Despite the expansion of denaturalization campaigns, large-scale enforcement remains difficult.
Since the U.S. Department of Justice (DOJ) filed multiple lawsuits in federal courts nationwide on May 8th requesting the revocation of naturalized citizens“ citizenship, there has been a significant increase in questions among Korean citizens asking, ”Is my citizenship safe?" A month later, on June 2nd, public radio NPR released a report examining publicly disclosed denaturalization cases and their outcomes. There was a considerable gap between the administration's stated goals and its actual enforcement. This report outlines the reality as told by the numbers and what naturalized citizens should actually be mindful of.
Reality in Numbers
“An NPR review of denaturalization cases reported in June 2026, covering instances up to mid-May, identified 34 confirmed cases, of which 11 resulted in actual revocation of citizenship.”
The administration has set a strong goal. The U.S. Citizenship and Immigration Services (USCIS) reportedly plans to refer between 100 and 200 denaturalization cases per month to the Department of Justice through internal guidance. The Department of Justice also stated that the number of denaturalization lawsuits it has filed in the past 16 months is greater than in the entire four years of the previous administration.
However, actual enforcement is far from espoused. A review by NPR of publicly available cases as of mid-May, as reported on June 2, found 34 cases of denaturalization proceedings, of which only 11 resulted in actual denaturalization. While this is an increase compared to the annual average of 11 denaturalizations from 1990 to 2017, it falls far short of the goal of “100 to 200 cases per month.”.
Moreover, looking at publicly disclosed cases, the vast majority of instances where citizenship was revoked involved individuals who concealed serious crimes such as drug trafficking, sexual offenses against children, or participation in war crimes before naturalizing. It is not the case that ordinary citizens have lost their citizenship due to minor errors in old documents. If so, why does this gap arise between objectives and execution? The answer lies in the structure of the denaturalization process itself.
Why is large-scale enforcement difficult?
“Denaturalization is a process in which the government must file a civil lawsuit in federal court to prove that a citizen's naturalization was unlawfully procured or was procured by concealment of material fact or by willful misrepresentation (8 U.S.C. §1451).”
Denaturalization is not something that administrative agencies can decide with a single document. The government must file a civil lawsuit in federal court and prove before a judge that citizenship was wrongly granted. The level of proof required at this stage is “clear, convincing, and unequivocal evidence,” which is higher than in a typical civil lawsuit. While not as high as the “beyond a reasonable doubt” standard in criminal trials, it is more than merely showing that one side is more likely than the other.
There are two paths to denaturalization. One is a criminal procedure that prosecutes the act of illegally obtaining citizenship as a crime. This has a statute of limitations, the defendant is provided with a public defender, but requires the highest standard of proof, “beyond a reasonable doubt.” The other path, which is rapidly increasing, is a civil procedure. This path has no statute of limitations or public defender, making it easier for the government to utilize, but it is not necessarily an easy win.
This structure has two sides. The side favorable to the government is also clear. In civil lawsuits for deprivation of citizenship, there is no statute of limitations, so even acts from decades ago can be called into question. Unlike criminal cases, defendants are not guaranteed a public defender, meaning those in difficult financial situations must face the government alone. However, each case is an individual lawsuit, requiring time and resources from government lawyers and the courts. Furthermore, the government must meticulously gather evidence to meet the high burden of proof for each case. This is why “100 to 200 cases per month” is merely an administrative goal and not easily achievable in reality.
The Supreme Court's defensive line
“In the Maslenjak v. United States decision (2017), the Supreme Court ruled that to revoke citizenship based on misrepresentation, the government must prove that the statement was ‘material’ – meaning it influenced the decision to grant citizenship.”
In 2017, the Supreme Court unanimously drew a critical line. In the case of Maslenjak, a Bosnian refugee, the Court, in an opinion authored by Justice Kagan, held that trivial lies or lies that do not matter to the outcome cannot be used to strip someone of citizenship. The government must demonstrate that the false statement had a “natural tendency to influence” the decision on citizenship, meaning it was material. Maslenjak had made a false statement about her husband's military service during her asylum application, and lower courts had allowed her citizenship to be revoked without considering whether the statement was material. The Supreme Court overturned precisely that ruling.
This principle offers a strong shield to the ordinary naturalized citizen. Civil rights will not be revoked due to minor clerical errors or lapses of memory from long ago, or omissions that did not affect the outcome. Furthermore, the 1967 Afroyim decision affirmed that citizenship is a constitutional right that cannot be arbitrarily revoked against one's will. Denaturalization is intended for serious concealments that would have determined the grant of citizenship itself, such as war crimes, terrorism, or organized immigration fraud.
What does it mean for a Korean citizen?
“Revocation of citizenship lawsuits have historically targeted serious matters that would have determined the granting of citizenship itself, such as involvement in war crimes and human rights abuses, or organized fraud.”
A considerable number of the first-generation Korean immigrants have obtained citizenship after living as permanent residents for a long time. Most of them applied for citizenship honestly and legally, so there are not many cases that are immediately at risk due to this campaign. This means there is no reason to be swept up in vague anxiety.
However, there are also people who should calmly review their situation. If there were doubts about the authenticity of a marriage during the process of obtaining permanent residency or citizenship in the past, if criminal records were falsified, or if there were.
Between exaggerated fear and honest record
“According to USCIS guidance, the N-400, Application for Naturalization, requires applicants to answer all questions truthfully. Past arrest and/or conviction records must be disclosed, regardless of whether the case was resolved.”
Then what should we do? The most important thing is a balanced perspective that doesn't lean too far in either direction. It's not desirable to be swayed by anxiety marketing with exaggerated threats, nor is it desirable to be complacent.
For those who plan to apply for citizenship in the future, the most reliable preparation is to answer all questions on Form N-400 honestly. In particular, past arrest or indictment records must be fully disclosed if the question asks, even if the case has been resolved or the records have been sealed. For those who have already been naturalized, it is advisable to keep a copy of the documents submitted at the time of application. And remember, if someone approaches you saying, “Your citizenship is at risk, so pay money to fix it in advance,” it is very likely to be a scam preying on your fears.
You should be wary of solicitations that ask for fees, especially under names such as “citizenship re-examination” or “pre-emptive defense registration for citizenship revocation.” There is no system in place for the government to re-examine the citizenship of naturalized citizens on a mass basis without individual notification. If you receive a suspicious solicitation, please verify it with a trusted immigration lawyer or a non-profit immigration support organization before handing over any money.
Closing remarks
To summarize, the executive branch's goal of revoking citizenship has clearly increased, but actual enforcement is unlikely to be as swift or extensive as declared due to the process of individual civil lawsuits, high standards of proof, and the materiality requirement set by the Supreme Court. The numbers released on June 2nd illustrate this gap. Honest naturalized citizens have no reason to excessively fear this campaign. However, those applying for citizenship in the future are best prepared by answering all questions truthfully and, especially, by disclosing any arrest or indictment records, even if the case has been closed. Those who have already naturalized should keep the documents submitted during their application process well-preserved, and if there are any concerning aspects in their records, they should seek an accurate diagnosis from an immigration attorney before succumbing to anxiety. Rather than being surprised by the numbers announced by the executive branch, the realistic starting point is to first confirm the honesty of one's own records.
Disclaimer: This column is for general information purposes only and is not legal advice for your specific case. You should always consult with an attorney who specializes in immigration law for your individual case.
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