions;
Conduct a comprehensive review of USCIS policies, procedures, and screening and vetting processes for benefit requests filed by nationals of the listed countries; and
Re-review previously approved benefit requests for nationals of these countries that were approved on or after January 20, 2021.
This means that even applicants who have already received approvals may face renewed scrutiny under the new directive.
Countries Subject to the Adjudicative Hold and Re-Review
Nationals of the following countries are subject to the adjudicative hold and comprehensive re-review:
Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Côte d'Ivoire, Cuba, Dominica, Republic of the Congo, 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, individuals holding Palestinian Authority-issued or Palestinian Authority-endorsed travel documents are also subject to the adjudicative hold and re-review.
Exceptions to the Adjudicative Hold
USCIS has identified limited categories of benefit requests that are exempt from the adjudicative hold, including:
Pending Form I-90, Form N-565, and Form N-600 applications;
Benefit requests prioritized for law enforcement purposes where ICE has requested USCIS action to support public safety or national security;
Form I-765 applications in categories (c)(11) and (c)(14) only when filed at the request of law enforcement due to the applicant’s assistance;
Initial Form I-765 applications in category (c)(8);
Benefit requests where the applicant’s entry would serve a U.S. national interest; and
Benefit requests for athletes, athletic team members, coaches, essential support personnel, and immediate relatives traveling to participate in the World Cup, Olympics, or other major international sporting events, as determined by the Secretary of State.
All other benefit requests remain subject to the hold unless an exception clearly applies.
USCIS hold on immigration applications - what this Means for Applicants
This policy creates significant uncertainty for affected individuals and families. Pending cases may remain on hold indefinitely, and previously approved applications may be reopened for further review. At this time, USCIS has not provided a timeline for completion of these reviews or for when normal adjudications may resume.
Given the complexity and evolving nature of this policy, applicants should not assume their case will proceed normally, even if they have already received an approval notice.
How Our Office Can Help
Our office is closely monitoring USCIS implementation of this directive and advising clients on:
Whether an exception may apply to their case
Risks associated with pending or recently approved benefits
Strategic options while cases are on hold
National interest and law enforcement-related exemptions
If you or a family member may be affected by this USCIS adjudications pause, we encourage you to contact our office for an individualized legal analysis to determine the best course of action under these new restrictions.



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