The United States Citizenship and Immigration Services (USCIS) has issued memorandum PM‑602‑0188, entitled “Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization”This directive marks a return to a totality-of-the-circumstances approach to assessing good moral character (GMC) under Section 101(f) of the Immigration and Nationality Act (INA).

What does this change mean?

Previously, especially since the 90s, GMC assessments tended to be rigid, based on the absence of certain predefined offenses or legal barriers. Under that model, only the absence of serious offenses was sufficient to meet the requirement.

With this new directive, officials must now consider both the negative and positive aspects of an applicant. This includes evaluating affirmative contributions, such as:

• Constant participation in the community
• family responsibilities
• Educational achievements
• Stable and legal employment
• Legal residence time in the U.S.
• Fiscal responsibility and tax compliance

New levels of scrutiny

Furthermore, the memorandum reinforces the analysis of behaviors that, while not necessarily criminal, may be considered contrary to moral character. Examples include:

• Repeated or dangerous traffic violations
• Harassment or aggressive solicitation
• Financial violations such as unpaid child support
• Substance abuse, repeated DUIs, or failure to comply with tax obligations

More equitable or potentially subjective approach

This change seeks to ensure that citizens reflect true civic values ​​and community responsibility, not just the absence of violations. However, it also significantly expands officers' discretion, which has led to criticism regarding possible inconsistencies or a lack of clarity in the process.