A new USCIS policy memorandum directs officers to hold final decisions on pending benefit applications connected to countries listed in Presidential Proclamation 10998, while the agency conducts enhanced national security and public safety review.

Introduction

On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0194, titled Hold and Review of USCIS Benefit Applications Filed by Aliens from Additional High-Risk Countries. The guidance is effective immediately and expands prior “hold and review” procedures to cover additional countries identified in Presidential Proclamation (PP) 10998, issued December 16, 2025.

In practical terms, this memorandum directs USCIS to apply enhanced screening to certain cases connected to the countries listed in PP 10998, which may affect adjudication timelines.

What the Policy Requires

1. Holds on certain pending cases (no final decision issued)

USCIS officers are instructed to place an adjudicative “hold” on pending benefit applications filed by—or on behalf of—individuals covered by PP 10998. A “hold” means USCIS may continue internal processing steps, but it will not issue a final decision (approval, denial, or dismissal) while the hold remains in place.

The hold applies where the person identifies a covered country as a country of birth or country of citizenship. The memo also highlights situations USCIS views as potential efforts to avoid scrutiny (for example, certain travel documents or citizenship-by-investment scenarios), which may prompt additional review.

• Re-review of certain approvals

USCIS also directs a re-review of certain previously approved benefit requests connected to PP 10998, particularly those approved on or after January 20, 2021. This additional review may include interviews or re-interviews in some cases.

• How USCIS will evaluate cases during review

The memorandum instructs officers to prioritize national security and public safety considerations. USCIS may examine, among other factors:

• Watchlist-related information (including the Terrorist Screening Dataset)
• Potential terrorism-related inadmissibility or removability issues
• Indicators of serious criminal conduct
• Whether the applicant’s identity can be reliably established

Exceptions and Practical Takeaways

The memorandum includes limited exceptions (e.g., certain replacement documents and select application types such as Form I-90, Form N-565, Form N-600 with stated limits, certain Form I-765 categories, and specific national-interest or law-enforcement priority matters).

USCIS indicates impacted cases may experience longer processing times while enhanced review is conducted. Importantly, a “hold” is a process step and does not automatically signal a negative outcome; it means USCIS is pausing final action pending additional screening.

Applicants should closely review any USCIS correspondence and be prepared to submit additional supporting documents or appear for an interview if requested. As a practical matter, the best course is to keep your filings and identity documents well organized, track case updates regularly, and respond quickly and thoroughly to any request for evidence or interview notice.

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Legal Disclaimer

This article is for informational purposes only and does not constitute legal advice. Reading any content on our website does not create an attorney-client relationship. For legal guidance tailored to your specific situation, consult a qualified immigration attorney.