U.S. Citizenship and Immigration Services (USCIS) recently increased the scrutiny officers would apply in determining whether naturalization applicants can establish their necessary “good moral character” (GMC). The new Policy Memorandum, titled “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization,” marks a notable shift in how applicants for U.S. citizenship are evaluated — not just for past misconduct, but also for their positive contributions and overall character. While certain acts, set forth in INA § 101(f), will make the applicant ineligible to establish GMC, the new standard requires the applicant to proactively demonstrate certain positive set forth in the memo. The new memo has yet to be incorporated into the USCIS Policy Manual. 

What Changed? 

Establishment of good moral character during the required statutory period — typically three or five years preceding applying for naturalization — has been a requirement for obtaining U.S. citizenship since the Naturalization Act of 1790. But for the last 235 years, that requirement has been evaluated by checking for disqualifying conduct, such as certain criminal offenses, fraud, or other statutory bars. Absent such issues, applicants generally cleared this requirement.  

The new memo replaces that narrow checklist approach with a totality-of-the-circumstances, “holistic” standard. Officers must now, on a case-by-case basis, assess an applicant’s: 

• Behavior and societal adherence — how the individual has lived in their community; and 
• Positive attributes and contributions — such as family responsibility, educational achievement, community involvement, and financial responsibility.  

USCIS explains this shift aims to emphasize what applicants affirmatively contribute, rather than only what they have avoided doing. The examples of “positive attributes” the applicant should evidence include: 

• Sustained community involvement and contributions in the United States; 
• Family caregiving, responsibility, and ties in the United States; 
• Educational attainment; 
• Stable and lawful employment history and achievements; 
• Length of lawful residence in the United States; and  
• Compliance with tax obligations and financial responsibility in the United States.  

Why It Matters 

The new interpretive framework is subjective and gives officers more discretionary power that could introduce inconsistent or arbitrary decisions. The standard has shifted beyond basic non-misconduct — so much so that many U.S.-born citizens, if reviewed today, might not meet it. A USCIS spokesperson even characterized the change as a move to ensure “citizenship is granted to the world’s best of the best,” stressing a restoration of “integrity” in the system. 

Practical Implications 

Practitioners should be prepared to face much higher scrutiny when it comes to naturalization applicants’ ability to show GMC. In particular, practitioners should prepare their clients with negative discretionary factors, such as convictions, to face detailed questions from examining USCIS officers on those factors. Practitioners should also be prepared to argue how their client’s behavior is consistent with “the current ethical standards and expectations of the community in which they reside,” a standard likely to be ambiguously interpreted and applied. 

Naturalization applicants with multiple traffic offenses, for example, may expect to be found lacking good moral character based on one examining officer’s subjective interpretation of that local community’s ethical standards. Legal representatives can attempt to challenge that finding by preparing strong arguments ahead of the examination demonstrating how their client does, in fact, meet those standards. Evidence of rehabilitation or reformation will assist advocates in supporting such a finding. Someone with multiple past traffic offenses, then, might provide proof that they had complied with all court imposed conditions and that they had avoided additional traffic offenses for a certain amount of time. 

It remains to be seen how USCIS will implement this memo in practice. Therefore, advocates should keep abreast of reports from immigration law organizations and fellow practitioners to prepare as best as possible for how USCIS is currently interpreting and applying the policy memo. 

Broader Context 

This policy shift aligns with broader Trump administration themes of immigration tightening, increased scrutiny of applicants, and emphasis on subjective assessments of fitness for citizenship. Underlying executive orders and policy initiatives have stepped up enforcement, implemented “extreme vetting,” encouraged denaturalization, and raised standards across immigration pathways.  

Conclusion 

The memo does not merely tweak the “good moral character” requirement; it transforms it. By calling for a holistic, affirmative evaluation — balancing disqualifying conduct with civic contributions — USCIS elevates the bar for naturalization. Practitioners will need to make sure applicants are prepared to present evidence of these “positive attributes,” such as educational degrees, employment history, childcare responsibilities, community involvement, volunteer activities, and payment of federal taxes, when they appear for their interview.