USCIS has announced a significant shift in its security and vetting procedures following Presidential Proclamation 10949 and recent national-security incidents. These changes include broad adjudication holds, mandatory interviews, and a comprehensive re-review of pending and previously approved cases involving nationals of 19 “high-risk countries.” The new requirements are outlined in USCIS Policy Memorandum PM-602-0192, issued December 2, 2025.
While the proclamation originally restricted visa issuance and entry from abroad, USCIS is now extending its impact to cases already within the United States. This will affect a very wide range of pending and future immigration applications.
Background and Purpose of the New Measures
The stated purpose of the memorandum is to strengthen national security screening after two recent cases involving Afghan nationals, including the November 2025 shooting of two National Guard members in Washington, DC. USCIS states that enhanced vetting and temporary adjudication holds are necessary to ensure that individuals from the affected countries do not pose national-security or public-safety risks. Although the agency acknowledges that delays will result, it expressly concludes that these delays are “necessary and appropriate” when weighed against security obligations.
Applications Affected by the Hold
USCIS is placing an adjudicative hold on all pending asylum applications, regardless of nationality, and on a wide range of immigration benefit requests filed by nationals of the 19 countries listed in Presidential Proclamation 10949. A “benefit request” is defined broadly and includes nearly all applications handled by USCIS unless specifically excluded. This means that many common filings, including adjustment of status, travel documents, green-card replacements, removal of conditions, and numerous employment-based petitions, may remain pending without adjudication until security reviews are completed.
Impact on Employment-Based Petitions, Including H-1B
The memorandum does not carve out exceptions for employment-based filings. As a result, petitions such as H-1B, H-1B1, O-1, L-1, TN, and employment-based immigrant petitions may fall under the same adjudicative hold when filed for nationals of the designated countries. USCIS will continue to receive these petitions, but adjudication may pause, and premium processing cannot overcome the security hold.
For individuals already in the United States in valid H-1B or other employment status, day-to-day work authorization remains unaffected. Employers may continue to file extensions or amendments, but such filings may be delayed during the review period. Applicants should also expect that interviews, even for categories that historically did not require them, may now be mandatory, as USCIS has instructed officers not to waive interviews for this population. 25120362
These measures do not affect the Department of Labor’s jurisdiction, so processes such as Prevailing Wage Determination and PERM recruitment continue as usual.
Re-Review of Previously Approved Cases
USCIS is also initiating a comprehensive re-review of approved cases for nationals of the affected countries who entered the United States on or after January 20, 2021. This reassessment may involve interviews, re-interviews, updated identity verification, and additional background checks. The agency may expand this review to individuals who entered before 2021 if deemed necessary.
Practical Expectations for Applicants
Applicants from the designated countries should prepare for longer processing times and more intensive vetting for most USCIS-based benefits, including employment authorization requests, extensions of status, adjustment of status, and employment-based petitions. Individuals should also avoid international travel where possible, particularly if they may require a new visa to reenter the United States.
Although PERM and other DOL processes remain unaffected, the later USCIS stages of an employment-based green card—particularly the I-140 (if consular processing is required) and the I-485—may be significantly delayed. The new vetting procedures may also extend to dependents, including those filing for H-4 or adjustment of status.
Conclusion
The December 2025 policy memorandum represents one of the most expansive security-based review initiatives in recent years. While it does not prevent filings, it will slow adjudications for many applicants from the affected countries and impose new interview and screening requirements. Individuals and employers should anticipate delays but may continue moving forward with filings, including H-1B petitions and other employment-based petitions, with the understanding that USCIS may hold these cases pending enhanced review.
For guidance on how these measures may affect a specific case, our office can assist.