The document sitting at the center of this story is a single internal Justice Department memorandum, dated June 11, 2025. It directed the DOJ’s Civil Division to “prioritize and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence.” What followed from that directive was anything but routine. Within months, the United States government had launched what officials themselves describe as the largest campaign to denaturalize citizens in the country’s modern history – and the pace has only accelerated into 2026.
This is not a marginal shift in enforcement posture. It is a structural transformation of how the United States government views the permanence of naturalized citizenship – one that is already rattling legal scholars, immigration attorneys, and the roughly 20 million foreign-born Americans who hold U.S. citizenship today.
What “Denaturalization” Actually Means – and What the Law Requires
To understand what is happening, it helps to start with the numbers. Between 1990 and 2017, the Department of Justice filed a total of 305 denaturalization cases – roughly 11 per year. That number climbed during Trump’s first term, which generated 168 cases across four years. After President Joe Biden took office in 2021, the DOJ filed 64 cases over the next four years – an average of 16 per year, according to data compiled by Hofstra University professor Irina Manta. Now compare those figures to the current trajectory: since the beginning of January 2025, the Trump administration has filed more than 60 civil complaints seeking to revoke the citizenship of naturalized individuals. And the administration has made clear it intends to go far further.
Denaturalization is the process of revoking a foreign national’s American citizenship, which they gained either through long-term legal residency or through a relationship to a U.S. citizen. The legal standard is narrow and deliberately demanding. Unlike most other immigration proceedings that USCIS handles in an administrative setting, revocation of naturalization can only occur in federal court.
There are two routes: a civil action under 8 U.S.C. § 1451(a) (INA § 340) to revoke a certificate that was “illegally procured” or obtained “by concealment of a material fact or by willful misrepresentation,” and a criminal prosecution under 18 U.S.C. § 1425, where a conviction triggers automatic revocation under 8 U.S.C. § 1451(e).
The government must prove its case by clear, convincing, and unequivocal evidence in civil cases, and beyond a reasonable doubt in criminal cases. That evidentiary bar was not accidental. The Supreme Court addressed the standard directly in Kungys v. United States in 1988, holding that a misrepresentation in the naturalization process is only disqualifying if it was material – meaning it had a “natural tendency to influence” the decision to grant citizenship.
The practical implications of the civil route deserve particular attention. Civil denaturalization is the one to fear for ordinary cases. It carries no jury, no appointed lawyer, and no time limit. The government does not have to prove a crime – only that the naturalization was illegally procured or obtained by a material misrepresentation, by clear and convincing evidence. That is a lower-friction path than a criminal trial, which is exactly why the 2025 DOJ memo emphasized the civil route.
The June 2025 Memo and What It Changed
The Trump administration dramatically elevated denaturalization as a federal enforcement priority through a June 11, 2025 memorandum directing the Department of Justice Civil Division to “prioritize and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence.”
The memo gives federal agencies broad discretion to pursue denaturalization actions without weighing the overall benefit to the country or the severity of the individual case. While the government still must meet the legal threshold for denaturalization, it no longer views these cases as exceptional. The result is a shift away from targeting only the “worst of the worst,” toward a potentially much broader class of cases.
The Justice Department’s guidance identifies specific priority categories for denaturalization review, including individuals who concealed criminal histories during their naturalization process, those who committed financial fraud including PPP or Medicare fraud schemes, and gang members and individuals connected to drug cartels. The June 11 memo tells attorneys in the Civil Division to move to strip citizenship from immigrants if they pose a threat to national security or gained the status through fraud by failing to acknowledge past crimes. The memo also lists other qualifying crimes, adding that attorneys can prioritize denaturalization even for those who are facing “pending criminal charges” that have not yet secured a conviction.
That last point – pursuing denaturalization against individuals with pending but unresolved charges – marks a significant departure from historical practice, which focused almost exclusively on people with final convictions or confirmed national security risks.
The Largest-Ever Filing: 17 Cases and a Broadening Target List
The Trump administration announced it is seeking to revoke the citizenship of 17 U.S. citizens accused of immigration fraud, expanding its unprecedented denaturalization campaign. Officials said the move represents the largest-ever effort by the U.S. government to use its denaturalization powers, which were rarely invoked before President Trump returned to the White House.
Those targeted for status revocation range in age from 39 to 69 and are immigrants from Cuba, Colombia, Haiti, Mexico, and India, according to the DOJ. Some of the 17 citizens targeted in the latest denaturalization campaign were convicted of violent or serious crimes, including sex offenses against children. Others were convicted of fraud crimes or accused of committing immigration fraud.
Among the more prominent individuals named in the federal filings: Fernando Cristancho, 69, a Colombian national and ordained Roman Catholic priest who federal prosecutors alleged used his church leadership role to gain access to minors. Cristancho is accused of sexually grooming and abusing a parishioner between the ages of 11 and 13.
As of the time of the latest announcement, a DOJ official confirmed that 15 people had seen their U.S. citizenship stripped from them since January 20, 2025, out of 22 cases filed. That figure has since grown. With 78 cases filed in federal court in less than six months of 2026, the DOJ is revisiting naturalization cases at a historically elevated pace, following a 2025 White House directive for USCIS to regularly review thousands of naturalization cases per year.
The Quota: 100 to 200 Cases Per Month
The most dramatic element of the administration’s escalation is not the individual cases filed to date – it is the internal quota structure now in place for fiscal year 2026. According to internal guidance reported by The New York Times, U.S. Citizenship and Immigration Services has directed field offices to refer between 100 and 200 denaturalization cases per month to the Justice Department during fiscal year 2026.
The new directive instructs USCIS to refer 100 to 200 cases per month to the Justice Department in fiscal year 2026, potentially reaching up to 2,400 cases annually – more than a twentyfold increase from historical averages.
The New York Times also reported that the DOJ is planning to utilize regional office workers to file denaturalization cases against individuals already identified as eligible. This would mark a change from the traditional practice of using specialists in the DOJ’s immigration litigation office to work on cases.
A DOJ spokesperson told the paper that the department was “pursuing the highest volume of denaturalization referrals in history” from the Department of Homeland Security, adding that the DOJ is “laser focused on rooting out criminal aliens defrauding the naturalization process.”
The administration has already identified a substantial initial target list. Officials have identified approximately 384 individuals as targets for denaturalization, though the criteria used to select these cases have not been fully disclosed, raising transparency concerns.
Historical Context: From Operation Janus to the Present
The current push did not emerge from a vacuum. Operation Janus, begun during the Obama administration, exists to identify individuals who may have committed naturalization fraud by consulting fingerprint records collected by USCIS. The program originated after the government realized it had failed to upload fingerprints from immigration records in the early 1990s into its centralized database.
Operation Janus identified about 315,000 cases where some fingerprint data was missing from the centralized digital fingerprint repository. Among those cases, some individuals may have sought to circumvent criminal record and other background checks in the naturalization process.
Operation Janus did not begin as an explicit denaturalization program and was not used for this purpose while President Obama was in office. When President Trump was first elected, denaturalization cases escalated and Operation Janus turned into Operation Second Look, which was an explicit denaturalization program designed to strip citizenship from naturalized Americans.
At the end of Trump’s first term, the Justice Department created a division dedicated to denaturalization cases due to the “growing number of referrals anticipated from law enforcement agencies.” The second term has taken that institutional infrastructure and dramatically expanded its mandate.
Who Is at Risk – and Who Is Not
Acting Attorney General Todd Blanche addressed the scope of the effort directly in public remarks. Blanche stated that “when criminal aliens exploit the naturalization process by breaking the law, there are consequences,” adding that “criminal aliens are lying about their past crimes, including drug dealers, sexual predators, and fraudsters.”
Blanche also offered a limiting frame: in an interview, he acknowledged that only “a very small percentage” of the roughly 24 million naturalized citizens in the U.S. should be concerned about the administration’s efforts.
Legal practitioners, however, are drawing sharper distinctions. A denaturalization proceeding can be a civil proceeding where there is no constitutional right to legal counsel. This means that a person facing denaturalization must obtain their own counsel for their defense. Foreign nationals who are denaturalized do not automatically lose valid status and instead revert to the immigration standing they held before receiving U.S. citizenship. They could, however, lose deportation protection if they did not hold legal status before naturalization or if they have been or are convicted of a crime.
What is not typically a real trigger: honest, immaterial errors, lawful conduct that the government simply dislikes, or political speech. The constitutional protections around citizenship exist precisely to keep denaturalization from becoming a tool of viewpoint punishment.
Legal and Civil Liberties Pushback
Despite the administration’s aggressive policy shift, constitutional law professor Steve Vladeck of Georgetown University Law Center emphasizes that there is “simply, no easy, fast path to revoking any American’s citizenship without their consent – and there hasn’t been for decades.”
Critics warn that expanding denaturalization efforts could raise serious civil rights concerns, particularly if applied beyond clear cases of fraud or criminal conduct, where legal standards may be more contested. Some experts caution that citizenship may no longer feel secure or permanent if revocation becomes routine at the scale now contemplated.
The American Immigration Lawyers Association has been among the most vocal institutional critics. In prior administrations, denaturalization priorities included cases involving national security risks, war criminals, and those who omitted serious criminal history from their naturalization application. The current expansion goes considerably further, raising questions about where the line falls.
Critics worry that implementing monthly case quotas could transform denaturalization from a carefully considered legal process into a quota-driven system. Immigration experts say it would be a “Herculean undertaking” for the administration to meet the 100-to-200-per-month quota without cutting corners, and some advocates have noted the administration is “very willing to set legal precedent aside.” Immigration law experts and advocates say these efforts will likely be challenged in court.
The institutional resource demands alone raise practical barriers. Denaturalization cases involve significant resources, and without additional funding the proposed scope will be difficult to carry out. USCIS is already reallocating staff and deploying specialized experts across approximately 80 field offices to review past naturalization approvals.
One particularly pointed concern involves the chilling effect on legal permanent residents who are eligible to apply for citizenship but may now hesitate to do so. These efforts will have a chilling effect on the number of legal permanent residents applying for U.S. citizenship and will further burden a system that is already delayed in adjudicating and processing applications.
A Legislative Front: The Exclusive Citizenship Act
Alongside the executive enforcement push, a parallel legislative effort has emerged in Congress. Senator Bernie Moreno (R-Ohio) introduced the Exclusive Citizenship Act of 2025 on December 1 – legislation that would eliminate dual citizenship for U.S. citizens by requiring them to hold “sole and exclusive allegiance” to the United States. Under the bill, those who hold dual citizenship would have to submit a written renunciation of their foreign citizenship to the Secretary of State, or a written renunciation of U.S. citizenship to the Secretary of Homeland Security, no later than one year after enactment.
The bill has not advanced through committee as of June 2026, but its introduction signals a legislative appetite to fundamentally redefine the terms of American citizenship in ways that go beyond individual denaturalization cases.
Key Takeaways
The Trump administration’s denaturalization campaign represents the most significant policy shift in the use of citizenship revocation in modern U.S. history. What was once a tool reserved for war criminals, proven fraudsters, and national security threats – deployed roughly 11 times a year for nearly three decades – is now a stated top-five enforcement priority at the Department of Justice, with internal quotas calling for up to 200 cases per month in fiscal year 2026.
Between 1990 and 2017, the United States averaged approximately 11 denaturalization cases per year. By contrast, the new guidance calls for up to 2,400 referrals annually – a more than twentyfold increase over historical averages. The Biden administration filed only 24 denaturalization cases during its entire four-year tenure.
Three structural facts define this moment. First, the legal standard for denaturalization has not changed: courts still require clear, convincing, and unequivocal evidence, and the Supreme Court’s materiality precedent from Kungys remains in force. What has changed is the administration’s willingness to marshal resources and set numerical targets for pursuing cases at scale. Second, the civil route – which carries no right to appointed counsel and no statute of limitations – gives prosecutors a lower-friction path than many affected citizens may realize. Third, the volume targets set by USCIS guidance are aspirational, not guaranteed: legal challenges, resource constraints, and judicial scrutiny will all shape how many of these cases actually proceed to completion.
What This Means Going Forward
For the approximately 24 million naturalized citizens in the United States, the practical risk at the individual level remains low for anyone who disclosed all required information honestly during naturalization. The legal framework still requires the government to prove, in federal court, that a material misrepresentation occurred. The law has not been rewritten. The courts still demand the same evidentiary burden. The Supreme Court’s holding in Kungys still applies.
What has changed is not the law – it is the government’s stated willingness to use it at an unprecedented scale, and the institutional machinery now being built to do exactly that. Monthly quotas, redeployed staff, and a broadened target list all point to a government that views naturalized citizenship not as a settled conclusion but as an open file. That is a different posture than the United States has taken for most of its modern history, and the legal challenges now forming in response will take years to resolve. Some of these questions about where the boundaries lie have never been tested at this volume before. They are being tested now.
AI Disclaimer: This article was created with the assistance of AI tools and reviewed by a human editor.