As of January 2026, DHS national security policy has imposed a total pause on the adjudication of immigration benefits for nationals of 39 countries designated as "high risk." Memorandum PM-602-0194 not only freezes new applications but mandates the re-review of applications approved since 2021. This means that permanent residents or naturalized citizens from these countries could face status revocation if "vulnerabilities" are detected in the retroactive security review.
"SECURITY ALERT: If you are a national of one of the 39 designated countries and obtained an immigration benefit (Green Card, citizenship, asylum) between 2021 and 2025, your case may be under active re-review. Consult an immigration attorney IMMEDIATELY."
Scope of Memorandum PM-602-0194
| Aspect | Detail |
|---|---|
| Implementation Date | January 1, 2026 |
| Affected Countries | 39 countries designated by national security (includes Syria, Iran, Iraq, Libya, Somalia, Yemen, Sudan, Venezuela, Nicaragua, Cuba, Haiti, among others) |
| Retroactive Review Period | Cases approved from January 2021 to present |
| Affected Benefits | Permanent residence, naturalization, asylum, TPS, EAD |
| Maximum Risk | Revocation of immigration status |
Retroactive Risk: What Does It Mean for You?
The memorandum orders the re-review of approved applications looking for "vulnerabilities" that include:
- Incomplete security checks in the original approval
- Document inconsistencies between the application and subsequent records
- Unreported changes in circumstance (travel to home country, address changes)
- Updated intelligence information that did not exist at the time of approval
"Strategic Note: This is a security bottleneck that prioritizes surveillance over efficiency. Cases in administrative limbo may remain unresolved for months while additional review is completed."
Defense and Protection Strategies
| Action | Detail | Resource |
|---|---|---|
| 1. Immediate Legal Consultation | Contact a certified immigration attorney who handles national security cases | ailalawyer.com (AILA Attorney Search) |
| 2. Document Collection | Gather ALL documentation from your original case: forms, receipts, supporting evidence | Keep certified copies |
| 3. FOIA Request | Request your full USCIS file through the Freedom of Information Act | uscis.gov/records/FOIA |
| 4. Congressional Inquiry | Contact your representative's office to press for a resolution | house.gov/representatives |
| 5. DHS Ombudsman | File a formal complaint if your case is stalled without communication | dhs.gov/case-assistance |
Legal Resources and Portals
| Resource | Detail |
|---|---|
| Verify Case Status | egov.uscis.gov/casestatus |
| AILA Attorneys | ailalawyer.com |
| Free Legal Assistance | CLINIC Legal Directory |
| FOIA Request | uscis.gov/records |
| DHS Ombudsman | dhs.gov/case-assistance |
| USCIS Phone | 1-800-375-5283 |
"Immediate Action: If you are a national of one of the 39 high-risk countries, DO NOT travel outside the U.S. without consulting an attorney. Request your FOIA file and consult an attorney regarding the retroactive review of your status since 2021."