On January 1, 2026, USCIS issued a Policy Memorandum to place a hold on all pending benefit applications for noncitizens listed Presidential Proclamation 10998. This Memorandum expands the existing USCIS processing hold to include the countries added to the high-risk country list on December 16.
Additionally, USCIS will conduct a comprehensive review of all policies and procedures for benefit requests from citizens of the high-risk countries and conduct a comprehensive re-review of all approved benefit requests that were approved on or after January 20, 2021.
The case-by case review will assess benefit eligibility including whether:
- The noncitizen is listed in the Terrorist Screening Dataset in Tier 1, 2, or 3;
- The noncitizen is connected to prior, current, or planned involvement or association with an activity, individual, or organization described in INA 212(a)(3)(A), (B), or (F) or INA 237(a)(4)(A) or (B);
- The noncitizen is liked to prior, current, or planned association with an activity, individual, or organization that may pose a risk of serious harm or danger to the community, including criminal conduct described in INA 101(a)(43), INA 212(a)(1)(A)(iii), INA 212(a)(2), INA 237(a)(2), or INA 237(a)(4)(A)(ii); and
- The noncitizen is unable to establish identity as outlined in PP 10949 and PP 10998.
Exceptions to the hold on processing include the following forms and circumstances:
- Form I-90;
- Form N-565;
- Form N-400;
- Form I-765 filed under (c)(8) as an initial filing or limited (c)(11) and(c)(14) categories where requested by law enforcement;
- Form I-910;
- Requests filed by athletes or members of athletic teams for purposes of participating in the World Cup, Olympics, or other major event;
- Requests that are a priority for law enforcement and where ICE has requested USCIS take action;
- Requests by noncitizens whose entry would serve a U.S. national interest;
- Requests for programs that are terminated or discontinued; and
- Automatic terminations for ancillary benefit requests when a noncitizen is granted LPR status.
