Immigrants across the United States 🇺🇸 say the ground has shifted under their feet since a run of federal actions in late 2025 that pause or slow immigration decisions, order fresh reviews of past approvals, and make it harder for some people to keep working while they wait. The centerpiece is a USCIS Policy Memorandum dated Dec. 2, 2025, which, according to the provided material, was issued after the Department of Homeland Security directed U.S. Citizenship and Immigration Services to hold and review “all Pending Asylum Applications” and other benefit requests filed by nationals of 19 designated “High‑Risk Countries.” The policy has left many families unsure whether to stay put, renew leases, keep jobs, or travel, because the same filing that once brought progress can now bring a long pause—and, for some, a second look at approvals they thought were settled.
What the Dec. 2, 2025 memo does

- The memo’s full title is: “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High‑Risk Countries.”
- It calls for suspending processing of asylum claims filed on Form I‑589 and suspending other pending immigration benefit requests for nationals of the 19 designated countries.
- Asylum seekers file the I‑589 to ask for protection because they fear harm back home; the form itself is public, but the decision can shape the rest of a person’s life. The official page for Form I-589, Application for Asylum and for Withholding of Removal includes filing information and updates, and applicants often rely on it when policy changes interrupt routine processing.
Backward reach: re-reviews of past approvals
- Beyond freezing new decisions, DHS and USCIS ordered comprehensive re-reviews of previously approved benefits for nationals of the 19 countries who entered the United States on or after Jan. 20, 2021.
- USCIS said it would create a prioritized re-review list within 90 days of implementation.
- The source material indicates that cases may be referred to immigration enforcement as a result of these re-reviews.
- For many immigrants, this is particularly alarming: it suggests previously approved grants could be re-examined, with requests for documents, re-interviews, or even rescission.
Additional agency actions in late 2025
- A separate USCIS guidance memo dated Nov. 27, 2025 broadened how officers can weigh “country-specific factors” when deciding discretionary benefits. This affects decisions that rely on officer judgment as well as strict eligibility.
- The Department of State issued enhanced vetting guidance from Dec. 3 to Dec. 15, 2025, applying negative, country-specific factors to H‑1B and H‑4 visa applicants; these changes took effect in mid-December.
- Taken together, these measures create a pattern: being from a listed country can trigger deeper screening at consulates, the border, and within USCIS casework—even for people who have lived in the U.S. for years.
The 19‑country framework
- The source material links the 19-country approach to a June 4, 2025 Presidential Proclamation, followed by later USCIS and DHS guidance.
- It does not provide a single, complete list of all 19 countries in one place, but it identifies several that appear in commentary and legal analyses:
- Afghanistan, Burma (Myanmar), Chad, the Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen
- People from those countries are now encountering a mix of paused adjudications, added screening, and in some cases travel and visa restrictions.
- Even immigrants who do not see their country listed in public summaries worry about sudden additions, because details can shift through memos, advisories, and court filings.
Immediate effect on asylum seekers and ripple effects
- Practically, a person can file the I‑589, receive a receipt, and still face a long stretch with no decision because processing is suspended for targeted nationalities.
- That delay can ripple through every part of life: asylum applicants often seek work authorization while their cases are pending and build daily plans around expected processing timelines.
- When the federal government pauses adjudications, it can also pause eligibility for related steps—such as renewals or follow-on filings—creating what analysts call “shadow backlogs.” According to analysis by VisaVerge.com, blanket holds tend to create these situations where cases appear pending but are not moving through normal queues.
Change to Employment Authorization Document (EAD) automatic extensions
- A DHS final rule published Oct. 30, 2025 ended the 540‑day automatic extension of Employment Authorization Documents for renewal filings made on or after that date.
- Automatic extensions have been crucial because many immigrants file to renew work permits on time but still wait months for a decision; the extension allowed continued employment while USCIS processed renewals.
- With the 540‑day policy ended, people whose renewals are stuck—especially those affected by High‑Risk Country pauses—face a sharper risk of losing the legal ability to work, even after timely filing.
Human impact and practical concerns
- Agency language about “holds” and “re-review lists” understates the human cost. Many immigrants plan around steady expectations: keep a job, pay taxes, attend check-ins, file renewals, and wait for decisions.
- When a case is paused, families can’t easily answer basic questions—whether to sign a new lease, buy a car, or accept a promotion that requires travel.
- For people from countries like Haiti, Sudan, or Yemen, re-reviews can be retraumatizing: they may be asked to retell why they fled, re-collect hard-to-obtain documents, or explain gaps common to those escaping conflict.
Important: The memos raise the prospect of referrals to enforcement and possible removal proceedings for some people if approvals are rescinded or reclassified. This can change how people interact with public life—from reporting crimes to seeking medical care—and it can create fear for mixed-status families.
Litigation and uncertainty
- The source material describes lawsuits and injunctions in other policy areas and says multiple legal challenges are underway against parts of the administration’s measures.
- It does not name specific cases, courts, judges, or the officials who signed the key memos. That missing detail matters because many immigrants ask, “Who decided this, and can a court stop it?”
- For now, the material indicates that many suspensions and guidance documents remain in effect while litigation proceeds, leaving people to live between changing policy and uncertain court timelines.
Practical advice from legal service groups
- Legal service groups and attorneys advise affected immigrants not to disappear from the system, even if stopping filings feels safer.
- The source material reports these common recommendations:
- Continue to file timely applications—USCIS guidance does not bar filing when adjudication is suspended.
- Keep careful records of filings, receipts, and correspondence.
- Hold on to proof of lawful entry or status.
- Prepare for possible re-interviews and requests for documents if past approvals are reopened.
- National groups tracking updates include the American Immigration Lawyers Association (AILA) and the National Immigration Law Center (NILC), along with local clinics that assist communities as changes are issued.
Why the moment is destabilizing
- What makes this period unusually destabilizing is the layering of tools rather than a single rule:
- USCIS holds on pending adjudications (Dec. 2, 2025 memo).
- State Department enhanced vetting affecting visas (Dec. 3–15, 2025 guidance).
- DHS changes to EAD automatic extensions (Oct. 30, 2025 final rule).
- An individual could face a paused asylum case, a shorter work-authorization runway, and tougher visa screening for family members abroad—all tied to the High‑Risk Countries framework.
Where to find authoritative updates
- For applicants checking next steps, the safest sources for case and filing updates are official agency postings—including USCIS’s form pages and policy alerts—because instructions can change quickly as litigation and internal guidance evolve.
- As noted earlier, the official I‑589 page is: Form I-589, Application for Asylum and for Withholding of Removal.
Key dates and actions (summary table)
| Date | Agency/Action | What changed or was announced |
|---|---|---|
| Oct. 30, 2025 | DHS final rule | Ended 540‑day automatic extension for EAD renewals filed on/after this date |
| Nov. 27, 2025 | USCIS guidance memo | Broadened consideration of country-specific factors for discretionary benefits |
| Dec. 2, 2025 | USCIS Policy Memorandum | Hold and review of pending asylum and other benefit applications from nationals of 19 High‑Risk Countries |
| Dec. 3–15, 2025 | Department of State guidance | Enhanced vetting applying negative country-specific factors to H‑1B and H‑4 applicants |
If you’d like, I can:
– Turn the list of identified countries into a printable checklist.
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– Draft a short script for clients to use when contacting legal aid or USCIS about their cases.
A Dec. 2, 2025 USCIS memorandum ordered holds and reviews of pending asylum claims and other benefit applications for nationals of 19 High‑Risk Countries. DHS also ended the 540‑day EAD automatic extension (Oct. 30, 2025), while USCIS expanded country-specific vetting (Nov. 27, 2025). USCIS will prioritize re-reviews within 90 days for entrants since Jan. 20, 2021. The measures increase delays, risk rescissions, and sparked litigation and guidance urging applicants to keep filings and records current.
