The U.S. immigration landscape underwent a seismic shift this week. On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0192, titled “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries”.
For thousands of applicants—including investors, professionals, and families—this new directive effectively presses the “pause” button on their immigration journey.
At Kameli Law, we understand the anxiety this news brings. Here is a comprehensive breakdown of the policy, who it affects, and why securing experienced legal counsel is now more critical than ever.
1. The Three Critical Mandates of the New Policy
Citing national security concerns and Presidential Proclamation (PP) 10949, USCIS has instructed its officers to take immediate action in three specific areas:
A. A Total Halt on All Asylum Applications
USCIS has placed a hold on all Forms I-589 (Application for Asylum and for Withholding of Removal) pending a comprehensive review.
Crucial Note: This applies to every applicant, regardless of their country of nationality. If you have a pending asylum case, it is currently frozen.
B. Immediate Freeze on Benefits for “High-Risk” Countries
For nationals of the 19 countries listed in PP 10949, USCIS has placed a hold on pending benefit requests. This is sweeping and includes:
- Form I-485: Adjustment of Status (Green Card applications).
- Form I-131: Travel Documents and Parole.
- Form I-751: Removal of Conditions.
- Form N-470: Preservation of Residence for Naturalization.
This hold applies regardless of when you entered the United States.
C. Retroactive Re-Review of Approved Cases
Perhaps the most alarming aspect of this memo is the mandate for a comprehensive re-review of previously approved benefits. If you are from one of the 19 high-risk countries and entered the U.S. on or after January 20, 2021, your approved status may be re-examined.
2. Which Countries Are Considered “High-Risk”?
While the memo references Presidential Proclamation 10949, widely reported lists of the 19 affected nations include several countries with significant immigrant populations in the U.S., such as Afghanistan, Iran, Yemen, Sudan, Somalia, and others.
If you were born in or are a citizen of one of these nations, your pending applications are subject to this new, rigorous security vetting.
3. What This Means for Employment-Based Applicants (EB-1, NIW, EB-5)
Many of our clients at Kameli Law are high-skilled professionals (EB-1/NIW) or investors (EB-5). Even if your underlying petition (I-140 or I-526E) is strong, your Adjustment of Status (I-485) is likely affected if you are from a listed country.
Mandatory Interviews:
The policy states that for the re-review population, interviews “shall not be waived under any circumstance”.
Delays are Expected:
USCIS acknowledges that this directive “may result in delay to the adjudication of some pending applications” but deems it necessary for national security.
Risk of Re-Interview:
Even if you have already been interviewed, you may be called in for a “re-interview” to assess national security threats.
4. Why You Cannot Face This Alone
The memo explicitly instructs officers to conduct “individualized, case-by-case review and assessment”. They are looking for any links to “national security and public safety threats”.
In this environment, a simple misunderstanding or a documentation error during an interview could lead to severe consequences.
Kameli Law has been navigating complex immigration landscapes since 1996. Attorney Taher Kameli and our team are prepared to:
- Analyze your specific risk factor based on your country of origin and entry date.
- Prepare you intensively for mandatory interviews. We ensure your answers are clear, accurate, and consistent.
- Monitor your case status and intervene if the hold is applied incorrectly.
Take Action Today
Do not wait for a rejection notice or a confusing Request for Evidence (RFE). If you are from a high-risk country or have a pending asylum claim, you need a strategic legal plan immediately.
Contact Kameli Law today for a consultation.
