USCIS’s New Standard for Good Moral Character in Naturalization Cases

As an immigration attorney at SG Legal Group, I carefully monitor USCIS policy changes that can affect eligibility for naturalization. A recent USCIS policy memorandum on Good Moral Character (GMC) introduces a significant shift in how officers assess whether an applicant merits U.S. citizenship.

Rather than focusing solely on the absence of misconduct, USCIS now directs officers to take a “totality of the circumstances” approach—weighing both positive and negative aspects of an applicant’s life. The memorandum, available on the American Immigration Lawyers Association (AILA) website, replaces a checklist-style analysis with a more holistic one.

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A “Holistic” Evaluation of Character

Under this new guidance, officers must decide whether it is “more likely than not” that the applicant has demonstrated good moral character. This preponderance-of-the-evidence standard means applicants should show that they are worthy of assuming the rights and responsibilities of U.S. citizenship.

In other words, good moral character is no longer simply the absence of criminal or unethical conduct. USCIS now encourages officers to consider positive attributes such as:

• Consistent community involvement and contributions in the United States.

• Family caregiving, financial responsibility, and strong family ties.

• Educational achievement and career advancement.

• Stable, lawful employment history.

• Long-term lawful residence and integration.

• Compliance with tax laws and overall financial integrity.

While this approach allows for a more nuanced view of applicants, it also introduces greater discretion. The memorandum does not define how much community service, family involvement, or financial responsibility is “enough.” This can lead to inconsistent results between field offices or individual officers.

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Conduct That May Disqualify an Applicant

The memo reiterates that certain actions permanently or conditionally bar a finding of good moral character. These include:

• Permanent bars: murder, aggravated felonies, crimes of violence, genocide, torture, persecution, or severe violations of religious freedom.

• Conditional bars: drug offenses, multiple DUI convictions, false claims to U.S. citizenship, unlawful voter registration or voting, and other serious misconduct.

Additionally, USCIS may now consider “any acts contrary to the average behavior of citizens” in the applicant’s community. This vague standard may cover actions that are technically legal but socially unacceptable—such as reckless driving, harassment, or repeated minor offenses.

Because this “average behavior” test is undefined, officers may apply it inconsistently or even subjectively. As such, applicants and attorneys should prepare for broader questioning about lifestyle, responsibility, and civic engagement.

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Rehabilitation and Positive Evidence

If an applicant has prior misconduct or negative factors, the memo encourages officers to evaluate rehabilitation efforts and evidence of reform. USCIS will look for proof that the applicant has:

• Paid overdue taxes or child support.

• Completed probation or complied with all court orders.

• Repaid government overpayments or debts.

• Provided community or religious service.

• Received credible community testimony supporting their character.

• Mentored others or demonstrated reformation in a meaningful way.

In practice, this means that applicants with past issues can still succeed if they show a clear record of responsibility and community contribution.

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How I Advise Clients to Prepare

In my practice at SG Legal Group, I encourage clients to proactively gather evidence of good moral character before filing Form N-400. This may include:

• Tax transcripts for the statutory period showing full compliance.

• Employment verification letters confirming stability and good standing.

• Community letters from religious or nonprofit organizations.

• Proof of education or training, if relevant.

• Evidence of caregiving for family members.

Depending on the client’s background, I may recommend submitting these materials with the N-400 filing or uploading them to the USCIS online account before the interview.

Applicants should also be prepared to discuss their motivation for becoming a U.S. citizen, their understanding of civic duties, and any volunteer or community work they have done. Officers are increasingly asking such questions at interviews, reflecting USCIS’s emphasis on assimilation, allegiance, and positive engagement.

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Local Field Office Trends

Each USCIS Field Office may interpret the new standard differently. In my experience, offices in Maryland and the Washington, D.C. area often expect applicants to demonstrate community involvement, consistent tax compliance, and personal responsibility. Preparing clients for these discussions is key to avoiding delays or unexpected denials.

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What This Means for Naturalization Applicants

The 2025 GMC memorandum marks a fundamental change in how USCIS views moral character. It offers flexibility for well-prepared applicants with strong community and family ties—but also grants officers wider discretion to deny applications for vague or subjective reasons.

Applicants should not assume that a lack of criminal history automatically satisfies the good moral character requirement. A thoughtful presentation of positive contributions and evidence of rehabilitation can make a decisive difference.

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If You’re Applying for Naturalization

If you plan to apply for U.S. citizenship, I recommend consulting an experienced immigration attorney who can evaluate your record and help present the strongest possible case.

If you need experienced legal guidance for your naturalization or citizenship application, contact me at SG Legal Group. My team and I will help you navigate the process with confidence. Consultations are available in English, Russian, or Romanian.

Call 410-618-1288 or visit our contact page to schedule a consultation.

Disclaimer: This article provides general information and is not legal advice. For advice about your specific situation, please contact me directly.