Trump Administration Plans to Ramp Up Efforts to Strip More Foreign-Born Americans of Citizenship

The Trump administration is preparing to significantly expand efforts to revoke US citizenship from some naturalised Americans, according to internal government guidance obtained by The New York Times. The move signals a renewed and aggressive focus on denaturalisation—an uncommon but legally permitted process that strips individuals of citizenship after it has been granted.​

The guidance instructs US Citizenship and Immigration Services (USCIS) field offices to refer 100 to 200 denaturalisation cases per month to the Department of Justice’s Office of Immigration Litigation during the 2026 fiscal year, a sharp escalation compared to historical norms. If implemented as outlined, this would represent a dramatic increase from the 120 cases filed cumulatively from 2017 to the present.​

Understanding Denaturalisation: Legal Grounds and Historical Context

Denaturalisation is the legal process by which the US government revokes citizenship that was previously granted through naturalisation. Under US law, citizenship can be revoked through civil or criminal proceedings only under specific, limited grounds.​

Primary statutory grounds for denaturalisation include:

The federal government may pursue denaturalisation under 8 U.S.C. Section 1451 if a naturalised citizen’s citizenship was either “illegally procured” or “procured by concealment of a material fact or by willful misrepresentation.” Illegal procurement means the individual was not eligible for naturalisation in the first place because they failed to comply with statutory requirements such as residency or physical presence requirements, lawful admission, possession of good moral character, or demonstrated attachment to the Constitution.​

Alternatively, denaturalisation based on concealment or misrepresentation requires the government to prove four key elements: that the person misrepresented or concealed a material fact prior to naturalisation; that this misrepresentation or concealment was willful; that the concealed fact was material to the naturalisation decision; and that the misrepresentation or concealment resulted in the person’s naturalisation.

Historically, denaturalisation has been used sparingly and typically reserved for extreme cases, such as former Nazi collaborators or individuals who concealed serious crimes during the immigration process. However, the Trump administration has demonstrated an intent to expand the scope significantly beyond these historical precedents.​

The New Guidance: Scale and Scope

According to internal guidance released on Tuesday to USCIS field offices, the administration has instructed each field office to “provide the Office of Immigration Litigation with 100-200 denaturalization cases each month” for the fiscal year 2026. This volume, if sustained, would represent an extraordinary escalation compared to previous years, when denaturalisation cases numbered in the dozens annually nationwide.​

To contextualise the scope: during Trump’s first term, former Attorney General Jeff Sessions initiated investigations into 700,000 naturalised citizens with the goal of presenting around 1,600 cases in court. Despite these efforts, only 120 cases were filed cumulatively from 2017 through 2024, according to Justice Department data. The current guidance, if successfully implemented, would generate between 1,200 and 2,400 cases annually—a volume that would fundamentally transform denaturalisation from a rare enforcement action to a systematic programme.​

The Trump Administration’s Enforcement Priorities

The Trump administration has consistently taken a hardline stance on immigration, emphasising border security, reduced legal immigration, and tighter scrutiny of existing immigration benefits. During Trump’s first term, denaturalisation units were expanded within the Justice Department, and officials openly described citizenship as a “privilege” rather than an irreversible right.​

A June 11, 2025 memorandum from the Department of Justice further clarified the administration’s strategy. The memo instructs the Civil Division to “prioritise and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence,” with specific priority categories including:​

• Naturalised citizens who are members of terrorist organisations or present potential dangers to national security
• Naturalised citizens who have engaged in torture, war crimes, and other human rights violations
• Naturalised citizens who have furthered the unlawful enterprises of gangs, drug cartels, and transnational criminal organisations
• Naturalised citizens who committed felonies and failed to disclose their criminal history during the naturalisation process
• Naturalised citizens who committed human trafficking offences, sex offences, and other violent crimes
• Naturalised citizens who have committed financial fraud against the US government, including Medicare fraud, Medicaid fraud, and Paycheck Protection Program (PPP) fraud
• Naturalised citizens who have committed fraud against private individuals or certain organisations
• Cases referred in connection with pending criminal charges
• Other cases the DOJ determines to be “sufficiently important to pursue”

Who Could Be Affected?

The administration has not released comprehensive public criteria detailing which cases will be prioritised beyond these broad categories. However, based on the DOJ memo and past denaturalisation efforts, potential targets may include individuals accused of:​

• Lying on naturalisation applications
• Concealing criminal records or prior deportation orders
• Misrepresenting identity, marital status, or immigration history
• Failing to disclose eligibility issues during the naturalisation interview

Legal experts note that even relatively minor misstatements—if deemed “material”—can form the basis for denaturalisation, especially if prosecutors argue that truthful disclosure would have affected the original decision. This has raised concerns that long-settled immigrants, some of whom have lived in the US for decades, could face legal uncertainty over past paperwork errors or unintentional omissions.​

Legal Requirements and Evidentiary Burdens

While denaturalisation remains legally permissible, the law imposes significant requirements on the government. In civil proceedings, which the DOJ increasingly prioritises, the government must present “clear, convincing, and unequivocal evidence” that a person’s naturalization was procured illegally or through concealment or misrepresentation.​

The Supreme Court has further limited denaturalisation by requiring that the government not only demonstrate that an individual lied during the citizenship application process but also prove that the falsehood affected the underlying citizenship claim. This “materiality” requirement means that trivial false statements, without demonstrable impact, cannot serve as grounds for revocation.​

Furthermore, a Ninth Circuit decision established that administrative denaturalisation—removal of citizenship by agency action—is not permissible. Instead, revocation of citizenship can only occur in federal district courts, where naturalized citizens (in civil cases) can defend their status, though civil denaturalisation proceedings do not guarantee the right to a taxpayer-funded attorney.​

Civil Liberties and Legal Concerns

Immigration advocates and civil liberties groups have expressed alarm at the scale suggested by the guidance. They argue that denaturalisation, while legal, should remain exceptional due to the profound consequences it carries. Loss of citizenship can lead to:​

• Deportation and separation from family
• Loss of voting rights and social benefits
• Potential statelessness in extreme cases
• Loss of travel and work authorisation

Critics also warn that aggressive denaturalisation could create a two-tier citizenship system, where naturalised Americans feel less secure in their status than US-born citizens. Several legal scholars have pointed out that naturalisation has long been understood as a permanent step, not a conditional one subject to ongoing review based on evolving government standards.​

Additionally, experts have flagged concerns that the reliance on civil rather than criminal proceedings—where defendants are not guaranteed counsel—could disadvantage vulnerable populations. This procedural shift represents what one senior immigration litigator called “a quiet but significant” alteration in denaturalisation enforcement.​

Government’s Likely Justification

From the administration’s perspective, the policy is expected to be framed as a law-and-order initiative aimed at protecting the integrity of the immigration system. Officials are likely to argue that citizenship obtained through deception undermines the legitimacy of naturalisation and disadvantages lawful applicants who followed proper procedures.

A USCIS spokesperson stated: “It’s well-known that USCIS’s efforts against fraud prioritise those who’ve unlawfully obtained U.S. citizenship. We will pursue denaturalization proceedings for those individuals lying or misrepresenting themselves during the naturalisation process, and we are eager to collaborate with the Department of Justice to uphold the integrity of America’s immigration system.”​

Supporters of the policy argue that revoking fraudulently obtained citizenship protects the naturalisation system and ensures fairness for those who followed the law. Mark Krikorian, executive director of the right-leaning Center for Immigration Studies, has stated that casting a wider net in search of fraud is a logical approach: “It’s about ensuring the rules are enforced as intended. It must be broad because the entire immigration system has been excessively lenient.”​

Political and Social Implications

The guidance comes amid an already polarised national debate over immigration, citizenship, and national identity. Immigration policy remains a central issue for the Trump administration’s political base, and tougher enforcement measures could play well with supporters ahead of future electoral cycles.​

At the same time, the plan risks energising opposition from immigrant communities, civil rights groups, and Democratic lawmakers, who may challenge the policy through courts or legislation. For millions of naturalised Americans—particularly those who experienced bureaucratic delays or language barriers during their naturalisation interviews—the announcement alone may generate anxiety, even if only a fraction are ultimately affected.​

The policy also intersects with broader Justice Department reforms under the Trump administration, including efforts to curtail diversity, equity, and inclusion programmes and challenge race-based policies, suggesting that immigration enforcement is part of a larger ideological transformation.​

Implementation Challenges and Realistic Outcomes

Denaturalisation cases are complex, resource-intensive, and often contested aggressively by defence attorneys. The government must navigate federal courts and meet rigorous evidentiary standards. To date, the administration’s 2025 efforts have resulted in 13 denaturalisation cases filed, with eight victories, according to Justice Department data.​

While the targets of 100-200 cases per month represent a dramatic escalation in intent, several factors may limit actual implementation. Legal challenges are likely, particularly if patterns emerge suggesting selective or discriminatory enforcement. Additionally, federal courts have limited capacity to rapidly process denaturalisation dockets, and the required evidentiary burdens mean that not all referred cases will result in successful revocation.

Legal experts note that individuals facing denaturalisation proceedings should consult experienced immigration attorneys immediately, as the outcome of these cases can fundamentally alter their legal status and future in the country.

Conclusion

The Trump administration’s denaturalisation initiative represents one of the most ambitious efforts in modern US history to revoke citizenship from naturalised Americans. While the legal framework for denaturalisation has long existed, the dramatic increase in referral targets—potentially affecting thousands of individuals annually—signals a fundamental shift in how the government views the permanence of citizenship for foreign-born Americans.

For naturalised citizens, immigration lawyers, and civil rights advocates, the coming months will be critical in determining how aggressively the policy is enforced and whether courts impose constraints on its implementation. Until more details emerge regarding case prioritisation and enforcement patterns, uncertainty will persist regarding the true scope and impact of this policy shift.

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