On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a Policy Memorandum directing adjudicators to place an immediate hold on final adjudication of a wide range of immigration benefit requests filed by (or on behalf of) individuals associated with countries newly designated as “high-risk” by recent Presidential Proclamation.
While USCIS may continue processing these cases, officers are instructed to pause the case before issuing a final decision unless a narrow exception applies. The hold applies regardless of entry date, meaning impacted applicants may face delays even if they entered the United States years ago.
Who is covered?
USCIS confirms that the policy applies broadly—not only to individuals based on nationality, but also those whose country of birth is on the designated list, individuals who obtained citizenship through citizenship-by-investment (CBI) programs, and certain individuals traveling on Palestinian-Authority issued documents, even if nationality differs.
Family-based cases impacted
A significant development is that USCIS notes family-based immigrant visa applicants are no longer broadly exempt from these restrictions and will be subject to heightened scrutiny and screening.
Re-review of previously approved benefits
USCIS is also directing a comprehensive re-review of certain benefit requests previously approved for covered individuals on or after January 20, 2021, including the possibility of additional interviews or re-interviews.
Heightened security, identity, and document scrutiny
USCIS emphasizes that these cases involve enhanced review related to national security and public safety concerns, including checks involving the Terrorist Screening Dataset (TSDS) and concerns about identity documentation reliability.
Limited exceptions
USCIS outlines limited exceptions (e.g., select document replacement applications, certain EAD categories, and cases involving national interest or major sporting events), but most affected benefits will remain subject to the adjudication hold.
What This Means for Employers and Families
This policy is expected to cause significant adjudication delays for impacted applicants, including employment-based and family-based cases, and may result in increased Requests for Evidence, additional interview scheduling and gaps in employment authorization.
Meltzer Hellrung will continue monitoring updates and any further implementation guidance which is expected within 90 days. Please contact us if you have any questions about how this adjudication hold may affect your employees.
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