AIS Statement: Survivors of Domestic Violence, Sexual Assault, Human Trafficking and other Gender-Based Violence Need Practical Policy, Not Reactive Measures
Halting benefit processing for some countries means prolonged danger, instability, and trauma, not safety
December 19, 2025 — The Alliance for Immigrant Survivors strongly opposes the Department of Homeland Security’s recent decision to halt immigration benefit processing following the tragic shooting over the Thanksgiving holiday. While violence must always be taken seriously, the agency’s imposition of blanket interruptions to immigration benefit processing in response to the actions of a single individual is a sweepingly reactive measure that will not improve public safety. Instead, it places immigrant survivors of gender-based violence, including asylum seekers fleeing gender-based persecution, at heightened risk by cutting off timely access to protection, stability, and due process.
The administration has frozen all asylum adjudications and halted U.S. Citizenship and Immigration Services (USCIS) benefit processing for individuals from the 19 countries named in the travel ban proclamation issued earlier this year. The latest proclamation issued on December 16 is likely to expand the scope of impact to additional countries. The administration has also announced its intention to review and reassess cases the government has already approved over the past several years.
“Halting processing in response to a single act of violence puts survivors of domestic violence, sexual assault, and human trafficking at even greater risk,” said Alexander Delgado, Director of Policy, Esperanza United. “For many survivors, delays mean prolonged danger, instability, and trauma, not safety.”
This is not a narrow or targeted action. The blanket freeze of adjudications affects the full spectrum of immigration benefits, including asylum applications, VAWA self-petitions; U and T visa petitions (including, potentially, bona fide determinations); work authorization; adjustment of status; and naturalization. In addition, the memorandum contains no exceptions for minors, suggesting that Special Immigrant Juvenile petitions may also be impacted. As a result, individuals who have complied with the law and timely filed applications may nonetheless languish without status or fall out of valid status solely because the government is refusing to adjudicate their cases.
Survivors of gender-based violence from countries listed in the travel bans are unnecessarily punished by a policy that treats nationality as a proxy for danger rather than assessing individual risk. The rationale for targeting specific countries is opaque and structurally flawed, relying on generalized country conditions and information gaps rather than evidence of actual threats. In effect, the policy punishes individuals for the failures of their governments—governments many survivors are actively fleeing. As a result, survivors who have already undergone rigorous screening are blocked from accessing asylum, lawful status, and work authorization, cutting off pathways to safety, economic independence, and long-term stability while advancing no credible national security benefit.
The duration of the freeze remains unclear. Meanwhile, backlogs continue to grow, interviews are being canceled, and, in some cases, naturalization ceremonies have been called off just days before individuals were scheduled to become U.S. citizens. While DHS has indicated that it intends to conduct a “comprehensive review” and issue further guidance within 90 days, there is no assurance that processing will resume at that time or that the freeze will not be extended or expanded.
Even once adjudications resume, survivors may face additional barriers. Recent changes to the USCIS Policy Manual instruct adjudicators to treat nationality from certain countries as a “significant negative factor” in discretionary determinations. These policies risk embedding bias into adjudications and further delaying or denying protection to individuals who are already subject to extensive vetting and screening.
Many of the immigrants impacted by these policies are survivors of domestic violence, sexual assault, trafficking, and other forms of gender-based violence. For these survivors, access to work authorization is not ancillary. The ability to work lawfully is essential to supporting themselves and their families, securing safe housing, and achieving economic stability and independence—cornerstones of survivor safety and long-term healing. When work permits are delayed indefinitely, survivors are pushed into financial precarity, dependence, and, in some cases, unsafe or exploitative situations.
“For survivors, time is not neutral. Administrative delays that push survivors out of lawful status or hinder their ability to support their families do not enhance public safety,” said Linda Phan, Policy Director, Asian Pacific Institute on Gender-Based Violence. “Instead, they increase vulnerability to detention, deportation, and over-enforcement by ICE, even when individuals have done everything required of them under the law. These outcomes compound trauma, place survivors at heightened risk of further harm, and erode trust in our justice and immigration systems.”
“Reactive, blanket measures do not make our communities safer,” said Cristina Velez, Legal & Policy Director at ASISTA. “They instead harm survivors who are already navigating violence, displacement, and uncertainty, and who rely on timely application processing and work authorization to rebuild their lives.”
The United States has long benefited from immigrants, asylum seekers, and refugees who support U.S. efforts abroad, contribute to local economies, and strengthen communities across the country. Policies should honor those contributions and uphold long-standing legal protections, rather than erasing them through sweeping suspensions that punish people based on nationality or circumstance.
“Public safety and protecting survivors are not competing goals. We can uphold security while maintaining asylum systems that are lawful and grounded in individualized assessments rather than reactive fear.”
The Alliance for Immigrant Survivors urges DHS to promptly restore asylum and immigration benefit processing and to pursue evidence-based approaches that protect survivors, honor due process, and uphold our legal and moral commitments, rather than relying on measures that deepen harm.