The U.S. Citizenship and Immigration Services (USCIS) August 2025 policy memorandum on naturalization applications demonstrates the agency’s heightened scrutiny in conferring citizenship and raises questions on how newly empowered officers will conduct their review.
Citizenship is the final step in what can be a long and complicated journey for foreign nationals seeking immigration benefits. After a period of years of holding lawful permanent residence, the length of which depends on the basis and terms of their green cards, they become eligible to apply for citizenship.
As statutorily required, USCIS has always assessed an applicant’s “good moral character” in adjudicating citizenship requests. That assessment has generally involved a review of whether an applicant has committed certain crimes, including “aggravated felonies,” and disqualifying misconduct. In the absence of such offenses, applicants have generally been judged to possess “good moral character.”
The August 2025 policy memorandum changes that approach. USCIS’s evaluation now will involve “more than a cursory mechanical review focused on the absence of wrongdoing.” Rather, it will make a “holistic assessment of an alien’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.” In other words, citizenship applicants will not be considered to possess “good moral character” simply by pointing to a clean criminal record. They must “demonstrate[e] how their life aligns with a pattern of behavior that is consistent with the current ethical standards and expectations of the community in which they reside.”
Among the positive factors USCIS will assess are “community involvement, family caregiving, educational attainment, stable and lawful employment history, length of lawful residency in the U.S. and compliance with tax obligations and financial responsibility.”
Conversely, if applicants have committed or engaged in “controlled substance violations, multiple DUI convictions, false claims to citizenship, unlawful voting, or ‘any other acts that are contrary to the average behavior of citizens in the jurisdiction where aliens reside,’” they may be disqualified.
This new, increasingly subjective approach and lower standard for disqualification have raised questions and concerns as to how USCIS will assess “good moral character” and adjudicate naturalization applications. It is possible that inconsistent and unpredictable adjudications may result from this updated approach.
Jackson Lewis attorneys are closely monitoring USCIS policy and trends and will continue to provide updates. If you have any specific questions regarding these developments, please reach out to a Jackson Lewis immigration attorney.