UPDATED - February 6, 2026
On January 1, 2026, USCIS issued a policy memorandum that updated its earlier December 2, 2025 announcement (discussed below), in which the agency announced a hold on the processing of immigration benefits applications submitted by or on behalf of persons from “high-risk” countries. In the new memorandum, USCIS effectively expands the hold to include nationals from countries listed in Presidential Proclamation 10998 (announced on December 16, 2025 and implemented on January 1, 2026), which imposed travel restrictions on 20 countries in addition to those included in Presidential Proclamation 109494 (effective as of June 9, 2025). A full list of countries now affected by travel restrictions can be found on our Current Travel Restrictions by Presidential Proclamation web page.
Impact: Under this updated policy announcement, immigration benefits applications from nationals from countries and entities currently subject to travel restrictions will continue to be accepted and processed. However, final adjudication (i.e., a final decision) may not be made until USCIS operationalizes procedures for additional screening or otherwise decides to remove the hold. As a result, there may be delays for many common benefits applications - including Form I-765 applications for employment authorization (including for OPT or J-2 employment), Form I-129 petitions for temporary workers (including H-1B petitions), and Form I-539 for changes of status - submitted by or a foreign national with citizenship from or born in one of the travel-restricted countries. Delays can involve additional security checks as well as requests for additional evidence (RFEs).
Recommendations: Students and others from an affected country who plan to apply for post-completion Optional Practical Training, STEM Extension Optional Practical Training, or other immigration benefits are encouraged to apply as soon as they are eligible to do so. Given the possibility of extended processing delays, filing as early as allowed may minimize the chance of interruptions to employment. ISSS will continue to monitor the situation, and students are encouraged to contact their ISSS advisor in the event they receive USCIS updates and requests for evidence related to their applications.
ISSS is also actively reviewing any employment-based non-immigrant or permanent residence petition for employees and scholars that may be affected by the processing pause, and will discuss options and impacts with their individual sponsoring departments.
This is an ongoing development, and please contact isss@brown.edu if you have any questions or concerns.
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December 5, 2025
On December 2, 2025, the U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum, "Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries." The memorandum included the following directives, which go into effect immediately:
- Places a hold on all Forms I-589 (Application for Asylum and for Withholding of Removal), regardless of the alien’s country of nationality or citizenship
- Places a hold on pending benefit requests for nationals whose country of birth or country of citizenship is included in Presidential Proclamation (PP) 10949, Restricting the Entry of Foreign Nationals To Protect the United States From Foreign Terrorists and Other National Security and Public Safety Threats, pending a comprehensive review, regardless of the person's date of entry into the U.S.
- Orders a comprehensive re-review of approved benefit requests for aliens from countries listed in PP 10949 who entered the United States on or after January 20, 2021.
The countries included in Presidential Proclamation 10949 include Afghanistan, Myanmar (Burma), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra, Leone, Togo, Turkmenistan, and Venezuela.
In the memo, USCIS directs that any person "meeting these criteria undergo a thorough re-review process, including a potential interview and, if necessary, a re-interview, to fully assess all national security and public safety threats along with any other related grounds of inadmissibility or ineligibility."
The memo does not fully explain what types of “benefits requests” would be subject to a processing hold. Among those requests that are explicitly mentioned are Form I-485 for adjustment of status, Form I-90 for green card replacements, Form I-751 for removing conditions on permanent residency, Form I-131 for travel documents including advance parole, and Form N-470 for preserving residence for naturalization. However, this list may not be exhaustive and other types of benefits applications (including I-765 applications for employment authorization as well as I-129 applications for H-1B or O-1 employment authorization) may also be affected, although this has yet to be determined conclusively. This is a developing situation, International Student and Scholar Services (ISSS) will provide updates when additional information becomes available.
If you are a student or scholar from one of the 19 countries included in the PP 10949 travel ban, and have a pending immigration benefits request, please contact your ISSS advisor for more information.