On his first day in office, President Trump signed a series of executive orders.  

One such order, entitled, “Protecting The United States from Foreign Terrorists and Other National Security And Public Safety Threats,” is expected to be enforced by March 20, 2025 to ramp up the screening process for immigration and international travel. The Executive Order contains language that there is to be an enhancement of the vetting process for foreign nationals, whether they are applying for entry to the United States at consular posts, applying for entry to the United States at ports of entry including land and air points, or at those located within the United States. 

The goal of the Executive Order is to address security risks posed by individuals seeking to enter the United States by mandating stricter screening efforts.  This Executive Order, widely expected and anticipated, reflects a continuation of prior policy under the first Trump administration.

Employers are advised to prepare for impacts to their international workforce in the following ways:

Employer’s expectations 

U.S. employers should expect travel bans from countries previously included on the travel ban list, and possibly additional countries that might be added, going forward.

Employers should also expect heightened interruption to employee travel in the following ways:

• Enhanced security screening at U.S. consular posts, delayed visa issuance and risk assessment of countries on an individual basis, putting international travelers at risk for highlevel disruption at a moment’s notice.
• Delays in adjudication of adjustment of status applications or potential removal of individuals if they are deemed to possess specific security risks.

What actions should employers take going forward and in anticipation of a travel ban announcement on March 20, 2025?

Employers should get ready now for near-future disruption by taking the following steps: 

• Prepare for visa delays for employees being transferred to the United States on international assignments.
• Review travel policies considering potential disruption and risk for employee international travel assignments and prepare for backup contingency plans to minimize disruption in business activities.
• Support employees when applying for visas at U.S. consular posts.
• Consult counsel to assure that your expat group is properly represented to anticipate any immigration changes that will affect your population.

While no one can foresee which countries might be included in the travel ban or whether the ban will be implemented by March 20, 2025, it is best to prepare and review travel plans for foreign nationals in anticipation of changes that are likely to occur.

Our immigration practice will keep you up to date on any travel ban updates.