USCIS Expands Adjudication Hold to Most Immigration Benefits for High-Risk Countries

USCIS issued a policy memorandum on January 1, 2026, significantly expanding its pause on adjudicating immigration benefit applications for nationals of countries designated as high-risk. This new guidance builds on a December 2, 2025 memorandum that initially paused asylum applications, and a December 16 Presidential Proclamation that expanded the list of designated high-risk countries to 39 total. The January 1 memorandum establishes a default rule: all pending immigration benefit applications involving nationals of affected countries are paused while USCIS conducts enhanced screening and national security review. This expansion applies broadly across filing types, including employment-based, family-based, and humanitarian applications. Only limited exceptions apply. USCIS will continue processing Form I-90 (Permanent Resident Card replacement), Form N-600 (Certificate of Citizenship), certain narrow employment authorization categories mandated by statute, and select law-enforcement-related relief on a case-by-case basis. Notably, previously approved benefits granted on or after January 20, 2021 may also be subject to re-review and potential revocation. For EB-3 applicants and their sponsoring employers, this hold introduces significant uncertainty. Pending I-140 petitions, adjustment of status applications, and employment authorization documents for nationals of affected countries may face indefinite delays. Employers must reassess onboarding timelines, work authorization expiration dates, and international travel plans for impacted employees. Affected employers and beneficiaries should consult immigration counsel immediately to evaluate case-specific impacts, identify whether any exceptions apply, and develop contingency planning for work authorization gaps or delayed approvals.