The immigration landscape in 2026 has shifted dramatically with the implementation of new national security protocols. On January 1, 2026, U.S. Citizenship and Immigration Services (USCIS) issued a critical policy memorandum (PM-602-0194) that directly impacts thousands of applicants.
If you or someone you know are from a designated “high-risk” country, your pending applications may have suddenly come to a standstill. At Gillman Immigration Law, we are working around the clock to help families and businesses navigate these unprecedented delays.
The 2026 high-risk list: Which countries are affected?
The current list of high-risk countries has expanded significantly, now encompassing 39 nations subject to strict adjudication holds and enhanced vetting. This list includes countries from the original 2025 designations—such as Afghanistan, Venezuela, Iran, and Haiti—as well as 20 new additions effective this year, including Nigeria, Senegal, Mali, and Syria. Individuals born in these countries or holding their citizenship are subject to these rules, regardless of how long they have lived in the United States.
This policy also applies to individuals traveling with documents issued by the Palestinian Authority. It is important to understand that this is not an automatic denial of your case, but rather a mandatory “pause” while the government conducts a comprehensive security re-review. If your country is on this list, your I-485 (Adjustment of Status), I-765 (Work Permit), or I-539 (Change of Status) application is likely sitting in a specialized vetting queue.
What a USCIS “hold” means for your pending case
A USCIS “hold” means that an immigration officer is prohibited from issuing a final decision on your benefit request until a multi-agency security screening is completed. In 2026, this process includes checks against the Terrorist Screening Dataset (TSDS) and a deeper dive into the reliability of your identity documents. Even if you have already completed your biometrics or had a successful interview, the “hold” prevents the final approval from being printed.
Furthermore, the 2026 memorandum mandates a re-review of previously approved benefits. If you received an approval on or after January 20, 2021, USCIS may reopen your case for a “thorough re-interview” to ensure no national security threats were missed. This has created a wave of uncertainty for those who thought their immigration journey was over. Knowing the specific exceptions to this hold is vital—for instance, Green Card replacements (I-90) and certain naturalization cases (N-400) may still move forward under specific conditions.
Is your case stuck in a high-risk hold? Contact Gillman Immigration Law to protect your rights and explore your legal options.
Strategic steps to manage delays and protect your status
For those waiting for the 2026 processed applications that have been affected by this hold, the best strategy is usually not to sit back and wait. Applicants should be ready for an influx of RFE especially related to financial records and social media accounts as well. The government’s increased scrutiny of the “public charge” test and digital footprints of applicants is something that will continue through 2026, so it is important to have complete documentation to ensure timely approval when the hold is lifted.
For all applicants from high-risk countries, we also recommend avoiding international travel – even for individuals holding valid Advance Parole documentation. Applicants returning during the time period the adjudication hold is in place could be stranded in their country of origin and may not be able to return to the United States. Gillman Immigration Law specializes in the filing of writs of mandamus and other administrative challenges to protect against unreasonable delays.
You might be interested in: Why Consulting an Attorney is Your Best Immigration Strategy
Why you need Gillman Immigration Law in this new era
Navigating the 2026 high-risk designations requires more than just filling out forms; it requires a sophisticated defense of your identity and your background. The government’s “security-first” framework means that any small discrepancy in your past can be magnified into a national security concern. You need a legal team that stays ahead of the latest policy memos and knows how to communicate effectively with the new USCIS Vetting Centers.
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