Practice Alert: USCIS to Review Approvals and Immediately Pause LPR Applications for Refugees Admitted 1/21/21-2/20/25

On November 21, 2025, USCIS Director Joe Edlow issued an internal memo¹ ordering USCIS personnel to review and potentially re-interview all refugee approvals from January 21, 2021, to February 20, 2025—approximately 200,000 cases. This memo also orders USCIS to stop adjudicating any applications to adjust status filed by refugees, their derivatives, and follow-to-join refugees admitted during this timeframe.

This is a significant and unprecedented large-scale effort to review the cases of people whom the U.S. government has already resettled in the United States after an extensive and thorough adjudication and review process involving refugee experts with the U.N. High Commissioner for Refugees, the International Organization for Migration, the State Department, and Department of Homeland Security officials, among others. The memo relies upon Executive Order 14163, Realigning the United States Refugee Admissions Program (USRAP) which suspended the USRAP under Immigration and Nationality Act §§ 212(f) and 215(a), 8 U.S.C. 1182(f) and 1185(a). The memo cites the desire to “only admit refugees who can fully and appropriately assimilate into the United States.”

What we know at this time:

• USCIS has 90 days to compile a list of cases to prioritize for re-interview and will work with its Office of Policy and Strategy (OP&S) to issue guidance. However, the memo also states that USCIS has determined that a "comprehensive review and a re-interview of all refugees" admitted during the above timeframe is warranted.
• USCIS intends to review all grants of refugee status during this timeframe to scrutinize whether USCIS made legally sufficient decisions on the I-590 refugee applications and whether refugees and their derivatives met the definition of a refugee as described in INA § 101(a)(42) at the time they were admitted to the United States.
• USCIS will be looking at all eligibility criteria and possible grounds of inadmissibility under INA § 212, including examining INA § 207.3 waivers to confirm those deemed inadmissible under INA § 212(a) had an appropriate waiver. The memo specifically emphasizes the persecutor bar.
• The memo directs USCIS to terminate refugee grants as provided in INA § 207.9 if reviewers find they were not eligible at the time of admission to the U.S.
• USCIS is placing an adjudicative hold on all pending I-485s filed by refugees during the above timeframe, until the USCIS Director lifts it in a subsequent memo. However, if a refugee's status is terminated, then the I-485 may be denied.
• Any requests to lift the hold for either litigation reasons or other extreme circumstances must be approved by the USCIS Director or Deputy Director in coordination with OP&S.
• The memo states that refugees who have already adjusted status to lawful permanent residency will also be subject to review.

AILA will continue to monitor and provide updates when available.

¹ Although the guidance has not been published by USCIS, AILA has had an opportunity to review the guidance and provides this practice alert based on our review of that document.