On August 15, 2025, U.S. Citizenship and Immigration Services (USCIS) released Policy Memorandum PM-602-0188, announcing a significant change in how the agency evaluates good moral character (GMC) for naturalization applicants. This marks a return to a rigorous, holistic, and comprehensive standard, moving beyond the narrow checklist approach that has dominated much of the past three decades.
At Saluja Law, we see this as an important development for lawful permanent residents who aspire to become U.S. citizens. Below, we break down what this means, why it matters, and how it may affect applicants.
The Importance of Good Moral Character
Becoming a naturalized citizen is more than obtaining a legal status—it represents full membership in American civic life. Under the Immigration and Nationality Act (INA), applicants must prove that they have been, and continue to be, persons of good moral character during the statutory period.
Historically, this standard was not limited to avoiding crime or wrongdoing. It reflected a totality of circumstances approach: examining whether an applicant has lived as a responsible, contributing member of their community.
Shifting Standards Over Time
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Pre-1990s: Immigration officers had wide discretion. They considered not only statutory bars but also positive traits like community service, family responsibility, and rehabilitation.
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Post-1990: Congress expanded “aggravated felony” definitions and introduced fixed statutory bars (through the 1990 Immigration Act and IIRIRA in 1996). Officers increasingly equated GMC with simply avoiding listed disqualifications.
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Today: With this new memorandum, USCIS is returning to the broader vision of GMC—requiring a holistic evaluation that weighs both positive contributions and any negative conduct.
Key Elements of the New Policy
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Totality of Circumstances
Officers must evaluate not only adverse conduct but also the applicant's positive attributes. -
Emphasis on Positive Contributions
Favorable factors include:-
Community involvement and volunteer work
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Family caregiving and responsibilities
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Educational achievements
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Steady employment and lawful work history
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Compliance with taxes and financial obligations
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Scrutiny of Disqualifying Behavior
Permanent bars remain in place (e.g., murder, aggravated felonies, persecution, genocide, torture).
Conditional bars (e.g., multiple DUIs, controlled substance violations, false claims to U.S. citizenship) will still apply—but can now be evaluated alongside rehabilitation evidence. -
Rehabilitation Matters
Evidence of genuine reform can weigh in favor of an applicant. This includes repayment of debts or taxes, compliance with court orders, mentoring others, and strong testimony from community members.
Why This Matters
This policy shift could benefit applicants who may have past mistakes but have since shown long-term responsibility, stability, and contribution to society. It allows individuals to present their full story rather than being reduced to a checklist of disqualifications.
Case law, such as Hussein v. Barrett and Matter of Castillo-Perez, has long underscored that GMC should balance both negative conduct and positive contributions. USCIS's new directive aligns with this understanding.
What Applicants Should Do
If you are preparing for naturalization:
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Document positive contributions: Keep records of volunteer work, employment history, tax compliance, and family caregiving.
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Address past issues: Show evidence of rehabilitation, compliance with court orders, or repayment of obligations.
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Seek legal guidance: Each case is evaluated individually, and professional representation can help ensure your story is presented fully and persuasively.
Saluja Law's Perspective
At Saluja Law, we welcome USCIS's renewed commitment to a fair and comprehensive evaluation of naturalization applicants. Citizenship is not only about avoiding misconduct—it is about affirmatively demonstrating that one is prepared to assume the rights and responsibilities of being an American citizen.
We will continue to monitor how this policy is applied in practice and stand ready to assist clients in preparing strong, holistic applications that reflect both their challenges and their contributions.