What you need to know about the Trump administration’s recent focus on denaturalization
Recently, the Department of Justice (DOJ) published a memo listing out its priorities for civil enforcement cases. In that memo, the DOJ states that it will be focusing on denaturalization cases. This memo - along with statements made by administration officials and members of congress - has sparked a lot of attention on denaturalization and questions about who could be denaturalized. This has caused a lot of fear and uncertainty in communities, but denaturalization is not as straightforward as you might think.
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What is denaturalization?
Denaturalization is a process by which the federal government can take back a naturalized citizen’s U.S. citizenship where the government can show “sufficient evidence” that the person is subject to a ground of denaturalization - mainly that they were naturalized when they were not actually eligible. Historically, denaturalization has been used in rare instances where people had concealed their identities in order to obtain citizenship. However, over the past two decades, the federal government has expanded its priorities as to who can be denaturalized and increased its resources to target more people for denaturalization as part of larger anti-immigrant enforcement measures.
How many people are actually denaturalized every year?
It’s unclear because there isn’t any public place where denaturalization cases are posted, however the actual number of denaturalization cases per year tends to be in the tens, rather than the thousands. For example, from 1990 to 2017, an average of 11 denaturalization cases were opened per year. There was an uptick during the first Trump administration to about 25 cases per year, which was a significant increase, but still kept the actual number of cases low, despite many more resources funneled to denaturalization cases.
How does denaturalization work?
The primary question in any denaturalization case is whether the naturalized citizen was eligible to naturalize at the time they were granted citizenship. Specifically, when the government brings a denaturalization case against someone, they are alleging that the person did not meet all of the naturalization requirements when they applied for citizenship, but that naturalization was granted anyway.
The allegation by the government is frequently that the citizenship was obtained through the applicant’s fraud or misrepresentation. Put another way, a person may be subject to denaturalization for misrepresentation or concealment of a fact that was material to them obtaining citizenship.
Denaturalization cases can be either civil cases or criminal cases. While criminal denaturalization cases can only be brought within ten years of the date that the person obtained naturalization allegedly unlawfully, the government can begin a civil denaturalization case at any point regardless of how long the person has been a citizen. Both types of cases must be brought by the U.S. Attorney’s Office (USAO) and filed in federal court. A federal agency cannot revoke a person’s citizenship on its own.
Denaturalization cases often start with the Department of Homeland Security (DHS) referring a case to the USAO who then decides whether or not to pursue the case. If a person is to be denaturalized - no matter whether it is a criminal or civil case - that decision must be made by a federal judge after the person has been given the opportunity to present their case against denaturalization. Because each case must be heard by a judge, there are significant resources needed to bring each denaturalization case.
The Department of Justice (DOJ) routinely sets out priorities for which types of cases it will prioritize for denaturalization. Previously, the DOJ priorities for denaturalization included those who were threats to public safety or national security, those who engaged in war crimes, and those who committed serious felonies before naturalizing and did not disclose them on the application. However, on June 11, 2025, the DOJ published a memo outlining its priorities for civil enforcement cases, which included expanded categories of people the DOJ will consider for denaturalization.
What is in the June 2025 DOJ policy memo?
The memo lays out new categories of people who could be prioritized for denaturalization.
The previous priorities are still listed, but the memo adds:
- Those who furthered the interests of gangs or cartels;
- Those who committed human trafficking offenses;
- Those who committed crimes of fraud including financial fraud against the United States and private individuals and companies; and
- Those who obtained naturalization through fraud or government corruption.
The memo also leaves room for the DOJ to prioritize cases where there are related criminal charges or any case that the DOJ considers important. Overall, DOJ officials have a lot of discretion on whether to bring a denaturalization case.
Will the Trump administration really start prioritizing denaturalization cases?
The new DOJ memo represents an expansion of the types of cases the government may be considering for denaturalization. Considering the other actions that the Trump administration has taken since taking office in January 2025, and the pattern from the first Trump administration, it’s possible that we could see more people targeted for denaturalization in the next few years. For example, during the first Trump administration, the government created a denaturalization task force for the purpose of flagging, reviewing, and investigating possible fraudulent cases.
HOWEVER, as explained in this resource, denaturalization is a complicated process that involves a lot of resources from the federal government, which historically has kept the number of denaturalization cases low. Whether the Trump administration will use significantly more resources in this area remains to be seen, but without significant additional investment, it’s hard to see how the numbers of cases could increase much beyond where they are now.
What should I do now?
It is too soon to tell how the Trump administration’s priorities will be put into practice. For naturalized citizens, there has been no change to your rights as a U.S. citizen. This includes your right to travel abroad and return to the United States. Remember - your citizenship cannot be unilaterally revoked by any one federal agency and you are entitled to re-enter the United States as a U.S. citizen. However, a person subject to denaturalization in civil proceedings is not entitled to a government-appointed attorney, which raises concerns about the potential for due process violations. It is recommended that you consult with an immigration attorney or qualified legal representative if you are concerned about your risks for denaturalization.
For prospective naturalization applicants, the law and eligibility requirements for naturalization have not changed! Changing who is eligible for naturalization requires Congress to pass legislation, which has not happened. It is recommended that you consult with a trusted legal representative before filing your application. You can find resources and organizations that can help you with your naturalization application through the New Americans Campaign.
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