DHS Pauses USCIS Applications for Additional High-Risk Countries: What You Need to Know

The Law Offices of Norka M. Schell, LLC

Effective January 1, 2026, the U.S. Department of Homeland Security (DHS) has expanded its pause on the adjudication of immigration benefits. Under Policy Memorandum PM-602-0194, U.S. Citizenship and Immigration Services (USCIS) is implementing an immediate “hold and review” for applications from an expanded list of high-risk countries.

This directive follows Presidential Proclamation (PP) 10998, which adds dozens of new countries to the restricted list originally established in June 2025.

Key Update: The “Hold and Review” Policy

The new USCIS policy memorandum mandates three primary actions:

  • Adjudicative Hold: A pause on all pending benefit applications for individuals from high-risk countries until a comprehensive security review is completed.
  • Mandatory Re-Reviews: A full re-review of immigration benefits already approved on or after January 20, 2021, for individuals from these countries.
  • Operational Scrutiny: A complete audit of all screening and vetting procedures for these specific regions.

Which Countries Are Affected? (2026 Updated List)

The pause now impacts two categories of countries: those under Full Restrictions (no entry for most immigrants or nonimmigrants) and those under Partial Restrictions (restrictions on B, F, M, and J visas).

New Full Restriction Countries (Added Jan 1, 2026)

In addition to the original 12 countries (like Afghanistan, Iran, and Somalia), the full ban now includes:

  • Burkina Faso
  • Mali
  • Niger
  • South Sudan
  • Syria
  • Laos (Moved from partial to full)
  • Sierra Leone (Moved from partial to full)
  • Palestinian Authority Travel Document Holders

New Partial Restriction Countries (Added Jan 1, 2026)

Fifteen additional countries now face partial restrictions:

  • Africa: Angola, Benin, Cote d’Ivoire, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Zambia, Zimbabwe.
  • Caribbean/Pacific: Antigua and Barbuda, Dominica, Tonga.

Who Does This Policy Impact?

The USCIS hold is not limited to those currently outside the U.S. It specifically targets:

  • Anyone listing a high-risk country as their Country of Birth or Country of Citizenship.
  • Individuals who obtained Citizenship by Investment (CBI) from a second country to bypass restrictions.
  • Family members of individuals in the United States, as broad family-based exemptions have been narrowed.

Are There Exceptions?

While most benefits (including Green Cards and Naturalization) are paused, some specific forms are exempt from the hold:

  • Form I-90: Green Card replacements.
  • Form N-600: Certificate of Citizenship (except for Yemen and Somalia).
  • Specific Work Permits: Initial (c)(8) asylum-based EADs and certain law enforcement-related (c)(11)/(c)(14) categories.
  • National Interest Waivers: Cases involving critical medical research, infrastructure, or U.S. national security.

What to Expect Next

Applicants from affected countries should prepare for significant processing delays and the possibility of mandatory re-interviews. USCIS is expected to issue further operational guidance within 90 days of the memorandum’s issuance.

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