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)
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.
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:
Memo source:
USCIS PM-602-0194
When USCIS places a case on adjudicative hold, it often means:
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
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:
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.
USCIS issued two closely linked memos:
The December memo established the initial hold-and-review framework for 19 high-risk countries.
Memo: USCIS PM-602-0192
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.
One of the most asked questions in 2026 is: “Is my country on the list?”
Framework memo: USCIS PM-602-0192
A widely circulated summary list is compiled here (useful for readers cross-checking):
Expanded USCIS high-risk country processing holds (summary)
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.
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:
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
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.
The memo covers “USCIS benefit applications” broadly. In practice, these holds can affect the benefits people rely on most.
Adjustment of status applicants may see delays in:
Overview:
USCIS Adjustment of Status
EAD delays can trigger cascading harm:
Expedite starting point:
How to Make an Expedite Request (USCIS)
Advance Parole is especially sensitive because travel plans can become unsafe or impossible while cases are delayed.
Overview:
USCIS Travel Documents
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:
Institutional summaries tracking implementation:
Yale OISS summary of expanded holds
UC Berkeley International Office summary
If you believe you are affected, rely on documentation and planning—not rumors.
Confirm:
If you have a pending I-485 or pending travel authorization, do not assume normal timelines apply.
Start here:
USCIS Travel Documents
Prepare a ready-to-produce set of documents:
Use:
USCIS Case Status
USCIS Processing Times
Expedite rules:
USCIS Expedite Requests
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
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
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
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
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
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
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.
For affected nationals, USCIS may delay final decisions on naturalization cases while enhanced review is completed, including delaying oath scheduling.
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.
It can. Some EAD processing may slow down for affected nationals due to additional screening requirements.
It can. Travel document processing may slow down, which can create hardship for people facing urgent family emergencies.
USCIS can still place a case on hold after an interview pending enhanced review.
Usually not. Withdrawing and refiling often creates more risk, more delay, and new documentary burdens.
Start with the memo itself: USCIS PM-602-0194
Dual citizenship can complicate screening triggers. Confirm what USCIS has recorded in your filings and consult counsel if there is uncertainty.
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.
Yes. These memos direct USCIS to re-review certain approvals issued on or after January 20, 2021 for affected nationals.
USCIS does not provide a reliable public timeline. Some cases resolve quickly; others can remain pending for extended periods.
Yes. Enhanced review can delay a case, but approval remains legally possible if the applicant meets the requirements and clears vetting.
Employers should plan for timelines, maintain compliant documentation, and consider whether an expedite request may be appropriate in severe hardship situations.
If you are facing status expiration, employment interruption, urgent travel, or an unusually long delay, legal strategy may prevent avoidable harm.
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:
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.
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