What’s Happening
On August 15, 2025, the United States Citizenship and Immigration Service (USCIS) issued a new Policy Memorandum (PM) that changes how they assess whether someone can sufficiently demonstrate “good moral character” (GMC) when applying for U.S. citizenship.
What you Need to Know
In order to qualify for naturalization as a U.S. citizen, applicants must, among other things, demonstrate that they have been a person of good moral character for the “statutory period” (typically 3 or 5 years) preceding the submission of the application for naturalization. Previously, when assessing GMC, USCIS mainly checked for criminal convictions or other serious wrongdoing. Now, USCIS is shifting to a totality-of-the-circumstances approach—meaning officers will weigh both any negative factors as well as their positive contributions.
Factors that USCIS Will Consider in Assessing GMC
While the new PM does provide some specific examples of positive and negative factors (outlined below), we will need to see how adjudicators ultimately apply these new standards in practice in order to develop strategies for adequately demonstrating GMC under the new policy.
Positive Contributions:
Community involvement, volunteering, civic or religious participation
Family caregiving, such as helping children or elderly relatives
Education and professional or personal development
Stable, lawful employment and strong work historyTax compliance, including paying fines or debts on time
Length of lawful U.S. residence and financial responsibility
Behaviors That Could Raise Concerns (Even If Not Criminal):
Reckless or repeated traffic violations
Harassment or aggressive solicitation
Other behavior that doesn’t align with what’s “typical in the community”
Rehabilitation & Reform Matter
Having negative factors that could detract from a showing of GMC does not automatically result in a denial and the PM instructs officers to consider evidence of reform, such as:
Paying overdue taxes or child support
Complying with court orders or probation
Participating in community programs or mentoring
Letters from people who can attest to reform/good character
Serious Disqualifiers Still Apply:
Certain crimes remain outright bars to naturalization:
Permanent bars: murder, genocide, aggravated felonies
Conditional bars: multiple DUIs, false claims to U.S. citizenship, certain drug offenses
What This Means
| What’s Different | What You Should Do |
|---|---|
| USCIS now reviews overall character—not just legal history | Tell your full story—include positive actions and life context |
| More subjective assessment by officers | Include evidence of positive actions: community letters, employment, payment of taxes, charitable donations, volunteer work |
| Even minor infractions could be flagged without counter-evidence | Be proactive: address past issues honestly and show rehabilitation |
| Application reviews may take longer or include Requests for Evidence (RFEs) | Work closely with an attorney—especially if there’s a complicated history |
It’s possible this policy could be subject to a Federal Court challenge and D&S will continue to monitor and provide updates as they become available.
This post is for informational purposes only and does not constitute legal advice.