Overview of the August 15, 2025 USCIS Memo

On August 15, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a new Policy Memorandum (PM-602-0188) that changes the way officers evaluate the “good moral character” (GMC) requirement for naturalization applicants.

Instead of focusing mainly on whether an applicant has avoided disqualifying conduct, officers are now instructed to use a holistic, totality-of-circumstances review. This means USCIS will weigh not only any negative behavior, but also evidence of positive contributions an applicant has made to their family, workplace, and community.

What Has Changed?

The memo emphasizes that good moral character is more than simply avoiding criminal convictions. Officers must now balance both positive and negative factors, which expands the range of issues applicants should be prepared to address.

Positive factors USCIS will weigh include:

  • Community service and civic engagement

  • Family caregiving and strong family ties

  • Educational achievement and pursuit of skills

  • Stable, lawful employment

  • Consistent tax compliance including having paid off all tax debts in their entirety

  • Length of lawful residence in the U.S.

Negative factors receiving increased scrutiny include:

  • Permanent bars (e.g., murder, aggravated felonies, persecution)

  • Conditional bars (e.g., multiple DUIs, drug violations, false claims to U.S. citizenship, unlawful voting)

  • Non-criminal behavior that reflects poorly on civic responsibility, such as reckless driving, harassment, or aggressive conduct

The memo also places emphasis on rehabilitation. Applicants with past misconduct must present compelling evidence that they have truly reformed.

Finally, USCIS is reviving neighborhood investigations under INA § 335(a). Officers may interview neighbors, employers, or community members—or request applicants to provide testimonial letters.

What This Means for Applicants

The most significant consequence of this change is that good moral character evaluations are now more subjective. Rather than a clear checklist, much depends on how an officer interprets an applicant’s lifestyle, history, and contributions.

This shift could lead to:

  • Inconsistent decisions depending on the officer’s perspective

  • Longer processing times due to requests for more evidence

  • Increased denials or delays for applicants who have not proactively gathered proof of their positive contributions

Applicants should understand that merely avoiding criminal conduct may no longer be enough. Instead, they must be prepared to demonstrate a well-rounded picture of their character.

Practical Strategies for Clients

Here are key steps applicants can take to strengthen their case:

  1. Document Positive Contributions

    • Collect letters from community organizations, religious leaders, or nonprofits confirming volunteer work.

    • Provide proof of family caregiving, such as caring for elderly parents or children with special needs.

  2. Demonstrate Stability and Responsibility

    • Submit employment verification, tax returns, and educational certificates.

    • Show financial reliability with evidence of timely rent, mortgage, or bill payments.

  3. Explain Minor Issues Clearly

    • For traffic infractions or other minor violations, provide receipts of payment or certificates from corrective programs (e.g., defensive driving).

  4. Show Rehabilitation Where Needed

    • If there is a past arrest or problem, include program completion certificates, rehabilitation records, and letters of support demonstrating change.

  5. Proactively Offer Testimonials

    • Request letters from neighbors, teachers, employers, or faith leaders who can speak to your honesty, reliability, and contributions.

  6. Stay Organized

    • Prepare a supplemental statement summarizing your evidence of good moral character.

    • Work with an immigration attorney to anticipate potential issues and respond quickly to any USCIS requests.

Conclusion

USCIS’s new guidance signals increased scrutiny of naturalization applicants’ moral character. While this higher bar may feel daunting, it also provides an opportunity for applicants to highlight their positive contributions and long-term commitment to the United States. With careful preparation, thorough documentation, and clear presentation of evidence, applicants can overcome the heightened standards and move forward toward U.S. citizenship.