PM-602-0192, Part 2: Deep Dive on Forms, Re-Review, Delays, and Strategy for High-Risk Country Nationals

Recap
In Part 1, we looked at the structure of PM-602-0192: who is covered, what is frozen, and how the new national-security hold fits into the USCIS workflow.
In Part 2, we focus on practical impact and strategy: which forms are affected, what “comprehensive re-review” looks like in real life, and what applicants can do now.

This article is aimed at:

• Nationals of the 19 high-risk countries identified in Presidential Proclamation 10949, and
• Anyone with a pending asylum application (I-589),
• Employers, universities, and families who depend on benefits now placed on hold.

As with Part 1, this is analysis, not legal advice. Individual cases can be very fact-specific.

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1. Forms and Benefits Most Directly Affected

The policy memo itself is short. The real complexity comes from how it intersects with dozens of USCIS forms and processes. Practice alerts from universities, law firms, and bar associations all highlight the same core categories.

Below is a practical breakdown.

1.1 Asylum and Withholding (Form I-589)

• Status: All pending I-589s filed with USCIS are under an adjudicative hold.
• Who: All nationalities, not only high-risk countries.
• What it means in practice:
  • No new asylum approvals from USCIS for the time being.
  • Cases can still be pre-screened, transferred, or queued, but no final grants.

Knock-on effects:

• Work authorization based on pending asylum (category C08) may still be processed because the memo’s “benefit requests” carve out certain screening functions, but serious delays are likely if local offices hesitate or routing changes.
• Asylum interviews may be rescheduled, reprioritized, or postponed depending on how each asylum office interprets the hold.

1.2 Adjustment of Status (Form I-485)

For nationals of the 19 high-risk countries:

• Employment-based I-485s (e.g., EB-1, EB-2, EB-3)
• Family-based I-485s (spouse, parent, child of a U.S. citizen or LPR)
• Humanitarian or special categories that adjust in the U.S.

are all potentially frozen at the final decision stage.

Typical patterns we expect to see:

• I-485s moving through biometrics and even interviews, but no approvals issued.
• Requests for Evidence (RFEs) focusing on identity, travel history, and security-related issues.
• Some cases transferred to specialized units for “further review.”

1.3 Travel Documents (Form I-131)

Form I-131 is used for multiple purposes:

• Advance Parole for those with pending I-485 or certain humanitarian statuses.
• Refugee Travel Documents for asylees and refugees.
• Re-entry Permits for permanent residents.

Under PM-602-0192, for nationals of high-risk countries:

• I-131s are likely held or slowed while USCIS decides whether it is safe to allow departure and re-entry.
• In some cases, even if an I-131 is technically still processing, airlines and CBP discretion at the border add additional layers of risk.

For asylees and refugees from high-risk countries, travel has always been sensitive. The memo significantly increases that sensitivity.

1.4 Removal of Conditions (Form I-751)

For conditional permanent residents (often spouses of U.S. citizens) from high-risk countries:

• I-751 is the form that removes the 2-year condition and converts to a full 10-year green card.
• If PM-602-0192 causes extended delay, it may:
  • Prolong the period of conditional status,
  • Trigger more in-person interviews,
  • Increase scrutiny of marital bona fides and security indicators.

At the same time, conditional residents generally keep their status while I-751 is pending, which is some protection against immediate loss of rights.

1.5 Naturalization (Form N-400)

PM-602-0192 does not explicitly say “pause all N-400s,” but multiple institutional alerts report:

• Canceled naturalization interviews for applicants from the 19 countries.
• Officers reviewing the entire underlying history of how the person became an LPR before recommending approval.

Practically, that means:

• If your green card was based on a benefit now under re-review (for example, asylum or a prior I-485), your N-400 may stall until the underlying grant is cleared again.
• In extreme cases, underlying status could be questioned, putting naturalization out of reach for some time.

1.6 Other forms that may be indirectly impacted

Even if not named directly in alerts, you should assume higher scrutiny and possible delays for high-risk nationals filing:

• I-539 (extension or change of nonimmigrant status),
• I-824 (follow-to-join or duplicate approval notices),
• Certain humanitarian requests (e.g., parole-in-place, deferred action),
• Requests that rely heavily on officer discretion.

In the new environment, discretionary benefits are more likely to be denied or left pending when there is any unresolved security question.

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2. What “Comprehensive Re-Review” Probably Looks Like

For nationals of the 19 countries who:

• Entered the U.S. on or after January 20, 2021, and
• Have a USCIS-approved benefit (asylum, I-485, I-131, etc.),

PM-602-0192 calls for a “comprehensive re-review.” The memo doesn’t publish its checklist, but we can infer a likely pattern from similar programs.

2.1 Likely steps in a re-review

Step 1 – Targeting
• Identify all cases that match: country + entry date + benefit type.

Step 2 – File reconstruction
• Pull A-files and electronic records.
• Merge data from multiple systems (USCIS, DOS, CBP, etc.).

Step 3 – Identity and document review
• Compare biographic data across all filings.
• Re-check travel history, prior visas, and prior entries.

Step 4 – Security screening
• Run updated vetting across partner databases.
• Look for new derogatory information or patterns.

Step 5 – Case-level action
• Clear and keep approval in place, OR
• Schedule interview / request more evidence, OR
• Refer to Fraud Detection / law enforcement, OR
• Initiate revocation in extreme cases.

Most people will likely fall into the “clear and keep approval” category. But the process itself can take months or years, and there is no official timeline.

2.2 Triggers that may increase risk in re-review

Factors that might draw more attention to a case include:

• Inconsistent identity information between older and newer forms.
• Travel to third countries with security concerns.
• Social media or public activity that officers interpret as risk (fairly or unfairly).
• Criminal history (even minor, in some cases).

Because the criteria are broad and partly discretionary, the safest assumption is that any ambiguity in your record is now more dangerous than before.

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3. A Practical Flow: You Have a Pending Case From a High-Risk Country

Here is a simplified decision flow for someone from a high-risk country with one or more pending USCIS applications.

Start
  ↓
Do you have a pending I-589 (asylum)?
  ↓
 Yes ───────────────────────────────┐
  ↓                                │
Asylum case is on hold             │
(pending comprehensive review)     │
                                   │
No / In addition ──────────────────┘
  ↓
Do you have other pending USCIS benefits
(I-485, I-131, I-751, N-400, etc.)?
  ↓
 Yes
  ↓
Are you from one of the 19 high-risk countries
(by birth or citizenship)?
  ↓
 Yes
  ↓
Other benefits placed on hold or slowed
pending security review
  ↓
Potential outcomes:
• Extended delay with no decision
• RFE focusing on identity/security
• Interview with more security questions
• In extreme cases, adverse action

No (not from a high-risk country)
  ↓
Other benefits may continue normally,
but background checks and timelines
may still be affected by wider policy.

This is not an official flowchart; it is a way to visualize how multiple layers of the policy might interact for a single person.

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4. Timelines and Expectations: How Long Will This Last?

Right now, there are no clear end dates.

• The memo instructs USCIS to organize and prioritize cases, not to finish them by a specific time.
• Early commentary from practitioners is consistent: applicants should prepare for significant, open-ended delays.

Practically, that means:

• Many asylum and high-risk country cases could sit for months or longer without movement.
• Naturalization and green card approvals for affected individuals may be slowed even if the law technically allows them now.
• Even if lawsuits are filed, litigation takes time, and outcomes are uncertain.

From a planning standpoint, the safest mindset is:

“I am in a long, policy-driven queue, not a normal processing line.”

That mindset helps you avoid making risky assumptions (like planning international travel or quitting a job) based on pre-memo timelines.

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5. Strategy for Applicants and Families

Every case is different, but there are some recurring strategies that make sense for many people affected by PM-602-0192.

5.1 Clean up your history and documentation

Because identity and background inconsistencies are especially risky now, it’s smart to:

• Collect all past filings (asylum, visas, DS-160s, DS-260s, prior I-130s, etc.).
• Check for inconsistencies in:
  • Dates of birth and spelling of names,
  • Place of birth and prior residence history,
  • Employment and education timelines.
• Correct errors where possible in upcoming filings, and be ready to explain past mistakes.

Having a clean, consistent story across all documents is more important than ever.

5.2 Consider a records request

Many attorneys will recommend that high-risk country nationals:

• File FOIA or records requests with USCIS, CBP, or DOS when appropriate.

The goal is to:

• Understand what the government already has on file,
• Catch surprises (like old notes or mis-entered data) before they show up in an interview.

5.3 Plan travel very cautiously

If you are from a high-risk country and:

• You are applying for or have asylum, or
• You have a pending I-485 or similar benefit,

then you should treat all international travel as high-risk until you have:

• Advice from an experienced immigration lawyer,
• A clear understanding of your re-entry documents and the policy environment at ports of entry.

Even with an Advance Parole document, current policy may lead to:

• Delays and secondary inspection at the airport,
• Questions about re-admission,
• In worst cases, refusal of entry.

5.4 Maintain a backup status if possible

For some people (especially students and workers), it may be possible to:

• Keep or extend a nonimmigrant status (like F-1, J-1, H-1B, etc.) while a long-term benefit is pending.

This keeps you from being entirely dependent on a case that is frozen under PM-602-0192.

Of course, this is not always possible, and it often requires careful coordination:

• With your employer or university,
• With your attorney,
• With the timing of filings.

5.5 Employers and universities: be proactive with planning

If you are an employer or school with affected employees or students:

• Audit who is from the 19 countries and what benefits they have pending.
• Scenario-plan around:
  • EAD renewals being delayed,
  • I-485s stuck for long periods,
  • Possible travel complications.
• Communicate carefully so you support affected individuals without giving legal advice.

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6. Strategy for Naturalization-Eligible LPRs

If you are a permanent resident from a high-risk country and are thinking about filing Form N-400:

• Understand that your file may be pulled into re-review of the underlying basis of your green card.
• This is especially true if:
  • Your green card came from asylum or refugee status, or
  • It was approved after January 20, 2021 under a category with broad discretion.

A few practical tips:

• Do not rush into filing N-400 without understanding your old record.
• If you have any unresolved criminal or security-related issues, get legal advice before filing.
• If you already filed N-400, be prepared for:
  • Interview questions that dig into your past filings, and
  • Possible delays while background checks are repeated.

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7. Community-Level Response: Advocacy, Lawsuits, and Mental Health

PM-602-0192 is already being criticized as a form of collective punishment and nationality-based discrimination. Advocacy groups and some lawmakers have signaled that court challenges are likely.

From an individual planning perspective, it helps to:

• Follow reputable immigration law organizations for updates.
• Understand that court victories, if they come, take time.
• Avoid basing urgent life decisions on “maybe the policy will be struck down next month.”

7.1 Emotional impact

For many people, the hardest part of PM-602-0192 is psychological:

• Uncertainty about safety,
• Fear of re-review of long-settled cases,
• Anxiety about family separation and travel.

A few realistic steps that can help:

• Build a case file: keep copies of everything in one place. Feeling prepared reduces some anxiety.
• Develop a communication plan with family: who you will call if you are detained, who has your documents, and so on.
• Connect with trusted community organizations rather than random social media rumors.

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8. Final Thoughts: Living Under a Policy-Driven Freeze

Taken together, PM-602-0192 and the related national-security measures create a new reality for many immigrants from the 19 high-risk countries, and for all asylum seekers:

• Asylum applicants: face an indefinite freeze on decisions, even after years of waiting.
• High-risk country nationals with pending benefits: see their cases pulled into an opaque security review system.
• Those with previously approved benefits: live with the possibility that their past approvals will be revisited.

In this environment, smart strategy is about control over what you can influence:

• Your documents (consistent, complete, ready).
• Your status planning (backup options where possible).
• Your travel choices (only when truly necessary, and with counsel).
• Your information sources (credible legal and policy updates, not rumors).

Part 1 gave you the architecture of PM-602-0192. Part 2 has focused on forms, timelines, and strategy.

As the situation evolves, there will likely be:

• More detailed USCIS guidance,
• Litigation and potential injunctions,
• And possibly further changes to the list of high-risk countries or the scope of affected benefits.

For now, understanding the landscape – and planning around long delays and intensive re-review – is the most realistic way to navigate this moment.