USCIS Issues New Guidance on Referring Naturalized Citizens for Denaturalization

In Policy Alert PA-2026-13, issued Sept. 14, 2026 and effective immediately, USCIS set out detailed guidance on when it refers naturalized U.S. citizens for revocation of naturalization — commonly called denaturalization — under INA § 340. This is Policy Manual guidance rather than a regulation, so it took effect without notice and comment. It reorganizes Volume 12, Part L, now retitled "Loss of U.S. Nationality and Revocation of Naturalization." The part that matters most to the families we work with is how a case comes to USCIS's attention in the first place. The guidance says USCIS may identify cases that potentially warrant revocation through an officer's review of an Alien Registration File (A-File), "including any application, petition, hearing, or other proceeding before USCIS, such as a Petition for Alien Relative (Form I-130), Application for Certificate of Citizenship (Form N-600) ... or any other petition and application where U.S. citizenship is an eligibility criterion," and through "[a]utomated enhanced screening tools aimed at detecting fraud, national security, and public safety concerns." The policy alert states the point directly: for "any pending or future filed petition or application associated with a U.S. citizen, USCIS determines whether the petitioner lawfully obtained citizenship." So a naturalized citizen's own case can come under review because they filed a petition for a relative. The guidance then lists prioritized referral categories, beginning with national security and egregious public safety cases and running through war crimes and human rights violations, gang and cartel involvement, INTERPOL hits, felonies not disclosed during the naturalization process, human trafficking and violent crimes, financial fraud, false identity, false claims to U.S. citizenship, unlawful voting in U.S. elections before naturalization, and marriage fraud — and it closes with a catch-all permitting USCIS to refer other cases as well, so this list is illustrative of where USCIS says it is focusing, not a complete boundary on what can be referred. The counterweights are real and should not be lost in the alarm. USCIS cannot revoke anyone's citizenship. Revocation happens only in a federal district court — civilly under INA § 340 after the Justice Department files suit, or following a criminal conviction under 18 U.S.C. § 1425 — and in a civil case the government's burden is "clear, convincing, and unequivocal evidence, which does not leave the issue in doubt," a deliberately high standard. The alert states that the update "does not otherwise change the existing guidance describing the circumstances under which a naturalized citizen is subject to revocation," and the Policy Manual still says the government "generally cannot initiate revocation of naturalization proceedings against an individual who was eligible for naturalization when it was granted but committed crimes after naturalization." What changed is prioritization and referral process, not the legal grounds. Two timing points are worth knowing: civil revocation has no statute of limitations and may be sought at any point after naturalization, while criminal denaturalization carries a 10-year one — and USCIS says cases past that criminal deadline may still be referred for civil revocation. If you are a naturalized citizen preparing to petition for a relative and there is anything in your own immigration or naturalization history you are unsure about — an old filing, an answer you are not certain was complete, a marriage USCIS questioned — raise it with us before the petition goes in rather than after.