Labor & Employment Law Daily Wrap Up, EXPERT INSIGHTS—Feds halt immigration applications from 19 countries and signal broader freeze: What employers need to know, (Dec 4, 2025)

By Jocelyn Campanaro, David S. Jones, and Shanon R. Stevenson of Fisher Phillips, LLP

Now is the time to make sure your immigration compliance efforts are spotless.

The Trump administration just announced yesterday it has paused all immigration applications from individuals born in or holding citizenship from 19 countries previously covered by partial or total travel restrictions, triggering a significant operational and compliance event for employers. USCIS has also ordered a comprehensive re-review of previously approved cases tied to these nationalities, and reports indicate the administration is preparing to expand the travel-ban list to roughly 30 countries. Employers have questions about workforce stability, hiring pipelines, and compliance risk management, and this Insight will provide answers—and a five-step game plan for what your organization should do now.

What Does the Pause Do?

DHS and USCIS confirmed a complete pause on immigration benefits for those from 19 countries. This will impact all immigration applications, including:

• Green card applications

• Employment authorizations

• H-1B and other temporary work visas

• Adjustments of status

• Naturalization work

• Waivers

• Asylum and humanitarian benefits

Which Countries are Impacted?

The list of countries impacted by this pause:

Afghanistan, Myanmar (Burma), Chad, Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela.

Who is Covered?

This move applies to all foreign nationals born in these countries or holding citizenship, regardless of their current residence, length of time in the US, or employment history.

What About Cases Already Approved?

USCIS also announced it will now reassess all immigration approvals granted to nationals of these countries who entered the U.S. on or after January 20, 2021. The announcement authorizes:

• New or repeat interviews

• Broad review under any INA “inadmissibility” clause

• Potential reopening of closed cases

Will This List Be Expanded?

DHS has recommended expanding the travel-ban list significantly, perhaps adding 10 to13 more countries. The list has not yet been released, but officials indicate it will be broad and security-driven.

Have Other Vetting Operations Changed?

The administration has also announced a wider vetting operation to include:

• Social media screening

• Cross-checking biometrics with foreign governments

• Criminal history screening through origin-country databases

• Mandatory annual check-ins with DHS for certain applicants

What Can Employers Expect?

This action will result in a cascading series of events that will hit the workplace community immediately:

Immediate status volatility for existing foreign-national employees

Employees from the 19 countries may suddenly be unable to extend or renew status, travel abroad, complete long-planned green card steps, or obtain EAD renewals on normal timelines—even if they have lived in the US for years.

Potentially sudden loss of work authorization

If pending applications are frozen mid-stream (e.g., H-1B extensions, L-1 renewals, EAD extensions), employers could face unexpected work stoppages, gaps in staffing, and an inability to deploy employees for international projects.

Hiring pipelines will stall or collapse

Recruiting from affected regions will be nearly impossible until the freeze is lifted. If you have made employment offers to impacted workers, you may need to rescind or defer them indefinitely.

Increased I-9, compliance, and audit risk

With enhanced scrutiny and increased data sharing between agencies, you can expect more I-9 audits, reverification questions, Requests for Evidence (RFEs), Notices of Intent to Deny (NOIDs), and “expedited denials” for incomplete documentation.

Potential multi-year delays across the entire system

Even applicants from unaffected countries could feel the impact as USCIS reassigns staff to re-review cases and conduct new interviews. Processing times, which already are hitting two to three years in some cases, could lengthen.

What Should Employers Do?

It seems inevitable that opponents will file lawsuits challenging the policy, arguing that targeting individuals based on place of birth raises constitutional concerns. We could even see lower court judges temporarily block the move as litigation winds its way through the process. However, employers cannot and should not bank on these policies being tossed out by courts, and should instead take immediate steps to adjust to this new system.

Your 5-Step Game Plan

1. Identify impacted employees (carefully and discreetly)

Work with immigration counsel to run a list of employees born in or citizens of the 19 affected countries, and then assess their status, expiration dates, and pending petitions. If possible, prioritize urgent filings related to these workers, as some may still be accepted even if processing is paused. Make sure to only use this list to assist your compliance efforts and do not use it to make other nationality-based employment actions—which could be considered discriminatory under federal and state law.

2. Freeze all non-essential international travel

Advise impacted employees that departing the US could prevent re-entry and they should act accordingly. As soon as possible, issue company-wide travel guidance and suspend any international travel for these workers. Take into consideration that consular appointments abroad may be indefinitely suspended, and that advance parole or visa stamps will be difficult to obtain.

3. Strengthen I-9 compliance and re-verification processes

Now is the time to make sure your immigration compliance efforts are spotless. Work with your FP immigration counsel to clean up I-9 records, conduct privileged internal audits, train your HR staff and managers on best practices, and document reverification steps. Most importantly, prepare for increased enforcement activity by reading FP’s Playbook For ICE Audits And Workplace Raids.

4. Prepare staffing contingencies

Develop contingencies for employees who may suddenly lose work authorization and other unplanned absences or departures. Remember that you will most likely experience stalled hiring from these countries and potential for interrupted mobility assignments.

5. Adjust recruiting and mobility strategies for 2026

To the extent that you have international workforce hiring as one of your action items for the new year, you may want to readjust your plans as necessary. At a minimum, consult with your FP immigration counsel before making offers to candidates from affected regions. You may also need to increase your domestic recruitment efforts and reconsider roles that assumed international transfers.

Conclusion

For support, please contact your Fisher Phillips attorney, the authors of this Insight, or any member of our Immigration Practice Team. Make sure you are subscribed to Fisher Phillips’ Insight System to receive the most up-to-date information directly to your inbox.

Jocelyn Campanaro, David S. Jones, and Shanon R. Stevenson

Fisher Phillips, LLP

URL: https://www.fisherphillips.com/

Attorneys: (Fisher Phillips).

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