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The memo emphasizes a return to a totality-of-circumstances, holistic assessment under INA section 101(f), rather than a cursory checklist based solely on absence of wrongdoing. It reviews the pre-1990 discretionary approach, post-1990 statutory expansions and fixed bars, and explains the role of evidentiary standards, positive counterbalancing factors, and the “catch-all” clause when conditional bars apply.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/restoring-a-rigorous-holistic-and-comprehensive-good-moral-character-evaluation-standard-for-aliens-applying-for-naturalization-policy-memorandum/310253/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/restoring-a-rigorous-holistic-and-comprehensive-good-moral-character-evaluation-standard-for-aliens-applying-for-naturalization-policy-memorandum/310253.png","ImageObject",300,407,{"name":92,"@type":93},"Rhys","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-04","2026-09-20",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",17,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What does the memo require USCIS officers to do when evaluating good moral character for naturalization?","Question",{"text":113,"@type":114},"USCIS officers must use a holistic, totality-of-circumstances approach that considers both adverse and favorable evidence, including positive attributes and contributions, not just the absence of wrongdoing.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"How did the approach to GMC determinations change after 1990?",{"text":118,"@type":114},"Statutory changes expanded aggravated felony definitions and introduced fixed bars for certain issues, shifting policy toward a stricter checklist that relied more on statutory disqualifications than individualized consideration of circumstances.",{"name":120,"@type":111,"acceptedAnswer":121},"What legal framework governs how USCIS weighs evidence for naturalization, including GMC?",{"text":122,"@type":114},"Under INA 316(a) and 8 CFR 316.2, officers apply the preponderance of the evidence standard, weighing relevant evidence before granting or denying naturalization, while certain unconditional permanent bars remain without exceptions.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},310253,1790325876,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":19,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":52,"preview_page_count":4},687207024643,"https://ap-avatar.wpscdn.com/davatar_3d24733baf745e90a7e4bdd5f77d97b2","U.S. Citizenship and Immigration Services Office of the Director (MS 2000)  \nCamp Springs, MD 20588-0009  \nAugust 15, 2025 PM-602-0188  \nPolicy Memorandum  \nSUBJECT: Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization  \nPurpose  \nEvaluating aliens seeking to become naturalized is the most sacred and profound responsibility that U.S. Citizenship and Immigration Services (USCIS) is charged with performing. Becoming a naturalized U.S. citizen means being an active and responsible member of society instead of just having a right to live and work in the United States. Among other eligibility factors, aliens applying for naturalization must demonstrate that he or she has been and continues to be an individual of good moral character (GMC). Evaluating GMC involves more than a cursory mechanical review focused on the absence of wrongdoing. It entails a holistic assessment of an alien’s behavior, adherence to societal norms, and positive contributions that affirmatively demonstrate good moral character.  \nThis memorandum charters an improved direction for making GMC determinations and signals a return to a comprehensive, totality of circumstances approach to GMC under section 101(f) of the Immigration and Nationality Act (INA) .  \nAuthority  \n•  INA 101(a)(43)– Definition of“aggravated felony”  \n•  INA 103(a)– Powers and duties of the Secretary of Homeland Security  \nBackground  \nPre-1990 Discretionary Framework  \nBefore the early 1990s, INS officers determined GMC broadly through a model that treated the bars in INA 101(f) as the minimum disqualifiers, not as exclusive criteria. Officers considered  \nrehabilitative evidence, volunteer service, family responsibilities, and other positive traits in weighing GMC. 1  \nPost-1990 Statutory Changes  \nThe Immigration Act of 19902 expanded the definition of “aggravated felony” to include offenses committed on or after November 29, 1990, creating a permanent bar to GMC and moving away from considering individual circumstances for those convictions. Later, Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) 3 introduced fixed bars for issues like drug offenses, fraud, and misrepresentation, further pushing the policy toward a firm checklist that equated GMC with the absence of statutory disqualifications rather than the presence of positive moral conduct and character.  \nCurrent Legal Framework  \nUnder INA 316(a) and 8 CFR 316.2, officers apply the preponderance of evidence standard to all naturalization requirements. Although certain bars remain unconditional and permanent (e.g., murder, aggravated felony, torture and genocide) for which no exceptions exist, the statute also includes a “catch-all clause”, stating that an alien may lack good moral character even if he or she does not commit an offense within one of the nine enumerated classes.4 In assessing conditional bars officers have authority—and now explicit directive—to weigh all relevant evidence, both adverse and favorable, before granting or denying naturalization.  \nGMC Standard: Naturalization is envisioned not simply as a procedural immigration benefit—the greatest of all—but a significant legal transformation, an assimilation to a country that demands both allegiance and character. A step towards naturalization is determining whether an alien has met the requirement of demonstrating GMC. Section 316(a)(3) requires that an alien applying for naturalization “has been and still is a person of good moral character” during the statutory period. USCIS determines whether an alien has met the GMC requirement on a caseby-case basis. The standard of proof for all naturalization decisions, including GMC, is preponderance of the evidence. This means that aliens must show it is more likely than not that they have met all the requirements for naturalization.  \nThe regulations and policy affirm that GMC findings must go beyond the absence of disqualifyi","cbCaiqLIHRZkVTOQ","https://ap.wps.com/l/cbCaiqLIHRZkVTOQ","pdf",321873,"English","# Purpose\n## Authority\n# Background\n## Pre-1990 Discretionary Framework\n## Post-1990 Statutory Changes\n## Current Legal Framework\n# GMC Standard\n# Totality of Circumstances Approach","[{\"question\":\"What does the memo require USCIS officers to do when evaluating good moral character for naturalization?\",\"answer\":\"USCIS officers must use a holistic, totality-of-circumstances approach that considers both adverse and favorable evidence, including positive attributes and contributions, not just the absence of wrongdoing.\"},{\"question\":\"How did the approach to GMC determinations change after 1990?\",\"answer\":\"Statutory changes expanded aggravated felony definitions and introduced fixed bars for certain issues, shifting policy toward a stricter checklist that relied more on statutory disqualifications than individualized consideration of circumstances.\"},{\"question\":\"What legal framework governs how USCIS weighs evidence for naturalization, including GMC?\",\"answer\":\"Under INA 316(a) and 8 CFR 316.2, officers apply the preponderance of the evidence standard, weighing relevant evidence before granting or denying naturalization, while certain unconditional permanent bars remain without exceptions.\"}]","Restoring a Rigorous, Holistic, and Comprehensive Good Moral Character Evaluation Standard for Aliens Applying for Naturalization - Policy Memorandum | PDF",1789880278]