USCIS Expands Hold on Case Processing to New Travel Ban Countries

 

U.S. Citizenship and Immigration Services (USCIS) has released updated guidance that expands and clarifies its hold on case processing and re-review policies to align with the Trump Administration’s newly expanded travel ban, which took effect on January 1. This action builds on USCIS’s “Additional National Security Measures” announced in early December. 

By way of background, following the November 2025 shooting of two National Guard service members, USCIS announced a series of measures aimed at strengthening screening and vetting procedures based on public-safety concerns. These measures took effect immediately on December 2, 2025, and included:

  • A pause on immigration benefit processing for individuals born in or nationals of countries covered by the June 2025 travel ban.

  • A re-review of certain previously approved immigration benefits for those individuals who entered the U.S. on or after January 20, 2021. 

  • A nationwide pause on the adjudication of all pending asylum applications.
     

Following these measures, the Trump Administration issued an expanded travel ban in December 2025, adding more countries, with the restrictions taking effect on January 1, 2026.  As a result, the countries subject to a partial or full travel ban has grown to the following: Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma (Myanmar), Burundi, Chad, Côte d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, the Republic of the Congo, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, The Gambia, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe. The travel ban also covers individuals seeking to travel using Palestinian Authority issued or endorsed travel documents.

Under USCIS’s new guidance, the pause on immigration benefit adjudications has now been expanded to include requests filed by or on behalf of individuals who were born in or are nationals of any country listed in the December 2025 travel ban. USCIS has also broadened its re-review policy to cover these individuals, but clarifies that the agency will only re-examine immigration benefits approved on or after January 20, 2021, regardless of the individual’s date of entry into the U.S.

This new guidance further clarifies that cases subject to the adjudication hold may continue to be accepted and move forward through processing, but USCIS will not issue a final decision (approval or denial) until the hold is lifted.  USCIS may also continue issuing Requests for Evidence (RFEs) or Notices of Intent to Deny (NOIDs) during this period. Notably, USCIS makes clear that the pause applies broadly across benefit types, including employment-based filings such as Forms I-129 and I-140.

The guidance does, however, introduce limited exceptions to the hold on finalizing a case. Benefit requests that are exempt include:

  • Applications to replace permanent resident or citizenship documents (Forms I-90, N-565, and N-600).

  • Certain employment authorization applications (Form I-765) filed by asylum seekers (c)(8), humanitarian parolees (c)(11), and individuals granted deferred action (c)(14). 

  • Applications related to civil surgeon designation.

  • Benefit requests connected to participation in major international sporting events. 

USCIS also retains discretion to exempt cases that are prioritized for law enforcement purposes or where the individual’s entry or continued presence would serve a U.S. national interest.

The memorandum also notes that it does not supersede the December 2025 guidance, except as to the newly identified exemptions. As a result, the hold on all pending asylum applications remains in place for applicants of all nationalities. That pause, implemented in early December, continues to prevent final asylum adjudications while USCIS conducts a separate review of its national vetting procedures.

Separately, USCIS has recently updated its Policy Manual to instruct adjudicators to consider an individual’s country of birth or nationality as part of discretionary determinations. As a result, even when these holds are lifted, individuals from affected countries may continue to face increased scrutiny, including RFEs or NOIDs requesting evidence of positive discretionary factors.

We will continue to monitor this development and provide updates as additional guidance becomes available.  Please contact us if you would like to discuss this development further. 

 
Nadia Yakoob