On August 22, 2025, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0189, titled “Resumption of Personal Investigations of Aliens Applying for Naturalization (INA 335(a))”, which marks a significant shift in how naturalization applicants are vetted under U.S. immigration law.
1. Background & Authority
Under Section 335(a) of the Immigration and Nationality Act (INA), USCIS is authorized to conduct personal (“neighborhood”) investigations covering an applicant’s residence and workplace from the five years preceding the naturalization application. These investigations help verify key eligibility factors such as residence, moral character, constitutional attachment, and support for the nation’s good order.
However, by 1991, USCIS routinely waived these checks and relied on FBI-led biometric and criminal background screenings instead.
2. What’s Changing?
The new memorandum immediately reinstates neighborhood investigations by ending the prior blanket waiver. Now, USCIS will assess whether to conduct or waive such investigations on a case-by-case basis, relying on existing records rather than presuming a waiver applies.
This policy reinstates statutory intent and legislative oversight, reinforcing the agency’s commitment to comprehensive vetting rather than relying solely on remote checks.
3. Why It Matters
- Broader scrutiny: Applicants may experience home or workplace visits, interviews with acquaintances, or expanded background verification.
- Stricter moral character evaluation: These on-the-ground checks aim to confirm an applicant’s good moral conduct and societal integration in a more rigorous manner than prior biometric-only approaches.
- Individual discretion: USCIS officers now have more authority to tailor checks based on each applicant’s case details.
4. Legal Foundation
The policy restores enforcement of INA 335(a) and aligns with existing regulations in 8 CFR 335. Personal investigations historically served as the primary means to corroborate essential eligibility factors. While the fingerprint and FBI checks remain critical, this change reasserts USCIS’s statutory mandate.
5. Conclusion
The USCIS memorandum dated August 22, 2025 (PM-602-0189) reinstates neighborhood checks for naturalization applicants under INA 335(a), reversing decades of general waivers and signaling a move toward more grounded, individualized vetting. Naturalization applicants should be prepared for potential personal investigations that verify their residency, character, and constitutional attachment.
USCIS’s reinstatement of personal investigations underscores the importance of transparency and societal integration in naturalization. While potentially more demanding for applicants, this policy aims to uphold the integrity of U.S. citizenship. Eligible individuals are encouraged to strengthen their naturalization applications with credible evidence and be ready for the possibility of an in-person investigation.
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Citations
USCIS Policy Memorandum PM-602-0189
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JEREMY L. RICHARDS is the founding partner of Richards and Jurusik and has dedicated his career to U.S. immigration law, with a specialized focus on assisting Canadian and Mexican citizens under the United States-Mexico-Canada Agreement (USMCA) to work and live in the United States. (Full Bio)
