The 39 “high-risk” countries currently designated by the Proclamation are Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma (Myanmar), Burundi,  Chad, Republic of the Congo, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Gabon, The Gambia, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and  Zimbabwe. The Proclamation also applies to individuals holding travel documents issued by the Palestinian Authority.

This new policy will likely result in processing delays for international students and scholars (researchers, faculty, instructional staff, and visitors) and their family members, from these designated countries (or who have travel documents issued by the Palestinian Authority) who file, or have filed, applications for benefits with USCIS. These application types include: 

• Form I-765 employment authorization (ex. F-1 Optional Practical Training/OPT, F-1 STEM OPT Extension, J-2 work permission)
• Form I-539 Change of Status (ex. to F-1 or to J-1)
• Form I-129 Employment Visa Petitions (ex. H-1B, O-1, etc.), 
• Adjustment of Status (Green Card), asylum petitions
• Other applications. 

After an application is filed, applicants may receive from USCIS a Request for Additional Evidence (RFE) if USCIS needs more information to process an application, which is not uncommon.  If you receive an RFE, please contact the Center for Global Education.

The hold on USCIS application processing under this memorandum, as well as the comprehensive re-review of approved benefit requests and review of policies, procedures, and screening and vetting processes for benefit requests, are effective January 1, 2026. The hold will be “in effect until lifted or modified by the USCIS Director through a subsequent memorandum or memorandum attachment.” We do  not know how long that could be.

We advise international students and scholars to submit applications to USCIS as far in advance as permitted. 

If any questions arise, please be sure to contact your advisor at the Center for Global Education. Bates continues to monitor immigration developments and will post any new information on the Immigration News page.

Per the announcement, the following are examples of the USCIS application types eligible for Premium Processing that are common for our international students/scholars:

Form I-765 – Application for Employment Authorization (for F-1 Optional Practical Training, F-1 STEM Optional Practical Training Extension):  increase from $1,685 to $1,780

Form I-539 Application to Extend/Change Nonimmigrant Status (for applications requesting change to F-1, F-2, J-1, J-2):  $1,965 to $2,075

Full Restrictions and Entry Limitations (ALL immigrant and ALL nonimmigrant visas, including H, O, B-1/B-2, F, M, and J visas):

• Afghanistan, Burma (Myanmar), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen
• Newly designated: Burkina Faso, Mali, Niger, South Sudan, Syria, individuals holding travel documents issued by the Palestinian Authority
• Changing from partial to full restrictions: Laos, Sierra Leone

Partial Restrictions and Entry Limitations(immigrants and nonimmigrants on B-1, B-2, B-1/B-2, F, M, and J Visas, except where indicated):

• Burundi, Cuba, Togo, Venezuela
• Newly designated: Angola, Antigua and Barbuda, Benin, Cote d’Ivoire, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Tonga, Zambia, Zimbabwe
• Turkmenistan (restrictions continue on immigrant visa holders only)

People from countries with full travel and immigration restrictions under the ban will not be granted travel documents to immigrate to the United States (“immigrant visas”) or travel documents to enter the U.S. for other reasons (“nonimmigrant visas”), such as to visit family and friends or to study or work in the country temporarily.

People from countries with partial restrictions under the ban will not be granted travel documents to immigrate to the United States (“immigrant visas”). They also will not be granted certain types of travel documents to enter the U.S. for other reasons (“nonimmigrant visas”): B-1, B2, B-1/B-2, F, M, and J visas. Additionally, if you are from a country with partial restrictions and you apply for and receive a visa in a category that is not subject to the ban, your visa may be valid for a shorter period of time.

*Note: For people from Turkmenistan, there is no longer a ban on entry with “nonimmigrant visas” into the U.S. However, entry with “immigrant visas” remains banned.

The Proclamation applies only to foreign nationals of the designated countries who:

• Are outside the United States on or after the effective date of the proclamation [12:01 AM (00:01) Eastern Daylight Time on January 1, 2026]; AND
• Do not have a valid visa as of January 1, 2026.

The Proclamation does NOT apply to the following individuals:

• any lawful permanent resident of the United States;
• any dual national of a country designated under sections 2, 3, 4, or 5 of this proclamation when the individual is traveling on a passport issued by a country not so designated;
• any foreign national traveling with a valid nonimmigrant visa in the following classifications:  A-1, A-2, C-2, C-3, G-1, G-2, G-3, G-4, NATO-1, NATO-2, NATO-3, NATO-4, NATO-5, or NATO-6;
• any athlete or member of an athletic team, including the coaches, persons performing a necessary support role, and immediate relatives, traveling for the World Cup, Olympics, or other major sporting event as determined by the Secretary of State;
• Special Immigrant Visas for United States Government employees under 8 U.S.C. 1101(a)(27)(D);
• immigrant visas for ethnic and religious minorities facing persecution in Iran;
• “an individual who has been granted asylum by the United States or to a refugee who has already been admitted to the United States. Nothing in this proclamation shall be construed to limit the ability of an individual to seek asylum, refugee status, withholding of removal, or protection under the Convention Against Torture, consistent with the laws of the United States.”

The Proclamation indicates that “No immigrant or nonimmigrant visa issued before the applicable effective date of this proclamation shall be revoked pursuant to this proclamation,” so valid entry visas may be used to enter the U.S.

Within 180 days of the date of the proclamation, and every 180 days after, the Secretary of State along with other agencies will report on whether any suspensions and limitations imposed by the proclamation may be modified. (NOTE: In previous travel bans, there were some countries who were able to meet the security criteria and were able to be removed from the subject list.) 

Based on the USCIS Policy Memo issued on December 2, 2025, advising that applications filed with USCIS by nationals from the 19 high-risk countries would face additional vetting procedures, it is likely that individuals from the 20 additional countries added by this Proclamation (or with travel documents issued by the Palestinian Authority) may also find their USCIS applications similarly subject to additional vetting and may face processing delays.