Immigration Attorneys
Representing Employers,
Employees & Families
Around the World
Representing Employers,
Employees & Families
Around the World
Travel Advisory
To: Human Resources
Date: March 19, 2025
Re: Travel Ban Warning: Executive Order:
PROTECTING THE UNITED STATES FROM FOREIGN TERRORISTS AND OTHER NATIONAL SECURITY AND PUBLIC SAFETY THREATS
On January 20, 2025, the President signed an Executive Order (EO) entitled, PROTECTING THE UNITED STATES FROM FOREIGN TERRORISTS AND OTHER NATIONAL SECURITY AND PUBLIC SAFETY THREATS. This EO instructed the Department of State, Attorney General, Department of Homeland Security and the National Intelligence Agency to jointly identify countries with inadequate security screening within 60 days of the issuance of the EO and to recommend to the President that he suspend entry of travelers (Travel Ban) from identified “countries of particular concern.”
Therefore, we expect very soon to see travel restrictions and/or travel bans, as well as changes and delays to visa procedures and processing, re-entry requirements, and other travel-related delays that will affect an employee, student or interns ability to return to, or enter, the United States. Based on media sources, the Travel Ban will potentially be implemented in tiers as follows:
- Red Tier: Total suspension of U.S. visas for citizens and nationals of: Afghanistan, Bhutan, Cuba, Iran, Libya, North Korea, Somalia, Sudan, Syria, Venezuela, and Yemen.
- Orange Tier: Partial visa suspension and mandatory in-person visa interviews at US Consulates for citizens and nationals of: Belarus, Eritrea, Haiti, Laos, Myanmar, Pakistan, Russia, Sierra Leone, South Sudan, and Turkmenistan.
- Yellow Tier: 60-day probation period to address identified security issues and if identified security issues are not addressed, citizens and nationals of these countries could move to the Red or Orange Tiers noted above: Angola, Antigua and Barbuda, Benin, Burkina Faso, Cambodia, Cameroon, Cape Verde, Chad, Republic of Congo, Democratic Republic of Congo, Dominica, Equatorial Guinea, Gambia, Liberia, Malawi, Mali, Mauritania, Saint Kitts and Nevis, Saint Lucia, São Tomé and Príncipe, Vanuatu, and Zimbabwe.
The Travel Ban is expected to affect employers and their employees’ global mobility. Nationals of the restricted or banned countries who are outside the United States when the Travel Ban is announced may be unable to return, even with a valid non-immigrant visa stamp. Employees and/or business visitors from restricted countries should expect a rigorous visa application process such as was seen under the initial Travel Ban during the first Trump Administration. We expect that the following results could be felt due to this expected Travel Ban:
| Tier | Restrictions | Impact on Hiring | Impact on Existing Employees | Majority Industries Likely to be Effected |
| Red | Full Visa Suspension | Unable to hire from these countries | Difficulty reentering the U.S.; possible visa revocations | Tech, healthcare, education, manufacturing, hospitality |
| Orange | Partial Visa Suspension & Interview Required | Hiring delays and difficulties | Travel delays, increased scrutiny of visa applications | Tech, healthcare, education, hospitality, service |
| Yellow | 60-Day Probationary Period Then Future Review | Uncertain future hiring potential | Possible future visa and travel issues | All industries |
As the administration finalizes the details for this expected Travel Ban, it is crucial to stay informed about the potential impacts and legal challenges that may arise. We will continue to update you regarding these immigration issues which directly impact you and your employees. While this Travel Ban is not a certainty at this point, we felt it was prudent to alert our clients to potential changes and/or disruptors in the immediate future to your business and workforce. Please address any questions and comments to this memo to matthew@maionaward.com. Thank you.