The Department of Homeland Security (DHS) through the US Citizenship and Immigration Service (USCIS) issued a policy in response to President Trump’s Protecting the American People Against Invasion Executive Order, EO 14159.
In order to formalize this program, USCIS issued an interim final rule (IFR) on March 12, 2025. The program begins effective April 11, 2025.
USCIS is requiring that all aliens 14 years of age or older who were not fingerprinted or registered when applying for a U.S. visa and who remain in the United States for 30 days or longer, must apply for registration and fingerprinting. Parents will be responsible to schedule their children’s registration and fingerprinting.
In addition, DHS is requiring that all noncitizens who move update their address with USCIS within 30 days of the move. Failure to register or update address information could render someone deportable.
Anyone who has applied for, and received, a benefit (i.e. visa or other status) from DHS, USCIS or the Department of State (DOS) and is over 14 years of age is already considered registered.
For instance, USCIS is considering the following individuals as already registered:
•Lawful permanent residents; •Aliens paroled into the United States under INA 212(d)(5), even if the period of parole has expired; •Aliens admitted to the United States as nonimmigrants who were issued Form I-94 or I-94W (paper or electronic), even if the period of admission has expired; •All aliens present in the United States who were issued immigrant or nonimmigrant visas prior to arrival; •Aliens whom DHS has placed into removal proceedings; •Aliens issued an employment authorization document; •Aliens who have applied for lawful permanent residence using Forms I-485, I-687, I-691, I-698, I-700, even if the applications were denied; and, •Aliens issued Border Crossing Cards.
The following individuals must apply for registration:
•All aliens 14 years of age or older who were not registered and fingerprinted (if required) when applying for a visa to enter the United States and who remain in the United States for 30 days or longer. They must apply before the expiration of those 30 days. •The parents and legal guardians of aliens less than 14 years of age who have not been registered and remain in the United States for 30 days or longer, prior to the expiration of those 30 days. •Any alien, whether previously registered or not, who turns 14 years old in the United States, within 30 days after their 14th birthday.
Once a noncitizen has been registered, DHS will issue evidence of registration. Noncitizens over the age of 18 must carry and keep this evidence of registration in their possession at all times.
For the most part, the enforcement of this law should not impact most noncitizen employees of religious institutes and sponsored ministries. However, these requirements may impact on the underage children of such employees who are not US Citizens and who may not be considered registered. Noncitizen employees should keep a copy of their I-94 in their person at all times.
In addition, in the IFR, DHS makes clear that DHS will prosecute cases of noncitizens who fail to update their addresses within 30 days of moving. Under 8 USC 1227(a)(3)(A-B), noncitizens who fail to update their addresses or register are subject to deportation. As a result, if a religious institute or sponsored ministry has noncitizen employees that have moved addresses, ascertain that an AR11 is submitted to update the address on file with USCIS. This requirement will exist until the person in question becomes a citizen.
Failure to comply with the requirements of the IFR will be treated as a civil and criminal enforcement priority for deportation.
Alien Registration Form and Evidence of Registration, RIN 1615-AC96, 90 FR 90 FR 11793 (Mar. 12, 2025). Click here.
Print Page
Email to a Friend