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 (PM-602-0188, “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization” (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.
Lawful Permanent Residents (“LPRs”) seeking to become naturalized U.S. citizens are required to establish “Good Moral Character” (“GMC”)—character that measures up to the standards of an average citizen of the community in which the applicant resides—for the required period (e.g., 5 years for most LPRs and 3 years for certain spouses of U.S. citizens) prior to the filing and up to the time the applicant for naturalization takes the Oath of Allegiance. Prior to the issuance of USCIS’ August 2025 Policy Memorandum, 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. In other words, GMC could be shown through the absence of negative factors.
USCIS’ new 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 evidence of applicants’ positive attributes or contributions in GMC determinations.
- Focus greater attention on whether applicants 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 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 satisfies this new GMC standard.
Positive factors identified by USCIS 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.
- Compliance with tax obligations and financial responsibility in the United States.
Negative factors identified by USCIS include the following:
- Permanent bars to GMC, such as murder, aggravated felony, crimes of violence, persecution, genocide, torture, or severe violations of religious freedom.
- Conditional bars to GMC, such as controlled substances violations, two or more convictions for driving under the influence (DUI), false claim to U.S. citizenship, unlawful voter registration, or unlawful voting.
- Any other acts that are contrary to the average behavior of citizens in the jurisdiction where aliens reside. These could be actions that, while technically lawful, may be inconsistent with civic responsibility within the community, such as reckless or habitual traffic infractions, or harassment or aggressive solicitation.
USCIS also comments that:
In assessing acts that are unlawful or contrary to the average behavior of citizens of the community in which the alien resides USCIS will review all available documentation and question aliens seeking naturalization regarding the specific circumstances of their actions to determine if a particular situation or act should bar an alien from naturalization.
The presence of negative factors (which are not permanent bars to GMC) indicates that evidence of rehabilitation may be required.
Evidence of rehabilitation identified by USCIS includes:
- Rectifying overdue child support payments or other family obligations.
- Compliance with probation or other conditions imposed by a court.
- The availability of favorable character statements from credible sources attesting to your ongoing GMC
- Reformation or mentoring those with similar past.
- Full repayment of overpayment of benefits such as SSI.
- Full payment of overdue taxes.
In light of this new memorandum, applicants for naturalization should be prepared to submit evidence of the positive factors identified above, and if necessary, evidence of rehabilitation overcoming any negative factors. Retaining qualified immigration counsel is recommended for analysis of applicable factors and preparation of affirmative evidence to show good moral character under this new policy.
