IMMIGRATION LAW ALERT — 2025–2026
The New Enforcement Era: What Every Immigrant and Naturalized Citizen Must Know Right Now
USCIS has issued sweeping new policies. They target asylum seekers, green card holders, diversity visa applicants — and even U.S. citizens. Here is what is happening, who is at risk, and how to protect yourself.
Immigration enforcement in the United States has entered a new era. Over the past several months, USCIS has issued a series of sweeping policy changes. These changes affect not only people applying for visas or green cards. They also affect people who already hold lawful permanent residence. Most surprisingly, they affect naturalized U.S. citizens.
This article breaks down each major policy shift in plain language. First, we explain what the government has done. Then, we identify who is most at risk. Finally, we outline the steps you can take to protect yourself and your family.
| 39
Countries subject to application holds |
100–200
Denaturalization referrals targeted per month in 2026 |
2,400+
Projected annual denaturalization cases — up from ~11/year historically |
26M
Naturalized U.S. citizens subject to increased scrutiny |
1. Application Holds for 39 Countries
What Is an Adjudicative Hold?
Starting in December 2025, USCIS placed administrative holds on immigration applications from nationals of so-called “high-risk” countries. A hold does not mean your case is denied. However, it does mean your case will not be approved until USCIS completes a full re-review. That review may include a mandatory in-person interview.
| PM-602-0192 — Dec. 2, 2025
Hold on All Asylum Applications + Benefit Requests from 19 High-Risk Countries USCIS placed holds on every pending asylum application (Form I-589), regardless of nationality. In addition, all benefit requests from nationals of 19 countries listed in Presidential Proclamation 10949 were frozen. This includes green card applications, travel documents, and petitions to remove conditions on residence. |
| PM-602-0193 — Dec. 19, 2025
Hold on All Diversity Visa Adjustment of Status Applications All pending green card applications filed through the Diversity Visa (DV) Lottery program were placed on hold. As a result, associated work permits and advance parole documents are also frozen. Importantly, spouses and children following to join a DV winner are not exempt from this hold. |
| PM-602-0194 — Jan. 1, 2026
Expanded Hold: Additional High-Risk Countries Under PP 10998 A second wave of holds expanded the restricted country list to 39 total. Notably, this policy also covers nationals who acquired citizenship-by-investment (a “golden passport”) from a restricted country, even if they are traveling on a different passport. Furthermore, applications approved after January 20, 2021 are subject to re-review. |
The New USCIS Vetting Center
In December 2025, USCIS announced a new Vetting Center in Atlanta. This center will use artificial intelligence and classified intelligence resources. Its purpose is to conduct enhanced reviews of both pending and previously approved applications. As a result, even people who already received immigration benefits may face fresh scrutiny.
| KEY TAKEAWAY
If you are a national of any country on the restricted lists and have a pending application, your case is likely on hold. Being on hold is not a denial. However, it means you should not expect movement until USCIS completes its review. Do not make major life decisions — such as international travel — without first consulting an attorney. |
2. The Denaturalization Push: Even Citizens Are at Risk
A Historic Shift in Policy
Denaturalization is the legal process of stripping someone of their U.S. citizenship. Historically, it was reserved for extreme cases. For example, it was used against Nazi war criminals who lied about their pasts. Courts treated it as a rare and serious remedy.
That is now changing. According to internal guidance obtained by The New York Times and confirmed by NPR, USCIS field offices have been told to refer between 100 and 200 denaturalization cases per month to the Department of Justice. This target applies to fiscal year 2026. To understand the scale: from 2017 through late 2025, the government filed only about 120 total cases — roughly 13 per year. Under the new quota, that number could be exceeded in a single month.
| ~11
Average annual cases, 1990–2017 |
24
Total cases filed during the entire Biden administration |
120
Total cases filed 2017–2025 combined |
2,400
Projected annual cases under the new 2026 quota |
Who Is Being Targeted?
The Department of Justice has said it will “maximally pursue” denaturalization. Priority targets include people who hid criminal histories during naturalization. They also include individuals involved in PPP or Medicare fraud. Additionally, people connected to gangs or drug cartels are on the list.
However, experts warn that meeting a monthly quota of this size is extremely difficult. As a result, there is real risk that the government will pursue cases involving minor or unintentional errors. These are errors that would never have triggered action under prior standards.
| WHAT IS DENATURALIZATION?
Denaturalization is the legal process of revoking U.S. citizenship from a naturalized citizen. It requires a federal court proceeding — the government must prove its case before a judge. Under current law, it is only permitted when citizenship was obtained illegally or through willful misrepresentation. If citizenship is revoked, it is treated as though it never existed. This typically makes the person deportable. |
What Legal Experts Are Saying
Critics — including former USCIS officials — have raised serious concerns. One former policy chief noted that the Supreme Court has repeatedly called citizenship too fundamental to take away lightly. Another former official warned that quota-driven enforcement turns a careful legal process into a blunt instrument.
Importantly, the legal standard in federal court has not changed. The government still bears a heavy burden of proof. Nevertheless, the sheer volume of referrals will create fear and uncertainty. There are approximately 26 million naturalized Americans living in the United States today. Even those with completely clean records may feel the effects.
3. The VAWA Confidentiality Rollback
What Changed and Why It Matters
On December 22, 2025, USCIS issued a policy alert narrowing the confidentiality protections for domestic violence survivors, trafficking victims, and crime victims. These protections apply to people seeking status under VAWA, the T visa program, or the U visa program.
Under 8 U.S.C. 1367, information provided by abusers or traffickers cannot normally be used against a protected person. Previously, this rule was applied broadly. The new policy narrows it in three important ways.
Three Key Changes to the Confidentiality Rules
- Criminal conviction exception: USCIS now applies a criminal conviction exception. Specifically, if a survivor has been convicted of certain crimes under INA 237(a)(2), information from their abuser may now be used against them in an immigration proceeding.
- Protections no longer end at naturalization: Previously, confidentiality protections ended when a person became a U.S. citizen. Now, that is no longer the case. As a result, even naturalized citizens who came through VAWA, T, or U proceedings may face renewed scrutiny under the denaturalization program.
- Narrowed scope of the prohibited source rule: The ban on using abuser-supplied information now applies only to adverse admissibility or deportability determinations. Therefore, it does not apply to benefit denials, such as denial of a VAWA self-petition or an employment authorization application.
| WHO THIS PUTS AT RISK
Survivors of domestic violence, trafficking, or serious crimes who have a pending or approved VAWA, T, or U case now face a very different legal environment. Information that was previously off-limits may now be considered. Moreover, naturalized citizens who came through these programs may be revisited under the denaturalization push. Accordingly, legal representation is more important than ever for this population. |
Who Is Most at Risk Right Now?
Based on the policies described above, the following groups face the greatest risk of being affected. If you fall into any of these categories, you should consult an attorney as soon as possible.
- Nationals of any of the 39 countries listed in PP 10949 or PP 10998 with pending green card, asylum, or benefit applications
- Diversity Visa lottery winners and their families with pending adjustment of status applications
- Nationals from restricted countries who entered the U.S. on or after January 20, 2021 and received an approved benefit — their cases may be re-reviewed
- Naturalized U.S. citizens who obtained citizenship after receiving VAWA, T, or U status, or who had any discrepancies or omissions in their naturalization paperwork
- Naturalized citizens with any criminal history — even old or resolved matters — who did not fully disclose that history during naturalization
- Anyone who acquired citizenship-by-investment from a country now subject to entry restrictions
- VAWA, T, and U visa applicants with criminal records, or whose abusers or traffickers have provided adverse information to USCIS
- Refugees and asylees from high-risk countries who have already received status and entered the U.S. on or after January 20, 2021
How to Protect Yourself: Practical Steps
Step 1: Consult an Immigration Attorney Now
The single most important step you can take is to speak with an experienced immigration attorney before doing anything else. Do not travel internationally. Do not respond to government notices. Do not file new applications without legal guidance. The stakes in each of these areas are simply too high for self-representation.
Step 2: Gather and Organize Your Records
Find and secure all key documents. These include your naturalization certificate, green card, prior immigration applications, approval notices, and any USCIS correspondence. If questions arise about your history, strong documentation is your first line of defense.
Step 3: Do Not Travel Internationally Without Advice
Departing the U.S. while a hold or re-review is pending can have serious consequences. Specifically, it can affect your ability to return or can be treated as abandonment of a pending application. Therefore, always speak with an attorney before booking international travel.
Step 4: Review Your Naturalization File
If you have any concern about whether your naturalization application fully and accurately reflected your history — including prior criminal matters, prior names, addresses, marriages, or immigration violations — speak with an attorney now. It is far better to address potential issues proactively than to wait for the government to find them.
Step 5: For VAWA, T, and U Applicants
Document your victimization as thoroughly as possible. Work closely with your attorney to build the strongest case you can. Because the confidentiality protections have been narrowed, your own evidence and credibility now matter more than ever. Additionally, be aware that a criminal record — even an old one — may now be used against you in ways it previously could not.
Resources: Know Your Rights in Print
The following books from the Pro Se Immigration Law Library offer in-depth, accessible guidance on two of the areas most directly affected by these policy changes. They are valuable resources for affected individuals, their families, and the attorneys representing them.
| 📘 Defending Against Denaturalization Actions
Pro Se Immigration Law Library — Available on Amazon. An essential resource for naturalized citizens, their families, and counsel facing the government’s escalating denaturalization efforts. |
| 📗 VAWA, U Visas, and T Visas: A Comprehensive Guide
Pro Se Immigration Law Library — Available on Amazon. Covers the full landscape of victim-based immigration relief at a time when these protections are under significant legal pressure. |
Disclaimer: This article is for general informational purposes only. It does not constitute legal advice. Immigration law is highly fact-specific. Please consult a qualified immigration attorney regarding your individual circumstances.