Well, this was worse than I expected, even if I can't really claim to be totally surprised by anything at this point in the Trump administration.
Once again, there was no meaningful opportunity for public comment and the "flawless" roll-out includes significant confusion among visa applicants.
A few interesting points I saw upon first read were an acknowledgment/admission that "foreign policy" interests beyond security alone guided decision making this time around, the fact that undue hardship will have to be demonstrated by the alien visa applicant rather than USC family members (that will certainly add a level of burden above and beyond 13780 for the Persian and other communities in the US), and that there will be some standardized form of special screening (presumably something more than the DS-5535) for those permitted to enroll in student and exchange programs from Iran.
I'm at a loss. The concession for student and exchange NIVs for Iran coupled with the adoption of what looks to me like an even tougher "undue hardship" standard for family reunification is not an outcome I would have anticipated. I never got to file the extreme hardship petition I had prepared for Embassy Abu Dhabi thanks to the injunctions blocking 13780, but seeing how other federal agencies define an "undue" level of hardship suggests that State may be gearing up to fight with folks like myself who just happen to fall in love with someone with the wrong passport.
If we're really going down this road, I know of cases where USCs may end up being tempted to move to Iran. I can think of at least one highly educated USC with a profile that don't seem too far off from that of Xiyue Wang who would fall into this category. I sincerely hope that Secretary Tillerson understands the sorts of predicaments that some citizens may find themselves in as a result of this.
I'm sure I'll have more reactions shortly. I'll be very interested to read the documents that must have been generated as part of the review process whenever State clears the FOIA requests that one hopes they are getting as a result of this.
Last edited by lonelycrowd; Sep 26, 2017 at 9:22 am
Reason: I misread part of the proclamation; it's a *little* less severe in reality than I initally understood.