Trump Administration Offers New Immigration Updates and Details

Our Immigration Team inspects the latest guidance and new policies from the Trump Administration and how they will affect travel for U.S. citizens, immigrants, and visitors.

• All noncitizens must carry evidence of legal status in the United States
• Parents must update their children’s status at age 14 or face fines and criminal penalties
• A potential travel ban may prevent entry for those who have traveled to or carry passports from a list of “red” and “orange” countries

The Trump Administration is continuing to expand its enforcement of U.S. immigration laws through more guidance for already released efforts and new policies that will ensnare both citizens and noncitizens.

• Form AR-11. The Administration has provided new guidance, including notice of new penalties, on the Form AR-11 change of address requirement that applies to all persons living in the United States except U.S. citizens. Effective date: April 11, 2025.
• Registration. The Administration has provided a fourth set of information on the alien registration program unveiled late last week. Parents must act on their child’s fourteenth birthday. Effective date: April 11, 2025.
• International Travel. The Administration is considering new travel bans, but even without them, travel to certain countries and nationals of certain countries may be impacted. In addition, the Administration announcement on increased vetting of noncitizens at U.S. borders has been reported in the news and sparked some concern about traveling to America.
• Electronic Device and International Travel. For anyone entering the United States, including U.S. citizens, U.S. Customs and Border Protection (CBP) has the authority to physically inspect electronic devices, including a review of its contents. No one is required to provide their passwords to CBP, but refusing to do so may result in possible consequences, such as device seizure or denial of entry.
• REAL ID. Applicable to everyone in the United States, including U.S. citizens, a REAL ID driver’s license or ID will be required to board a domestic flight, enter a federal building, or access limited facilities. Effective date: May 7, 2025.

Form AR-11

Within 10 days of moving to a new residence, all noncitizens must file a Form AR-11, Alien’s Change of Address Card, online or by mail to notify U.S. Citizenship and Immigration Services (USCIS) of the address change (A and G visa holders and visa waiver visitors are exempt). The failure to timely file the AR-11 now results in a fine of $5,000, imprisonment for up to 30 days, or both. Criminal sanctions can also be imposed for misrepresentations made in the AR-11 process. Non-citizens subject to this requirement include green card holders/permanent residents, non-immigrant visa classifications such as E, F, L, TN, H-1B, H-4, L, and TN, temporary protected status (TPS), asylees, refugees, and the undocumented.

Registration

Among other goals, the Administration is trying to get undocumented people to register and has made it a crime if they do not register. Non-citizens subject to this requirement include green card holders/permanent residents, non-immigrant visa classification such as E, F, L, TN, H-1B, H-4, L, and TN, TPS, asylees, refugees, and the undocumented.

Rule
Under this reinvigorated law (8 U.S.C. § 1302), all noncitizens aged 14 or older in the United States 30 days or longer who were not fingerprinted or registered when they applied for a U.S. visa or entered the United States must register. Most children who receive a visa abroad and enter the country under the age of 14 are not fingerprinted at the embassy issuing the visa or at entry. Non-citizens aged 14 or older, now or in the future, issued a green card/I-551, Form I-94 record, EAD-I-766, parolee status, Form I-862 Notice to Appear in immigration court, or Form I-221, I-865, or I-866 are deemed registered and that documentation is evidence of their registration. If a person has no such registration, the person must complete the online Alien Registration Form (more and updated information found here). Failure to register as an alien and to carry proof of registration is a federal crime and can result in a fine of $5,000, imprisonment, or both. Criminal sanctions can also be imposed for misrepresentations made in the AR-11 process.

Examples, including children

• If at age 16 a person received an H-4 visa, entered the United States, and was issued a Form I-94 valid for three years, then the valid/unexpired I-94 is the registration and is evidence of the registration, as well as evidence of legal status.
• If at age 26 a person received a green card/I-551 valid for 10 years, then at age 30 took a trip outside the United States and returned to the country with a valid/unexpired green card/I-551, then the valid/unexpired green card/I-551 is the registration and is evidence of the registration, as well as evidence of legal status.
• If at age 12 a person received an H-4 visa, entered the United States, and was issued an I-94 valid for three years, then the unexpired I-94 is only a registration until the child’s fourteenth birthday (even though the I-94 is evidence of legal status).
• If at age 13 a person received an green card/I-551 valid for 10 years, then the valid green card/I-551 is only a registration until the child’s fourteenth birthday (even though the green card/I-551 is evidence of legal status).
• If a Canadian citizen at age 45 enters the United States at a land border as a short-term visitor (business or tourism) and is not issued an I-94, then they are not registered. If they stay more than 30 days, they must register before the thirtieth day. Anyone can check to see if they were issued an electronic I-94 by visiting i94.cbp.dhs.gov.

Registration and child’s fourteenth birthday/parent obligation
Regardless of whether a child in the United States already has a valid I-94 or unexpired green card/I-551, upon the child’s fourteenth birthday, the parent (or guardian) has 30 days to register the child at my.USCIS.gov. Specifically:

• If the child is in the United States via a non-immigrant visa and was issued an I-94 at entry, upon the child’s fourteenth birthday, the parent (or guardian) has 30 days to register the child at the USCIS site.
• If the child was issued their green card/I-551 at the age of 13 or younger, upon the child’s fourteenth birthday, the parent (or guardian) has 30 days to register the child at the USCIS site.

The legal obligation, including consequences of the failure to comply, is on the parent to timely complete the registration for the child. The myuscis account for the registration must be in the name of the child. Penalties against the parent for failure to register the child at their fourteenth birthday include a fine of $5,000, imprisonment for up to 30 days, or both. Additionally, criminal sanctions can be imposed for misrepresentations made in the registration process.

Carry Evidence of Registration

All noncitizens age 18 and older are required to carry evidence of registration. Evidence of registration includes confirmation of the Alien Registration Form 325R completed online (via their myuscis account), green card/I-551, I-94 record, EAD-I-766, parolee, I-862 Notice to Appear in immigration court, and other forms. Failure to carry registration can result in a fine of $5,000 or imprisonment for up to 30 days and is a criminal offense that may result in expedited removal from the country.

REAL ID

The REAL ID Act requires a REAL ID–compliant driver’s license or another federally approved ID to board a U.S. domestic flight, enter federal buildings, and access certain secure facilities, effective May 7, 2025. This requirement applies to all persons, including U.S. citizens. To confirm what is a REAL ID and for more information, see www.dhs.gov/real-id.

International Travel

Documentation
Generally, for all persons, required international travel documentation includes: (1) a current, unexpired passport; (2) a visa or other entry documentation valid for the day of proposed entry; and (3) identity documentation such as a driver’s license or other government-issued ID. Persons concerned that at entry into a country an officer may seek confirmation of employment may carry an employment confirmation letter from their employer verifying the employment, dated within 30 days, or copies of two to three months of recent paystubs issued by their employer.

Certain countries
Persons who ever traveled to or were born in, are citizens of, or ever issued passports by “red” or “orange” countries (see list below) should anticipate that they will be impacted at arrival to the United States, including a review of luggage and being barred entry, sent to secondary inspection, or asked about the purpose of your trip, affiliations, family members, or names of business associates. If the purpose of the travel to one of these countries was business related, contact legal counsel for guidance before the travel and be sure to follow their guidance (which might include carrying explanatory documentation from your employer).

News
News outlets are carrying stories of people being barred from entry into a country, or potentially removed from a country based on the person’s alleged threats, social media postings, or visible or vocal opposition to persons or positions deemed protected or policies of a country. Be aware that enforcement agencies worldwide have access to much data. Legal guidance can only be given on a case-by-case basis, and note that typically, at the point of entry, officers prohibit access to a lawyer. Generally, in some cases a person may be able to withdraw the application for entry into the country (and then be required to board the next departing flight), exercise their right to remain silent, or provide an explanation (warning: depending on the facts, this could result in a permanent bar). If you have any concern, seek guidance before travel.

Potential Travel Ban

Even though the proposed travel ban and country list is a draft, travel to or from these countries will impact one’s ability to enter the United States. If the current draft proposal is adopted, travel to the “red” countries will bar entry into United States for an undisclosed period. Nationals from orange countries will require a meeting at the U.S. embassy before being able to enter the country. Yellow countries have alleged security deficiencies that must be cured within 60 days or the country will be added to the red or orange list.

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