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USCIS expands adjudication hold and retroactive benefit review
On 1 January 2026, U.S. Citizenship and Immigration Services (USCIS) issued a Policy Memorandum directing its personnel to immediately place a hold on all pending benefit applications for foreign nationals from countries listed in Presidential Proclamation (PP) 10998 (Restricting and Limiting of Foreign Nationals to Protect the Security of the United States) regardless of their date of entry to the United States. This action expands the scope of previous restrictions and introduces additional “high-risk countries” subject to comprehensive review. The memorandum also requires a thorough re-review of approved benefit requests for affected individuals that were approved on or after 20 January 2021.
A Tax Alert prepared by EY's People Advisory Services, and attached below, provides additional details.