
U.S. Citizenship and Immigration Services (USCIS) has released policy guidance directing officers to treat an applicant’s nationality from any of the countries listed in Presidential Proclamation 10949 as a “significant negative factor” in discretionary immigration decisions. The update, effective for all filings pending or submitted on or after November 27, 2025, applies to adjustment-of-status, change-of-status, extension, waiver and employment-authorization requests that depend on officer discretion.
The proclamation targets nations that the U.S. deems non-compliant with information-sharing or presenting security risks. While USCIS stops short of mandating denials, applicants from affected countries can expect additional evidence requests, lengthier adjudications and higher scrutiny during interviews. The policy also applies to dual nationals who subsequently acquire citizenship in a listed country.
For employers, the change raises the bar for sponsoring talent from Afghanistan, Iran, Libya, Somalia, Sudan, Yemen and a dozen other states. Human-resources teams should budget extra lead time, brace for more Requests for Evidence and prepare robust documentation regarding project necessity and security vetting. Assignments involving travel abroad while a case is pending now carry heightened re-entry risks.
Individual applicants should consult counsel before filing or international travel. Stronger proof of qualifications, ties and compliance history will be essential to overcome the negative presumption. Mobility managers should update internal policies to flag employees whose cases fall under the new guidance and prioritize alternative immigration strategies where feasible.
The proclamation targets nations that the U.S. deems non-compliant with information-sharing or presenting security risks. While USCIS stops short of mandating denials, applicants from affected countries can expect additional evidence requests, lengthier adjudications and higher scrutiny during interviews. The policy also applies to dual nationals who subsequently acquire citizenship in a listed country.
For employers, the change raises the bar for sponsoring talent from Afghanistan, Iran, Libya, Somalia, Sudan, Yemen and a dozen other states. Human-resources teams should budget extra lead time, brace for more Requests for Evidence and prepare robust documentation regarding project necessity and security vetting. Assignments involving travel abroad while a case is pending now carry heightened re-entry risks.
Individual applicants should consult counsel before filing or international travel. Stronger proof of qualifications, ties and compliance history will be essential to overcome the negative presumption. Mobility managers should update internal policies to flag employees whose cases fall under the new guidance and prioritize alternative immigration strategies where feasible.









