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08/17/2025

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08/17/2025
LAWIN.news

Is USCIS Raising the Bar for New Citizens

by Aileen Ligot Dizon, LAWIN.news August 17, 2025
written by Aileen Ligot Dizon, LAWIN.news August 17, 2025
9

U.S. Citizenship and Immigration Services (USCIS) rewrote a key part of the naturalization playbook, and the change could shift who gets to call themselves American. The new policy tells officers to look beyond simple criminal disqualifiers and make a holistic judgment about an applicant’s “good moral character,” weighing both positive contributions and a wider range of everyday behaviors. 

Supporters call it a move to restore integrity. Critics warn it could inject vagueness and subjectivity into decisions, potentially deterring eligible immigrants and increasing denials. Which will it be? A smarter, more complete review or a new barrier for would‑be citizens?

New USCIS Policy 


On August 15, 2025, USCIS issued a policy memorandum that broadens how officers evaluate whether lawful permanent residents meet the “good moral character” requirement for U.S. naturalization. The move shifts the evaluation from a largely checklist-based screen for statutory disqualifiers toward a broader, holistic assessment that weighs positive contributions and a wider range of conduct, including some otherwise lawful behavior.

What the new policy says

USCIS now requires a holistic assessment of an applicant’s moral character. Adjudicators are to review an individual’s behavior, adherence to societal norms, and positive contributions as part of a comprehensive evaluation, rather than limiting their review to the presence or absence of statutorily disqualifying offenses. For example, an officer might consider whether an applicant regularly volunteers at a local food bank or participates in neighborhood safety meetings as evidence of positive civic engagement.

The guidance identifies several positive factors that officers should weigh. These include community involvement, family caregiving and ties, educational attainment, stable and lawful employment, the length of U.S. residence, and consistent payment of taxes. Here are some practical examples: a record of 200+ volunteer hours with a nonprofit, letters from supervisors confirming steady employment for several years, school transcripts or diplomas showing completion of a degree or certification, tax returns demonstrating timely filing and payment, and statements from family members documenting long-term household caregiving responsibilities.

At the same time, the policy expands the kinds of negative conduct that may be considered. Beyond statutory disqualifiers, such as murder, aggravated felonies, controlled-substance offenses, or being a “habitual drunkard,” adjudicators are instructed to consider conduct that, while legally permissible, might be “contrary to the average behavior of citizens” or “inconsistent with civic responsibility.” USCIS cites examples including reckless or habitual traffic infractions and harassment or aggressive solicitation.

The memo also emphasizes rehabilitation and mitigating factors. Officers are directed to consider evidence that an applicant has reformed or addressed past misconduct, for example through compliance with probation, payment of overdue taxes or child support, and submission of letters of support from community members.

Finally, the policy memorandum revises the evaluation standard used in naturalization interviews and decisions and offers guidance intended to promote consistent application of these factors across cases. In practice this may mean officers request a broader set of documents up front – tax returns, employer letters, volunteer logs, or probation completion certificates – or issue requests for additional evidence when applications lack information about community ties or rehabilitation steps.

Comments and Reactions

USCIS said the policy is intended to restore integrity to the naturalization process and to ensure applicants demonstrate a commitment to U.S. civic life. Agency leaders described U.S. citizenship as the “gold standard” that should be awarded only to those who meet higher standards of conduct and contribution.

Supporters argue the change gives adjudicators better tools to distinguish applicants who make demonstrable contributions and who act responsibly in their communities. They say a broader review lets officers recognize positive civic engagement that statutory checklists may miss.

Critics, including former officials and immigration advocates, contend the guidance is vague and open-ended, potentially giving officers too much discretion to deny applications over minor or noncriminal conduct such as traffic citations. They warn the policy could discourage eligible legal immigrants from applying for citizenship and introduce greater subjectivity into decisions that historically relied on clearly defined statutory disqualifiers.

What about you?

What do you think about this change, and how will it affect you or someone you know? Have routine citations, unpaid taxes, or volunteer work ever influenced an application? Would the new focus on “everyday behavior” feel like a fairer, fuller review or like an uncertain hurdle?

Moving Forward

USCIS now expects a fuller, evidence‑based picture of “good moral character,” weighing positive contributions and a wider range of noncriminal conduct. That change hands more power to adjudicators, which could help applicants whose service, steady work, and community ties strengthen their case, but it also makes outcomes less predictable and raises the real possibility of more denials and longer waits. If you plan to naturalize, don’t leave this to chance. Gather proof of volunteer work, employment records, tax returns, school credentials, and any documents showing rehabilitation (probation completion, paid debts, letters of support). Getting that material together now, and consulting an immigration attorney to present it effectively, is the best way to protect your application and reduce the risk this policy creates.

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Aileen Ligot Dizon, LAWIN.news

Aileen Ligot Dizon is a licensed attorney in Texas and the Philippines, and serves as the Managing Partner at Ligot Dizon Law Firm, P.C. Her areas of practice include Divorce & Family Law, Immigration Law, Business Law, Wills-Trusts-Probate, and Philippine legal matters. Aileen is actively engaged in several professional and community organizations and currently holds the position of State President of the Philippine-American Chamber of Commerce of Texas, as well as President & CEO of Lawin Media Network Corp. For additional information about the author, please visit https://aileenligotdizon.com. Disclaimer: The views and beliefs expressed by the author do not necessarily represent those of LAWIN.news, its management, editorial board, or staff.

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