USCIS updates policy manual on denaturalization referrals, expands fraud-based triggers

On October 9, U.S. Citizenship and Immigration Services quietly posted Policy Alert PA-2026-13, revising Volume 12 of the USCIS Policy Manual. The update standardizes when USCIS officers must refer cases to the Department of Justice for possible **revocation of naturalization** under INA §340. Key changes include a new mandatory referral when an applicant obtained any immigration status by fraud—even if the statute of limitations for criminal prosecution has run— and when the underlying conduct **“could have influenced”** a naturalization decision. The alert also clarifies evidentiary thresholds, adds a 30-day supervisory review clock and requires field offices to track referrals in a centralized database shared with ICE. Naturalization revocation remains rare (just 192 civil cases since 2009), but the guidance signals a broader enforcement alignment with the DOJ’s Denaturalization Section. Naturalized employees under internal investigation—for example, after I-9 audits—may now face *dual jeopardy*: civil denaturalization and removal. For global-mobility and compliance teams, due-diligence files on long-tenured employees should be revisited, especially where initial visa entries involved third-party agents or questionable degree evaluations. Companies sponsoring citizenship workshops may need to build in a fraud-screening step and advise employees to seek counsel if any prior misrepresentation exists.