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Achieving U.S. citizenship represents, for many immigrants, the culmination of years of planning, sacrifice, and building a life in the United States. Few, however, are aware that this citizenship can, under specific circumstances, be revoked by the federal government. The Department of Justice (DOJ) memo issued on June 11, 2025, significantly expanded investigation priorities for denaturalization cases, placing approximately 25 million naturalized citizens under potential scrutiny.
What Denaturalization Is
Denaturalization is the legal process by which the U.S. government revokes citizenship previously granted to an individual through the naturalization process. Once denaturalized, the person loses all rights and protections associated with U.S. citizenship, including the right to vote, the right to hold a U.S. passport, and lawful permanent residency in the country.
The immediate effect varies by situation. In some cases, the individual reverts to their prior status as a Lawful Permanent Resident (LPR). In others — particularly when no valid immigration status remains after revocation — loss of citizenship can lead directly to removal proceedings, that is, deportation.
The DOJ Memo of June 2025
The memo issued by the DOJ’s Civil Division on June 11, 2025, establishes ten priority categories for denaturalization investigations. The breadth of these categories represents a significant departure from the historical focus, which was largely limited to war crimes and serious fraud.
The priority categories include naturalized citizens who: pose national security threats (terrorism or espionage); were involved in torture, war crimes, or human rights violations; have ties to gangs, cartels, or transnational criminal organizations; committed serious crimes not disclosed during naturalization; participated in human trafficking, violent crimes, or sexual offenses; defrauded the U.S. government through programs such as Medicare, Medicaid, or PPP loans; participated in private financial fraud schemes; obtained citizenship through corruption, document falsification, or misrepresentation; have pending criminal charges that may affect their eligibility; or are deemed significant enough by the DOJ’s Civil Division to warrant investigation.
The breadth of that last category, in particular, grants the government substantial discretion to reopen and investigate old cases.
How Denaturalization Proceedings Begin
Most denaturalization proceedings begin when United States Citizenship and Immigration Services (USCIS) refers a case to the DOJ. From that referral, the DOJ decides whether to pursue the case through civil or criminal channels — a legally decisive distinction for the outcome.
Civil Denaturalization
In civil proceedings, there is no statute of limitations. The government may initiate a case 10, 15, or even 20 years after citizenship was granted, provided it believes fraud, concealment, or misrepresentation occurred during the naturalization process.
The evidentiary burden is high: the government must present clear, convincing, and unequivocal evidence that citizenship was obtained illegally or fraudulently. If the government prevails, citizenship is revoked. The individual may revert to their prior immigration status or, if no status remains, face deportation.
Criminal Denaturalization
Criminal denaturalization applies when an individual is prosecuted under 18 U.S.C. § 1425 for obtaining citizenship through fraud. Unlike civil cases, the criminal path carries a 10-year statute of limitations and can result in up to 10 years of federal imprisonment, as well as automatic revocation of citizenship upon conviction.
In Maslenjak v. United States (2017), the Supreme Court established an important limit: only lies or omissions that directly influenced the naturalization decision can serve as the basis for criminal revocation. Immaterial errors or those irrelevant to the granting of citizenship are insufficient. That decision, written by Justice Elena Kagan, narrowed the reach of criminal charges under 18 U.S.C. § 1425.
Practical Consequences of Revocation
Once citizenship is revoked, the person’s legal status reverts to what it was before naturalization. Those who held a Green Card beforehand may return to lawful permanent resident status. Those without a valid status face removal proceedings and potential deportation.
In some cases, individuals choose to voluntarily renounce citizenship to avoid prolonged litigation, though that decision carries serious tax implications, including the exit tax applicable to covered expatriates under Section 877A of the Internal Revenue Code.
What Naturalized Citizens Should Consider
Although denaturalization remains statistically rare, the expanded scope of priorities makes documentary transparency essential. Naturalized citizens who faced immigration issues, criminal charges, or irregularities during the naturalization process should consider a preventive review of their records with a qualified professional.
Relevant documentation includes the original N-400 form, proof of tax filings during the eligibility period, travel records, and any correspondence with USCIS. Keeping accessible copies of this documentation throughout one’s life may prove decisive if an investigation is opened decades after naturalization.
The post-2025 landscape reinforces that U.S. citizenship, while protected by the Fourteenth Amendment for those born on American soil, retains a conditional character for naturalized citizens when there are indications of fraud in the original process.
Victoria Harper
Editor-in-Chief
Leading journalism and editorial content at Visto n’ Visa, Victoria helps make immigration topics clear, trustworthy, and easy to understand. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.
