Consistent with its concerted anti-immigration efforts, the Trump administration recently released a USCIS policy memo designed to drastically change the criteria officers are to use in deciding whether an application should be approved for U.S. citizenship. Applicants for citizenship have always been required to prove that they are people of “good moral character.” Traditionally, demonstrating good moral character involved having no criminal convictions or disqualifying conduct; however, pursuant to the new policy memo, officers are required to apply a broader, more holistic evaluation of applicants. Officers are now instructed to subjectively consider the following:
- Positive contributions: long-term community involvement, caregiving roles, educational attainment, stable employment, paying taxes, and strong ties to the U.S.
- Behavior that may be “technically lawful” but inconsistent with community standards (e.g., repeated traffic violations, participating in political marches)
Immigration officers now have greater discretion to apply these new standards on a case-by-case basis, giving them leeway to interpret ambiguous behavior under the guise of good moral character. The primary issue with the policy change is that the language is vague and extraordinarily subjective, which will assuredly result in inconsistent or arbitrary enforcement. Decisions will be based strictly on varying officers’ opinions. This shift purposely adds uncertainty to the naturalization process, potentially making it more difficult for applicants to predict the outcome of their applications. This uncertainty, combined with the general fear this administration has worked to create among immigrant communities will no doubt have the intended chilling effect of dissuading aspiring citizens from applying.
What You Can Do to Increase Chance of Approval:
Applicants should now prepare to document not only a clean legal record but also evidence of civic engagement, stability, community ties, rehabilitation, and positive contributions that reflect American ideals. Given the heightened discretion and subjectivity, effective presentations of these factors may become crucial. Recommended Documentation:
- Employment & Financial Responsibility
- Pay stubs or employer verification letters (showing stable work history)
- IRS tax transcripts proving consistent filing and payment of taxes
- Business ownership or professional licenses
- Community Involvement & Civic Engagement
- Letters of recommendation from community leaders (teachers, clergy, nonprofit directors)
- Proof of volunteering or community service (certificates, organization letters, photos)
- Membership in civic, cultural, or professional organizations
- Family & Caregiving Roles
- School records or letters showing involvement in children’s education
- Medical records demonstrating care for elderly or disabled relatives
- Custody or guardianship documents
- Education & Self-Improvement
- Diplomas, transcripts, or certificates from schools, vocational training, or English/civics classes
- Certificates of rehabilitation, substance abuse treatment, or counseling (if relevant)
- Law-Abiding Conduct
- Signed affidavits from employers, neighbors, or colleagues attesting to your character
- Other Positive Contributions
- Records of property ownership, mortgage statements, or rental agreements showing stability
- Military service records or honorable discharge papers (if applicable)
- Evidence of paying child support or alimony consistently
Summary: Key Impacts for Applicants
| Element | Before | Now (New Policy) |
| Evaluation basis | Absence of disqualifying crimes | Holistic—positive contributions reviewed alongside behavior consistency |
| Officer discretion | Limited to statutory bars | Broader discretionary power to assess subjective traits |
| Positive criteria | Not required | Expected—community service, caregiving, education, employment, tax compliance |
| Subjective scrutiny | Minimal | Increased—for conduct that may be legal yet inconsistent with community norms |
