PM-602-0192, Part 1: USCIS Freezes Asylum and High-Risk Country Cases – Structure, Scope, and Process

Series overview
This is Part 1 of a two-part deep dive into USCIS Policy Memorandum PM-602-0192.
Part 1 explains the structure of the memo: who is covered, what is frozen, and how the new adjudication flow works.
Part 2 (separate article) will focus on practical strategy, form-by-form impacts, and long-term risks for applicants.

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1. Background: How We Got PM-602-0192

On December 2, 2025, USCIS issued Policy Memorandum PM-602-0192, titled roughly:

Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries.

The memo is part of a larger national-security response following the November 26, 2025 shooting of two National Guard members in Washington, D.C., carried out by a noncitizen who reportedly entered the U.S. through immigration or humanitarian channels.

In the days after the incident, the Administration rolled out several restrictive measures, including:

• A new travel ban (PP 10949) naming 19 “high-risk” countries, with full or partial entry suspensions.
• A directive to USCIS to tighten national-security vetting and revisit already approved cases from those countries.
• The issuance of PM-602-0192, which is effectively a mass pause and re-review program for asylum and immigration benefits.

Professional associations and practice alerts usually summarize PM-602-0192 in three core bullet points:

1. All pending asylum applications are on hold, regardless of nationality.
2. All pending USCIS benefit applications filed by nationals of the 19 high-risk countries are on hold.
3. All approved benefit requests for people from those countries who entered the U.S. on or after January 20, 2021 are subject to comprehensive re-review.

This is one of the broadest pauses on immigration adjudications in recent memory.

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2. What PM-602-0192 Actually Does

At a structural level, PM-602-0192 orders USCIS officers to do three things immediately:

2.1 Hold all pending asylum applications (Form I-589)

Every Form I-589 pending with USCIS is now frozen “pending comprehensive review”, regardless of the applicant’s country of nationality.

That means:

• No final asylum approvals or denials from USCIS for now.
• Cases can still move in limited ways internally (file transfer, preliminary review), but final decisions are paused until the review phase happens.

2.2 Hold all pending USCIS benefit applications for nationals of 19 high-risk countries

USCIS must also place a hold on all pending benefit applications filed by people whose country of birth or citizenship is on the 19-country list in PP 10949.

This can include, for example:

• Adjustment of Status (Form I-485)
• Green card replacement / renewal (Form I-90)
• Travel documents (Form I-131, including Advance Parole)
• Removal of conditions on residence (Form I-751)
• Preservation of residence for naturalization (Form N-470)
• Other USCIS benefits tied to immigration status or future eligibility

Practice alerts from law firms and universities note these categories specifically as being impacted.

2.3 Re-review approved cases from high-risk countries (post-Jan 20, 2021)

PM-602-0192 does not stop at pending cases. USCIS is also directed to go backwards and re-examine already approved cases if:

• The applicant is from one of the 19 high-risk countries; and
• The person entered the U.S. on or after January 20, 2021; and
• A USCIS benefit (for example, asylum, green card, travel document, or certain discretionary benefit) was approved.

Commentary from immigration analysts and law firms explains that these previously approved benefits may be:

• Re-screened under new security criteria.
• Referred for additional interviews.
• In serious cases, potentially revoked or challenged.

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3. The 19 High-Risk Countries

PM-602-0192 uses the same “high-risk” list defined earlier in PP 10949. Public reporting and summaries indicate that the 19 countries are split between full restrictions and partial restrictions under the travel ban.

For purposes of PM-602-0192, the key point is not which restriction level applies under the travel ban, but whether the applicant’s nationality or country of birth appears on that list. If yes, their USCIS benefit request is now on hold or subject to re-review.

🔍 Practical note for applicants
If your passport, birth certificate, or previous applications show you were born in or are a citizen of one of the PP 10949 countries, USCIS will likely treat you as “from a high-risk country” for purposes of this policy.

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4. Who Is Covered – Three Concentric Circles

One useful way to understand PM-602-0192 is to imagine three concentric circles of people affected.

We can’t draw perfect circles in plain text, but we can think of them from the “innermost” group to the “outermost” group like this:

[ Circle 1 ]
All pending asylum cases
(all nationalities)

[ Circle 2 ]
Pending USCIS benefits from
19 high-risk countries

[ Circle 3 ]
Previously approved benefits from
19 high-risk countries (post-1/20/21)

Circle 1: All asylum applicants (any nationality)

• Everyone with a pending Form I-589 before USCIS.
• Country of origin does not matter for this part – the pause is universal.

Circle 2: Benefit applicants from the 19 high-risk countries

• Anyone with a pending USCIS benefit (not just asylum) who is from a high-risk country.
• This includes many forms: I-485, I-90, I-131, I-751, N-470, and others, depending on the facts.

Circle 3: Previously approved beneficiaries from the 19 high-risk countries

• People from the listed countries who:
  • Entered the U.S. on or after January 20, 2021, and
  • Have already had a benefit approved (for example, asylum, adjustment, certain travel documents).
• These cases are now in a pool for comprehensive re-review.

If you are:

• In Circle 1 only → your asylum application is frozen, but other benefits may move if you are not from a high-risk country.
• In Circle 1 + 2 → both your asylum and your other benefits are frozen.
• In Circle 2 + 3 → your pending benefits are on hold, and old approvals may be re-reviewed.

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5. How the New Adjudication Flow Works

At a high level, PM-602-0192 inserts a “national security hold” into the normal USCIS adjudication pipeline.

5.1 Pre-memo (old world)

Before PM-602-0192, the typical simplified flow for a USCIS case looked like this:

┌──────────────────────────────┐
│ Application Filed            │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Receipt & Initial Review     │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Biometrics & Background      │
│ Checks                       │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Interview / RFEs (if needed) │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Final Decision               │
│ (Approval / Denial / Hold)   │
└──────────────────────────────┘

There were already security checks, but the default expectation was that the case would keep moving toward a decision.

5.2 Post-memo (new world under PM-602-0192)

Now, for asylum and high-risk country cases, the flow includes an extra structural step:

┌──────────────────────────────┐
│ Application Filed            │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Receipt & Initial Review     │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Country / Category Check     │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Does PM-602-0192 apply?      │
└───────────────┬──────────────┘
                │ Yes
                ↓
┌──────────────────────────────┐
│ NATIONAL SECURITY HOLD       │
│ (pending comprehensive       │
│ review and re-screening)     │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Enhanced Vetting / Re-review │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Final Decision               │
└──────────────────────────────┘

In practical terms, this means:

• Cases don’t simply “time out” into a decision; they must pass through this hold + review layer.
• Even if an officer is otherwise ready to approve, PM-602-0192 may block that approval until higher-level security review is completed.

Some practitioner alerts suggest that USCIS expects to organize and prioritize affected cases within about 90 days, but that does not mean decisions will be issued within 90 days – only that the agency will have sorted which cases need what kind of review.

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6. Internal Shifts for USCIS Officers

While the exact internal guidance to officers is in the full memo, practitioner summaries and policy analyses give a good sense of how the day-to-day work inside USCIS changes.

6.1 From “case-by-case” to “country + category + time window”

Under normal conditions, officers primarily look at individual eligibility. Under PM-602-0192, they must also treat cases as part of a larger risk group, defined by:

• Nationality or country of birth (19 high-risk countries),
• Type of benefit (asylum vs other benefits), and
• Time window (entry on or after January 20, 2021, for re-review cases).

6.2 Re-review as a second layer

For previously approved cases, the memo effectively adds a second pass over the file:

┌──────────────────────────────┐
│ Initial Adjudication (Past)  │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Case Approved                │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ PM-602-0192 Trigger          │
└───────────────┬──────────────┘
                ↓
┌──────────────────────────────┐
│ Re-Review Layer              │
└───────────────┬──────────────┘
                ↓
• Confirm approval
• Flag for interview
• Refer for investigation
• Consider revocation (extreme cases)

The memo signals that security concerns can override previous discretionary decisions. That’s a major shift for people who believed their cases were “settled.”

6.3 Emphasis on identity, origin, and security indicators

Based on how similar reviews have operated in the past and on commentary around this memo, the key themes for officers likely include:

• Identity resolution: Is this person who they say they are? Are there conflicting identities in other systems?
• Document reliability: Does the country of origin have weak or compromised civil registries? Are travel or identity documents seen as high-risk?
• Security indicators: Any hits or flags in inter-agency databases or patterns that suggest risk.
• Consistency across filings: Does what the person said in older applications match what they say now?

In other words, PM-602-0192 pushes officers to treat cases as security investigations first, benefit adjudications second.

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7. Who Is Not Covered (At Least Directly)

It’s equally important to understand who is not directly targeted by PM-602-0192:

• U.S. citizens – The memo is about noncitizen benefit requests. U.S. citizenship status that is already acquired is not what the memo targets.
• Non-asylum applicants from non-high-risk countries – For example, a family-based I-485 for a national of a country not listed in PP 10949 should not be pulled into the hold just because PM-602-0192 exists.
• Consular processing alone – PM-602-0192 governs USCIS-handled benefits. It does not itself change what consular officers abroad do (though the broader policy environment does affect them through separate cables and guidance).

That said, the political and policy climate created by PM-602-0192 and the related travel ban will often spill over into:

• Consular officer attitudes,
• CBP inspection practices at ports of entry,
• and future policy memos.

So even people technically outside the three circles may feel secondary effects in the long run.

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8. Big Picture: Why This Matters Before We Even Talk Strategy

From a structural perspective, PM-602-0192 does three big things:

1. Freezes movement for huge categories of cases (all asylum + 19-country universe).
2. Turns time backwards by re-opening the past (re-review of approvals since January 20, 2021).
3. Reframes immigration benefits as security risks first, benefits second.

For applicants, attorneys, and advocates, understanding this architecture is the necessary first step before discussing strategy, litigation options, or long-term planning.

• If you have a pending asylum case, Plan A ("just wait for interview and decision") is no longer realistic.
• If you are from one of the 19 high-risk countries, you must think in terms of multi-year uncertainty, even if your case was already approved.
• If you work with affected communities, you need to explain that this is not a normal processing delay – it is a policy-driven hold and re-review.

In Part 2 of this series, we’ll drill into:

• How PM-602-0192 interacts with specific forms (I-589, I-485, I-131, I-751, N-400, etc.).
• How applicants can prepare documentation and manage risk.
• What to expect in terms of processing times, RFEs, and interviews.
• What this may mean for long-term status stability, travel, and naturalization.

For now, Part 1 gives you the map: who is covered, how USCIS has re-wired its process, and why your case may feel like it has suddenly hit a wall.