A new policy memorandum, PM-602-0194, issued January 1, 2026, implements a nationwide Benefits Pause travel ban“>that freezes final adjudications for certain immigration benefits for nationals from 39 designated High-Risk Countries, signaling a shift from entry bans to status/work-authorization restrictions.
Put simply, a traditional “travel ban” focuses on who can enter the united states. A benefits-based freeze focuses on what people can get approved for after they are already here—such as a change or extension of status, an adjustment of status (green card), or work authorization.
That difference matters for employees and families who are living in the U.S. and trying to keep lawful status and jobs on track. PM-602-0194 is framed as a security and integrity measure; the memo states USCIS “remains dedicated to ensuring aliens from high-risk countries of concern who have entered the United States do not pose risks to national security or public safety,” and directs staff to “place an adjudicative hold … allowing for a thorough case-by-case review.”
This guide explains: how the adjudicative hold works, what retroactive re-review since January 20, 2021 may mean, which countries are covered, what happens to Form I-589 asylum cases, and what employers and individuals can do now. Official documents to review include PM-602-0194, Presidential Proclamations 10949 and 10998, and the related State Department notice.
Policy Details and Adjudicative Hold
USCIS’s central mechanism is the adjudicative hold. In many cases, USCIS may still accept filings, issue receipt notices, schedule biometrics, request documents, and conduct interviews.
The key change is at the finish line. Final approvals (and in some cases final denials) may not be issued while the hold remains in place.
An analogy helps: think of a case as moving down an assembly line. Under the Benefits Pause, the line may keep moving through several workstations, but the case can be parked before the “release” step, and that parking can last indefinitely.
Practical effects often follow. Applicants may sit in limbo even after completing biometrics or interviews, and USCIS may send Requests for Evidence (RFEs), call people for interviews or re-interviews, and request additional biometrics.
- Longer pending periods. Applicants may remain in limbo after biometrics or interviews.
- More procedure during the wait. USCIS may issue RFEs, request re-interviews, or seek additional biometrics.
- Expiration management becomes harder. Passports, prior approvals, I-94 admission periods, and employment authorization documents can lapse while a new benefit stays pending.
- Case status tracking matters more. Pending cases can generate new notices with short response deadlines.
PM-602-0194 also directs retroactive re-review. Benefit requests approved on or after January 20, 2021 may be reopened or re-evaluated, meaning people who believed a case was “finished” may face a new review cycle.
Re-review can include requests for updated evidence, re-interviews, or additional vetting steps. Outcomes depend on the specific benefit type and the person’s facts, so individualized legal review is usually critical.
Readers should monitor official USCIS updates and seek individualized counsel to understand impact on their case timelines and work authorization.
Affected Countries: Lists and Scope
The country-based scope is tied to Presidential Proclamations 10949 and 10998, which are referenced as the basis for the “high-risk” designation. PM-602-0194 applies a two-tier structure: full restriction and partial/enhanced scrutiny.
Full restriction cases linked to these countries are subject to the strongest form of the Benefits Pause. Partial / enhanced scrutiny cases may face added review and can still be subject to the adjudicative hold.
Country-based rules raise practical questions such as citizenship versus country of birth and dual nationality. The memo describes coverage as nationals of, or individuals born in, designated countries, and USCIS may look at passports, birth certificates, prior immigration records, and identity documents.
People with dual nationality should not assume a “safer” passport always controls; nationality indicators across filings can still trigger review. Counsel may need to assess how prior filings listed citizenship, birth, and travel document history.
PM-602-0194 explicitly includes holders of Palestinian Authority documents in the full restriction category. That can matter even when a person’s personal background is more complex than a single label.
- Overall count: 39 total designated countries, with 19 in full restriction and 20 in partial/enhanced scrutiny.
The following lists preserve the original country breakdown. These are presented as prose and lists (not a table), so tools or interactive displays may be used later to show this information visually.
Full restriction (19): Afghanistan; Burma (Myanmar); Burkina Faso; Chad; Republic of the Congo; Equatorial Guinea; Eritrea; Haiti; Iran; Laos; Libya; Mali; Niger; Sierra Leone; Somalia; South Sudan; Sudan; Syria; Yemen; and holders of Palestinian Authority documents.
Partial / enhanced scrutiny (20): Angola; Antigua and Barbuda; Benin; Burundi; Côte d’Ivoire; Cuba; Dominica; Gabon; The Gambia; Malawi; Mauritania; Nigeria; Senegal; Tanzania; Togo; Tonga; Turkmenistan; Venezuela; Zambia; Zimbabwe.
Asylum Processing Status
Form I-589 (Asylum) processing remains paused indefinitely, regardless of country of origin. This is a separate, sweeping constraint that does not depend on the 39-country designation.
“Paused indefinitely” can be confusing: a person may be able to file and receive a receipt in many settings, but the key step—USCIS adjudication—may not move forward in a normal timeframe. When an asylum case is stalled, interview scheduling and expectations related to employment authorization timing can become harder to plan around.
Because asylum posture can vary widely by procedural history, prior entries, and prior filings, case-specific planning should be guided by official notices and qualified counsel.
Significance: Impacts on Employers and Individuals
A Benefits Pause changes day-to-day reality inside the United States. Someone can remain physically present, avoid international travel, and still lose predictability over status and work authorization because the “approval step” is frozen.
Employers feel the shock first in workforce continuity. A pending extension or change of status may not be enough if the employee’s current work authorization expires before USCIS can issue the final approval.
That uncertainty can affect onboarding, project staffing, and retention planning. HR teams may also face I-9 pressure, especially around reverification timing and document expiration.
Individuals often carry the heavier personal burden. Many will experience prolonged pending status, more mail from USCIS, and greater preparation demands for interviews or biometrics. Retroactive re-review since January 20, 2021 adds a second layer.
People who already received approvals may have to revisit old filings and explain inconsistencies that seemed settled years ago. Case-specific legal advice is generally important.
Do not travel internationally if your status is tied to a benefit subject to the adjudicative hold unless advised by counsel.
What Employers Need to Do: Actionable Steps
Employers can take practical steps without drifting into unlawful discrimination. The goal is compliance and continuity planning, not decisions based on nationality.
One way to frame the internal playbook is to mirror four common action items—while applying them through lawful, document-based processes and counsel review.
- Identify At-Risk Employees. Review immigration case types and filing histories in partnership with counsel, focusing on pending or soon-to-expire benefits rather than national origin.
- Plan for Authorization Gaps. Map expiration dates for I-9 reverification and current work authorization, and build contingency staffing options in case approvals are processed but not finalized.
- Minimize International Travel. Provide neutral guidance that travel can complicate cases on hold and advise employees to make travel decisions with individualized legal advice.
- Prepare for Re-Interviews. For workers with approvals since January 20, 2021, organize records now. Consistency across forms, prior addresses, employment history, and supporting documents matters, and good recordkeeping helps if USCIS requests updated biometrics or issues new RFEs.
Official Sources and References
Primary documents to review include:
- USCIS policy memorandum PM-602-0194 (posted on USCIS): PM-602-0194-PendingApplicationsAdditionalHighRiskCountries-20260101.pdf
- Presidential Proclamations 10949 and 10998, which PM-602-0194 cites for the high-risk country designations
- The related State Department notice referenced in connection with Proclamation 10998
When checking official updates, focus on any revisions to the list or scope, implementation guidance for adjudicators, FAQs addressing dual nationality and document issues, and any change to the duration or terms of the adjudicative hold.
Keep copies of every receipt notice, RFE, interview notice, and decision, as those documents often control deadlines and options. This article discusses policy changes with potential personal and business consequences and does not imply guaranteed outcomes.
For most families and employers, the immediate priority is simple: treat pending and recently approved cases as “active” again, track expirations aggressively, and make travel and work-authorization decisions only after individualized legal review.
USCIS has introduced a nationwide Benefits Pause affecting 39 countries, shifting the focus from travel restrictions to freezing status and work-authorization approvals for those already in the U.S. This policy includes an adjudicative hold on final decisions, indefinite pauses on asylum cases, and retroactive reviews of applications approved since early 2021. It creates significant uncertainty for workforce continuity and legal status management.
