US Citizenship and Immigration Services (USCIS) has published a policy memorandum clarifying its policy for adjudicating applications submitted by foreign nationals from high-risk countries.
This memorandum specifies which cases are subject to the adjudicative hold, identifies exemptions, and outlines the factors to consider when assessing benefit eligibility during the re-review, interview, or re-interview of affected aliens. USCIS personnel are instructed to prioritize national security and public safety concerns and ensure compliance with applicable laws and regulations during the adjudication process.
Background
On January 20, 2025, the government issued Executive Order (EO) 14161, titled Protecting the United States From Foreign Terrorists and Other National Security and Public Safety Threats. This order aimed to safeguard US citizens from aliens who may seek to commit terrorist acts, pose threats to national security, promote hateful ideologies, or exploit immigration laws for malicious purposes.
EO 14161 underscores the importance of vigilance during the visa issuance process to ensure that individuals approved for admission into the United States do not intend to harm Americans or compromise US national interests.
Accordingly, through Presidential Proclamations (PP) 10949 (June 4, 2025) and PP 10998 (December 16, 2025), the government restricted the entry of foreign nationals from countries lacking adequate screening and vetting information to safeguard the national security and public safety of the United States and its citizens. The proclamations also instructed the government to promptly engage with the countries identified, outlining the necessary steps to meet US screening, vetting, immigration, and security standards.
Entry will not be granted to aliens who advocate for, aid, or support designated foreign terrorists or other threats to our national security or public safety.
Considering identified concerns and the threat to the American people, USCIS has identified the necessity of a comprehensive re-review, potential interview, and re-interview of all aliens from high-risk countries of concern who entered the United States on or after January 20, 2021.
USCIS will place an adjudicative hold on all pending benefit requests submitted by or for aliens from the high-risk countries identified in PP 10998, allowing for a thorough case-by-case review. This hold will remain in effect until lifted or modified by the USCIS Director through a subsequent memorandum or memorandum attachment.
Erickson Insights & Analysis
Erickson Immigration Group will continue to monitor developments and share updates as more news is available. Please contact your employer or EIG attorney if you have questions about anything we’re reporting above or case-specific questions.