Important Updates
Important Updates
September 8, 2025 | EcuadorEcuador: Yellow Fever Vaccination Requirement Update
September 9, 2025 | GabonGabon: New Foreign National Quota Introduced
September 9, 2025 | United Arab Emirates, Saudi ArabiaGulf Business: Why Immigration Due Diligence is as Critical as Financial Scrutiny in the GCC
September 9, 2025 | United StatesUnited States: EB-3 Immigrant Visa Category Unavailable Through September 30 After Reaching Annual Limit for FY 2025
September 8, 2025 | Poland Fragomen Welcomes Partner Karolina Schiffter to Poland Practice, Adds to Poland Presence with New offices in Wrocław and Gdańsk
September 8, 2025 | EcuadorEcuador: Yellow Fever Vaccination Requirement Update
September 9, 2025 | GabonGabon: New Foreign National Quota Introduced
September 9, 2025 | United Arab Emirates, Saudi ArabiaGulf Business: Why Immigration Due Diligence is as Critical as Financial Scrutiny in the GCC
September 9, 2025 | United StatesUnited States: EB-3 Immigrant Visa Category Unavailable Through September 30 After Reaching Annual Limit for FY 2025
September 8, 2025 | Poland Fragomen Welcomes Partner Karolina Schiffter to Poland Practice, Adds to Poland Presence with New offices in Wrocław and Gdańsk
September 8, 2025 | EcuadorEcuador: Yellow Fever Vaccination Requirement Update
Subscribe
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Navigating Immigration Under the Second Trump AdministrationTravel & Mobility Considerations: Situation in the Middle EastImmigration Matters: Your U.S. Compliance RoadmapHumanitarian and Evolving Legal Pathways (HELP)Vietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Navigating Immigration Under the Second Trump Administration
  • Travel & Mobility Considerations: Situation in the Middle East
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Humanitarian and Evolving Legal Pathways (HELP)
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
  • Insights

United States: Naturalization Applicants to Undergo Broader Good Moral Character Review Under New USCIS Guidance

August 20, 2025

insight-news-default

Country / Territory

  • United StatesUnited States

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a glance

  • In a departure from prior practice, USCIS officers will consider whether a naturalization applicant has positive attributes to support the approval of the application, not just the absence of misconduct in their background. 
  • Adjudicators are also being directed to engage in greater scrutiny of each applicant’s background and to assess whether, in the adjudicator’s discretion, an applicant’s conduct, despite being lawful, is “inconsistent with civic responsibility within a community.”
  • The new guidance could be subject to a court challenge.

The issue

Applicants for naturalization will undergo a more searching review of their background, behavior, and activity under a new U.S. Citizenship and Immigration Services (USCIS) policy memorandum on good moral character (GMC) assessments in the naturalization process. It has long been a requirement for U.S. citizenship that an applicant have good moral character, but the new policy memorandum directs USCIS adjudicators to exercise that authority in a more expansive and heightened manner. The new policy is being issued at the same time as stringent new guidelines for scrutiny of applicants for other types of immigration benefits.

Background

U.S. law directs USCIS officers to evaluate a naturalization applicant’s good moral character on a case-by-case basis. USCIS reviews conduct and character within the applicant’s qualifying naturalization statutory period (five years or three years, depending on the basis of naturalization) as well as conduct outside that period. Typically, if the applicant’s history did not contain criminal offenses or other behavior identified as problematic under U.S. immigration law, then the good moral character test was deemed satisfied. In some cases where there was a negative history – for example, failure to pay child support – rectifying the issue and providing evidence that the applicant has changed the problematic behavior has been deemed sufficient.

Traditional bars to a finding of good moral character include permanent bars, such as aggravated felonies and crimes of violence, and conditional bars (those that can be overcome), such as controlled substance violations, two or more convictions for driving under the influence (DUI), false claim to U.S. citizenship, unlawful voter registration, or unlawful voting.

The new good moral character guidelines

The new policy memorandum directs USCIS officers to place greater emphasis on whether a naturalization applicant possesses positive attributes to support approval of the naturalization application. This change suggests that an applicant may be asked to affirmatively assert good moral character factors by demonstrating qualities that USCIS considers to be positive. The memorandum lists some examples of such factors, including but not limited to sustained community involvement and contributions; family caregiving and responsibility; educational attainment and employment history; and length of lawful residence. It is not clear in what manner naturalization applicants would be required to make this showing. It could come in the form of a response to a request for evidence from USCIS, perhaps after a review of the applicant’s social media and online presence.

The policy memorandum includes in its list of disqualifying behaviors actions that, though lawful, may be deemed by the agency to be “inconsistent with civic responsibility within the community.” The guidance cites examples such as “reckless or habitual traffic infractions,” or “harassment or aggressive solicitation.”

Finally, the memorandum directs officers to focus greater attention on ensuring that applicants who have engaged in disqualifying acts are rehabilitated and reformed.

What’s next

The full impact of the new policy will not be clear until USCIS begins to issue decisions informed by the new guidance. It is likely that applicants for naturalization will be subject to a closer review of their personal history, including their social media and online presence, and may be asked to provide additional evidence to the government. Naturalization applicants attending their USCIS interview may find that adjudicators engage in more in-depth questioning and fact-finding regarding their character and behavior. As a result of the enhanced review, applicants could see longer waits for decisions, greater uncertainty and, potentially, higher rates of denial. It is also possible that the new guidelines will be challenged in court.

Fragomen is closely following the implementation of the new policy guidance and will provide updates as trends emerge. Inquiries about naturalization can be directed to the Fragomen attorney with whom you work or submitted through Fragomen’s U.S. Naturalization Contact Form.

This alert is for informational purposes only.

Country / Territory

  • United StatesUnited States

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Costa Rica Investment Residency Explained: Requirements and Options

Immigration Supervisor Michael Salas Guzman discusses Costa Rica investment residency options and requirements for foreign investors, retirees and rentiers.

Learn more

Media mentions

Gulf Business: Why Immigration Due Diligence is as Critical as Financial Scrutiny in the GCC

Managing Partner for the Middle East and Africa Murtaza Khan discusses why immigration due diligence is important in GCC mergers.

Learn more

Fragomen news

Fragomen Welcomes Partner Karolina Schiffter to Poland Practice, Adds to Poland Presence with New offices in Wrocław and Gdańsk

Fragomen announces the opening of new offices in Wrocław and Gdańsk, welcoming Partner Karolina Schiffter to its Poland practice.

Learn more

Blog post

How to Get Luxembourg Citizenship: Requirements, Benefits & Application Process

This blog post by Manager Virginie Todesco and Immigration Consultant Chiara Caredda, available in English and Portuguese, outlines the requirements, benefits and application process for obtaining Luxembourg citizenship.

Learn more

Awards

Fragomen and Regional Partner for the Asia Pacific Mark Buchanan Named 2025 FEM APAC EMMAs Winners

Fragomen and Regional Partner for the Asia Pacific Mark Buchanan were recognized at the 2025 FEM APAC EMMAs.

Learn more

Awards

Partner Archana Iyer Wins "Innovation Award" at The New York Law Journal's 2025 New York Legal Awards

Partner Archana Iyer won the "Innovation Award" at The New York Law Journal's 2025 New York Legal Awards.

Learn more

Media mentions

Times of India: A War on Fraud: USCIS to Train Special Armed Agents with Powers to Arrest Applicants and Lawyers

Senior Counsel Mitch Wexler discusses how USCIS’s new rule could potentially increase enforcement and affect how applicants interact with the US immigration system.

Learn more

Blog post

Red Carpet or Red Tape? Indonesia’s Immigration Strategy After the Election

Assistant Business Immigration Manager Raga Rasuanta discusses Indonesia’s post-election immigration strategy and its shift toward balancing openness to global talent with increased regulatory scrutiny.

Learn more

Fragomen news

2025年8月 アメリカ移民法ダイジェストLearn more

Fragomen news

Fragomen Center for Strategy and Applied Insights Names Leah Rogal Senior Director

Fragomen announces the appointment of Leah Rogal as Senior Director of its Center for Strategy and Applied Insights.

Learn more

Blog post

Moving to Saudi Arabia: How Orientation Programs Help Expats Adjust

Destination Services Manager Ali Sikandar discusses how orientation programmes in Saudi Arabia help expatriates adapt to cultural differences, workplace norms and everyday challenges, easing their transition into a new environment.

Learn more

Blog post

Exploring Self-Sponsored Visa Pathways in the UAE

Manager Olga Astapova outlines options for individuals to obtain residency without employer sponsorship, highlighting legal routes and strategic considerations.

Learn more

Blog post

Costa Rica Investment Residency Explained: Requirements and Options

Immigration Supervisor Michael Salas Guzman discusses Costa Rica investment residency options and requirements for foreign investors, retirees and rentiers.

Learn more

Media mentions

Gulf Business: Why Immigration Due Diligence is as Critical as Financial Scrutiny in the GCC

Managing Partner for the Middle East and Africa Murtaza Khan discusses why immigration due diligence is important in GCC mergers.

Learn more

Fragomen news

Fragomen Welcomes Partner Karolina Schiffter to Poland Practice, Adds to Poland Presence with New offices in Wrocław and Gdańsk

Fragomen announces the opening of new offices in Wrocław and Gdańsk, welcoming Partner Karolina Schiffter to its Poland practice.

Learn more

Blog post

How to Get Luxembourg Citizenship: Requirements, Benefits & Application Process

This blog post by Manager Virginie Todesco and Immigration Consultant Chiara Caredda, available in English and Portuguese, outlines the requirements, benefits and application process for obtaining Luxembourg citizenship.

Learn more

Awards

Fragomen and Regional Partner for the Asia Pacific Mark Buchanan Named 2025 FEM APAC EMMAs Winners

Fragomen and Regional Partner for the Asia Pacific Mark Buchanan were recognized at the 2025 FEM APAC EMMAs.

Learn more

Awards

Partner Archana Iyer Wins "Innovation Award" at The New York Law Journal's 2025 New York Legal Awards

Partner Archana Iyer won the "Innovation Award" at The New York Law Journal's 2025 New York Legal Awards.

Learn more

Media mentions

Times of India: A War on Fraud: USCIS to Train Special Armed Agents with Powers to Arrest Applicants and Lawyers

Senior Counsel Mitch Wexler discusses how USCIS’s new rule could potentially increase enforcement and affect how applicants interact with the US immigration system.

Learn more

Blog post

Red Carpet or Red Tape? Indonesia’s Immigration Strategy After the Election

Assistant Business Immigration Manager Raga Rasuanta discusses Indonesia’s post-election immigration strategy and its shift toward balancing openness to global talent with increased regulatory scrutiny.

Learn more

Fragomen news

2025年8月 アメリカ移民法ダイジェストLearn more

Fragomen news

Fragomen Center for Strategy and Applied Insights Names Leah Rogal Senior Director

Fragomen announces the appointment of Leah Rogal as Senior Director of its Center for Strategy and Applied Insights.

Learn more

Blog post

Moving to Saudi Arabia: How Orientation Programs Help Expats Adjust

Destination Services Manager Ali Sikandar discusses how orientation programmes in Saudi Arabia help expatriates adapt to cultural differences, workplace norms and everyday challenges, easing their transition into a new environment.

Learn more

Blog post

Exploring Self-Sponsored Visa Pathways in the UAE

Manager Olga Astapova outlines options for individuals to obtain residency without employer sponsorship, highlighting legal routes and strategic considerations.

Learn more

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • Twitter

© 2025 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.