Business Immigration Insights

Quick summary

 The White House has reinstated and significantly expanded travel restrictions affecting 19 countries, with full travel restrictions on 12 nations and partial restrictions on seven others. The proclamation took effect on June 9, 2025, at 12:01 AM EDT, but contains important exceptions.

On June 4, 2025, President Trump issued a proclamation outlining full and partial travel restrictions on 19 total countries, with some exceptions for certain visa holders or Lawful Permanent Residents.  The proclamation affects millions of people worldwide and is expected to draw legal challenges. For immigration practitioners, employers, and affected individuals, understanding the scope, exceptions, and practical implications of the proclamation is crucial.

Who Is Affected?

Complete Travel Restriction (12 countries): Citizens from the following countries face a full suspension of both immigrant and nonimmigrant visa issuance:

• Afghanistan
• Burma (Myanmar)
• Chad
• Republic of Congo
• Equatorial Guinea
• Eritrea
• Haiti
• Iran
• Libya
• Somalia
• Sudan
• Yemen

 Partial Restrictions (Seven countries): Citizens of these countries face suspension of immigrant visas and B-1/B-2 (business/tourist), F, M, and J (student/exchange) visas, with reduced validity periods for other categories:

• Burundi
• Cuba
• Laos
• Sierra Leone
• Togo
• Turkmenistan
• Venezuela

*Egypt remains under review and could be added to future restrictions.

Critical Exemptions

The proclamation includes several important exceptions for protected individuals, those in special visa categories and those granted an exception from the Attorney General or Secretary of State:

Protected Individuals:

• Lawful Permanent Residents (green card holders)
• Anyone physically present in the United States on June 9, 2025
• Valid visa holders as of June 9, 2025
• Dual nationals traveling on non-restricted country passports

 Special Visa Categories:

• Immediate relative immigrant visas (IR-1/CR-1, IR-2/CR-2, IR-5) with DNA evidence
• Afghan Special Immigrant Visa holders
• Adoption cases (IR-3, IR-4, IH-3, IH-4)
• Athletes competing in major sporting events
• Diplomatic visa holders (A, G, NATO, certain C visas)
• Refugees and asylees (though subject to separate restrictions)

 Case-by-Case Exceptions:

On a case-by-case basis review, the Attorney General and Secretary of State may grant exceptions where travel would advance critical U.S. national interests, including participation in criminal proceedings.

Timing and Scope

The ban applies only to individuals outside the United States on June 9, 2025, who do not have valid visas. No existing visas will be revoked solely due to this proclamation.

Periodic Review

The restrictions will be reviewed every 90 days initially, then every 180 days, potentially leading to modifications or removals from the list.

Legal Landscape and Challenges

The Supreme Court’s 2018 decision in Trump v. Hawaii may make it difficult for opponents to challenge this proclamation, as the Court upheld presidential authority under INA §212(f) for national security-based restrictions. However, such actions must be “justified and demonstrated by the administrative record,” so the Trump administration will likely need to demonstrate justification for this expansion to succeed in a legal challenge.

Immigration advocacy groups are already preparing legal challenges, and we anticipate court filings soon.

Practical Advice for Affected Individuals, Families and Employers

Immediate Actions

• Return to the United States Before June 9: Those currently abroad with valid status should consider immediate return
• Document Review: Make certain all immigration documents are current and properly maintained
• Legal Consultation: Seek immediate counsel to assess exception eligibility and strategic options

 Ongoing Considerations

• Travel Restrictions: Even exempt individuals may face increased scrutiny at ports of entry
• Family Separation: The proclamation may keep family members separated who are abroad and subject to restrictions
• Employment Impact: U.S. employers in healthcare, technology, and education sectors may face significant workforce disruptions

Current Visa Holders

While existing visas will not be revoked, renewal applications may be denied once current visas expire. Non-immigrant visa holders already in the U.S. who travel abroad would be subject to the proclamation when they try to return.

Economic and Humanitarian Impact

State Department data shows that in fiscal year 2023, nationals from the 12 fully banned countries received over 112,000 visas, while those from partially restricted countries received nearly 115,000 visas. The 19 affected countries represent over 475 million people.

Looking Ahead

This proclamation represents a shift in U.S. immigration policy and reasserts presidential authority under INA §212(f) to address national security concerns through targeted entry restrictions. Given the administration’s stated goal of expanding immigration restrictions, affected individuals and their legal representatives should anticipate continued policy changes and increased enforcement.

We will continue monitoring implementation details, court challenges, and any clarifying guidance from relevant agencies. For clients from affected countries, we recommend immediate consultation to assess individual circumstances and develop appropriate strategies.