Trump Administration Restrictions on Legal Immigration Reach Unprecedented Scale
Initially presented as a simple review of certain green cards, an internal directive from U.S. Citizenship and Immigration Services (USCIS) now targets a broad range of immigration benefits, directly affecting employers and foreign workers from 19 countries deemed “high-risk.”
In addition to green cards and citizenship applications, the government now includes work permit applications.
A Freeze Far Broader Than Expected
In its internal memo referenced PM-602-0192, USCIS had indicated it would temporarily suspend review of five types of forms, primarily related to permanent residence and legal resident status. These notably included forms I-485 (adjustment of status), I-90 (green card replacement), and I-131 (travel documents).
But the agency has since clarified, through internal communications and operational practices, that this list was not exhaustive.
The freeze now extends to benefits essential for legal employment in the United States, including:
- Temporary work visa applications, including H-1B (Form I-129);
- Immigration status changes or extensions (Form I-539);
- Petitions for immigrant workers (Form I-140);
- Work authorizations, known as EADs (Form I-765).
This extension marks a major turning point in current immigration policy, affecting not only permanent residence candidates but also temporary workers and their employers.
According to information published by The National Law Review, based on analysis by law firm Jackson Lewis P.C., the federal agency has confirmed that the freeze announced on December 2, 2024, far exceeds the scope initially communicated.
In practice, nationals of the 19 targeted countries may now see their cases placed on indefinite hold, even when they meet all legal requirements. More concerning still, USCIS has been instructed to reexamine benefits already granted to individuals who entered the United States on or before January 20, 2021.
Each case undergoes a thorough individualized review, with no specific timeline or guarantee of expedited processing. This approach creates legal uncertainty for workers who are otherwise in compliance, including some who hold key positions in the technology, healthcare, engineering, or higher education sectors.
Growing Concerns Among Employers
For American businesses, the consequences are immediate. The freeze on EAD renewals can lead to work interruptions, while delays in H-1B visas risk compromising the hiring or retention of foreign talent.
Immigration law firms now recommend that employers anticipate delays, assess risks of work authorization lapses, and implement contingency plans. Some companies may be forced to suspend contracts or revise their international recruitment strategies.
No End Date Announced
At this stage, USCIS has provided no indication of the duration of these suspensions or the specific criteria for resuming normal processing. This lack of visibility fuels concerns among affected workers and among economic organizations that rely heavily on skilled foreign labor.
For observers, this measure is part of a broader strategy to tighten legal immigration, with a marked emphasis on security screening and the reconsideration of benefits already granted.
As the United States faces labor shortages in several strategic sectors, the expansion of this immigration freeze could have lasting economic repercussions. Pending official clarifications, workers and employers remain subject to administrative decisions that have far-reaching impacts beyond the bureaucratic sphere.
