Sweeping Restrictions on “Countries of Concern” 

Topics We're MonitoringDecember 3, 20250

Sweeping Restrictions on “Countries of Concern” 

Originally Posted: 12/3/2025 | Last Updated: 12/22/2025 

On November 26, 2025, two members of the West Virginia National Guard were shot in D.C. Various reports confirm the individual accused of the shooting is an Afghan national who was screened and vetted prior to entry under the Operation Allies Welcome program in 2021 after serving alongside U.S. Special Forces for 10 years and later granted asylum in April 2025. This event set off a flurry of social media posts by President Trump and Secretary of Homeland Security Kristi Noem calling for additional measures to protect national security and DHS was quick to respond with multiple policy updates in the following days. Other events since then have further tightened restrictions, including the expansion of the travel ban on December 16, 2025.  

Impacted Countries:

travel ban was implemented June 9, 2025 by Presidential Proclamation 10949, which remains in effect. 19 countries were initially impacted by a full or partial travel ban in June, and 20 more were added to that list on December 16, 2025 (effective January 1, 2026). The travel ban countries are those referred to as “countries of concern” as it relates to the policy updates and restrictions described below. 

  • This includes the following as “countries of concern”: 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 those holding Palestinian Authority-issued travel documents. 

Restrictions on individuals from countries of concern: 

  • Reexamination of green card holders. On November 27, 2025, it was announced via social media that USCIS will conduct a “full scale, rigorous reexamination of every green card for every alien from every country of concern” (referring to the travel ban countries). 
    • According to a Policy Memo released on December 2, 2025, the reexamination process could include an interview, or re-interview, to fully reassess eligibility. The eligibility assessment may include determining whether the applicant is listed in the Terrorist Screening Dataset (TSDS), has been involved with certain criminal or related organizations or activities listed in the INA, and whether the applicant is able to establish their identity in line with PP 10949. 
    • At this time, apart from the above, no further guidance has been released to indicate the scope of permanent residents to be re-examined, the full criteria to be reviewed, or the exact process for doing so. The Policy Memo notes: “Within 90 days of issuance of this memorandum, USCIS will prioritize a list for review, interview, re-interview, and referral to ICE and other law enforcement agencies as appropriate, and, in consultation with the Office of Policy and Strategy and the Fraud Detection and National Security Directorate, issue operational guidance.” 
    • Impacted case types per the Policy Memo include: “Form I-485 (Application to Register Permanent Residence or Adjust Status), Form I-90 (Application to Replace Permanent Resident Card (Green Card)), Form N-470 (Application to Preserve Residence for Naturalization Purposes), Form I-751, (Petition to Remove Conditions on Residence), and Form I-131 (Application for Travel Documents, Parole Documents, and Arrival/Departure Records).” 
  • Additional scrutiny for discretionary immigration benefits. On November 27, 2025, USCIS updated its Policy Manual with guidance to consider relevant country-specific facts and circumstances in the adjudication of discretionary benefits. 
    • This guidance applies to discretionary benefit requests that are pending or filed with USCIS on or after November 27, 2025. Discretionary benefits include but are not limited to adjustment of status applications, nonimmigrant extensions of stay, and change of status requests. 
    • Updated sections of the USCIS Policy Manual state that the mere fact that an individual is from one of the travel ban countries is not by itself a significant negative factor. It goes on to specify that adjudicators must consider relevant country-specific facts and circumstances, such as insufficient vetting and screening information that limit USCIS’ ability to assess the risks aliens from certain countries pose to the United States, as a significant negative factor in its discretionary analysis. Consistent with other policy guidance, it also makes clear that USCIS will “consider circumstances where an alien has endorsed, promoted, supported, or otherwise espoused the views of an anti-American or terrorist organization or group, including those who support or promote antisemitic terrorism, antisemitic terrorist organizations, and antisemitic ideologies, to be an overwhelmingly negative factor in any applicable case involving USCIS discretionary analysis.” These factors are to be considered on a case-by-case basis in the totality of the circumstances, considering the relevance of those facts to the benefit request being adjudicated and the individual requesting the benefit. 
  • Pause on final adjudication of all case types. On December 2, 2025, USCIS published an update implementing a pause on final adjudications on all cases and naturalization oath ceremonies for individuals from the travel ban countries, and on all asylum cases, regardless of nationality. The pause is effective immediately and will remain in effect until USCIS issues further guidance on additional vetting of these nationals.  

Additional restrictions for Afghan nationals: 

In an address on November 26th, President Trump called for the “re-examination” of all Afghans who came to the U.S during the Biden Administration. On November 28thUSCIS announced via social media that it has indefinitely halted processing of “all immigration requests” for Afghan nationals pending further review of security and vetting protocols, and the Department of State posted an indefinite halt on the issuance of non-immigrant and immigrant visas for all individuals traveling on Afghan passports. 

Other measures in response to D.C. shooting and other events: 

  • As noted above, the original travel ban imposed in June 2025 was expanded as of December 16th to include 20 more countries subject to a full or partial ban on entry into the United States. See our Travel Ban post for more information on the current travel ban and keep an eye on that page for any updates. 
  • As always, the true impact of these changes will not be known until we see how these policies and other directives are applied in practice. This is a rapidly evolving situation with further updates expected over the coming months. This page will be updated with any new information as it becomes available.  

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