USCIS Policy Memorandum PM-602-0192 (December 2, 2025)
USCIS has directed officers to put broad categories of cases on hold, require interviews that are normally waived, and re-review already approved benefits for people connected to the 19 “high-risk countries” in Presidential Proclamation 10949, alongside a sweeping pause of all pending asylum applications.
When the system stops moving, the burden shifts to the applicant
For years, U.S. immigration has operated on a familiar bargain. If you qualify, you file. If you file correctly, you wait. If you wait long enough, you get a decision. Even in hard categories, there was still a sense that the machine moved, slowly but forward.
The last few days broke that assumption.
In response to the Washington, D.C. National Guard shooting and the administration’s national-security framing, the government has moved from tightening entry at the border to pausing adjudications inside the United States. Reporting describes disruptions across green cards, citizenship, and other immigration benefits, tied to a USCIS directive focused on 19 countries already covered by the June 2025 entry proclamation.
This is not only about who can enter. It is about who can finish.
What the December 2 USCIS memo actually does (and why this is different)
The December 2, 2025, USCIS policy memorandum does three operational things, “effective immediately.”
- First, it places a hold on all pending Form I-589 asylum applications, regardless of nationality, while USCIS conducts a “comprehensive review.” This aligns with reporting that USCIS asylum offices were instructed to pause asylum adjudications across the board.
- Second, it places a hold on “pending benefit requests” for people tied to the 19 high-risk countries listed in Presidential Proclamation 10949, and it says this applies based on “Country of Birth or Country of Citizenship,” regardless of entry date.
- Third, it orders a “comprehensive re-review” of already approved benefit requests for people from those countries who “entered” the United States on or after January 20, 2021, using a definition of “entered” broad enough to include inspection, parole, or entry without inspection.
The memo also makes two details explicit that immigration lawyers usually have to infer from patterns.
- One, interviews cannot be waived for this population. If the case type normally has no interview, USCIS can still require the person to appear at a USCIS office after “case review and evaluation.”
- Two, the hold stays in place until the USCIS Director lifts it through a later memorandum. Litigation or “extraordinary circumstances” requests to lift a hold require Director or Deputy Director approval.
This is why the memo feels so disruptive. It is not a new eligibility standard. It is a decision to stop deciding, then restart only after re-screening and re-interview.
The legal logic USCIS is using: discretion, identity, and security datasets
The memo frames the policy as an operational necessity tied to national security and public safety, and it directs case-by-case review using terrorism-related inadmissibility and deportability provisions in the INA.
USCIS lists specific triggers for escalated concern, including whether a person is in the Terrorist Screening Dataset, alleged associations with covered activities or organizations, certain criminal conduct, and inability to establish identity “as outlined in PP 10949.”
And it explicitly ties this to the USCIS “Discretionary Analysis” framework in the Policy Manual. That chapter states, in plain English, that many benefits require a favorable exercise of discretion even after threshold eligibility is met, and that discretion must be case-specific and not based on “biases or assumptions.”
That sentence matters because it is where the fight will live. The memo expands scrutiny. The Policy Manual places limits on how far that scrutiny can lawfully drift into stereotype or nationality-based suspicion.
How this affects immigration cases generally (all categories)
The practical impact depends on two variables that now matter more than the category name on the form.
- One is location. Are you already inside the United States, asking USCIS for a benefit, or are you outside, dealing with the State Department and the entry proclamation.
- The other is whether your case is connected to the 19 high-risk countries through country of birth or citizenship, or whether it is an asylum application, which is now paused regardless of nationality.
- The pause on benefit requests applies to individuals from the following 19 countries, regardless of entry date: Afghanistan, Burma, Chad, the Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan and Venezuela.
Inside the United States: change of status, extensions, and pending benefits
If you are in the United States, the headline is simple. The new memo is a USCIS machine decision. It freezes adjudication for covered populations and forces additional review steps before the agency will move again.
This does not mean every case is denied. It means timelines, work authorization strategies, and travel plans that were built on predictable processing have become fragile.
For people from the 19 high-risk countries, USCIS is holding “pending benefit requests.” The memo provides examples of covered forms like adjustment of status (I-485), green card replacement (I-90), removal of conditions (I-751), travel document and parole applications (I-131), and preserving residence for naturalization purposes (N-470). It does not provide a complete list, and that uncertainty is part of the problem. In practice, applicants should assume that common USCIS benefit requests tied to staying, traveling, adjusting, or naturalizing are vulnerable to delay under this directive. Reuters and AP reporting describe the policy as pausing immigration applications for applicants from the 19 countries and disrupting interviews and processing across categories.
For asylum applicants, the memo is explicit. All pending I-589s are held, regardless of nationality. Asylum officers were instructed to pause asylum adjudications broadly.
The human consequence is predictable. People who were waiting for decisions will remain in limbo longer, and some will be pulled into interviews that would otherwise never happen.
Outside the United States: visas, consular processing, and the June 2025 entry proclamation
For people outside the United States, the dominant instrument remains the June 4, 2025 proclamation restricting entry for nationals of 19 countries, including a “full suspension” list that includes Iran.
That proclamation is framed as an entry restriction, not a USCIS adjudication order. It generally applies to foreign nationals who are outside the United States on the effective date and who do not have a valid visa on that date, with listed exceptions including lawful permanent residents and certain dual nationals traveling on a non-designated passport.
But in the real world, consular processing does not occur in a vacuum. When the government publicly defines a set of countries as high-risk, consular decision-making predictably becomes slower, more security-driven, and less transparent. That is not a legal conclusion. It is an operational reality that anyone watching administrative processing over the last decade recognizes.
For many applicants outside the U.S., the most important practical shift is that a strong petition is no longer the end of the story. The petition can be approved, and the visa can still stall.
Talent-based petitions: what changes, and where the real bottlenecks appear
Talent-based immigration has always been a strange mix of objective proof and subjective judgment. The petition reads like a legal document, but the person’s future often turns on workflow choices inside agencies that do not publish their playbook.
The new memo makes those workflow choices the main event.
Talent-based petitions inside the U.S.: pending cases and change of status
For O-1, P, EB-1, and NIW cases filed and pending at USCIS, the first question is whether the beneficiary is tied to one of the 19 high-risk countries by birth or citizenship. If yes, the memo directs USCIS to hold pending benefit requests while a comprehensive review is conducted.
If your talent-based strategy involves adjustment of status (I-485), travel permission (I-131), or related benefits, those are explicitly within the examples USCIS lists in the memo. And if you are in a population that is forced into interview, even routine cases can become slower and more complicated because USCIS has removed its ability to waive interviews and can require appearances even where interviews are not typically required.
If your talent-based strategy involves a change of status while remaining in the United States, a second dynamic matters. USCIS’s own Policy Manual emphasizes that discretionary analysis is a separate layer in many benefit decisions and must be grounded in the individual record, not in assumptions. The memo itself signals the types of national-security and identity issues USCIS will be prioritizing during re-review.
In plain terms, applicants should expect more scrutiny of identity, background checks, prior status history, and record consistency across filings.
Talent-based petitions outside the U.S.: consular processing and reentry
For talent-based applicants outside the United States, the June 2025 proclamation shapes the landscape first, particularly for nationals of countries in the full suspension list.
For those who are already in the U.S. but need to travel and return for stamping, the “petition approved” moment now sits uncomfortably beside the “entry restricted” reality. The proclamation includes exceptions, but exceptions are not the same thing as predictability.
If there is a single practical shift in talent-based planning, it is this. Case strategy can no longer treat travel as a neutral administrative step. Travel is now a risk event.
Iranian nationals: why this hits harder, faster, and across more categories
Iran is listed in the proclamation’s full suspension set. It is also within the 19-country group referenced in the USCIS memo, which triggers holds on pending benefit requests for people who list one of those countries as country of birth or citizenship.
That combination creates a double pressure.
Outside the United States, Iranian nationals are more likely to encounter entry restrictions, denials, or long administrative processing because the proclamation is designed to treat the country itself as a vetting problem.
Inside the United States, Iranian nationals with pending benefit requests are now directly in the path of a memo-driven hold, plus a review framework that explicitly includes identity concerns tied to PP 10949 and heightened national-security screening.
For Iranian artists, researchers, founders, and professionals, the result is that immigration status feels less like a stable civil document and more like a recurring audit.
It is also important to understand the memo’s retroactive reach. USCIS is directed to comprehensively re-review approved benefit requests for covered nationals who entered on or after January 20, 2021, and it reserves the ability, “when appropriate,” to extend review beyond that timeframe.
What we still do not know (the part that matters most)
Right now, the written directives and the news coverage tell us what the government wants to do. They do not yet tell us what will actually happen to real cases, in real offices, under real timelines. Early reporting describes broad pauses and re-reviews affecting multiple benefit types. But the operational details that determine outcomes are still moving, and agencies do not implement major restrictions uniformly on day one.
The gap is not academic. It is the difference between a case that is merely delayed and a case that gets pulled into an interview, rerouted for additional screening, or treated as a discretionary judgment call based on a shifting record of “positive and negative factors.” USCIS’s own policy framework makes clear that, where discretion exists, eligibility alone does not guarantee approval, and the agency can weigh the full record in a case-specific way. In the current climate, that discretionary layer is where uncertainty becomes outcome.
This is also why generic answers to “what should I do next” are dangerous right now. Artificial intelligence tools are built to produce plausible text, not verified operational truth. In fast-changing enforcement environments, they routinely fill gaps with confident-sounding speculation because the underlying implementation data does not yet exist in public form. Making case decisions based on AI-generated recommendations in this moment is simply wrong.Abachi Lawis tracking implementation the only way that matters: by collecting and analyzing case-level outcomes across consulates and USCIS local offices as these restrictions are applied in practice. Where we can confirm reliable patterns, we will publish them through our website. For case-specific planning, consultation remains the only responsible way to make decisions under this level of uncertainty.
