This article was prepared with the assistance of ABIL, the Alliance of Business Immigration Lawyers, of which Loan Huynh is an active member.
On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a memorandum ordering USCIS personnel to “hold and review” all pending asylum applications and all USCIS benefit applications filed by those from “high-risk countries.” The memo also calls for re-review and re-interview of certain applicants.
USCIS said it has determined that a “comprehensive re-review, potential interview, and re-interview” of those from high-risk countries of concern who entered the United States on or after January 20, 2021, is necessary. USCIS said it “may, when appropriate, extend this review and re-interview process to aliens who entered the United States outside of this timeframe.”
The high-risk countries are listed in Presidential Proclamation 10949, issued in June 2025. Secretary of Homeland Security Kristi Noem reportedly met with President Donald Trump recently to discuss expanding the number of countries included in the Trump administration’s travel ban to more than 30, and those plans are moving forward. A Department of State (DOS) cable sent out in June reportedly said that the agency “has identified 36 countries of concern that might be recommended for full or partial suspension of entry if they do not meet established benchmarks and requirements within 60 days.”
