In August 2025, U.S. Citizenship and Immigration Services (USCIS) issued two significant policy memoranda that reshape how naturalization applications are evaluated. These changes mark a return to more discretionary and comprehensive assessments of applicants’ character and community ties, and they reintroduce neighborhood investigations that had largely been dormant for decades.
For individuals, families, and businesses navigating the U.S. immigration system, these updates carry important implications. At Berardi Immigration Law, we’re here to help you understand what’s changed and how to prepare.
What’s New: A Shift Toward Holistic Evaluation
The Good Moral Character (GMC) Memo
USCIS has restored a “rigorous, holistic, and comprehensive” standard for evaluating Good Moral Character (GMC) in naturalization cases. This marks a departure from the checklist-style approach that focused primarily on statutory bars to citizenship.
Under the new guidance, officers must assess the “totality of the circumstances” using a preponderance of the evidence standard. This means applicants must show that it is more likely than not that they possess good moral character, not just that they lack disqualifying conduct.
Positive factors USCIS may now consider include:
- Community involvement and contributions
- Family caregiving and responsibilities
- Educational achievements
- Lawful employment and financial responsibility
- Compliance with tax obligations
- Length of lawful residence in the U.S.
“Citizenship is more than a legal status, it’s a reflection of who you are and how you contribute to your community,” says Rosanna Berardi, Esq., Managing Partner at Berardi Immigration Law. “This policy change gives applicants a chance to show their full story, not just their record.”
However, the memo also emphasizes scrutiny of disqualifying behavior, including:
- Permanent bars such as murder, aggravated felonies, and crimes against humanity
- Conditional bars like drug offenses, multiple DUIs, and false claims to U.S. citizenship
- Conduct inconsistent with community norms, even if technically lawful
This last category introduces ambiguity. USCIS now considers whether actions are “contrary to the average behavior of citizens” in the applicant’s jurisdiction. Without a clear definition, this standard may vary widely and lead to inconsistent outcomes.
Applicants with past infractions may still qualify if they demonstrate genuine rehabilitation. USCIS will look for evidence such as:
- repayment of overdue taxes or child support;
- compliance with probation;
- community testimony; and
- mentorship of others with similar backgrounds.
The Neighborhood Investigations Memo
USCIS has also reinstated personal investigations under INA §335(a), ending the general waiver that had been in place for years. These investigations, often referred to as “neighborhood checks”, allow officers to gather information from an applicant’s community, including neighbors, employers, and co-workers.
While USCIS states that these investigations will be discretionary and case-by-case, applicants may be asked to provide contact information for individuals who can speak to their character and conduct.
This change raises privacy concerns and underscores the importance of preparing clients for potential inquiries. As Rosanna notes: “We’re advising clients to think carefully about who in their community might be contacted and what they might say. It’s better to be proactive than reactive.”
What Applicants and Practitioners Should Do
Given these changes, Berardi Immigration Law recommends the following steps:
- Document Positive Contributions: Include evidence of community service, family responsibilities, educational achievements, and employment history.
- Address Past Issues: If applicable, show rehabilitation through repayment of debts, compliance with legal obligations, and character references.
- Prepare for Interviews: Be ready to discuss why you want to become a U.S. citizen and what citizenship means to you.
- Upload Supporting Documents Early: Use the myUSCIS portal to submit evidence before interviews, especially in offices that request it.
- Know Your Local Office Trends: USCIS field offices may apply these policies differently. AILA liaisons can provide insights into local practices.
USCIS Naturalization FAQs
What does “average behavior of citizens” mean in the GMC memo?
USCIS has not defined this term. It may vary by location and officer interpretation. Applicants should be prepared to explain any conduct that could be viewed as inconsistent with civic norms.
Will everyone undergo a neighborhood investigation?
No. USCIS states these investigations will be discretionary and case-specific. However, applicants should be prepared for the possibility and consider who in their community might be contacted.
Should I submit evidence of good moral character with my application or wait until the interview?
It depends on your case and local office practices. Many officers appreciate when supporting materials are uploaded to the USCIS online account before the interview.
Stay Aware of Naturalization Changes
The USCIS memos from August 2025 signal a return to more nuanced and discretionary evaluations in naturalization cases. While this opens the door for applicants to present a fuller picture of their lives, it also introduces uncertainty and potential inconsistency.
At Berardi Immigration Law, we believe that every applicant deserves a fair and thorough review. Our team is here to help you navigate these changes with confidence and clarity.
For personalized guidance, contact us at (716) 634-1010 or book your consultation online.
Ready to have Berardi on your side?
Whether you’re a business looking to hire or a professional hoping to relocate, immigration law can be complicated. But you don’t have to do it alone. Put our experience to work for you.