On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum directing officers to hold and further review certain pending immigration benefit applications filed by (or on behalf of) individuals connected to additional “high-risk” countries. This memo is referred to as the USCIS high-risk country hold memo January 2026.
For many immigrants, families, and employers, the practical impact is simple:
Even if a case is approvable, USCIS may pause final adjudication until enhanced review is completed.
You can read the memo here:
USCIS Policy Memorandum PM-602-0194 (January 1, 2026)
To understand why the January memo matters so much, it also helps to read the earlier memo that created the initial “hold-and-review” framework:
USCIS Policy Memorandum PM-602-0192 (December 2, 2025)
Quick Answer: What the January 1, 2026 USCIS Memo Does
The January 1, 2026 USCIS memo (PM-602-0194) directs USCIS to place an adjudicative hold on certain pending benefit applications connected to designated “high-risk” countries. USCIS can continue internal processing, but the memo authorizes USCIS to delay final approval until additional screening and review are completed.
The memo also directs USCIS to re-review certain approvals issued on or after January 20, 2021 involving affected nationals, which can add uncertainty even for some people who believed their case was finalized.
Fast Facts: USCIS Hold-and-Review Memo (January 1, 2026)
- USCIS has ordered holds on certain pending immigration benefits for nationals of designated high-risk countries.
- The most common result is delay, not automatic denial.
- USCIS can keep working the file but pause final approval pending enhanced review.
- Some applicants will receive RFEs or additional questioning as part of the screening process.
- EAD work permits and Advance Parole travel documents may be delayed for affected nationals.
- Naturalization (N-400 citizenship cases) may also be delayed for affected nationals.
- USCIS may re-review certain approvals going back to January 20, 2021.
- If your status or work authorization is time-sensitive, proactive planning is essential.
What Is USCIS Policy Memorandum PM-602-0194?
USCIS Policy Memorandum PM-602-0194 is titled:
“Hold and Review of USCIS Benefit Applications Filed by Aliens from Additional High-Risk Countries.”
This is a USCIS adjudication directive. It is not a statute passed by Congress. However, USCIS policy memoranda are highly consequential because they determine how USCIS officers handle:
- internal case routing
- evidence requirements
- interviews and re-interviews
- holds versus approvals
- escalation to additional screening steps
Memo source:
USCIS PM-602-0194
What “Adjudicative Hold” and “Enhanced Review” Mean in Real Life
When USCIS places a case on adjudicative hold, it often means:
- biometrics were completed
- documentation appears sufficient
- an officer can evaluate eligibility
- but USCIS will not finalize the decision until additional screening clears
For applicants, this commonly looks like a case that is “stuck” with no meaningful updates.
You can still monitor status here:
USCIS Case Status Online
And compare processing norms here:
USCIS Processing Times
Can USCIS Approve These Benefit Applications After Enhanced Review?
Yes. USCIS is allowed to approve covered benefit applications after enhanced review is completed, assuming the applicant is otherwise eligible.
This policy is best understood as:
- a delay mechanism, not an automatic denial rule
- a hold pending internal clearance, not a permanent legal bar to approval
That said, these holds can feel “indefinite” because USCIS often does not provide a clear timeline for when enhanced screening will finish.
Key takeaway: Approval is possible, but the timeline may become unpredictable.
What Is the Difference Between the December 2, 2025 Memo and the January 1, 2026 Memo?
USCIS issued two closely linked memos:
December 2, 2025 memo (PM-602-0192): Created the hold-and-review system
The December memo established the initial hold-and-review framework for 19 high-risk countries.
Memo: USCIS PM-602-0192
January 1, 2026 memo (PM-602-0194): Expanded the hold system to more countries
The January memo expanded the same framework by adding 20 additional countries, dramatically increasing the number of pending cases subject to enhanced review.
Memo: USCIS PM-602-0194
One-sentence summary:
The December memo created the USCIS hold-and-review process, and the January memo expanded it to additional countries, increasing delays and enhanced screening for many more applicants.
Which Countries Are Covered by the USCIS “High-Risk Country” Holds?
One of the most asked questions in 2026 is: “Is my country on the list?”
Countries covered under the earlier “high-risk” USCIS hold framework (19)
- Afghanistan
- Burma (Myanmar)
- Chad
- Republic of the Congo
- Equatorial Guinea
- Eritrea
- Haiti
- Iran
- Libya
- Somalia
- Sudan
- Yemen
- Burundi
- Cuba
- Laos
- Sierra Leone
- Togo
- Turkmenistan
- Venezuela
Framework memo: USCIS PM-602-0192
Additional countries added effective January 1, 2026 (20)
- Angola
- Antigua and Barbuda
- Benin
- Burkina Faso
- Côte d’Ivoire (Ivory Coast)
- Dominica
- Gabon
- The Gambia
- Malawi
- Mali
- Mauritania
- Nigeria
- Niger
- Senegal
- South Sudan
- Syria
- Tanzania
- Tonga
- Zambia
- Zimbabwe
A widely circulated summary list is compiled here (useful for readers cross-checking):
Expanded USCIS high-risk country processing holds (summary)
Additional designation frequently noted in summaries
Some institutional summaries also note screening triggers related to Palestinian Authority-issued or endorsed travel documents.
See: Summary discussion (Grossman Young)
Important note:
USCIS implementation can evolve. The best practice is to treat the USCIS memo itself as the controlling source and consult counsel for complicated nationality or travel-document situations.
Does This USCIS Memo Affect Naturalization (N-400 Citizenship Cases)?
Yes. Naturalization is one of the most overlooked impacts of these memos.
If you are a national of one of the designated high-risk countries and you filed Form N-400, USCIS may:
- conduct enhanced review
- delay a final decision
- postpone oath scheduling even after the interview is completed
In other words, a naturalization case can be moving forward procedurally but still be unable to finalize until the hold clears.
Naturalization overview:
USCIS Citizenship and Naturalization
Can USCIS approve a Palestinian N-400 after enhanced review?
Yes. A Palestinian N-400 can still be approved after enhanced review if the applicant meets the requirements and clears vetting. Enhanced review generally functions as a delay and screening requirement—not a categorical citizenship ban.
What Types of Immigration Benefits Can USCIS Delay Under These Holds?
The memo covers “USCIS benefit applications” broadly. In practice, these holds can affect the benefits people rely on most.
1) Adjustment of Status (I-485 green card inside the U.S.)
Adjustment of status applicants may see delays in:
- interview scheduling
- post-interview approval
- final card production timing
Overview:
USCIS Adjustment of Status
2) Work permits (EAD)
EAD delays can trigger cascading harm:
- lost wages
- job disruption
- employer compliance headaches
Expedite starting point:
How to Make an Expedite Request (USCIS)
3) Travel documents (Advance Parole)
Advance Parole is especially sensitive because travel plans can become unsafe or impossible while cases are delayed.
Overview:
USCIS Travel Documents
Re-Review of Prior Approvals: Why That Matters for Families and Workers
A major feature of these memos is that USCIS is not only placing holds on pending cases—it is also directed to re-review certain approvals going back to January 20, 2021 for affected nationals.
This does not automatically mean USCIS will revoke prior approvals. But it can lead to:
- reopened scrutiny
- additional screening in future filings
- delayed follow-up benefits
- future adjudications being slowed due to prior flags
Institutional summaries tracking implementation:
Yale OISS summary of expanded holds
UC Berkeley International Office summary
What You Should Do Right Now If Your Case Is Pending (Practical Checklist)
If you believe you are affected, rely on documentation and planning—not rumors.
Step 1: Confirm the trigger (nationality and travel-document details)
Confirm:
- citizenship
- dual citizenship
- what nationality appears in USCIS filings
- travel-document history where relevant
Step 2: Avoid risky travel assumptions
If you have a pending I-485 or pending travel authorization, do not assume normal timelines apply.
Start here:
USCIS Travel Documents
Step 3: Build a “clean evidence file” now
Prepare a ready-to-produce set of documents:
- identity and civil records
- full immigration history
- address history
- work and school records
- prior approvals and notices
- travel record consistency
Step 4: Monitor deadlines and processing expectations
Use:
USCIS Case Status
USCIS Processing Times
Step 5: Consider expedite strategies when the harm is severe
Expedite rules:
USCIS Expedite Requests
Scenario-Based Guidance (What This Looks Like in Real Cases)
Scenario 1: Pending I-485 for applicant from a designated country
Risk level: Medium
Likely USCIS action: Hold final adjudication for enhanced review
Consequences: Green card delayed, life planning disrupted
Options: Maintain stability, preserve eligibility evidence, minimize travel risk
Scenario 2: EAD renewal pending and current EAD is expiring
Risk level: High
Likely USCIS action: Delay EAD issuance pending enhanced review
Consequences: Work interruption, income loss
Options: Employer support letters, possible expedite strategy
Start here: USCIS expedite request guidance
Scenario 3: N-400 interview completed but oath is not scheduled
Risk level: Medium
Likely USCIS action: Delay decision or oath scheduling pending hold clearance
Consequences: Citizenship timeline uncertainty
Options: Track case, prepare for follow-up questions
Overview: USCIS naturalization overview
Scenario 4: Advance Parole pending but family emergency requires travel
Risk level: High
Likely USCIS action: Delay travel document issuance
Consequences: Inability to travel, high-risk travel decisions
Options: Consult counsel before leaving the U.S.
Overview: USCIS travel documents
Scenario 5: Employer-sponsored worker needs extension while case is delayed
Risk level: Medium to High
Likely USCIS action: Slow decision issuance due to screening requirements
Consequences: Business disruption, employment uncertainty
Options: Workforce planning and careful filing strategy
Timeline tool: USCIS processing times
Scenario 6: Previously approved benefit is flagged for re-review
Risk level: High
Likely USCIS action: File re-review and follow-up action
Consequences: Uncertainty even after approval
Options: Preserve records and get legal counsel early
FAQs
1) Is this a permanent pause, or can USCIS approve after enhanced review?
USCIS can approve after enhanced review if the case is eligible and clears screening. The memos authorize holds and additional review, which often cause delays, but they do not create an automatic permanent denial policy.
2) Is USCIS putting naturalization (N-400) applications on hold?
For affected nationals, USCIS may delay final decisions on naturalization cases while enhanced review is completed, including delaying oath scheduling.
3) Does this memo mean USCIS will deny all cases from high-risk countries?
No. The most common result is delay. Some cases are approved after review, while others may receive RFEs or be denied if USCIS finds a legal eligibility issue.
4) Will this affect work permits (EAD)?
It can. Some EAD processing may slow down for affected nationals due to additional screening requirements.
5) Will this affect Advance Parole travel documents?
It can. Travel document processing may slow down, which can create hardship for people facing urgent family emergencies.
6) What if my interview already happened?
USCIS can still place a case on hold after an interview pending enhanced review.
7) Should I withdraw and refile to restart the clock?
Usually not. Withdrawing and refiling often creates more risk, more delay, and new documentary burdens.
8) How do I check whether my country is covered?
Start with the memo itself: USCIS PM-602-0194
9) What if I have dual citizenship?
Dual citizenship can complicate screening triggers. Confirm what USCIS has recorded in your filings and consult counsel if there is uncertainty.
10) What documents should I prepare now?
Prepare identity documents, consistent travel and address history, immigration records, and proof supporting eligibility so you can respond quickly to any RFE or interview questions.
11) Can USCIS re-review older approvals?
Yes. These memos direct USCIS to re-review certain approvals issued on or after January 20, 2021 for affected nationals.
12) How long will the hold last?
USCIS does not provide a reliable public timeline. Some cases resolve quickly; others can remain pending for extended periods.
13) Can a Palestinian N-400 be approved after enhanced review?
Yes. Enhanced review can delay a case, but approval remains legally possible if the applicant meets the requirements and clears vetting.
14) What should employers do if a worker’s case is delayed?
Employers should plan for timelines, maintain compliant documentation, and consider whether an expedite request may be appropriate in severe hardship situations.
15) When should I speak with an immigration lawyer?
If you are facing status expiration, employment interruption, urgent travel, or an unusually long delay, legal strategy may prevent avoidable harm.
What This Means Going Forward
USCIS has made clear that for certain designated countries, some immigration and citizenship applications will move more slowly due to enhanced screening and internal review requirements. In 2026, the safest planning assumptions are:
- longer timelines
- unpredictable hold durations
- more evidence requests
- fewer “normal processing” expectations
If your case is pending and the stakes are high, the safest approach is early planning rather than waiting for a crisis. If you want help developing a strategy for a pending case affected by USCIS delays, you can schedule a consultation here:
Book a consultation with Herman Legal Group
If your case is pending and time-sensitive, the safest strategy is early planning rather than last-minute crisis response.
Resource Directory
USCIS Primary Sources (Start Here)
- USCIS Policy Memorandum PM-602-0194 (Jan. 1, 2026)
- USCIS Policy Memorandum PM-602-0192 (Dec. 2, 2025)
- USCIS Case Status Online
- USCIS Processing Times
- USCIS Contact Center
- USCIS Request for Case Assistance (Online Tools)
- USCIS How to Make an Expedite Request
- USCIS Policy Manual
USCIS Benefit Pages Commonly Affected by “Hold and Review”
- Adjustment of Status (Green Card Inside the U.S.)
- Employment Authorization Document (EAD)
- Travel Documents (Advance Parole)
- Citizenship and Naturalization (N-400)
Federal Court Delay Tools (For Unreasonable Processing Delays)
Institutional Immigration Office Summaries (Clear, Practical Explainers)
- Yale OISS – Expanded USCIS “Hold and Review” Summary
- UC Berkeley International Office – Hold and Review Guidance
