USCIS Holds on Cases from "High-Risk Countries": What You Need to Know

If you or your family members are from one of the countries on the U.S. government's "high-risk" list, your pending immigration case may be frozen right now. You might not have received any notice. Your application might be sitting untouched on a USCIS officer's desk, and there is nothing obviously wrong with it — except your country of origin.

Two DHS policy memos issued in late 2025 and early 2026 have placed blanket holds on immigration benefit applications from nationals of dozens of countries. Here is what happened, who is affected, and what you should do if your case has gone silent.

What Happened: Two Policy Memos That Froze Thousands of Cases

On December 2, 2025, USCIS issued policy memorandum PM-602-0192, titled "Hold and Review of All Pending Asylum Applications and All USCIS Benefit Applications Filed by Aliens from High-Risk Countries." The memo did two things at once: it froze every pending asylum application regardless of nationality, and it placed an adjudicative hold on all pending immigration benefit requests from nationals of 19 countries listed under Presidential Proclamation 10949.

Then on January 1, 2026, USCIS issued a second memo — PM-602-0194 — expanding the hold to cover additional countries added under Presidential Proclamation 10998. The combined effect: nationals of more than 35 countries now have their immigration applications frozen indefinitely.

No timeline has been given for when these holds will be lifted.

Which Countries Are Affected?

The holds apply to two tiers of countries. The distinction matters because the restrictions differ.

Full Suspension Countries (All Entry Banned)

Nationals of these countries face a complete ban on immigrant and nonimmigrant entry, plus a hold on all pending USCIS benefits:

• Afghanistan
• Burkina Faso
• Burma (Myanmar)
• Chad
• Equatorial Guinea
• Eritrea
• Haiti
• Iran
• Laos
• Libya
• Mali
• Niger
• Sierra Leone
• Somalia
• South Sudan
• Sudan
• Syria
• Yemen

Palestinian Authority travel document holders are also included.

Partial Suspension Countries (Some Visas Banned)

Nationals of these countries face restrictions on B-1/B-2, F, M, and J visas, plus the same hold on all pending USCIS benefits:

• Angola
• Antigua and Barbuda
• Benin
• Burundi
• Côte d'Ivoire
• Cuba
• Dominica
• Gabon
• The Gambia
• Malawi
• Mauritania
• Nigeria
• Senegal
• Tanzania
• Togo
• Tonga
• Turkmenistan
• Venezuela
• Zambia
• Zimbabwe

What Does "Hold" Actually Mean for Your Case?

An adjudicative hold means USCIS officers are instructed not to make a final decision on your application. Your case is not denied. It is not approved. It sits in administrative limbo.

Specifically, here is what happens:

• Your application is not being processed. Even if you have submitted everything correctly, met all requirements, and passed background checks, your case will not move forward.
• Interviews may be postponed. If you had an interview scheduled, it may be cancelled or rescheduled indefinitely.
• You will not receive a decision. No approval, no denial — just silence.
• Your filing fees are not refunded. USCIS has not indicated any refund policy for cases placed on hold.
• Work permits tied to pending applications may be affected. If your employment authorization depends on a pending I-485 or other frozen application, renewals could be delayed.

Already-Approved Cases Are Also at Risk

Both memos direct USCIS to conduct a comprehensive re-review of immigration benefits already approved on or after January 20, 2021, for nationals of the affected countries. This means even if your green card, work permit, or other benefit was approved months or years ago, USCIS may reopen your case for additional review.

For re-reviews, USCIS has stated that interviews cannot be waived — even for benefits that did not originally require one. If concerning information surfaces during re-review, cases may be referred to ICE or other law enforcement agencies.

Which Applications Are Frozen?

The hold covers virtually every immigration benefit USCIS adjudicates:

• Form I-485 — Adjustment of Status (green card applications)
• Form I-589 — Asylum applications (frozen for ALL nationalities under PM-602-0192)
• Form I-751 — Removal of conditions on permanent residence
• Form I-131 — Advance parole and travel documents
• Form N-400 — Naturalization (citizenship applications)
• Form I-130 — Petition for alien relative
• Form I-765 — Employment authorization (with exceptions)
• Form N-470 — Preserving residence for naturalization

What Is NOT Frozen: Exceptions

A limited set of applications are exempt from the hold:

• Form I-90 — Green card replacement or renewal
• Form N-565 — Replacement of naturalization or citizenship documents
• Form N-600 — Certificate of citizenship (except for nationals of Yemen and Somalia)
• Initial asylum-based work permits — Category (c)(8) EADs for asylum applicants who filed on or after January 4, 1995
• Law enforcement-related work permits — Categories (c)(11) and (c)(14) when requested by law enforcement
• National interest waivers — Cases involving critical medical research, infrastructure, or U.S. national security
• Athletes and sports teams — For World Cup, Olympics, or other major sporting events

If you are unsure whether your specific application falls into an exception, consult an immigration attorney. The exceptions are narrow, and USCIS has broad discretion in applying them.

The Asylum Freeze Affects Everyone

One critical detail that many people miss: the hold on asylum applications under PM-602-0192 is not limited to high-risk countries. Every pending Form I-589 asylum application, regardless of the applicant's nationality, is frozen. Whether you are from Ukraine, China, Guatemala, India, or anywhere else — if your asylum case is pending with USCIS, it is on hold.

USCIS has stated this pause is necessary to conduct a "comprehensive review" of screening and vetting procedures. No timeline has been provided for when asylum adjudications will resume.

What You Should Do Right Now

If you are from an affected country or have a pending asylum case, take these steps immediately:

1. Do Not Stop Filing

A hold does not mean you should stop filing applications. Filing deadlines, one-year asylum filing deadlines, and other statutory timelines still apply. If you fail to file because of the hold, you could lose your eligibility permanently. Continue filing as normal and keep all receipts and confirmation notices.

2. Keep Your Work Permit Current

If your employment authorization is tied to a frozen application, apply for renewal well in advance of expiration. Some EAD categories have automatic extensions (the 180-day or up-to-540-day extensions under the October 2023 rule), but these extensions only apply if you file timely. Talk to your attorney about whether your specific EAD category qualifies.

3. Do Not Travel on Advance Parole Without Legal Advice

If you have a pending I-485 and were planning to travel on advance parole (Form I-131), think twice. With the hold in place, there is a risk that your advance parole document could be revoked, delayed, or that your I-485 could face additional scrutiny upon return. Consult your attorney before any international travel.

4. Respond to Any USCIS Requests Immediately

Even though your case is on hold, USCIS may still issue Requests for Evidence (RFEs) or Notices of Intent to Deny (NOIDs). These have strict response deadlines. If you receive any communication from USCIS, respond within the deadline — do not assume the hold means you can wait.

5. Document Everything

Keep copies of every filing, receipt notice, biometrics appointment, and communication with USCIS. If the hold causes you to lose work authorization, miss a travel opportunity, or suffer financial harm, documentation will be critical if you later need to demonstrate the impact of the delay.

6. Contact an Immigration Attorney

This policy is unprecedented in its scope. An experienced immigration attorney can assess whether your specific case falls into an exception, whether alternative filings might protect your status, and whether legal challenges to the hold may benefit your case. Several lawsuits have already been filed challenging the constitutionality of these memos.

Legal Challenges to the Hold

Multiple organizations and law firms have filed federal lawsuits challenging PM-602-0192 and PM-602-0194. The legal arguments include:

• Violation of the Administrative Procedure Act (APA) — The memos were issued without notice-and-comment rulemaking, which is required for substantive policy changes of this magnitude.
• Equal protection violations — Blanket holds based on country of birth raise constitutional equal protection concerns.
• Due process violations — Indefinite holds without any timeline or individualized review may violate the Fifth Amendment.
• Exceeding statutory authority — Congress set timelines for processing certain applications, and blanket holds may violate those mandates.

These cases are working through the federal courts. Some early injunctions have been granted in individual cases, but no nationwide relief has been ordered as of March 2026. The legal landscape is changing quickly.

What This Means for Families

The practical impact on families is severe. Spouses waiting for green cards cannot travel. Parents petitioned by U.S. citizen children see their cases frozen. Workers whose EADs depend on pending I-485s face potential gaps in employment authorization. And asylum seekers from every country — not just those on the high-risk list — have no idea when their cases will be heard.

If you are a U.S. citizen or permanent resident with family members affected by these holds, the most important thing you can do is work with an immigration attorney to explore all available options. In some cases, congressional inquiries, mandamus actions (lawsuits to compel USCIS to act), or alternative filing strategies may help move a case forward.

At Modern Law Group, we represent families from countries on the high-risk list and handle asylum cases, green card applications, and family immigration petitions nationwide. If your case is frozen, we can review your options and fight for your family. Call us today: (888) 902-9285.