On Friday, August 15, 2025, the U.S. Citizenship and Immigration Services (USCIS) released a new policy memorandum (PM-602-0188) that significantly increases scrutiny of U.S. citizenship applications. The guidance reshapes how officers evaluate whether applicants meet the long-standing good moral character requirement for naturalization.
Naturalization is more than a procedural immigration step. According to USCIS, it is “a significant legal transformation, an assimilation to a country that demands both allegiance and character.” Alongside meeting residency requirements and passing English and civics tests, applicants must establish that they are, and continue to be, “persons of good moral character.”
A Holistic Approach to Good Moral Character
Previously, the good moral character test was often applied like a checklist: as long as an applicant avoided disqualifying crimes such as aggravated felonies or multiple DUIs, they typically qualified.
Under the new memorandum, USCIS instructs officers to move beyond a “cursory mechanical review.” Instead, officers must apply a totality of the circumstances test — requiring a holistic assessment of an applicant’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.
Greater Emphasis on Positive Contributions
For the first time in decades, USCIS has directed officers to weigh an applicant’s positive contributions to U.S. society, not just the absence of misconduct. Factors now considered include:
- Sustained community involvement and volunteer work
- Family caregiving, responsibility, and close family ties in the U.S.
- Educational achievements
- Stable and lawful employment history
- Length of lawful residence in the United States
- Tax compliance and financial responsibility
Expanded Scrutiny of Disqualifying Conduct
At the same time, USCIS has sharpened its focus on conduct that may show a lack of good moral character.
Examples include:
- Permanent bars: murder, aggravated felonies, crimes of violence, persecution, genocide, torture, or severe violations of religious freedom
- Conditional bars: controlled substance violations, two or more DUI convictions, false claim to U.S. citizenship, unlawful voting or voter registration
- Other problematic acts: repeated reckless driving, harassment, or aggressive solicitation, even if technically lawful
Officers are required to review all documentation and question applicants closely about the circumstances of their actions.
Rehabilitation and Reformation
Importantly, USCIS acknowledges the possibility of rehabilitation. Evidence of genuine reform may support a finding of good moral character, including:
- Rectifying overdue child support or family obligations
- Compliance with probation or court conditions
- Credible community testimony of good character
- Mentorship or contributions to others facing struggles
- Full repayment of benefits received in error
- Full payment of overdue taxes
As USCIS explains: “This approach empowers officers to review the complete history of applicants and require them to present their full story, demonstrating how their life aligns with current ethical standards and expectations of the community.”
What This Means for Citizenship Applicants
The new USCIS policy represents a stricter interpretation of the good moral character requirement. Applicants must do more than avoid disqualifying conduct — they must proactively demonstrate positive contributions to American society while addressing any past issues.
At Ricci Law, we help applicants:
- Document positive contributions such as employment, community service, and family responsibilities
- Address issues that may raise questions under the new guidance
- Present a complete and compelling narrative that meets this heightened standard.
📞 If you are considering applying for U.S. citizenship, contact Ricci Law today to discuss how this policy may affect your case.
