On December 2, 2025, USCIS issued Policy Memorandum PM-602-0192 directing officers to immediately place broad adjudicative holds on (1) all pending asylum applications (Form I-589) and (2) all pending USCIS benefit requests filed by applicants from countries designated as “high-risk” under Presidential Proclamation 10949. The memo also orders a retroactive re-review of certain already-approved cases for applicants from those countries.
This is an extraordinary system-wide pause that will affect thousands of cases across asylum and family/employment-based immigration. It is already triggering interview cancellations and longer processing times, and it is likely to generate litigation.
Below is what the memo does, who is impacted, and what applicants should expect next.
1. What the Memorandum Directs USCIS to Do
PM-602-0192 orders three major actions, effective immediately:
- Hold all pending asylum applications (Form I-589), regardless of nationality. Every affirmative asylum filing currently pending at USCIS is frozen while the agency performs a “comprehensive review.”
- Hold all pending “benefit requests” from applicants tied to PP 10949 high-risk countries. This applies to anyone who lists a covered country as the country of birth or citizenship, and includes major forms such as:
- I-485 adjustment of status
- I-90 replacement green card
- I-751 removal of conditions
- I-131 travel documents/advance parole
- N-470 (preserve residence)
- Other USCIS benefits identified by the agency
- Re-review already-approved benefit requests for covered-country applicants who entered on/after Jan. 20, 2021.
USCIS must reopen security vetting on approvals granted to this group, with mandatory interviews and possible re-interviews.
The hold remains in place until the USCIS Director rescinds it in a future memo. There is no fixed end date.
2. Which Countries Trigger the Benefits Hold?
The benefits hold and re-review apply to the 19 countries listed in Presidential Proclamation 10949 (issued June 4, 2025).
Full suspension countries (12)
- Afghanistan
- Burma (Myanmar)
- Chad
- Republic of the Congo
- Equatorial Guinea
- Eritrea
- Haiti
- Iran
- Libya
- Somalia
- Sudan
- Yemen
Partial suspension countries (7)
- Burundi
- Cuba
- Laos
- Sierra Leone
- Togo
- Turkmenistan
- Venezuela
Key detail: USCIS uses country of birth OR country of citizenship as the trigger. That means even dual nationals, LPRs filing to replace cards, or applicants long present in the U.S. may be swept in if either field matches a listed country.
3. Why USCIS Says It’s Doing This
The memo ties its action to:
- Executive Order 14161 (Jan. 20, 2025) calling for “extreme vetting” and expanded national-security screening.
- Presidential Proclamation 10949 (June 4, 2025) imposes travel/entry restrictions on the same 19 countries based on vetting and information-sharing concerns.
USCIS also cites recent terrorism-related cases involving Afghan nationals as justification for pausing adjudications to reassess screening processes.
4. Practical Impact on Pending Asylum Cases (All Nationalities)
A. Every affirmative asylum case at USCIS is frozen
Even applicants not from high-risk countries are affected. If your I-589 is pending at an Asylum Office, USCIS officers must place it on hold during the agency review.
B. Interviews may be postponed or rescheduled
The memo doesn’t explicitly cancel asylum interviews, but because adjudication is frozen, many offices will pause scheduling or cancel upcoming interviews until further guidance is issued. Practitioners should anticipate:
- Delayed interview notices
- Delayed decisions after interview
- Longer overall processing timelines
- Potential EAD “asylum clock” consequences
C. Backlogs will grow
Asylum offices were already facing multi-year queues. A nationwide freeze, especially one without an end date, will compound the backlog and likely push many cases further into 2026–2027 timelines unless USCIS adds major capacity later.
5. Impact on Pending Benefit Requests for High-Risk Countries
If you are from one of the 19 designated countries, your pending USCIS benefits case is now stopped until USCIS completes its review and restarts adjudications.
Benefits most likely to be affected
- Adjustment of status (I-485): approvals paused, and interviews will be mandatory.
- Naturalization (N-400): many applicants are already reporting interview cancellations.
- Green card renewals/replacements (I-90) and removal of conditions (I-751): holds may delay proof-of-status updates.
- Advance parole / travel documents (I-131): expect longer waits and possible need for emergency AP, where eligible.
Interviews cannot be waived
PM-602-0192 explicitly forbids interview waivers for this population. Even benefit lines that often waive interviews (certain I-485 categories, I-751 joint filings, etc.) must now require one.
6. Retroactive Re-Review of Approved Cases
USCIS will re-open security screening for approved benefits where:
- the applicant is tied to a PP 10949 country, and
- they entered the U.S. on or after Jan. 20, 2021 (including EWI, parole, admission, or inspection).
What “re-review” can involve
- Mandatory interview or re-interview
- New evidence requests (identity, travel, affiliations)
- Referral to ICE or other agencies
- Potential rescission/revocation actions if USCIS finds new inadmissibility or fraud grounds
The memo also states that USCIS may extend re-review beyond the stated time window “when appropriate,” so older entries are not fully shielded from scrutiny.
7. How USCIS Will Evaluate People Under the New Review
The memo lists four screening questions officers must examine case-by-case:
- Terrorist Screening Dataset (TSDS) hits (KST Tier 1/2 or derogatory Tier 3/4 info).
- Links to INA 212(a)(3) or 237(a)(4) activity (terrorism/security bars).
- Links to serious criminal conduct or community-harm risks.
- Inability to establish identity as required by PP 10949.
This indicates USCIS will rely heavily on:
- Identity documentation
- Travel history
- Social media/associations
- Interagency vetting outputs
- Prior immigration filings and internal consistency
8. Legal and Policy Concerns
A. Nationality-based adjudication delays
A categorical hold based on country of birth/citizenship will likely invite Equal Protection and APA challenges, especially for already-approved cases.
B. Due process and reliance interests
Retroactive re-reviews can be challenged where families and employers relied on approvals in good faith, particularly for LPRs and naturalization applicants already deep into the process.
C. Backlog and humanitarian pressure
The asylum hold affects all nationalities, including high-vulnerability groups. Extended delays could increase unlawful presence, employment authorization gaps, and family-separation harms.
9. What Applicants Should Do Now
If you have a pending I-589 asylum case
- Expect delays. Your case will not be decided until USCIS lifts the hold.
- Track EAD eligibility. If you are waiting for a (c)(8) EAD or renewal, monitor your asylum clock and plan ahead.
- Update your address promptly. Rescheduling waves increases the risk of missed notices.
If you are from a PP 10949 country with a pending benefit
- Do not travel without legal advice. Travel document adjudications may stall.
- Prepare for a mandatory interview. Review your filing for consistency and gather identity/travel evidence.
- Watch for RFEs/NOIDs. The memo signals a stricter posture.
If you already have an approval and entered after Jan. 20, 2021
- Be alert for reopening notices or interview letters.
- Gather identity and background documentation now.
- Speak with counsel immediately if you receive any intent-to-reopen or fraud/security inquiry.
Bottom Line
PM-602-0192 is one of the most sweeping USCIS adjudicative pauses in recent history. It freezes:
- All pending affirmative asylum cases (every nationality), and
- All pending benefits for applicants from 19 designated high-risk countries,
- while re-reviewing many approvals going back to January 20, 2021.
Until USCIS lifts the hold, applicants should expect longer timelines, mandatory interviews, heightened vetting, and possible reopening of prior approvals. If you are affected, speak with an immigration attorney about case-specific risk, travel strategy, and evidence preparation.
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SIANA J.MCLEAN is a Partner at Richards and Jurusik, who practices immigration law with a focus on asylum, removal defense, and immigration court matters. She has extensive experience representing clients before U.S. Immigration Courts and the Board of Immigration Appeals. (Full Bio)
