Reflecting a trend under the new administration to narrow eligibility for certain U.S. immigration benefits, USCIS issued a new policy memorandum on August 15, 2025 which directs its officers to place a heavier burden on applicants for naturalization to establish that they satisfy the good moral character requirement for U.S. citizenship.
As background, lawful permanent residents (“LPRs”) seeking to become naturalized U.S. citizens are required to meet the following requirements:
- LPR status for at least 5 years (or 3 years, if they married to and living with a U.S. citizen spouse);
- Continuous residence in the U.S. for at least 5 years (or 3 years, if they married to and living with a U.S. citizen spouse);
- Physical presence in the U.S. for at least 30 months (or 18 months, if they married to and living with a U.S. citizen spouse);
- Good moral character;
- Ability to read, write and speak basic English; and
- Knowledge of U.S. history and government
Good moral character (“GMC”) must be shown for the required period (e.g., 5 years for most LPRs) prior to the filing and up to the time the applicant for naturalization takes the Oath of Allegiance. Previously, GMC meant character that measures up to the standards of an average citizen of the community in which the applicant resides. GMC assessments could be satisfied as long as the applicant did not have a disqualifying criminal record or other conduct prohibited by the Immigration and Nationality Act.
The August 15, 2025 memo now instructs USCIS officers to go beyond a “cursory mechanical review focused on the absence of wrongdoing” when making GMC determinations. Officers must now conduct a “holistic assessment of an alien’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character … [that reflects] … a genuine positive assessment of who the alien is and how they have lived in their community …” to determine whether the alien has “… affirmatively established … that they are worthy of assuming the rights and responsibilities of United States Citizenship.” Officers are now explicitly directed to “weigh all relevant evidence, both adverse and favorable, before granting or denying naturalization.”
Under this new policy, USCIS officers are required to:
- Place greater emphasis on applicants’ positive attributes or contributions in GMC determinations.
- Focus greater attention on whether applicants who have engaged in any behaviors or acts that disqualify them from a finding of GMC; and,
- Focus greater attention on ensuring that applicants who have engaged in wrongdoing are properly rehabilitated and reformed, allowing evidence of genuine rehabilitation to support a finding of GMC.
The policy memo indicates that positive factors may include: sustained community involvement and contributions in the United States; family caregiving, responsibility, and ties in the United States; educational attainment; stable and lawful employment history and achievements; length of lawful residence in the United States; and compliance with tax obligations and financial responsibility in the United States.
Genuine evidence of rehabilitation may include but is not limited to: rectifying overdue child support payments or other family obligations; compliance with probation or other conditions imposed by a court; community testimony from credible sources attesting to alien’s ongoing GMC; reformation or mentoring those with similar past; full repayment of overpayment of benefits such as SSI; and full payment of overdue taxes.
The heavier emphasis on proving GMC gives USCIS officers more discretion to deny naturalization applications if a naturalization applicant fails to meet this more stringent standard. Accordingly, applicants for naturalization may need – based on their individual background and circumstances – to augment their applications with documentary evidence that satisfy this new GMC standard. Naturalization applicants should also more thoroughly prepare for their personal interview if they might have prior incidents that could result in concerns with demonstrating GMC under this new policy memo.
LPRs interested in applying for U.S. citizenship should contact experienced immigration attorneys to discuss USCIS’s new policy and how it might impact their own application for naturalization. Filing a well-documented application and being prepared for the interview are the best ways to ensure a successful application.