On June 11, 2025, the U.S. Department of Justice issued an internal memorandum on Civil Division enforcement priorities that included denaturalization as a top 5 priority.
The priorities laid out in the DOJ internal memorandum seem to expand the criteria beyond the scope historically pursued for denaturalization cases. The memorandum is ripe for abuse in turning the denaturalization process into a political weapon. The memorandum specifically prioritized the following individuals for denaturalization:
- Cases against individuals who pose a potential danger to national security, including those with a nexus to terrorism, espionage, or the unlawful export form the United States of sensitive goods, technology, or information raising national security concerns;
- Cases against individuals who engaged in torture, war crimes, or other human rights violations;
- Cases against individuals who further or furthered the unlawful enterprise of criminal gangs, transnational criminal organizations, and drug cartels;
- Cases against individuals who committed felonies that were not disclosed during the naturalization process;
- Cases against individuals who committed human trafficking, sex offenses, or violent crimes;
- Cases against individuals who engaged in various forms of financial fraud against the United States (including Paycheck Protection Program (PPP) loan fraud and Medicaid/Medicare);
- Cases against individuals who engage in fraud against private individuals, funds, or corporations;
- Cases against individuals who acquired naturalization through government corruption, fraud, or material misrepresentations, not otherwise addressed by another priority category;
- Cases referred by the United States Attorney’s Office or in connection with pending criminal charges, if those charges do not fit within one of the other priorities; and
- Any other cases referred to the Civil Division that the Division determines to be sufficiently important to pursue.
The memorandum goes on to state that the Civil Division retains the discretion to pursue cases outside of the above listed categories as it determines appropriate.
Denaturalization is the revocation of citizenship of a naturalized immigrant by the U.S. Government. The Immigration and Nationality Act (INA) authorizes denaturalization under two general grounds:
- Procurement of naturalization by concealing a material fact or by willful misrepresentation – Generally, a naturalized U.S. citizen can be denaturalized under this ground if:
- The individual misrepresented or concealed some fact;
- The misrepresentation or concealment was willful;
- The misrepresented or concealed fact or facts were material; and
- The individual procured citizenship as a result of the misrepresentation or concealment.
2. Illegal procurement of naturalization – Individual was not eligible for naturalization in the first place because he/she does not meet or fails to comply with all of the statutory requirements for naturalization (residency requirement, physical presence, lawful admission for permanent residence, good moral character, and attachment to the U.S. Constitution)
The burden of proof that the federal government must show for civil denaturalization is “clear, convincing, and unequivocal evidence which does not leave the issue in doubt” that the individual procured naturalization illegally and/or concealed or willfully misrepresented a material fact during the naturalization process. There is no statutory limitation for the federal government to pursue a civil denaturalization case.
Criminal Conviction denaturalization falls under 18 U.S.C. §1425, where the individual knowingly obtained or attempted to obtain naturalization through fraud. The denaturalization for a criminal conviction is subject to a ten-year status of limitation.
Given language barriers and vagueness of some of the questions asked during the naturalization process, many naturalized citizens may not even know that they had made minor or unintentional mistakes/omissions when completing their naturalization applications. For the 24.5 million naturalized U.S. citizens currently in the United States, the current Administration is sending an unwritten threat to tow-the-line and keep your opinions/views/comments to yourself, otherwise there will be consequences. It takes away the rights given to every person in the United States under the First Amendment of the U.S. Constitution. Since there is no statutory limitation on civil denaturalization, an individual who has become a U.S. Citizen through naturalization is always at risk of having denaturalization proceeding filed against him/her.
The One Big Beautiful Bill that President Trump signed into law on July 4, 2025, is a commitment of additional funding in the amount of $170.7 billion for immigration-related and border enforcement-related activities to the U.S. Department of Homeland Security (DHS) and its sub-agencies, including Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP), as well as the U.S. Department of Defense (DOD) and the U.S. Department of Justice (DOJ). A portion of this additional funding will undoubtable go to the DOJ for its’ denaturalization campaign. The Legislative and Judicial branches of the U.S. Government must step up to ensure the government is effective and ALL citizens’ rights are protected.
