Recent USCIS Memo On Good Moral Character For Naturalization (What It Changes And How To Prepare)
27 August 2025By New York Immigration Lawyer Alena Shautsova
On August 15, 2025, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0188, instructing officers to apply a rigorous, holistic “totality of the circumstances” review when deciding Good Moral Character (GMC) for naturalization. In plain terms: officers must now consider not only any negative conduct but also affirmative, positive contributions you can document—community involvement, family responsibilities, steady lawful work, education, and tax compliance, among others.
This memo operates within the long-standing statutory framework of the Immigration and Nationality Act (INA) and the USCIS Policy Manual. GMC for naturalization means character meeting the standards of the average citizen in your community, and it must be shown for the statutory period (generally 5 years; 3 years if applying based on marriage to a U.S. citizen) and up to the oath; however, conduct outside the period can still matter.
USCIS also reminds officers to build a full evidentiary record at interview, probing any criminal, unlawful, or questionable activity and assessing credibility. At the same time, the memo emphasizes weighing rehabilitation and positive equities—not just the absence of wrongdoing.
What Hasn’t Changed: Permanent and Conditional Bars
Some rules remain the same:
- Permanent bars: for example, murder or aggravated felony after 11/29/1990, forever preclude a finding of GMC.
- Conditional bars: apply to acts in the statutory period (for example, certain controlled-substance violations—including marijuana under federal law—multiple DUIs in the period, false testimony for an immigration benefit, unlawful voting or false claim to U.S. citizenship).
USCIS’s Appendix—Conditional Bars is a helpful quick reference for common pitfalls like false claim to citizenship, unlawful voter registration, or voting.
What Did Change: How Officers Weigh Your Life
Under the new memo, officers are explicitly directed to take a holistic view and give greater emphasis to positive attributes and contributions—such as sustained community involvement, caregiving responsibilities, educational attainment, stable lawful employment, length of lawful residence, and compliance with tax obligations—while also scrutinizing conduct inconsistent with civic responsibility (including patterns of reckless traffic behavior or aggressive harassment, even if not strictly criminal).
Bottom line: You should now come to your N-400 process ready to affirmatively prove who you are as a citizen-in-waiting—not just that you lack disqualifying offenses.
Practical Examples: A Document Checklist Aligned with the Memo & Policy Manual
1) Community Contributions & Character
- Letters on letterhead from nonprofit, school, union, house of worship, or community leader describing your role, dates, and impact.
- Volunteer logs; event programs listing your name; awards, certificates.
- Neighbor testimonials (specific, factual—not form letters).
Why it matters: Officers must weigh positive contributions in the GMC analysis.
2) Family Responsibility
- Proof of caregiving (elder care schedules, school correspondence about your children, medical appointment confirmations).
- Child support orders and payment history (including proof of curing any arrears).
Why it matters: Family responsibility and curing arrears are listed as affirmative equities and rehabilitation indicators.
3) Education and Employment
- Diplomas, transcripts, professional licenses, continuing-education certificates.
- Employment verification letters, W-2s, recent pay stubs.
Why it matters: Educational attainment and stable lawful employment are positive factors.
4) Taxes & Financial Responsibility
- IRS Account Transcripts for the statutory period; proof of payment plan and on-time payments if applicable.
- Business owners: payroll filings, sales tax filings, licenses.
Why it matters: USCIS highlights tax compliance and financial responsibility as affirmative evidence of GMC.
5) Criminal or “Unlawful Acts” Context (If Any)
- Certified court dispositions for every arrest/charge; probation completion proof; substance-abuse counseling certificates; victim impact program completions; ignition-interlock compliance; character letters showing rehabilitation.
- For DUIs: understand the rebuttable presumption problems when there are two or more within the statutory period; bring robust rehabilitation proof.
- For controlled-substance issues (including marijuana): federal law controls; be prepared for a conditional bar analysis.
Why it matters: Officers must elicit a complete record and weigh both adverse and favorable evidence.
6) Voting and Citizenship Claims
- State voter-registration screenshot/letter confirming no registration (or proof of cancellation) and no voting history if there is any doubt.
- If you mistakenly registered or voted, bring counsel and documentation; these are specifically analyzed in USCIS guidance.
“Unexpected but Useful” Preparation Tips
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Pull your state DMV driving record and resolve old fines.
Repeated reckless or habitual traffic infractions can be weighed negatively under the memo’s “contrary to average citizens’ behavior” language—even if not crimes. Bring proof you cured any issues. USCIS -
Run an IRS account check before you file.
Settle balances or get into a payment plan and bring transcripts and plan paperwork; financial responsibility is an express positive factor. USCIS -
Document “quiet” caregiving and community roles.
If you routinely drive elders to appointments or coordinate school events, capture it in writing (calendars, confirmations, letters). Officers now must factor these positive equities. USCIS -
If you have any arrest—ever—prepare to discuss it fully.
The interview is designed to elicit a complete record of criminal, unlawful, or questionable activity, even if it seems minor or was dismissed. Bring certified records and rehabilitation proof. USCIS -
Verify Selective Service and voter registration status in advance.
If applicable, secure a Selective Service status letter and voter-record letter. False claim to citizenship, unlawful registration, or voting are specifically analyzed in the Policy Manual’s GMC sections and appendix. USCIS -
Marijuana is still federal law.
Even if legal in your state, federal controlled-substance violations remain conditional bars in USCIS policy. Avoid new conduct and bring counsel if you have past issues. USCIS
How Long Does USCIS Look Back—and How Far Can They Reach?
USCIS assesses GMC for the statutory period and up to the oath, but may consider older conduct if relevant to who you are now (for example, to see whether you truly reformed). My prior explainer on “Unexpected Bars to Naturalization” discusses how USCIS can consider conduct beyond five years when evaluating present character.
Putting It All Together: A Preparation Roadmap
1. Before Filing N-400
- Order IRS Account Transcripts; resolve balances or start a plan.
- Pull DMV driving record; fix any open tickets.
- Confirm no voter registration (or bring proof of cancellation) and no voting unless you’re a U.S. citizen; collect official letters.
- Gather community/character letters and volunteer proof.
- For any arrests/charges: collect certified court dispositions and rehabilitation evidence; understand DUI presumptions.
2. At Filing
- Attach a concise GMC packet behind your N-400 exhibits: index + tabs for taxes, work/school, community letters, family responsibility, court records (if any).
- Consistency across all forms and records is crucial; the interview will probe discrepancies.
3. Before the Interview
- Refresh your memory with a personal timeline of residence, jobs, travel, and any incidents—so your testimony is complete and accurate.
- Update proof of current compliance (latest pay stubs, transcripts, payment-plan receipts).
Sources & Further Reading
- USCIS Policy Memorandum PM-602-0188 (Aug. 15, 2025), Restoring a Rigorous, Holistic, and Comprehensive GMC Evaluation Standard for Naturalization.
- USCIS Policy Manual, Vol. 12, Part F, Ch. 1 (Purpose & Background); Ch. 3 (Evidence & the Record); Part I, Ch. 4 (Permanent Bars); Part F, Ch. 5 (Conditional Bars); Policy Alerts on Controlled Substances (2019) and DUI (2019).
- Attorney commentary and explainers:
— Unexpected Bars to Naturalization: Good Moral Character (shaustova.com).
Shautsova Law
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