USCIS has issued a policy directive that halts processing of certain immigration applications from individuals linked to countries designated as high-risk under Presidential Proclamation 10949. For global employers, this introduces a new layer of complexity, with potential delays to onboarding, reassignment, and compliance procedures for foreign nationals affected by the adjudication hold.
Understanding the operational and legal scope of this policy is critical for companies that manage U.S.-bound mobility from globally diverse talent pools. Mobility, legal, and HR leaders must prepare to navigate a period of elevated scrutiny and procedural slowdowns.
What Has Changed: USCIS Policy PM-602-0192
As of December 2, 2025, USCIS has mandated a hold on two major categories of cases:
- All pending asylum applications (Form I-589), irrespective of nationality.
- All pending benefit requests (e.g., green cards, parole documents, naturalization forms) filed by individuals from the 19 countries listed in PP 10949, which invokes INA §212(f) national security authority.
Additionally, USCIS is re-reviewing benefit requests that were previously approved for individuals from these countries who entered the U.S. on or after January 20, 2021. Entry is defined broadly and includes those who were admitted, paroled, or entered without inspection.
Applicants within the scope of the policy will be subject to individual re-assessment, mandatory interviews (or re-interviews), and new screenings designed to evaluate potential ties to terrorism or public safety threats.
Strategic Implications for Global Employers
For organizations with mobile workforces or active immigration pipelines, the consequences are significant. Processing delays are now unavoidable for individuals from impacted countries, even for routine benefit types. These delays are not limited to new filings; they also apply retroactively to applications already submitted and, in some cases, approved.
This introduces unpredictability into workforce planning. Employees scheduled for assignment or onboarding in the U.S. may now face indefinite delays pending USCIS review. In addition, re-interviews could raise new eligibility concerns, even where prior adjudications were favorable.
The impact extends beyond case-by-case delays. It signals a broader shift toward heightened scrutiny for foreign nationals from certain geopolitical regions, potentially altering how companies prioritize or sequence international assignments.
Operational Considerations and Risk Mitigation
In this context, proactive planning becomes essential. Employers may be advised to conduct an audit of their current immigration portfolio, flagging employees who may be subject to this hold. Open communication with affected talent will be important for managing expectations and preserving engagement.
Legal teams should prepare for requests for evidence (RFEs), new interview requirements, and more detailed scrutiny of identity documentation. In parallel, mobility programs may need to reassess timing, explore visa alternatives, or shift assignment destinations as part of a short-term mitigation strategy.
The USCIS memo also reinforces the importance of sound compliance practices. Gaps in documentation or ambiguity in travel histories could now invite intensified review, increasing the burden on employers to maintain rigorous internal processes.
Looking Forward
There is no clear timeline for lifting the adjudication hold. USCIS has framed this action as necessary to safeguard national security, indicating that delays are not a side effect but an intentional measure. Until the hold is formally rescinded, employers should expect prolonged processing for individuals from the designated countries.
As U.S. immigration enforcement evolves, Newland Chase remains committed to helping clients navigate uncertainty with clarity and confidence. Our global immigration advisors are available to assess risks, advise on compliant strategies, and support organizations in adapting their mobility programs to meet changing regulatory conditions.
This immigration update is for informational purposes only and is not a substitute for legal or scenario-specific advice. Furthermore, it is important to note that immigration announcements are subject to sudden and unexpected changes. Readers are encouraged to reach out to Newland Chase for any case- or company-specific assessments.
