USCIS Holds and Reviews Pending Asylum and Benefit Applications

(CAMP SPRINGS, MD) The new Department of Homeland Security policy memorandum PM-602-0192 orders an immediate hold and review of a wide range of immigration cases, with a particular focus on asylum applications and benefit requests filed by people from 19 “high-risk” countries named in Presidential Proclamation 10949.

This memo, issued by U.S. Citizenship and Immigration Services (USCIS) on December 2, 2025, reshapes what many applicants can expect from their cases in the coming months and possibly years. It affects people already in the United States 🇺🇸 who have filed for protection or other immigration benefits, and it also triggers a new, deeper re-check of cases that were already approved for certain nationals who entered on or after January 20, 2021.

Below is a step-by-step walkthrough of what this change means, how the new hold and review process is expected to work, what types of cases are affected, and what applicants should expect from USCIS at each stage.

Policy Changes Overview: Who Is Affected and How

Under PM-602-0192, USCIS officers must now take three major actions:

1. Place a hold on all Form I-589 asylum applications
   USCIS will pause adjudication of all pending <a href="https://www.uscis.gov/i-589">Form I-589</a> (Application for Asylum and for Withholding of Removal), for every nationality, not just those from high-risk countries. No exceptions are written into this memo for pending asylum; every I-589 goes into this broader review environment.

2. Place a hold on pending benefit requests for nationals of 19 high-risk countries
   For people who list one of the 19 countries named in Presidential Proclamation 10949 as their country of birth or citizenship, USCIS must hold adjudication of their pending immigration benefit requests, including, for example:
   • Form I-485 – Application to Register Permanent Residence or Adjust Status
   • Form I-90 – Application to Replace Permanent Resident Card (Green Card)
   • Form N-470 – Application to Preserve Residence for Naturalization Purposes
   • Form I-751 – Petition to Remove Conditions on Residence
   • Form I-131 – Application for Travel Document

   The memo makes clear this hold applies regardless of when they entered the United States.

3. Re-review of already approved benefit requests for certain nationals
   USCIS must also re-review previously approved immigration benefits for people from the same 19 high-risk countries if they entered the United States on or after January 20, 2021. “Entered” is broadly defined here to include:

   • Admission after inspection
   • Parole
   • Entry without inspection

   This is not a light administrative check. The agency will carry out a “comprehensive re-review,” and in many cases this may involve interviews or re-interviews.

Importantly, the memo states that interviews for this population may not be waived under any circumstance. Even in cases where there normally is no required interview (for example, some green card renewals), USCIS can now decide, after case review, that the applicant must appear in person.

USCIS notes that this hold will stay in place until the USCIS Director lifts it through another memorandum, and any request to lift the hold for a particular case because of litigation or “extraordinary circumstances” must be approved by the USCIS Director or Deputy Director, in coordination with the Office of Policy and Strategy.

Why USCIS Is Imposing a Hold and Review Now

The memo roots this policy shift in two recent presidential actions and specific recent terrorist cases.

• It cites Executive Order 14161, issued on January 20, 2025, titled “Protecting the United States from Foreign Terrorist and Other National Security and Public Safety Threats.” That order focuses on preventing the entry and presence of people who may:
  • Commit terrorist acts
  • Pose national security risks
  • Promote hateful ideologies
  • Misuse immigration laws for harmful purposes
• It cites Presidential Proclamation 10949, issued on June 4, 2025, under Immigration and Nationality Act (INA) section 212(f). That proclamation restricts the entry of aliens from 19 high-risk countries, based on the President’s power to suspend or restrict entry when it is considered detrimental to U.S. interests. According to the memo, these are the same 19 “high-risk countries” at the center of this USCIS review.

The policy memo directly connects these concerns with recent incidents. It mentions:

• Nasir Ahmad Tawhedi, an Afghan national who planned a terrorist attack in the United States on Election Day 2024, and who pleaded guilty in federal court to conspiring and attempting to provide material support and resources to ISIS. The memo cites the U.S. Department of Justice release titled “Afghan National Pleads Guilty to Plotting Election Day Terror Attack in the United States,” dated June 13, 2025.

• Rahmanullah Lakanwal, another Afghan national, who is suspected of planning and carrying out a terrorist attack in Washington, DC, shooting two National Guard members, one of whom died and one who remains critically injured. The memo notes that, according to a Department of Homeland Security press release dated November 26, 2025, Lakanwal had been let into the country through the Biden Administration’s Operation Allies Welcome program.

USCIS stresses that these events show what can happen when screening and vetting are not strong enough or when speed in processing is prioritized over deeper review. The memo says the agency’s role is to prevent terrorists from using the U.S. immigration system as a safe haven and to ensure immigration adjudications prioritize the safety of the American people.

According to analysis by VisaVerge.com, these kinds of security-driven policy shifts often lead to longer processing times across many case types, even for applicants who pose no security concerns, as USCIS reshapes internal review steps and redistributes its staff.

Scope of the Hold: Which Processes Are Not Included

The memo states that the term “benefit request” in this context does not include certain USCIS screening activities, such as:

• Credible fear screenings
• Reasonable fear screenings
• Safe third country determinations
• Third country removal screenings
• Threshold screenings under Asylum Cooperative Agreements

This means that people in fast-moving protection processes at the border or in removal proceedings, whose cases involve these initial screenings, are not covered by the benefit-request hold described here. Their screenings continue as usual.

However, once a person files a full Form I-589 asylum application with USCIS, that application itself falls under the hold, no matter the person’s nationality.

Core Review Criteria: What USCIS Will Examine in Each Case

USCIS emphasizes that this is a case-by-case review. Officers must look at all available information about an individual and decide whether they qualify for the benefit and whether they present any national security or public safety risk.

The memo lists four main questions officers must address when they review or re-review a case:

1. Terrorist Screening Dataset (TSDS) Listings
   Officers must check whether the person is:
   • Listed in the Terrorist Screening Dataset (TSDS) as a Known or Suspected Terrorist (KST) in Tier 1 or Tier 2, or
   • Listed in Tier 3 or Tier 4 with “significant derogatory information” related to them.
2. Links to Terrorism-Related Activities under INA 212 and 237
   Officers must determine if the person is connected to prior, current, or planned involvement in, or association with, any activity, individual, or organization described in:
   • INA 212(a)(3)(A) – security and related grounds
   • INA 212(a)(3)(B) – terrorism-related grounds
   • INA 212(a)(3)(F) – security and foreign policy grounds
   • INA 237(a)(4)(A) or (B) – deportability on security and terrorism grounds
3. Risk of Serious Harm or Danger to the Community
   Officers must assess if the person is linked to activities or associations that “may pose a risk of serious harm or danger to the community,” including criminal conduct described in:
   • INA 101(a)(43) – definition of aggravated felony
   • INA 212(a)(1)(A)(iii) – certain mental or physical disorders associated with harmful behavior
   • INA 212(a)(2) – criminal and related grounds
   • INA 237(a)(2) – deportability on criminal grounds
   • INA 237(a)(4)(A)(ii) – certain security grounds
4. Ability to Establish Identity
   USCIS must look at whether the applicant can establish their identity as required by PP 10949 and existing USCIS guidance, specifically the USCIS Policy Manual, Volume 1, Part E, Chapter 8, which deals with discretionary analysis.

For many applicants, especially asylum seekers who fled quickly and may have incomplete documents, this new focus on identity and background can feel worrying. But the memo emphasizes that decisions remain discretionary and based on individual facts.

Practical Step-by-Step: What Applicants Can Expect

Step 1: Automatic Hold on Pending Cases

If you have a pending Form I-589 asylum application, USCIS will pause a final decision on your case. You do not need to file anything to trigger this hold; officers apply it automatically.

If you are from one of the 19 high-risk countries under PP 10949 and you have any pending USCIS benefit request (such as a green card application or a green card renewal), your case also enters this hold status.

At this stage, you can generally expect:
– Delays in interviews being scheduled or rescheduled
– Delays in final decision notices (approvals or denials)
– No automatic right to have the hold lifted

USCIS openly acknowledges in the memo that this direction “may result in delay to the adjudication of some pending applications,” but states that it has weighed this burden against the need to “vet and screen to the maximum degree possible.”

Step 2: Internal Case Review for Security and Identity Concerns

USCIS then performs a comprehensive internal review of cases that fall under this policy. Officers will:
– Check security databases, including the TSDS
– Compare identity information and documents
– Look for any indication of terrorism-related, criminal, or public safety concerns
– Document every finding according to existing agency protocols

This review may happen without any immediate contact with the applicant. You may see no visible activity on your case for weeks or months while background and database checks are completed.

Step 3: Scheduling of Interviews or Re-Interviews

If USCIS sees any concern, or if your case falls into a priority category under this memo, the agency may:
– Schedule an initial interview (for example, for an I-589 or I-485 case that has not yet had one)
– Schedule a re-interview if you already had one in the past
– Require you to appear at a USCIS office even for types of applications that usually do not require an interview

The memo specifically says interviews for this population “shall not be waived under any circumstance.” That means personal appearance becomes a central part of the review for affected applicants.

During these interviews, you should expect detailed questions about:
– Your identity and documents
– Your travel history, including prior stays in other countries
– Any associations, organizations, or groups you have been involved with
– Your criminal history, if any
– For asylum, the details of your claim, including any new facts since you filed

Step 4: Possible Referral to ICE or Other Law Enforcement

Within 90 days of issuing this memorandum, USCIS plans to create and prioritize a list of cases for:
– Review
– Interview or re-interview
– Referral to ICE (Immigration and Customs Enforcement) and other law enforcement agencies, as needed

This list will be developed in consultation with:
– The Office of Policy and Strategy
– The Fraud Detection and National Security Directorate

For applicants, a referral to ICE may mean:
– More intensive questioning
– Placement into removal (deportation) proceedings in some cases
– Possible enforcement actions if serious security or criminal issues are discovered

The memo does not give detailed timeframes for each individual case beyond this 90-day planning window, but it signals that national security cases will receive priority treatment.

Step 5: Final Decision Once Hold Is Lifted or Review Completed

The memo states the hold remains in effect until lifted by the USCIS Director. Once a hold is lifted for a category of cases or for a specific case, USCIS will:
– Finalize its review
– Make a benefit decision (grant, deny, or possibly issue a Notice to Appear in removal proceedings)
– Rely on the documented review findings to support any action

The agency also notes that this memo does not create any enforceable rights. That means applicants cannot claim in court that they are entitled to a specific outcome or timeline just because of what this memo says.

Practical Guidance for Affected Asylum Seekers and Applicants

For people with pending asylum applications or other benefit requests covered by this memo, there are several practical steps to consider:

• Keep your contact information current with USCIS. If you move or change phone numbers, file the required change of address so you don’t miss interview notices.
• Organize identity documents. Even if you fled quickly, gather what you can: passports (even expired), national IDs, birth certificates, school or employment records. USCIS is now placing strong emphasis on identity proof.
• Be ready for an interview or re-interview. You may be called in again, even if you already had a full asylum or green card interview. Prepare to give consistent, detailed answers.
• Expect longer processing times. The memo openly accepts delay as a trade-off for deeper security vetting.

For official background on asylum itself, USCIS maintains an overview page on Asylum in the United States, which explains eligibility, forms, and the standard process outside of this temporary hold and review environment.

Limits of the Memo and Officer Discretion

The final section of PM-602-0192 states the memo is “intended solely for the guidance of USCIS personnel in the performance of their official duties.” It also makes clear:
– It does not remove officer discretion in adjudicatory decisions. Officers still weigh evidence and apply the law case by case.
– It cannot be used to create a legal right or benefit, either substantive or procedural, by any individual or party in:
– Removal proceedings
– Litigation with the United States
– Any other context

In other words, while this memo actively instructs officers to hold and review asylum and other benefit cases linked to high-risk countries, applicants cannot point to it in court to demand faster action or a particular decision. Instead, it shapes internal USCIS practice with a strong emphasis on security screenings, detailed reassessment, and careful documentation of all national security and public safety concerns.

Key takeaway: Expect increased delays, mandatory interviews for affected groups, intensified identity and security checks, and possible referrals to law enforcement — all applied on a case-by-case basis under USCIS discretion.