By Corinne Brooks, Alan Perkins, Melina LaMorticella, and Melany Savitt
On December 2, 2025 and January 1, 2026, the U.S. Citizenship and Immigration Services (USCIS) published Policy Memoranda announcing a pause in processing immigration benefits for individuals from 39 “travel ban” countries outlined in the Presidential Proclamations from June and December 2025. The pause applies to, but is not limited to, benefits applications pending review with USCIS for adjustment of status, extension of nonimmigrant stay, and change of nonimmigrant status.
The USCIS policy memoranda explain that the agency is placing an adjudicative hold on all pending benefit requests filed by individuals who are citizens of, or were born in, the travel-ban countries to allow for a thorough, case-by-case review. There is no indication when the pause will be lifted. When applications subject to the pause are ultimately adjudicated, country-specific facts and circumstances will be considered as significantly negative factors. Country-specific factors include the rate of visa overstays, the reliability of a country’s central authority to issue passports and identity documents, and the availability of law enforcement information.
The USCIS adjudication pause is effective for individuals who are citizens of, or born in, the following countries: Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma (Myanmar), Burundi, Chad, Cote d ‘Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, The Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Republic of Congo, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe.
Pursuant to the December 2025 Presidential Proclamation, Turkmenistan has been moved to the partially restricted list and a full restriction on travel has been placed on the entry of individuals whose travel documents are endorsed by the Palestinian Authority.
In addition to the pause on all pending applications, USCIS plans to conduct a comprehensive re-review of applications for individuals from the 39 travel ban countries approved after January 20, 2021. Re-review may include new or repeat interviews or reopening of previously adjudicated applications. In certain circumstances, USCIS may re-open cases approved prior to this date.
As the Trump Administration’s travel bans continue to evolve with little notice, we will keep our clients and community informed as we receive reliable guidance. Please contact our office or immigration counsel prior to traveling internationally.
This client alert is prepared for the general information of our clients and friends. It should not be regarded as legal advice. If you have any questions regarding this update, or for more information about this topic, please contact any of the attorneys in our Business Immigration Practice Group, or the attorney with whom you normally consult.
