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Over the past several weeks, I’ve seen many clients and colleagues grapple with the practical impact of the USCIS policy memo that took effect on January 1, 2026 , directing adjudicative holds on certain immigration benefit applications . These developments have created real uncertainty on the ground, especially for clients from countries designated as “high-risk” under the relevant Presidential Proclamations. What the Policy Actually Does USCIS’s Policy Memorandum PM-602-01