On Dec. 16, 2025, the White House issued a presidential proclamation expanding restrictions on the entry of foreign nationals into the United States, advancing a policy framework rooted in national security considerations and data-driven assessments of vetting infrastructure in foreign countries. This development represents an extension of earlier travel and entry limitation policies, including Proclamation 10949, issued on June 4, 2025, which established broad entry restrictions on nationals from 19 countries.

Policy Scope and Expansion

Under the December 2025 proclamation, the United States continues and enhances entry limitations on some nations, based on criteria such as deficient civil documentation systems, lack of reliable law-enforcement cooperation, high visa overstay rates, and ongoing security challenges in certain countries. The expanded restrictions include the following elements:

  1. Continuation of full entry restrictions: The proclamation reaffirms and continues full restrictions on nationals from the 12 high-risk countries identified under Proclamation 10949: Afghanistan, Burma (Myanmar), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, and Yemen. These designations reflect long-standing concerns regarding screening deficiencies, security risks, and limited government cooperation with U.S. authorities.
  1. Addition of new countries under full restrictions: The December proclamation subjects nationals of five additional countries—Burkina Faso, Mali, Niger, South Sudan, and Syria—to full entry restrictions, based on updated assessments of civil documentation challenges, terrorist activity, and overstay data. The new proclamation also subjects individuals holding Palestinian-Authority-issued travel documents to full entry limitations, an expansion which reflects security concerns in areas with compromised vetting capacity.
  1. Transition from partial to full restrictions: The new proclamation sees nationals of two countries formerly under partial restrictions—Laos and Sierra Leone—subject to full suspension of entry, based overstay data and other considerations.
  1. Partial restrictions on additional countries: The updated proclamation imposes partial entry restrictions on 15 additional countries, including Angola, Benin, Cote d’Ivoire, Gabon, Nigeria, Senegal, Tanzania, Zambia, and others. Partial restrictions generally limit specific categories of visas (e.g., tourist or student visas), while preserving discretionary adjudications and case-by-case assessments for other categories.
  1. Retention and adjustment of prior restrictions: Several countries originally under partial restrictions—Burundi, Cuba, Togo, and Venezuela—remain subject to limited entry provisions. The White House lifted non-immigrant visa limits on Turkmenistan, previously under partial restrictions, due to productive engagement; still, immigrant entry remains suspended for Turkmen nationals.

Exceptions and Waivers

The proclamation includes specified exceptions for U.S. lawful permanent residents, holders of valid visas issued prior to effective dates, diplomats, certain categories of essential travelers (including athletes), and individuals whose entry is clearly in the national interest. Additionally, case-by-case waivers remain available for extraordinary circumstances, though family-based immigrant visa exceptions have been narrowed to address concerns about fraud risk.

Rationale and Administration Perspective

The White House frames the expanded entry restrictions as necessary to “protect the security of the United States” by preventing the admission of foreign nationals whose identities and backgrounds cannot be reliably verified due to systemic deficiencies in civil documentation, overstay trends, and limited information-sharing mechanisms from foreign governments. The proclamation notes that these measures and others may be a path forward for foreign cooperation on vetting and security protocols, while safeguarding domestic security interests.

Contextual Developments

This proclamation follows policy measures from earlier in the year. Those measures tightened vetting and suspended asylum and certain benefit processing for nationals from high-risk countries, following security incidents involving foreign nationals. The policies, taken together, may represent a broader strategy aimed at integrating national security considerations directly into immigration policy and adjudicatory practices across agencies.

Practical Implications for Stakeholders

  • Travelers: Nationals of fully restricted countries may face suspension of both immigrant and non-immigrant entry unless they qualify under specific exceptions or obtain waivers. Those from partially restricted countries may encounter heightened scrutiny and limited visa validity.
  • Employers and Educational Institutions: Organizations hiring or hosting foreign nationals may wish to reassess timelines for visa processing and international mobility planning, particularly for student, work, and exchange visitor categories.
  • Compliance and Legal Advisers: Immigration counsel and compliance professionals may need to update internal policies and client advisories to reflect the expanded scope of restrictions and emerging guidance from the Department of Homeland Security and the Department of State on implementation.

Conclusion

The December 2025 expansion of U.S. entry restrictions represents a shift in the intersection between immigration policy and national security enforcement. By broadening the list of fully and partially restricted countries and refining exceptions, the administration seeks to reduce security risk exposures while preserving targeted avenues for essential travel. Organizations and individuals affected by these changes should seek up-to-date guidance to help facilitate compliance and effective planning in a rapidly evolving regulatory landscape.

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Photo of Kate Kalmykov Kate Kalmykov

Kate Kalmykov is based in our New York and New Jersey offices and has over two decades of experience in business immigration matters. Kate currently Co-Chairs the Global Immigration & Compliance Practice at Greenberg Traurig. In this role, she works with employers of

Kate Kalmykov is based in our New York and New Jersey offices and has over two decades of experience in business immigration matters. Kate currently Co-Chairs the Global Immigration & Compliance Practice at Greenberg Traurig. In this role, she works with employers of all sizes across a variety of industries in understanding and complying with the immigration laws relating to the hiring and retention of foreign talent. Specifically, her practice focuses on supporting clients and advising them on temporary and permanent residency immigration options for multi-national executive, business, scientific, and information technology personnel. In addition, her practice provides support to companies in the global transfer of personnel. Known by her clients for her out-of-the-box thinking, responsiveness and hands-on approach, Kate is often called upon to assist in developing immigration options and strategies in the most unique circumstances and to respond to complex Requests for Evidence (RFEs), Notices of Intent to Deny (NOIDs) or to appeal denied cases. Likewise, she has also been instrumental in developing employer compliance programs for DOL related filings including H-1Bs and PERMs, as well as for I-9 employment eligibility verification. To this end, she develops and conducts nationwide I-9 compliance trainings and policy manuals for human resources personnel, advises on best practices for E-Verify employers, provides guidance on avoiding immigration-related unfair employment practices claims and has defended and minimized penalties in immigration-related government audits. Kate regularly works with professionals from the firm’s labor, employment, tax and benefits groups, to provide strategic planning on immigration issues within a cross-border framework.

Kate also has deep experience working on all aspects of the EB-5 immigrant investor program. Kate has worked with real estate developers, private equity funds, and other organizations on applications to designate new EB-5 Regional Centers, applications for pre-approval of EB-5 projects; having projects adopted by existing EB-5 Regional Centers; structuring projects to be EB-5 compliant, the sale of existing EB-5 Regional Centers, preparing template I-526 petitions and advice on structuring direct EB-5 projects. Pursuant to the requirements introduced under the EB-5 Reform and Integrity Act, Kate works with EB-5 Regional Centers, EB-5 Projects, Overseas Migration Agents and Broker/ Dealers to develop internal programs for ongoing compliance and to prepare USCIS I-956, I-956F, I-956,G, I-956H, I-956K submissions. Kate has represented thousands of investors in obtaining their green cards through EB-5 regional center projects, as well as direct EB-5 investment opportunities. She also represented and structured the largest EB-5 offering in the Program’s history and has over the course of her career structured over $12 billion in EB-5 deals.

Within the field of immigration law, Kate is a well-known speaker and author. She is often called upon by various media outlets to comment on topics of business immigration law including the Real Deal, the Wall Street Journal, and Law360. Kate has appeared on numerous TV programs related to immigration law including CNN, the Stoler Report, Vietface TV, and China Business Network. Kate is also a prolific writer on the topic of immigration and has been published in immigration practice handbooks for the American Bar Association, American Immigration Lawyers Association, ILW, and in news periodicals that include the New Jersey Lawyer, the New York Law Journal, the New Jersey Law Journal, USA Today, GlobeSt.com, and the Commercial Observer. At the request of the American Bar Association, Kate co-authored the book “What Every Lawyer Needs to Know About Immigration Law,” a guide for non-lawyers on immigration law practice. She has sat on numerous bar association related committees including the American Immigration Lawyers Association EB-5 Practice Committee, the New Jersey Business Immigration Coalition and has chaired the American Bar Association’s, Committee on Immigration and Naturalization, Section of Administrative Law since 2011. Kate has been recognized in various legal surveys including Chambers Global, New York Super Lawyers, the New Jersey Law Journal who ranked as her as a “New Leader of the Bar,” (formerly 40 under 40) in 2012, NJBIZ “Best 50 Women in Business,” 2019, National Law Review, “Go-To Thought Leader: Immigration Law,” 2022, and Lawdragon 500, Leading U.S. Corporate Employment Lawyers, 2020-2022.

Kate is devoted to pro bono matters and has spent extensive time helping clients fleeing conflict and persecution with asylum applications, applying for and obtaining Temporary Protected Status and Humanitarian Parole.