Last week I wrote about how high-volume, assembly-line filing operations slow honest T-visa and VAWA cases. The occasion was the collapse of Alexandra Lozano’s Tukwila, Washington practice, the self-described “lawyer of miracles” whose firm left behind more than 35,000 clients, nearly 54,000 pending petitions, and an eleven-page statement of alleged misconduct from the Washington State Bar Association. The theory of that article was a principle everyone already understands: a few bad actors ruin it for everyone. The “everyone” in that story was the applicants — the trafficking survivors and abused spouses whose truthful cases now sit in longer lines and face harder questions because, as the Bar alleged, applications were filed at industrial scale — regardless of eligibility, by staff working from scripts.
Seven weeks after Lozano resigned her license, the other shoe dropped. On July 13, 2026, USCIS issued Policy Alert PA-2026-04, adding a new Part D, “Attorneys and Representatives,” to Volume 1 of its Policy Manual — five chapters on who may represent applicants, how representation is established and ended, and, at the center of it, a chapter titled Professional Conduct and Reporting Misconduct. The guidance took effect immediately and applies to every benefit request pending on or filed after that date. This time the “everyone” is not the applicants. It is the lawyers — all of us.
What USCIS Actually Did on July 13
Policy Manual updates are usually quiet housekeeping, and this one dresses itself that way. The alert’s stated purpose is to consolidate and update guidance that previously lived in the Adjudicator’s Field Manual, the aging internal handbook USCIS has spent years retiring. But read the alert’s own highlights. The new part, it says, “[e]xplains expectations for the professional conduct of practitioners, grounds for discipline, and procedures for reporting criminal, unethical, or unprofessional conduct or frivolous behavior (such as immigration fraud) by practitioners or organizations.”
When an agency writes “such as immigration fraud” into the headline of new guidance about lawyers, it is telling you what problem it has recently been staring at. To see how much actually changed, though, you have to look at what this replaced.
The Old Rulebook: Two Paragraphs and a Website
Until July 13, the guidance USCIS officers had on attorney conduct lived in Chapter 12 of the Adjudicator’s Field Manual (since withdrawn). Chapter 12 was almost entirely mechanics: who qualifies as an attorney, who may file a Form G-28, how law students appear, what a “reputable individual” is. Professional conduct got a single section — 12.5 — and that section ran two paragraphs. Its entire substance: practitioners are “subject to discipline for criminal, unethical, or unprofessional conduct”; complaints should go to the DHS Disciplinary Counsel; and officers “should visit the Disciplinary Counsel website for more information.” Most of the section’s remaining words were about officer manners — do not argue with attorneys during interviews, and elevate disagreements to the Field Office Director.
That was the disciplinary architecture as the front-line adjudicator saw it: a referral address and a suggestion to browse a website. The actual rules of professional conduct existed — they have sat in the federal regulations at 8 CFR 1003.102 for many years — but an officer working a stack of I-360s would never confront them unless she went looking. Discipline was a specialist’s corner of the agency. A lawyer had to work hard to end up in it.
The New Chapter: A Checklist of Ways to Lose Your Ticket
The new Chapter 5 is a different animal. It opens by stating expectations — a practitioner’s behavior “must be within the bounds of the law and in accordance with the rules of professional conduct” — and then does what the AFM never did: it enumerates the grounds for discipline, roughly two dozen of them, in the operating manual every USCIS employee uses daily. The first ground on the list — the first — is charging or receiving “a grossly excessive fee.”
The list continues: knowingly or with reckless disregard making a false statement of material fact, including offering false evidence. Making false or misleading communications about one’s qualifications or services. Soliciting clients through runners. Repeatedly filing documents that show “little or no attention to the specific factual or legal issues” of a client’s case and instead use “boilerplate language indicative of a substantial failure to represent the client competently and diligently.” Assisting the unauthorized practice of law. Failing to provide competent representation, failing to follow the client’s decisions about the objectives of the case, failing to communicate. And one that deserves its own sentence: a practitioner is subject to discipline for “having resigned while a disciplinary investigation or proceeding was pending.”
The surrounding chapters put teeth behind the list. Chapter 4 instructs officers to affirmatively verify every attorney who files a G-28 — consult the state licensing authority’s website, check the Justice Department’s roster of disciplined practitioners, and alert a supervisor if they find a bar suspension. Chapter 5 closes with reporting: officers route misconduct concerns through supervisors and agency counsel, and members of the public are pointed to two channels of their own — the state bar where the attorney is licensed, and the DHS Disciplinary Counsel.
Now Read That List Against the Charge Sheet
Here is where the two halves of this story meet. Set the Washington bar’s statement of alleged misconduct next to the new chapter and match them line by line. (These were allegations; the resignation resolved the case without any of them being adjudicated, and Lozano admitted none of them.)
- The Bar alleged flat fees of $10,000 to $15,000 for humanitarian filings — fees it alleged were unreasonable for work done by non-lawyers and for applications the clients were not eligible for. The new chapter’s first listed ground for discipline is the grossly excessive fee.
- The Bar alleged scripted sales pitches, delivered by staff, containing false and misleading promises — “100% protection.” The new chapter lists false or misleading communication about a practitioner’s services.
- The Bar alleged that non-lawyer staff conducted the legal consultations. The new chapter lists assisting in the unauthorized practice of law — and, for organizations, “engaging in the practice of law through staff” with no attorney involved.
- The Bar alleged sworn declarations drafted by staff and signed without the client’s review, some of which contained false information. The new chapter lists false statements of material fact and the offering of false evidence.
- One signature appeared on nearly 54,000 petitions. The new chapter lists boilerplate filings that show little or no attention to the individual client’s facts.
- The Bar alleged adjustment applications filed regardless of eligibility, with no explanation of the risks a denial creates. The new chapter lists failing to provide competent representation and failing to consult the client about the objectives of the case.
- And she resigned while the disciplinary investigation was pending — which is itself on the list. Three weeks after the resignation, on June 18, the Board of Immigration Appeals suspended her from practice before DHS, the immigration courts and the Board.
Every material allegation in the charge sheet has a mirror image in the new chapter. The match is so clean you could teach the regulation from the case, or the case from the regulation.
What Actually Changed — and the Joke Buried in It
I want to be precise here, because precision is the difference between analysis and conspiracy theory. USCIS did not write new law on July 13. Nearly every ground in Chapter 5 is lifted, close to verbatim, from 8 CFR 1003.102 — the Justice Department’s professional-conduct rules for immigration practitioners, most of which have been on the books since 2008. The excessive-fee rule is old. The boilerplate rule is old. USCIS has also been migrating AFM content into the Policy Manual for years; Chapter 12 was on that conveyor belt regardless of anything that happened in Tukwila.
But there is a real difference between a rule that exists and a rule that is read every day, and it is the difference between a speed limit buried in the county code and one posted on your street. Before July 13, the conduct rules lived in a regulation adjudicators never opened, summarized in two paragraphs whose practical instruction was to visit a website. After July 13, every officer’s manual carries the full checklist, an affirmative duty to verify the credentials of every attorney who appears, and a routing system for reporting what they see. An agency chooses what to emphasize when it consolidates, and this consolidation chose to put “grounds for discipline” and “(such as immigration fraud)” in the headline — twenty-five days after the BIA suspension, seventeen days after USCIS issued its own public notice to Lozano’s former clients. Agencies, like the rest of us, rewrite the manual right after the fire.
They called her la abogada de los milagros — the lawyer of miracles. Give her this: the title finally fits. Most lawyers spend an entire career hoping to influence the law once. Her practice managed, in roughly seven weeks, to take a set of conduct rules that had sat mostly undisturbed for the better part of two decades and get them promoted into the daily working manual of the agency that receives every immigration filing in the country — with a checklist, a verification duty, and a complaint pipeline attached, applicable to every attorney and accredited representative who practices before it. One bad actor does not just ruin it for the clients. One bad actor gets the rules changed for the entire profession. That is a miracle of a kind, though I doubt it is the kind her marketing had in mind.
What This Means for You — Whether You Have a Lawyer or Are One
For anyone shopping for an immigration lawyer, the new chapter is something unexpected: a government-issued consumer checklist. The red flags I described last week — the guaranteed outcome, the same five-figure flat fee for every case, the intake run entirely by non-lawyer staff from a script — now carry regulatory citations. If a firm quotes you $15,000 flat for a VAWA self-petition or a T-visa case and promises the result, you are not just looking at a bad deal. You are looking at conduct the government now trains its own officers to recognize. A promise that sounds too good to be true is not merely a warning sign anymore; it is a documented ground for taking the promiser’s license. Before you sign anything, it is still worth knowing how to read a firm’s reviews and the promises it makes.
There is a harder point in the new Part D for clients, and I would be doing you no favors by softening it. Chapter 1 reminds officers that the applicant signs the benefit request under penalty of perjury — and that when a representative makes a false representation, the applicant is held responsible if the applicant was aware of it. Clients of an assembly-line practice do not get to assume the practice absorbs the consequences; thousands of Lozano’s former clients are living that lesson now, as USCIS re-reads filings under the tightened December 2025 VAWA evidence standards. If you suspect a petition filed in your name says things you never said, get an independent review quickly — the remedy may be correcting the record or withdrawing a pending application before USCIS reaches it, and that decision should be made with counsel, not alone.
If you need to report an attorney or an unauthorized practitioner, the channels are the ones the new chapter names: the disciplinary authority of the state bar where the attorney is licensed, and the DHS Disciplinary Counsel for conduct in matters before DHS. USCIS maintains a plain-language guide on reporting immigration scams.
For honest lawyers, nothing in Chapter 5 is new or frightening; we have practiced under these rules all along, and a fee tied to the actual work of an individual case has nothing to fear from a grossly-excessive-fee standard. But we all inherit the climate the new chapter announces: more verification, more skepticism, more friction at the window — the beach patrols from last week’s article, now walking the lawyer’s side of the beach as well. The reservoir of trust got drained, and the agency responded the way institutions respond. The way back has not changed either: honest work, correctly priced, one file at a time. If you want a candid second opinion on your case — especially a case filed by a firm you are no longer sure you can trust — that is exactly the kind of consultation this office does. If that is your situation, start with our playbook on what to do when your immigration firm is accused of fraud.
