What’s Happening
In the week following the November 26, 2025, shooting of two National Guard members in Washington, D.C. the federal government has announced a series of significant and fast-moving immigration policy actions reflecting a shift toward stricter national-security-based assessments. These measures span consular visa issuance, domestic USCIS adjudications, asylum processing, green card reviews, and discretionary determinations for certain immigration benefits requests.
What You Need to Know
Below is a summary of the various statements, guidance, directives, and policy memoranda issued in response to the November 26th shooting. Additional directives are expected in the coming days and weeks.
USCIS Authorization to Consider Negative Country-Specific Factors
On November 27, 2025 USCIS issued a Policy Alert authorizing adjudicators to weigh “relevant country-specific factors” as negative elements when deciding discretionary immigration benefits. This policy applies to benefits requests that involve and element of discretionary review, including adjustment of status applications (Form I-485), applications to change or extend nonimmigrant status (filed on Form I-539), applications for employment authorization documents (filed on Form I-765), and humanitarian benefits such as asylum, refugee processing, humanitarian parole, and Temporary Protected Status.
A full list of immigration benefits requiring discretionary review is contained in Chapter 8 of the USCIS Policy Manual. With a few, limited exceptions, employment-based nonimmigrant visa petitions filed on Form I-129 are not discretionary and thus would not be impacted by the Policy Alert. Similarly, I-130 Family-Based Immigrant Visa Petitions (with some exceptions), I-140 Employment-Based Immigrant Visa Petition (with the exception of National Interest Waivers), and N-400 Naturalization Applications do not involve discretionary review.
Under this framework, officers adjudicating impacted benefits requests may evaluate relevant country-specific facts and circumstances, such as insufficient vetting and screening information. These factors may be treated as significant negative considerations even where the applicant presents no individualized derogatory information. These changes to the USCIS Policy Manual are effective immediately for all pending and newly filed applications.
State Department Suspends Visa Issuance to Afghan Nationals
On November 28, 2025, the Department of State announced on X an immediate suspension of visa issuance to Afghan passport holders. Although Afghan nationals were already largely restricted under President Trump’s June 2025 travel ban, this new directive closes remaining exceptions that previously allowed some individuals to qualify for visas despite the entry suspension.
Reuters and the New York Times have also confirmed that a State Department cable was issued to diplomatic posts on Friday, November 28th, directing consular officers to “reject any immigrant or nonimmigrant visa applications from Afghan nationals including applicants for Special Immigrant Visas.” The cable instructs officers to conduct any scheduled interviews but to refuse applicants following the interview and to destroy any visas that have been printed by not returned to the applicant.
The plain wording of the announcement seems to apply only to those traveling on Afghan passports, thus leaving open the possibility for dual nationals of Afghanistan and another country to continue to be issued visas when using their non-Afghan passport. The State Department has not confirmed this nor has it provided a timeline for the resumption of visa issuance to Afghan passport holders.
Potential Expansion of Entry Restrictions
On November 28, 2025 President Trump posted on social media that he will permanently pause immigration from certain countries he deems as “third world countries”. No new list or directive has yet been released providing additional details on these entry restrictions, but the administration has emphasized its intention to broaden current security-based entry suspensions.
USCIS Pauses and Re-Reviews a Wide Range of Immigration Applications
Processing Hold for Applicants From 19 Travel Ban Countries
On December 2, 2025, USCIS issued a Policy Memorandum (“PM”) mandating an immediate pause on all pending immigration benefit requests filed by individuals who either were born in or are citizens of any of the 19 countries covered by President Trump’s June 2025 travel ban, which includes Afghanistan, Burma, Burundi, Chad, the Republic of Congo, Cuba, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Sierra Leone, Somalia, Sudan, Togo, Turkmenistan, Venezuela, and Yemen.
Unlike the scope of the travel ban, this standard applies not just to nationality but, more broadly, to country of birth or citizenship, thus affecting a larger group of foreign nationals and not exempting dual nationals of non-listed countries, which served as a basis for exemption from the travel ban.
The PM notes that any requests to lift the hold on processing of applications due to litigation or other extraordinary circumstances must be approved by the USCIS Director or Deputy Director.
Re-Review of Approved Benefits
In the same PM, USCIS announced that it is initiating a comprehensive re-review of eligibility and admissibility, including a potential interview or re-interview, of previously approved immigration benefits for nationals of the 19 countries who entered the United States on or after January 20, 2021. The policy memorandum clarifies that officers may also extend review to individuals who entered before that date, but does not elaborate upon the criteria considered for extending the review to individuals with earlier entries. The re-review and processing hold apply to a broad range of filings, including:
I-485 Application to Register Permanent Residence or Adjust Status
I-90 Application to Replace Permanent Resident Card (Green Card)
N-470 Application to Preserve Residence for Naturalization Purposes
I-751 Petition to Remove Conditions on Permanent Residence
I-131 Application for Travel Documents, Parole Documents, and Arrival/Departure Records
The PM notes that this list is not exhaustive and employer sponsored filings may also be impacted when the beneficiary is from one of the listed countries. It remains unclear whether and how pending N-400 Naturalization Applications will be affected for lawful permanent residents whose underlying adjustment of status cases are now subject to re-review.
Pausing of Asylum and Withholding Adjudications
Further, the PM ordered an immediate, blanket pause on processing all Form I-589 Applications for Asylum and for Withholding of Removal, regardless of nationality or place of birth, pending comprehensive review of eligibility and admissibility.
Things to Keep in Mind
Expect Processing Delays and Requests for Evidence (RFEs)
Applicants from the 19 listed countries as well as all applicants for asylum and withholding of removal should anticipate slower processing times as USCIS conducts mandatory holds and re-reviews. Even applicants with no individual security concerns may receive RFEs or interview notices as part of these enhanced assessments. There have also been reports of individuals from one of the 19 listed countries having their adjustment of status interviews and naturalization oath ceremonies abruptly cancelled in the wake of these new directives.
Travel Plans May Be Disrupted
Individuals from the 19 countries with pending applications, especially those requiring advance parole or visa renewals, should avoid international travel where possible. Sudden issuance pauses, re-screenings, and new consular restrictions may prevent reentry or delay return to the United States.
Dual Nationals Are Not Necessarily Exempt from Re-Review
While the State Department’s visa suspension announcement referenced Afghan passport holders specifically, other USCIS policies hinge on country of birth or citizenship, not the passport used. Dual nationals should not assume exemption from pauses or re-reviews unless expressly confirmed by agency guidance.
Approved Benefits Are Not Final Under the New Policy
USCIS’s authority to re-review previously approved cases means that green card holders, parolees, and others meeting the re-review criteria may be called for interviews, asked to provide updated evidence, or required to respond to new admissibility inquiries, even if their benefits were issued years earlier.
Employers Should Prepare for Workforce Impacts
Delays or holds on employment authorization applications or renewals, adjustment applications, and nonimmigrant status extensions may affect hiring, I-9 compliance, and continuity of employment authorization for impacted employees. This is further compounded by the October 30th Interim Final Rule ending the automatic extension of employment authorization for certain categories of individuals with timely filed renewal applications for their Employment Authorization Documents (EADs).
Employers should both encourage potentially impacted employees to file EAD renewals as early in the filing window as possible and also undertake contingency planning for affected employees in the event of a lapse in employment authorization.
Agency Guidance Is Changing Rapidly
Several announcements to date have been made by social media posts without many details or formal directives. Revisions, clarifications, and additional restrictions are likely as agencies formalize new policy directives and issue new agency guidance.
D&S is continuing to monitor this developing situation and will provide updates as they become available.