Tougher Morality Checks, and the Road to Citizenship - A Different Path to Citizenship
On December 9, 2025, 100 people attended a scheduled citizenship oath ceremony at a federal building in Indianapolis. Thirty-eight of them were informed that the ceremony was canceled as soon as they entered the building. That same week, at Faneuil Hall in Boston, a Haitian permanent resident who had been in the citizenship process for years was called out of line. No specific reason was given. Immigration lawyers report a spike in canceled oath ceremonies and interviews across the country since late 2025. In Minnesota, only four people were reportedly granted citizenship in a single month, where 40 to 70 usually receive it each month. Some applicants didn't even receive official written notification, just that their appointments disappeared from their online accounts. Since the start of the Trump administration's second term, all gateways to citizenship have been simultaneously narrowing. From the indefinite suspension of processing for nationals of 39 countries, to radical changes to the ‘good moral character’ test, to the revival of neighborhood canvassing, to increased social media and ideological vetting, to increasing the difficulty of the citizenship test, to the push for denaturalization for those who have already obtained citizenship. It's a time when the final door to citizenship is not only narrowing, but even those already through it could be reopened.
39 Country Vetting Freeze - People Turned Away at the Oath of Office Door
On January 1, 2026, USCIS issued a policy memorandum (PM-602-0194) indefinitely suspending immigration benefit adjudications for nationals of 39 countries and the Palestinian Territories. This action is based on two travel ban presidential proclamations signed in June and December 2025, with most of the affected countries located in Africa, Asia, the Middle East, and South America. The hold includes not only green card applications, but also citizenship applications (N-400). Even those who had already passed their interviews and passed the citizenship test were stopped at the final gate, with their oath ceremonies canceled. USCIS said the move is part of its “rigorous screening and verification of foreign nationals from high-risk countries” and that it will “not take shortcuts in the adjudication process.” South Korea is not on the list of 39 countries, so the freeze does not directly apply to Korean American permanent residents. However, the direction the administration is taking with this action is worth noting. The overall increase in scrutiny, longer processing times, and more frequent requests for additional documentation are affecting all citizenship applicants, regardless of nationality.
From checklists to ‘holistic assessment' - a fundamental shift in morality checks
On August 15, 2025, USCIS released a policy memo that fundamentally changes the way it evaluates ‘good moral character’ (GMC). Previously, the moral character test was effectively a checklist: if you didn't fall under any of the statutory inadmissibility grounds (murder, drug dealing, gambling, etc.), you were presumed to have met the moral character requirement. The new guidance shifts this to a ‘totality of circumstances’ evaluation. Section 316 of the Immigration and Nationality Act (INA) requires applicants for citizenship to demonstrate that they have maintained and will continue to maintain ‘good moral character for the statutory period (usually five years, three years for citizen spouses).‘ The burden of proof is on the applicant, and is judged in light of ‘the standards of the average citizen in the place of residence. Under the new criteria, adjudicators will look at the applicant's overall life, not just the presence or absence of legal prohibitions. "Conduct inconsistent with civic responsibility," such as repeated traffic violations, harassment, or aggressive behavior, may be considered a negative factor, even if the applicant has not been criminally punished. At the same time, positive factors such as community service, responsibility to family, educational attainment, and fulfillment of tax obligations will also be considered. This guidance will apply to all pending applications and future new applications upon publication. This means that even if you filed your N-400 before August 15, 2025, the new criteria will apply at the time of your interview.
Neighborhood canvassing and social media review - new gateways
Along with the changes to the moral character test come two additional gateways: the first is the revival of neighborhood visits. According to a policy memo released on August 22, 2025, USCIS adjudicators have the authority under section 335(a) of the Immigration and Nationality Act (INA) to visit the neighborhood where a naturalization applicant lives, ask neighbors and landlords about the applicant's conduct and reputation, and interview co-workers and supervisors. This authority originally existed in the Immigration and Nationality Act but was rarely exercised for decades and has now been explicitly revived. If an officer questions an applicant's conduct, character, or reputation, he or she may initiate a home visit or further investigation. This can take place without prior notice and is aimed at gathering a comprehensive assessment of the applicant's physical presence, living arrangements, and surroundings.
The second is social media and increased ideological screening. On August 19, 2025, USCIS announced that it will consider ‘anti-Americanism’ as a material adverse factor in applications for discretionary benefits. Naturalization (becoming a citizen) is not typically classified as a discretionary benefit, so it's hard to assume that this guidance will translate directly into a reason to deny naturalization. However, there is a separate section of the Immigration and Nationality Act, Section 313(a), which prohibits citizenship for those who advocate the overthrow of the U.S. government or support totalitarian regimes. It's the flow through these two regimes that matters. USCIS is broadening the scope of its social media reviews across the board, and the trend is toward increased scrutiny of past statements and online activity. The term ‘anti-Americanism" itself is not clearly defined in the policy manual, raising concerns in the legal community that it leaves room for subjective interpretation by adjudicators.
Of practical importance to citizenship applicants is social media management. Even posts made in Korean can be reviewed through translation tools. Activity on Facebook, Instagram, and even Korean portals can be targeted. While the right to express political opinions is guaranteed by the First Amendment, how that expression is interpreted in a citizenship vetting is another matter. In the case of a neighborhood canvass, the apartment building superintendent or a flatmate may ask “what kind of person this person is and if they've ever caused any problems.” In heavily Korean-American neighborhoods like Flushing or Palisades Park, your reputation within the same community is important, so don't neglect your neighbors. It's still unclear how widely these two gateways will be applied in practice, but the mere fact that the policy exists means applicants should be prepared.
Tougher citizenship tests and citizenship revocation - harder to get and harder to keep
The new citizenship test is effective for N-400s received on or after October 20, 2025. The old test was 10 questions out of 100, with 6 questions answered correctly to pass. The new test will be 20 questions out of 128, with 12 or more questions answered correctly to pass. The questions are broader in scope, with a greater emphasis on history and government structure. There is still an exception for those who are 65 years of age or older and have been a permanent resident for at least 20 years, with 10 questions out of 20 special questions. The way the test is administered has also changed: examiners will end the test immediately if you get 12 questions right, and conversely, if you get nine questions wrong, you will fail. The increased difficulty of the test itself places an additional burden on non-English speaking Korean applicants. Not only has the number of questions doubled, but there are also more questions about specific events in U.S. history and the structure of the federal government, making it difficult to pass without adequate preparation. The USCIS official website offers 128 questions and answers for free, so it is recommended that you study systematically before applying if possible.
It's not just citizenship that has become more difficult to obtain - the denaturalization drive, which involves reviewing the eligibility of people who already have citizenship, is also expanding at an unprecedented scale. The Department of Justice (DOJ) officially designated denaturalization as a priority for the Civil Division on June 11, 2025, and subsequent reports have discussed internal guidance that expects each USCIS district office to refer 100 to 200 denaturalization cases per month in fiscal year 2026. This goal of up to 2,400 cases per year would represent a more than 20-fold spike compared to the historical average of just 11 cases per year from 1990 to 2017. In 2025, the Department of Justice filed 13 removal of citizenship cases and won eight of them. The legal basis for removal of citizenship is fraud, misrepresentation, or concealment of material facts in the process of obtaining citizenship. While the Supreme Court affirmed in Afroyim v. Rusk that citizenship cannot be revoked absent a voluntary relinquishment, revocation of citizenship based on flaws in the citizenship application process is not covered by this protection. The aggressiveness of the current administration's targets is evident when compared to the estimated 24 to 64 revocation of citizenship cases filed during the four years of the Biden administration, depending on the count. Whether or not you accurately reported your criminal or immigration history when you applied for citizenship can be revisited years later.
Closing remarks
Citizenship has long been considered the end point of the immigration process and the most secure status. But now is an unprecedented time when the threshold for obtaining it is rising, and even citizenship that has already been obtained is up for review. If you are a Korean American permanent resident considering citizenship, now is the time to apply. It's wise to start preparing before the standards are further tightened and before the processing time increases. The more precarious your green card status becomes, the greater the value of citizenship, which guarantees the right to vote and immunity from deportation. Before you file your N-400, you should make sure you have your tax filing records, traffic violation records, and immigration records in order, and study the 128 questions on the new citizenship test in advance. Specifically, we recommend keeping copies of your last five years of tax returns, traffic citation checks, immigration records (I-94), social media accounts organized, and proof of community involvement in one file. If you're nervous about an English-language interview, you should practice anticipated interview questions in advance and prepare honest and consistent answers to questions that may be asked in a morality screening - “Have you ever been fined,” “Have you ever been arrested,” “Have you ever failed to pay taxes,” etc. Meanwhile, even those who have already earned their citizenship should double-check the accuracy of their application and keep their documents safe and secure. What the law requires is not a perfect life, but a record of a life that has consistently honored the laws and values of this country.
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.
Law Offices of Jin Dong Cho
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