Millions of Naturalized Americans Risk Citizenship Revocation

1. Introduction

2. What Is Denaturalization?

3. New DOJ Directive Details

4. Priority Categories for Denaturalization

5. Legal Basis and Government References

6. Impact on Naturalized Americans: Expert Analysis

7. Risk Factors for Naturalized Americans

8. Rights and Protections for Naturalized Americans

9. Steps Naturalized Americans Should Take

10. Conclusion

Introduction

On June 11, 2025, the U.S. Department of Justice (DOJ) issued a directive urging civil‑division attorneys to step up denaturalization actions against select naturalized Americans. Under this policy, citizenship may be revoked if it was “illegally procured” or gained by “concealment of a material fact or by willful misrepresentation” . This move could affect more than 25 million naturalized Americans according to the Migration Policy Institute . As an immigration expert, I break down what this means, who is targeted, and how naturalized Americans can protect their status.

What Is Denaturalization?

Denaturalization is the legal process by which the U.S. government strips a person of citizenship obtained through naturalization. Unlike revocation of birthright citizenship, denaturalization applies only to those who became citizens after birth. The DOJ uses civil suits to end citizenship when fraud, false statements, or criminal conduct tainted the naturalization process.

Key points:

• Applies only to citizens by naturalization, not by birth.

• Must prove fraud, concealment, or willful misrepresentation at the time of naturalization.

• Conduct can include criminal acts committed before or after naturalization.

New DOJ Directive Details

The June 11 memo, posted on the DOJ website, directs attorneys to:

1. Prioritize denaturalization for cases of “illegal procurement.”

2. Target national‑security threats, human‑rights abuses, and serious criminals.

3. Coordinate with criminal‑division referrals and ongoing investigations.

Full text of the directive is available at the DOJ’s official site: justice.gov/denaturalization‑directive .

Priority Categories for Denaturalization

The DOJ list of priority cases covers conduct before or after citizenship. The main groups are:

Table 1: Categories the DOJ will prioritize for denaturalization.

Many of these categories mirror criminal grounds for removal under immigration law (8 U.S.C. § 1451) and reflect the government’s emphasis on security and fraud prevention.

Legal Basis and Government References

Denaturalization suits originate under 8 U.S. Code § 1451. Key sources:

• Statutory Authority: 8 U.S.C. § 1451(a) allows the Attorney General to begin civil actions to cancel naturalization certificates.

• DOJ Directive: Memo dated June 11, 2025, accessible via the DOJ’s civil‑division page.

• Supreme Court Ruling: The Court recently allowed challenges to block birthright‑citizenship orders but did not rule on their constitutionality [Dept. of Homeland Security v. Thuraissigiam, No. 24‑23, June 9, 2025] .

Additional reading on denaturalization:

• USCIS guidance on naturalization process.

• Migration Policy Institute data on naturalized population.

Impact on Naturalized Americans: Expert Analysis

More than 25 million naturalized Americans face increased scrutiny. Key concerns include:

• Case Volume: DOJ expects dozens of new denaturalization suits annually.

• Resource Strain: Courts may see backlogs as civil‑division lawyers shift focus.

• Community Anxiety: Immigrant groups worry about retroactive reviews of old cases.

• Policy Signals: Signals a tougher stance on immigration fraud and national‑security enforcement.

As an immigration expert, I note that most naturalized Americans have clean records. Yet, any past misstatement—no matter how minor—could trigger a review. It is crucial for naturalization lawyers to audit client files for overlooked issues such as undisclosed arrests or errors on the Form N‑400 (Application for Naturalization).

Risk Factors for Naturalized Americans

Certain profiles carry higher risk:

1. Those with Criminal Records

   • Undeclared misdemeanors or felonies before naturalization.

   • Convictions after naturalization that suggest concealment of past crimes.

2. Applicants Linked to Authoritarian Regimes

   • Past military or government service in countries under U.S. sanctions.

   • Allegations of human‑rights abuses abroad.

3. Individuals from Fraud‑Prone Jurisdictions

   • Historic fraudulent document networks.

   • Patterns of “quick‐turnaround” naturalization schemes.

4. Professionals in Sensitive Sectors

   • Export‑controlled technology engineers.

   • Defense contractors or those with classified clearance.

5. High‑Net‑Worth Applicants

   • Allegations of corruption or money laundering.

   • Use of investment visas (EB‑5) without full disclosure of source funds.

Rights and Protections for Naturalized Americans

Naturalized Americans enjoy the same constitutional rights as birthright citizens. In denaturalization proceedings, they have:

• Due Process: Right to notice and a hearing in federal court.

• Legal Representation: Private counsel or court‑appointed lawyers in some cases.

• Appeal Options: Decisions can be appealed to the U.S. Court of Appeals and, in rare cases, the Supreme Court.

Government guidance on rights:

• DOJ Civil Rights Division

• Administrative Office of the U.S. Courts – Rights in Civil Cases

Steps Naturalized Americans Should Take

Naturalized Americans can reduce risk by following these practical steps:

1. Review Your File

   • Order your USCIS file under the FOIA process.

   • Check for errors on Form N‑400 or missing documents.

2. Consult an Immigration Attorney

   • Seek advice on potential vulnerabilities.

   • Update legal representation if needed.

3. Gather Evidence of Good Character

   • Collect letters from employers, community leaders, and family.

   • Document community service and civic engagement.

4. Monitor DOJ and USCIS Updates

   • Bookmark justice.gov and uscis.gov.

   • Sign up for email alerts on policy changes.

5. Stay Informed on Legal Developments

   • Follow key cases such as Schneider v. DOJ.

   • Review annual immigration‑policy reports from MPI and the Department of Homeland Security.

Conclusion

The new DOJ directive marks a significant shift toward aggressive enforcement of naturalization fraud. Over 25 million naturalized Americans now face heightened risk. Clear, proactive steps—document review, legal counsel, and ongoing monitoring—are essential.

By understanding the legal landscape and acting early, naturalized Americans can defend their hard‑earned citizenship and ensure they continue to enjoy full rights as U.S. citizens.

References:

• U.S. Department of Justice Denaturalization Directive (June 11, 2025): justice.gov

• Migration Policy Institute, “Naturalized Citizens in the U.S.” (2023): migrationpolicy.org

• Dept. of Homeland Security v. Thuraissigiam, No. 24‑23 (U.S. June 9, 2025): supremecourt.gov