Homeland Security
INS Cannot Locate Many Aliens Because It Lacks Reliable Address Information Gao ID: GAO-03-188 November 21, 2002Following the terrorist attacks of September 11, 2001, the federal government's need to locate aliens in the United States was considerably heightened. Without reliable alien address information, the government is impeded in its ability to find aliens who represent a national security threat or who could help with the nation's anti-terrorism efforts. Requesters from both the Senate and House asked GAO to review the reliability of INS's alien address information and identify the ways it could be improved.
Recent events have shown that INS's alien address information could not be fully relied on to locate many aliens who were of interest to the United States. For example, the Department of Justice sought to locate and interview 4,112 aliens who were believed to be in the country and who might have knowledge that would assist the nation in its anti-terrorism efforts. However, as shown below, almost half of these aliens could not be located and interviewed because INS lacked reliable address information. The reliability of INS's alien address information is contingent, in part, on aliens' compliance with the requirement that they notify INS of any change of address. However, lack of publicity about the requirement that aliens should file change of address notifications, no enforcement of penalties for noncompliance, and inadequate processing procedures for changes of address also contribute to INS's alien address information being unreliable. Because INS does not publicize the change of address requirement, some aliens may not be aware of it and may not comply with it. Alternatively, some aliens who are aware of the requirement may not comply because they do not wish to be located. These aliens have little incentive to comply given that INS does not enforce the penalties for noncompliance. On the basis of our review of available data, INS does not appear to have enforced the removal penalty for noncompliance since the early 1970s. When aliens do comply with the requirement, INS lacks adequate processing procedures and controls to ensure that the alien address information it receives is recorded in all automated databases. Addressing these problems should help improve the reliability of INS's alien address information but would not necessarily result in a system that would allow INS to reliably locate all aliens, because some aliens will not likely comply. INS has recognized the need to increase the reliability of its alien address information and is taking some steps to improve it.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-188, Homeland Security: INS Cannot Locate Many Aliens Because It Lacks Reliable Address Information
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Report to Congressional Requesters:
United States General Accounting Office:
GAO:
November 2002:
Homeland Security:
INS Cannot Locate Many Aliens Because It Lacks Reliable Address
Information:
Homeland Security:
GAO-03-188:
Contents:
Letter:
Results in Brief:
Background:
Congress Provided the Framework for INS to Locate Aliens:
INS‘s Alien Address Records Are Not Reliable:
Lack of Publicity, No Enforcement of Penalties, and Inadequate
Processing Procedures Contribute to INS‘s Unreliable Address
Information:
INS‘s Actions to Improve Alien Address Reliability:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: An Historical Overview of INS‘s Alien Registration
Programs,
1940-1981:
The Alien Registration Program of 1940:
The Alien Address Report Program of 1950:
Alien Registration Programs Shared Common Program Elements:
Appendix III: Comments from the Department of Justice:
Appendix IV: GAO Contacts and Staff Acknowledgments:
Contacts:
Acknowledgments:
Tables:
Table 1: Examples of Requests for Alien Registration Data INS Approved
and Their Intended Use:
Table 2: Examples of Requests for Alien Registration Data INS Denied
and Their Intended Use:
Table 3: Examples of Requests for Alien Address Report Program Data INS
Approved and the Intended Uses:
Figures:
Figure 1: INS‘s Form AR-11 Is Available in Six Languages:
Figure 2: Requirements and Penalties for Registration and Address
Reporting from June 28, 1940 to June 28, 2002:
Figure 3: INS‘s Alien Address Report Provided for Collecting Aliensí
SSNs:
Figure 4: INS‘s Processing of the Form AR-11:
Figure 5: INS‘s Processing of Other Change of Address Forms:
Figure 6: Number of Aliens Who Reported During the Alien Address Report
Program, 1951-1980:
Figure 7: The Post Office Department Cancelled Stamps with a Reminder
That Aliens Must Report Their Addresses:
Figure 8: INS‘s 1953 Sign Placed in Post Offices Instructing Aliens to
Report Their Addresses:
Abbreviations:
CLAIMS 3: Computer Linked application Information Management
System:
DACS: Deportable Alien Control System:
DOJ: Department of Justice:
FBI: Federal Bureau of Investigation:
INS: Immigration and Naturalization Service:
NIIS: Nonimmigrant Information System:
SSN: Social Security number:
United States General Accounting Office:
Washington, DC 20548:
November 21, 2002:
The Honorable Strom Thurmond
United States Senate:
The Honorable George W. Gekas
Chairman, Subcommittee on Immigration, Border Security, and Claims
Committee on the Judiciary
House of Representatives:
Following the terrorist attacks of September 11, 2001, the federal
government‘s need to locate aliens who represented a national security
threat or who could help with the nation‘s anti-terrorism efforts was
considerably heightened.[Footnote 1] The Immigration and
Naturalization Service (INS) is the federal agency that is responsible
for maintaining address information for aliens who are in the United
States and was called upon to help by providing current addresses for
aliens who were being sought by the Department of Justice (DOJ).
However, efforts to locate these aliens were impeded by INS‘s lack of
current address information.
Because of growing concern over the government‘s need to locate aliens,
you asked us to determine what was impeding INS from using its alien
address information to reliably locate aliens in the United States.
This report discusses (1) the statutory framework that requires aliens
to report their addresses and any address changes, (2) the reliability
of INS‘s alien address records to locate aliens who were sought by DOJ,
and (3) the principal factors affecting the reliability of INS‘s alien
address records. You further asked for historical background
information on prior alien registration requirements and programs,
which is included in appendix II.
To determine the statutory framework that requires aliens to report
their addresses and any address changes, we identified and reviewed the
laws and regulations, congressional testimony and reports, and prior
GAO reports. To determine whether INS‘s alien address information can
be used to reliably locate aliens in the United States, we reviewed INS
documentation and data, observed processing of the change of address
forms in INS headquarters, and interviewed INS managers and staff and a
representative of the U.S. Postal Service. We also interviewed senior
representatives from the Executive Office for U.S. Attorneys, Federal
Bureau of Investigation (FBI), the Secret Service, and the Foreign
Terrorist Tracking Task Force.[Footnote 2] To identify the principal
factors affecting the reliability of INS‘s alien address records, we
analyzed the information we obtained during the review. To obtain
information on the historical background of the alien registration
requirement and programs, we reviewed INS historical documentation and
data and interviewed INS managers and staff. See appendix I for a more
detailed discussion of our scope and methodology.
We performed our work from October 2001 through September 2002 in
accordance with generally accepted government auditing standards. We
requested comments on a draft of this report from the Attorney General.
Results in Brief:
Since 1940, the Congress has provided a statutory framework that
requires aliens entering or residing in the United States to provide
identifying and address information. This information is provided to
INS. While the law requires aliens who remain in the United States for
30 days or longer to apply for registration, INS usually registers
aliens at the time of their entry into the country. Registration
documents provide an alien‘s identity and address where the alien can
be located. The law requires that an alien report any change of address
within 10 days of moving. Thus, if aliens comply with the requirement,
INS should be able to record and maintain an address history for each
alien, including their current address. If an alien fails to comply
with the change of address notification requirement, it can result in
the alien‘s prosecution for a misdemeanor. As provided in law,
irrespective of whether the alien is charged with or convicted of a
misdemeanor, an alien, who fails to notify the Attorney General in
writing of each change of address and new address within 10 days from
the date of such change, shall be taken into custody and removed from
the United States unless the alien can establish to the satisfaction of
the Attorney General that the failure was reasonably excusable or was
not willful.
Recent events have shown that INS‘s alien address information cannot be
relied on to locate aliens. For example, as part of the nation‘s anti-
terrorism effort, the Attorney General directed all U.S. Attorneys in
November 2001 to locate and request voluntary interviews with about
4,800 nonimmigrant aliens who were believed to be in this country. U.S.
Attorneys, in cooperation with the Foreign Terrorist Tracking Task
Force, obtained the names and addresses for these aliens from INS. The
task force further supplemented INS‘s alien address information by
obtaining address information from public source databases. The aliens‘
names and addresses were then forwarded to the U.S. Attorneys in order
that they could locate and request interviews with them. U.S. Attorneys
determined that 681 aliens had left the country. By the end of February
2002, even with the information from public source data bases, 1,851,
or about 45 percent, of the 4,112 aliens who were believed to still be
in the country had not been located and interviewed. Two other DOJ
efforts to locate aliens have met with even less success.
Lack of publicity, no enforcement of penalties for not filing change of
address notifications, and inadequate processing procedures and
controls explain in part why INS‘s alien address information is
unreliable. Unreliable address information can also be attributed, in
part, to aliens‘ failure to report changes of address to the INS. Some
aliens may be unaware that they need to file a change of address form
and do not comply. This may be understandable given that INS does not
publicize the change of address requirement. Aliens may be aware that
they need to file but do not comply because they have little incentive
to do so. On the basis of our review of available data, INS does not
appear to have enforced the removal penalty for noncompliance since the
early 1970s. According to INS officials, INS cannot and does not
enforce the penalty provisions of the law because it cannot determine
and certify from its change of address records whether an alien failed
to file the change of address notification. When aliens are aware of
and comply with the requirement to file a change of address
notification, INS‘s address information may still be unreliable. INS
lacks adequate procedures and controls to ensure that the alien address
information it receives is completely processed. Addressing these
problems should help improve the reliability of INS‘s address
information but would not necessarily result in a system that would
allow INS to reliably locate all aliens. This is because the accuracy
and reliability of INS‘s address information is contingent on aliens‘
compliance and some aliens may not comply.
In April 2002, INS established an Address Issues Task Force to review
and assess how alien address information is processed. The task force
recommended a multi-phased strategy to improve operational efficiency.
As of September 11, 2002, INS had accepted the task force‘s
recommendations. The Executive Associate Commissioner for Management
was designated as the lead agency official for address issues, an
Address Issues Office was established, and the Commissioner approved a
Senior Level Advisory Group for address issues. INS has also taken the
first steps toward establishing a centralized address repository and
plans to implement the task force‘s other recommendations.
We are making seven recommendations to the Attorney General to promote
compliance through publicity and enforcement and to improve INS‘s
identification and processing of aliens‘ address information. We
provided DOJ with a draft of this report for comment, and it generally
concurred with five, and did not comment on two of them. DOJ‘s comments
are included as appendix III.
Background:
INS regulates immigration to the United States and oversees immigrants,
who intend to remain permanently in the United States, and
nonimmigrants, who intend to remain in the United States temporarily.
INS receives and maintains alien address information for benefits
administration, law enforcement, and national security purposes.
Through registration and change of address notifications, aliens
provide their identity and an address where they can be located while
in the United States to INS, which can share this information to help
law enforcement officials identify and locate aliens.[Footnote 3]
Generally, INS registers aliens at the time of their entry, using 1 of
12 different INS forms, including the Arrival and Departure Record
(Form I-94). For example, aliens arriving in the United States are
generally required to complete a two-part Form I-94. The first part
records aliens‘ arrivals. The second part is to be surrendered when
aliens leave the country. INS is to match the first and second parts of
the Form I-94 to identify those aliens who have left the country.
However, as reported by DOJ‘s Inspector General in 1997 and 2002, INS
lacked many Form I-94 departure records, and as a result, INS could
not identify all of the aliens who had left the country.[Footnote 4]
Aliens are required to report their change of address to INS within 10
days of moving. Failure to report a change of address can result in an
alien being taken into custody and placed in removal proceedings before
an immigration judge with the Executive Office for Immigration Review.
To place an alien in proceedings, INS is to serve the alien with a
Notice to Appear, which cites the charge(s) and the date and location
where the hearing is to be held. At the conclusion of the hearing, the
immigration judge may order the alien to be removed or may grant relief
from removal. Either INS or the alien may appeal the immigration
judge‘s decision to the Board of Immigration Appeals.
As shown in figure 1, INS has a prescribed change of address form,
(i.e., Form AR-11) that is available in six languages (English,
Spanish, Chinese, Russian, Korean, and Vietnamese) and is to be used by
all aliens to report their new addresses.
Figure 1: INS‘s Form AR-11 Is Available in Six Languages:
[See PDF for image]
Source: INS.
[End of figure]
Prior to the terrorist attacks on September 11, 2001, the Congress
mandated that INS improve its ability to identify aliens who arrive and
depart the United States and who overstay their visas. In Section 110
of the Illegal Immigration Reform and Immigrant Responsibility Act of
1996[Footnote 5] and amendments to that section, the Congress
reinforced the importance of the government being able to identify
which lawfully admitted nonimmigrants remained in the United States
beyond their authorized period. This section directs the Attorney
General to develop an integrated entry and exit control system that
will collect the records of arrival and departure for every alien
entering and leaving the United States. The 1996 act also authorized
the establishment of an electronic student tracking system to verify
and monitor the foreign student and exchange visitor information
program.
[Footnote 6] The deadline for implementing the new electronic student
tracking system is January 1, 2003.
According to proposed rules issued by DOJ on June 13, 2002, the events
of September 11 point to the need to implement measures that would
provide the government with information on certain aliens who are in
the country, whether they are in compliance with their authorized
limits of stay, and their activities and whereabouts. The USA Patriot
Act (P.L. 107-56), enacted in October 2001, directs the Attorney
General to implement the entry-exit system ’with all deliberate speed
and as expeditiously as practicable“ and authorized funds to fully
implement INS‘s new foreign student tracking system. The Enhanced
Border Security and Visa Entry Reform Act (P.L. 107-173), enacted in
May 2002, also authorized funds for implementing the foreign student
tracking system.[Footnote 7] The Congress has required that the entry-
exit system be implemented at airports and seaports by December 31,
2003.
Congress Provided the Framework for INS to Locate Aliens:
Since the 1940 passage of the Alien Registration Act, the Congress has
required aliens to register and provide address information so that the
government can track aliens‘ past and current locations and locate
aliens when necessary.[Footnote 8] As part of the effort to protect the
nation in anticipation of World War II, the Congress required aliens to
register, be fingerprinted, and notify the Attorney General of each
change of address, thereby providing INS with the means to identify,
track, and locate aliens while they are in the United States. According
to the legislative history of the Alien Registration Act, the act was
considered to be ’a measure of self-defense to provide for the
fingerprinting and registration of all aliens in the United
States—(and)—a safeguard to know something about their activities and
their movements here.“[Footnote 9]
Although some requirements of the law have varied since 1940, the
Congress has continuously required immigrant and nonimmigrant aliens
entering or living in the United States to provide identifying and
current address information and has provided penalties for failing to
register or file address information. As shown in figure 2, the Alien
Registration Act of 1940 required immigrant and nonimmigrant aliens to
register with the government.[Footnote 10] Immigrants were required to
report changes of address within 5 days, and nonimmigrants were
required to report their address every 90 days irrespective of whether
they had moved. In 1950, the Congress increased the reporting
requirements for immigrants by requiring them to annually report their
addresses.[Footnote 11] In 1952, the Congress extended the annual
address reporting and change of address notification requirements to
all aliens and also extended from 5 to 10 days the amount of time
aliens were provided to file a change of address.[Footnote 12] In 1981,
the Congress eliminated the requirements that aliens annually report
their addresses and that nonimmigrants report their address every 90
days.[Footnote 13] Although the Congress eliminated these requirements,
it vested the Attorney General with discretionary authority, upon 10
days‘ notice, to require aliens from any country or countries, or any
class or group, who are required to be registered, to provide their
current address and such additional information as may be
required.[Footnote 14] These changes represent the latest amendments to
the laws governing alien registration and address reporting. The
Congress currently requires aliens to provide address information
through registration and change of address reporting
requirements.[Footnote 15]
In addition to the registration and change of address requirements, the
Congress has continuously provided penalties for aliens who failed to
comply with these requirements, as shown in figure 2. The misdemeanor
penalty enacted in 1940 for failing to file a change of address notice
was a fine of up to a $100 and/or imprisonment for up to 30 days. In
1952, the misdemeanor penalty was increased to a $200 fine and/or
imprisonment for up to 30 days and a removal penalty was added,
irrespective of whether the alien is charged with or convicted of a
misdemeanor. The law provides that an alien, who fails to notify the
Attorney General in writing of each change of address and new address
within 10 days from the date of such change, shall be taken into
custody and removed from the United States unless the alien can
establish to the satisfaction of the Attorney General that the failure
was reasonably excusable or was not willful. As of September 2002, this
penalty remained in effect.[Footnote 16]
Figure 2: Requirements and Penalties for Registration and Address
Reporting from June 28, 1940 to June 28, 2002:
[See PDF for image]
[A] All aliens 14 years of age or older who remain in the United States
for 30 days or more must register. A parent or legal guardian must
register an alien who is under 14 years of age. Exceptions to the
registration requirements are provided for aliens who remain in the
United States for less than
30 days, foreign government officials and their family members, and
representatives of international organizations and their family
members.
[B] Required by regulation 8 C.F.R. 119.3 (1950).
[C] The requirement to report an address every 90 days was by
regulation (8 C.F.R. 119.3), a condition of entry. Violation of a
condition of entry could result in an alien‘s deportation.
[D] An alien is to be removed from the United States unless the alien
establishes to the satisfaction of the Attorney General that the
violation was reasonably excusable or was not willful.
Source: GAO‘s analysis.
[End of figure]
On June 13 and July 26, 2002, DOJ reiterated that certain aliens are
legally obligated to file a change of address form with INS within 10
days of moving to a new address to be used for enforcement and other
purposes. On June 13, 2002, DOJ issued a proposed rule concerning the
registration and monitoring of certain nonimmigrants.[Footnote 17]
Specifically, the proposed rule would impose registration requirements
on nonimmigrants from Iran, Iraq, Libya, Sudan, and Syria; certain
nonimmigrant aliens from other countries that the State Department and
INS determine to be an elevated national security risk; and aliens
fitting specific criteria who are identified by INS inspectors at
points of entry into the United States. Individuals falling into these
categories would be required to provide specific information at regular
intervals to ensure that they were in compliance with the terms of
their visas and admission and that they departed at the end of their
authorized stay. The proposed rule reminded aliens that they are
required to submit to INS changes of address and that failure to do so
could result in their removal. The final rule was published and became
effective on September 11, 2002.[Footnote 18]
On July 26, 2002, INS issued a proposed rule requiring every alien who
is applying for immigration benefits to acknowledge having received
notice of the requirement to provide a valid current address to INS,
including any change of address within 10 days of the change.[Footnote
19] INS plans to use the most recent address information for all
purposes, including the service of a Notice to Appear if INS initiates
removal proceedings.
INS‘s Alien Address Records Are Not Reliable:
Despite these laws and regulations, INS‘s address information cannot be
relied upon to locate many aliens who are in the United States. Since
September 11, 2001, DOJ has made several different attempts to locate
aliens as part of its anti-terrorism efforts. These efforts have not
been fully successful. In addition, the alien identifying and address
information maintained by INS may not allow law enforcement officials
to verify the identity of an alien being sought in cases where several
aliens have the same name but are located at different addresses.
Senior representatives of the FBI, the Secret Service, and the Foreign
Terrorist Tracking Task Force told us that the ability to locate aliens
within the United States is crucial to their respective missions.
According to a senior representative of the task force, the ability to
locate aliens in this country is also crucial to the nation‘s success
in fighting the war on terrorism.
On November 9, 2001, as part of the nation‘s anti-terrorism effort, the
Attorney General directed all U.S. Attorneys to locate and request
voluntary interviews with 4,793 nonimmigrant aliens who might have had
knowledge of foreign terrorists or their organizations. To assist the
U.S. Attorneys, the Foreign Terrorist Tracking Task Force asked INS to
provide current address information for the aliens who were to be
sought for interviews. INS obtained the address information from the
Nonimmigrant Information System (NIIS), an automated database that
contains address and identity information on nonimmigrants who were
inspected upon their entry into the United States. Because the task
force considered INS‘s address information to be of questionable
reliability, it consulted public source databases and supplemented
INS‘s information in order to provide the most current address
information for these aliens to the U.S. Attorneys. U.S. Attorneys
determined that 681 aliens had left the country. As of February 26,
2002, even with the information from public source data bases, 1,851,
or 45 percent, of the 4,112 aliens believed to be in the country had
not been located and interviewed while 2,261, or 55 percent, had been
located and interviewed.[Footnote 20]
As a second example, INS investigators determined that INS‘s address
information was inaccurate for 45 aliens who may have known some of the
terrorists responsible for the September 11th attacks. According to the
Assistant District Director for Investigations in San Diego, he was
advised that at least two of the terrorists had student visas and were
supposed to be attending school in the San Diego area. He requested
that INS headquarters provide him with a list of aliens with student
visas who had entered the United States within the last 2 years and, at
the time of their entry, indicated they were going to the San Diego
area. From a list of 700 aliens, INS investigators identified 45 whom
they wanted to locate. According to INS investigators who sought to
locate these aliens, INS‘s address information for all 45 student
aliens
was inaccurate as none of them were located at the addresses that INS
had provided. Efforts to supplement INS‘s address information with the
schools‘ address information provided accurate addresses for 10
students.
It is possible that some or all of the 35 aliens that INS could not
locate had left the country.
As a third example, in January 2002, the Deputy Attorney General
directed INS and other DOJ components to establish an Absconder
Apprehension Initiative to locate and remove aliens who had been
ordered removed but who had failed to leave the United States. Of the
estimated 314,000 aliens with final orders of removal still at large in
the United States, INS identified 5,046 who were from countries in
which there has been an Al Qaeda terrorist presence or activity. To
locate and apprehend these aliens, INS, in cooperation with the FBI,
the Foreign Terrorist Tracking Task Force, and U.S. Attorneys, used
INS address data and supplemented these data with address information
from public source databases. According to a senior INS official, as
of June 24, 2002, 4,334, or 86 percent, of the 5,046 alien absconders
had not been apprehended, while 712, or 14 percent, had been
apprehended.
It is possible that some of the aliens who had not been located may
have left the country.
These examples illustrate one inherent limitation of an address
reporting requirement that relies on self reporting, as the reliability
and completeness of the address information is dependent on the extent
to which aliens comply with the reporting requirement. Those aliens who
wish to remain illegally in the country would not likely comply as it
could lead to their removal. In these examples, many aliens were not
found even after INS‘s address information was supplemented with
address information from public source databases or schools, which
could indicate that some aliens may be able to avoid detection.
In addition, aliens‘ identifying and address information maintained by
INS may not allow law enforcement officials to verify the identity of
an alien being sought in cases where several aliens have the same name
but are located at different addresses. Senior officials from the FBI,
the Secret Service, and the Foreign Terrorist Tracking Task Force
stressed the need to be able to verify an alien‘s identity in order to
determine the correct address. These officials recommended that INS
collect aliens‘ Social Security numbers (SSNs) in order to verify an
alien‘s identity. The law provides authority for the Attorney General
to require aliens to provide their SSNs.[Footnote 21] As shown in
figure 3, INS formerly collected aliens‘ SSNs on the Form I-53 as part
of the alien address reporting program.
Figure 3: INSís Alien Address Report Provided for Collecting Aliens‘
SSNs:
[See PDF for image]
Source: INS.
[End of figure]
When the program ended in 1981,[Footnote 22] INS eliminated the Form I-
53 and did not revise the change of address form (Form AR-11) to
provide for aliens to report their SSNs. Collecting aliens‘ SSNs can
help verify an individual‘s identity and provide ready access to
records, such as drivers licenses and financial records, that are
searchable using SSNs. Having aliens‘ SSNs would also afford the
federal government a better opportunity to locate aliens through
automated databases that are searchable using SSNs.[Footnote 23]
Revising the Form AR-11, to include a field that an alien can use to
report a SSN or indicate that he or she does not have one, would
provide one method for collecting this information.
Lack of Publicity, No Enforcement of Penalties, and Inadequate
Processing Procedures Contribute to INS‘s Unreliable Address
Information:
Lack of publicity, no enforcement of penalties for not filing a change
of address notification, and inadequate procedures and controls for
processing change of address notifications explain in part why INS
cannot maintain current and reliable address information. Unreliable
address information can also be attributed, in part, to aliens‘ failure
to report changes of address to the INS. Since INS does little to
actively publicize the requirement, aliens may not know of the
requirement and may not file the notification. Alternatively, aliens
may know of the requirement and choose not to file the notification.
INS is not in a position to enforce the penalty, and aliens who
knowingly do not file change of address notifications are not likely to
face any adverse consequences. When aliens file the notification, INS
may have unreliable address information because it lacks adequate
procedures and controls to ensure that aliens‘ address information is
processed properly so that all automated databases are updated.
INS Does Not Publicize
the Address Notification Requirement:
Aliens cannot comply with the requirement to file a change of address
notification if they are not aware of the need to file or if they lack
ready access to the form. To promote compliance with the change of
address notification requirement, INS needs to make aliens aware that
the requirement exists. However, according to INS officials, INS does
not publicize the requirement, and INS does not inform aliens of the
requirement when they enter the country. Furthermore, for those aliens
who know about and seek to comply with the filing requirement, INS has
not made the Form AR-11 available at post offices as required by the
Code of Federal Regulations.[Footnote 24] According to a senior postal
service official, INS‘s change of address notification forms are not
available in post offices because INS has not made arrangements with
the U.S. Postal Service to provide and distribute the form. INS
provides the Form AR-11 at its field offices, through its form centers,
and on its Web site at www.ins.usdoj.gov.
INS Is Not in a Position To Enforce the Removal Penalty:
According to INS officials, INS is not in a position to place aliens in
removal proceedings for failing to file a change of address
notification because their address records are not maintained in a
manner that will permit INS to certify that an alien has not complied
with the law. Aliens may be aware of the requirement but may have
little incentive to comply given that, based on our review of available
data, INS does not appear to have enforced the removal penalty for
noncompliance since the early 1970s.
INS‘s historical records from 1950 through 2002 do not provide the
number of aliens who were placed in removal proceedings for failing to
file a change of address notification. According to an official with
the Executive Office for Immigration Review, its records date from 1988
and contain no cases where aliens were charged and placed in removal
proceedings for failing to file a change of address notification. A
review of federal cases and cases brought on appeal from the Executive
Office for Immigration Review to the Board of Immigration Appeals
indicates just a few instances where INS charged an alien with failure
to file a notification of address or change of address in a removal
proceeding.[Footnote 25] We also found a few cases where an alien was
prosecuted for failure to give notice of an address or change of
address. [Footnote 26]
Senior INS investigators cited two reasons for INS‘s lack of
enforcement. The principal reason cited was that INS‘s change of
address records are not maintained in a manner that permits the agency
to determine whether an alien has complied with the requirement. In
order to place an alien in removal proceedings, INS is required to
certify that the alien did not comply with the filing requirement by
issuing a certificate of no record. According to a senior official with
INS‘s Office of General Counsel, if the certificate is to be legally
sustainable, INS must be able to check all change of address records to
be certain that the alien did not comply. However, INS lacks procedures
and controls for maintaining complete and current change of address
records. As a result, INS cannot determine whether an alien has
complied and, therefore, cannot issue certificates of no record with
the required degree of certainty. According to a 1944 INS report, INS
was able to determine if an alien had complied with the change of
address requirement because it maintained all address verification
cards within the Alien Registration Division in headquarters. As a
result, INS personnel could review the change of address records to
determine if an alien had provided a change of address. If no change of
address card for a specific alien was in INS‘s centralized file, INS
could determine that it did not have a record showing that the alien
had reported a change of address. Senior INS records officials said
that it would be impossible to reliably reconstruct years of change of
address records in order to create a complete, current, and centralized
system of address records because they could not be certain that some
change of address records had not been lost, misplaced, misfiled, or
destroyed.
The second reason cited for INS‘s lack of enforcement was that the
agency‘s internal policy discourages enforcement of this type of case.
INS‘s Operations Instructions provide internal guidance to its
employees. The Operations Instructions governing the enforcement of the
penalties for failure to comply with the reporting requirement states
that noncompliance shall not normally serve as the sole basis for
initiating prosecution or removal proceedings.[Footnote 27] In
contrast, under the law, noncompliance can be the sole basis for
removal unless the alien can establish that the violation was not
willful or was reasonably excusable. This internal policy has been in
effect since March 8, 1972. According to a senior INS investigative
official, this policy may have been established because INS could not
reliably determine if an alien had or had not filed a change of address
notification. Senior INS investigative officials said they interpret
the instruction as preventing enforcement of the penalties.
INS Lacks Procedures and Controls Needed To Ensure Alien Address
Information Is Complete:
When aliens do submit Forms AR-11, INS must update its automated
databases for the estimated 111,500 change of address notifications it
receives annually.[Footnote 28] However, INS lacks written procedures
and automated controls to help ensure that reported changes of address
are recorded in all automated databases.
INS Does Not Update Address Information in All Automated Databases:
INS has at least 16 different automated databases that capture alien
identity and address information.[Footnote 29] For example, when an
alien enters the country as a visitor, his or her name and intended
address are to be recorded in the automated NIIS. If the alien
subsequently applies to adjust his or her visa status, the application
for adjustment is to be recorded in the automated Computer Linked
Application Information Management System (CLAIMS 3). Consequently, an
alien‘s name and address may appear in more than one INS automated
system. In this example, if the alien then moved and filed a change of
address notification, INS would have to update both NIIS and CLAIMS 3
to ensure that the most current address information was recorded and
that the address data across different automated databases was
consistent. However, INS does not update all databases that contain
alien address information and does not have the ability to update
address information in NIIS.
Figure 4: INS‘s Processing of the Form AR-11:
[See PDF for image]
Source: GAO‘s analysis.
[End of figure]
As shown in figure 4, INS‘s prescribed change of address form is the
Form AR-11 that is to be used by all aliens to report their new
address. Aliens are to complete a Form AR-11 and mail it to INS
headquarters in Washington, D.C. Upon receipt, INS staff determine
where each alien‘s file is located and forward the change of address
card to the appropriate INS office. INS does not create paper-based
files for most nonimmigrant aliens. Consequently, if INS headquarters
staff cannot associate a Form AR-11 with an alien‘s file, the card is
placed in a box and held until a technician can do further research on
them. These cards are not forwarded to any INS office and are not used
to update automated databases. The forms that are sent to district
offices or INS‘s National Records Center may not be used to update any
database as there are no written procedures or automated controls that
require or would provide for updating all databases. Change of address
forms that are sent to the service centers are to be used to update the
CLAIMS 3 database. No other databases that may also contain the alien‘s
address are updated.
Figure 5: INS‘s Processing of Other Change of Address Forms:
[See PDF for image]
Source: GAO‘s analysis.
[End of figure]
In addition to the Form AR-11, INS has four other change of address
forms and a 1-800 telephone number that are generally to be used by
aliens who qualify or have applied for a specific immigration benefit.
As shown in figure 5, the different forms are to be sent to INS‘s
service centers or asylum offices for processing. At the service
centers and asylum offices, some but not all automated databases are
required to be updated with the new address information.[Footnote 30]
Consequently, for those aliens who submit a change of address form, the
consistency of their address information may vary between or among
different INS automated databases.
Irrespective of the change of address form that is used, all databases
are not updated because INS does not have adequate written procedures
or automated controls that require or provide for updating address
information in all automated databases in which the alien‘s name and
address information appears. INS could establish automated controls
such as a single automated address database from which other INS
databases download alien address information. Alternatively, INS could
establish automated linkages whereby updating address information in
one automated database would automatically update address information
in all databases. In either case, INS would need to record the date
that the change of address was received in order to identify which
address was most current and to determine whether an alien had filed a
change of address within the required 10 days. Furthermore, INS‘s
written procedures do not require all databases with address
information to be updated. INS has drafted but not yet implemented
field office processing procedures for the Form AR-11. These draft
procedures do not require that all automated databases be updated.
Potential alien address inconsistencies among INS databases may have
hampered DOJ‘s efforts to locate aliens. For example, if any of the
4,793 aliens who were being sought for interviews by U.S. Attorneys had
submitted changes of address, their new addresses would not have been
recorded in the database that was used to search for their current
addresses. These aliens‘ address information was provided to the
Foreign Terrorist Tracking Task Force by INS from the NIIS database
that is not updated when INS receives changes of address. Consequently,
these 4,793 aliens‘ address information was only as current as the
date of their last entry into the United States. In a similar example,
the Alien Absconder Initiative obtained address information on aliens
who were ordered removed but who failed to depart the country from
INS‘s Deportable Alien Control System (DACS). As with the NIIS
database,
change of address information submitted to INS is not used to update
address information in DACS. As a result, INS may have had current
address information for some of these aliens, but was not able to
provide it because all INS databases are not updated.
INS‘s Actions to Improve Alien Address Reliability:
In April 2002, INS established an Address Issues Task Force to review
and assess how alien address information is processed. The task force
identified numerous issues regarding the capture, processing, and
recording of aliens‘ addresses. In May 2002, the task force prepared a
White Paper that developed a concept of operations for handling address
information and recommended a multi-phased strategy to improve
operational efficiency. INS‘s concept of operations includes capturing
and electronically storing alien address information in a timely
manner, providing access to appropriate personnel through a single
facility that provides easy sharing and updating of address
information, and providing clear direction to aliens concerning their
responsibility to provide current address information. To implement
this concept of operations, the task force recommended a short-,
medium-, and long-term strategy including the designation of a lead
agency official for address issues, a reduction in the number of change
of address forms, making the updating of address information a
priority, issuing a request for information to identify best practices,
developing a single centralized address repository, and developing
compliance policies to monitor the process.
As of September 11, 2002, INS had accepted the task force‘s
recommendations. The Executive Associate Commissioner for Management
was designated as the lead agency official for address issues, an
Address Issues Office was established, and the Commissioner approved a
Senior Level Advisory Group for address issues. INS has also taken the
first steps toward establishing a centralized address repository and
plans to implement the task force‘s other recommendations. According to
the Executive Associate Commissioner for Management, INS has received
about 700,000 change of address notifications since July 22, 2002, when
the Attorney General announced the planned publication of a proposed
rule that, in part, restated that aliens are required to notify INS of
changes of address. To handle this unexpected deluge of change of
address forms, INS has made arrangements with one of its contractors to
electronically image and capture these forms. INS expects that the
changes of address it has received will form the basis for a new
central address repository.
Conclusions:
The Congress has provided a statutory framework that requires aliens
entering or residing in the United States to provide identifying and
address information to INS. If aliens comply with the requirement, INS
should be able to record and maintain an address history for each alien
and locate the alien if needed. If an alien fails to comply with the
change of address notification requirement, it can result in the
alien‘s prosecution for a misdemeanor and removal from the country.
INS should have a practical, reliable system to ensure that it has
current address information for aliens in the United States who are
required to register and provide any address changes. However, INS has
not taken steps to ensure that aliens know about their responsibility
to notify INS of new addresses, does not have an adequate system for
handling change of address forms it receives, cannot determine whether
aliens are in compliance, and has not sought to enforce the removal
penalty against violators.
Since the events of September 11, 2001, it may be even more important
for the federal government to know where aliens are located. Without
this information, INS and law enforcement officials cannot quickly
locate certain aliens who could help with the nation‘s anti-terrorism
efforts or who represent a national security threat. Because its alien
address information is unreliable, INS has had numerous difficulties
locating aliens who represented a national security threat or who could
help with the nation‘s anti-terrorism efforts.
There are several steps that INS can take to begin the process of
improving its system for maintaining alien address information. These
involve implementing a publicity campaign to make more aliens aware of
their responsibilities; making arrangements with the U.S. Postal
Service to make forms available in post offices; establishing internal
controls for ensuring that data from aliens‘ change of address forms
are consistent in all automated databases and permit the issuance of a
certificate of no record; and clarifying internal guidance to establish
that noncompliance can be the sole basis for removal. INS has begun to
take action to implement the Address Issues Task Force recommendations
that will help to improve INS‘s alien address information. As of
October 2002, INS had designated a lead agency official for address
issues. Furthermore, INS planned to reduce the number of change of
address forms, make the updating of address information a priority,
issue a request for information to identify best practices, develop a
centralized address repository, and develop compliance policies to
monitor the process.
Taking these steps should help improve the reliability of INS‘s address
information, but they would not likely result in a system that would
allow INS to locate all aliens. To a large extent, the accuracy and
reliability of INS‘s address information is contingent on aliens‘
compliance. It is reasonable to assume that INS will never be able to
know where every alien is located at any point in time because some
aliens who are in the United States illegally may not want INS to know
where they are and, therefore, will not likely comply with the address
reporting requirement. It is also likely that some aliens will not know
about the requirement or may simply forget to file the forms. Moreover,
for INS to maintain a reliable system that is based solely on alien
self-reporting would seem an almost impossible task without a
significant infusion of resources. There may be alternative cost-
effective approaches for obtaining or assembling more complete and
accurate alien address information, particularly for those aliens who
do not comply with the change of address notification requirement, that
meets the needs of INS and the law enforcement community. These
approaches include, but are not limited to, conducting a nationwide
alien address registration pursuant to the Attorney General‘s
discretionary authority, requesting legislative reinstatement of the
alien address reporting program, matching INS address data with those
of federal and/or state agencies, and purchasing address information
from commercially available sources. These approaches may expedite the
acquisition and/or reduce the cost of acquiring complete and reliable
alien address information.
Recommendations
for Executive Action:
In order to promote compliance with the change of address notification
requirements through publicity and enforcement and to improve the
reliability of its alien address data, we recommend that the Attorney
General direct the INS Commissioner to:
* Identify and implement an effective means to publicize the change of
address notification requirement nationwide. As part of its publicity
effort, INS should make sure that aliens have information on how to
comply with this requirement, including where information may be
available and the location of change of address forms.
* Develop procedures for distributing change of address forms to
include making arrangements with the U.S. Postal Service to provide for
placing change of address forms in all post offices, as required by the
Code of Federal Regulations.
* Establish written procedures and controls to ensure that alien
address information in all automated databases is complete, consistent,
accurate, and current.
* In connection with updating automated databases, establish procedures
and controls that permit INS to verify receipts of change of address
records and issue a certificate of no record, when aliens do not comply
with the change of address notification requirement.
* Revise INS‘s operating instructions to make clear that noncompliance
with address reporting requirements can be the sole basis for removal,
as provided at 8 U.S.C. 1306(b).
* Provide a field on change of address forms that an alien can use to
report a SSN or indicate that they do not have one, with the
appropriate notifications and safeguards required by law.
* Evaluate alternative approaches and their associated costs for
obtaining or assembling complete alien address information,
particularly for those aliens who do not comply with the change of
address notification requirement.
Agency Comments and Our Evaluation:
DOJ‘s Acting Assistant Attorney General for Administration provided us
with written comments on a draft of this report. In its comments, DOJ
generally concurred with five of our seven recommendations and will
proceed in accordance with them. Specifically, DOJ agreed to publicize
address notification requirements; widely distribute change of address
forms, which would include U.S. post offices; establish procedures and
controls to permit INS to enforce the penalty provisions for
noncompliance with the change of address notification requirement;
revise INS‘s internal operating instructions; and provide for aliens to
report their Social Security number or indicate they do not have one on
the change of address form. DOJ also described actions it has already
taken and some of the more significant constraints in proceeding with
the recommendations we proposed.
The constraints DOJ cited included (1) the need to revise the change of
address form and renegotiate an agreement with the U.S. Postal Service
before distributing the forms; (2) the need to develop a comprehensive
address file system to ensure that record keeping will support removal
proceedings, and (3) the likelihood that revising internal operating
instructions will not result in additional criminal prosecutions for
failing to file a change of address notice because U.S. Attorneys
generally decline to prosecute minor offenses.
We recognize that there are practical and time sequential
considerations associated with implementing our recommendations;
however, these considerations should not obviate the need to improve
the government‘s ability to locate aliens by increasing the reliability
of INS‘s alien address information. We agree that change of address
forms should be revised before they are distributed and that an
agreement with the U.S. Postal Service needs to be reached before the
forms can be placed in post offices. We further agree that INS‘s alien
address records need to be complete, consistent, accurate, and current
before they can reasonably be expected to support removal proceedings.
Also, we would not expect an increase in criminal prosecutions for
failing to file a change of address notice. However, INS investigative
officials viewed the revision of INS‘s internal operating instructions
as a necessary condition precedent to placing noncomplying aliens in
removal proceedings. We view these considerations not as constraints
but as reasonable steps that must be taken to implement our
recommendations.
DOJ did not comment on our recommendations to (1) establish written
procedures and controls to ensure that alien address information in all
automated databases is complete, consistent, accurate, and current or
(2) evaluate alternative approaches and their associated costs for
obtaining or assembling complete alien address information,
particularly for those aliens who do not comply with the change of
address notification requirement.
DOJ provided us with technical comments, which we incorporated in the
report as appropriate. DOJ‘s comments are reproduced in appendix III.
We are sending copies of the report to the Chairmen and Ranking
Minority Members of the Senate and House Committees on the Judiciary;
the Chairman and Ranking Minority Member of the Subcommittee on
Immigration, Senate Committee on the Judiciary; the Ranking Minority
Member of the Subcommittee on Immigration and Claims, House Committee
on the Judiciary; the Attorney General; the Commissioner of INS; the
Director of the FBI; the Director of the Secret Service; the Director
of the Foreign Terrorist Tracking Task Force; the Director of the
Office of Management and Budget; the Director of the Office of Homeland
Security; and other interested parties. We will also make copies
available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staffs have any questions about this report, please
contact Evi Rezmovic or me at (202) 512-8777. Key contributors to this
report are listed in appendix IV.
Richard M. Stana
Director, Justice Issues
Signed by Richard M. Stana
[End of section]
Appendix I: Scope and Methodology:
To determine the statutory framework that requires aliens to report
their addresses and any changes, and to provide historical background
information on prior alien registration requirements and programs, we
reviewed laws, regulations, and Immigration and Naturalization Service
(INS) publications and reports, including 8 U.S.C. 1301-1306 from 1940
to 2002, 8 C.F.R. 264-5; INS Annual Reports from 1941 to 1982; the
Administrative History of the INS During World War II; a 1943 Report to
the Attorney General on Alien Registration; a 1944 Report of Survey of
the Alien Registration Division; the INS Monthly Review from May 1944
to April 1952; the I&N Reporter from January 1956 to Winter 1977-
1978[Footnote 31]; the INS Information Bulletin from August 22, 1951,
through January 28, 1953; INS‘s Operating Instructions from April 19,
1954, to January 2002; and INS‘s internal publicity and operation files
for the Alien Address Report Program for 1977 through 1982. We reviewed
prior reports on alien address information issued by the Congressional
Research Service, the Department of Justice (DOJ) Office of the
Inspector General, and us. We interviewed a representative of the U.S.
Postal Service to determine if change of address forms were available
in post offices. We also observed and documented the processing of
change of address forms in INS headquarters, reviewed documentation
from a 1995 INS task force that was responsible for identifying ways to
improve the change of address program, and interviewed INS records and
computer managers and senior representatives of the Executive Office
for U.S. Attorneys.
To determine whether INS‘s alien address information can be used to
reliably locate aliens in the United States, we reviewed documentation
and interviewed senior investigators in INS‘s National Security Unit
and the San Diego District and senior representatives from the Federal
Bureau of Investigation (FBI), the Secret Service, and the Foreign
Terrorist Tracking Task Force. We did not independently review the
accuracy and reliability of INS‘s databases, nor did we independently
review the task forces‘ attempts to locate aliens. We also did not
independently verify the data provided to us by (1) INS on the numbers
of alien absconders who were sought and apprehended, and (2) the
Executive Office for U.S. Attorneys on the numbers of nonimmigrants who
were sought, had departed the country, or who were located and
interviewed.
To identify the principal factors affecting the reliability of INS‘s
alien address information, we developed audit findings by analyzing the
information we obtained during the review.
We performed our work from October 2001 through September 2002 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: An Historical Overview of INS‘s Alien Registration
Programs, 1940-1981:
From 1940 through 1944, INS‘s Alien Registration Division administered
the registration provisions of the Alien Registration Act of 1940. The
act required all aliens, except for foreign government officials and
their families, to be registered and fingerprinted. In 1950, the
Congress established an annual address reporting requirement for
resident aliens that was expanded in 1952 to cover all aliens who were
required to be registered. INS assigned responsibility for the Alien
Address Report Program to the Records Division, which administered the
program until it was ended in 1981.
The Alien Registration Program of 1940:
In implementing the Alien Registration Act of 1940, INS sought to
create an inventory of aliens in the United States to include their
locations and to maintain current address information. Beginning August
27, 1940, INS, in cooperation with the Post Office Department,
registered and fingerprinted aliens in the United States who were
required to register. As of December 31, 1940, 4,921,452 aliens had
been registered. Aliens in the United States were required to submit
(1) an official registration form, which contained information such as
name, country of birth, address, occupation, and immigration status,
and (2) a fingerprint card. INS reviewed the registration documents and
if they were found acceptable, a registration receipt card bearing the
individual number, name, and address of the registrant was issued and
mailed. Fingerprint cards were forwarded to the FBI to identify aliens
with criminal records. INS considered the requirement that resident
aliens notify of a change of address within 5 days to be important
because it provided the only statutory method for keeping these aliens‘
locations current. As of February 1, 1943, INS received about 1,850,000
notifications of changes of address. In a 1943 report to the Attorney
General on alien registration, the INS Commissioner reported that the
information collected by the Alien Registration Program had been
essential
to preserving the nation‘s internal security.
In 1944, the Commissioner requested that a survey of the Alien
Registration Division be undertaken to determine if the division‘s
functions should be integrated into the central office or should
continue to be maintained separately. The survey concluded that it
would be more efficient to integrate the division‘s functions into the
central office, and accordingly, the division was eliminated on
December
31, 1944. One of the reasons cited for eliminating the division was the
inability to maintain current address information for aliens who were
in the country. According to the survey report, an estimated 5 to 40
percent of the registered aliens had moved without filing changes of
address as required, and the U.S. Attorneys had refused to prosecute
these violations. In addition, the act did not require that aliens‘
deaths and departures be reported to the Alien Registration Division
and many were not reported. As a result, the survey concluded that it
was impossible to maintain a file of aliens‘ address cards with any
degree of accuracy.
The Alien Address Report Program of 1950:
Prior to 1950, INS had reported that aliens‘ address information,
gathered during the 1940 registration, was out of date because aliens
were not filing change of address notices, as required. In 1950, the
Congress required all resident aliens in the United States on January
1st to report their addresses to INS. In addition, resident aliens were
still required to file a change of address notice if they moved. INS
established the Alien Address Report Program. INS created Alien Address
Report Cards (Form I-53) and placed them in about 42,000 U.S. Post
Offices and 450 Immigration offices nationwide, so aliens could report
their addresses to INS. In 1951, nearly 2.4 million resident aliens
reported. Of that number, INS identified over 50,000 individual aliens
for whom INS had no record. These cases were referred to INS field
offices for investigation. INS also found a fairly high incidence of
noncompliance by comparing the address reports to alien records at the
central office. INS referred at least 120,000 noncompliance cases to
its field offices for investigation. By 1980, aliens who annually
reported their addresses to INS had increased to nearly 5.4
million.[Footnote 32] Figure 6 shows the number of annual address
reports INS received between 1951 and 1980, the last year that complete
data were available before the annual address reporting requirement was
eliminated.
Figure 6: Number of Aliens Who Reported During the Alien Address Report
Program, 1951-1980:
Note: The 1952 data are approximate.
[See PDF for image]
Source: GAO‘s analysis of INS‘s data.
[End of figure]
According to congressional and internal INS documentation, the program
was eliminated (1) to save between $542,000 and $800,000, (2) because
the address information was used primarily for statistical purposes,
and (3) because the Office of Management and Budget wanted to reduce
the public‘s annual reporting burden by about 470,000 person-hours.
Alien Registration Programs Shared Common Program Elements:
Both the Alien Registration Program and the Alien Address Report
Program shared common program elements, including (1) publicizing the
program requirements nationwide, (2) centralizing management
responsibility, (3) centralizing nationwide alien address information
which provided the capability to conduct searches, and (4)
investigating cases of alleged violations of the requirements to file a
change of address notification and/or an annual address report.
Program Requirements Were Publicized Nationwide:
INS had about 2 months to publicize the registration requirements from
the time the law was enacted on June 28, 1940, until registration
commenced on August 27, 1940. In congressional testimony, the Director
of the Alien Registration Division said that government and private
organizations conducted an educational campaign to publicize the
registration requirements. Furthermore, according to the Director, the
education effort was deemed to be effective because most aliens were
found to have registered. In many cases, those who failed to register
misunderstood the requirement.
For the Alien Address Report Program, INS undertook extensive
publication of the filing requirements each year. Through a memorandum
of understanding with the U.S. Postal Service, INS placed forms and
signs in about 42,000 post offices nationwide to instruct aliens about
the annual address reporting requirement. In addition, as shown in
figure 7, the Post Office Department cancelled postage stamps with a
cancellation that read, ’Aliens must report their addresses during
January.“ Further, INS placed public service advertisements on radio
and television to remind aliens of the annual filing requirement. INS
also prepared a poster to remind aliens of the reporting requirement
and placed it in railroad, airline, and bus terminals. According to an
INS official who worked in the program, the nationwide publicity was
responsible for ensuring that there was broad public awareness that
aliens were required to report their addresses to INS during January of
each year.
Figure 7: The Post Office Department Cancelled Stamps with a Reminder
That Aliens Must Report Their Addresses:
Note: This is a copy of the original envelope; however, the name and
return address have been redacted for privacy reasons.
[See PDF for image]
Source: Provided courtesy of John Hotchner, Past President, American
Philatelic Society.
[End of figure]
Figure 8: INS‘s 1953 Sign Placed in Post Offices Instructing Aliens to
Report Their Addresses:
[See PDF for image]
Source: GAO photograph of the original in the INS History Office
Library.
[End of figure]
Program Responsibility and Data Were Centralized:
To administer the provisions of the Alien Registration Act, INS
established the Alien Registration Division, which was responsible for
managing all aspects of the alien registration program. The four
principal objectives of the division were to:
* develop and maintain an index of information on aliens,
* verify the accuracy of information provided by aliens,
* maintain the currency of the records, and:
* produce requested or required data.
The Alien Registration Division received and processed the forms
required by the act. Registration forms were inspected upon arrival
and, if they were complete, they were numbered, coded, and microfilmed
for preservation. On December 31, 1944, the Alien Registration Division
was disbanded, and the alien registration files were forwarded to INS‘s
field offices.
In 1950, when INS established the Alien Address Report Program, it
placed responsibility for administering the program in the office with
responsibility for records administration. This office, the Records,
Administration and Information Branch, was responsible for receiving
and processing all annual reports and responding to inquiries from
within and outside the agency. By 1978, INS had automated the
processing of the annual address reports using a contractor.
Alien Registration Information Was Searchable:
Requiring all aliens to register in 1940 was intended to enable the
government to obtain comprehensive and detailed information on all
noncitizens in the United States for the first time in the history of
the nation. The nationwide information could be searched using
different criteria and was used by INS for purposes such as conducting
background checks on naturalization applicants. According to an
internal INS report, prior to alien registration, INS was hampered in
these investigations by a lack of sufficient information. The alien
registration information remedied this situation. In addition to using
the data for their own purposes, INS began receiving war time requests
for information from other federal agencies. However, before
information could be released, it required the approval of the Attorney
General as the act required that all registration information be kept
confidential.
Examples of the requests that INS received and were granted by the
Attorney General are shown in table 1.
Table 1: Examples of Requests for Alien Registration Data INS Approved
and Their Intended Use:
Requesting agency: Treasury Department; Intended use: Freeze funds of
aliens with enemy nationalities.
Requesting agency: Federal Communications Commission; Intended use:
Identify licensed radio operators.
Requesting agency: Civil Aeronautics Board; Intended use: Identify
alien pilots.
Requesting agency: Selective Service System; Intended use: Identify
aliens who failed to register for the draft.
Requesting agency: War and Navy Departments; Intended use: Identify
aliens applying for employment in wartime industries.
Requesting agency: Office of Export Control and Defense Board; Intended
use: Identify aliens engaged in exporting.
Requesting agency: Securities and Exchange Commission; Intended use:
Identify aliens in violation of securities acts.
Note: Information on the date the specific request was made and the
specific information that was requested were not available.
Source: GAO‘s analysis of INS data.
[End of table]
However, all requests for alien registration data were not granted.
Table 2 shows some examples of requests that were denied. INS
documentation does not provide the reasons for the denials.
Table 2: Examples of Requests for Alien Registration Data INS Denied
and Their Intended Use:
Requester: Welfare organizations; Intended use: Citizenship and
nationality of persons applying for aid.
Requester: Relatives; Intended use: Locate missing relatives who were
aliens.
Requester: Creditors; Intended use: Locate alien debtors.
Requester: Attorneys; Intended use: Divorce and/or custody proceedings.
Requester: Prisoners of war; Intended use: Locate relatives.
Note: Information on the date the specific request was made and the
specific information that was requested were not available.
Source: GAO‘s analysis of INS data.
[End of table]
In cases where relatives were trying to find an alien, INS would notify
the alien that his or her relatives were seeking to locate him or her.
They would not release the alien‘s location to the relatives. In a 1943
report to the Attorney General on the alien registration program, the
INS Commissioner said,
’Primarily intended as a safeguard, the Act has made it possible to
provide war agencies and agencies concerned with the internal security
of the nation with the specific and essential information about
individual aliens and groups of aliens. At the same time, it has
afforded the Government an opportunity to gather basic sociological
data about our alien population that has long been needed for
legislative and educational purposes.“
As with the 1940 alien registration program, INS centrally received and
processed the alien address report program information. However, where
the 1940 registration program sorted punched cards using tabulation
equipment, the 1950 program eventually established an automated
database and entered nationwide address-related information into it,
thus enabling INS to readily conduct searches. INS collected
information that was used by agencies to locate aliens, identify alien
migration patterns, develop investigative leads, estimate the
naturalization workload, correspond with aliens, and plan resource
allocation. As shown in table 3, INS also received requests from the
Congress and federal, state, and local government agencies.
Table 3: Examples of Requests for Alien Address Report Program Data INS
Approved and the Intended Uses:
Requesting agency: Congress; Intended use: About 100 requests per year
for alien data.
Requesting agency: State and local governments; Intended use: Requests
for alien data.
Requesting agency: Department of Justice: Office of Special
Investigations; FBI; Drug Enforcement Administration; Department of
Treasury; Customs Service; Secret Service; Intended use: Locate aliens.
Requesting agency: Department of State: Cuban/Haitian Task Force;
Intended use: Allocate state refugee funding, identify unaccompanied
minors, and validate and correct refugees‘ files.
Requesting agency: Department of Health and Human Services:
Office of Refugee Resettlement; Intended use: Allocate state and local
refugee funding.
Requesting agency: Department of Commerce: Bureau of the Census;
Intended
use: Estimate illegal alien population, identify Cuban refugee
locations,
and track alien migration.
Note: Information on the date the specific request was made and the
specific information that was requested were not available.
Source: GAO‘s analysis of INS data.
[End of table]
Change of Address and Annual Address Reporting Violations Were
Investigated:
In 1941, INS organized the Special Inspections Division to enforce the
Alien Registration Act of 1940. The Division was responsible, among
other things, for identifying aliens who had failed to register or
report a change of address. However, enforcing the change of address
provisions proved difficult for INS because U.S. Attorneys generally
declined to prosecute the cases.
One potential method used by INS investigators to identify possible
violators of the change of address requirement involved mail that was
returned to INS by the Post Office Department. For example, INS mailed
registration receipt cards to aliens who had submitted acceptable
registration documents. Of about 5 million cards that were sent out,
480,000 were returned by the Post Office. Following a second mailing,
160,000 of the 480,000 were again returned by the Post Office. The
160,000 aliens, whose cards were returned, could have been investigated
as potential violators of the change of address filing requirement. INS
identified many violations of the change of address requirement;
however, U.S. Attorneys generally refused to prosecute the offenders.
According to the INS Commissioner in a letter to the Bureau of the
Budget at that time,
’Although a penalty is provided for failure to notify change of
address, practically every United States Attorney has refused to
prosecute unless it is shown that such failure was willful. As a matter
of fact, the majority of the United States Attorneys have issued
blanket waivers of prosecution in these cases and have requested this
Service not to present them unless it is shown that the violation was
willful. During the calendar year 1943, some 7,488 investigations were
conducted of aliens who failed to notify change of address; 4,287 such
cases were presented to the United States Attorneys, and only 19
convictions were obtained. It is not possible to make an accurate
estimate of how many registrants have failed to report changes of
address.“[Footnote 33] According to the 1944 Survey of the Alien
Registration Division to the INS Commissioner, INS staff estimated that
between 5 and 40 percent of the registered aliens had not notified INS
of their new address.
INS does not appear to have enforced the removal penalty for
noncompliance since the early 1970s. INS‘s historical records from 1950
to 2002 do not identify the number of aliens who were placed in removal
proceedings for failing to file a change of address notification.
According to an official with Executive Office for Immigration Review,
their records date from 1988 and contain no cases where aliens were
charged and placed in removal proceedings for failing to file a change
of address notification. A review of federal cases and cases brought on
appeal from the Executive Office for Immigration Review to the Board of
Immigration Appeals indicates just a few instances where INS charged an
alien with failure to file a notification of address or change of
address in a removal proceeding.[Footnote 34] We also found a few cases
where an alien was prosecuted for failure to give notice of an address
or change of address.[Footnote 35]
[End of section]
Appendix III: Comments from the Department of Justice:
U.S. Department of Justice:
Washington, D.C. 20530:
November 7, 2002:
Mr. Richard M. Stana, Director, Justice Issues, Tax Administration and
Justice Team, U.S. General Accounting Office:
441 G Street, N. W. Washington, D C. 20548:
Dear Mr. Stana:
On October 9, 2002, the General Accounting Office (GAO) provided the
Department of Justice (DOJ) copies of its draft report entitled
’Homeland SECURITY: INS Cannot Locate Many Aliens Because It Lacks
Reliable Address Information.“ The Immigration and Naturalization
Service (INS) is pursuing vigorously a long-range strategy to manage
alien addresses. These efforts include establishing an Address Issues
Task Force, designating a specific unit to handle address issues, and
conducting a study of the operational and functional address needs of
the INS in order to develop and maintain an address repository of alien
addresses. While the INS and the Department generally concur with the
report recommendations and will proceed in accordance with them, we
would like to describe actions already taken and discuss some of the
more significant constraints in proceeding with the recommendations as
proposed.
Recommendation: Identify and implement an effective means to publicize
the change of address notification requirements nationwide. As part of
its publicity effort, INS should make sure aliens have notification on
how to comply with this requirement, including where information is
available and the location of change of address forms.
The INS concurs with this recommendation. As previously discussed with
GAO representatives, INS‘ long-term strategy includes a nation-wide
effort to publicize the address reporting requirements.
The GAO draft report, however, does not appear to recognize past
efforts by the Department of Justice and the INS to publicize the
change of address requirements of the Act. For example, the GAO draft
report points to the NPRM published by the Department of Justice on
June 13, 2002, as indicative of the need for nation-wide publicity of
these requirements. The proposed rule:
establishing the National Security Entry - Exit Registration System set
out the address notification requirements. 67 FR 40581, 40583 (June 13,
2002). The final rule, promulgated on August 12, 2002, reiterated this
requirement and further explained the requirements and how those
requIrements related to the National Security Entry-Exit Registration
System 67 FR 52584, 52587-52588 (Aug. 12, 2002). These points were
reiterated in the Attorney General‘s implementing Notices published
pursuant to the final rule.
Moreover, the Attorney General has promulgated a specific NPRM to
ensure that aliens are aware of and comply with the change of address
notification requirements in light of a Board of Immigration Appeals
decision that pointed out the shortcomings of the current system. 67 FR
48818 (July 26, 2002). This proposed rule would amend the regulations
of the INS by requiring every alien who is applying for immigration
benefits to acknowledge having received notice that he or she is
required to provide a valid current address to the Service, including
any change of address within 10 days of the change; that the Service
will use the most recent address provided by the alien for all
purposes, including the service of a Notice to Appear if the Service
initiates removal proceedings; and, if the alien has changed address
and failed to provide the new address to the Service, that the alien
will be held responsible for any communications sent to the most recent
address provided by the alien. This rule will satisfy the requirements
for advance notice to the alien of the obligation to provide a current
address to the Service, and of the consequences that may result for
failure to do so, including the entry of an in absentia removal order
against the alien in accordance with 8 CFR 3.26 if the alien fails to
appear at a removal hearing. This advance notice will avoid the kind of
problems that have arisen in the past where aliens have failed to
provide a new address. See Matter of G-Y-R-, 23 I&N Dec. 181 (BIA
2001). The INS is currently analyzing the comments received on this
NPRM, but the type and number of comments received clearly indicates
that this NPRM and other actions already taken, have made the
requirements of the law very clear to the immigration community.
In each of these instances, both the Department and the INS have
publicized the requirements that aliens report changes of address to
the INS, not only through official statements and press releases
directed to a wide range of media outlets, but through community
relations efforts directed to the specific immigrant populace. We
believe that the GAO report would be more informative if it reflected
more of the efforts that have already been undertaken.
Recommendation: Develop procedures for distributing change of address
forms to include making arrangements with the U.S. Postal Service to
provide for placing change of address forms in all post offices, as
required by the CFR.
The INS generally concurs with this recommendation. As previously
discussed with GAO representatives, INS‘ long-term strategy includes
wide distribution of change of address forms and the submission of
forms through the Internet and other media. INS will examine all
possible distribution sources, including the United States Postal
Service.
GAO should understand that the requirements of the law have been widely
publicized in recent months, with, as GAO correctly points out, over
700,000 forms being filed within the two months following the
publication of the notification of address requirements rule. Form AR-
11 is currently available on the internet through the INS website. See:
http://www.ins. usdoj.gov/graphics/formsfee/forms/files/ar-1 1.pdf
(English edition). We should note that this form is also available in
Spanish, Chinese and Russian.
The INS also agrees that it is prudent and efficacious to provide the
forms at all United States Post Offices. However, that process is one
that will require renegotiation with the United States Postal Service.
Although current INS regulations recognize this process, the provision
of large numbers of forms at this moment may not be the most efficient
means of gathering the information. As noted in the proposed rules
cited above, the INS is currently revising a number of forms, including
Form ARA 1, to ensure better compliance. After that revision takes
place and the Attorney General approves a final rule, it will be
important to ensure that the new forms are distributed as widely as
possible and to assist aliens in complying with the law.
Recommendation: In connection with updating automated databases,
establish procedures and controls that permit INS to verify receipts of
change of address records and have a certificate of no record, when
aliens do not comply with the change of address notification
requirement.
The INS concurs. When in place, the alien address repository will
provide a confirmation of receipt to aliens submitting change of
address information. When conducting a search within the system, INS
will have the address repository return the alien‘s last recorded
address or an appropriate ’no record“ certification to the searcher
when the system does not contain an address for the given alien. INS
agrees that the address repository must provide accurate and timely
information to search requests.
Recommendation: Revise INS‘ operation instructions to make clear that
noncompliance with address reporting requirements can be the sole basis
for removal, as provided in 8 USC 1306(b).
The INS concurs, but for different reasons than underlie the
recommendation. INS agrees that failure to report changes of address
under 8 USC 1306(b) can form the sole basis for removal. However,
recognizing the shortcomings of the current address file, INS believes
it is more important to develop a comprehensive address file system and
ensure that recordkeeping will support removal before attempting to
undertake removals solely on this basis.
Congress has mandated the development of a comprehensive, universal
entry - exit system by 2005. The INS supports that goal and believes
that management information must be brought into line with that goal.
At the point that at which adequate assurance that an alien is on
sufficient Notice of the responsibility to file a change of address,
together with adequate assurance that any change of address has been
properly accounted for, the INS will consider revisiting internal
operating instructions and more aggressive enforcement of 8 USC
1306(b). At this time, it would be premature to change the operating
instructions and invite unnecessary litigation.
We should also note that section 266(b) includes a criminal sanction
and that the revision of these internal operating procedures, when the
are implemented, will not perforce result in additional criminal
prosecutions. The penalties for willful failure to file a notice of a
change of address are generally not conducive to the filing of criminal
charges. Section 266(b) of the Immigration and Nationality Act (8
U.S.C. § 1306(b)) provides that an alien who wilfully fails to file a
notice of change of address may be imprisoned for 30 days and fined
$200. In light of ever increasing demands for the scarce prosecutorial
resources of the United States Attorneys and judicial resources of the
United States District Courts, merely changing internal operating
instructions and making referrals will not provide greater enforcement
or deterrent and compliance value. As a general rule, the United States
Attorneys will decline to prosecute such minor offenses. If enforcement
of the requirement to file a notice of change of address is to be
effective, these penalties would need to be substantially increased.
Only then will a change in operating procedures and referring cases to
the United States Attorneys be effective.
Recommendation: Provide a field on the address change form that an
alien can use to report an SSN or indicate that they do not have one,
with appropriate certifications and safeguards as required by law.
The INS concurs. The INS is currently reviewing and revising Form AR-
11, as well as other forms for collection of changes of address
information. Many aliens in the United States do not have a social
security number, so inclusion of a social security number in these
forms will have a limited benefit. However, fNS believes that this
added identifying is worth making the change and will attempt to do so,
consistent with all of the legal requirements for utilizing social
security numbers.
I hope you will consider our concerns in preparing the final GAO report
on this subject. If you have any questions regarding the Department‘s
comments, you may contact Vickie L. Sloan, Director, Audit Liaison
Office, on (202) 514-0469.
Sincerely,
Robert F. Diegelman, Acting Assistant Attorney General for
Administration
Signed by Robert F. Diegelman
Appendix IV: GAO Contacts and Staff Acknowledgments:
Contacts:
Richard M. Stana (202) 512-8777
Evi L. Rezmovic (202) 512-8777:
Acknowledgments:
In addition to the above, James M. Blume, Leah S. DeWolf, Jan B.
Montgomery, Ann H. Finley, Elizabeth Anne Laffoon, Leo M. Barbour, Mary
Catherine Hult, Kimberly A. Hutchens, Maureen R. Shields and Jay
Jennings made key contributions to this report.
FOOTNOTES
[1] References in this report to aliens, unless otherwise specified,
refer to those immigrants and nonimmigrants in the United States who
are required to provide address information.
[2] On October 29, 2001, the President directed the Attorney General to
create the Foreign Terrorist Tracking Task Force (Homeland Security
Presidential Directive - 2, National Security Presidential Directives).
The task force is to ensure that federal agencies coordinate their
programs so that aliens associated with, suspected of being engaged in,
or supporting terrorist activity are to be denied entry into and
removed from the United States.
[3] Registration is a shared responsibility between the Departments of
State and Justice. The Attorney General is responsible for registering
aliens who remain in the United States for 30 days or more and who have
not otherwise registered, such as during the visa application process
administered by the Department of State. The Attorney General is also
responsible for collecting change of address information and issuing
certificates of registration.
[4] See Department of Justice, Office of the Inspector General,
Immigration and Naturalization Service Monitoring of Nonimmigrant
Overstays, Report Number I-97-08 (Washington, D.C.: Sept. 1997); and
Follow-Up Report On INS Efforts To Improve The Control of Nonimmigrant
Overstays, Report No. I-2002-006, (Washington, D.C.: Apr. 2002).
[5] P.L. 104-208, codified at 1365a.
[6] Section 641, codified at 8 U.S.C. 1372.
[7] The Congress is considering the inclusion of INS in the Office of
Homeland Security.
[8] Diplomats, representatives of international organizations and their
families, and individuals remaining in the United States for less than
30 days are not required to register.
[9] 86 Cong. Rec. H. 9033 (June 22, 1940) (statement of Rep. C.E.
Hancock, one of the House managers).
[10] Ch. 439, 54 Stat. 670 (1940).
[11] The Internal Security Act of 1950 required alien residents to
annually report their addresses. Ch. 1024, 64 Stat. 987. The law also
extended coverage to nonimmigrants who had overstayed their visas and
any alien in an illegal status.
[12] Immigration and Nationality Act, Ch. 477, 66 Stat. 163 (1952).
[13] Immigration and Nationality Act Amendments of 1981, P.L. No. 97-
116, 95 Stat. 1611 (1981).
[14] The Attorney General‘s discretionary authority in 8 U.S.C. 1305(b)
extends to ’the natives of any one or more foreign states, or any class
or group thereof“ referred to here as aliens.
[15] The current requirements for alien registration and change of
address are codified at
8 U.S.C. 1301-1306.
[16] The current penalties for noncompliance with registration and
change of address requirements are codified at 8 U.S.C. 1306.
[17] 67 Fed. Reg. 40581 (June 13, 2002).
[18] 67 Fed. Reg. 52584 (August 12, 2002).
[19] 67 Fed. Reg. 48818 (July 26, 2002).
[20] According to an Executive Office for U.S. Attorneys‘ report, ’a
small percentage“ of aliens were located and declined to be
interviewed.
[21] 8 U.S.C. 1304(f).
[22] INS collected but did not process alien address reports in 1981.
[23] Not every alien is required to have an SSN.
[24] 8 C.F.R. 265.1.
[25] For example, Matter of Winter, 12 I. and N. 638, (BIA, Feb. 9,
1968), Sevitt v. Del Guercio, 150 F. Supp. 56 (S.D. Cal. 1957).
[26] For example, U.S. v. Ushi Shiroma, 123 F. Supp. 145 (D. Haw.
1954), U.S. v. Ginn, 222 F. 2d 289 (3rd Cir. 1955). In addition, during
the period of time when annual address report requirements were in
effect, we identified several Board of Immigration Appeals and federal
court cases relating to the enforcement of this provision. See U.S. v.
Sacco, 428 F. 2d 264 (9th Cir. 1970), Patsis v. Immigration &
Naturalization Service, 337 F2d 733 (8th Cir. 1964), Matter of S, 7 I.
and N. 536, (BIA, Aug. 19, 1957), Matter of M, 5 I. and N. 216, (BIA,
May 6, 1953), Matter of B, 5 I. and N. 692, (BIA, Mar. 2, 1954).
[27] INS Operations Instructions 265.1(a), TM 105 revised 11/17/82, p.
4341.
[28] The Comptroller General‘s standards for federal internal controls
specify that control activities should be established to ensure
transactions are completely and accurately recorded in a timely manner.
[29] Some of the automated databases that contain address information
are: the Employment Authorization Document System; Marriage Fraud
Amendment System; Computer Linked Application Information Management
System 3 and 4; Deportable Alien Control System; Re-engineered
Naturalization Application Casework System; Refugees, Asylum, and
Parole System; Integrated Card Production System; Global Enrollment
System; Arrival Departure Information System; Enforcement Case Tracking
System; Student and Schools System; General Counsel Electronic
Management System; Student Exchange Visitor Information System; Asylum
Pre-screening System; and the Nonimmigrant Information System.
[30] The majority of alien sponsors, who are to complete Form I-865,
are U.S. citizens. Only those sponsors who are aliens would need to
have their addresses updated.
[31] In 1976, the I&N Reporter was renamed the ’INS Reporter.“
[32] INS received annual address reports in 1981, but did not process
them.
[33] ’Survey of the Alien Registration Division,“ letter of
Commissioner Harrison to E.B. Wilber, Bureau of the Budget, March 6,
1944.
[34] For example, Matter of Winter, 12 I. and N. 638, (BIA, Feb. 9,
1968), Sevitt v. Del Guercio, 150 F. Supp. 56 (S.D. Cal. 1957)
[35] For example, U.S. v. Ushi Shiroma, 123 F. Supp. 145 (D. Haw.
1954), U.S. v. Ginn, 222 F. 2d 289 (3rd Cir. 1955). In addition, during
the period of time when annual address report requirements were in
effect, we identified several BIA and federal court cases relating to
the enforcement of this provision. See U.S. v. Sacco, 428 F. 2d 264
(9th Cir. 1970), Patsis v. Immigration & Naturalization Service, 337
F2d 733 (8th Cir. 1964), Matter of S, 7 I. and N. 536, (BIA, Aug. 19,
1957), Matter of M, 5 I. and N. 216, (BIA, May 6, 1953), Matter of B, 5
I. and N. 692, (BIA, Mar. 2, 1954).
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