On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a new policy memorandum, PM-602-0194, significantly expanding a pause on immigration benefit decisions for individuals from certain countries considered “high-risk” under Presidential Proclamation 10998, issued on December 16, 2025.
This policy is effective immediately and impacts a wide range of immigration applications — including some that were already approved.
What Does the New USCIS Policy Do?
Under PM-602-0194, USCIS officers are instructed to:
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Place a hold on most pending immigration benefit applications for individuals from the listed countries, regardless of when the person entered the United States
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Conduct a comprehensive review of USCIS policies, procedures, and vetting processes related to applications from these countries
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Re-review approved immigration benefits that were granted on or after January 20, 2021, for individuals from the affected countries
This means that cases that appeared “safe” or already approved may now face additional scrutiny.
Who Is Affected?
The adjudication pause applies to individuals based on nationality, country of birth, or citizenship obtained through investment, even if the person is already in the United States. It also applies to individuals using Palestinian Authority-issued or endorsed travel documents.
Countries subject to the pause include:
Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Côte d’Ivoire, Cuba, Dominica, Republic of the Congo, Equatorial Guinea, Eritrea, Gabon, The Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe.
Are There Any Exceptions?
Yes — but they are limited.
Certain applications are exempt from the adjudicative hold, including:
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Form I-90, N-565, and N-600
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Certain cases requested by law enforcement for public safety or national security reasons
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Limited work permit categories tied to cooperation with law enforcement
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Initial asylum-based work permits (Form I-765 category (c)(8))
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Cases determined to be in the U.S. national interest
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Athletes, coaches, and support staff participating in major international sporting events such as the World Cup or Olympics
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Certain benefit terminations that occur automatically when a person becomes a permanent resident or U.S. citizen
Any request for an exception must be coordinated directly with USCIS’s Office of Policy and Strategy (OP&S), and additional guidance is expected within the next 90 days.
What This Means for Applicants and Families
This policy is more than just a delay. The inclusion of re-reviewing already approved cases creates uncertainty for many individuals and families who believed their immigration matters were resolved.
If your case falls within this policy:
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Do not assume delays are routine
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Do not file new requests or inquiries without legal guidance
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Be cautious about travel, renewals, or follow-up filings
Every case is fact-specific, and missteps during this period can have serious consequences.
Final Thoughts
USCIS has broad discretion under this policy, and implementation details are still evolving. As further guidance is released, the impact of this adjudication pause may expand or shift.