U.S. Citizenship and Immigration Services (USCIS) has issued an immediate, sweeping Policy Memorandum (PM-602-0192) that significantly impacts the adjudication process for asylum claims and various other immigration benefits. The agency has put a blanket adjudicative hold on all asylum cases and is pausing the processing of benefit requests for applicants from 19 designated countries, citing national security concerns.

Our team at Cohen, Tucker + Ades is closely monitoring the implementation of this directive and strongly advises all affected individuals to consult with counsel immediately.

🛑 IMMEDIATE IMPACT: Cases on Adjudicative Hold

Effective immediately, USCIS personnel are directed to place a hold on the following two categories of pending applications:

USCIS states that this hold will remain in effect until the Director issues a subsequent memorandum to lift it.

Affected Countries (PP 10949)

The hold on benefit requests applies to aliens who list one of the following 19 countries as their Country of Birth or Country of Citizenship:

• Full Restriction: Afghanistan, Myanmar (Burma), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, and Yemen.

• Partial Restriction: Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.

🔎 Comprehensive Re-Review of Approved Cases

The new Policy Memorandum mandates a comprehensive re-review of approved benefit requests for aliens from the 19 high-risk countries who entered the United States on or after January 20, 2021.

What This Means:

• Mandatory Interviews: Interviews for this population cannot be waived under any circumstance. Affected individuals must undergo a thorough re-review, including a potential re-interview, to fully assess national security and public safety threats.

• Referral Risk: USCIS states it will prioritize a list for review and, if deemed necessary, referrals to ICE and other law enforcement agencies for further action.

• Rationale: The memorandum explicitly cites recent criminal and terrorist activity by certain foreign nationals as justification for the urgent need to ensure maximum vetting and screening.

⚠️ Our Guidance for Affected Clients

USCIS has acknowledged that these steps will result in processing delays for applicants. The agency has determined that the burden of these delays is “necessary and appropriate” when weighed against the obligation to protect national security.

If you or your family members are affected by this memorandum, we advise the following:

1. Understand Your Case Status: If you have a pending asylum application (Form I-589), understand that your case will not move forward until the hold is lifted.

2. Prepare for a Re-Interview: If you are a national of one of the 19 countries and adjusted status or received a benefit on or after January 20, 2021, you must prepare for a mandatory, non-waivable re-interview and thorough security vetting.

3. Prioritize Document Review: Ensure all documentation related to your identity, history, and travel is complete, accurate, and ready for immediate review.

Our dedicated immigration team is actively analyzing this guidance to understand the full scope of its impact on specific immigration benefit types and will provide strategic counsel tailored to your unique circumstances. Please contact us immediately if you believe you are affected by this adjudicative hold or re-review directive.

Disclaimer: This blog post contains general information and is for informational purposes only. It is not legal advice and does not create an attorney-client relationship between you and Cohen, Tucker + Ades P.C. Immigration laws and fee schedules are subject to frequent change. The information provided herein may not reflect the most current legal developments. You should not act or refrain from acting based on information contained in this post without seeking professional counsel from an attorney licensed in your jurisdiction. Cohen, Tucker + Ades P.C. expressly disclaims all liability in respect to actions taken or not taken based on any or all of the contents of this post.

Sources: 

USCIS | Policy Memorandum: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries