Naturalization, a legal process established by Congress for noncitizens to become U.S. citizens, will now involve additional scrutiny of personal “moral” attributes, such as family, finances and employment.
Under Section 316(a)(3) of the Immigration and Nationality Act (INA), a lawful permanent resident must have “been and still is a person of good moral character” during the statutory period—typically three years (for spouses of U.S. citizens) or five years for other applicants—evaluated by a preponderance of the evidence standard, which means more likely than not true.
The current administration has emphasized a policy shift from a checklist for naturalization applicants to a holistic evaluation. On Aug. 15, 2025, The U.S. Citizenship and Immigration Services (USCIS) issued a pivotal policy memorandum (PM-602-0188) instructing officers to adopt a rigorous, holistic and comprehensive approach toward assessing good moral character (GMC), moving beyond a simple checklist of disqualifiers toward a full evaluation of each applicant’s character and contributions.
This shift restores pre-1990 practices that emphasize positive traits, such as rehabilitation, education, community involvement, family responsibility and financial responsibility—factors that were historically considered but diminished in recent years by more procedural approaches.
USCIS now explicitly directs adjudicators to assess favorable personal attributes including sustained community involvement, family caregiving and responsibilities, educational attainment, stable and lawful employment, length of lawful residence, compliance with tax obligations and financial accountability, etc. Combined, these reinforce the broader expectation that citizenship reflects not only legality but a civic and moral commitment.
Heightened Scrutiny of Disqualifying Conduct
Simultaneously, USCIS is intensifying review of disqualifying behaviors, including both permanent bars—such as murder, aggravated felonies, genocide, torture—and conditional bars, like controlled substance violations, multiple DUI convictions, false claims of U.S. citizenship or unlawful voting.
Media and legal professionals are raising concerns about the subjectivity of the new GMC policy. Critics argue that vague standards could disproportionately affect lower-income or marginalized applicants, introducing inconsistency in decision-making. Notably, even conduct that—while legal—may contravene societal norms (e.g., repeated traffic violations or aggressive solicitation) might now be weighed unfavorably.
Moreover, USCIS has revived field verifications, interviewing neighbors or coworkers as a form of background check traditionally used under earlier administrations. These measures underscore a transition from service-based adjudication to an enforcement-first model.
The recent shifts are part of a broader enforcement posture. USCIS now plans to hire armed law enforcement agents empowered to investigate and arrest individuals suspected of immigration fraud, including abuses tied to naturalization like sham marriages or misrepresentation.
What This Means for Prospective U.S. Citizens
As of September 2025, the naturalization process requires more than clean records—it demands affirmative evidence that applicants embody the civic and moral standards of their communities. Positive personal contributions now weigh just as heavily as the absence of disqualifying conduct.
At the same time, USCIS is increasing enforcement efforts, including the deployment of armed agents and the resumption of surveillance tactics, to combat fraud. This dual-track shift reflects a fundamental philosophical change: naturalization is framed not merely as a benefit earned through compliance, but as a privilege earned through demonstrable moral worthiness.
For those seeking U.S. citizenship, it would be worthwhile to consider a full view of your involvement in the community, your personal activities, including any work or education-related contributions or involvement that may shed a favorable light on your naturalization application.
Barbara Wong-Wilson is an attorney at Mission Law & Advocacy, P.C. and SW Law Group P.C. wo**@*********ws.com.
