On August 15, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a pivotal Good Moral Character Standard policy memorandum titled “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization” (PM-602-0188). This memorandum marks a significant shift in how USCIS evaluates applicants for naturalization, emphasizing a comprehensive assessment of an individual’s character rather than a mere checklist of disqualifying offenses.
What Is the Purpose of the Holistic Good Moral Character Standard Policy Memorandum?
The purpose of the USCIS Holistic Good Moral Character Standard policy memorandum is to restore a comprehensive approach in evaluating naturalization applicants. Instead of relying solely on statutory bars or disqualifying offenses, the policy directs USCIS officers to assess the totality of an applicant’s life and conduct. USCIS underscores that becoming a naturalized U.S. citizen signifies more than just the right to reside and work in the United States; it represents an individual’s commitment to being an active and responsible member of society. Therefore, evaluating Good Moral Character Standard (GMC) involves a thorough assessment of an applicant’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.
Historical Context
Prior to the early 1990s, the Immigration and Naturalization Service (INS) employed a broad discretionary framework to determine GMC. Officers considered various factors, including rehabilitative evidence, volunteer service, family responsibilities, and other positive traits, in evaluating GMC. However, legislative changes in the 1990s, such as the Immigration Act of 1990 and the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) of 1996, introduced fixed bars for certain offenses, leading to a more rigid approach that equated GMC with the absence of statutory disqualifications.
Current Legal Framework
Under Section 316(a) of the Immigration and Nationality Act (INA) and 8 CFR 316.2, USCIS officers apply the preponderance of evidence standard to all naturalization requirements. While certain offenses, such as murder, aggravated felony, torture, and genocide, result in permanent bars to GMC with no exceptions, the statute also includes a “catch-all clause” allowing for the denial of naturalization based on conduct not enumerated in the nine listed categories. This provision enables officers to consider all relevant evidence, both adverse and favorable, when making GMC determinations.
Holistic Evaluation of GMC
The memorandum emphasizes that GMC findings must go beyond the mere absence of disqualifying acts. Instead, they should reflect a genuine positive assessment of an applicant’s life and conduct. This approach aligns with the “totality of circumstances” framework, which considers the full scope of an individual’s behavior and contributions.
Key factors in this holistic evaluation include:
- Sustained Community Involvement: Active participation and contributions to the community.
- Family Caregiving and Responsibilities: Demonstrating care and responsibility within the family unit.
- Educational Attainment: Pursuit and achievement in educational endeavors.
- Stable and Lawful Employment History: Consistent and legal employment over time.
- Length of Lawful Residence: Duration of lawful presence in the United States.
- Compliance with Tax Obligations: Meeting financial responsibilities, including tax payments.
These positive attributes are weighed against any disqualifying behavior or actions, such as:
- Permanent Bars: Offenses like murder, aggravated felonies, crimes of violence, persecution, genocide, torture, or severe violations of religious freedom.
- Conditional Bars: Offenses including controlled substances violations, multiple DUI convictions, false claims to U.S. citizenship, unlawful voter registration, or unlawful voting.
- Other Contrary Acts: Behaviors 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.
In assessing such acts, USCIS reviews all available documentation and may question applicants about the specific circumstances to determine if a particular situation or act should bar them from naturalization.
Emphasis on Rehabilitation and Reformation
A significant aspect of the updated policy is the focus on rehabilitation and reformation. USCIS recognizes that individuals can change and that evidence of genuine rehabilitation may support a finding of GMC. Factors demonstrating rehabilitation include:
- Rectifying Family Obligations: Addressing overdue child support payments or other family responsibilities.
- Compliance with Legal Conditions: Adhering to probation terms or other court-imposed conditions.
- Community Testimonies: Statements from credible sources attesting to the applicant’s ongoing good moral character.
- Mentorship and Reformation: Engaging in activities that mentor or assist others with similar pasts.
- Financial Responsibility: Full repayment of overpaid benefits or overdue taxes.
This rehabilitative approach empowers USCIS officers to consider the complete history of applicants seeking naturalization, especially in cases where no regulatory or statutory bars exist. Applicants are encouraged to present their full story, demonstrating how their life aligns with the ethical standards and expectations of the community in which they reside.
Conclusion
The August 15, 2025, policy memorandum by USCIS signifies a return to a more comprehensive approach in evaluating GMC for naturalization applicants. By emphasizing a holistic assessment that considers both positive contributions and the potential for rehabilitation, USCIS aims to ensure that naturalized citizens are individuals who embody the values and responsibilities of U.S. citizenship. This shift reflects a commitment to fairness and the recognition that individuals can demonstrate GMC through their actions and contributions to society.
If you have any questions about USCIS’ new holistic GMC Standard policy, please contact our Chicago office for guidance. At HSD Immigration Lawyer, we specialize in complex employment– investment- and family-based immigration matters.