On August 22, 2025, U.S. Citizenship and Immigration Services (USCIS) released a policy memorandum signaling a significant shift in how it evaluates applicants for naturalization.  

Effective immediately, USCIS has resumed the ability to use  neighborhood investigations as part of its assessment of an applicant’s eligibility for U.S. citizenship—ending a long-standing practice of waiving such checks. 

A Brief Historical Background 

From 1802 to 1981, applicants for naturalization were required to present two witnesses who could testify to their qualifications for citizenship. Then, in 1981, Congress eliminated the requirement for witnesses, a change justified in part by the fact that a petitioner’s character could be better determined by an investigation, including a neighborhood investigation, if necessary.  

 By 1991, the former Immigration and Naturalization Service had essentially phased out the practice of conducting neighborhood investigations, as the agency relied on the Federal Bureau of Investigation (“FBI”) to conduct background backchecks.   

What’s Changing Now? 

Until this recent announcement, the USCIS has waived the requirements for neighborhood investigations and has relied largely on biometric checks and criminal history checks performed by the FBI to obtain information related to the applicant’s good moral character and eligibility for naturalization. 

However, with the release of this latest policy memorandum, the USCIS will now exercise its statutory authority and will immediately end the general waiver of neighborhood investigations to fully ensure that aliens applying for naturalization meet statutory requirements.    

 What Are “Neighborhood Checks?” 

USCIS may request information from individuals applying for naturalization to help determine whether to conduct a “neighborhood” investigation. This may include testimonial letters from neighbors, employers, co-workers, or business associates who are familiar with the applicant’s conduct, moral character, and other eligibility criteria relevant to the naturalization process. 

 Additional Updates Regarding “Good Moral Character” 

On August 15, 2025, the USCIS issued a policy memorandum focusing on the “good moral character” requirement for naturalization applicants. Under this updated guidance, the USCIS is restoring a “rigorous, holistic, and comprehensive” good moral character evaluation standard for applicants applying for naturalization.   

 The updated guidance notes that USCIS officers must account for an applicant’s positive attributes and not simply the “absence of misconduct.” Moving forward, there will be a greater emphasis on positive factors such as:  

• An applicant’s sustained community involvement and contributions 
• An applicant’s family caregiving, responsibility, and ties in the United States 
• An applicant’s educational attainments 
• An applicant’s stable and lawful employment history and achievements 
• An applicant’s length of lawful residence in the United States 
• An applicant’s compliance with tax obligations and financial responsibility in the United States  

Additionally, the updated guidance also broadens the scope of conduct that the USCIS officer may consider as disqualifying such as:  

• Permanent bars to good moral character such as murder, aggravated felony, crimes of violence, persecution, genocide, torture, or severe violations of religious freedom 
• Conditional bars to good moral character such as controlled substances violations, two or more convictions for driving under the influence (DUI), false claim to U.S. citizenship, unlawful voter registration, or unlawful voting 
• Any other acts that are contrary to the average behavior of citizens in the jurisdiction where aliens reside.   These could be actions that, while technically lawful, may be inconsistent with civic responsibility within the community, such as reckless or habitual traffic infractions, or harassment or aggressive solicitation.  
• Acts that are unlawful or contrary to the average behavior of citizens of the community in which the applicant resides.   

 Lastly, for applicants who have engaged in wrongdoing, the USCIS will focus on their rehabilitation and reformation.   This includes:  

• Rectifying overdue child support payments or other family obligations 
• Compliance with probation or other conditions imposed by a court 
• Community testimony from credible sources attesting to alien’s ongoing good moral character   
• Reformation or mentoring those with similar past 
• Full repayment of overpayment of benefits such as Social Security  
• Full payment of overdue taxes 

 What Applicants Should Know 

Submitting evidence of good-moral character proactively with the Form N-400 may assist USCIS in determining whether a neighborhood check is appropriate in a particular case.  If you are considering filing a naturalization application and have questions regarding the implementation and document requirements related to these recent policy changes, please contact qualified immigration counsel, such as Foster LLP.    

As these policies take effect immediately, applicants should stay informed and be well-prepared for any additional developments with the naturalization process. Foster LLP will continue to monitor changes in the naturalization process and will provide additional updates via our firm’s website at fosterglobal.com.