{"id":186,"date":"2009-05-18T19:58:11","date_gmt":"2009-05-19T01:58:11","guid":{"rendered":"http:\/\/blog.messersmithlaw.com\/?p=186"},"modified":"2026-10-26T12:36:47","modified_gmt":"2026-10-26T18:36:47","slug":"us-department-of-state-lists-eight-countries-as-religious-freedom-violators","status":"publish","type":"post","link":"https:\/\/blog.messersmithlaw.com\/?p=186","title":{"rendered":"2009 Religious Freedom Designations: Historical Context for Immigration Cases"},"content":{"rendered":"

On May 11, 2009, the US Department of State designated Burma, China, Eritrea, Iran, North Korea, Saudi Arabia, Sudan, and Uzbekistan as \u201cCountries of Particular Concern\u201d for particularly severe violations of religious freedom. This article describes that historical designation. It should not be read as a current list of designated countries.<\/p>\n

The International Religious Freedom Act requires the US government to assess religious freedom conditions and allows the Secretary of State to designate countries based on the statutory criteria. Designations can change over time. Anyone relying on a designation as current evidence should consult the Department of State\u2019s latest official announcement and the underlying country report rather than rely on a list from 2009.<\/p>\n

Can a designation help an immigration case?<\/h2>\n

A government report or designation may provide background evidence about religious freedom conditions in a country. Depending on the immigration benefit at issue, reliable country information can help explain the context in which a person experienced threats, discrimination, detention, violence, or other harm. The relevance of the material depends on the legal standard and the facts of the individual case.<\/p>\n

A country designation does not<\/strong> automatically establish that a particular person was persecuted, that the person has a well-founded fear of future persecution, or that the person qualifies for asylum or another immigration benefit. For asylum, the applicant generally must show past persecution or a well-founded fear of persecution on account of race, religion, nationality, political opinion, or membership in a particular social group. The applicant must also address the required connection between the harm and a protected ground, credibility, government protection, internal relocation, and any statutory bars.<\/p>\n

The evidence should connect the country information to the applicant\u2019s own experience and risk. Depending on the case, that may include a detailed personal declaration, threats or communications, medical or police records, witness statements, expert evidence, and reliable country reports. A broad designation may support context, but it cannot replace proof of the individual elements.<\/p>\n

Why the date matters<\/h2>\n

The eight-country list in this article reflects a specific 2009 announcement. Later administrations have issued different designations. Before citing a present-day designation, check the Department of State\u2019s current page and date the source. If the article is being used to explain an older event, retain the 2009 list but clearly identify it as historical.<\/p>\n

Sources<\/h2>\n