39-Country Ban? What USCIS Isn’t Telling You (April 2026 Update)

USCIS may not be denying your green card case — but it may be quietly putting it on hold.

As of December 2, 2025, USCIS and the State Department began a new “hold and review” process for certain immigration applications filed by individuals from 39 countries – suspending the issuance of visas and green cards for all applicants for an uncertain period of time. Under this policy, officers are expected to pause final decisions while enhanced security vetting processes are established by the government.

For applicants, that means one thing: more delays and uncertainty.

If your case was moving forward, your fingerprints were already taken, or you were expecting an interview soon, this sudden pause could explain why everything has gone silent.

In this update, we break down what USCIS’s “hold and review” policy means, who may be affected, whether you need to take action, and what applicants should watch for next.


Why is there a “hold and review” policy?


In June and December 2025, the President issued various executive orders, imposing immigration restrictions affecting individuals from 39 countries. The ban affects their ability to enter the United States, receive U.S. visas, and obtain immigration benefits through agencies like USCIS and the Department of State via Consular processing.

The affected countries include Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Republic of the Congo, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, The Gambia, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, Zimbabwe, and individuals holding Palestinian-Authority-issued travel documents.


“Born In” USCIS Policy


Unfortunately, USCIS has adopted a “born in” rule, meaning it may consider not only a person’s current citizenship or nationality, but also their country of birth, when determining whether the person is restricted from receiving immigration benefits.

So under the hold-and-review policy, a person may be affected if they were born in one of the listed travel-ban/high-risk countries, even if they are now a citizen of another country. In other words, the trigger is broader than nationality alone.

Example: someone born in Iran, Syria, Haiti, Venezuela, Nigeria, or another listed country could be flagged for hold-and-review even if they later became a Canadian, British, French, or other nationality.

The State Department has not adopted the “born in” rule.


When Will the 39-Country Hold and Review Policy End?


There is a good chance the “hold and review” policy will be lifted for individuals who successfully pass enhanced security vetting. The purpose of the pause is additional review, not a permanent denial of immigration benefits.

Once the government completes its background checks and determines that no security, fraud, or public-safety concerns exist, USCIS may resume adjudication and move the case forward for those affected.


Are there National Interest Exceptions to the Hold and Review Policy?


The “hold and review” policy is not automatically lifted. Instead, USCIS appears to lift the pause only on a case-by-case basis, based on the government’s internal discretion.

In limited situations, affected nationals may request that USCIS lift the suspension and adjudicate the pending application if it is in the national interest. The government has not clearly explained what qualifies as a national interest exception, making it difficult for applicants to know whether they are eligible to request relief.

Although there does not appear to be a clear public policy explaining exactly how these requests should be filed, our office has had success submitting these requests in compelling cases, including for a nurse working in an ICU unit who was waiting for her green card to be adjudicated so she could work on a U.S. military base.

If you believe your work serves an important U.S. national interest, you should seek legal guidance to determine whether you may qualify to submit a request.

Highlights – Things to Watch for: 

How Operation PARRIS is Affecting Refugees


Operation PARRIS, short for Post-Admission Refugee Reverification and Integrity Strengthening, is a DHS/USCIS initiative to re-review certain refugee cases after admission to the United States.

The program may require additional background checks, reinterviews, and renewed review of refugee claims, with an initial focus reportedly placed on thousands of refugees in Minnesota who had not yet become lawful permanent residents.

PARRIS appears to be part of the government’s broader enhanced vetting and “hold and review” framework, meaning some cases may be paused, reexamined, or subject to additional security screening before USCIS moves forward.

Affected individuals should seek immediate legal assistance if contacted by USCIS.


 USCIS Work Permits Expiring Sooner


USCIS shortened work permit validity periods in late 2025, reducing many EAD validity periods from up to five years to 18 months for applications pending or filed on or after December 5, 2025.

The shorter work permit validity periods were adopted to allow for more frequent screening and vetting, with the goal of identifying fraud, public-safety risks, and national-security concerns before employment authorization is extended.

Applicants may file Form I-765 to renew an Employment Authorization Document up to 180 days (6 months) before their current EAD expires.


Enhanced Social Media & Financial Vetting


Immigration agencies are taking a broader look at an applicant’s online presence, financial history, and other background information before approving immigration benefits or issuing visas.

USCIS has described this as part of its strengthened screening and vetting efforts, including increased social media and financial review, community interviews, and additional background checks.

The Department of State has also expanded online-presence review to additional visa categories, meaning applicants may face closer scrutiny of social media accounts, public posts, professional profiles, and other online activity during the visa interview process.

These measures may lead to longer processing times, issuance of more requests for evidence, additional interviews, or delays while the government completes security-related reviews.


Enhanced Biometrics Vetting


USCIS is enhancing security checks for certain immigration applications that require fingerprint-based background checks including green cards. The new process became effective on April 27, 2026, and requires officers to pause or delay final adjudication while pending applications are submitted for enhanced FBI vetting. Affected cases may include adjustment of status, asylum, naturalization, family-based green card petitions, and other immigration benefit requests requiring biometrics.


Stronger Information Sharing with USCIS


USCIS is receiving more direct and timely updates from other government agencies, including law enforcement and security databases. If a noncitizen is arrested, charged with a crime, convicted, or flagged for certain immigration or public-safety violations, that information may be shared with USCIS and considered during the review of a pending or future immigration application. This increased interagency communication may lead to delays, additional questioning, requests for evidence, or further security review before USCIS makes a final decision.


The Bottom Line


The 39-country “hold and review” policy has created a new layer of uncertainty for affected applicants, especially those waiting on green cards, visas, work permits, or other immigration benefits. With enhanced security checks, broader agency information-sharing, shorter EAD validity periods, and little public guidance from the government, applicants cannot afford to simply wait and hope for the best.

If your case has stalled, or you may qualify for a national interest exception, you should speak with an immigration attorney as soon as possible to understand your options and protect your case.


Contact Us. If you would like to schedule a consultation, please text 619-483-4549 or call 619-819-9204.


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