USCIS Expands Immigration Application Freeze to 39 Countries

U.S. Citizenship and Immigration Services (USCIS) has issued a new policy memorandum formally expanding its pause on immigration benefit adjudications to cover nationals of all countries included in President Trump’s expanded travel ban.

The memorandum, issued January 1, 2026, broadens an earlier USCIS directive that applied to 19 countries. Under the updated policy, USCIS officers must place holds on most pending immigration benefit applications filed by or on behalf of nationals of the 39 countries covered by the expanded travel restrictions announced in December.

The directive is effective immediately and affects a wide range of immigration benefits, including green card applications, naturalization requests, work permits, and other filings processed by USCIS.

What the New USCIS Memo Does

Under the updated guidance, USCIS officers may continue reviewing affected cases but generally may not issue final decisions while the hold is in place, unless an exception applies. The agency also confirmed that previously approved cases may be subject to renewed scrutiny, particularly those approved on or after January 20, 2021.

The memo adds procedural detail that was not included in earlier guidance, outlining how cases should be identified, held, and reviewed while USCIS evaluates its screening and vetting practices for applicants from affected countries.

USCIS said it expects to prioritize a subset of cases for additional review and interviews and to issue further operational guidance within 90 days.

Exceptions Clarified

For the first time, USCIS has outlined a clearer set of exceptions to the adjudication hold. Certain applications may continue to move forward, including select document replacement filings, limited categories of employment authorization, some citizenship-related applications, and cases determined to be in the national interest.

The memo also notes that professional athletes and essential support staff participating in major international competitions may qualify for exceptions.

At the same time, the guidance makes clear that some applicants who were previously treated as broadly exempt, including certain family-based cases, are no longer automatically excluded from review.

Who Is Affected

The expanded adjudication hold applies to pending applications filed by nationals of all countries covered by the expanded travel ban. Many of those affected are already living and working in the United States and are seeking to adjust status, renew work authorization, or complete the naturalization process.

Immigration attorneys report that USCIS continues to cancel or postpone interviews, oath ceremonies, and other appointments as the agency implements the new policy.

Why This Matters

While the travel ban focuses on who may enter the United States, the USCIS adjudication pause affects individuals who are already inside the immigration system and pursuing lawful permanent residence or citizenship.

For employers, the policy introduces new uncertainty around work authorization timelines, onboarding, and workforce planning. For families, it increases the risk of prolonged delays for cases that were previously nearing completion.

USCIS has not said how long the adjudication holds will remain in place, beyond indicating that additional guidance is expected following the agency’s internal review period.

Boundless will continue monitoring developments and updating its guidance as USCIS releases further details on how the expanded adjudication pause will be implemented.

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