A Timeline of USCIS's Adjudication Holds for High-Risk Countries: How We Got Here
Updated August 17, 2026
Over the past several months, I have watched USCIS build, expand, and then partially lose in court a sweeping set of policies that paused final decisions on immigration benefits for people connected to a growing list of countries. If you or a family member has a pending case and you are from, or were born in, one of the affected countries, this timeline is meant to help you understand how we got to where we are today, step by step, in the order it actually happened.
I will keep updating this post as the litigation and USCIS guidance continue to evolve.
December 1, 2025: The Pause Begins
Before there was any public memo, word started to spread that USCIS had issued internal guidance pausing final decisions, both approvals and denials, on all case types for individuals from what were then 19 travel ban countries: Afghanistan, Burma, Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.
The impact was immediate and personal for a lot of people. Naturalization oath ceremonies scheduled for that same week were abruptly canceled for applicants from Venezuela, Iran, and Afghanistan, even for people who also held other citizenships. Adjustment of status interviews were canceled as well, particularly for Venezuelan nationals.
December 2, 2025: The First Memo
USCIS then published PM-602-0192, Hold and Review of All Pending Asylum Applications and All USCIS Benefits Filed by Aliens from High-Risk Countries. This made the pause, review, and re-interview process official.
One detail from this memo surprised a lot of people I talked to: the hold applied not just to current nationals of the listed countries, but to anyone born in one of those countries, regardless of what passport they currently hold. It also became clear that "all benefits requests" really did mean all of them, including Form I-129, I-140, I-539, I-765, and I-131, among others.
January 1, 2026: The Pause Grows
USCIS issued a new memo, PM-602-0194, expanding the hold to align with Presidential Proclamation 10998, signed December 16, 2025, which restricted entry for foreign nationals from an expanded list of countries.
The new memo directed USCIS to do three things for nationals of the listed countries:
Place a hold on all pending benefit applications, regardless of when they were filed, pending a comprehensive review.
Conduct a comprehensive review of the screening and vetting process for these applicants.
Conduct a comprehensive re-review of benefit requests that had already been approved on or after January 20, 2021.
The expanded list grew substantially and eventually included: Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Cote d'Ivoire, Cuba, Dominica, Republic of the Congo, Equatorial Guinea, Eritrea, Gabon, the Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe, along with individuals holding Palestinian Authority issued or endorsed travel documents.
The memo did carve out ten specific exceptions to the hold, including pending green card replacement or naturalization certificate requests, cases where ICE requested adjudication for public safety or national security reasons, certain work permit categories tied to law enforcement cooperation, cases involving a genuine United States national interest, and benefit requests for athletes and support staff attending major international sporting events. Any request for an exception had to be coordinated through USCIS's Office of Policy and Strategy, and the agency said further guidance on that process was coming within 90 days.
January 15, 2026: A Related Pause at the State Department
Around this same time, the State Department separately announced a pause on immigrant visa processing for nationals of 75 countries. At that point, USCIS had not yet issued a matching pause for adjustment of status cases involving those nationals, so those cases continued moving forward. It was clear, though, that this was likely to change soon.
April 14, 2026: USCIS Details Its Expanded Vetting
USCIS issued an update outlining what its expanded national security screening actually involved. This is where a lot of the mechanics of the pause became clearer, including:
Shortened validity periods for certain work permits to allow more frequent security checks
New photograph reuse and biometric identity verification requirements
Increased social media and financial vetting, along with community interviews
The launch of Operation PARRIS, a new initiative for additional background checks, re-interviews, and merit reviews of refugee claims
New systems to automatically flag biometric matches and new criminal history information
A requirement to check final arrest records and State Department consular databases before any final decision is issued
USCIS also described an internal process for lifting holds on certain categories, including cases vetted through Operation PARRIS, petitions filed by U.S. citizens, intercountry adoption cases, some rescheduled oath ceremonies, certain Special Immigrant Visa petitions, some work permit applications, and asylum applications from countries not considered high risk. Beyond that, though, the update remained fairly vague, and case processing continued to slow as officers worked to implement the new procedures.
April 22, 2026: Clarifying the National Interest Exemption
One of the more frustrating aspects of this whole process, from where I sit, has been the lack of a clear path for requesting a national interest exemption. USCIS confirmed around this time that there is no external process for individuals or organizations to formally request one. Exceptions are decided entirely by USCIS during its standard review, case by case, and only in what the agency calls exceptional circumstances.
For clients who may qualify, my advice has been to include a written national interest exemption request directly in the cover letter accompanying a filing, since there is no separate application or form for it.
May 1, 2026: A Small but Notable Addition
USCIS quietly updated its guidance to add medical physicians to the list of group cases eligible for the internal hold-lifting process. The update did not change the official posting date on USCIS's page, which technically still read March 30, 2026, but the substantive language had clearly been added.
June 5, 2026: A Federal Court Steps In
This is where the story shifts significantly. In Dorcas International Institute of Rhode Island v. USCIS, a federal court in Rhode Island vacated four of USCIS's policies at once: the Benefits Hold Policy, the Global Asylum Hold Policy, the Comprehensive Re-Review Policy, and the Country-Specific Factors Policy.
The court found that USCIS had acted arbitrarily and capriciously under the Administrative Procedure Act because the agency failed to give a reasoned explanation for the policies, failed to account for the reliance interests of people affected by them, and offered what the court viewed as a pretextual justification.
USCIS did not immediately explain how it would implement the ruling. Instead, it asked the court to clarify its order and sought a final judgment so it could appeal. On June 11, 2026, the court issued a pointed second order, stating plainly that the challenged policies were "vacated," "set aside," "cancelled," "annulled," "revoked," and "void," and that the government had 24 hours to report on its compliance.
On June 12, 2026, USCIS filed its appeal to the First Circuit Court of Appeals. It also issued an alert stating it disagreed with the court's order but would "follow its terms pending possible further judicial review," clarifying that it would no longer treat the underlying policy memos as effective for the time being.
July 15, 2026: The Government's Request for a Pause Is Denied
USCIS asked the district court to pause its own order while the appeal moved forward. The court said no. It found that USCIS had not shown it was likely to win on appeal, had not shown it would suffer real harm without a stay, and that the public interest and the interests of the people who filed the lawsuit weighed heavily against granting one.
As a result, USCIS was required to keep processing the cases that had been affected by all four vacated policies. Reports from immigration attorneys around the country began to confirm that USCIS had, in fact, started issuing decisions in at least some previously paused cases.
August 14, 2026: A Partial Win for the Government on Appeal
Most recently, the First Circuit Court of Appeals granted USCIS a partial stay while the appeal continues. Specifically, the court allowed USCIS to resume its Comprehensive Re-Review Policy, meaning the agency can once again re-review previously approved cases for individuals from the listed countries who entered the United States on or after January 20, 2021.
However, the First Circuit denied the government's request to pause the rest of the district court's ruling. That means the Benefits Hold Policy and the Country-Specific Factors Policy remain vacated for now. The government had not asked the court to stay the portion of the ruling related to the Global Asylum Hold Policy, so that part of the decision stands as well.
Where Things Stand Today
As of this update, here is the practical reality for anyone affected:
The Comprehensive Re-Review Policy is back in effect, so previously approved cases for people from the listed countries who entered on or after January 20, 2021 can be re-reviewed.
The Benefits Hold Policy and Country-Specific Factors Policy remain vacated, meaning USCIS should not be applying them.
The Global Asylum Hold Policy also remains vacated.
The underlying appeal is still pending, so this is very likely not the final word.
What This Means for You
If you or a family member falls into one of the affected categories, whether because of current nationality, country of birth, or a prior citizenship by investment connected to one of these countries, this is not a situation where "no news is good news." Policies have been announced, walked back, litigated, partially reinstated, and are still moving. A case that was stuck for months could suddenly move forward, and a case that seemed to be progressing normally could become subject to re-review.
My recommendation is the same one I give every client navigating a moving target like this: document everything, keep your filings current, and do not assume last month's guidance still applies today. If your case has been delayed, denied, or flagged for re-review, or if you simply are not sure where you stand, reach out. I would rather help you figure out where things actually stand now than have you find out the hard way later.
This post is for general informational purposes only and does not constitute legal advice. Every case is different. Contact Cameron Moore Law to discuss your specific situation.