On August 15, 2025, the Department of Homeland Security published PM-602-0188, a Policy Memorandum with the subject, “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character
Evaluation Standard for Aliens Applying for Naturalization.”
KEY POINTS
- The evaluation of good moral character for naturalization applicants will now be a “holistic assessment” of a person’s behavior and adherence to societal norms.
- The assessment will not only check for an absence of disqualifying acts and negative factors but applicants will be required to show a “genuine positive assessment of character.”
- USCIS officers should consider how the applicant has lived in their community and whether they made positive contributions.
- USCIS officers are now explicitly directed to weigh all relevant evidence, both adverse and favorable, before making a decision.
- The standard of proof for all naturalization requirements, including GMC, remains a preponderance of the evidence, meaning an applicant must show it is “more likely than not” that they have met all requirements.
The policy memorandum from U.S. Citizenship and Immigration Services (USCIS) outlines a new more “comprehensive and holistic standard” for evaluating an applicant’s “good moral character” (GMC) for naturalization. Key points of the new policy include a new assessment of a person’s behavior looking for adherence to societal norms, and positive contributions, looking for more than just the absence of disqualifying acts and requiring a “genuine positive assessment of character”, USCIS officers are now explicitly directed to weight all evidence to determine if GMC is established by a preponderance of the evidence.
Changes and Potential Impacts on Applicants
- Holistic Evaluation: This policy signals a shift from a firm, checklist-based approach to a “totality of circumstances” approach. Before the 1990s, the evaluation was broader, and USCIS is now returning to that framework.
- Greater Emphasis on Positive Contributions: USCIS will place greater emphasis on an applicant’s positive attributes and contributions, such as sustained community involvement, family caregiving, educational attainment, a stable and lawful employment history, length of lawful residence, and compliance with financial obligations.
- Increased Scrutiny of Negative Behavior: While permanent bars like murder or aggravated felonies remain unconditional and permanent, USCIS will also focus greater attention on other potentially disqualifying behaviors. This includes conditional bars (e.g., DUI convictions, unlawful voting) and other acts that are “contrary to the average behavior of citizens” even if technically lawful, such as reckless traffic infractions or aggressive solicitation.
- Focus on Rehabilitation: The policy emphasizes that evidence of genuine rehabilitation for past wrongdoing may support a finding of GMC.
How Does This Change the Application Process
- Affirmatively Demonstrate Positive Character
Applicants should not rely solely on the absence of disqualifying acts. They must actively present their full story, showing how their life aligns with the ethical standards of their community and affirmatively demonstrate their positive character. - Provide Evidence of Positive Attributes
Applicants must provide, wit their N-400 Application, evidence of their positive attributes and contributions. This could include documentation of community involvement, educational achievements, stable employment, and a history of financial responsibility. - Address Past Issues with Evidence of Rehabilitation or Consider Waiting to Apply
If an applicant has a history of wrongdoing that does not bar them and they wish to apply they must first speak with an immigration attorney to assess the risk and if they proceed then they should provide evidence of rehabilitation. Examples of such evidence include proof of rectifying overdue child support or taxes, complying with probation, and obtaining community testimony from credible sources.
Any applicant with a criminal record, even if it does not disqualify them from naturalizing, should strongly consider waiting util Trump is no longer in office to apply for naturalization. - Be Prepared for Detailed Questions
USCIS officers will review all available documentation and may question applicants about the specific circumstances of their past actions to determine if they should be barred from naturalization. Applicants should be prepared to explain any past issues and demonstrate how they have reformed. You should speak with an attorney to get prepped for your interview even if you are going to attend the interview by yourself unrepresented.
Read the full Policy Memorandum from the USCIS website.
Learn more about Naturalization and the Good Moral Character requirement for US citizenship. Learn how to Prepare for the Civics Examination for Naturalization.
If you would like to consult an immigration attorney about the naturalization process you can schedule a virtual consultation.
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