The U.S. Department of Justice has issued a memorandum that expands the federal government’s pursuit of denaturalization, the revocation of citizenship from naturalized Americans. A June 11, 2025 memo, signed by Assistant Attorney General Brett A. Shumate, directs Civil Division attorneys to “prioritize and maximally pursue denaturalization proceedings in all cases permitted by law and supported by the evidence”

This represents a significant escalation from historical norms, where denaturalization averaged only 11 cases per year between 1990-2017.

Civil denaturalization proceedings operate under a “clear, unequivocal, and convincing evidence” standard, higher than typical civil cases but lower than criminal proceedings. Key advantages for the government include:

• No right to jury trial (unlike criminal cases)
• No statute of limitations for civil cases
• Lower burden of proof than criminal denaturalization
• Defendants not guaranteed court-appointed attorneys

The memo establishes specific enforcement priorities targeting individuals who:

1. National security threats – terrorism, espionage, unlawful export of sensitive materials
2. Human rights violators – war crimes, torture, extrajudicial killings
3. Criminal organization members – gangs, transnational organizations, drug cartels
4. Undisclosed felons – those who committed crimes not disclosed during naturalization
5. Violent criminals – human trafficking, sex offenses, violent crimes
6. Government fraud – PPP loan fraud, Medicare/Medicaid fraud
7. Private fraud – financial crimes against individuals or corporations
8. Naturalization fraud – citizenship obtained through corruption or misrepresentation
9. Pending cases – referred by U.S. Attorney’s Offices or connected to criminal charges
10. Discretionary cases – any other cases deemed “sufficiently important to pursue”

These categories are guidance only and do not limit the Civil Division from pursuing any particular case. ICE is requesting up to $45 billion over two years for immigration detention operations, with plans to triple detention capacity to accommodate an additional 84,000 people.

The current denaturalization push builds on significant increases during Trump’s first term. The DOJ filed at least 30 denaturalization cases in 2017—twice the number filed in 2016. By 2018, USCIS had selected approximately 2,500 cases for possible denaturalization and referred at least 110 cases to DOJ. A dedicated Denaturalization Section was established in February 2020

During the second Trump Administration, American citizens and immigrants, even children, who have not committed crimes have been detained and deported through ICE.

This enforcement expansion affects an estimated 25 million naturalized U.S. citizens, with the government maintaining a 95% success rate in denaturalization proceedings. The directive represents a dramatic shift from targeting primarily war criminals and terrorists to potentially including a much broader range of naturalized citizens with criminal histories or immigration irregularities.

The Nazi regime implemented one of history’s most comprehensive and systematic denaturalization programs, ultimately stripping 39,000 German citizens of their citizenship between 1933 and 1945. This process served as a crucial precursor to broader persecution and genocide.

The Nazi denaturalization program began with the Law on the Revocation of Naturalizations and the Deprivation of German Citizenship, enacted on July 14, 1933. This law, passed just four months after the Enabling Act, pursued two primary objectives:

1. Revocation of naturalization granted to Eastern European Jews since the end of World War I
2. Denaturalization of Jews and political opponents who had fled Germany

The law used deliberately vague language, allowing authorities to revoke naturalizations deemed “undesirable” or to denaturalize persons whose “conduct violated the duty of loyalty toward Germany or harmed German interests”. This broad discretionary power enabled systematic targeting without explicitly naming Jews in the legislation.

The denaturalization priority represents just one component of a comprehensive five-point enforcement strategy outlined in the memo. The other priorities include:

• Combating diversity, equity, and inclusion (DEI) programs through False Claims Act litigation
• Aggressive prosecution of antisemitism
• Targeting healthcare providers offering gender-affirming care
• Legal challenges to sanctuary jurisdictions.