USCIS Naturalization Overhaul: What’s New in Good Moral Character & Investigations

 In August 2025, U.S. Citizenship and Immigration Services (USCIS) issued two major policy updates that reshape how naturalization is evaluated—particularly in the areas of Good Moral Character (GMC) and personal investigations. These changes mark a shift toward deeper assessments of applicants’ characters and histories.

As a reminder, applicants for naturalization must have at least 5 years of lawful permanent residency in the United States (3 years of residency for certain spouses of U.S. citizens), 5 years of good moral character prior to filing of the application for naturalization, continuous physical presence in the United States as well as English language and civics requirements.

We focus in this article on changes recently announced by USCIS regarding good moral character determinations in naturalization applications.

 

1. USCIS Policy Memorandum: Rigorous Good Moral Character Evaluation

On August 15, 2025, USCIS released a policy memorandum titled “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization.” The memo directs officers to move away from a checklist-only approach and instead adopt a totality-of-circumstances framework when evaluating GMC under INA §101(f).

Key Shifts:

• From “absence of misconduct” to “presence of virtue.”
  Rather than simply ensuring applicants haven’t committed disqualifying actions, USCIS now will place greater emphases on evaluating positive contributions—like community involvement, family responsibilities, educational attainment, and financial responsibility—as affirmative evidence of GMC, even in the absence of any negative behaviors.
• Flexible discretion across statutory bar situations.
  While certain offenses—like murder, genocide, or aggravated felonies—remain permanent bars, other offenses (e.g., controlled substance violations, multiple DUIs, misrepresentation, unlawful voting) are conditional bars. Officers are now explicitly tasked to weigh both adverse and favorable evidence, considering rehabilitation when applicable.
• Rehabilitation and redemption matter.
  The memo encourages presenting evidence of positive change—such as child‐support compliance, court-ordered probation fulfillment, community testimonials, mentoring efforts, repayment of overpayments or taxes—as meaningful evidence of moral reform.

Implications:

• Applicants with past missteps may now demonstrate redemption. Genuine efforts to reform and contribute to the community can tip the scale in GMC determinations.
• Whether or not a naturalization applicant demonstrates enough “virtue” is now in the hands of the individual USCIS officers conducting the naturalization examination. Whether or not an application for naturalization will be successful potentially becomes much more subjective, and more likely to be based on individual officers’ explicit and implicit biases.

 

2. Resumption of Personal Investigations

On August 26, 2025, USCIS announced the Resumption of Personal Investigations for Naturalization Applicants as authorized by INA §335(a).  Prior to 1981, applicants for Naturalization had to present two witnesses who could testify to their qualifications for citizenship.  In 1981, Congress eliminated this requirement and indicated that a neighborhood investigation could be completed if necessary.

Most importantly, the use of personal investigations was essentially stopped by 1991. That is until now.

What This Means:

• Expanded background checks. USCIS may initiate interviews, home visits, or other investigative steps to verify the truthfulness and completeness of naturalization applications.
• Heightened scrutiny. Applicants should expect more thorough checks into their background, character, and credibility.
• End of General Waiver of Neighborhood Investigations. Instead, USCIS will make the decision to conduct or waive the investigation on an individualized discretionary basis after reviewing “relevant evidence”.

Implications:

• Applicants should be prepared for possible in-depth inquiries, especially those with inconsistencies or past incidents in their record.
• Those seeking to demonstrate GMC should ensure documentation is accurate, comprehensive, and ready for verification.
• Applicants should be prepared to submit additional statements or documents if requested prior to, at, or after their Naturalization interview.

 

3. Why Now—and What’s Next?

Together, these updates indicate a strategic pivot by USCIS toward a more subjective, and presumably, more restrictive character-based evaluation of naturalization applicants.

Moving forward, we anticipate that naturalization applicants may need both compelling narratives of moral character and verifiable documentation to support their claims.

 

Final Takeaway

The August 2025 memoranda appear to provide USCIS adjudicators with more discretion and flexibility in deciding who is worthy of U.S. citizenship.

Please reach out to the attorneys at Kolko & Casey, PC if you have additional questions regarding Naturalization and/pr would like a consultation with one of our experienced attorneys regarding your potential eligibility for Naturalization.