The Trump administration officially launched the Gold Card program on Dec. 10. U.S. Citizenship and Immigration Services has published Form I-140G, Immigrant Petition for the Gold Card Program, on its website — along with instructions, valid edition date (Nov. 19, 2025) and other filing details.

Key Points:

  • Before filing Form I-140G, applicants must:
    • First register their information on trumpcard.gov
    • Submit payment of the filing fee via credit card or wire transfer on trumpcard.gov
    • Receive submission confirmation from trumpcard.gov
    • Wait for USCIS’s notice instructing when to log in and/or create a USCIS online account to upload the form
  • Form I-140G can only be filed online via a USCIS online account. Paper submissions will not be accepted.
  • According to the website, “The filing fee is $15,000 per person (principal beneficiary, spouse, child(ren), as applicable).”
  • Form I-140G requires identification of source of donation funds and documentary evidence of the source.
  • Applicants will be able to message USCIS via their online account if further help is required completing Form I-140G. The BAL Gold Card Practice Group is also available to assist applicants with the process.
  • Upon receiving an email after vetting is complete, applicants or their corporate sponsors will be invited to pay the $1 million or $2 million payment (depending on application type). Note: Additional $1 million payments will be collected for dependent applicants.
  • According to the trumpcard.gov website, processing time will be “weeks.”
  • Upon approval of the I-140G, the applicant will be required to attend an interview at a U.S. consulate or embassy abroad. Timing for this stage will depend on the availability of visas in the EB-1 and EB-2 categories.
  • BAL will continue to monitor related developments and provide updates.

Additional Information: The Department of Homeland Security received emergency approval on Nov. 19 from the Office of Management and Budget to implement Form I-140G. The Trump Gold Card program was established by executive order 14351 as an immigration initiative marking an exclusive pathway to permanent residency in the U.S.

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

Copyright © 2025 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.

Today, U.S. Customs and Border Protection (CBP) published a Federal Register Notice (FRN) announcing planned updates to certain Form I-94 processes and changes to related systems, including the Electronic System for Travel Authorization (ESTA), and requests public comments on the proposal be submitted by Feb. 9, 2026.

Key Points:

  • CBP is seeking feedback on proposed updates to certain Form I-94 processes and related systems, which the FRN states “were submitted to and approved by OMB through an emergency clearance.” These include but are not limited to:
    • New functionality on the CBP mobile app to enable foreign nationals subject to I-94 requirements and departing the U.S. “to voluntarily provide biographic data from their passports or other travel documents, facial images and geolocation to provide evidence of that departure.”
    • Updating the ESTA application website to require applicants to provide a photograph of their face, or “selfie”, in addition to the photo of the passport biographical page.
    • Updating information collection for Visa Waiver Program (VWP) countries “to include travelers from current VWP designated countries and travelers from potentially added designated countries over the next three years.”
  • CBP also invites the public to comment on “newly proposed changes,” including:
    • The decommissioning of the ESTA website application process “to establish the ESTA Mobile application as the sole platform to apply for a new ESTA.”
    • Updates to “relevant collections” to reflect the removal of Romania from the VWP.
    • Adding social media collection from the last five years as a mandatory data element for an ESTA application.
    • Adding certain “high value data fields” to the ESTA application “when feasible” that include but are not limited to certain information used in the last five or ten years, such as telephone numbers and email addresses, as well as biometrics, to include face, fingerprint, DNA and iris.
  • According to CBP, “the continued evolution of mobile technology will further streamline and secure the traveler authentication process, paving the way for future advancements in contactless verification and biometric authentication.”
  • The FRN states public comments should be submitted “no later than” Feb. 9, 2026, to the following email address: CBP_PRA@cbp.dhs.gov. Additional details on submitting comments can be found here.

Additional Information: The FRN states that CBP will be submitting the information request to the Office of Management and Budget (OMB) for approval. At this time, changes in the FRN are not yet in effect. BAL will continue to monitor related developments to the proposed changes and provide updates.

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

Copyright © 2025 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.

Following the State Department’s mandate published on Dec. 3 expanding the requirement for “online presence review” to include all H-1B visa applicants and their H-4 dependents, effective Dec. 15, 2025, the U.S. Embassy and Consulates in India announced visa appointments had been rescheduled via email.

On Dec. 9, the U.S. Embassy and Consulates in India posted the following update on its official X account:

“ATTENTION VISA APPLICANTS – If you have received an email

advising that your visa appointment has been rescheduled, Mission

India looks forward to assisting you on your new appointment date.

Arriving on your previously scheduled appointment date will result

in your being denied admittance to the Embassy or Consulate.”

Newsweek reported on Dec. 9 that the U.S. Consulates in Chennai and Hyderabad have sent applicants emails that read in part, “Due to operational constraints related to processing these visas and to ensure that no applicants issued a visa pose a threat to U.S. national security or public safety, the U.S. Consulate in Chennai must reduce the number of applicants each day.”

The State Department’s Dec. 15 mandate instructs all H-1B applicants and their H-4 dependents, F, M and J nonimmigrant visa applicants to adjust the privacy settings on all of their social media profiles to “public.”

Per the U.S. Embassy India announcement, visa applicants who receive an email advising that their appointment has been rescheduled will not be allowed entry if they appear on the date of their previously scheduled appointment.

The State Department has not issued further public guidance on the matter as of the publication date of this alert.

BAL clients are advised to consult directly with their BAL support team regarding this matter. BAL will continue to monitor related developments and provide updates.

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

Copyright © 2025 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.

Following the posting of PERM processing times as of Dec. 1, the Department of Labor posted the latest processing times for prevailing wage determination (PWD) requests.

As of Dec. 1, the National Prevailing Wage Center is processing PWD requests filed in July 2025 for H-1B and PERM OEWS* cases. For H-1B Non-OEWS* cases, the DOL was processing requests filed in May 2025 and earlier, and for PERM Non-OEWS cases, the department was processing requests filed in April 2025 and earlier.

*OEWS and Non-OEWS are the sources used for determining the prevailing wage for a job. OEWS stands for Occupational Employment and Wage Statistics. Non-OEWS refers to other sources used for prevailing wage determinations, such as collective bargaining agreements or private wage surveys.

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

Copyright © 2025 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.

 

Update on applications received for requested date of need from April 1, 2025 (fiscal year 2025 second half of the visa cap):

The Department of Labor reported that as of Dec. 6, a total of 8,947 cases were issued Final Decisions. Certified positions for this period were allocated for 120,553 workers.

Update on applications received for requested date of need from Oct. 1, 2025, through March 31, 2026:

DOL reported that as of Nov. 29, a total of 3,876 cases were issued Final Decisions. Certified positions for this period were allocated for 73,234 workers.

H-2B Prevailing Wage Determination (PWD) processing times:

As of Dec. 1, the number of remaining requests for H-2B visa PWD applications received in November were 4,054. The number of remaining requests for September was 34 and for October was 32. The disparity between September, October and November reflects the impact of the government shutdown.

These dates reflect the month and year in which applications were filed (request date) or submission date of the appeal request for Redeterminations or Center Director Review. The Office of Foreign Labor Certification (OFLC) encourages employers to request a prevailing wage determination for the H-2B program at least 60 days before the date the determination is needed. For various reasons, OFLC may be completing the processing of applications filed prior to the month posted. Withdrawn and voided requests are excluded from the total, which may cause the numbers for previous months to fluctuate.

Learn more about H-2B visas here.

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

Copyright © 2025 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.  

Immigration, Refugees and Citizenship Canada announced a new Express Entry category for international doctors, filling critical health workforce gaps by creating a simpler path to permanent residence.

Key Points:

  • To be eligible for the new Express Entry category, individuals must have at least one year of Canadian work experience as a general practitioner, family physician, specialist in surgery or specialist in clinical and laboratory medicine, gained within the last three years.
  • The government will reserve 5,000 federal admission spaces, in addition to the annual Provincial Nominee Program allocations, for provinces and territories to nominate licensed doctors with job offers.
  • Invitations to apply for the new Express Entry category will be issued in early 2026.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2025 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 Labor posted the latest processing times for permanent labor certification (PERM) as of Dec. 1. Prevailing wage determination (PWD) processing times have not yet been updated and still reflect PWD processing times as of Sept. 1. However, internal BAL reports show PWDs are being processed in approximately 5-6 months and currently July 2025 filed requests are being processed.

PERM Processing Times: As of Dec. 1, the department was adjudicating PERM applications filed in July 2024 and earlier. Those filed in November 2024 and earlier were under audit review and appeals for reconsideration to the certifying officer filed in August 2025 are currently under review.

These dates reflect the month and year in which cases were filed and are currently being adjudicated. The Reconsideration Request date for reviewing appeals reflects the month and year in which cases that are currently being reviewed were appealed. For various reasons, the Office of Foreign Labor Certification (OFLC) may be completing the processing of applications filed prior to the month posted.

Average number of days to process PERM applications

Determinations Month Calendar Days
Analyst Review November 2025 496
Audit Review N/A N/A

These dates reflect the amount of time to process applications. Actual processing times for each employer’s PERM application may vary from the average depending on material facts and individual circumstances of the case. The OFLC is reporting the average processing time for all PERM applications for the most recent month.

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

Copyright © 2025 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. Embassy Mexico announced that, effective Nov. 24, 2025, the embassy is operating at its new location. All consular services conducted in Mexico City, including visa interviews and services for U.S. citizens, are now conducted exclusively at the new embassy headquarters.

The embassy’s new address is: Presa Angostura 225, Colonia Irrigación, Alcaldía Miguel Hidalgo, Mexico City, C.P. 11500.

The visa section entrance is located at the corner of Casa de la Moneda and Calzada Legaria.

According to the embassy’s official X account, visitors should be aware that the following are not allowed inside the embassy: liquids, cellphones, electronic car keys, tablets, headphones or smartwatches. The embassy does not have security or parking.

For more information, visit the embassy website.

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

Copyright © 2025 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 State Department announced that, effective Dec. 15, 2025, it will expand the requirement for “online presence review” to include all H-1B visa applicants and their H-4 dependents.

Key Points:

  • This requirement, introduced by the State Department in June, previously applied only to students and exchange visitors in the F, M and J nonimmigrant visa classifications.
  • The December update instructs all H-1B applicants and their H-4 dependents, F, M and J nonimmigrant visa applicants, to adjust the privacy settings on all of their social media profiles to “public.”
  • The announcement notes the State Department “uses all available information in visa screening and vetting to identify visa applicants who are inadmissible to the United States … including online presence review of all student and exchange visitor applicants in the F, M and J nonimmigrant classifications.”

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

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

Copyright © 2025 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 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:
  • 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.

Copyright © 2025 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.