USCIS Places “Hold” on Processing of Benefit Applications From or On Behalf of Foreign Nationals from 39 “High Risk” Countries, for Increased Vetting

On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a policy memorandum relating to vetting of benefit applications* filed by, or on behalf of, foreign nationals born in or citizens of, 39 designated “high-risk” countries, and holders of travel documents issued by the Palestinian Authority, effective immediately. This new policy memorandum updates and expands upon the policy memorandum issued by USCIS on December 2, 2025.

USCIS confirmed that it is:

Placing a “hold” on all applications currently pending or filed in future by or on behalf of foreign nationals who were born in, or are citizens of, the 39 countries subject to travel restrictions (travel ban) under Presidential Proclamation 10998 (December 16, 2025) pending a comprehensive review, regardless of their date of entry into the U.S.; and

Conducting a comprehensive re-review of approved applications filed by or on behalf of foreign nationals from countries listed in Presidential Proclamation 10998 that were approved on or after January 20, 2021.

*The phrase “benefit applications” refers to a broad set of requests such as applications for employment authorization, change of status, employment visa petitions, green card applications, and more.

We anticipate that this policy will result in processing delays for students and scholars from these countries. Therefore, we advise international students and scholars (and their family members) to submit applications to USCIS as far in advance as permitted.

Please see the “Frequently Asked Questions” (FAQ) below for more detail. MIT continues to monitor immigration developments and will to post any new information on the Major Immigration Alerts and Updates webpage.

We understand the concerns and uncertainty that these changes in U.S. immigration policy create as you pursue your academic and research goals at MIT. Please know that the MIT leadership, faculty, and staff are here to support you, and we encourage you to reach out to us if we can be of any assistance.

Frequently Asked Questions (FAQ)

Which countries does this policy impact?

The 39 “high-risk” countries currently designated by the Proclamation are Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma (Myanmar), Burundi, Chad, Republic of the Congo, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, The Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe. The Proclamation also applies to individuals holding travel documents issued by the Palestinian Authority.

How will the policy impact international students and scholars from those countries?

This new policy will likely result in processing delays for international students and scholars (researchers, faculty, instructional staff, visitors and postdocs) and their family members, from these designated countries (or who have travel documents issued by the Palestinian Authority) who file, or have filed, applications for benefits with USCIS. These application types include:

Form I-765 employment authorization (ex. F-1 Optional Practical Training/OPT, F-1 STEM OPT Extension, J-2 work permission)
Form I-539 Change of Status (ex. to F-1 or to J-1)
Form I-129 Employment Visa Petitions (ex. H-1B, O-1, etc.),
Adjustment of Status (Green Card), asylum petitions
Other applications.

After an application is filed, applicants may receive from USCIS a Request for Additional Evidence (RFE) if USCIS needs more information to process an application, which is not uncommon. If you receive an RFE, please contact an ISO Advisor or ISchO Advisor.

When does this new policy go into effect? When might it be lifted?

The hold on USCIS application processing under this memorandum, as well as the comprehensive re-review of approved benefit requests and review of policies, procedures, and screening and vetting processes for benefit requests, are effective January 1, 2026. The hold will be “in effect until lifted or modified by the USCIS Director through a subsequent memorandum or memorandum attachment.” We do not know how long that could be.

What else does the policy memo say?

USCIS will also:

Conduct a comprehensive re-review of approved applications filed by or on behalf of foreign nationals from countries listed in Presidential Proclamation 10998 that were approved on or after January 20, 2021.

Conduct a review of all policies, procedures, and screening and vetting processes for benefit applications filed by or on behalf of foreign nationals from countries listed in Presidential Proclamation 10998.

What should impacted students and scholars do, given this policy change?

We advise international students and scholars (and their family members) to submit applications to USCIS as far in advance as permitted.

If any questions arise, please be sure to contact your advisor at the International Students Office (ISO) or the International Scholars Office (ISchO).

MIT continues to monitor immigration developments and will post any new information on the Major Immigration Alerts and Updates webpage.