President Donald Trump signed a proclamation Friday suspending entry of Chinese nationals seeking to enter the U.S. on an F or J visa to study or conduct research in the U.S. if they have connections to an entity in China that implements or supports the country’s “military-civil fusion strategy.” Chinese nationals coming to the U.S. to pursue undergraduate study are not subject to the restrictions.

Key points:

  • The proclamation will take effect June 1 at 12 p.m. ET and will remain in effect until terminated by the president.
  • To be subject to the proclamation, an individual must currently receive funding from or be employed by, study at, or conduct research at or on behalf of, an entity in China that implements or supports the country’s military-civil fusion strategy; or have done so in the past.
  • The proclamation defines “military-civil fusion strategy” as actions by or at the behest of China to acquire and divert foreign technologies, specifically critical and emerging technologies, to incorporate into and advance China’s military capabilities.
  • The order requires the State Department to consider whether to revoke visas of Chinese nationals currently in the U.S. on F or J visas who meet the criteria in the proclamation. It also directs the immigration agencies to review nonimmigrant and immigrant programs and provide recommendations within 60 days on other measures to mitigate the risk posed by China’s acquisition of sensitive U.S. technologies and intellectual property.
  • Exempt from the entry suspension are: students pursuing undergraduate study; those who are studying or conducting research in a field involving information that would not contribute to the country’s military-civil fusion strategy, as determined by the U.S. government; and people whose entry would be in the national interest.

BAL Analysis: Entry of foreign nationals who have been physically present for a 14-day period in China is currently restricted, which means the impact of this proclamation may not be clear for some time. The restrictions on entry will apply only to Chinese nationals who are outside the U.S., though the State Department has discretion to cancel or revoke visas of individuals who are currently in the U.S. so that they cannot re-enter. If the State Department does revoke the visa of a person in the U.S., the visa revocation would only affect future travel and would not rescind the student’s status. The proclamation does not indicate whether or not the restrictions will apply to students who are seeking to enter the U.S. to work under post-graduation Optional Practical Training (OPT). BAL is continuing to review the proclamation and will provide additional analysis in the coming days.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) is a step closer to issuing a final regulation that would increase immigration-related government filing fees. The agency sent the final regulation to the Office of Management and Budget (OMB) Wednesday, the last stage in the rulemaking process.

Key points:

  • The text of the final rule is not yet available, so its contents and the precise amount of the USCIS fee increases have not been made public and could differ from the proposed version that was released in November and amended in December.
  • According to the proposed version of the rule, USCIS filing fees would increase overall and petitions for nonimmigrants would vary according to visa type. Filing fees for H-1B petitions would increase up to 22% and L-1 petitions by up to 77%. The proposed version would also impose hefty new fees on companies whose workforce consists of a large percentage of H-1B and L-1 workers.

Background: The USCIS move to finalize the rule comes as the agency seeks $1.2 billion in emergency funding from Congress to make up for a revenue shortfall because of COVID-19. The agency said it would run out of money this summer without an injection of funding and is reportedly considering imposing a surcharge on petitions and applications to cover the shortfall.

BAL Analysis: After OMB completes its review, the rule will be posted for public inspection on the Federal Register website before being officially published. The rule has been classified as a major rule and is expected to have a 60-day delayed effective date. The impact of the regulation will depend on how it is drafted, and it is not yet known whether the agency made changes from the proposed version. Since the proposed rule included significant policy changes, the final rule could be subject to litigation. BAL is closely monitoring the progress of the regulation and will provide additional analysis when the text is published.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

A White House proclamation imposing an entry ban on foreign nationals who have been in Brazil in the past two weeks took effect Tuesday. It is one of a number of COVID-19 travel restrictions that remain in effect even as states, localities and businesses move to reopen.

Current restrictions are as follows:

  • Country-based entry restrictions. Travel from Brazil, China (not including Hong Kong or Macau), Iran, Ireland, the United Kingdom and any of Europe’s 26-member Schengen Area countries is restricted. Foreign nationals who have been in any of these countries within 14 days of attempting to enter the United States will be denied entry. The restrictions do not apply to U.S. citizens, lawful permanent residents, foreign national spouses of U.S. citizens or lawful permanent residents, certain family members of U.S. citizens or lawful permanent residents, foreign nationals whose entry is in the U.S. national interest or a limited number of others. The restrictions are indefinite and will remain in effect until the president terminates them.
  • Immigrant visa entry ban. Entry of immigrant-visa applicants is suspended. This suspension only applies to entry on immigrant (i.e., permanent) visas and does not apply to temporary visas (e.g., H-1B, L-1 or other nonimmigrant visa categories). The order only applies to applicants who were outside the U.S. and did not have a visa or other type of travel document permitting them to travel to the U.S. when the suspension took effect on April 23. In addition, a number of categories of people are excluded from the suspension, including spouses and unmarried children under 21 of U.S. citizens, healthcare professionals working to combat the COVID-19 pandemic, those applying for EB-5 immigrant investor visas, individuals whose entry is in the national interest, individuals who would further U.S. law enforcement objectives, members of the U.S. Armed Forces and a limited number of others. The suspension is in effect until June 22 and may be extended. Because most routine consular services remain suspended, the impact of this proclamation will likely depend on whether it is extended beyond 60 days.
  • Visa services and travel abroad. Routine visa services at embassies and consulates around the world are suspended. It is not clear when normal visa services will resume or how they will be affected by COVID-19 safety protocols when they do. The U.S. State Department has directed those requiring emergency appointments to follow guidance posted on the relevant embassy website. The department has also issued a worldwide level 4 travel advisory, urging Americans to avoid international travel at this time.
  • Land borders with Canada and Mexico. Non-essential travel across the U.S. borders with Canada and Mexico is suspended. The list of individuals permitted to engage in “essential travel” includes U.S. citizens and lawful permanent residents returning to the United States; and people traveling to work in the United States (e.g., agricultural workers), engaging in lawful cross-border trade (e.g., truck drivers transporting goods), or traveling to attend school, receive medical treatment, for public health purposes, or a limited number of other reasons. The restrictions do not include air or sea travel, but do apply to passenger rail, passenger ferry travel and pleasure boat travel. The restrictions are in place until June 22, but may be extended, rescinded or modified.

BAL Analysis: Travel to the U.S. remains limited by country-based entry bans, the suspension of entry for immigrant visa applicants, limitations on consular services abroad, and the suspension of non-essential travel across the U.S.-Canada and U.S.-Mexico borders. Employers should account for affected employees and reschedule travel if necessary. BAL continues to closely monitor COVID-19 related developments, including potential new restrictions, and will provide updates as new information becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

News reports indicate that the Trump administration is planning to cancel the visas of thousands of Chinese graduate students whom the administration believes have ties to the Chinese military.

Few details about the plan are available at this time, but it appears likely that the initial push would target a small fraction of the overall number of Chinese F-1 visa holders in the United States. It is not clear at this time whether additional vetting may be imposed at U.S. consulates for Chinese students looking to come to the U.S.

An official announcement is expected soon. While the administration has broad authority to cancel or revoke visas, doing so may not directly impact the ability of individuals already in the country to work and study in the U.S., as long as they do not leave the country. BAL will continue to follow this matter and will provide additional information to clients as it becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

U.S. Citizenship and Immigration Services (USCIS) announced Wednesday that it is preparing to reopen some of its domestic offices and resume non-emergency public services June 4.

In March, USCIS temporarily closed its offices to the public and suspended non-emergency public services because of the COVID-19 pandemic. USCIS said Wednesday that information on the status of individual offices will be posted on the agency’s office closings page.

Services will be rescheduled as follows:

  • Interviews and appointments. USCIS will send notices to applicants and petitioners who had appointments canceled because of the COVID-19 closures. Applicants will be required to reschedule their appointments through the USCIS Contact Center once field offices reopen. Applicants should check the office closings page to see whether their local office is open before calling the contact center.
  • Application Support Centers. USCIS will reschedule ASC appointments that were canceled. Applicants will receive a notice in the mail detailing specific safety requirements for their visit. Those who appear at a time or date other than the one listed on their appointment notice will likely face significant delays.
  • Naturalization ceremonies. USCIS will send notices to applicants who had a naturalization ceremony postponed because of the closures. Ceremonies will be shorter than normal, and attendance will be limited to naturalization candidates and those providing assistance to disabled individuals.
  • Asylum interviews. USCIS asylum offices will reschedule asylum interviews that were canceled and will send applicants a new interview notice with a new time, date and location for the interview. Interviews will be completed in accordance with social distancing guidelines, including the use of video-facilitated interviews with the interviewer and applicant in separate rooms.

Guidelines for visitors: USCIS provided guidelines for entering USCIS facilities, saying that visitors should not enter a USCIS facility more than 15 minutes before their appointment (or 30 minutes for a naturalization ceremony), that hand sanitizer will be provided and that members of the public must wear a facial covering. Applicants should also bring their own pens (blue or black ink).

Anyone who has COVID-19 symptoms, has been in close contact with someone who has (or is suspected to have) COVID-19, or who has been directed to self-isolate will not be permitted to enter a USCIS facility. The agency stressed that there is no penalty for applicants who have to reschedule appointments because they are sick. Additional information about visiting USCIS facilities is available here.

Revenue shortfall: The announcement about reopening came after USCIS asked Congress for $1.2 billion in emergency funding to make up for a shortfall in revenue because of COVID-19. The agency said it would run out of money this summer without an injection of funding and is reportedly considering imposing a surcharge on petitions and applications to cover the shortfall.

BAL Analysis: While some USCIS offices are moving toward reopening, services will be limited as some offices are likely to remain closed and others will adhere to new safety measures. Additional information on which offices will reopen is expected soon. BAL continues to monitor USCIS’s operations and funding status and will provide information as it becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The White House has amended its May 24 proclamation banning entry of foreign nationals who have recently been in Brazil, changing the implementation date to today, May 26. Previously, it was set to take effect Thursday.

Key points:

  • The ban will take effect tonight at 11:59 p.m. Eastern Daylight Time. It will not apply to travelers aboard flights that depart for the United States before that time.
  • The ban applies to foreign nationals who have been physically present in Brazil within the 14 days preceding their intended entry into the U.S.
  • The ban does not apply to U.S. citizens, lawful permanent residents, foreign national spouses of U.S. citizens or lawful permanent residents, certain family members of U.S. citizens or lawful permanent residents, foreign nationals whose entry is in the U.S. national interest or a limited number of others.
  • The proclamation will remain in effect until the president terminates it.

Background: The White House issued its initial proclamation on travel from Brazil on Sunday, citing the ongoing widespread transmission of COVID-19 in Brazil. As of this morning, the World Health Organization reported that Brazil had 363,211 confirmed cases, the second highest number of cases after the United States.

BAL Analysis: Employers should account for affected employees and reschedule travel if necessary. BAL is closely monitoring COVID-19 developments and will update clients as new information becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

 

The White House issued a proclamation today imposing a travel ban on travelers who have recently been to Brazil.

Key points:

  • Foreign nationals who have been physically present in the Federative Republic of Brazil within the 14 days preceding their intended entry into the U.S. will be barred from entry.
  • The ban does not apply to U.S. citizens. Others who are exempt include: lawful permanent residents; foreign spouses of U.S. citizens or lawful permanent residents; certain family members of U.S. citizens or lawful permanent residents; foreign nationals whose entry is in the U.S. national interest; and a limited number of other categories of people.
  • The proclamation takes effect Thursday, May 28 at 11:59 p.m. Eastern Daylight Time. The proclamation does not apply to travelers aboard a flight scheduled to arrive in the U.S. that departed before the proclamation takes effect.
  • The proclamation will remain in effect until terminated by the president.

Background: The proclamation cites ongoing widespread transmission of COVID-19 in Brazil. As of May 23, the World Health Organization reported that Brazil had 310,087 confirmed cases, the third highest number of confirmed cases in the world after the U.S. and Russia.

BAL Analysis: Employers should account for affected employees and reschedule travel if necessary. BAL is closely monitoring COVID-19 developments and will update clients as new information becomes available.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

 

U.S. Citizenship and Immigration Services has announced that in June it will only accept employment-based adjustment-of-status applications based on the Final Action Dates chart.

The Dates for Filing chart published in the State Department’s June Visa Bulletin will not apply. Employment-based immigrants must follow the Final Action Dates chart (below) to determine whether they are eligible to file their adjustment-of-status petitions with USCIS. Only applicants with priority dates earlier than the dates listed in the chart will be permitted to file their applications for adjustment of status in June.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines Vietnam
EB-1 Current Aug. 15, 2017 Current June 8, 2016 Current Current Current
EB-2 Current Nov. 1, 2015 Current June 12, 2009 Current Current Current
EB-3 Nov. 8, 2017 June 15, 2016 Nov. 8, 2017 April 1, 2009 Nov. 8, 2017 Nov. 8, 2017 Nov. 8, 2017

BAL Analysis: June will mark the third time this fiscal year that USCIS will use Final Action Dates for employment-based adjustment-of-status applications. The Final Action Dates chart is less progressive than the Dates for Filing chart in a number of categories. Family-based applicants must use the applicable Dates for Filing chart, except for F2A category applicants, who may use Final Action Dates.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

Priority-date cutoffs will advance significantly in some employment-based categories and more modestly in others, according to the State Department’s June Visa Bulletin.

Key movements in the June Visa Bulletin:

EB-1

  • China EB-1 will advance one month to Aug. 15, 2017.
  • India EB-1 will advance more than 10 months to June 8, 2016.
  • All other countries under EB-1 will remain current.

EB-2

  • China EB-2 will advance one month to Nov. 1, 2015.
  • India EB-2 will advance ten days to June 12, 2009.
  • All other countries under EB-2 will remain current.

EB-3

  • China EB-3 will advance one month to June 15, 2016.
  • India EB-3 will advance one month to April 1, 2009.
  • The cutoff for all other countries will advance more than 10 months to Nov. 8, 2017.

Final Action Dates for Employment-Based Preference Cases:

Preference All Other Countries China El Salvador Guatemala Honduras India Mexico Philippines Vietnam
EB-1 Current Aug. 15, 2017 Current June 8, 2016 Current Current Current
EB-2 Current Nov. 1, 2015 Current June 12, 2009 Current Current Current
EB-3 Nov. 8, 2017 June 15, 2016 Nov. 8, 2017 April 1, 2009 Nov. 8, 2017 Nov. 8, 2017 Nov. 8, 2017

The State Department also released its Dates for Filing chart for June. Applicants seeking to file for adjustment of status are reminded that the chart does not take effect unless U.S. Citizenship and Immigration Services confirms that it does via a web posting in the coming days. BAL will update clients once officials confirm whether the chart can be used.

Last month, President Trump issued a proclamation temporarily suspending the entry of immigrant-visa applicants for 60 days. Since U.S. consulates had already suspended routine visa operations abroad because of COVID-19, the order has had a limited impact. In addition, several categories of people are excluded from the suspension, including U.S. lawful permanent residents, spouses and unmarried children under 21 of U.S. citizens, foreign healthcare professionals performing research to combat the spread of COVID-19, those applying for EB-5 immigrant investor visas, members of the U.S. Armed Forces and those who would further U.S. law enforcement objectives or whose entry is in the national interest.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The United States, Canada and Mexico have agreed to extend the current COVID-19 border restrictions for another 30 days, the Department of Homeland Security (DHS) has announced.

Key points:

  • The travel restrictions will now remain in place until 11:59 p.m. EDT on June 22, but may be amended, rescinded or extended. The restrictions initially took effect March 20 for 30 days and were extended in April until May 21.
  • Only “essential travel” is permitted at all land ports of entry along the U.S.-Canada and U.S.-Mexico borders.
  • The list of individuals permitted to engage in “essential travel” includes U.S. citizens and lawful permanent residents (LPRs) returning to the U.S.; and people traveling to work in the U.S. (e.g., agricultural workers), engaging in lawful cross-border trade (e.g., truck drivers transporting goods), or traveling to attend school, receive medical treatment, for public health purposes, or a limited number of other reasons.
  • The restrictions do not include air or sea travel, but do apply to passenger rail, passenger ferry travel and pleasure boat travel.

BAL Analysis: DHS is expected to publish official notices extending the restrictions in the Federal Register this week. Individuals traveling across the U.S.-Canadian and U.S.-Mexico border for essential travel are exempt from the restrictions, but travelers should be prepared for delays and increased scrutiny, as well as possible changes in how U.S. Customs and Border Protection officers interpret “essential travel.”

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2020 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.