Former media tycoon Conrad Black will have to wait until next month to find out if he can return to Canada.
A judge asked for more thorough financial information before she decides whether to allow him to return.
Black was in court on Friday after being released from a US jail on two million dollars' bail (£1.3m).
He walked free from the minimum security prison in Coleman, Florida, on Wednesday after serving two years and four months of a six-and-a-half-year sentence for defrauding investors out of millions of dollars.
District Judge Amy St Eve in Chicago ordered him to surrender his expired passport. She also said he cannot obtain a new passport without the court's permission.
Black's lawyers said he wanted to return to Toronto because of media attention and because his wife had medical conditions which made their Florida home unsuitable. The judge ordered him to return to court on August 16.
She said: "I want more certainty. I need more to make a fully informed decision."
Black left the court without speaking to reporters and was whisked away in a waiting car.
The former head of the Hollinger International media empire was convicted with three other former executives of defrauding shareholders out of 6.1 million dollars (£4 million).
He was also convicted of obstruction of justice after he was seen carrying boxes of documents out of his offices, loading them into his car and driving away. The documents were sought by US government investigators.
