By Sang M. Shin and Emmanuel Arowolo

The U.S. Citizenship and Immigration Services announced Tuesday an immediate hold on all pending asylum applications and a pause on the adjudication of a broad range of immigration benefit requests filed by nationals of 19 countries designated as “high risk” by the Trump administration. The action follows the shooting of two National Guard members and is tied to the country list referenced in Presidential Proclamation 10949. In addition to pausing pending requests, USCIS will re‑review certain previously approved benefits for affected nationals who entered the United States on or after January 20, 2021.

USCIS Guidelines

USCIS has implemented two parallel measures pending a comprehensive review:

• Asylum applications (Form I‑589): USCIS has placed an immediate hold on all Forms I‑589, regardless of the applicant’s nationality. These applications will not move forward until the review is complete.
• Other immigration benefits for designated nationals: Separately, USCIS has paused adjudication of pending immigration benefit requests for applicants who list one of 19 designated countries as their country of birth or citizenship, regardless of date of entry. For these applicants, requests will not be considered until further review.

The policy memorandum also mandates a comprehensive re‑review of certain previously approved benefits for nationals of the 19 countries who entered the United States on or after January 20, 2021. Impacted individuals will undergo renewed vetting—potentially including an interview and, if needed, a re‑interview—to assess national security and public safety risks. USCIS emphasizes that all reviews will be individualized and conducted on a case‑by‑case basis, considering all relevant information and facts.

For applicants who list one of these 19 countries as their country of birth or citizenship, USCIS will not consider requests for benefits until the review is complete. Affected benefits include, among others, applications to register permanent residence, applications to replace a green card, and applications for documents related to travel, parole, and arrival/departure records.

USCIS referenced the country list in Presidential Proclamation 10949. Under that framework, the government restricts the entry of citizens of certain countries and partially restricts entry from others.

Designated Countries and Entry Restrictions

What to Expect

USCIS has not provided a timeline for completing the review. Given the extent of the asylum hold and the pause on benefits affecting the 19 nationalities, applicants, petitioners, and employers should anticipate material delays and potential requests for evidence or interviews once vetting resumes. Employers should plan for possible disruptions to onboarding, travel, document renewals, I‑9 reverifications, and related compliance calendars.

How Jackson Walker Can Help

Jackson Walker’s immigration team is monitoring implementation and can advise on strategy, timing, documentation, interview preparation, and contingency planning for travel and employment verification, as well as coordinate communications with USCIS as the review proceeds.

The opinions expressed are those of the author and do not necessarily reflect the views of the firm, its clients, or any of its or their respective affiliates. This article is for informational purposes only and does not constitute legal advice. For assistance, please contact an attorney in Jackson Walker’s Business Immigration & Compliance practice.

Meet Sang

Sang M. Shin is a business immigration attorney with broad experience managing immigration matters for companies, individuals, investors, and institutions through the U.S. and internationally. Sang handles a wide range of nonimmigrant visas and petitions and provides advanced and strategic advice to clients on a variety of immigrant visas and labor certification (PERM). Sang also helps foreign companies with their U.S. market entry, growth, and expansion efforts as they enter the United States by serving as outside counsel to their various legal needs.

Meet Emmanuel

Emmanuel Arowolo is a corporate immigration attorney who advises U.S. and multinational employers on employment-based immigration. He handles nonimmigrant visas (L-1, H-1B, TN, E-2, E-3), and investment visas and applications for permanent residency, including PERM and immigrant visa petitions, with a focus on efficient, compliant, and scalable programs. He also counsels on EB-5, including regional center investments, evidentiary strategy, and source-of-funds.