Donald Trump has upended U.S. politics and defeated former Secretary of State Hillary Clinton in the presidential election.

From day one of his campaign, President-elect Trump made immigration enforcement a centerpiece of his campaign, and he carried that theme throughout the election. He committed to build a wall on the border with Mexico, declared that he would suspend immigration from certain regions, and proposed to “end the use of the H-1B as a cheap labor program.” But he also stated that he will welcome immigrants and that his companies have leveraged high-skilled and low-skilled visa categories to meet their staffing needs.

Please visit this site for an outline of Trump’s immigration plan and for information about an upcoming BAL Webinar on the election and its implications for high-skilled immigration.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact BerryApplemanLeiden@bal.com.
Copyright © 2016 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 cutoff dates for India EB-2, China EB-2 and EB-3, and the Philippines EB-3 will advance modestly, according to the State Department’s December Visa Bulletin.

Key movements in priority cutoff dates: 

  • EB-2 will advance three months to Feb. 1, 2008, while India EB-3 will advance by one week to March 15, 2005.
  • China EB-2 will advance by more than two months to Sept. 22, 2012, while China EB-3 will advance nearly three months to July 1, 2013.
  • The Philippines EB-3 category will advance two months to June 1, 2011.
  • EB-3 categories for Mexico, El Salvador, Guatemala, Honduras and All Other Chargeability Areas will remain at July 1, 2016.

Additional notes: All EB-1 categories will remain current. All EB-2 categories other than India and China will also remain current.

Application Final Action Dates for Employment-Based Preference Cases:

Preference China El Salvador Guatemala Honduras India Mexico

 

Philippines

 

All Other Countries
EB-1 Current Current Current Current Current Current
EB-2 Sept. 22, 2012 Current Feb. 1, 2008 Current Current Current
EB-3 July 1, 2013 July 1, 2016 March 15, 2005 July 1, 2016 Jun 1, 2011 July 1, 2016

The State Department also released its Dates for Filing chart for December 2016. Applicants seeking to file for adjustment of status are reminded that the chart does not take effect unless USCIS confirms it via a web posting in the next week or so. BAL will update clients once the State Department confirms whether the chart can be used in December.

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

Copyright © 2016 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.

Prevailing wage determinations for PERM labor certification cases are experiencing significant delays. In particular, requests based on private wage surveys are backlogged several weeks beyond the Labor Department’s stated processing times.

Key points:

  • The department’s stated processing time for prevailing-wage requests in PERM cases is approximately four months. (As of Oct. 1, the agency was processing initial and redetermination requests filed in June).
  • According to B·A·L’s internal case tracking, employers who submit prevailing wage requests based on private wage surveys are waiting four to six weeks longer than the stated processing time in PERM cases. Some requests have been pending since May.
  • The Labor Department appears to be operating a two-track review: one for prevailing wage requests based on DOL wage surveys and another for requests based on private wage surveys.

Background: Employers are required to obtain a prevailing wage determination from the Labor Department before filing a PERM labor certification application to sponsor a foreign national employee. The employer must offer at least the prevailing wage. Employers may use private wage surveys rather than the Labor Department’s wage data to support a prevailing wage request, but private surveys must meet stringent regulatory requirements.

B·A·L Analysis: Employers with pending PERM cases should anticipate delays in obtaining a prevailing wage determination. Employers with new PERM cases should work with their B·A·L legal team to determine the best strategies in conducting recruitment and requesting prevailing-wage determinations going forward.

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

Copyright © 2016 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 U.S. Customs and Border Protection’s Electronic Visa Update System (EVUS) for Chinese travelers is now accepting enrollments. EVUS enrollment is mandatory for Chinese nationals holding 10-year visitor visas who are traveling to the U.S. on or after Nov. 29.

Key points:

  • Affected Chinese nationals can now enroll online on the Customs and Border Protection’s EVUS enrollment site.
  • The EVUS requirement applies to Chinese nationals (mainland only) who hold 10-year visitor (B1/B2, B1, and B2) visas. Travelers will have to renew their enrollment every two years or when their passport expires, whichever comes first. The requirement will apply to both new visa applicants and current visa holders. Enrollment is currently free during early enrollment, but a fee will be implemented in the future.
  • The enrollment process involves providing biographical and employment information as well as  travel history. In most cases, enrollments will be processed within minutes, although some cases may take as long as 72 hours.
  • For now, the EVUS requirement only applies to Chinese nationals. The government has said that the requirement may be applied to other countries in the future.

BAL Analysis: Chinese nationals traveling to the U.S. on or after Nov. 29 must complete the EVUS enrollment requirement before traveling. The system is now accepting enrollments, and those with plans to travel to the U.S. on or after Nov. 29 should consider enrolling ahead of time in order to avoid possible travel delays. Additional information about the program is available on this website.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact BerryApplemanLeiden@bal.com. Copyright © 2016 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.

International travelers entering the U.S. by land may now apply and pay online for their I-94 arrival record up to seven days before entry.

Key points:

  • Travelers may complete an I-94 form and pay the $6 application fee on the I-94 website.
  • A provisional I-94 arrival record will be issued. In order to complete the process, the traveler must appear at a land border within seven days of the application and be prepared to show evidence of their residence, employment and travel plans and give biometrics if required.
  • If the applicant fails to appear within seven days, the provisional I-94 will expire and the traveler must reapply and pay the fee again.

Background: The I-94 arrival record indicates that an international traveler has been lawfully admitted to the U.S. and is needed to verify alien registration, immigration status and employment authorization. Since 2013, the online I-94 process has been available to air and sea travelers. The recent announcement extends it to travelers entering by a land border.

BAL Analysis: The online I-94 application will make it more convenient and faster for nonimmigrant visa holders to provide their biographical information for purposes of obtaining an arrival record upon entry.

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

Copyright © 2016 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.

IMPACT – MEDIUM

What is the change? Saudi Arabia has changed visa validity and duration of stay requirements for both commercial visit (business) and work visit (temporary work) visas.

What does the change mean? Commercial visit visas will be valid for 180 days, with a 30-day duration of stay, or 365 or 730 days, with a 90-day duration of stay. Work visit visas will be valid for 180, 365 or 730 days, with a permitted duration of stay of 30 days. U.S. nationals remain eligible to obtain commercial and work visit visas that are valid for five years with a 180-day duration of stay.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Commercial visit (business) and work visit (temporary work) visas.
  • Who is affected: Employers and foreign nationals applying for commercial visit or work visit visas.
  • Impact on processing times: No significant impact.
  • Business impact: Businesses should take the new validity periods and duration of stay requirements into account when developing a mobility strategy.

Background: The changes to the visa validity periods and duration of stay requirements went into effect Oct. 2, when Saudi Arabia also increased visa fees across a number of categories. U.S. nationals will continue to be eligible for five-year commercial and work visit visas, with a duration of stay of 180 days. While foreign nationals of a handful of countries are banned from entering Saudi Arabia, most foreign nationals will be eligible for the following visas:

Commercial visit (business)

Validity Duration
180 Days 30 days
365 Days 90 days
730 days 90 days

Work visit (temporary work)

Validity Duration
180 Days 30 days
365 Days 30 days
730 days 30 days

Visa applicants must obtain a letter of invitation from the Saudi government in order to obtain a visa. Visas will be issued in accordance with the validity and terms stated in the letter, and terms may vary at the discretion of Saudi officials.

BAL Analysis: Employers and applicants should take the new validity periods and duration of stay requirements into account, but should also keep in mind that terms and conditions might vary from applicant to applicant.

This alert has been provided by the BAL Global Practice group and our network provider located in Saudi Arabia. For additional information, please contact your BAL attorney.

Copyright © 2016 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

IMPACT – HIGH

A regulation that contains provisions allowing greater flexibility for high-skilled foreign workers is awaiting approval by the Office of Management and Budget before a final version is published.

The proposed rule provides significant reforms to job portability for employees who have an approved employment-based immigrant visa petition during the wait for a green card.

Key proposed provisions:

  • An individual with an immigrant petition (I-140) that has been approved for 180 days or more will not have the petition automatically revoked if the employer withdraws it or goes out of business. Although the I-140 remains valid, the individual would need a new job offer or new petition in order to apply for a green card.
  • High-skilled employees who lose their job will be given a one-time grace period of 60 days to seek new employment. This provision would apply to the following categories: E-1, E-2, E-3, H-1B, H-1B1, L-1 and TN nonimmigrant status. The 10-day grace periods currently available to H-1B workers would also be extended to other nonimmigrant classifications.
  • Individuals in certain visa categories who are unable to obtain an immigrant visa due to numerical limits and who face compelling circumstances would become eligible to apply for an employment authorization document (EAD). This provision would apply to individuals in E-3, H-1B, H-1B1, L-1 or O-1 status. Examples of “compelling circumstances” include serious illness or disabilities, employer retaliation, other substantial harm to the applicant, or significant disruption to the employer.
  • Certain individuals may obtain automatic EAD extensions for up to 180 days, if they have timely applied to renew the EAD and maintain the same basis for employment authorization, which does not require adjudication of an underlying application.

Background: The proposed regulation contains long-awaited reforms that allow greater job portability for high-skilled foreign workers and proposes significant policy changes that will affect foreign workers present in the U.S. on nonimmigrant visas or seeking to obtain employment-based green cards.

The regulation implements the American Competitiveness in the 21st Century Act and codifies much of the previous informal guidance by the Department of Homeland Security. The agency proposed the regulation in December and received nearly 28,000 comments on the proposal during the public comment period that ended Feb. 29.

BAL Analysis: The proposed regulation is not effective yet, but is in the final stages of approval. The agency was required to consider the comments submitted by members of the public in finalizing the rule and may have made changes to the proposal. If finalized as proposed, the regulation would be a significant development and would have far-reaching implications for foreign workers in the U.S. on nonimmigrant visas.

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

Copyright © 2016 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.

Secretary of Homeland Security Jeh Johnson has extended temporary protected status (TPS) for eligible nationals of Nepal for an additional 18 months.

Key dates and deadlines:

  • The extension is effective Dec. 25 and will run until June 24, 2018.
  • Current Nepalese nationals holding TPS must re-register for the status during the 60-day period running from Oct.26, 2016 through Dec. 27, 2016.
  • Individuals who re-register during the above period and request a new Employment Authorization Document (EAD) will receive one with an expiration date of June 24, 2018.
  • Existing EADs of current Nepalese TPS holders will automatically be valid until June 24, 2017 to avoid expiration before re-registrants receive their new documents.

Background: Johnson originally designated Nepal for TPS due to a 7.8 magnitude earthquake that occurred April 25, 2015 and has determined that the country continues to suffer in the aftermath as most of the damage to homes, schools and hospitals has not been repaired.

BAL Analysis: Individuals eligible to re-register are encouraged to do so as early as possible during the 60-day period. Employers should be aware of the automatic extension of EADs for existing holders of Nepal TPS for Form I-9 purposes.

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

Copyright © 2016 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 California law that takes effect next year prohibits employers from asking for additional documents beyond federal law requirements in the Form I-9 document verification process.

Key points:

  • The law takes effect Jan. 1, 2017.
  • Under the law, California employers are prohibited from requesting more or different documents than required by federal law.
  • The law also prohibits employers from refusing to honor documents that reasonably appear to be genuine on their face or refusing documents because they contain a specified status or term of status accompanying the work authorization.
  • Employers are also prohibited from attempting to re-verify an existing employee’s document using an unfair immigration-related practice.
  • Employers who violate provisions of the law may be liable for up to $10,000 per violation.

Background: The law, SB 1001, is intended to address immigration-related discrimination in the I-9 employment eligibility verification process. California law already prohibits employers from requesting additional I-9 documents in retaliation for an employee’s exercise of protected rights. The new law addresses similar acts of discrimination in the hiring process.

Under the new law, an aggrieved job applicant or employee may file a complaint with the Labor Commissioner, who may impose fines up to $10,000 per violation and equitable relief.

BAL Analysis: California employers should be aware of the new law and review their I-9 procedures. Among the concerns that the law addresses, employers are prohibited from refusing an employment authorization document (EAD) based on the holder’s status (such as Deferred Action for Childhood Arrivals  or other status) or one that has a specified duration (such as an expiration date). BAL can assist employers in conducting a review and compliance audit of their I-9 policies.

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

Copyright © 2016 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 Department of Homeland Security published a final rule today containing significant increases to filing fees for immigration-related benefits.

Key points:

  • The new fees take effect Dec. 23. Petitions filed or postmarked on or after that date must include the new fees.
  • The fees will increase by a weighted average of 21 percent.

Below are some of the relevant fee changes for employment-related petitions and benefits:

Type of Benefit (Form Number) Current Fee New Fee Increase
Immigrant Petition for Alien Worker (I-140) $580 $700 21%
Application to Register Permanent Residence or Adjust Status (I-485) $985 $1,140 16%
Application for Employment Authorization (I-765) $380 $410 8%
Application to Extend/Change Nonimmigrant Status (I-539) $290 $370 28%
Application to Replace Permanent Resident Card (I-90) $365 $455 25%
Petition for a Nonimmigrant Worker (I-129) $325 $460 41%
Petition for Alien Relative (I-130) $420 $535 27%
Application for Travel Document (I-131) $360 $575 60%
Immigrant Petition by Alien Entrepreneur (I-526) $1,500 $3,675 145%
Notice of Appeal of Decision $755 $890 18%
Application for Naturalization $595 $640 8%
USCIS Immigrant Fee $165 $220 33%

Background: DHS has indicated that the increases are necessary to cover the costs of processing immigration benefits. The agency proposed the rule May 4. The final rule represents the first fee increases since 2010.

BAL Analysis: Employers and affected foreign nationals should budget for the new fees or plan to file in advance of the changes if possible.

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

Copyright © 2016 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.