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2.0

DHS Secretary ratifies interim final rule on Asylum Cooperative Agreements

  1. Original Date Announced

    September 2, 2025

    DHS Secretary Kristi Noem ratifies an interim final rule (IFR) titled “Implementing Bilateral and Multilateral Asylum Cooperative Agreements Under the Immigration and Nationality Act.” 84 Fed. Reg. 63,994 (Nov. 19, 2019). The IFR provides for implementation of ACAs signed between the U.S. and third countries, authorizing asylum-seekers in the U.S. to be sent to third countries to process their claims.

    The initial IFR was approved and issued by former Acting DHS Secretary Chad Wolf in 2019. Secretary Noem states she ratified the IFR "[o]ut of an abundance of caution" in response to a Government Accountability Office (GAO) Opinion and lawsuits challenging the validity of agency actions taken by improperly appointed officials.

    For additional information regarding the Trump 1.0 Interim Final Rule, please see this Trump 1.0 entry.

    Trump 2.0 [ID #1985]

    2025.09.02 DHS 2025–16809 - Ratification of Department Action
  2. Effective Date

    September 2, 2025
  3. Subsequent Trump and Court Action

    September 8, 2025

    2025.09.08 Proposed Amended Complaint - UT v. Noem

    Plaintiffs in U.T. v. Noem filed a motion to amend complaint. The case was filed in 2020 to challenge the 2019 interim final rule, and has been held in abeyance since 2021. The plaintiffs earlier filed a motion to lift the stay on September 8, 2025, in light of DHS Secretary Noem’s ratification of the interim final rule.

    The proposed amended complaint, included here, alleges that the rule and associated policies violate the "safe third country" provision of the Immigration and Nationality Act (INA), as well as the Administrative Procedure Act (INA). It also states that the federal government is “actively working to sign further ACAs with inappropriate third countries,” and that an ACA with Ecuador is “reportedly imminent.” U.T. v. Noem, No. 1:20-cv-00116 (D.D.C.).

    **Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

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