United States | USCIS places hold on pending asylum and benefit applications for nationals of certain “high-risk” countries

U.S. Citizenship and Immigration Services issued a “hold and review” policy memorandum on Dec. 2, 2025, effective immediately, directing USCIS personnel to place holds on certain asylum applications and benefit requests and conduct a “comprehensive re-review” of benefit requests for certain foreign nationals from 19 identified “high-risk” countries.

Key Points:

• According to the memorandum, “This guidance outlines the adjudicative hold, procedural requirements and processes for the re-review, interview or re-interview of affected aliens” and includes direction for USCIS personnel to:
  • Place a hold on all Forms I-589, Application for Asylum and for Withholding of Removal, regardless of nationality, pending a comprehensive review.
  • Place a hold on benefit requests for foreign nationals from the 19 “high-risk countries” identified in presidential proclamation 10949 issued on June 4, 2025, pending a comprehensive review.
  • Conduct a “comprehensive re-review” of approved benefit requests for foreign nationals from the 19 high-risk countries who entered the U.S. on or after Jan. 20, 2021.
• The memorandum states, “USCIS will also conduct a comprehensive review of all relevant policies, procedures and operational guidance for compliance, accuracy and needed improvements during this time” and “within 90 days of issuance of this memorandum, USCIS will prioritize a list for review, interview, re-interview and referral to ICE and other law enforcement agencies as appropriate, and, in consultation with the Office of Policy and Strategy and the Fraud Detection and National Security Directorate, issue operational guidance.”
• The hold will remain in effect “until lifted by the USCIS Director through a subsequent memorandum. Any requests to lift the hold due to litigation or other extraordinary circumstances must receive approval from the USCIS Director or Deputy Director.”

Additional Information: BAL will continue to monitor related policy developments and provide updates.

This alert has been provided by the BAL U.S. Practice Group.

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