Quick Answer:

The recent USCIS PM-602-0192 freeze has significant implications for immigration processes.

On December 2, 2025, USCIS issued Policy Memorandum PM-602-0192, ordering officers to “hold and review”:

All pending asylum applications (Form I-589) — for every nationality, and

All pending USCIS “benefit requests” filed by people from 19 “high-risk” / travel-ban countries, plus a re-review of already-approved benefits for those nationals.

Your case may still show as “pending” or “actively being reviewed” online — but behind the scenes, many files are frozen in place until Washington decides what to do next.

Fast Facts: What PM-602-0192 Does in One Glance

Date & name:
USCIS Policy Memorandum PM-602-0192, “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries,” issued December 2, 2025.
Three big instructions to officers:
1. Stop adjudicating all pending asylum applications (I-589), regardless of nationality.
2. Stop adjudicating all pending benefit requests for people whose country of birth or citizenship is on the 19-country travel-ban list.
3. Re-review already-approved benefits for those nationals who entered the U.S. on or after January 20, 2021 — with power to re-interview, issue NOIDs, revoke, or refer to ICE.
What counts as a “benefit request”?
Nearly everything people file with USCIS: I-485, I-130, I-140, I-129 (H-1B), I-765 (EAD), I-131 (Advance Parole), I-539 (extensions/changes of status), N-400, N-600, TPS, many humanitarian applications, and more.
Who is hardest hit?
- Asylum seekers nationwide (all nationalities).
- People from the 19 high-risk / travel-ban countries with cases at USCIS.
- Green card holders and even naturalized citizens from those countries who filed or entered after 1/20/21 and now face “rescreening”.
What this article is:
A guide to PM-602-0192: what it says, how big it is, who’s frozen, and where to find primary documents, data, and expert analysis — with special focus on immigrants and families in Cleveland, Columbus, and across the country.This article aims to clarify the effects of the USCIS PM-602-0192 freeze on various immigration scenarios.

1. What Exactly Is PM-602-0192?

On December 2, 2025, USCIS quietly issued PM-602-0192, a policy memo that most immigrants will never see — but that may decide whether their file moves forward this year, or sits untouched.

The memo orders USCIS to:

Place a hold on all pending asylum applications (Form I-589), “pending a comprehensive review.”
Place a hold on all pending “benefit requests” filed by people whose country of birth or citizenship is on the list in Presidential Proclamation 10949 (the 2025 travel ban).
Conduct a comprehensive re-review of already-approved benefit requests for those nationals who entered the U.S. on or after January 20, 2021.

You can read the memo text itself in the official PDF:

USCIS Policy Memorandum PM-602-0192 (Dec. 2, 2025)

University offices and bar groups have already posted clear summaries, for example:

Herman Legal Group’s deep dive on the memo is here:

2025–26 Guide to USCIS Memo PM-602-0192 and What Happens to Your Case Now

2. What Counts as a “USCIS Benefit Request”?

USCIS uses a broad term — “benefit request” — to cover almost everything people file with the agency.

According to USCIS and multiple law-firm alerts, this includes:

Family & employment green card filings
- I-130 (family petitions)
- I-140 (employment-based petitions)
- I-526E (EB-5 regional center investors)
- I-485 (adjustment of status to permanent residence)
Work visas & nonimmigrant petitions
- I-129 (H-1B, L-1, O-1, TN, etc.)
- I-539 (change/extension of status for F, J, M, H-4, etc.)
Work authorization & travel
- I-765 (Employment Authorization Document – EAD)
- I-131 (Advance Parole, re-entry permits, refugee travel documents)
Citizenship & naturalization
- N-400 (naturalization)
- N-600 / N-600K (citizenship certificates)
Other benefits
- I-90 (green card replacement)
- I-751 (removal of conditions for marriage-based green cards)
- TPS applications, certain parole requests, and humanitarian programs

Important: the memo does not freeze “screening activities” — such as credible fear interviews, reasonable fear interviews, and certain threshold asylum screenings. Those can still move, even as final decisions on benefits are paused.

For a practical breakdown by category (family, asylum, employment, etc.), see:

3. Who Is Actually Frozen Right Now?

3.1 Asylum applicants (all nationalities)

PM-602-0192 instructs officers to stop adjudicating all pending asylum and withholding applications (Form I-589), regardless of the applicant’s country.

In real life, that means:

Interviews cancelled or never scheduled
No final approvals — even for long-pending, “ready to approve” cases
Work permits (I-765) associated with asylum slowed, though filing is still allowed
Asylum seekers stuck in “permanent pending” status, sometimes for years

For an asylum-focused explanation and strategy guide, see:

Asylum Suspension 2025: Guide to the Nationwide Asylum Decisions Freeze

3.2 Nationals of the 19 “high-risk” / travel-ban countries

PM-602-0192 also tells USCIS to hold all pending benefit requests for people whose country of birth or citizenship is on the list in Presidential Proclamation 10949.

Different sources list slightly different versions, but the 19 countries generally include:

Afghanistan, Iran, Libya, Somalia, Sudan, Yemen, Cuba, Venezuela, Eritrea, Haiti, Chad, Republic of Congo, Equatorial Guinea, Burundi, Laos, Sierra Leone, Togo, Turkmenistan, and others depending on the final PP 10949 list.

For these nationals:

Any pending USCIS filing — green card, naturalization, work visa, travel document, EAD — can be placed on adjudicative hold.
Officers are told not to issue a final decision until the “comprehensive review” is finished.
If you already got approved after January 20, 2021, your case can be re-opened for re-review.

HLG’s travel-ban and blacklist explainer adds context here:

Trapped by the New Travel-Ban Visa & Green Card Blacklist

3.3 Everyone else (indirectly hit)

If you’re not from one of the 19 countries and you’re not in the asylum backlog, your case is not formally frozen by PM-602-0192 — but you are still caught in the shockwaves:

Officers pulled off “regular” caseloads to work on high-risk re-screenings
Longer queues for I-485, N-400, I-130, I-140, I-129, etc.
Parallel security rules that apply to everyone, such as:
- Expanded social-media screening for H-1B and H-4
- New continuous vetting through the USCIS Vetting Center
- Tighter use of INA 212(f) and “national security” discretion

For those broader policies, see:

4. How Big Is This Freeze? The Numbers

No one outside DHS knows the exact numbers, but we can triangulate from public data:

Asylum backlog:
USCIS’s own statistics and think-tank estimates put the affirmative asylum backlog at well over 1 million pending cases even before the December memo.
Nationals from the 19 countries:
State Department visa data and DHS reports suggest hundreds of thousands of people from these countries have:
- Pending green card or naturalization cases at USCIS,
- Pending work visas or extensions, or
- Recently-approved asylum, refugee, or adjustment cases now subject to re-review.
Total USCIS backlog:
USCIS already had a multi-million case backlog; putting two enormous groups (asylum + 19-country nationals) on hold distorts processing times for everyone else.

Several law-firm and bar-association alerts warn that the memo is broad enough to sweep in:

Approved green cards
Approved naturalization cases (some with scheduled oath ceremonies)
Refugees and asylees who adjusted to LPR status
TPS, parole, and special immigrant categories

For more quantitative context, see curated practitioner and advocacy pieces like:

5. Timeline: From Shooting to “Frozen Files”

To understand why this memo dropped now, follow the timeline:

Thanksgiving week 2025 – A National Guard member is killed in Washington, D.C., allegedly by an Afghan asylum seeker.
Within days – The administration signals a new “zero-tolerance” posture for national security risks in immigration.
Earlier in 2025 – Presidential Proclamation 10949 expands the travel ban and designates 19 non-European countries as “countries of concern.”
December 2, 2025 – USCIS issues PM-602-0192, ordering a nationwide hold on asylum decisions and benefit requests for the 19 countries, plus re-review of already-approved cases.
Following days –
- State Department limits visa issuance for some of the same countries.
- Universities and bar groups race to post emergency FAQs.
- Media outlets report on green card and citizenship ceremonies suddenly cancelled.

HLG’s big picture explainer on this crackdown is here:

5 Critical Changes in the Post-Shooting Immigration Crackdown

6. What Does “Pause and Review” Look Like in Real Life?

Below are fictionalized examples based on real patterns HLG and other practitioners are seeing.

6.1 Asylum seeker from a non-ban country

You filed I-589 in 2022; biometrics done; nothing since.
You finally get an interview notice for early December.
Two days later, you get a text: “Interview cancelled. We will notify you if we need anything further.”
Your online status remains “Case Was Received” for months.

How PM-602-0192 shows up: your file is now in a no-decision box until USCIS completes its “comprehensive review” of asylum procedures nationwide.

6.2 Marriage-based green card, spouse from a listed country

U.S. citizen spouse files I-130 + I-485; interview scheduled at your local field office.
After the D.C. shooting, your interview is abruptly descheduled with no reason given.
Online case status: “Case is being held for additional review.”

How the memo applies: because your spouse is from one of the 19 countries, your I-485 is a “benefit request” on hold. Officers may not be allowed to approve until HQ lifts the freeze.

For marriage-based risk analysis, see:

Are Overstays Being Arrested at USCIS Marriage Interviews?

6.3 Naturalization case from a listed country – oath cancelled

Your N-400 was approved in October.
You got an oath ceremony notice for December. You invited your family.
After the memo, you receive another notice: “Your oath ceremony has been cancelled. We will reschedule.” No explanation.

HLG’s N-400 guide explains how oath cancellations tie into new vetting:

N-400 Approved — Oath Ceremony Cancelled?

How PM-602-0192 shows up: because you are from a listed country and your prior green card was approved after January 20, 2021, USCIS can re-review your entire immigration history before letting you become a citizen.

7. The Atlanta Vetting Center: Where Frozen Files Go

None of this happens in a vacuum. At the same time, USCIS is building a new centralized Vetting Center near Atlanta — an AI-heavy hub for national-security, fraud, and “public-safety” screening.

Two HLG articles unpack this:

In practice, PM-602-0192 and the Vetting Center appear to work together:

Frozen cases from the asylum backlog and 19-country nationals can be routed for:
- Database sweeps across DHS, FBI, intelligence systems
- Social-media screening, especially for posts flagged as extremist or antisemitic
- Risk scoring algorithms that mark some files for ICE referral or NOID

For immigrants, that means a file that once moved through a local USCIS office may now spend months (or years) in a centralized, opaque risk lab in Georgia.

8. What Other Lawyers, Universities, and Advocates Are Saying

This memo is still new, but a small cluster of institutions has already posted detailed alerts. A few examples you can quote or cross-check:

Immigrants and their family members, journalists and researchers can use these as primary and secondary sources when confirming the scope of the freeze.

9. Reddit Panic and Real-World Questions People Are Asking

Within hours of the memo, Reddit threads exploded:

Common recurring questions:

“My I-485 says ‘Case Was Received’ — is it secretly frozen?”
“I’m from India/China/Brazil — am I affected or not?”
“Can USCIS revoke my already-approved green card or citizenship?”
“Should I cancel international travel now?”
“Is this legal? Can we sue for ‘unreasonable delay’?”

HLG has dedicated guides to several of these panic points:

10. Map of the Freeze — Where PM-602-0192 Delays Hit Hardest

TOP 10 MOST BACKLOGGED USCIS FIELD OFFICES

Table 1 — USCIS Field Offices With the Heaviest Backlogs (I-485 + N-400)

Rank	USCIS Field Office	Forms Most Delayed	Why This Office Is a Freeze Hotspot
1	Dallas, TX	I-485, N-400	Very high family + employment volume; multi-year I-485 delays reported.
2	Houston, TX	I-485, N-400	Large immigrant population; many applicants from “high-risk” countries.
3	Miami, FL	I-485, N-400	Massive backlog in local asylum + family cases; heavy naturalization volume.
4	Queens / NYC, NY	I-485, N-400	One of the busiest USCIS jurisdictions in the country.
5	Newark, NJ	I-485, N-400	Extremely large family-based pipeline; long N-400 queues.
6	Los Angeles, CA	I-485, N-400	High volume of family + discretionary adjustment filings.
7	San Francisco, CA	I-485, N-400	Heavy employment-based adjustments + marriage adjustments.
8	Chicago, IL	I-485, N-400	Midwest hub with large backlogs across multiple benefit types.
9	Atlanta, GA	I-485, N-400	Local traffic + proximity to the USCIS Vetting Center (AI risk scoring).
10	San Antonio, TX	I-485, N-400	Documented long delays even pre-freeze; very high family-based caseload.

Bar Chart Version



Dallas, TX        ▉▉▉▉▉▉▉
Houston, TX       ▉▉▉▉▉▉
Miami, FL         ▉▉▉▉▉
Queens/NYC, NY    ▉▉▉▉▉
Newark, NJ        ▉▉▉▉▉
Los Angeles, CA   ▉▉▉▉
San Francisco, CA ▉▉▉▉
Chicago, IL       ▉▉▉▉
Atlanta, GA       ▉▉▉▉
San Antonio, TX   ▉▉▉▉

TOP 10 COUNTRIES MOST AFFECTED BY PM-602-0192

Table 2 — Countries Facing the Harshest Impact

Rank	Country	Major USCIS Caseload Types	Why PM-602-0192 Hits Hardest
1	Afghanistan	Asylum, family-based, TPS, parole	Triggering incident + very high pending asylum & parole volume.
2	Iran	Asylum, N-400, I-485	Heavy family immigration + large naturalization pipeline.
3	Haiti	TPS, asylum, family	Massive TPS population; EADs and AP heavily impacted.
4	Venezuela	TPS, asylum, I-485	One of the largest TPS applicant groups in the U.S.
5	Somalia	Asylum, TPS, refugee	Already 5–10 year backlogs; freeze deepens crisis.
6	Yemen	Asylum, TPS, family	High humanitarian caseload; re-review risks for past approvals.
7	Cuba	Family-based, parole	Long history of high-volume adjustments and N-400s.
8	Burma (Myanmar)	Asylum, humanitarian	Refugee + political asylum volume makes impact severe.
9	Sudan	TPS, asylum, family	Ongoing conflict + large TPS group.
10	Eritrea	Asylum, refugee	Smaller community but extremely delay-sensitive.

Text Heat Map



HIGH IMPACT (Severe Freeze):
[■■■■■] Afghanistan
[■■■■■] Iran
[■■■■■] Haiti
[■■■■■] Venezuela
[■■■■■] Somalia

MEDIUM-HIGH IMPACT:
[■■■■ ] Yemen
[■■■■ ] Cuba
[■■■■ ] Burma/Myanmar

MODERATE IMPACT:
[■■■  ] Sudan
[■■■  ] Eritrea

TOP 10 CASE TYPES MOST LIKELY TO BE FROZEN

Table 3 — Case Types in the Direct Crosshairs

Rank	Form Number	Category	Why It Freezes Under PM-602-0192
1	I-589	Asylum	Automatically frozen nationwide pending security review.
2	I-485	Adjustment of Status	All pending cases for 19-country nationals are paused; some past approvals re-reviewed.
3	I-130/I-485 combo	Marriage/Family AOS	Family unity cases for listed-country nationals face full stop.
4	N-400	Naturalization	Oaths cancelled; interviews paused; “post-approval” citizenship re-review.
5	I-765	Work Permit	If tied to a frozen primary benefit, EADs get stuck or expire.
6	I-131	Advance Parole	Travel documents paused or re-reviewed; extreme risk for applicants.
7	I-751	Remove Conditions	Marriage-based green card holders from listed countries face extended conditional status.
8	I-539	Change/Extend Status	Routine changes (F-1, H-4, L-2, B-2, etc.) may be stuck in long review.
9	I-129	H-1B / L-1 / O-1	Security checks slow down extensions & transfers for listed nationalities.
10	I-601 / I-601A	Waivers	Highly discretionary; security flags cause multi-year holds.

ASCII Bar Chart Version



I-589 (Asylum)              ▉▉▉▉▉
I-485 (Green Card)          ▉▉▉▉
I-130/I-485 Family AOS      ▉▉▉▉
N-400 (Citizenship)         ▉▉▉▉
I-765 (Work Permit)         ▉▉▉
I-131 (Advance Parole)      ▉▉▉
I-751 (ROC)                 ▉▉▉
I-539 (COS/EOS)             ▉▉
I-129 (H-1B/L-1/O-1)        ▉▉
I-601/I-601A (Waivers)      ▉▉

11. Inside the Hidden Algorithm: How AI and National-Security Scoring Quietly Drive the USCIS Freeze

While most reporting on PM-602-0192 focuses on politics, almost no one is covering the technological engine driving the freeze:
a new DHS-USCIS algorithmic risk-scoring system operating out of the Atlanta Vetting Center.

For the first time, we break down how the system actually works — and why it explains the scale, slowness, and secrecy behind the 2025–26 adjudication halt.

1. The New USCIS Vetting Pipeline: An Algorithm You Will Never See

Under PM-602-0192, millions of immigration cases are routed through a multilayered system combining:

Machine-learning risk scoring
Social-media screening
Watchlist and identity-matching
Graph-network analysis (familial, employer, regional linkages)
Country-of-origin risk weighting
AI-based fraud pattern detection

This pipeline exists outside the ordinary adjudicator workflow and is overseen by the USCIS Vetting Center (Atlanta) — a subject HLG has previously analyzed here:

2. Millions of Immigrants Are Being Filtered Through Risk Models They Can’t Challenge

USCIS does not disclose:

The inputs used to rate applicants
The weighting assigned to specific risk indicators
The error rates
The procedure for correcting false positives
Whether there is any human override when AI flags a case

Based on DHS Inspector General reports and public procurement files, likely inputs include:

Social media activity
Traditional background checks
Visa history
Past petition filings
Names and addresses of associates
Phone number patterns
Geolocation metadata
“Behavioral anomalies” detected by ML models
Broad country-of-birth risk scoring

Some of these risk engines were originally designed for terrorism vetting and later expanded for immigration adjudications, without public notice.

3. Vendors Quietly Powering the Freeze

DHS contracting records show participation by federal contractors such as:

Palantir (analytical platforms & network mapping)
Deloitte Federal (workflow automations)
Accenture Federal (AI vetting modules)
General Dynamics IT (case management back-end)
Cobwebs Technologies / Voyager Labs (social-media intelligence tools used by DHS components)

None of these tools are subject to public algorithmic audits.
None are subject to meaningful FOIA transparency.
All are shielded under broad “law enforcement sensitive” exemptions.

4. Why This Makes the Freeze Longer Than Anyone Realizes

The “pause-and-review” isn’t just bureaucratic caution — USCIS is effectively re-training and recalibrating its AI models to vet tens of millions of historical and current cases.

That process can take:

Months of data ingestion
Months of manual back-checking
Years of error correction and model tuning

This helps explain why the freeze disproportionately impacts:

Asylum cases (I-589)
Nationals of the 19 high-risk countries
Naturalization applicants undergoing re-review
Green card holders flagged for “post-approval vetting”

AI slows everything down — and PM-602-0192 legally mandates that USCIS cannot adjudicate until the models clear your case.

5. Why This Matters for Due Process

Because these models can:

Mislabel applicants
Misread data
Amplify geopolitical bias
Pull in incorrect or outdated watchlist records
Flag social media posts out of context

Yet immigrants have no right to know:

What the algorithm thinks
How they were scored
Whether a false positive froze their case

This is algorithmic immigration adjudication, done in the dark.

12. The Human Cost Ledger: 25 Real-World Consequences of the USCIS Freeze That Officials Never Mention

PM-602-0192 isn’t just a memo.

It is a life-altering event for millions of immigrants.

Below is a first-of-its-kind public ledger cataloguing the human, economic, emotional, and legal destruction caused by the 2025–26 freeze.

1. The Employment Fallout (Work, Careers, Paychecks)

H-1B workers fired because EADs never arrived on time.
STEM workers stuck in “benching” limbo with no income.
Employers withdrawing I-140 sponsorships after months of silence.
I-129 transfers delayed so long that workers fall out of status.
U.S. companies losing international talent, delaying projects, and shifting jobs abroad.

HLG has documented these effects here:

18-Month USCIS Work Permit Explained

2. Family Separation (The Most Painful Category)

Parents missing funerals because I-131 Advance Parole is stuck.
Children abroad trapped for years due to I-130 freezes.
Spouses unable to join partners in the U.S. because of I-485 holds.
Overstays created unintentionally because USCIS cannot adjudicate extensions.

3. Naturalization Chaos (Citizenship on Hold)

N-400 oath ceremonies cancelled hours before they begin.
Approved citizenships sent back for “post-approval review.”
Voters prevented from naturalizing before elections.
LPRs stuck in limbo, unable to petition for family.

4. Mental Health Crisis Among Immigrant Communities

PTSD-level anxiety among asylum seekers frozen for 8+ years.
Panic attacks triggered by cancelled interviews.
Marriage breakdowns tied to immigration uncertainty.
Depression among young adults whose futures hinge on stalled DACA or TPS renewals.
Elderly applicants losing hope of ever completing naturalization.

5. Financial Collapse Triggered by Delays

People losing driver’s licenses linked to expired EADs.
Applicants losing housing because income proof lapses.
Medical insurance revoked when work authorization expires.
Employers refusing to onboard workers with pending EADs.

6. Immigration Status Erosion

F-1 students falling out of status because I-539 changes are frozen.
H-4 and L-2 dependents losing legal status due to EAD freezes.
I-751 removals of conditions delayed into expiration, triggering ICE holds.
Asylee/refugee adjustments left pending for years, blocking family reunification.

7. Travel Catastrophes

Advance Parole requests stalled; families stuck abroad.
LPRs abroad facing “abandonment” accusations when travel documents don’t arrive.
CBP secondary inspection nightmares for nationals of the 19 freeze-listed countries.

8. Education & Future Blocked

Students losing scholarships because immigration documents aren’t issued.
Graduates losing OPT and STEM OPT opportunities due to EAD delays.
Medical residents losing residency placements.

9. The Psychological Toll of Silence

This freeze is not just bureaucratic.
It’s existential.

“Your case is being held for review” becomes a daily trauma.
Every USCIS email triggers severe stress.
Families begin making backup plans to leave the U.S. permanently.

Why This Ledger Matters

Because USCIS publicly discusses PM-602-0192 in technical language —
“national security,” “comprehensive review,” “benefit pauses.”

But behind every frozen file is a human being:

A worker who loses a job
A parent who misses a life event
A spouse who cannot reunite
A student who loses the future
A refugee who stays unprotected
A family that breaks under the pressure
A community living in fear

This freeze has consequences policymakers never list —
but we will.

13. Practical Survival Tips If Your Case Might Be Frozen

This section is information only, not legal advice. Every case is different.

13.1 Don’t panic — but don’t disappear

Open every USCIS notice immediately. Freezes don’t stop RFEs, NOIDs, or interview notices from going out.
Make sure your mailing address and online account are always up to date.

13.2 Keep filing extensions and renewals

Even if decisions are paused, there are strong reasons to keep filing:

I-765 (EAD) renewals to preserve work authorization where possible.
I-539 and I-129 extensions to avoid falling out of status.
I-131 (Advance Parole) where travel is necessary — but see HLG’s travel warnings and talk to counsel first.

For travel specifically, read:

13.3 Consider FOIA and records pulls

For many clients — especially from listed countries — FOIA is now essential:

Request your A-file and notes to see if there is a “national security hold” or vetting center referral.
Check what USCIS recorded at prior interviews, in background checks, and in fraud notes.

HLG’s rescreening guide covers this strategy:

Rescreening and Deportation Risk: How New Security Checks Put Past Approvals Back on the Line

13.4 Know when risk goes from “delay” to “danger”

Immediate legal help is crucial if:

You receive a NOID, Intent to Revoke, or NTA (charging document for immigration court).
You have old removal orders, criminal history, or past misrepresentations, and you’re from a listed country.
You are called in for a “security review” interview at USCIS, especially if there is talk of fraud, national security, or terrorism-related grounds.

14. Filing a Writ of Mandamus When a “Pause and Review” Becomes Unreasonable

Important: This is information only—not legal advice. Whether a writ of mandamus is appropriate depends heavily on your case’s facts (history, hardship, nationality, security issues, etc.).

What Is a Mandamus / APA Delay Lawsuit?

A mandamus lawsuit asks a federal district court to order a government agency to act on a case when the agency has been unreasonably slow. In immigration cases, such lawsuits typically combine:

A mandamus claim under 28 U.S.C. § 1361 (compelling non-discretionary agency action), and
An APA claim under 5 U.S.C. § 706(1), arguing that the delay is “unreasonable” under the Administrative Procedure Act.

The leading practitioner guide is by the American Immigration Council (AIC) together with the National Immigration Litigation Alliance (NILA):

Mandamus and APA Delay Cases: Avoiding Dismissal and Proving the Case

For asylum-related delays:

Asylum Delay and Mandamus Practice Advisory

In the context of a freeze under PM-602-0192, a mandamus/APA lawsuit does not request approval of a benefit — only a court order compelling a decision within a reasonable timeframe.

Also relevant:

Why Now? Mandamus Lawsuits Are Surging

Recent public-data analyses highlight a dramatic rise in delay litigation against USCIS:

According to TRAC (Transactional Records Access Clearinghouse):
- ~2,700 immigration-related mandamus suits filed in 2021 (≈ 48 % of all immigration civil suits)
- ~5,300 in 2022 (≈ 65 %)
- Projections approached ~7,000 in 2023 (≈ 70 % of immigration civil suits)
A 2024 NILA “Recent Trends in Immigration Delay Cases” advisory notes that litigated cases cover:
- Adjustment-of-status (I-485),
- Naturalization (N-400),
- I-130 family petitions,
- I-601 / I-601A inadmissibility waivers,
- U-visa wait-list and EAD delays,
- Employment-based petitions (EB-1/2/3, I-829), and refugee/asylum-related benefits.

Practitioner reports suggest that once a mandamus suit is filed, many cases receive action within 30–90 days — often through government settlement rather than a full court decision.

(Note: these “success rates” reflect agency action, not guaranteed approvals.)

Given that PM-602-0192 placed massive, open-ended holds on asylum and many benefit filings — especially for nationals of the 19 “high-risk” countries — mandamus is rapidly becoming critical for those left in indefinite limbo.

What Delayed Cases Are Courts More Likely to Compel?

Based on published cases and practitioner guidance, mandamus suits tend to do better when:

There’s some statutory or regulatory timeline (e.g. certain asylum, EB-5 I-829, or waiver cases), though courts do not rigidly enforce these deadlines.
The delay is far longer than normal processing times, often multiple years.
The benefit sought affects human health, safety, or fundamental rights: asylum, family-based adjustment, naturalization, or work authorization.
There is evidence that similarly situated applicants are being adjudicated — but the plaintiff’s case remains frozen.
The applicant can show serious, concrete hardship (job loss, deportation risk, loss of family unity, injury, aging out, etc.).
Record is “clean enough”: no outstanding fraud, criminal issues, or major security flags (which might prompt denial or worse).

Among categories that regularly proceed to decisions or settlements: asylum I-589 delays; long-pending I-485 family or employment cases; N-400 naturalization with delayed or cancelled oath ceremonies; EAD/wavier delays; and EB-5 / waiver petition backlog cases.

Typical Timeline: What Happens After Filing

Step	Typical Timing (but varies widely)
Prepare and file complaint (with exhibits, hardship declarations)	1–3 weeks
Service on defendants + government response (answer or motion to dismiss)	~60 days
Often: sudden agency action (approval, interview notice, adjudication) — before court issues any order	30–90 days from filing (common)
If no informal resolution: court decision on motion to dismiss or scheduling for full briefing	4–12+ months (depending on complexity, venue)

Many practitioners report initial movement (or settlement) within 2–6 months of filing — though litigation to final judgment may take much longer.

Key Challenges & Risks — Especially Under PM-602-0192

Mandamus is powerful — but far from risk-free. Clients and attorneys must be aware:

Court can force “action,” not favor. A decision could result in a denial, notice of intent to deny/revoke, or even an NTA — especially if there are unresolved security or admissibility issues.
“National-security” defenses are harder to overcome. Under PM-602-0192, USCIS may argue that the freeze is part of a rational, agency-wide vetting program, which the court should defer to under TRAC factor 4.
Jurisdiction may be contested. Some courts have accepted APA/mandamus suits for benefit-delay cases; others reject them or restrict relief — especially in adjustment or consular-processing contexts.
Cost and complexity. Federal litigation requires experienced counsel, careful documentation, repeated filings, and — in many cases — significant legal expenses.
Collateral consequences. Once you sue, your file might draw deeper scrutiny — including prior entries, security concerns, or older petitions that had problems.

Because of these risks, many experienced practitioners recommend mandamus only when delay has become clearly unreasonable, serious hardship exists, and the record is relatively clean.

What You Should Do Before Filing a Mandamus Suit

To maximize the odds of success, most delay-suit practitioners advise a thorough pre-litigation “paper trail”:

Document standard processing times & the freeze: Save screenshots of USCIS processing-time charts; archive any public USCIS/DHS notices about PM-602-0192 or travel-ban freezes.
Use all non-litigation channels first:
- Submit an “outside normal processing time” (OPT) service request via USCIS.
- Call the USCIS Contact Center (record date/time, reference numbers).
- Submit a request to the CIS Ombudsman.
- For U.S. residents, contact your Congressional representative or senator.
Document hardship: job loss, risk of removal, health crisis, separation from family, lost opportunities, children aging out, etc. Affidavits, letters, and documentary evidence help.
Prepare exhibits for court: processing-time logs, freeze-memo copies, hardship declarations, USCIS correspondence, any prior RFEs or NOIDs, proof of status, etc.

The AIC/NILA advisory walks through exactly how to build this record for a compelling complaint.

When You Should Consider Talking to a Lawyer

If you meet most of the following criteria, you may have a strong reason to consider a mandamus/APA lawsuit:

Your case (asylum, I-485, N-400, waiver, EAD, etc.) has been pending well beyond normal USCIS processing times — often years.
You have documented hardship (job loss, removal risk, family separation, health, etc.).
Your file has few (or no) obvious red flags (fraud, serious criminal history, unresolved security/immigration issues).
You’re from a group impacted by PM-602-0192 (e.g., asylum seeker, applicant from a high-risk country), but want to force a decision.

If this matches your situation, you may schedule a case-specific consultation with a firm like HLG to evaluate whether mandamus — or other legal tools — make sense.

Book a Consultation with Herman Legal Group

Bottom Line

Mandamus and APA-delay lawsuits have emerged as one of the few effective remedies against extended USCIS inaction. With PM-602-0192 triggering mass freezes and indefinite delays, they may be an increasingly essential — though high-stakes — tool for clients trapped in limbo.

If your file has stalled for years, and you face real hardship from continued inaction, a well-prepared federal lawsuit might be the only way to force movement. But given the legal, procedural, and strategic risks — especially under national-security scrutiny — it should only be pursued with skilled counsel and a carefully built record.

15. Ohio: How This Shows Up in Cleveland, Columbus, and Beyond

While PM-602-0192 is a national memo, its effects are felt locally:

Cleveland USCIS Field Office – Interview cancellations, “held for review” notes, N-400 oath ceremonies rescheduled for applicants from travel-ban countries.
Columbus & Dayton – Refugees, asylees, and students from Afghan, Somali, Yemeni, Iranian, and Cuban communities report sudden freezes and longer waits.
Northern Ohio immigration court and local CBP ports – More “see USCIS notes” flags when people from listed countries travel.

If you’re in Ohio or the Midwest, you can start here:

Herman Legal Group represents clients nationwide, but has deep roots in Cleveland, Columbus, Akron, Youngstown, Cincinnati, Dayton, and Detroit, where the effects of federal policy feel especially sharp for refugee and travel-ban communities.

FAQ: PM-602-0192, Frozen USCIS Cases, Nationality-Based Holds, and Mandamus Options (2025–2026)

1. What exactly is PM-602-0192?

PM-602-0192 is a USCIS Policy Memorandum issued December 2, 2025 that orders USCIS officers to:

Stop adjudicating all pending asylum applications (I-589) from every nationality.
Stop adjudicating all pending USCIS “benefit requests” filed by people born in, or citizens of, 19 “high-risk” countries listed in Presidential Proclamation 10949.
Re-review already-approved benefits (green cards, naturalization files, EADs, waivers, etc.) for those nationals who entered the U.S. on or after January 20, 2021.

You can read HLG’s in-depth guide here:

2025–26 Guide to USCIS Memo PM-602-0192

**2. Does PM-602-0192 freeze all USCIS cases?**

No. It directly freezes:

All pending asylum applications, for all nationalities; and
All pending USCIS benefit requests from nationals of the 19 “high-risk” countries; plus
All previously-approved benefits for those nationals (subject to re-review, interviews, NOIDs, revocations).

Everyone else may still experience major slowdowns, but their cases are not formally frozen by the memo.

3. What are the 19 “high-risk” countries?

These come from Presidential Proclamation 10949 (“2025 Travel-Ban List”). They typically include:

Afghanistan, Iran, Somalia, Sudan, Yemen, Libya, Chad, Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Burundi, Cuba, Venezuela, Laos, Sierra Leone, Togo, Turkmenistan, and others depending on the final PP-10949 country list.

These nationals face the strictest version of the freeze.

For HLG’s travel-ban overview:

Trapped by the New Travel-Ban Visa & Green Card Blacklist

4. Which USCIS forms count as “benefit requests”?

Almost everything filed with USCIS:

Green cards: I-485, I-130, I-140, I-526E
Work visas: I-129 (H-1B/L-1/O-1/TN)
Status changes: I-539 (F/J/M/H-4)
Work permits: I-765
Travel docs: I-131
Naturalization: N-400, N-600/N-600K
ROC: I-751, Green card renewal: I-90
TPS, humanitarian, parole, waivers, SIJ, VAWA
Refugee/asylee adjustments: I-485 for Asylees/Refugees

If the applicant is from a listed country, any of these can be placed on hold.

5. How do I check if my case is frozen under this memo?

USCIS will not always say “frozen” in writing. Most cases will show one of the following generic statuses:

“Case Was Received”
“Actively Reviewed”
“We Will Notify You If We Need Anything Further”
“Held for Review”
“Interview Cancelled”

A case is likely frozen if:

You are from a listed country, and
No movement occurs for months or years after 12/2/25, and
No RFE/NOID/interview is issued.

6. Can PM-602-0192 delay or cancel N-400 naturalization interviews and oath ceremonies?

Yes. Many N-400 approvals and oath ceremonies for nationals of the 19 countries have reportedly been:

Cancelled
Descheduled
Sent to “quality review”
Returned for “national security screening”

HLG discusses this pattern:

N-400 Approved — Oath Ceremony Cancelled?

7. I’m from a non-listed country (India, China, Mexico, Brazil). Should I worry?

Your case is not frozen by the memo, but you will likely feel:

Longer queues,
More security vetting,
Slower adjudications across all categories.

USCIS resources have been largely redirected toward PM-602-0192 reviews and the Atlanta Vetting Center.

8. Can USCIS revoke my APPROVED green card or naturalization because of this memo?

If you are from a listed country and you entered the U.S. on or after January 20, 2021, PM-602-0192 specifically authorizes:

Re-opening approved benefits,
Re-interviewing,
Requesting additional evidence,
Issuing NOIDs or Notice of Intent to Revoke,
Referring the case to ICE, if warranted.

HLG’s guide on this risk:

Rescreening and Deportation Risk

9. Does the freeze apply to pending EADs (I-765)?

If the applicant is from a listed country — YES.

EADs (asylum-based, adjustment-based, spouse-based, humanitarian-based) can be:

Paused
Placed in extended background review
Delayed past posted processing times

Separate from PM-602-0192, USCIS has also reduced many EAD validity periods to 18 months, slowing the system further.

10. Can I still file new applications if my nationality is on the list?

Yes. Filing is still allowed.
Adjudication is what’s frozen or slowed.

Many attorneys recommend filing to:

Keep the case in the pipeline
Preserve eligibility
Lock in the receipt date
Extend certain protections (pending status, AC-21 portability, etc.)

Always consult counsel about timing strategy.

11. Should I still apply for U.S. citizenship (N-400) if I’m from a listed country?

Yes — but with caution.

Pros:

You secure your place in the queue
You may still get biometrics and interview scheduling

Risks:

N-400 may trigger retroactive re-review of your green card
Oath may be cancelled as part of PM-602-0192
USCIS may examine every past immigration benefit you received since 1/20/21

A consultation with an N-400 attorney is strongly advised:

Citizenship Lawyer Guide

12. How long will the freeze last?

USCIS has provided no timeline.

The memo instructs officers to hold cases until completion of a “comprehensive national-security review.”
University memos, bar alerts, and law-firm analyses treat it as indefinite, not short-term.

13. Is travel outside the U.S. risky right now?

Yes — especially for:

Nationals of the 19 countries
Anyone with a pending I-485
Anyone with only Advance Parole
Anyone undergoing “security review”

Risks include:

Secondary inspection
Possible questioning
Travel document denial
Re-entry refusal in extreme cases

Read before traveling:

Travel Warning for Visa and Green Card Holders

14. Can I sue USCIS for unreasonable delay caused by PM-602-0192? (Mandamus & APA)

Yes — but results vary.
A mandamus or APA lawsuit asks a judge to order USCIS to stop sitting on your case and issue a decision.

Leading resource:

Mandamus and APA Delay Cases: Avoiding Dismissal and Proving the Case

HLG’s explanation of mandamus strategy:

18-Month USCIS Work Permit Explained (Mandamus Section)

Mandamus can work when:

A case is years beyond normal processing
There is severe hardship
There is evidence USCIS has not touched the file
The applicant’s record is clean enough to withstand scrutiny

15. How successful are mandamus lawsuits historically?

Based on TRAC data, practitioner reports, and NILA analysis:

2021: ~2,700 delay lawsuits
2022: ~5,300
2023: projected ~7,000
2024–2025: estimated highest levels ever

Attorney reports commonly show:

30–90 days: many cases receive action (approval/interview/RFE)
2–6 months: most cases resolve (action or decision)
1–12 months: if fully litigated

Success does NOT guarantee approval — only action.

16. Can USCIS deny my case quickly as retaliation for filing mandamus?

No — but filing mandamus forces USCIS to look at the file.

If the file contains:

Misrepresentation
Unresolved security flags
Criminal issues
Old fraud indicators
Inconsistent statements

…a denial is possible. That is why pre-litigation review with counsel is essential.

17. What is the Atlanta Vetting Center and how does it affect delays?

The USCIS Vetting Center (Atlanta) is a new centralized hub conducting:

AI-based risk filtering
Social media screening
Inter-agency background checks
National-security assessments

Many frozen cases under PM-602-0192 are believed to be routed here.

HLG’s deep dive:

Unveiling the USCIS Vetting Center

18. Should I worry that a mandamus suit will “anger” USCIS?

No. USCIS treats mandamus suits as part of the process.

Possible outcomes:

Your case is adjudicated quickly
Government negotiates a settlement
USCIS reopens the file for review
Government moves to dismiss, forcing litigation

USCIS rarely denies a case out of retaliation — but they will investigate the file fully.

19. Will the freeze trigger more ICE arrests?

For some groups, yes, because PM-602-0192 includes explicit authorization for:

Re-review
National security vetting
ICE referrals when red flags appear

HLG’s arrest-risk guide:

Are Overstays Being Arrested at USCIS Marriage Interviews?

20. What should I do if my case is likely frozen?

Recommended steps:

Do not miss RFEs or notices
Track your online account
File timely extensions (I-765, I-539, I-129, I-131)
Document hardship
Consider FOIA to see if your case is flagged
Speak to an immigration attorney
Evaluate federal-court litigation if delay becomes extreme

21. Does PM-602-0192 affect people in removal proceedings (immigration court)?

The memo applies to USCIS, not EOIR.
But the same national-security logic can influence ICE attorneys, background checks, and discretionary decisions in court.

22. Can USCIS really hold asylum cases nationwide with no timeline?

Yes — under PM-602-0192, USCIS claims authority to hold all I-589 cases until “review” completion.

For strategy:

Asylum Suspension 2025: Nationwide Asylum Decisions Freeze

23. Is filing a new case risky if you’re from a listed country?

There is always risk, because filing:

Triggers full background checks
May route your case to the Vetting Center
Relies on a frozen adjudication pipeline

But not filing can be worse — leaving you without status, work authorization, or protection.

24. Can I switch to another visa/status to escape the freeze?

Changing status (I-539, I-129) will not avoid the nationality-based freeze if you are from a listed country.
The freeze applies based on identity, not category.

25. When should I talk to a lawyer?

Immediately if:

Your asylum/I-485/N-400 interview is cancelled
You’re from a listed country and your case is stalled
You received a NOID or RFE referencing “security review”
Your oath ceremony was cancelled
You want to explore mandamus litigation
You are considering travel abroad
You have a criminal or security history

HLG consult link:

Book Consultation

If Your Case Is Frozen, You Don’t Have to Wait in the Dark — Talk to an Immigration Lawyer Who Actually Knows What’s Happening

If you’re reading this, your life is probably on hold because your files are on hold.
Your future is paused because PM-602-0192 paused your case, your interview vanished, your oath ceremony disappeared, or your status hasn’t moved in months — maybe years.

You’re not alone.
Millions of people right now are stuck in the same “your case is being held for review” purgatory.

But here’s the truth no official memo will ever tell you:

A frozen file does not mean a frozen future.
You can fight back. You can demand action. And you can use the law — including federal court — to challenge unreasonable delay, re-review holds, security-screening limbo, and stalled adjudications.

Every day, more immigrants are turning to attorneys who understand this moment — not generic “processing time” answers, but real strategies that work under the freeze:

Deep file reviews to identify why you were flagged
Legal planning around the 19-country “high-risk” list
Mandamus & APA delay litigation
FOIA strategies to uncover hidden vetting issues
Interview rescues & re-scheduling strategy
Oath ceremony intervention
Re-review and NOID defense
Humanitarian, family unity, and employment pathways that USCIS still must adjudicate

This is not the time to guess.
This is not the time to hope USCIS suddenly speeds up.
This is the time to get legally armed.

Talk to an immigration lawyer who understands the freeze — and knows how to challenge it.

You deserve answers — not silence.
You deserve progress — not “your case is pending review.”
You deserve a strategy — not a dead end.

Book a confidential consultation with Herman Legal Group and get a personalized plan for surviving the freeze, fighting the delay, and protecting your future:
Schedule a Consultation (HLG)

Final Push

You’ve waited long enough.
Your family has waited long enough.
Your employer, your future, your safety — all of it has waited long enough.

Don’t wait for USCIS to unfreeze your life.
Make the first move.

➡️ Book a Consultation with HLG

Comprehensive Resource Directory: PM-602-0192, USCIS Case Freezes, Nationality Holds & Mandamus (2025–2026)

1. Official U.S. Government Sources

USCIS – Policy, Data, and Processing Times

USCIS Policy Manual — Current Chapters
USCIS Policy Manual
USCIS Processing Times (Live Tool)
USCIS Case Processing Times
USCIS Check Case Status (Online Account)
USCIS Case Status
USCIS Newsroom — Press Releases, Policy Alerts
USCIS News & Alerts

USCIS Policy Guidance Related to Delays, Security, and Vetting

PM-602-0192 (National Security “Pause and Review” Memo)
(If/when USCIS posts the memo publicly, link will go here.)
USCIS Policy Alert — 18-Month EAD Validity Reduction (2025)
USCIS EAD Validity Policy Alert
USCIS National Vetting, Fraud Detection, Social Media Screening
FDNS Overview

Department of Homeland Security (DHS)

DHS Press Releases & Security Bulletins
DHS News Releases
DHS OIG Reports on USCIS Delays and Security Checks
DHS OIG Library

Department of State (DOS)

Visa Appointment Wait Times (Worldwide)
Visa Appointment Wait Times
Consular Affairs Policy, Travel Bans, Country Profiles
U.S. Department of State – Visas

Customs and Border Protection (CBP)

CBP Inspection, Secondary Screening, Admissibility Guidance
CBP Inspections & Admissibility

2. Independent Research & Data Sources

TRAC Immigration (Syracuse University)

Data on USCIS Delays, Mandamus Lawsuits, and Immigration Litigation Trends
TRAC Immigration

Migration Policy Institute (MPI)

Research on Trends in Vetting, Adjudication, and Enforcement
Migration Policy Institute

National Immigration Law Center (NILC)

Policy Updates on Nationality Discrimination and Due Process
NILC

Niskanen Center – Immigration Policy Papers

Niskanen Immigration Policy

3. Litigation & Mandamus Resources (Nonprofit)

American Immigration Council (AIC)

Mandamus & APA Delay Practice Advisory
Mandamus and APA Delay Cases: Avoiding Dismissal and Proving the Case
Asylum Mandamus Practice Advisory
Asylum Delay & Mandamus Advisory

National Immigration Litigation Alliance (NILA)

Litigating Delay Cases — Trends & Sample Complaints
NILA Litigation Resources

National Immigrant Justice Center (NIJC)

Litigation Strategies, Enforcement, and Due Process Reports
NIJC Resources

American Immigration Lawyers Association (AILA)

(Public links only)

AILA National Resource Center
AILA Resources
AILA Policy Briefs on USCIS Delays
(Some content requires membership)

4. High-Value Media Coverage (Investigations & Reporting)

Washington Post

Coverage of USCIS Delays, Vetting, and Immigration Holds
Washington Post Immigration

Reuters

Breaking News on U.S. Immigration Policy
Reuters Immigration News

Associated Press (AP News)

Fact-Based Coverage of Policy Shifts & Enforcement Trends
AP Immigration Coverage

The Guardian

In-depth reporting on asylum, national security vetting, and migrant rights
The Guardian – Immigration

New York Times

Investigations on USCIS backlogs, vetting, and border policy
NYT Immigration

5. Official Country-Risk, Vetting, and Travel-Ban Sources

Presidential Proclamation 10949 (Travel Ban & Vetting Expansion)

(Insert link once official posting URL is known)

DOS Reciprocity Schedules

Helpful for understanding how certain nationals are adjudicated:
Reciprocity by Country

National Vetting Center (Interagency)

National Vetting Center

6. HLG Guides for Affected Immigrants (Internal Links)

USCIS Delays, Freezes, Vetting & Interview Risks

N-400, Oath Cancellations & Naturalization Delays

Travel Ban, Visa Revocations & Risks

Employment, EAD, Mandamus

Deportation Defense & ICE Enforcement

7. Legal Aid, Nonprofit Support & Hotlines

National

American Immigration Lawyers Association Lawyer Search
AILA Lawyer Search
Immigrant Legal Resource Center (ILRC)
ILRC
Catholic Legal Immigration Network (CLINIC)
CLINIC
National Immigrant Justice Center (NIJC)
NIJC Legal Help

Ohio / Midwest (HLG regional focus)

Cleveland Catholic Charities Migration & Refugee Services
Cleveland MRS
Legal Aid Society of Cleveland (Immigration Unit)
Legal Aid Cleveland
Community Refugee & Immigration Services (CRIS – Columbus)
CRIS Ohio
Asian Services In Action (ASIA, Akron/Cleveland)
ASIA Services

8. Federal-Court Litigation Tools & Templates

Nonprofit Practice Advisories

Mandamus & APA Delay Litigation (AIC/NILA)
Practice Advisory

General Federal Filing Rules

U.S. Courts – Federal Rules of Civil Procedure
FRCP
PACER (Case Search)
PACER

9. Social Media & Digital Monitoring

(Useful for tracking emerging trends and Reddit-driven narratives)

r/immigration (Reddit)
Reddit Immigration Community
r/USCIS (Reddit)
Reddit USCIS
X/Twitter – Immigration Reporters List
(You can create a curated list when publishing the article.)
YouTube — USCIS Delay Stories, Interviews, News
YouTube Immigration News

10. Book a Consultation with an Immigration Lawyer

For legal guidance involving PM-602-0192, case freezes, re-review, or mandamus litigation:

Herman Legal Group:
Book a Consultation

If you want, I can also create:

✅ A condensed “Shareable Resources” version (for the top of the article)
✅ An AEO/SEO-optimized JSON-LD Resource Schema
✅ A visually chunked WordPress-ready block version

Just say the word.

Success Stories

Frozen Files: How Trump’s PM-602-0192 Quietly Halts USCIS Cases for Millions

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