The U.S. Department of Justice’s Civil Division has announced a renewed focus on civil denaturalization proceedings, according to a memorandum issued by Assistant Attorney General Brett A. Shumate. The directive outlines the division’s intent to pursue cases against individuals who obtained U.S. citizenship through unlawful means.
According to the memo, “The Department of Justice may institute civil proceedings to revoke a person’s United States citizenship if the individual either ‘illegally procured’ naturalization or procured naturalization by ‘concealment of a material fact or by willful misrepresentation.’ 8 U.S.C. § 1451(a).”
The memo specifies that “the benefits of civil denaturalization include the government’s ability to revoke the citizenship of individuals who engaged in the commission of war crimes, extrajudicial killings, or other serious human rights abuses; to remove naturalized criminals, gang members, or any individuals convicted of crimes who pose an ongoing threat to the United States; and to prevent convicted terrorists from returning to U.S. soil or traveling internationally on a U.S. passport.”
It adds that “at a fundamental level, it also supports the overall integrity of the naturalization program by ensuring that those who unlawfully procured citizenship—including those who obtained it through fraud or concealment of material information—do not retain the benefits of such unlawful procurement.”
To guide its enforcement efforts, the Civil Division has established ten priority categories for denaturalization cases. The memo states, “The Civil Division shall prioritize and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence. To promote the pursuit of all viable denaturalization cases under 8 U.S.C. § 1451 and maintain the integrity of the naturalization system while ensuring the appropriate allocation of resources, the Civil Division has established the following priority categories for denaturalization cases.”
These categories include individuals posing national security risks, such as those involved in terrorism or espionage; perpetrators of war crimes and human rights violations; and members of criminal gangs or drug cartels. The list also includes individuals who committed undisclosed felonies, violent crimes, or financial fraud—including cases related to the Paycheck Protection Program (PPP) and Medicaid/Medicare fraud. Additionally, cases involving fraud against private entities, government corruption, and referrals from U.S. Attorney’s Offices are prioritized.

The memo clarifies that these categories are “intended to guide the Civil Division in prioritizing which cases to pursue; however, these categories do not limit the Civil Division from pursuing any particular case, nor are they listed in any specific order of importance.”
It further states, “The Civil Division retains the discretion to pursue cases outside of these categories as it deems appropriate. The assignment of denaturalization cases may be made across sections or units based on experience, subject-matter expertise, and the overall needs of the Civil Division.”
This structure allows the division to address a wide range of violations and allocate resources efficiently. The Civil Division plans to collaborate with other DOJ components and federal agencies to identify and pursue viable cases, signaling a robust enforcement effort. This initiative is expected to lead to an increase in denaturalization cases in the coming months.
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