U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division

Follow-up Review of the FBI’s Progress 

Toward Biometric Interoperability 

Between IAFIS and IDENT 

July 2006 

I-2006-007 
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Office of the Inspector General 

Evaluation and Inspections Division

EXECUTIVE SUMMARY 

 

This is the Office of the Inspector General’s (OIG) sixth review 

examining the ability of federal law enforcement and immigration 

authorities to share automated fingerprint identification information.1 In 

this report, we describe the progress since December 2004 toward achieving 

full interoperability between two automated fingerprint systems: the 

Federal Bureau of Investigation’s (FBI) Integrated Automated Fingerprint 

Identification System (IAFIS) and the Department of Homeland Security’s 

(DHS) Automated Biometric Identification (IDENT). We also describe the 

DHS’s efforts to make its United States Visitor and Immigrant Status 

Indicator Technology (US-VISIT) system interoperable with IAFIS. Achieving 

full interoperability among these systems is intended to provide federal, 

state, and local law enforcement and immigration officials with direct, realtime access to information in the millions of criminal history and 

immigration records in IAFIS, IDENT, and US-VISIT. 

U.S. immigration authorities have long recognized the need for an 

automated fingerprint identification system to quickly determine the 

immigration and criminal histories of aliens they apprehend. The FBI and 

the former Immigration and Naturalization Service (INS), now part of the 

DHS, began discussing integrating IAFIS and IDENT in the early 1990s, 

when the two systems were under development. However, the agencies had 

a difference of opinion, stemming from the different purposes of their 

systems, as to the number of fingerprints to collect from apprehended 

individuals. The FBI created IAFIS to automate its Criminal Master File of 

10 rolled fingerprints and serve the needs of the broader law enforcement 

community.2 The INS created IDENT using two flat fingerprints to quickly 

 1 The previous five reports are: The Rafael Resendez-Ramirez Case: A Review of the 

INS’s Actions and the Operation of its IDENT Automated Fingerprint Identification System, 

March 2000; Status of IDENT/IAFIS Integration, December 2001; Status of IDENT/IAFIS 

Integration, June 2003; IDENT/IAFIS: The Batres Case and the Status of the Integration 

Project, March 2004; and Follow-up Review of the Status of IDENT/IAFIS Integration, 

December 2004. For a description of each report, see the Background and Appendix of the 

OIG’s December 2004 report, available at 

www.usdoj.gov/oig/reports/plus/e0501/index.htm. 

2 IAFIS contains the largest criminal biometric database in the world, the Criminal 

Master file, which stores over 50 million fingerprint sets and corresponding criminal history 

information submitted by federal, state, and local law enforcement agencies. The Criminal 

Master File records follow the law enforcement standard of taking prints from all 10 fingers 

by rolling and pressing each finger on either a scanner or a standard paper fingerprint 

record form (10 rolled prints). Fingerprints also may be taken by pressing fingers straight 

down (flat fingerprints) and from fewer than 10 fingers. 
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process large groups of apprehended aliens.3 Because of the different 

fingerprint collection methods, the FBI and INS systems could not initially 

share information. The inability of these immigration and law enforcement 

fingerprint identification systems to share information prevented law 

enforcement agencies from identifying fully the criminals and wanted aliens 

in their custody, and has led to tragic results. In March 2004, the OIG 

described one such case, in which border authorities twice released a man 

with an extensive criminal record attempting to enter the country illegally. 

He subsequently returned to the United States illegally and traveled to 

Oregon where he raped two nuns, killing one. Because the federal 

government’s immigration and law enforcement fingerprint databases were 

not linked, the immigration agents who stopped and released the man at the 

border never learned of his criminal record. (See IDENT/IAFIS: The Batres 

Case and the Status of the Integration Project, March 2004.) 

In another report, published in December 2004, we found that the 

differing fingerprint collection requirements of the FBI and the DHS were 

one of two principal barriers that had created an impasse in achieving full 

interoperability between IAFIS and IDENT.4 In that report, we noted that 

the DHS and the Department of State (DOS), which is responsible for 

collecting fingerprints from visa applicants, had not agreed to implement the 

National Institute of Standards and Technology (NIST) recommendation of 

10 flat fingerprints as the uniform method for collecting fingerprint 

information and for searching against large databases.5 We recommended 

that the Department report to the President’s Homeland Security Council or 

Congress that it had reached an impasse in interoperability planning and 

3 The DHS subsequently designed US-VISIT to use IDENT to collect two flat 

fingerprints and a digital photograph from foreign nationals. IDENT contains the 

fingerprints of over 55 million individuals, including legitimate travelers and immigration 

violators. According to the DHS, IDENT processes 150,000 to 230,000 daily fingerprint 

identifications and verifications. 

4 The second principal barrier was that the DHS and the Department of Justice 

(Department) disagreed on the details of how to make “readily and easily accessible” to 

federal, state, and local law enforcement agencies the fully interoperable system specified in 

the USA PATRIOT Act (Patriot Act) and in subsequent congressional legislation. 

 

5 The NIST Technology Standard, issued in January 2003, calls for 10 flat 

fingerprints to be collected from foreign nationals and 2 flat fingerprints and a digital 

photograph to be used to verify a foreign national’s identity against an existing enrollment 

record. 
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formally request that a decision be made on whether to adopt the NIST 

Technology Standard.6

In our December 2004 report, we also found that the DHS was 

checking most visitors’ fingerprints against an IDENT database 

supplemented by IAFIS extracts rather than against the full IAFIS 

database.7 Checking only a subset of the IAFIS database created a risk that 

criminal aliens or terrorists could enter the United States undetected, 

highlighting the need for immigration and law enforcement fingerprint 

identification systems to share information in order to fully identify the 

criminals and wanted aliens in their custody. We concluded that for the 

Department to effectively proceed with making IAFIS interoperable with the 

biometric fingerprint systems of the DHS, high-level policy decisions needed 

to be made regarding who should be subjected to fingerprint searches, the 

fingerprint collection standard to be used, which of the databases should be 

queried, who should have access to the information, how the information 

should be used, and who should maintain the databases. In that report, we 

made five other recommendations to the Department related to the provision 

of IAFIS extracts to the DHS, risk analysis, sufficiency of IAFIS’s capacity for 

conducting all of the fingerprint searches the DHS requested, upgrades to 

IAFIS’s performance, and IAFIS availability to users of the system. 

In this follow-up to our December 2004 report, we examined 

interoperability planning documents; interagency correspondence; working 

group agendas; and IAFIS data on capacity, availability, and workload. We 

also interviewed officials from the Department, DHS, DOS, and NIST, and 

analyzed data from all four agencies. The scope of this report includes the 

interoperability progress made from December 2004 through June 2006. 

Because of the dynamic nature of the project, the details described in this 

report may change before the project is completed. 

RESULTS IN BRIEF 

The primary barrier to achieving full interoperability among 

federal biometric fingerprint systems was resolved in May 2005 when 

the DHS agreed to use 10 flat fingerprints as the standard for 

6 The Homeland Security Council, under the Executive Office of the President, is 

responsible for ensuring coordination of all homeland security-related activities among 

executive departments and agencies. 

7 At that time, the DHS was requesting IAFIS fingerprint searches on less than 

1 percent of the visitors subjected to US-VISIT (about 800 per day) at ports of entry. 
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US-VISIT.8 In response to that decision, the FBI and the DHS are 

implementing the first phase of a three-phase plan to make IAFIS and 

IDENT, including US-VISIT, fully interoperable by December 2009. In 

the first phase, the agencies plan to deploy a joint automated system 

for near real-time sharing of certain key immigration and law 

enforcement data between the FBI and the DHS by September 3, 

2006.9 The data to be shared are the FBI’s “Wants and Warrants” 

records that have fingerprints associated with them and the DHS’s 

“Visa Denial” and “Expedited Removal” records.10 

In the remaining two phases, the FBI and the DHS plan to 

expand the data shared to include law enforcement and immigration 

data in IAFIS, IDENT, and US-VISIT and to allow access to that data 

by federal, state, and local law enforcement agencies, authorized noncriminal justice agencies, and immigration authorities.11 By 

December 2009, IAFIS and IDENT users are expected to be able to 

submit a single request that searches all fingerprint records 

maintained by the FBI and the DHS to receive associated criminal 

history and immigration information about the subject. As of June 

2006, FBI officials stated that they are on schedule for achieving full 

interoperability among IAFIS, IDENT, and US-VISIT by December 

2009. 

To support full interoperability, the FBI is upgrading IAFIS to process 

more flat (in lieu of rolled) fingerprint submissions, and the DHS is planning 

to modernize IDENT and convert US-VISIT from a 2- to a 10-fingerprint 

8 The second barrier that we identified in our December 2004 report has been 

partially resolved. The DHS has agreed to provide the FBI and other law enforcement 

agencies with access to immigration data; however, the FBI and the DHS have not finalized 

a method of providing this access. 

9 According to the FBI, “near real time” means that information will be updated 

within 24 hours. However, the FBI plans to update this information more quickly after 

September 2006. 

 

10 Wants and Warrants are records of individuals with active warrants from the 

Wanted Persons file of the FBI’s National Crime Information Center. Visa Denials are the 

DOS’s “Biometric Visa Application Category 1 Critical Refusals,” which are fingerprint 

records from applicants whose visas were denied because the DOS determined that they 

posed a substantial risk to the United States. Expedited Removals are records of aliens 

removed from the United States because they lacked proper documentation or committed 

fraud when attempting to enter the United States. 

11 Authorized non-criminal justice agencies are those agencies permitted to request 

criminal background checks for employment, licensing, immigration, credentialing, and 

volunteer activities. 
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system. The FBI and the DHS are also working to develop an estimate of 

interoperability costs; have identified technical, funding, and policy risks to 

achieving full interoperability; and have developed risk mitigation strategies. 

To lessen the risk that criminal aliens or terrorists will enter the 

United States undetected before a fully interoperable system is 

available, the FBI has taken interim actions. These include providing 

daily transmissions of key terrorist records to the DHS, improving 

overall IAFIS availability and capacity for DHS fingerprint searches, 

and reducing the response time to DHS requests for checks of aliens’ 

fingerprints. However, Department officials feel that the DHS should 

initiate a risk analysis to determine how many individuals who are 

exempt from the US-VISIT requirements have records in IAFIS. 

We now discuss in more detail the three-phase interoperability 

plan, IAFIS and IDENT upgrades and the US-VISIT transition to 

10 fingerprints, interoperability cost estimates, interoperability risks, 

the FBI’s interim actions, and the risk analysis. 

The FBI and the DHS are implementing the first phase of a three-phase 

plan for achieving full interoperability. 

In May 2005, the DHS Secretary announced that the DHS would 

adopt a 10-fingerprint collection standard for enrolling visitors into 

US-VISIT, as recommended by the NIST. This decision resolved the primary 

barrier to achieving interoperability among the FBI’s IAFIS and the DHS’s 

IDENT and US-VISIT. The resolution of this issue allowed the FBI and the 

DHS to begin planning and implementing a three-phase approach to achieve 

full interoperability. In May 2005, the FBI, DHS, and DOS formed an 

Integrated Project Team (IPT) to develop a plan to achieve full 

interoperability in the following three phases: Interim Interoperability, 

Initial Operating Capability (IOC), and Full Operating Capability (FOC). 

Interim Interoperability 

The interim interoperability phase, currently being developed, is 

scheduled to be implemented by September 3, 2006. This phase uses an 

interim Data Sharing Model (iDSM), which is intended to enable the FBI and 

the DHS to directly access read-only copies of certain key law enforcement 

and immigration data from IAFIS and IDENT in near real time. By 

replicating the data (described below), the FBI and the DHS will each be able 

to conduct fingerprint searches against the other agency’s records at their 

respective locations. The replicated files will also provide a 24-hour backup 

for those shared IAFIS and IDENT records. The FBI’s and the DHS’s 

replicated files are expected to initially accommodate up to 1 million records 
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each. According to IPT planning documents, the iDSM will deliver the first 

interoperable biometric data capability between the FBI and the DHS and is 

intended to serve as a prototype for full interoperability. 

For the iDSM to become operational, the FBI and the DHS must 

identify the records to be shared and then exchange those records. As of 

June 2006, the FBI and the DHS had each agreed to share read-only copies 

of the approximately 800,000 FBI Wants and Warrants records that have 

fingerprints associated with them, 16,000 DOS Visa Denial records, and 

390,000 DHS Expedited Removal records. These three sets of records were 

identified as being the most useful to support FBI and DHS missions and 

IAFIS and IDENT users’ needs. FBI officials told us that, as of June 2006, 

the iDSM’s development was on schedule and that it is expected to become 

operational by September 3, 2006. 

In addition to developing the iDSM to provide the initial 

interoperability capability, the FBI has taken steps to improve the records 

available to the DHS until the iDSM becomes operational. On November 30, 

2005, the FBI began expanding the Wants and Warrants records extracted 

from IAFIS to provide the DHS with all newly issued or updated warrants 

created after November 2005, including those for U.S. citizens. Prior to 

November 30, 2005, the DHS had access only to a subset of the Wants and 

Warrants records that did not include U.S. citizens. The DHS’s immediate 

access to these additional records allows immigration officials to conduct 

fingerprint searches using more complete and current information. 

After September 3, 2006, when the iDSM is expected to become 

operational, the FBI and the DHS plan to begin using and testing the iDSM 

by conducting fingerprint searches against the data and tracking the 

number of fingerprint matches. The FBI plans to enable three agencies to 

submit fingerprint searches through IAFIS to be run against the DHS’s 

records. The three agencies are the Boston Police Department, the Texas 

Department of Public Safety, and the U.S. Office of Personnel Management. 

Those agencies represent state and local law enforcement and a federal 

agency authorized to conduct fingerprint searches for non-criminal justice 

purposes. The FBI is planning to divide the initial iDSM search capacity of 

1,000 daily fingerprint searches among those three agencies. The DHS is 

planning to use the iDSM to continue searching visitors’ fingerprints against 

the FBI’s Wants and Warrants records; once the iDSM is operational, the 

DHS will be able to conduct those searches against all Wants and Warrants 

records that contain fingerprints rather than a subset of the records. 
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Initial Operating Capability

The IOC development phase is scheduled to last approximately 22 

months, beginning on September 4, 2006, and ending in July 2008.12 At 

the beginning of the IOC phase, the IPT must choose one of three technical 

solutions currently under consideration for achieving full interoperability. 

The three technical solutions are the shared data model, the shared services 

model, and the base case. Under the shared data model, the FBI and the 

DHS would independently maintain their own biometric (e.g., fingerprint) 

and biographic data (e.g., name, date of birth, social security number), but 

would provide a copy of the fingerprint data to the other agency. The 

receiving agency would be responsible for searching the data and requesting 

the associated biographic information when a match is encountered. The 

shared services model would not utilize copies of the FBI’s and the DHS’s 

fingerprint data. Instead, each agency would maintain control over its data 

by requesting that the other agency perform a fingerprint search and return 

the associated biographic information. Finally, the base case option refers 

to a slightly improved version of the operational iDSM, which the FBI stated 

would encompass the DHS’s efforts to modernize IDENT as they occur. 

The FBI considers the iDSM to be a prototype of the shared data 

model because it allows the FBI and the DHS to access copies of each 

other’s fingerprint data located on their own servers. The iDSM also 

includes a shared services component in that the FBI and the DHS must 

each request immigration and criminal history data from the agency that 

owns the data when a fingerprint match is encountered. Although the FBI 

and the DHS have not made a final decision on the technical solution for 

full interoperability, they are implementing the iDSM to test the shared data 

approach. 

During the IOC development phase, the FBI and the DHS expect to 

have access to one another’s basic immigration and criminal history 

information associated with any fingerprint searches that result in a match. 

Specifically, the FBI and the DHS plan to: (1) expand the data shared 

between them; (2) establish the initial fingerprint search capacity and 

storage needed for full interoperability; (3) allow federal, state, and local 

agencies limited access to immigration data, which includes basic 

biographic data; and (4) provide immigration authorities full access to 

criminal history information. 

 12 The IPT’s plans call for the records in the iDSM to remain available for 

conducting fingerprint searches throughout the 22-month IOC development phase. 
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Expanded data sharing. During the IOC development phase, the FBI 

and the DHS plan to expand the data accessible to each agency beyond the 

records initially selected for sharing through the iDSM. With IOC, the FBI 

expects to have access to all biometric records in IDENT, and the DHS 

expects to have access to all biometric records from the IAFIS Criminal 

Master File.13 The method of providing this access will depend on which of 

the technical solutions (shared data or shared services) the IPT selects. 

 

Fingerprint search capacity and storage. The FBI and the DHS 

also expect to establish the initial fingerprint search and storage capacity 

needed for full interoperability during the IOC phase.14 The FBI plans to 

conduct up to 1,000 initial fingerprint searches per day of selected criminal 

arrestees and federal employees in positions of public trust or national 

security against the DHS’s records in the iDSM. By the end of the IOC 

development phase, the FBI plans to increase those fingerprint searches to 

approximately 50,000 per day and increase the storage capacity to 

accommodate all the records that will be in IAFIS and IDENT by fiscal year 

(FY) 2009. 

Federal, state, and local agencies’ limited access to immigration 

data. During the IOC development phase, the FBI plans to allow any 

agency – beyond the three pilot agencies – to request a fingerprint search 

against the DHS’s records. The agencies may be federal, state, or local law 

enforcement or civil agencies conducting non-criminal justice searches. The 

FBI’s current system receives approximately 60,000 search requests per day 

from all such agencies. Currently, FBI and other law enforcement personnel 

can obtain immigration data on a foreign national who is a “subject of 

interest” by submitting the subject’s name to the DHS’s Law Enforcement 

Support Center (LESC).15 During IOC, the LESC will continue to provide 

support to the FBI. When the FBI finds a match of a subject’s fingerprints 

against IDENT data, it plans to request the associated immigration data 

from the LESC. However, as of June 2006, FBI officials indicated that the 

amount and types of immigration data that the LESC would provide had not 

been determined. The FBI plans to request the data from the LESC by 

13 Information on individuals with protected identities (e.g., individuals seeking 

asylum or those enrolled in a witness protection program) will not be shared. 

14 If a shared data model or the base case is chosen, then the necessary capacity of 

the iDSM will have to be determined. If the shared services model is chosen, then the 

agencies will need to determine the necessary capacity of IAFIS and IDENT. 

15 The LESC – which operates 24 hours a day, 365 days a year – provides federal, 

state, and local law enforcement agencies with information about foreign nationals they 

encounter (e.g., immigration status, identity of individuals arrested or under investigation) 

by researching information available in various databases and criminal history repositories. 
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submitting an electronic request known as an Immigration Alien Query, to 

which the LESC will return an automated response. The FBI will then 

provide that response back to the requesting agency. 

Immigration authorities’ full access to criminal history data. For 

criminal justice purposes, the DHS plans to obtain criminal history 

information through the existing procedure whereby it submits a query to 

the FBI’s National Crime Information Center. For non-criminal justice 

agencies (e.g., the DOS), the FBI will provide the criminal history 

information associated with a fingerprint match after it makes a positive 

identification in IAFIS. 

Full Operating Capability

The FOC phase is scheduled to be developed over 17 months, 

beginning in July 2008 and ending in December 2009 with full 

interoperability. During the FOC development phase, the FBI and the DHS 

plan to: (1) provide complete, standardized data sharing between the FBI 

and the DHS; (2) increase fingerprint search capacity and storage to 

accommodate more transactions; and (3) allow federal, state, and local 

agencies full access to immigration data. 

 

Standardized data sharing. By the end of the FOC development 

phase, IAFIS and IDENT users are expected to be able to submit a single 

request that searches all fingerprint records maintained by the FBI and the 

DHS to receive associated criminal history and immigration information 

about the subject. The searches are to be based on fingerprints, although 

interoperability planning documents indicate that expansion to palm prints, 

facial recognition, and other biometrically based methods may be developed 

and used by the agencies in the future in a final interoperability solution 

(beyond FOC). The method of providing this information will depend on 

which of the technical solutions (shared data, shared services, or a base 

case) the IPT selects. 

Increased fingerprint search capacity and storage. FBI officials 

stated that by the end of the FOC development phase, the federal, state, and 

local agencies’ capacity to search against the DHS’s records will increase 

from the planned IOC capacity of approximately 50,000 transactions per 

day to approximately 200,000 per day, a level that according to FBI officials, 

will accommodate all requests. The FBI and the DHS are also planning to 

increase the storage capacity of the interoperability solution to 

accommodate all the records that will be in IAFIS and IDENT by FY 2010. 
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Federal, state, and local agencies’ full access to immigration 

data. By the end of the FOC development phase, the FBI and the DHS are 

planning to allow all federal, state, and local law enforcement agencies, as 

well as authorized non-criminal justice agencies, full access to the DHS’s 

immigration data, both benefits- and enforcement-related. However, the two 

agencies have not yet decided on the parameters of this access and must 

still make several policy decisions, including how law enforcement officials 

and authorized non-criminal justice agencies should use and safeguard the 

immigration data. With FOC, the LESC is expected to provide more 

comprehensive immigration information associated with fingerprint 

matches. 

To support full interoperability, the FBI and the DHS are upgrading 

IAFIS and IDENT, and the DHS is preparing to convert US-VISIT to 

10 fingerprints. 

 

Concurrent with the IPT’s efforts to implement full interoperability, 

the FBI and the DHS are independently upgrading IAFIS and IDENT to 

process 10 flat fingerprints. The FBI is implementing its Next Generation 

Identification (NGI) initiative, which includes the processing of flat 

fingerprints, and the DHS is planning to modernize IDENT and convert 

US-VISIT from a 2- to a 10-fingerprint system. 

 

Upgrading IAFIS

The FBI began planning its NGI initiative (originally called Next 

Generation IAFIS), in early 2004 to provide IAFIS users with quicker and 

more accurate fingerprint searches and more complete criminal history 

information. The FBI now plans to implement NGI concurrently with the 

overall interoperability effort. The interoperability-related portions of NGI 

include processing an increased volume of flat fingerprints. The FBI 

currently accepts flat fingerprint submissions from only three entities: the 

DOS, the American Bankers Association, and the Ohio Bureau of Criminal 

Identification and Investigation.16 NGI is also slated to provide several new 

services, such as a specialized biometric database expected to provide 

quicker identification of certain criminals and terrorists and improved 

disposition data associated with criminal history records. According to the 

FBI, the interoperability-related portions of NGI are tentatively scheduled to 

be completed by the end of the FOC phase in December 2009, pending the 

results of a study the FBI is conducting to determine IAFIS user needs. 

 

 16 To handle the volume of flat fingerprint submissions that will result from all 

visitors being enrolled into US-VISIT (approximately 43 million per year), the FBI has begun 

upgrading IAFIS search capacity. 
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Modernizing IDENT 

The DHS is planning to modernize IDENT through an effort it refers to 

as “Unified IDENT” to accept, store, and process 10 fingerprints and 

improve fingerprint matching accuracy. The DHS also plans to provide 

more comprehensive individual alien history information, link its various 

immigration databases, and establish a “person-centric view” that the DHS 

expects will allow each individual with an immigration history to have only 

one identity (known as a unique identifier) in the system. Under the personcentric view, the DHS expects that users will be able to submit a single 

query and receive a consolidated response containing all benefits- and 

enforcement-related immigration information associated with the individual 

in question. The DHS is planning to begin modernizing IDENT during the 

interim interoperability phase and intends to complete the modernization 

effort during the FOC phase. 

Converting US-VISIT to 10 Fingerprints 

The DHS and the DOS have begun planning for the transition of 

US-VISIT from a 2- to a 10-fingerprint enrollment standard during the 

interim interoperability phase. The DHS and the DOS currently enroll 

visitors to the United States into US-VISIT using two flat fingerprints and a 

digital photograph. DOS officials either enroll visitors at visa-issuing 

consulates before they travel to the United States or DHS officials enroll 

visitors at ports of entry upon arrival in the United States. When visitors 

subsequently re-enter the country, their two fingerprints are matched 

against their own enrolled fingerprints to verify their identity. Once the new 

US-VISIT enrollment standard is implemented, the DHS and the DOS plan 

to begin collecting 10 flat fingerprints from visitors using new scanners 

(described below), but to continue verifying visitors’ identities using 

2 fingerprints. 

To select new fingerprint scanners that will support the US-VISIT 

transition, the DHS formed a user group with representatives from the FBI, 

National Institute of Justice, DOS, NIST, and Department of Defense. The 

user group defined the criteria for fingerprint scanners that are faster, 

smaller, and more portable than the devices currently being used by the 

DOS and other agencies for capturing 10 flat fingerprints. The user group 

found two vendors capable of developing such scanners within 12 months. 

The user group plans to test and evaluate the scanners, once they become 

available, during the interim interoperability phase. 

 

The DOS has begun a series of pilot projects to collect 10 flat 

fingerprints from visa applicants at selected consulates and embassies. The 

DOS began its first pilot project in San Salvador, El Salvador in April 2006 
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and is planning additional pilot projects in London, England in July 2006 

and in Riyadh, Saudi Arabia in September 2006. To collect the fingerprints 

during the pilot projects, the DOS plans to use an existing type of 10-print 

scanner that the FBI certified as being in compliance with IAFIS. Once 

smaller, lighter scanners are available, the DOS plans to deploy the devices 

and require 10 flat fingerprint processing at its remaining consulates and 

embassies during the IOC phase. Because IDENT is not yet prepared to 

accept 10 fingerprints from the DOS, the DOS plans to continue 

transmitting 2 fingerprints to IDENT until September 2006, when IDENT is 

expected to begin accepting 10 fingerprints. 

The IPT is estimating interoperability costs for the IOC phase. 

The IPT is working on a cost-benefit analysis, which it expects to 

complete by August 2006, that will estimate the IOC interoperability-related 

expenses for the FBI, DHS, and DOS to make IAFIS, IDENT, and US-VISIT 

interoperable.17 Those expenses will include agency-specific initiatives 

needed for interoperability, such as a portion of the FBI’s NGI, the DHS’s 

IDENT modernization, and the DHS and DOS joint implementation of a 

10-fingerprint enrollment standard for US-VISIT. The final cost will depend 

largely on which of the technical solutions the IPT chooses for full 

interoperability. FBI officials noted that achieving full interoperability is 

dependent on the FBI, DHS, and DOS receiving adequate appropriations to 

cover all interoperability-related expenses. 

 

The FBI has estimated costs for the first two interoperability phases. 

Separate from the IPT’s cost-benefit analysis for IOC, FBI officials 

have developed FBI-specific cost estimates for the first two interoperability 

phases. For FY 2006, the FBI estimated a cost of $7.9 million for the iDSM 

and $24 million for the first portion of the IOC phase. In its FY 2006 

appropriation, the FBI budgeted $18.9 million for interoperability-related 

expenses, most of which included reprogrammed funding. For FY 2007, the 

FBI estimated that $33 million will be needed for hardware and software for 

the IOC phase, and the FBI subsequently requested that amount in the 

President’s FY 2007 budget. 

17 We attempted to obtain an estimate of the total interoperability-related expenses 

through the FOC phase but FBI officials stated that a total estimate was not available. 
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The FBI and the DHS have identified technical, funding, and 

policy risks and have developed mitigation strategies. 

We examined whether the FBI and the DHS (through the IPT) have 

identified potential technical, funding, and policy risks that could delay full 

interoperability and whether they have developed corresponding mitigation 

strategies. We found that the IPT has developed risk management plans 

and mitigation strategies that appear reasonable for the overall 

interoperability effort. We also found that the FBI developed a risk 

management plan with mitigation strategies for its portion of the interim 

interoperability phase (iDSM).18 

The IPT recognized several broad risks, including that it had limited 

time to develop, design, and deploy an interoperability solution; that there 

could be a lack of financial, personnel, or technical resources within 

participating agencies; that privacy issues may be of concern; and that 

IAFIS and IDENT users could misuse the data in the interoperable solution. 

In terms of the iDSM-specific risks, the FBI identified 57, and as of May 3, 

2006, 18 were still considered open.19 The open risks involved areas such 

as schedule, technology, system reliability, cost, policy, privacy, and 

security. Among them were: 

• Purchase and receipt of iDSM equipment: The FBI recognized that 

the acquisition process for the hardware and software needed for the 

iDSM would be lengthy and could significantly delay the deployment 

schedule of the first interoperability phase. To address this risk, the 

FBI stated that the purchase of this equipment must be made by 

June 2006 and the equipment received by July 2006. As of June 27, 

2006, FBI officials stated that they were in the process of purchasing 

the equipment. 

• Sufficient resources for the iDSM: The FBI recognized the possibility 

that insufficient resources could cause the first interoperability 

phase to fall behind schedule. To address this risk, the FBI stated it 

would apply Earned Value Management to optimize investment 

 18 FBI officials told us that the DHS has also devised risk management plans for its 

portion of the interoperability risks. However, we did not verify this with the DHS or 

examine those plans. 

19 The FBI closed a risk if: (1) it took action to mitigate the risk or render the risk 

moot, (2) it incorporated a specific risk with another one already being addressed, or (3) it 

determined that the probability of occurrence was low. 
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planning and control.20 Officials from both the FBI and the DHS 

have indicated that while implementation of the three 

interoperability phases is currently on schedule, delays in receiving 

necessary funding would push back the December 2009 target 

completion date for full interoperability. For example, FBI officials 

stated that if a purchase request is delayed by as little as 45 days, it 

could cause the FBI to miss a procurement cycle, which would push 

back each of the interoperability phases. 

• Protection of sensitive data to be shared through the iDSM: Because 

the data to be shared through the iDSM is considered sensitive, the 

FBI recognized the risk of not protecting this data and stated that 

owners of the data may need to restrict access. To address this risk, 

the FBI is working with privacy officials and conducting analyses to 

determine whether a privacy impact assessment is needed.21 The 

FBI also decided to limit the volume of data initially being shared 

through the iDSM. 

Although these interoperability risks and corresponding mitigation 

strategies appear to be reasonable, the scope of our review did not include a 

thorough analysis of whether the IPT or the FBI identified all potential risks 

to the interoperability project and appropriately closed or mitigated those 

risks. Further, the FBI has not completed risk analysis plans for the 

remaining two interoperability phases, although FBI officials stated that 

they have begun identifying potential risks for the IOC and FOC 

development phases. We therefore encourage the FBI to continue regularly 

monitoring the overall risks to the project and to develop risk mitigation 

strategies for the IOC and FOC phases. 

The FBI has taken action to lessen the risk of criminal aliens or 

terrorists entering the United States undetected. 

Since our December 2004 report, the FBI has taken several steps to 

lessen the risk of criminal aliens or terrorists entering the United States 

undetected. As our previous report recommended, the FBI has increased 

the transmission of “Known or Suspected Terrorists” records to the DHS 

 20 Earned Value Management is a program management technique for estimating 

the performance of a project in terms of its budget and schedule while taking risk into 

consideration. 

21 A privacy impact assessment is an analysis of how an agency handles 

information on individuals to ensure it conforms to applicable privacy laws and policies. 

The E-Government Act of 2002 requires executive branch agencies to conduct privacy 

impact assessments when they develop or modify electronic collections of such information. 

T
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from monthly to daily (or as available), which allows the DHS to conduct 

searches of visitors’ fingerprints using the most current IAFIS extracts. 

Similarly, by improving the FBI’s IAFIS availability so that users can access 

the system 99 percent of the time, the FBI has lessened the risk that the 

DHS could unknowingly release aliens because it could not access IAFIS to 

determine whether the aliens had criminal records. Also, the FBI increased 

IAFIS capacity from 8,000 daily fingerprint transactions from the DHS in 

2004 to 20,000 daily transactions in 2005, which is more than sufficient to 

handle the DHS’s current average daily workload for criminal checks. In 

addition, the FBI has significantly improved IAFIS response time and has 

implemented a “high priority” designation for DHS fingerprint transactions 

so that criminal aliens or terrorists can be identified more quickly. 

No risk analysis has been conducted on the visitors exempt from the 

US-VISIT requirements. 

During our 2004 review, Department officials proposed conducting a 

study to determine how many individuals whose fingerprints were in IDENT 

but who were not subjected to fingerprint searches against IAFIS had 

records in the IAFIS Criminal Master File. This population would have 

included both visitors subjected to US-VISIT and those exempt from the 

US-VISIT requirements.22 The study would have provided the Homeland 

Security Council with more information to use in making a decision on a 

uniform fingerprint collection methodology for foreign nationals. Our 

December 2004 report encouraged the Department to undertake such a 

study. 

However, after the DHS’s May 2005 decision to adopt the NIST 

Technology Standard, and the subsequent progress made toward achieving 

full interoperability, the Department announced that it was no longer 

planning to conduct the study. Given that the FBI and the DHS had already 

begun planning for full interoperability and were preparing to implement the 

iDSM, the Department stated, “it is less imperative from [the Department’s] 

perspective to conduct the study.” Nonetheless, Department officials stated 

that the study was still needed to assess the risk of unknowingly admitting 

criminal aliens into the United States, particularly those exempt from 

US-VISIT, and suggested to the OIG that the DHS conduct the study. 

 

22 Visitors exempt from US-VISIT (and therefore not subjected to fingerprint 

searches against IAFIS) include those with certain designated visa classifications, children 

under the age of 14, persons over the age of 79, Mexican nationals to whom the DOS has 

issued Border Crossing Cards for use along the southern border, and Canadians entering 

the United States across the northern border. 
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Department officials stated that it would be valuable to know the “hit 

rate” (i.e., the number of hits against IAFIS records) of individuals exempt 

from US-VISIT requirements, particularly the Border Crossing Card 

population. Department officials explained that because these visitors are 

not screened against IAFIS upon entry to the United States, the DHS does 

not know how many may have matches in the FBI’s database. The DHS 

could use that information to inform future immigration policy decisions, 

such as whether to expand the pool of individuals to which US-VISIT 

applies. Because it is the DHS’s responsibility to prevent inadmissible 

aliens from entering the country, Department officials asserted that the 

DHS, not the Department, should undertake the study. 

During this review, we asked DHS officials whether they intended to 

conduct a study similar to the one proposed by the Department using 

US-VISIT or Border Crossing Card data. On March 29, 2006, officials from 

the US-VISIT office indicated that the need for conducting this study has 

been “overcome by events” because the DHS has already decided to 

implement a 10-fingerprint standard for US-VISIT. 

We believe that until full interoperability is achieved in December 

2009, the DHS’s policy of using IAFIS to check the fingerprints of less than 

1 percent of the visitors subjected to US-VISIT will continue to create a risk 

that criminal aliens or terrorists could enter the United States undetected.23 

Once full interoperability is achieved, this risk will be reduced because the 

visitors subjected to US-VISIT will be checked against the full IAFIS 

Criminal Master File. However, this risk will not be eliminated because a 

substantial number of visitors exempt from US-VISIT, such as Border 

Crossing Card holders, will not have their fingerprints searched against 

IAFIS. 

CONCLUSION 

Since our December 2004 report, the FBI and the DHS have made 

progress toward achieving full interoperability among IAFIS, IDENT, and 

US-VISIT. The DHS’s decision to implement a 10-fingerprint enrollment 

standard for US-VISIT resolved 1 of the 2 barriers to interoperability that we 

identified in 2004. Since then, the FBI and the DHS have formed an 

interoperability working group and have began implementing the first phase 

of a three-phase plan to make IAFIS, IDENT, and US-VISIT interoperable by 

December 2009. In the remaining two phases, the agencies plan to facilitate 

complete sharing of the immigration and law enforcement records in IAFIS 

23 To date, no known terrorists have been identified through the IAFIS extract 

process, only criminal aliens. 
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and IDENT among federal, state, and local law enforcement agencies; 

authorized non-criminal justice agencies; and immigration officials. 

Although not completed, the decision to begin sharing immigration 

information with law enforcement officials through the iDSM partially 

resolves the second barrier that we identified in 2004. To support full 

interoperability, the FBI and the DHS are upgrading IAFIS and IDENT to 

process 10 flat fingerprints, and the DHS is preparing to convert US-VISIT 

to a 10-fingerprint enrollment standard. 

 

The FBI and the DHS stated that they are on schedule for achieving 

full interoperability by December 2009. The IPT is estimating the 

interoperability-related costs for the IOC phase and has identified technical, 

funding, and policy risks to the overall interoperability effort, along with risk 

mitigation strategies. Until full interoperability is achieved, the FBI has 

implemented interim actions since December 2004 that lessen the risk of 

criminal aliens or terrorists entering the United States undetected. 

Based on the results of our current review, we believe that the 

Department and the FBI have implemented actions to address our 

recommendations from 2004; therefore, we are closing them. However, 

there are still milestones and outstanding risks that need to be monitored 

as the interoperability project moves forward toward full interoperability 

among IAFIS, IDENT, and US-VISIT. For example, the IPT’s risk 

management plan for the iDSM states that the equipment purchase needed 

to be made by June 2006 and that the equipment must be received by July 

2006. The FBI has noted that if a purchase request is delayed by even 45 

days, it could cause them to miss a procurement cycle, which would push 

back each of the interoperability phases. The OIG plans to monitor the 

progress of the interoperability project, including the achievement of these 

and other milestones, until full interoperability is achieved. 

Officials from the Department (including the FBI), DHS, and DOS 

provided informal comments on this report. Those comments reflected a 

general concurrence with the facts presented in this report. 
TABLE OF CONTENTS 

INTRODUCTION ................................................................................... 1

BACKGROUND ..................................................................................... 3

PURPOSE, SCOPE, AND METHODOLOGY............................................ 17

RESULTS OF THE REVIEW – PART I .................................................. 19

The FBI and the DHS are implementing the first phase of a 

three-phase plan for achieving full interoperability. ............................... 19

The FBI and the DHS plan to implement the remaining two 

interoperability phases by December 2009. ........................................... 25

To support full interoperability, the FBI and the DHS are upgrading 

IAFIS and IDENT, and the DHS is preparing to convert US-VISIT to 10 

fingerprints. .......................................................................................... 30

The IPT is estimating interoperability costs for the IOC phase................ 35

The FBI has estimated costs for the first two interoperability phases. .... 36

The FBI and the DHS have identified technical, funding, and policy 

risks and have developed mitigation strategies. ..................................... 36

RESULTS OF THE REVIEW – PART II ................................................. 40

The FBI has taken action to lessen the risk of criminal aliens or 

terrorists entering the United States undetected.................................... 40

No risk analysis has been conducted on the visitors exempt from the 

US-VISIT requirements.......................................................................... 46

CONCLUSION..................................................................................... 49

APPENDIX I: COMPARISON OF FINGERPRINT COLLECTION 

METHODS.......................................................................................... 52

APPENDIX II: INTEROPERABILITY EVENTS IN 2005 ......................... 53

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INTRODUCTION 

 

The Office of the Inspector General (OIG) conducted this follow-up 

review to examine the Federal Bureau of Investigation’s (FBI) progress 

toward achieving biometric interoperability between its Integrated 

Automated Fingerprint Identification System (IAFIS) and the Department of 

Homeland Security’s (DHS) Automated Biometric Identification (IDENT). We 

also describe the DHS’s efforts to make its United States Visitor and 

Immigrant Status Indicator Technology (US-VISIT) system interoperable 

with IAFIS. 

In this report, the term “biometric interoperability” (interoperability) 

refers to the FBI’s and the DHS’s ability to exchange fingerprint data 

through compatible technology in IAFIS, IDENT, and US-VISIT. Full 

biometric interoperability (full interoperability) is intended to give federal, 

state, and local law enforcement agencies and immigration officials direct, 

real-time, multi-directional access to data in IAFIS, IDENT, and US-VISIT. 

 Once fully interoperable, the systems should provide: 

• Immediate identification and verification of aliens with criminal 

histories and other high-risk individuals, including those in custody; 

• Development and enhancement of investigative cases; 

• Support for eligibility determinations for admissibility, benefits, and 

employment of foreign nationals; and 

• Ability to use the data for trend and intelligence analyses. 

This is our sixth report since 2000 related to the progress of the 

efforts to integrate IDENT and IAFIS. The previous reports were: 

• The Rafael Resendez-Ramirez Case: A Review of the INS’s Actions and 

the Operation of its IDENT Automated Fingerprint Identification System, 

March 2000; 

• Status of IDENT/IAFIS Integration (follow-up report), December 2001; 

• Status of IDENT/IAFIS Integration (follow-up report), June 2003; 

• IDENT/IAFIS: The Batres Case and the Status of the Integration 

Project, March 2004; and 
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• Follow-up Review of the Status of IDENT/IAFIS Integration,

December 2004. 

For this report, we focused on the current status of the FBI’s efforts to 

achieve biometric interoperability among its IAFIS and the DHS’s IDENT and 

US-VISIT systems; the remaining actions needed to achieve full 

interoperability; and the interim measures taken by the FBI to lessen the 

risk that criminal aliens and terrorists could enter the United States 

undetected. In reviewing the FBI’s actions, we also examined the DHS’s and 

the DOS’s efforts related to the interoperability project. 
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BACKGROUND 

 

This Background section describes the IAFIS, IDENT, and US-VISIT 

systems; past efforts to achieve interoperability among the systems; the key 

agencies and working groups involved in the efforts to integrate the systems; 

and the findings from our December 2004 report that examined the status 

of the IDENT/IAFIS integration project and the disagreements between the 

Departments of Justice, Homeland Security, and State regarding 

development of an interoperable system. 

Fingerprint Identification Systems 

The IAFIS, IDENT, and US-VISIT systems were designed by different 

agencies to provide fingerprint identification support for different 

requirements. A description of each system follows.24

 

IAFIS. The FBI developed IAFIS to store digitized fingerprints and 

criminal history records to assist federal, state, and local law enforcement 

agencies in identifying criminals. The FBI also built IAFIS to conduct noncriminal justice (civil) fingerprint background checks for employment and 

license applications and immigration benefits. Deployed in 1999, the IAFIS 

automated fingerprint identification system is operated by the FBI’s 

Criminal Justice Information Services (CJIS) Division. IAFIS contains the 

largest criminal biometric database in the world, the Criminal Master File, 

which stores over 50 million sets of 10 rolled fingerprints and corresponding 

criminal history information submitted by law enforcement agencies.25 

IAFIS also contains a Civil Subject Index Master File, which stores noncriminal fingerprints (e.g., fingerprints of military, government, or 

authorized non-government personnel), and an Unsolved Latent File, which 

contains latent fingerprint images found at crime scenes. 

IDENT. The former Immigration and Naturalization Service (INS) 

developed IDENT to identify and track individuals apprehended for illegally 

crossing the U.S. border and to identify recidivists (i.e., those apprehended 

 24 For a more detailed description and history of each system, see the OIG’s 

December 2004 report, Follow-up Review of the Status of IDENT/IAFIS Integration, 

Background and Appendix I, www.usdoj.gov/oig/reports/plus/e0501/index.htm. 

25 The Criminal Master File records follow the law enforcement standard of taking 

prints from all 10 fingers by rolling and pressing each finger on either a scanner or a 

standard paper fingerprint record form (10 rolled prints). Fingerprints also may be taken 

by pressing fingers straight down (flat fingerprints) and from fewer than 10 fingers. 
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more than once).26 Deployed in 1994, IDENT is an automated fingerprint 

identification system that matches two flat fingerprints from the right and 

left index fingers of apprehended aliens against similar fingerprint records 

contained in a database of over 55 million subjects that includes legitimate 

travelers and immigration violators.27 Those fingerprint records are 

organized into distinct enforcement- and immigration-related data bases:28 

• Lookout database: The Lookout database contains approximately 

920,000 unique fingerprint records, as well as photographs and basic 

information, for aliens who have been previously deported or who 

have criminal records. The FBI provides the DHS with some of the 

data by extracting certain categories of records from IAFIS and 

sending them to IDENT. Those records include: 

o Known or Suspected Terrorists: Approximately 31,000 

fingerprint records from individuals detained by the U.S. 

military, the FBI’s most wanted terrorists, and records from 

certain field investigations.

o Wants and Warrants: Approximately 800,000 records of 

individuals with active warrants from the Wanted Persons file of 

the FBI’s National Crime Information Center.29 The FBI initially 

provided only those “Wants and Warrants” records that met the 

DHS’s screening criteria of individuals who are foreign born, 

have no place of birth listed, or who have had previous 

encounters with immigration officials documented in IAFIS. 

However, the FBI now also provides fingerprint records of U.S. 

citizens with new or recently updated active warrants. 

 26 On March 1, 2003, the INS was transferred to the DHS and its operational 

responsibilities divided among the Bureau of Customs and Border Protection, the Bureau of 

Immigration and Customs Enforcement, and the Bureau of Citizenship and Immigration 

Services. 

27 According to the DHS, IDENT processes 150,000 to 230,000 daily fingerprint 

identifications and verifications. 

 

28 IDENT also contains an Asylum database of approximately 501,000 fingerprint 

records entered and used by immigration officers who process asylum claims, and a Border 

Crossing Card database of approximately 7.5 million fingerprints of Mexican citizens that is 

used by DOS officials who process Border Crossing Card applications. 

29 The 800,000 Wants and Warrants reflect the number of records that the DHS 

had received from the FBI as of June 6, 2006. However this number changes regularly due 

to the addition of new records and the removal of “demoted” records, which are Wants and 

Warrants that are no longer active. 
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• Recidivist database: The Recidivist database contains over 8.3 million 

unique fingerprint records and photographs of aliens who have been 

previously apprehended. Those records include the following 

categories: 

 

o Apprehensions: Approximately 7.8 million fingerprint records of 

previous DHS and legacy INS enforcement actions. 

o Alerts: Approximately 658,000 fingerprint records of previous 

DHS and legacy INS encounters that may require special 

attention at a subsequent encounter, such as “armed and 

dangerous” or an officer safety alert. The alerts also include 

approximately 390,000 “Expedited Removal” records for aliens 

that have been removed from the United States because they 

lacked proper documentation or committed fraud when 

attempting to enter the United States. 

o Previous Criminal History: Approximately 446,000 fingerprint 

records of individuals from 25 high-risk countries, such as Iraq, 

Iran, Syria, and Sudan. The FBI provided these records as a 

one-time transfer and included demoted Wants and Warrants 

records. 

US-VISIT. The DHS developed US-VISIT as an entry/exit tracking 

system to collect, maintain, and share information on foreign nationals 

(visitors) in the United States so that immigration officials can determine 

whether these individuals should be prohibited from entering the country, 

have overstayed or violated the terms of their admission, or should be 

detained for law enforcement action. Deployed in January 2004, US-VISIT 

uses IDENT to collect two flat fingerprints and a digital photograph to 

provide the biometric identification for visitors. The fingerprints are taken 

either at ports of entry when the visitors arrive or by Department of State 

(DOS) employees at visa-issuing consulates before the visitors arrive. The 

first time a visitor’s fingerprints are taken, they are checked against the 

US-VISIT Watch List database (a “one-to-many” comparison) and enrolled 

into the US-VISIT Enrollment database by the DHS (at ports of entry) or the 

DOS (at consulates).30 The US-VISIT Watch List and Enrollment databases 

contain the following records from IDENT: 

 30 When visitors subsequently enter the United States, their fingerprints are 

matched only against their own enrolled fingerprints (a “one-to-one” comparison) to verify 

the visitors’ identity. 
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• US-VISIT Watch List database: The US-VISIT Watch List contains 

approximately 1.7 million unique fingerprint records of aliens who 

have been previously deported, previously apprehended, or who have 

been denied a visa. Those records include the entire Lookout 

database, plus: 

o The previous criminal history records (in the Recidivist 

database), 

o The Expedited Removal records (in the Recidivist database), and 

o “Visa Denial” records, formally called “Biometric Visa 

Application Category 1 Critical Refusals,” constituting 

approximately 16,000 fingerprint records from applicants whose 

visas were denied because the DOS determined that they posed 

a substantial risk to the United States.31 

• US-VISIT Enrollment database: The US-VISIT Enrollment database 

contains over 43 million unique fingerprint records of foreign 

nationals who have visited the United States or applied for an 

immigration benefit, such as a visa or a Border Crossing Card. 

According to the DHS, the US-VISIT Enrollment database has been 

increasing by approximately 80,000 fingerprint records per day since 

2004. 

Interoperability of Fingerprint Identification Systems 

IAFIS and IDENT were not designed to be interoperable. 

The FBI and the INS began discussing integrating IAFIS and IDENT in 

the early 1990s when the two systems were in their development stages. 

However, the agencies had a difference of opinion, stemming from the 

different purposes of the systems, as to whether the INS should collect 2 or 

10 fingerprints from apprehended aliens. The FBI created IAFIS to 

automate its Criminal Master File and serve the needs of the law 

enforcement community. Because fingerprints at crime scenes may be from 

any finger, the law enforcement standard requires that officers take prints 

from all 10 fingers of a subject. Conversely, the INS created IDENT as an 

internal system to track aliens apprehended illegally crossing the border 

 31 Although visitors’ fingerprints are compared to those on the Watch List, they are 

not searched against IDENT’s Apprehension, Asylum, or Border Crossing Card databases. 

However, DHS officials have informed us that by the end of fiscal year (FY) 2006, all IDENT 

databases will be searched during the US-VISIT process. 
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between ports of entry and to subsequently identify those who illegally 

crossed the border more than once. Because the INS frequently 

apprehended large groups of aliens that had to be processed quickly, taking 

10 rolled fingerprints was deemed too time-consuming, and IDENT therefore 

was designed to use only 2 fingerprints. 

Congress directed that fingerprint identification systems be interoperable. 

Since the late 1990s, Congress has expressed concern that IAFIS and 

IDENT could not share data readily. After the terrorist attacks of 

September 11, 2001, Congress required that federal fingerprint 

identification systems be made interoperable so that aliens and visitors to 

the United States who are criminals or known or suspected terrorists can be 

more readily identified. 

In the 2001 USA PATRIOT Act (Patriot Act), Congress required a 

“cross-agency, cross-platform electronic system that is a cost-effective, 

efficient, fully integrated means to share law enforcement and intelligence 

information necessary to confirm the identity of . . . persons applying for a 

United States visa . . . .”32 The Patriot Act specified that this system be 

“readily and easily accessible” to all consulates, federal inspection agents, 

and law enforcement and intelligence officers responsible for investigating 

aliens. 

In the Enhanced Border Security and Visa Entry Reform Act of 2002 

(Border Security Act), which amended several provisions of the Patriot Act, 

Congress changed the description of the electronic system from integrated 

to interoperable. The Border Security Act, in its description of an 

“interoperable data system,” required that immigration authorities have 

“current and immediate” access to information in federal law enforcement 

agencies’ databases to determine whether to allow aliens to enter the United 

States.33 

Congress directed that the NIST develop a technology standard for 

interoperability. 

One of the requirements in the 2001 Patriot Act was for the Attorney 

General and the Secretary of State, working jointly with the National 

Institute of Standards and Technology (NIST), to develop a technology 

 32 USA PATRIOT Act (P.L. 107-56), Section 403(c)(2). 

33 Enhanced Border Security and Visa Entry Reform Act of 2002 (P.L. 107-173), 

Section 202(a)(2). 
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standard for verifying the identity of foreign nationals when they apply for 

visas at U.S. consulates and when they arrive at ports of entry.34 In 

response to this requirement, the NIST issued a Technology Standard in 

January 2003 for collecting fingerprints from foreign nationals. The NIST 

Technology Standard called for 10 flat fingerprints to be collected for initial 

enrollment into automated systems and for 2 flat fingerprints and a digital 

photograph to be used to verify an individual’s identity against an existing 

enrollment record. 

US-VISIT did not incorporate the NIST Technology Standard. 

Notwithstanding the NIST’s January 2003 recommendation of 10 flat 

fingerprints as the Technology Standard for enrolling individuals in 

automated systems, on July 18, 2003, the Homeland Security Council 

Deputies Committee approved US-VISIT’s use of 2 flat fingerprints and a 

photograph to enroll individuals during the system’s initial deployment at 

sea and air ports of entry.35 In September 2003, the DOS began deploying 

single-finger scanners at its consulates to prepare for the enrollment of visa 

applicants into US-VISIT. On January 5, 2004, the DHS launched US-VISIT 

at air and sea ports of entry.36 

Integrated IDENT/IAFIS Workstations 

In 2004, the DHS began deploying integrated IDENT/IAFIS 

workstations that allow DHS personnel to directly search IAFIS using 

10 rolled fingerprints, and simultaneously enroll individuals into IDENT 

using 2 fingerprints.37 The purpose of the integrated workstations was to 

provide immigration authorities with access to criminal history information 

 34 After the DHS’s creation through the Homeland Security Act of 2002, the 

responsibility for immigration-related issues shifted from the Department of Justice to the 

DHS. 

35 The Homeland Security Council Deputies Committee, organized under the 

Executive Office of the President, is responsible for ensuring coordination of all homeland 

security-related activities among executive departments and agencies. 

36 As of December 30, 2005, US-VISIT was operating at 115 airports, 15 seaports, 

secondary inspection areas at 154 land ports of entry, and approximately 214 visa-issuing 

consulates. Secondary inspection refers to designated areas at ports of entry that allow 

inspectors to conduct additional screening to verify visitors’ information without causing 

delays to other arriving visitors. 

37 On September 21, 2004, the DHS reported that it had deployed IDENT/IAFIS 

workstations to all 142 Border Patrol stations. The DHS then deployed the workstations to 

all 284 air, land, and sea ports of entry on December 19, 2005. Integrated workstations 

have also been deployed at 342 Immigration and Customs Enforcement sites. 
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in IAFIS. Border Patrol agents use those workstations to check all aliens 

apprehended crossing the border illegally. In addition, inspectors at ports of 

entry use the workstations to check a small number of aliens who are 

referred to secondary inspection and denied admittance into the United 

States. However, the integrated workstations do not meet the goal of full 

interoperability because they are not multi-directional; the FBI and other 

law enforcement agencies do not have direct access to the DHS’s IDENT. 

When the DHS transmits an alien’s fingerprints to IAFIS using the 

integrated workstations, it uses a transaction referred to as a Ten-Print Rap 

Sheet (TPRS). TPRS transactions provide a quick response to searches of 

aliens’ fingerprints. When the DHS transmits an alien’s fingerprints to 

IAFIS, the system searches its Criminal Master File for a potential “hit” or 

match. If the alien’s fingerprints generate a potential match, IAFIS returns 

the criminal history file. 

 

Key Agencies and Working Groups 

 Department of Justice. The Department’s Justice Management 

Division (JMD) has maintained oversight of the integration of IAFIS and 

IDENT since 1999. The Department’s Chief Information Officer (CIO) 

manages the integration project for the Department and represents the 

Department in meetings with the DHS and other agencies. The FBI’s CJIS 

Division maintains and operates IAFIS. 

Department of Homeland Security. The DHS’s Bureau of Customs 

and Border Protection (CBP) employs Border Patrol agents and inspectors, 

whose mission includes preventing terrorists and criminal aliens from 

entering the United States and apprehending individuals attempting to 

enter the United States illegally. The US-VISIT Program Management Office 

(US-VISIT office) manages US-VISIT and is responsible for communicating 

with Department of Justice representatives and participating in interagency 

meetings. CBP and the US-VISIT office report directly to the DHS Deputy 

Secretary. 

 

Department of Commerce. Scientists at the Department of 

Commerce’s NIST have been working with the FBI for over 30 years to 

research, develop, and improve fingerprint-matching procedures. They are 

currently working with representatives from the Department of Justice, the 

FBI’s CJIS Division, DOS, and DHS in regular interagency meetings and 

joint studies regarding fingerprint biometrics. 

Department of State. The DOS’s Bureau of Consular Affairs is 

responsible for administering laws, formulating regulations, and 

implementing policies relating to consular services and immigration, 
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including issuing visas (both immigrant and non-immigrant), and passports 

to U.S. citizens. Representatives from the Bureau of Consular Affairs work 

with the Department of Justice and the DHS on biometrics issues and 

participate in the interagency meetings regarding fingerprint identification 

issues. 

 Homeland Security Council Deputies Committee. The Homeland 

Security Council Deputies Committee is responsible for ensuring 

coordination of all homeland security-related activities among executive 

departments and agencies. It is the senior sub-Cabinet interagency forum 

for consideration of policy issues affecting homeland security, including 

fingerprint biometrics, and comprises officials at the deputy level (or their 

designees) from the Department of Justice, DHS, DOS, and other agencies. 

The Deputies have met regularly since January 2004 to discuss security 

issues, including the interoperability of IAFIS, IDENT, and US-VISIT. 

 Policy Coordination Committee. Formed in January 2004, the 

Policy Coordination Committee reports to the Homeland Security Council 

Deputies on various executive branch issues, including current and future 

use of the fingerprint data contained in IAFIS, IDENT, and US-VISIT. The 

Policy Coordination Committee is managed by the Office of Management and 

Budget, and its participants include representatives from the Department of 

Justice, DHS, and DOS. 

Integrated Project Team. Formed in May 2005, the Integrated 

Project Team’s (IPT) mission is to achieve interoperability of biometric (e.g., 

fingerprint) information in the databases of the FBI and the DHS, and to 

share related biographic (e.g., name, date of birth, social security number), 

criminal history, and immigration information in real time or near real time 

with each other and federal, state, and local law enforcement agencies.38 

The IPT includes representatives from the CJIS Division, the US-VISIT office, 

and the DOS, with occasional participation from the NIST and other 

officials. Within the Department of Justice, the Office of the CIO is 

responsible for monitoring the IPT and its progress and the CJIS Division is 

the lead component responsible for system development activities.39

38 According to the FBI, “near real time” means that information will be updated 

within 24 hours. However, the FBI plans to update this information more quickly after 

September 2006. 

39 Officials from JMD’s Management and Planning Staff stated that they are 

becoming less involved in guiding interoperability efforts since the formation of the IPT, 

while the Office of the CIO and the CJIS Division have taken more active roles. 
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Office of the Inspector General 

Evaluation and Inspections Division

The IPT consists of an Executive Committee and three sub-teams: 

Business Requirements, which ascertains requirements from 

interoperability stakeholders and establishes operational consensus; 

Information Technology, which reviews the stakeholders’ requirements and 

advises the IPT on the most feasible technical solutions and logical 

approaches to design, development, and implementation; and Strategy and 

Policy, which ensures that the interoperability plan is consistent with FBI 

and DHS strategies and policies. 

In September 2005, the IPT created two working groups to address 

different aspects of the interoperability effort. The Unique Identity IPT, led 

by the DHS, is addressing the modifications needed to enable US-VISIT (via 

IDENT) to make the transition to a 10-fingerprint enrollment standard.40 

The Interoperability IPT, led by the FBI, is addressing all other issues 

related to making IAFIS interoperable with the DHS’s systems. Officials 

from the FBI and the DHS participate on both working groups and are 

responsible for jointly implementing interoperability between IAFIS and 

IDENT. 

December 2004 OIG Report on the Integration of IAFIS and IDENT 

In our 2004 review, we reported that efforts to achieve full 

interoperability had stalled because of two major barriers. The Department, 

DHS, and DOS still had not agreed on either a uniform method for collecting 

fingerprint information or on the extent to which federal, state, and local law 

enforcement agencies are to have access to the DHS’s immigration records. 

We also found that the DHS was using data extracted from IAFIS to 

supplement IDENT and was checking most visitors’ fingerprints against only 

IAFIS extracts, which created a risk that criminal aliens or terrorists could 

enter the United States undetected. Regarding the FBI, we found that IAFIS 

capacity was sufficient to handle the DHS’s projected daily workload, but 

the FBI was not prepared to process a large volume of flat fingerprints from 

the DHS and was not meeting its IAFIS availability requirement of 

99 percent. 

The Department, DHS, and DOS did not agree on a fingerprint collection 

standard. 

The first major barrier to achieving interoperability between IAFIS and 

IDENT that we identified in 2004 was that the Department, DHS, and DOS 

 40 According to the IPT’s Concept of Operations and a US-VISIT official we 

interviewed, the term “unique identity” refers to the biographic information connected to an 

individual’s unique set of fingerprints. 
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U.S. Department of Justice 12 

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had not agreed on a standard for collecting fingerprint information from 

foreign nationals applying at consulates for visas to visit the United States 

or seeking admission to the United States at ports of entry. The Department 

endorsed the NIST Technology Standard of 10 flat fingerprints for enrolling 

visa applicants and visitors in US-VISIT because 10 fingerprints would 

reduce the number of false positives and offer more options for system 

design and interoperability.41 We also reported that the agencies were using 

various fingerprint collection methodologies: 

• Department/FBI: The Department’s standard was to collect 10 rolled 

fingerprints for enrollment in IAFIS, although the Department 

acknowledged that 2 flat fingerprints could be used by the DHS to 

subsequently verify aliens’ identities by checking the aliens’ 

fingerprints against their own enrolled records. 

• DHS: The DHS was collecting two flat fingerprints at ports of entry to 

enroll visitors into US-VISIT. However, the DHS was also collecting 

10 rolled fingerprints (to check against IAFIS) from apprehended 

aliens at Border Patrol stations and from visitors referred to 

secondary inspection at ports of entry who were not going to be 

admitted to the United States.

• DOS: The DOS was collecting two flat fingerprints at U.S. consulates 

to enroll individuals applying for visas into US-VISIT. 

See Appendix I for a table comparing the fingerprint collection methods used 

by the three agencies. 

The Department, DHS, and DOS did not agree on how to provide law 

enforcement agencies with access to the DHS’s immigration records. 

The second major barrier to achieving interoperability that we 

identified in 2004 was that the DHS and the Department disagreed on a 

method of providing federal, state, and local law enforcement agencies with 

the “readily and easily accessible” access to the IDENT database specified in 

the Patriot Act and in subsequent congressional legislation. Also, the DHS 

did not believe that the FBI or other law enforcement agencies should have 

access to US-VISIT records. The DHS maintained that position for several 

reasons, including that the information in IDENT is incomplete and could be 

misinterpreted, and the privacy of visitors enrolled in US-VISIT must be 

protected. However, the OIG report noted that without direct access to the 

 41 False positives occur when the system incorrectly determines that a search 

fingerprint and a file fingerprint are matches. 
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DHS’s IDENT database, it is more difficult for federal, state, and local law 

enforcement agencies to identify illegal aliens they encounter. 

The DHS used data extracted from IAFIS to supplement IDENT. 

In our 2004 review, we described how, because the systems are not 

interoperable, the FBI is periodically providing the DHS with records 

extracted from IAFIS to supplement information in the IDENT Lookout 

database. However, there was some delay between when records are 

extracted from IAFIS and when they are entered into IDENT. For example, 

the FBI was providing the Known or Suspected Terrorists records to the 

DHS approximately once a month. 

Further, a Department Metrics Study found some of the extracts to be 

incomplete and prone to errors, which could allow criminals or terrorists 

whose data has not been extracted from IAFIS to use falsified identity 

papers to gain entry into the United States.42 For example, one of the 

DHS’s selection criteria for referring visitors to secondary inspection relies 

upon self-reported data (e.g., place of birth), but aliens being arrested may 

lie about their nationality to avoid deportation. Also, many U.S. citizens 

have an unknown or foreign place of birth. That selection criteria was 

particularly problematic for the Wants and Warrants extracts because the 

records of U.S. citizens may be loaded into the IDENT database, while the 

records of some non-U.S. citizens and potential criminal aliens are not 

included. The Metrics Study found that the Wants and Warrants extracts 

failed to include 22 percent (121 of 541) of criminal aliens with active wants 

and warrants. 

 

The DHS checked most visitors’ fingerprints only against IAFIS extracts. 

Our 2004 report also noted that the DHS was planning to limit direct 

IAFIS fingerprint searches (TPRS transactions) to a small percentage of 

visitors who are referred to secondary inspection and not admitted to the 

United States.43 According to the DHS’s workload projections through 

2005, only about 800 visitors per day – or 0.7 percent of the total projected 

visitors required to be enrolled in US-VISIT in 2005 – would be subjected to 

 42 JMD, Cost and Operational Effectiveness Analysis, Second Report to Congress, 

August 27, 2004. 

43 Visitors are referred to secondary inspection if a search in any of the law 

enforcement/immigration databases queried at primary inspection results in a hit or if they 

raise the suspicion of the primary immigration officer. 
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U.S. Department of Justice 14 

Office of the Inspector General 

Evaluation and Inspections Division

direct IAFIS TPRS searches at ports of entry.44 The other 99.3 percent of 

visitors enrolled in US-VISIT would be checked against the US-VISIT Watch 

List, which contains extracts from IAFIS, but not against the full IAFIS 

Criminal Master File. We found that the DHS’s practice of checking 

99.3 percent of the visitors’ fingerprints only against the limited data 

extracted from IAFIS and contained in the US-VISIT Watch List increased 

the risk of admitting criminal aliens. As the Metrics Study showed, 

searching individuals directly against IAFIS resulted in a significant 

increase in the number of criminal aliens identified. 

At the time of our 2004 review, the Department was interested in 

determining the risk posed by not checking all visitors against IAFIS. The 

Department proposed conducting a study to compare data from US-VISIT 

and other relevant immigration biometric databases against IAFIS. Also, we 

noted that while the IAFIS capacity of 20,000 daily TPRS transactions was 

sufficient to handle the then-projected DHS daily workload, if the DHS made 

a policy decision to request TPRS transactions on all visitors sent to 

secondary inspection, the resulting workload could exceed the IAFIS 

capacity. 

The FBI was not prepared to process flat fingerprints from the DHS. 

In 2004, we found that the FBI had recognized that it needed to 

upgrade IAFIS to begin accepting flat fingerprints (in lieu of rolled) for noncriminal justice (civil) purposes, such as in the case of employment and 

license applications or immigration benefits. At that time, the FBI had 

received approval from its National Crime Prevention and Privacy Compact 

Council to accept flat fingerprints, but had not yet begun receiving them.45 

Further, although the FBI planned to begin conducting flat fingerprint 

searches, it was not prepared to process the large number of searches that 

would be required if the DHS were to start submitting 10 flat fingerprints 

from all visitors enrolled into US-VISIT. 

 44 Visitors exempt from US-VISIT include those with certain designated visa 

classifications, children under the age of 14, persons over the age of 79, Mexican nationals 

to whom the DOS has issued Border Crossing Cards for use along the southern border, and 

Canadians entering the United States across the northern border. 

45 The Compact Council governs the use of the Interstate Identification Index 

system of criminal history record information for non-criminal justice purposes, according 

to the National Crime Prevention and Privacy Compact Act of 1998. The Interstate 

Identification Index is a segment of IAFIS that stores textual criminal history information 

on arrests and dispositions of criminal subjects. In addition, the Compact Council advises 

the CJIS Advisory Policy Board on civil fingerprint standards. 
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U.S. Department of Justice 15 

Office of the Inspector General 

Evaluation and Inspections Division

IAFIS was not meeting its availability requirement. 

In our 2004 review, we found that IAFIS was not meeting its 

availability requirement of being accessible to users 99 percent of the time. 

We determined that from November 2003 through April 2004, IAFIS was 

unavailable for a total of 161 hours, resulting in an average monthly 

availability of 96 percent. As a result, it was possible that some aliens 

whose criminal records were in IAFIS but not in IDENT would be released 

and allowed to enter the United States due to the system’s unavailability. 

For example, if IAFIS results are not received within about 10 minutes, 

which may happen if IAFIS is unavailable, immigration officials must make 

their decisions on whether to further detain aliens based only on the results 

of IDENT queries. Consequently, some criminal aliens who would have been 

identified through IAFIS queries may not be detained. 

The OIG made six recommendations in our previous report. 

In our December 2004 report, we concluded that for the Department 

to effectively proceed with making IAFIS interoperable with the fingerprint 

systems of the DHS and the DOS, high-level policy decisions needed to be 

made regarding who should be subjected to fingerprint searches, the 

fingerprint collection standard to be used, the databases to be queried, who 

should have access to the information, how the information should be used, 

and who should maintain the databases. We recommended that the 

Department seek to have the federal government address those decisions in 

a timely way. We made the following six recommendations to the 

Department: 

1. Within 90 days of the enactment of the Department’s FY 2005 

appropriations act, report to the Homeland Security Council and 

Congress that the Department, the DHS, and the DOS have 

reached an impasse and cannot complete the [memorandum of 

understanding] directed by Congress.46 The report should formally 

request that the Homeland Security Council or Congress decide on 

the adoption of the NIST Technology Standard and define the 

capabilities to be provided in the interoperable system; 

 46 In our March 2004 report, we recommended that the Department work with the 

DHS to develop and implement a memorandum of understanding to guide integration of 

IAFIS and IDENT. The Conference Report accompanying the FY 2004 omnibus 

appropriations legislation also directed the Department to develop such a document with 

the DHS and other appropriate federal agencies regarding the continued integration of 

fingerprint systems. 
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Evaluation and Inspections Division

2. Increase the transmission of the fingerprints of Known or 

Suspected Terrorists from the FBI to the DHS from monthly to at 

least weekly; 

3. Request access to a random sample of data from US-VISIT and 

other relevant immigration biometric databases used for 

enforcement or benefit purposes for comparison to IAFIS in order 

to determine the risk posed by not checking all visitors against 

IAFIS; 

4. Coordinate with the DHS to identify the capacity needed to 

conduct IAFIS searches on all visitors referred to secondary 

inspection and inform the Department’s CIO how the capacity of 

IAFIS (now planned to be 20,000 searches by October 1, 2005) 

could be increased to handle that level of activity; 

5. Develop options for the eventual upgrade of IAFIS to enable the 

system to conduct 10 flat fingerprint searches on all US-VISIT 

enrollees and TPRS submissions from the Border Patrol and from 

the ports of entry; and 

6. Take steps to ensure that IAFIS meets its availability requirement 

of 99 percent. 

As described in the Results of the Review section, our current review 

has found that the Department and the FBI have taken steps that were 

generally responsive to all of the recommendations we made in our 

December 2004 report. 
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U.S. Department of Justice 17 

Office of the Inspector General 

Evaluation and Inspections Division

PURPOSE, SCOPE, AND METHODOLOGY 

Purpose 

The OIG conducted this review as a follow-up to our December 2004 

report. This review assessed the current status of the FBI’s efforts in 

working with the DHS and other agencies to achieve biometric 

interoperability among its IAFIS and the DHS’s IDENT and US-VISIT 

systems, and the actions taken by the FBI to implement the 

recommendations contained in our December 2004 report. Specifically, this 

review assessed the: 

• Progress made by the FBI and the Department in working with the 

DHS and other agencies toward achieving biometric interoperability 

among IAFIS, IDENT, and US-VISIT; 

• FBI’s and the DHS’s planned actions for achieving full 

interoperability; and 

• Measures taken by the FBI in the interim, before full interoperability 

is achieved, to lessen the risk that criminal aliens and terrorists could 

enter the United States undetected. 

Scope 

The scope of this review included actions taken by the FBI, DHS, and 

DOS related to achieving interoperability among IAFIS, IDENT, and USVISIT; the steps taken by the FBI to implement its plans for a next version 

of IAFIS that are relevant to achieving interoperability; and the DHS’s plans 

to modify IDENT and US-VISIT to process 10 flat fingerprints.47 Our 

fieldwork for this review was completed in June 2006. Because of the 

dynamic nature of the project, the details described in this report may 

change before the interoperability project is completed. 

Methodology 

Our fieldwork consisted of interviews as well as documentation review 

and analysis. 

 

 47 Because the scope involved issues beyond the Department, including issues 

within the DHS, we coordinated with the DHS’s Office of Inspector General during this 

review. 
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U.S. Department of Justice 18 

Office of the Inspector General 

Evaluation and Inspections Division

Interviews. To understand each agency’s perspective and role in 

establishing biometric interoperability, we interviewed officials from the 

Department, DHS, DOS, and NIST. 

 

Interviews with Department personnel. From the Office of the Chief 

Information Officer, we interviewed the Special Assistant to the CIO and two 

Senior Program Analysts. From the Justice Management Division, we 

interviewed IDENT/IAFIS Program Managers and the Acting Program 

Manager for the Joint Automated Booking System Program Management 

Office. From the National Institute of Justice, we interviewed a Senior 

Program Manager in the Research and Technology Development Division. 

From the FBI’s CJIS Division, we interviewed the Deputy Assistant Director, 

Operations Branch; two Section Chiefs; a Unit Chief; Program Managers and 

other officials from the Next Generation Identification and Biometric 

Interoperability Program Offices; and a Senior Computer Engineer. 

Interviews with DHS personnel. From the US-VISIT Program 

Management Office, we interviewed the Director, Deputy Director, Chief 

Information Officer, and several key officials assigned to Mission Operations 

and the Office of the Chief Strategist. From CBP, we interviewed two 

Program Managers from the Office of Field Operations and an Assistant 

Chief from the Office of Border Patrol. 

Interviews with DOS personnel. From the DOS, we interviewed the 

Deputy Assistant Secretary of State for Visa Services and a member of the 

Office of Information Management and Liaison. 

 

Interviews with NIST personnel. From the NIST’s Information Access 

Division, we interviewed the chief scientist with principal responsibility for 

biometrics research and two of his colleagues. 

Document review. To determine the FBI’s progress toward achieving 

biometric interoperability of IAFIS with IDENT, we reviewed and analyzed 

numerous documents, including a 2005 status update from the Department 

to Congress; recent congressional testimony and reports; interoperability 

performance measures; drafts of several interagency (FBI, DHS, and DOS) 

planning documents; interagency correspondence and working group 

agendas; IAFIS data on capacity, availability, and workload; Department 

and DHS plans for the following: the Next Generation Identification 

initiative, the interim Data Sharing Model, the Fast Capture Finger/Palm 

Print program, and the US-VISIT transition to 10 fingerprints; and standard 

operating procedures for the Offices of Border Patrol and Field Operations. 
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U.S. Department of Justice 19 

Office of the Inspector General 

Evaluation and Inspections Division

RESULTS OF THE REVIEW – PART I 

In May 2005, the FBI and the DHS resolved a disagreement 

that had existed since the early 1990s regarding a common 

fingerprint collection methodology. Since then, the 

agencies have begun implementing a three-phase plan for 

achieving full interoperability of IAFIS, IDENT, and USVISIT, a process scheduled for completion in December 

2009. In the first phase, already under way, the FBI and 

DHS plan to deploy a joint automated system for sharing 

key immigration and law enforcement data by September 

2006. The FBI and the DHS must implement the remaining 

two phases to achieve full interoperability that would 

enable complete sharing of immigration and law 

enforcement records among federal, state, and local law 

enforcement agencies. To facilitate full interoperability, 

both agencies have begun upgrading their IAFIS and IDENT 

systems to process 10 flat fingerprints. In addition, the 

DHS is preparing to convert US-VISIT from a 2-fingerprint 

to a 10-fingerprint enrollment standard. While the FBI and 

DHS have made progress toward achieving interoperability 

of their biometric fingerprint identification systems, the 

project faces significant technological, funding, and policy 

challenges to meet the scheduled completion date of 

December 2009. 

 

The FBI and the DHS are implementing the first phase of a three-phase 

plan for achieving full interoperability. 

In May 2005, the DHS Secretary announced that the DHS 

would adopt a 10-fingerprint collection standard for enrolling visitors 

into US-VISIT, as recommended in the NIST Technology Standard. 

The DHS’s decision to modify US-VISIT resolved the first of two major 

barriers that had created an impasse toward achieving 

interoperability between IAFIS and IDENT.48 On May 19, 2005, the 

DHS sent a memorandum to the Homeland Security Council stating 

that it would modify the US-VISIT program as soon as practicable to 

use 10 flat fingerprints for enrollment and 2 flat fingerprints for 

 48 The second barrier has been partially resolved. In May 2005, the DHS agreed to 

provide the FBI and other law enforcement agencies with access to immigration data; 

however, the two agencies have not finalized procedures to provide this access. 
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U.S. Department of Justice 20 

Office of the Inspector General 

Evaluation and Inspections Division

identity verification. The Homeland Security Council concurred with 

the DHS’s decision and stated in a “summary of conclusions” dated 

June 7, 2005, that “it should be the policy of the United States 

Government that biometric screening of foreign visitors to the United 

States be based on a fingerprint standard requiring 10-[finger]print 

capture at enrollment and 2-[finger]print verification thereafter.” 

The resolution of the impasse has allowed the FBI and the DHS to 

begin planning their approach to achieving full interoperability of the 

fingerprint systems. The FBI and the DHS currently are implementing the 

first phase of a three-phase plan that is intended to produce a joint, 

automated system for the reciprocal sharing of key immigration and law 

enforcement data. Appendix II contains a table showing significant 

interoperability-related events during 2005. 

The FBI and the DHS have formed a working group and established a threephase plan for achieving full interoperability.

In May 2005, the FBI (through the CJIS Division), DHS (through the 

US-VISIT office), and DOS formed the IPT to coordinate efforts to achieve full 

interoperability. The IPT charter sets out guiding principles to serve as the 

foundation for sharing biometric and related information among the 

agencies in accordance with each agency’s mission.49 Since its creation, the 

IPT has produced several key interoperability planning documents, 

including the DHS/US-VISIT & DOJ/FBI Interoperability Concept of 

Operations and the DHS/US-VISIT & DOJ/FBI Interoperability Business 

Requirements.50 All issues regarding the interoperability of IAFIS and 

IDENT are vetted through the IPT and its sub-teams. 

The IPT plans to accomplish full interoperability in three phases. A 

brief description of the capabilities planned for each phase follows, while the 

 49 The guiding principles state that each agency has responsibility for its own 

mission, each agency maintains its own repository of information and must ensure its 

integrity, and each agency must protect the privacy rights of individuals represented by the 

information it maintains. IPT members from the FBI and the DHS commented that the 

guiding principles of the IPT, particularly those related to data ownership, were integral to 

the agencies’ agreeing to share data with each other and with federal, state, and local law 

enforcement agencies. 

50 The Interoperability Concept of Operations provides an overview of the proposed 

operational changes that would be required to achieve full interoperability (e.g., how law 

enforcement agencies will access and protect immigration data). The Interoperability 

Business Requirements, which the IPT derived from the Interoperability Concept of 

Operations, identifies the interoperability-related business processes and needs of all 

stakeholders. 
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U.S. Department of Justice 21 

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Evaluation and Inspections Division

phases themselves are described in more detail later in this report. 

According to CJIS Division officials who participate on the IPT, the 

interoperability efforts were on schedule as of June 2006. 

• Interim interoperability: The interim interoperability phase, 

currently being developed, is intended to enable the FBI and the 

DHS to directly access read-only copies of certain key law 

enforcement and immigration data from IAFIS and IDENT in near 

real time. By replicating the data, the FBI and the DHS will each 

be able to conduct fingerprint searches against the other agency’s 

records at their respective locations. The replicated files will also 

provide a 24-hour backup for those shared IAFIS and IDENT 

records. The interim interoperability development phase is 

scheduled to be completed by September 3, 2006.51

• Initial Operating Capability (IOC): The IOC development phase is 

intended to expand the data shared between the two agencies. By 

the end of the IOC development phase, plans are for the FBI to 

have access to all fingerprint images from IDENT, and for the DHS 

to have access to the entire Criminal Master File from IAFIS. This 

phase is also intended to provide the initial fingerprint search 

capacity and storage needed for full interoperability. As of June 

2006, the IOC development phase was scheduled to last 

approximately 22 months, beginning on September 4, 2006, and 

ending in July 2008. 

• Full Operating Capability (FOC): During the FOC development 

phase, the FBI and the DHS plan to provide all federal, state, and 

local law enforcement agencies, as well as authorized non-criminal 

justice agencies, access to immigration data from IDENT.52 By the 

end of the FOC development phase, the agencies expect to have 

increased fingerprint search capacity and storage, improved 

response time, and additional IAFIS capabilities and services. The 

FOC phase is scheduled to be developed over 17 months, 

beginning in July 2008 and ending in December 2009 with full 

interoperability. 

 51 The target completion dates for each phase are from a March 30, 2006, schedule 

developed by the CJIS Division that stated, “Dates are subject to further analysis and 

funding.” 

52 Authorized non-criminal justice agencies are those agencies permitted to request 

criminal background checks for employment, licensing, immigration, credentialing, and 

volunteer activities. 
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U.S. Department of Justice 22 

Office of the Inspector General 

Evaluation and Inspections Division

The FBI and the DHS are developing the first phase of the interoperability 

plan. 

For the interim interoperability development phase, the FBI and the 

DHS established the following objectives: (1) meet both agencies’ most 

urgent requirements for data access; (2) share data in both directions; (3) 

serve as a prototype of technical concepts for full interoperability; and (4) 

not detract from achieving full interoperability in terms of cost, schedule, 

effort, and technical architecture. To meet these objectives, the FBI and the 

DHS began developing the interim Data Sharing Model (iDSM).53 According 

to the iDSM Project Concept of Operations, the iDSM will deliver the first 

interoperable biometric data capability between the DHS and the FBI by 

allowing both agencies to share read-only copies of selected immigration and 

law enforcement data.54 For the iDSM to become operational, the FBI and 

the DHS must identify the records to be shared and exchange the replicated 

files containing the selected records. 

Data to be shared through the iDSM. In September 2005, the FBI, 

DHS, and DOS signed a letter of concurrence stipulating the data to be 

shared among agencies and the terms governing the use, disclosure, and 

protection of the shared data. As of June 2006, the FBI and the DHS had 

agreed to exchange read-only copies of records identified as being the most 

useful to support the other agency’s mission and data that would support 

IAFIS and IDENT users’ needs. According to iDSM planning documents, 

both the FBI and the DHS are responsible for updating the data that they 

share (e.g., expunging records or substituting records with better quality 

fingerprint images) through an automated process. 

The FBI’s data. The FBI is planning to transfer all of the 

approximately 800,000 IAFIS Wants and Warrants records that have 

fingerprints associated with them to provide the DHS with access to the 

complete set of these records.55 Once the iDSM becomes operational, the 

 

(cont.) 

53 The iDSM represents one of three technical solutions that the IPT is considering 

for full interoperability. These technical solutions are discussed in the next section of this 

report. 

54 On April 18, 2006, the IPT finalized an iDSM Concept of Operations, which defines 

user needs and operational concepts for the iDSM and describes the components for which 

the FBI and the DHS each have responsibility (e.g., development, deployment, operations, 

and maintenance of the iDSM). 

55 Prior to November 30, 2005, the DHS had access only to a subset of the Wants 

and Warrants records that did not include U.S. citizens. The FBI was providing the DHS 

with daily extracts of those Wants and Warrants records that met the DHS’s screening 
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U.S. Department of Justice 23 

Office of the Inspector General 

Evaluation and Inspections Division

DHS should have access to all fingerprint records of subjects with active 

warrants, including U.S. citizens, and the current daily extract process will 

be eliminated.56 According to the iDSM Concept of Operations, the DHS’s 

access to the full set of Wants and Warrants records will facilitate better 

decision-making about an individual’s admissibility, eligibility for 

immigration benefits, or deportability from the United States. Access also 

will allow the DHS to detain individuals who have outstanding arrest 

warrants and notify the appropriate law enforcement agency. Once all the 

Wants and Warrants data is available, IDENT users should be able to 

submit one transaction and receive the FBI’s and the DHS’s shared criminal 

history, biographic, and immigration information on the subject whose 

fingerprints are being searched. The DHS plans to conduct up to 250,000 

fingerprint searches of visitors per day against the Wants and Warrants 

data. 

 

In addition to developing the iDSM to provide the interim 

interoperability capability, the FBI also has taken steps to improve the 

records available to the DHS until the iDSM becomes operational. On 

November 30, 2005, the FBI began expanding the daily Wants and Warrants 

records extracted from IAFIS to provide the DHS with all newly issued or 

updated warrants created after November 2005, including those for U.S. 

citizens. The FBI provides up to 2,500 of these records to the DHS each 

day. Although technical limitations restrict the number of daily extracts to 

IDENT, the expansion is nonetheless increasing the information 

immediately available to the DHS. The DHS’s immediate access to these 

additional records allows immigration officials to conduct fingerprint 

searches using more complete and current information. 

The DHS’s data. The DHS is planning to transfer 2 sets of records 

from IDENT to the iDSM: the approximately 16,000 Visa Denial and the 

approximately 390,000 Expedited Removal records.57 The DHS does not 

currently provide the FBI – or the over 70,000 federal, state, and local law 

enforcement agencies that contribute to IAFIS – copies of any immigration 

data. The agencies chose to include those records in the iDSM because they 

 

criteria of individuals who had an unknown or foreign birthplace and citizenship or who 

had a prior arrest on immigration charges. 

 

56 Until full interoperability, the FBI plans to continue sending the DHS other IAFIS 

data, including the fingerprint records submitted as Known or Suspected Terrorists. 

57 The iDSM Concept of Operations states that the DHS is planning to include the 

Recidivists with Alerts records in the iDSM “as soon as technically feasible.” 
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U.S. Department of Justice 24 

Office of the Inspector General 

Evaluation and Inspections Division

 

were viewed as being most useful to law enforcement officials.58 According 

to the iDSM Concept of Operations, these immigration records will help the 

FBI and other IAFIS users establish the identity of individuals they 

encounter, determine whether someone is in the United States illegally, 

conduct better risk assessments, protect officer safety, and enhance law 

enforcement agencies’ ability to develop comprehensive history and threat 

profiles. The FBI plans to conduct searches of at least 1,000 fingerprint 

submissions per day against these DHS records. As of June 2006, the DHS 

had not begun providing copies of these records to the FBI, but DHS 

officials told us that they would be able to transfer both sets of records to 

the iDSM by September 3, 2006. 

CJIS Division officials stated that the initial iDSM storage capacity for 

the FBI’s and the DHS’s replicated files will accommodate up to 1 million 

records each. They explained that the FBI and the DHS designed each data 

storage component to accommodate about twice that amount of records to 

allow for growth and to prevent the need to immediately upgrade the iDSM. 

Status of system development. FBI and DHS officials told us that, 

as of June 2006, the development of the iDSM was on schedule to become 

operational on September 4, 2006. CJIS Division officials stated they were 

in the process of purchasing the hardware and software needed for the 

storing of the replicated files. According to documents the CJIS Division 

provided, the hardware and software must be delivered by July 2006 to 

maintain that schedule. 

On September 4, 2006, when the iDSM is expected to be fully 

populated with copies of the Wants and Warrants, Visa Denial, and 

Expedited Removal records, the FBI and the DHS plan to begin testing and 

using the iDSM. Once the iDSM is operational, the FBI plans to enable 

three agencies to submit fingerprint searches through IAFIS to be run 

against the DHS’s records. The three agencies are the Boston Police 

Department, the Texas Department of Public Safety, and the U.S. Office of 

Personnel Management. Those agencies represent state and local law 

enforcement and a federal agency authorized to conduct fingerprint 

searches for non-criminal justice purposes. The FBI is planning to divide 

the initial iDSM search capacity of 1,000 daily fingerprint searches among 

those three agencies. The FBI and the DHS plan to test the iDSM’s 

effectiveness by tracking the number of fingerprint searches each agency 

58 Some FBI personnel have limited access to US-VISIT and other immigration data 

via a February 2005 memorandum of understanding with the DHS. The DHS provided this 

access to allow certain FBI personnel at specified locations where the FBI and the DHS are 

co-located and co-operational (i.e., through the Joint Terrorism Task Forces) to conduct 

queries. 
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performs, the number of hits and positive identifications resulting from 

those searches, the number of individuals apprehended as a result of the 

positive identifications, the number of false positives, the transfer and 

storage of data in the iDSM, and the hardware and software performance. 

If successful, the iDSM will be instrumental in establishing the 

foundation for full interoperability between IAFIS and IDENT. The DHS’s 

access to the full set of Wants and Warrants records will help reduce the 

risk of unknowingly admitting criminal aliens into the United States, 

including those claiming to be U.S. citizens. Once all the Wants and 

Warrants containing fingerprint data are transferred to the iDSM, 

immigration officials will be able to search visitors’ fingerprints against all of 

these records rather than a subset. Similarly, the FBI’s access to the Visa 

Denial and Expedited Removal records will help identify illegal aliens. The 

FBI’s access to those immigration records is significant because, for the first 

time, the FBI will be able to search fingerprint records in IAFIS against 

those in IDENT. 

The FBI and the DHS plan to implement the remaining two 

interoperability phases by December 2009. 

To achieve full interoperability, the FBI and the DHS must next 

complete the final two interoperability phases (IOC and FOC). The IOC 

development phase is planned to begin on September 4, 2006, and continue 

through July 2008. The FOC development phase is to begin in July 2008 

and end by December 2009 with full interoperability. 

During the IOC phase, the FBI and the DHS plan to choose a technical 

solution, expand data sharing, and broaden access to the data. 

At the beginning of the IOC development phase, the FBI and the DHS 

must decide on one of three technical solutions currently under 

consideration for full interoperability. The three technical solutions, 

described below, are referred to as the shared data model, the shared 

services model, and a base case option. 

Shared data. This model involves the FBI and the DHS exchanging, 

and conducting searches against, read-only copies of each other’s 

fingerprint data. Under the shared data model, the FBI and the DHS would 

independently maintain their own biometric (fingerprint) and biographic 

data, but would provide a copy of the fingerprint data to the other agency. 

The receiving agency would be responsible for searching the data and 

requesting the associated biographic information when a match is 

encountered. The replicated data also would provide an offsite, 24-hour 

backup for IAFIS and IDENT data, which the agencies plan to keep updated 
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in near real time. The iDSM has a shared data component because it allows 

both agencies to access copies of the same biometric data (e.g., Wants and 

Warrants, Visa Denials, and Expedited Removals). 

Shared services. This model involves the FBI and the DHS each 

sending fingerprint search transactions directly to the other agency’s 

automated system. The shared services model would not utilize copies of 

the FBI’s and the DHS’s fingerprint data. Instead, each agency would 

maintain control over its data by requesting that the other agency perform a 

fingerprint search and return the associated biographic information. This 

model is similar to the current process whereby the DHS sends fingerprint 

searches (TPRS transactions) directly to IAFIS through the IDENT/IAFIS 

workstations and requests the criminal history or immigration information 

associated with any fingerprint matches. The iDSM has a shared services 

component because it allows both agencies to request biographic and 

criminal history data from the agency that owns it when a fingerprint match 

is found. 

Base case. Finally, the IPT is also considering a base case option, 

which refers to a slightly improved version of the operational iDSM. 

According to the FBI, this would encompass the DHS’s efforts to modernize 

IDENT as they occur. 

Although the FBI and the DHS have not made a final decision on the 

technical solution for full interoperability, they are implementing the iDSM 

as a prototype to test the shared data approach. CJIS Division officials 

stated that they are currently working on a cost-benefit analysis to 

determine the most efficient solution and estimate the necessary costs. The 

cost-benefit analysis is due to be completed by August 2006. CJIS Division 

officials stated that after September 3, 2006, when the iDSM is expected to 

become operational, they will test the technology for 30 to 90 days. The FBI 

and the DHS plan to make the records in the iDSM available for conducting 

fingerprint searches throughout the 22-month duration of the IOC 

development phase. Both agencies plan to track and evaluate the number 

of fingerprint searches performed against the other agency’s records and the 

number of positive identifications resulting from the searches. 

During the IOC phase, the FBI and the DHS expect to have access to 

one another’s basic immigration and criminal history information associated 

with any fingerprint searches that result in a match. Specifically, the FBI 

and the DHS plan to: (1) expand the data shared between them; 

(2) establish the initial fingerprint search capacity and storage needed for 

full interoperability; (3) allow federal, state, and local agencies limited access 

to immigration data, which includes basic biographic data; and (4) provide 

immigration authorities full access to criminal history information. 
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Expanded data sharing. During the IOC phase, the FBI and the DHS 

plan to expand the data accessible to each agency beyond the records 

initially selected for sharing through the iDSM. During the IOC phase, the 

FBI expects to have access to all biometric records in IDENT, and the DHS 

expects to have access to all biometric records from the IAFIS Criminal 

Master File.59 The method of providing this access will depend on which of 

the technical solutions (shared data or shared services) the IPT selects (the 

base case would not provide access to all biometric records in IDENT and 

IAFIS because it includes only the iDSM records). For example, if the 

shared data model is chosen, both agencies would exchange copies of 

additional IAFIS and IDENT data, beyond the records in the iDSM. 

 

Fingerprint search capacity and storage. The FBI and the DHS 

also expect to establish the initial fingerprint search and storage capacity 

needed for full interoperability during the IOC phase.60 The CJIS Division 

plans to search a subset of its federal, state, and local agencies’ IAFIS 

transactions against the DHS’s records. Specifically, the CJIS Division 

plans to conduct up to 1,000 initial fingerprint searches per day of selected 

criminal arrestees and federal employees in positions of public trust or 

national security against the DHS’s records in the iDSM. By the end of the 

IOC development phase, the FBI plans to increase those fingerprint 

searches to approximately 50,000 per day and increase the storage capacity 

to accommodate all the records that will be in IAFIS and IDENT by FY 2009. 

Federal, state, and local agencies’ limited access to immigration 

data. During the IOC development phase, the FBI plans to allow any 

agency – beyond the three pilot agencies – to request a fingerprint search 

against the DHS’s records. The agencies may be federal, state, or local law 

enforcement or civil agencies conducting non-criminal justice searches. The 

FBI’s current system receives approximately 60,000 search requests per day 

from all such agencies. Currently, FBI and other law enforcement personnel 

can obtain immigration data on a foreign national who is a “subject of 

interest” by submitting the subject’s name to the DHS’s Law Enforcement 

Support Center (LESC).61 During IOC, the LESC will continue to provide 

59 Information on individuals with protected identities (e.g., individuals seeking 

asylum or those enrolled in a witness protection program) will not be shared. 

60 If a shared data model or the base case is chosen, then the necessary capacity of 

the iDSM will have to be determined. If the shared services model is chosen, then the 

agencies will need to determine the necessary capacity of IAFIS and IDENT. 

61 The LESC – which operates 24 hours a day, 365 days a year – provides federal, 

state, and local law enforcement agencies with information about foreign nationals they 

encounter (e.g., immigration status, identity of individuals arrested or under investigation) 

by researching information available in various databases and criminal history repositories. 
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support to the FBI. When the FBI finds a match of a subject’s fingerprints 

against IDENT data, it plans to request the associated immigration data 

from the LESC. However, as of June 2006, FBI officials indicated that the 

amount and types of immigration data that the LESC would provide had not 

been determined. The FBI plans to request the data from the LESC by 

submitting an electronic request known as an Immigration Alien Query, to 

which the LESC will return an automated response. The FBI will then 

provide that response back to the requesting agency. Officials from the 

CJIS Division and US-VISIT office recently met with LESC representatives to 

plan for the additional workload. According to the iDSM Concept of 

Operations, the initial submissions to the LESC will not exceed 80 requests 

per day. 

Immigration authorities’ full access to criminal history data. For 

criminal justice purposes, the DHS plans to obtain criminal history 

information through the existing procedure whereby it submits a query to 

the FBI’s National Crime Information Center. For non-criminal justice 

agencies (e.g., the DOS), the FBI will provide the criminal history 

information associated with a fingerprint match after it makes a positive 

identification in IAFIS. 

 

During the FOC phase, the FBI and the DHS are planning to achieve full

interoperability. 

The FBI and the DHS plan to begin developing the FOC phase in July 

2008, after completion of the IOC phase. The FOC phase is scheduled to be 

developed over 17 months, ending in December 2009, and is to achieve full 

interoperability among IAFIS, IDENT, and US-VISIT. According to CJIS 

Division officials, however, implementing the FOC development phase will be 

affected by the progress of two separate projects that we discuss later in this 

report: the CJIS Division’s development of a new version of IAFIS and the 

DHS’s modernization of IDENT.

The FOC phase is intended to be an expansion of the IOC phase and 

is planned to: (1) provide complete, standardized data sharing between the 

FBI and the DHS; (2) increase fingerprint search capacity and storage to 

accommodate more transactions; and (3) allow federal, state, and local 

agencies full access to immigration data. 

 Standardized data sharing. By the end of the FOC development 

phase, IAFIS and IDENT users are expected to be able to submit a single 

request that searches all fingerprint records maintained by the FBI and the 

DHS to receive associated criminal history and immigration information 

about the subject. The searches are to be based on fingerprints, although 

interoperability planning documents indicate that expansion to palm prints, 
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facial recognition, and other biometrically based methods may be developed 

and used by the agencies in the future in a final interoperability solution 

(beyond FOC).62 The method of providing this information will depend on 

which of the technical solutions (shared data, shared services, or a base 

case) the IPT selects. 

Increased fingerprint search capacity and storage. CJIS Division 

officials stated that by the end of the FOC phase, the federal, state, and 

local agencies’ capacity to search against the DHS’s records will increase 

from the planned IOC capacity of approximately 50,000 transactions per 

day to approximately 200,000 per day, a level that according to CJIS 

Division officials, will accommodate all requests. The FBI and the DHS are 

also planning to increase the storage capacity of the interoperability solution 

to accommodate all the records that will be in IAFIS and IDENT by FY 2010. 

Federal, state, and local agencies’ full access to immigration 

data. By the end of the FOC development phase in December 2009, the FBI 

and the DHS are planning to allow all federal, state, and local law 

enforcement agencies, as well as authorized non-criminal justice agencies, 

full access to the DHS’s immigration data, both benefits- and enforcementrelated. However, the two agencies have not yet decided on the parameters 

of this access and must still make several policy decisions. As of April 

2006, officials from the CJIS Division and US-VISIT office were meeting to 

discuss the following issues: 

• The FBI and the DHS must decide on a policy for agencies’ use of the 

immigration data. IDENT does not yet provide an individual’s 

comprehensive immigration records, and the DHS is concerned about 

the potential for law enforcement officers using incomplete 

information to apprehend someone that they think is an immigration 

violator. For example, if an individual apprehended along the border 

is naturalized 2 years later, IDENT would contain information on the 

apprehension but may not contain information on the subsequent 

naturalization. The latter information is kept in other DHS databases 

that are available to immigration officers but not to law enforcement 

agencies querying IDENT. The DHS is working to make 

62 The Department’s National Institute of Justice is seeking to develop new 

fingerprint biometrics technology and also to improve current technology. Its Fast Capture 

Fingerprint/Palm Print Technology initiative is seeking to develop a device capable of 

collecting the equivalent of 10 rolled fingerprints in less than 15 seconds to improve the 

screening requirements for criminal, border, transportation, and employment checks. In 

September 2005, the National Institute of Justice awarded grants to 3 vendors to begin 

producing such devices, which will be available for testing within 18 to 24 months. 
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comprehensive information available through its efforts to modernize 

IDENT (described in the next section). 

• The DHS is responsible for protecting the privacy of its information, 

particularly information on individuals with records in US-VISIT who 

are presumed to be visitors with no existing criminal records. Thus, 

the FBI and the DHS must decide on an appropriate policy to ensure 

that individuals’ privacy is protected once agencies can access 

immigration data.63 

 

With FOC, the LESC is expected to provide more comprehensive 

immigration information associated with fingerprint matches. As of June 

2006, CJIS Division officials stated that although the amount and types of 

immigration data that the LESC would provide have not been determined, 

they described the idea of providing an “immigration summary sheet” that 

would contain a consolidated listing, from every available database, of all 

immigration information (including biographic) related to the subject. 

To support full interoperability, the FBI and the DHS are upgrading 

IAFIS and IDENT, and the DHS is preparing to convert US-VISIT to 10 

fingerprints. 

Concurrent with the IPT’s efforts to implement full interoperability, 

the FBI and the DHS are independently upgrading IAFIS and IDENT to 

process 10 flat fingerprints. The FBI is upgrading IAFIS to process more flat 

fingerprint submissions through its Next Generation Identification (NGI) 

initiative, and the DHS is planning to modernize IDENT and convert 

US-VISIT from a 2- to a 10-fingerprint system. 

The FBI is upgrading IAFIS through its NGI initiative. 

In early 2004, the FBI began planning the NGI initiative (then called 

Next Generation IAFIS) to provide IAFIS users with quicker and more 

accurate fingerprint searches and more complete criminal history 

information. As described below, the interoperability-related portions of the 

NGI initiative include the processing of an increased volume of flat 

 63 Access to immigration information in the DHS’s databases is governed by the 

Privacy Act of 1974 (5 U.S.C. § 552a, as amended), which contains requirements for 

agencies that maintain a system of records. The Privacy Act defines a system of records as 

“a group of any records under the control of any agency from which information is retrieved 

by the name of the individual or by some identifying number, symbol, or other identifying 

particular assigned to the individual.” The FBI acknowledged the need to protect the 

privacy of the data to be shared between IAFIS and IDENT users in its risk management 

plan, which we discuss in the next section of this report. 
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fingerprints as well as several new services, including a specialized 

biometric database and improvements in criminal history data. 

To oversee NGI planning and implementation, the CJIS Division 

created the NGI Program Office on March 15, 2005. On July 1, 2005, the 

FBI awarded a contract for a study to identify development and 

implementation strategies, functional and system level requirements, and 

cost estimates. To identify user needs, a team of contractors and FBI 

personnel from the NGI Program Office completed over 200 interviews with 

IAFIS users from federal, state, and local agencies, including the DHS and 

the DOS. NGI Program Office staff stated that they planned to categorize 

and prioritize user needs and develop cost estimates for them. The study is 

slated to be completed by December 2006. 

The NGI initiative is scheduled to be implemented concurrently with 

the overall interoperability effort. CJIS Division officials told us that the 

interoperability-related portions of NGI are tentatively scheduled to be 

completed by the end of the FOC development phase in December 2009, 

pending the results of the study. In FY 2006, the FBI received $16.8 million 

to support IAFIS hardware and software modernization associated with NGI. 

The CJIS Division estimated that it would need an additional $74.1 million 

in FY 2007 funding for further NGI development, however the Department 

requested $38.1 million in FY 2007 to cover the FBI’s NGI-related expenses. 

 

Flat fingerprint processing. In our 2004 review, we found that the 

CJIS Division was planning to incorporate in its NGI initiative flat 

fingerprint processing for non-criminal justice purposes, including checking 

employees’ and applicants’ backgrounds, issuing licenses, and enrolling 

foreign nationals into US-VISIT. To ensure that IAFIS would be prepared to 

handle 10 flat fingerprint submissions from the approximately 43 million 

annual US-VISIT enrollees, we recommended that the FBI develop options 

for the eventual upgrade of IAFIS.64 Since we issued our 2004 report, the 

FBI has begun accepting flat fingerprint submissions on a limited basis. 

According to NGI Program Office staff, IAFIS currently processes flat 

fingerprints from three entities: the DOS, the American Bankers 

Association, and the Ohio Bureau of Criminal Identification and 

Investigation. From July 27, 2005, through April 17, 2006, those entities 

submitted approximately 47,000 search requests. 

 

64 CJIS Division officials explained that the algorithms in IAFIS were designed to 

process 10 rolled fingerprint submissions and that searching IAFIS using flat fingerprints 

requires more processing power than searching using rolled fingerprints. 
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Evaluation and Inspections Division

 

NGI Program Office staff stated that although conducting searches 

using flat fingerprints requires more processing power than rolled 

fingerprints, IAFIS currently can process the number of fingerprint searches 

it is receiving without affecting response time. However, because searches 

of US-VISIT enrollees’ fingerprints will significantly increase the volume of 

flat fingerprint submissions, the CJIS Division is in the process of 

implementing upgrades to the fingerprint search segment of IAFIS and to 

the system’s overall search capacity. IAFIS is currently capable of 

processing up to 100,000 fingerprint searches a day from all sources, but 

NGI Program Office staff stated that the CJIS Division plans to expand this 

capacity to at least 200,000 daily fingerprint searches based upon 

requirements from IAFIS users from federal, state, and local agencies, 

including the DHS and the DOS.65

In addition, NGI planning documents we reviewed indicated that 

enhancing IAFIS to process more flat fingerprints will require the FBI to 

develop two separate initiatives. First, the CJIS Division must ensure 

efficient searching in IAFIS using 10 flat fingerprints and, second, must 

develop processes for the acceptance of 2-fingerprint verification requests. 

NGI Program Office staff confirmed that the IAFIS will have the capability to 

process both 10 flat fingerprint searches and 2-fingerprint verifications. 

Enhanced Terrorist Identification Service (ETIS). The CJIS 

Division is planning to implement a specialized biometric database that will 

allow more rapid identification of certain criminals and terrorists. The plans 

call for the ETIS to be integrated with the National Crime Information Center 

and to be interoperable with other automated fingerprint identification 

systems. The CJIS Division plans to implement the ETIS during the FOC 

development phase as a subsystem of IAFIS. 

Disposition improvements for criminal history records. Another 

NGI initiative planned for the FOC development phase will improve the 

disposition information on criminal history records from the National Crime 

Information Center. The disposition provides users with information on the 

outcome of an arrest, such as whether the individual was convicted or 

acquitted. 

65 Although the DHS is currently the CJIS Division’s only TPRS customer, the 

planned capacity increase should allow the CJIS Division to process TPRS transactions for 

other agencies in the future. However, if the IPT chooses a shared data or base case option, 

the need for TPRS transactions will be eliminated because the DHS will be able to conduct 

searches of visitors’ fingerprints against copies of IAFIS data. 
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Evaluation and Inspections Division

The DHS plans to modernize IDENT. 

The DHS is planning to begin modernizing IDENT through an effort it 

refers to as “Unified IDENT” to accept, store, and process 10 fingerprints 

and improve fingerprint matching accuracy. Further, according to the 

DHS’s draft Initial 10-print Transition Plan (10-Print Plan) dated 

September 16, 2005, the DHS plans to provide more comprehensive 

individual alien history information, link its various immigration databases, 

and establish a “person-centric view.” According to the 10-Print Plan, the 

goal of the person-centric view is for each individual with an immigration 

history to have only one identity across all DHS databases (known as a 

unique identifier). Under the person-centric view, the DHS expects users to 

be able to submit a single query and receive a consolidated response 

containing all biographic and immigration information (both benefits- and 

enforcement-related) associated with the individual being queried. The CJIS 

Division’s schedule reflects that the DHS is planning to begin modernizing 

IDENT during the interim interoperability development phase and complete 

the modernization during the FOC development phase. 

When we asked DHS officials whether they were on schedule with the 

IDENT modernization efforts, they stated that the project is likely to take 

longer than they anticipated, but that this would not affect the achievement 

of full interoperability. US-VISIT officials stated that they are currently 

working with CBP and others to consolidate fingerprint records, but that 

they must acquire additional fingerprint processing power to support 

searching of those records. US-VISIT officials stated that their first priority 

was to prepare the records to be shared through the iDSM, particularly the 

Expedited Removal records, by ensuring that all the records contain an 

identifying number and that there are no duplicates. US-VISIT officials 

confirmed that they plan to complete the IDENT modernization project 

during the FOC development phase. 

The DHS plans to convert US-VISIT to 10 fingerprints. 

The DHS and the DOS have begun planning for the transition of 

US-VISIT from a 2- to a 10-fingerprint enrollment standard during the 

interim interoperability development phase. The DHS has formed a user 

group to select a new scanner suitable for capturing 10 flat fingerprints. In 

April 2006, the DOS began a series of pilot projects to collect 10 flat 

fingerprints from foreign nationals applying for visas at selected consulates 

and embassies. The DOS plans to complete those pilot projects and begin 

deploying 10 flat fingerprint processing at the remaining consulates and 

embassies during the IOC development phase, according to the CJIS 

Division’s schedule. The DHS plans to begin pilot projects to collect 10 flat 
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fingerprints from foreign nationals at selected ports of entry during the IOC 

development phase. 

The DHS has estimated the costs to implement the US-VISIT 

transition from 2 to 10 fingerprints for both it and the DOS in FY 2006 and 

FY 2007. According to the DHS’s 10-Print Plan, the US-VISIT transition will 

cost approximately $281 million for both fiscal years ($240 million in DHS 

costs and $41 million in DOS costs).66 In FY 2006, the DHS received $340 

million for US-VISIT expenses.67 In FY 2007, the DHS requested $362 

million for US-VISIT expenses. 

The DHS’s plans to convert US-VISIT. In preparation for modifying 

US-VISIT, the DHS formed a user group with representatives from the FBI, 

the National Institute of Justice, the DOS, the NIST, and the Department of 

Defense. The user group identified a need for fingerprint scanners that are 

faster, smaller, and more portable than the devices currently being used to 

capture 10 flat fingerprints.68 The user group agreed on a set of core 

requirements and issued a Request for Information to vendors to develop a 

device capable of capturing 10 flat fingerprints. In a December 2005 report, 

the user group determined that, while the industry currently does not offer 

a device that meets all of its core requirements, two vendors would be able 

to provide, within 12 months, such a device.69 The DHS plans to test and 

evaluate the devices during the interim interoperability development phase, 

according to the CJIS Division’s schedule. 

The DOS’s pilot projects to collect 10 flat fingerprints. In April 

2006, the DOS began testing software capable of processing either 2 or 10 

fingerprints at the consulate office in Cairo, Egypt. The DOS also began a 

series of pilot projects recently to collect 10 flat fingerprints from visa 

66 The $281 million represents the higher of 2 cost estimates for the US-VISIT 

transition that the DHS provided in its 10-Print Plan. The higher estimate assumes that 

the transition to 10 fingerprints would require modifications to existing ports of entry 

facilities, whereas the lower estimate assumes that the transition would not require 

modifications. 

 

67 The DHS’s FY 2006 budget request included $24 million to begin implementing 

the person-centric view. 

68 Current scanners used by the DOS and other agencies are capable of capturing 

10 flat fingerprints. However, according to the user group, those devices are limited in 

many respects (e.g., fingerprint capture time, scanner size, image quality) and do not offer 

the capabilities that the DHS and the DOS have identified as necessary for the efficient 

collection of 10 flat fingerprints from foreign nationals. 

69 Smart Border Alliance, 10 Print Capture RFI Study Report, December 2005. 
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Evaluation and Inspections Division

 

applicants at selected consulates and embassies. The DOS began its first 

pilot project in San Salvador, El Salvador in April 2006 and is planning 

additional pilot projects in London, England in July 2006 and in Riyadh, 

Saudi Arabia in September 2006. 

 According to DOS officials, the pilot projects will test the process of 

collecting 10 fingerprints in an operational environment to identify the 

length of time needed to collect the fingerprints, the quality of the 

fingerprint images collected, and additional training needs. However, 

because IDENT is not yet prepared to accept 10 fingerprints, the DOS plans 

to continue transmitting 2 flat fingerprints for searches against IDENT.70 

DOS officials stated that they did not anticipate sending 10 flat fingerprint 

images to the DHS for inclusion in IDENT until September 2006, when 

IDENT is expected to begin accepting 10 fingerprints. To collect the 

fingerprints during the pilot projects, the DOS plans to use an existing type 

of 10-print scanner that the FBI certified as being in compliance with IAFIS. 

Once smaller, lighter scanners are available, the DOS plans to deploy the 

devices and require 10 flat fingerprint processing at its remaining 

consulates and embassies during the IOC development phase. 

Pilot projects to collect 10 flat fingerprints from foreign nationals at 

selected ports of entry are scheduled to occur during the IOC phase, 

according to the CJIS Division’s schedule. In April 2006, DHS officials 

stated that the pilot locations had not yet been identified. They also stated 

that before the DHS decides on appropriate ports of entry for a pilot, they 

must conduct further planning, such as operational and process modeling, 

facilities modifications, proposed technical solutions, and environmental 

planning, and collaborate with CBP and other stakeholders. The DHS is 

planning to deploy US-VISIT 10-fingerprint capabilities at all ports of entry 

and consulates by the end of the FOC development phase. 

The IPT is estimating interoperability costs for the IOC phase. 

The IPT is working on a cost-benefit analysis, which it expects to 

complete by August 2006, that will estimate the IOC interoperability-related 

expenses for the FBI, DHS, and DOS to make IAFIS, IDENT, and US-VISIT 

interoperable.71 Those expenses will include agency-specific initiatives 

needed for interoperability, such as a portion of the FBI’s NGI, the DHS’s 

70 Until the 10-print records can be transferred to IDENT, the DOS is planning to 

store them in its Consular Consolidated Database, which contains information on visa 

applicants. 

71 We attempted to obtain an estimate of the total interoperability-related expenses 

through the FOC phase but FBI officials stated that a total estimate was not available. 
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U.S. Department of Justice 36 

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IDENT modernization, and the DHS and DOS joint implementation of a 

10-fingerprint enrollment standard for US-VISIT. The final cost will depend 

largely on which of the technical solutions the IPT chooses for full 

interoperability. FBI officials noted that achieving full interoperability is 

dependent on the FBI, DHS, and DOS receiving adequate appropriations to 

cover all interoperability-related expenses. 

 

The FBI has estimated costs for the first two interoperability phases. 

Separate from the IPT’s cost-benefit analysis for IOC, FBI officials 

have developed FBI-specific cost estimates for the first two interoperability 

phases. For FY 2006, the FBI estimated a cost of $7.9 million for the iDSM 

and $24 million for the first portion of the IOC development phase. In its FY 

2006 appropriation, the FBI budgeted $18.9 million for interoperabilityrelated expenses, most of which included reprogrammed funding.72 For 

FY 2007, the FBI estimated that $33 million will be needed for hardware 

and software for the IOC development phase and the FBI subsequently 

requested that amount in the President’s FY 2007 budget.73 

The FBI and the DHS have identified technical, funding, and 

policy risks and have developed mitigation strategies. 

We examined whether the FBI and the DHS (through the IPT) have 

identified potential technical, funding, and policy risks that could delay full 

interoperability and whether they have developed corresponding mitigation 

strategies. We found that the IPT has developed risk management plans 

and mitigation strategies that appear reasonable for the overall 

interoperability effort. We also found that the FBI developed a risk 

management plan with mitigation strategies for its portion of the interim 

interoperability development phase (iDSM).74 

In a November 2005 draft Interoperability Concept of Operations, the 

IPT identified broad risks that must be managed throughout each of the 

72 That figure consists of $15.5 million of reprogrammed funding and $3.4 million 

from the FY 2005 funding of the FBI’s IDENT/IAFIS integrated workstations. 

73 The Department’s FY 2007 appropriations had not yet been awarded at the time 

this report was published. 

74 FBI officials told us that the DHS Unique Identity IPT has also devised risk 

management plans for its portion of the interoperability risks. However, we did not verify 

this with the DHS or examine those plans. 
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Evaluation and Inspections Division

interoperability phases.75 The IPT devised mitigation strategies for those 

risks and stated that it, along with the DHS and the DOS, would manage 

the risks and periodically report to the IPT’s Executive Committee on the 

status of the mitigation effort. The broad risks and mitigation strategies in 

the document we examined included the following: 

• Limited time to develop, design, and deploy an interoperability 

solution: To mitigate this risk, the IPT stated it would develop a plan 

with targeted milestones and project measurements. 

• Lack of financial, personnel, or technical resources within 

participating agencies: To mitigate this risk, the IPT stated it would 

provide joint (FBI and DHS) briefings to the Office of Management and 

Budget, Congress, and other authorizing/funding bodies to ensure 

that interoperability remains a priority. 

• Privacy issues limiting participation or categories of transactions: To 

mitigate this risk, the IPT stated that its Strategy and Policy sub-team 

would address all legal and policy issues. 

• Misuse of data in interoperable solution: To mitigate this risk, the IPT 

stated it would devise protections to guard against misuse of data, 

including recommendations for policies, procedures, and audits. 

The FBI identified the iDSM-specific risks in an April 2006 iDSM 

Concept of Operations. For the specific risks, the FBI identified 

corresponding mitigation strategies and risk consequences that build on the 

broader interoperability risks discussed in the previous document. CJIS 

Division officials stated that they regularly identify and monitor the iDSM 

risks, and on May 3, 2006, the officials provided documentation showing 18 

open risks and 39 risks that they had closed.76 The open risks involved 

areas such as schedule, technology, reliability of systems, cost, policy, 

privacy, and security. Among them were: 

• Purchase and receipt of iDSM equipment: The FBI recognized that 

the acquisition process for the hardware and software needed for the 

iDSM would be lengthy and could significantly delay the deployment 

 75 In the Interoperability Concept of Operations, the IPT defined “risk” as a potential 

event or condition that would be detrimental to the successful implementation and 

operation of the interoperability effort. 

76 The FBI closed a risk if: (1) it took action to mitigate the risk or render the risk 

moot, (2) it incorporated a specific risk with another one already being addressed, or (3) it 

determined the probability of occurrence was low. 
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Evaluation and Inspections Division

schedule of the first interoperability phase. To address this risk, the 

FBI stated that the purchase of this equipment must be made by 

June 2006 and the equipment received by July 2006. As of June 27, 

2006, FBI officials stated that they were in the process of purchasing 

the equipment. As a contingency plan in the event that a delay is 

encountered, the FBI stated that it would identify any similar 

equipment within the CJIS Division that can be temporarily but 

immediately utilized. 

• Sufficient resources for the iDSM: The FBI recognized the possibility 

that insufficient resources could cause the first interoperability 

phase to fall behind schedule. To address this risk, the FBI stated it 

would apply Earned Value Management to optimize investment 

planning and control.77 Officials from both the FBI and the DHS 

have indicated that while they are currently on schedule, delays in 

receiving necessary funding would push back the December 2009 

target completion date for full interoperability. For example, FBI 

officials stated that if a purchase request is delayed by as little as 45 

days, it could cause the FBI to miss a procurement cycle, which 

would push back each of the interoperability phases. 

• Protection of sensitive data to be shared through the iDSM: Because 

the data to be shared through the iDSM is considered sensitive, the 

FBI recognized the risk of not protecting this data and stated that 

owners of the data may need to restrict access. To address this risk, 

the FBI is working with privacy officials and conducting analyses to 

determine whether a privacy impact assessment is needed.78 The 

FBI also decided to limit the volume of data initially being shared 

through the iDSM. 

Although the interoperability risks and corresponding mitigation 

strategies appear to be reasonable, the scope of our review did not include 

an analysis of whether the IPT or the FBI identified all potential risks to the 

interoperability project and appropriately closed or mitigated those risks. 

Further, because the FBI is working toward establishing the iDSM, it has 

not completed risk analysis plans for the remaining two phases, although 

 77 Earned Value Management is a program management technique for estimating 

the performance of a project in terms of its budget and schedule while taking risk into 

consideration. 

78 A privacy impact assessment is an analysis of how an agency handles 

information on individuals to ensure it conforms to applicable privacy laws and policies. 

The E-Government Act of 2002 requires executive branch agencies to conduct privacy 

impact assessments when they develop or modify electronic collections of such information. 

T
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FBI officials stated that they have begun identifying potential risks for the 

IOC and FOC development phases. We therefore encourage the FBI to 

continue regularly monitoring the overall risks to the project and to develop 

risk mitigation strategies for the IOC and FOC phases. 
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U.S. Department of Justice 40 

Office of the Inspector General 

Evaluation and Inspections Division

RESULTS OF THE REVIEW – PART II

The FBI has taken interim actions to lessen the risk of 

criminal aliens or terrorists entering the United States 

undetected until full interoperability among IAFIS, IDENT, 

and US-VISIT can be achieved. For example, the FBI has 

begun transmitting key terrorist records to the DHS daily 

instead of monthly. The FBI also has improved fingerprint 

identification services for the DHS by enhancing IAFIS 

availability, capacity, and response time. 

The FBI has taken action to lessen the risk of criminal aliens or 

terrorists entering the United States undetected. 

Since our December 2004 report, the FBI has taken a series of actions 

to lessen the risk of criminal aliens or terrorists entering the United States. 

For example, the FBI has begun implementing the first phase of the IPT’s 

interoperability plan and has initiated improvements to IAFIS. Specifically, 

the FBI has increased the frequency of its transmissions to the DHS of the 

Known or Suspected Terrorists records and improved IAFIS availability, as 

the OIG recommended. The FBI also proactively enhanced IAFIS capacity 

for processing fingerprint search transactions from the DHS, improved 

response time for those transactions, and designated the transactions as 

high priority in IAFIS. 

The FBI increased transmissions of Known or Suspected Terrorists records. 

 In a May 2, 2005, memorandum to the OIG responding to 

recommendations in our December 2004 report, the Department stated that 

the FBI had changed its process to provide Known or Suspected Terrorists 

records to the DHS within 7 days of establishing the record in IAFIS. In a 

follow-up memorandum to the OIG, the Department stated that the FBI 

began providing these records on a daily basis on June 24, 2005. 

 

To ensure that the DHS was receiving the Known or Suspected 

Terrorists extracts on a daily basis, we asked DHS officials whether they 

had experienced any difficulties in receiving the information. DHS officials 

responded that they have been receiving the extracts without difficulty, 

although they commented that they do not always receive the records on a 

daily basis. To clarify the extracts’ frequency of transmission, we asked the 

Chief of the CJIS Division section responsible for the collection and 

transmission of the Known or Suspected Terrorists fingerprints why the 

DHS was not always receiving daily transfers. The Section Chief explained 
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Evaluation and Inspections Division

that with the automated extract process, IAFIS communicates with IDENT 

on a daily basis, but when there are no new records to send, IAFIS does not 

send extracts. 

The FBI has improved IAFIS availability. 

 In our 2004 review, we found that IAFIS experienced 161 hours of 

downtime (about 60 percent of it scheduled and 40 percent unscheduled) 

from November 2003 through April 2004, resulting in an average monthly 

availability of approximately 96 percent during that period.79 At that time, 

CJIS Division officials acknowledged that the downtime exceeded the IAFIS 

requirement of 99-percent availability. They told us that they were working 

to limit scheduled downtime to four occasions per year by researching 

methods of installing faster software, including upgrades that could be 

accomplished without taking the system out of service. 

In a series of memorandums responding to our recommendation that 

the FBI meet its 99-percent availability requirement for IAFIS, the 

Department described efforts to upgrade the system. In its December 16, 

2004, memorandum to the OIG, the Department noted that the FBI had 

improved availability annually since the system became operational in 1999. 

The Department reiterated that the CJIS Division was working to reduce 

unscheduled outages through a series of software and hardware upgrades 

that would be completed by April 2005. In a May 2, 2005, memorandum, 

the Department stated that the FBI had completed many of these upgrades, 

but officials believed it was premature to determine how the upgrades 

specifically affected IAFIS availability. In an October 6, 2005, 

memorandum, the Department stated that the FBI’s upgrades had improved 

the overall system availability and that IAFIS was available to users an 

average of 99.3 percent of the time from May to August 2005. Specifically, 

the system had 361 minutes of unscheduled downtime and 873 minutes of 

scheduled downtime (for system maintenance and enhancements). 

 In our current review, we examined IAFIS availability hours and found 

that the system was available an average of 98.7 percent of the time from 

January through November 2005 and that the average availability had risen 

to 99.3 percent for the period following the series of improvements (May 

through November 2005). We found that when compared with a similar 

time period, IAFIS’s average availability had increased by 3.1 percent in 

 79 Downtime refers to periods when IAFIS is unavailable to users because of 

planned maintenance (scheduled downtime) or an unexpected service outage (unscheduled 

downtime). Downtime is significant to the DHS because agents and inspectors process 

illegal and legal aliens around the clock at Border Patrol stations and ports of entry. 
2005.80 However, when we reviewed the availability on a monthly basis for 

the period of May through November 2005 (following the IAFIS 

improvements), we found that June and September fell below the FBI 

requirement of 99 percent, as shown in Chart 1. 

Chart 1: Average IAFIS Availability per Month 

(January – November 2005)

95.9%

98.4%

99.5%

99.4%

98.4%

99.7%

99.6%

98.3%

99.8%

99.7%

96.8%

90%

91%

92%

93%

94%

95%

96%

97%

98%

99%

100%

January

February

March

April

May

June

July

August

September

October

Available Each Month

November

 

 Source: FBI CJIS Division 

 When we asked CJIS Division officials about the drop in availability 

during June and September, they explained that they performed scheduled 

maintenance during those months in accordance with their quarterly 

maintenance goals. The CJIS Division coordinates the specific time periods 

for that maintenance with all IAFIS users, including the DHS, so that 

downtime will be the least disruptive to their operations. 

We found that the CJIS Division has decreased the average number of 

IAFIS downtime minutes by 80.7 percent – from an average of 1,618 

minutes per month from November 2003 through April 2004 to 312 minutes 

per month from May through November 2005. Additionally, the CJIS 

Division has decreased the percentage of time IAFIS is down due to 

unscheduled outages from 40.4 percent for the period covered in our prior 

 80 We calculated the percentage change by comparing the 6-month period of 

November 2003 through April 2004 (the period examined in our prior report) to the 

7-month period of May through November 2005. May 2005 is the point at which the CJIS 

Division upgrades resulted in IAFIS improvements and November 2005 reflects the most 

recent data that was available during our fieldwork. 

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U.S. Department of Justice 43 

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Evaluation and Inspections Division

report to 28.8 percent for the period May through November 2005. A CJIS 

Division official stated in February 2006 that the CJIS Division has 

sustained the 99-percent average IAFIS availability since November 2005. 

 

 In addition to responding to our recommendation, the CJIS Division 

initiated another project to further improve IAFIS availability. In 2005, an 

FBI contractor began a study to identify areas where overall IAFIS 

availability can be improved, including improving TPRS processing for the 

DHS. After the review, the CJIS Division expects the contractor to propose 

solutions for performing quarterly maintenance without affecting the TPRS 

services, including performing monthly maintenance activities without (or 

minimizing) a service outage. 

The FBI increased IAFIS capacity. 

 In our 2004 review, we found the existing IAFIS capacity of 8,000 

daily TPRS transactions was sufficient to handle the projected DHS 

workload increase that would result from deployment of the integrated 

IDENT/IAFIS workstations. We also reported in 2004 that the CJIS Division 

was planning to increase IAFIS capacity to 20,000 daily TPRS 

transactions.81 We concluded that the current and planned IAFIS capacity 

was sufficient for the DHS’s workload projections through 2005, which 

assumed that less than 1 percent of the visitors subjected to US-VISIT 

(about 800 per day) would be subjected to direct IAFIS fingerprint searches 

at ports of entry. 

 

However, we pointed out in our December 2004 review that DHS 

inspection policy states that “all subjects who are suspected of being 

inadmissible to the United States shall be queried through IDENT/IAFIS.” 

Had the DHS checked all visitors referred to secondary inspection against 

IAFIS, the workload would have exceeded the planned capacity of 20,000 

daily TPRS transactions. According to data US-VISIT officials provided in 

2004, CBP inspectors referred an average of 22,350 visitors to secondary 

inspection each day between July 1, 2003, and June 30, 2004.82 Thus, we 

 81 The CJIS Division was also planning to increase IAFIS capacity for another type 

of transaction. In 2004, the IAFIS capacity for Criminal Answer Required (CAR) bookings 

was 30,000 per day, which the CJIS Division was planning to increase to 60,000 per day in 

2005. CAR bookings occur when an alien is booked at a Border Patrol station or port of 

entry and the officer transmits a CAR transaction (with the alien’s 10 rolled fingerprints) to 

IAFIS so that the record is enrolled into IAFIS and available to other law enforcement 

agencies. 

82 During FY 2005, CBP inspectors referred an average of 23,934 visitors to 

secondary inspection each day. 
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U.S. Department of Justice 44 

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Evaluation and Inspections Division

 

recommended that the Department coordinate with the DHS to identify the 

actual capacity needed. 

In our current review, we found that the Department had not pursued 

discussions with the DHS regarding expanding IAFIS capacity beyond the 

20,000 daily TPRS transactions.83 In an October 6, 2005, memorandum to 

the OIG, the Department stated that it did not anticipate that all visitors 

referred to secondary inspection would be fingerprinted and checked against 

IAFIS. Only those thought to be inadmissible were to be checked against 

IAFIS to determine whether they had a prior criminal history record. 

Because of the ongoing discussion with the DHS regarding interoperability, 

the Department stated it was premature to determine whether additional 

IAFIS capacity was needed. For example, if the FBI and the DHS select a 

shared data model for full interoperability, meaning that the DHS would be 

searching copies of IAFIS data, then the issue of IAFIS capacity would be 

eliminated. Therefore, the CJIS Division officials said they have no current 

plans to expand IAFIS capacity beyond its current 20,000 TPRS 

transactions per day. 

Although the FBI has no plans to expand IAFIS capacity, the 

Department responded to our recommendation by identifying the costs 

associated with increasing IAFIS capacity beyond 20,000 daily TPRS 

transactions. In its October 6, 2005, memorandum to the OIG, the 

Department stated that while it and the DHS had not specifically identified 

the transaction volume that would be generated if all visitors referred to 

secondary inspection were searched against IAFIS, it estimated a cost of 

between $3 million to $10 million for each additional increment of 10,000 

daily TPRS transactions. 

 We asked DHS officials about their current plans for submitting TPRS 

transactions to IAFIS. In these interviews, DHS officials stated that the 

DHS is not planning to expand the number of visitors in secondary 

inspection subjected to TPRS transactions or change the pool of visitors 

subjected to US-VISIT at this time. 

 We analyzed FY 2005 TPRS transaction data from the CJIS Division to 

determine whether the current IAFIS capacity is sufficient. We found that 

in FY 2005, IAFIS processed an average of 4,199 daily TRPS transactions 

83 According to CJIS Division officials, they completed an enhancement of IAFIS to 

support 20,000 TPRS and 60,000 CAR transactions per day on October 4, 2005. This 

represents a 150-percent increase over the prior TPRS capacity and a 100-percent increase 

over the prior CAR capacity.
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U.S. Department of Justice 45 

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Evaluation and Inspections Division

from the DHS.84 Therefore, the FBI’s IAFIS capacity of 20,000 daily TPRS 

transactions is more than sufficient to handle the DHS’s current average 

daily workload for criminal checks. 

The FBI improved IAFIS response time. 

 The CJIS Division provides IAFIS responses to law enforcement 

agencies within 2 hours, but the DHS requires faster response times, 

particularly at Border Patrol stations that must process large numbers of 

apprehended aliens. According to CJIS Division documentation, its goal is 

to provide TPRS responses to the DHS within 2 minutes 90 percent of the 

time and within 3 minutes 100 percent of the time. 

 

We found that the CJIS Division’s IAFIS upgrades increased the 

percentage of responses returned within 3 minutes since 2004. During the 

period October through December 2005, IAFIS provided 98.2 percent of the 

TPRS responses within 3 minutes, compared to 93.7 percent during the 

same 3-month period in 2004. Even with a 6.1-percent increase in the total 

number of transactions during the most recent period, IAFIS supplied faster 

responses for a greater percentage of transactions, especially at the 

30-second and 1-minute intervals. For example, as shown in Table 1, there 

was a 132.6-percent change in the percentage of TPRS transactions 

processed within 1 minute from FY 2004 to FY 2005. These upgrades 

allowed IAFIS to provide responses to 88.2 percent of the DHS’s fingerprint 

searches within 1 minute. 

Table 1: Percentage of TPRS Transactions Processed 

by IAFIS Within Specific Intervals 

Comparison of time IAFIS Processing Intervals 

periods: 

October-December 30 seconds 

 

1 minute 2 minutes 3 minutes 

2004 3.7% 37.9% 88.2% 93.7% 

2005 6.2% 88.2% 97.2% 98.2% 

Percentage change from 

2004 to 2005 68.1% 132.6% 10.2% 4.8% 

 Source: OIG calculations of CJIS Division data 

 84 Of the 4,199 daily TPRS transactions submitted through IAFIS during FY 2005, 

685 were requested by inspectors at ports of entry and the remaining 3,514 were submitted 

by the Border Patrol, according to US-VISIT staff. 
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The FBI designated TPRS transactions as high priority. 

 To ensure that all TPRS transactions from the DHS are processed as 

quickly as possible, the CJIS Division created a new designation for TPRS 

transactions. The designation, referred to as “high priority,” means that 

IAFIS processes those transactions before other criminal fingerprint search 

transactions. On December 4, 2005, IAFIS began processing TPRS 

transactions as high priority. 

 

No risk analysis has been conducted on the visitors exempt from the 

US-VISIT requirements. 

During our 2004 review, Department officials proposed that they 

conduct a study to determine how many individuals whose fingerprints were 

in IDENT but who were not subjected to fingerprint searches against IAFIS 

had records in the IAFIS Criminal Master File. This population would have 

included both visitors subject to US-VISIT and those exempt from the 

US-VISIT requirements. The study would have provided the Homeland 

Security Council with more information to use in making a decision on a 

uniform fingerprint collection methodology for foreign nationals. 

Department officials told us that they wanted to obtain statistically valid 

random samples of data from US-VISIT and other relevant immigration 

databases in IDENT and search that data against IAFIS. The Department 

had discussed the possible study with the DHS, but the two agencies had 

not agreed on the parameters of the study or on the data to be sampled. 

Our December 2004 report recommended that the Department undertake 

such a study. 

In response to our recommendation, the Department CIO wrote to the 

Director of the US-VISIT office on March 1, 2005, to request that the DHS 

provide a sample of approximately 5,000 records from the US-VISIT 

Enrollment and Border Crossing Card databases for comparison to IAFIS. 

The CIO also stated in the letter that while the process of extracting data 

from IAFIS into IDENT had produced valuable results in the short term, 

Department officials believed that other criminal aliens could be identified 

and therefore denied admission.85 

However, after the DHS’s May 2005 decision to adopt the NIST 

Technology Standard, and the subsequent progress made toward achieving 

interoperability, the Department announced that it was no longer planning 

to conduct the study. In an October 6, 2005, memorandum from the 

 85 To date, no known terrorists have been identified through the IAFIS extract 

process, only criminal aliens. 
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Department to the OIG, the Department stated that its primary interest in 

pursuing the study was to encourage further efforts toward interoperability. 

Given the fact that the FBI and the DHS had already begun planning for full 

interoperability and preparing to implement the iDSM, the Department 

stated, “it is less imperative from [the Department’s] perspective to conduct 

the study.” 

Nonetheless, Department officials stated that the study was still 

needed to assess the risk of unknowingly admitting criminal aliens into the 

United States, particularly those exempt from US-VISIT, and suggested to 

the OIG that the DHS conduct the study. Officials from the Office of the 

CIO and the Justice Management Division confirmed that although the 

Department’s interest in conducting the study had lessened, the study was 

still needed to assess this risk. 

Once full interoperability is achieved in December 2009, the DHS will 

be able to use 10 fingerprints to screen the US-VISIT population against 

IAFIS or copies of IAFIS data. However, Department officials stated that it 

would be valuable to know the “hit rate” (i.e., the number of hits against 

IAFIS records) of individuals exempt from US-VISIT requirements, 

particularly the Border Crossing Card population. Department officials 

explained that because these visitors are not screened against IAFIS upon 

entry to the United States, the DHS does not know how many may have 

matches in the FBI’s database. The DHS could use that information to 

inform future immigration policy decisions, such as whether to expand the 

pool of individuals to which US-VISIT applies. Because it is the DHS’s 

responsibility to prevent inadmissible aliens from entering the country, 

Department officials asserted that the DHS, not the Department, should 

undertake the study. 

We then asked DHS officials whether they intended to conduct a 

study similar to the one proposed by the Department using US-VISIT or 

Border Crossing Card data. On March 29, 2006, officials from the US-VISIT 

office indicated that the need for conducting this study has been “overcome 

by events” because the DHS has already decided to implement a 

10-fingerprint standard for US-VISIT. 

We believe that until full interoperability is achieved, the DHS’s policy 

of using IAFIS to check the fingerprints of less than 1 percent of the visitors 

subjected to US-VISIT will continue to create a risk that criminal aliens or 

terrorists could enter the United States undetected. Once full 

interoperability is achieved, this risk will be reduced because the visitors 

subjected to US-VISIT will be checked against the full Criminal Master File. 

However, this risk will not be eliminated because a substantial number of 
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Evaluation and Inspections Division

visitors exempt from US-VISIT, such as Border Crossing Card holders, will 

not have their fingerprints searched against IAFIS. 

 
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CONCLUSION 

Since our December 2004 report, the FBI and the DHS have made 

progress toward achieving full interoperability among IAFIS, IDENT, and 

US-VISIT. The DHS’s May 2005 decision to implement a 10-fingerprint 

enrollment standard for US-VISIT resolved the primary barrier to 

interoperability that we identified in 2004. Since then, the FBI and the DHS 

have formed an interoperability working group and began implementing the 

first phase of a three-phase plan to make IAFIS, IDENT, and US-VISIT 

interoperable by December 2009. FBI officials stated that, as of June 2006, 

they were on schedule with the interoperability plan. 

In the first phase, the agencies plan to deploy the iDSM, a joint 

automated system for real-time sharing of key immigration and law 

enforcement data between the FBI and the DHS by September 2006. If 

successful, the iDSM will deliver the first interoperable biometric data 

capability between the FBI and the DHS. In the remaining two 

interoperability phases, the FBI and the DHS plan to enable full sharing of 

immigration and law enforcement records among federal, state, and local 

law enforcement agencies, authorized non-criminal justice agencies, and 

immigration officials. In addition, the decision to begin sharing immigration 

information with law enforcement officials through the iDSM partially 

resolves the second barrier that we identified in 2004. 

To support full interoperability, the FBI is upgrading IAFIS to process 

more flat fingerprint submissions and the DHS is planning to modernize 

IDENT and convert US-VISIT from a 2- to a 10-fingerprint system. 

Moreover, the IPT is developing a cost-benefit analysis that is expected 

to provide an estimate of the interoperability-related expenses for the IOC 

development phase. The IPT plans to complete that analysis by August 

2006. The interoperability-related expenses will include agency-specific 

initiatives needed for interoperability, such as portions of the FBI’s NGI, the 

DHS’s IDENT modernization, and the DHS and DOS joint implementation of 

a 10-fingerprint enrollment standard for US-VISIT. The final cost will also 

depend on which of the technical solutions the IPT chooses for full 

interoperability. 

There are significant technological, funding, and policy issues facing 

the FBI and the DHS if they are to meet the scheduled completion date of 

December 2009 for full interoperability. We found that the FBI has 

identified both the broad interoperability risks and the iDSM-specific risks 

and has devised mitigation strategies that appear to be reasonable. 

However, the scope of this review did not include a thorough analysis of 

whether the FBI identified all potential risks to interoperability and 
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U.S. Department of Justice 50 

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Evaluation and Inspections Division

appropriately closed or mitigated those risks. Further, although FBI 

officials stated that they have begun identifying potential risks to the IOC 

and FOC development phases, they have not completed risk analysis plans 

for those two phases. We therefore encourage the IPT to continue regularly 

monitoring the overall risks to interoperability and the iDSM, and to develop 

similar plans and risk mitigation strategies for the IOC and FOC phases. 

The FBI has implemented interim actions since December 2004 to 

lessen the risk of criminal aliens or terrorists entering the United States 

undetected until full interoperability can be achieved. Transmitting Known 

or Suspected Terrorists records to the DHS daily instead of monthly allows 

the DHS to conduct searches of visitors’ fingerprints using the most current 

IAFIS extracts. Increasing IAFIS availability to 99 percent lessens the risk 

that the DHS could unknowingly release aliens who, though they have no 

criminal records in IDENT, do have criminal records in IAFIS. Also, by 

increasing the IAFIS capacity from 8,000 to 20,000 daily TPRS transactions, 

the FBI has provided a capacity that is more than sufficient to handle the 

DHS’s current average daily workload for criminal checks. Lastly, the FBI’s 

significant improvement in IAFIS response time and implementation of a 

high-priority designation for the DHS ensures that criminal aliens or 

terrorists can be identified as quickly as possible. 

However, we believe that until full interoperability is achieved in 

December 2009, the DHS’s policy of using IAFIS to check the fingerprints of 

less than 1 percent of the visitors subjected to US-VISIT will continue to 

create a risk that criminal aliens or terrorists could enter the United States 

undetected. Once full interoperability is achieved, this risk will be reduced 

because the visitors subjected to US-VISIT will be checked against the full 

IAFIS Criminal Master File. However, this risk will not be eliminated 

because a substantial number of visitors exempt from US-VISIT, such as 

Border Crossing Card holders, will not have their fingerprints searched 

against IAFIS. Department officials feel that the DHS should initiate a risk 

analysis to determine the hit rate of these visitors. 

Based on the results of our current review, we concluded that the 

Department and the FBI have implemented actions to address the 

recommendations we made in our December 2004 report and therefore we 

are closing them. 

Nonetheless, important milestones and outstanding risks must be 

addressed before full interoperability among the FBI’s IAFIS and the DHS’s 

IDENT and US-VISIT is achieved. For example, the FBI’s risk management 

plan for the iDSM states that the equipment purchase must be made by 

June 2006, and that the equipment must be received by July 2006. The 

FBI has already noted that if a purchase request is delayed by even 45 days, 
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Office of the Inspector General 

Evaluation and Inspections Division

it could cause them to miss a procurement cycle, which would push back 

the anticipated completion dates of each of the interoperability phases. The 

OIG plans to monitor the progress of the interoperability project, including 

the achievement of these and other milestones. 

Officials from the Department (including the FBI), DHS, and DOS 

provided informal comments on this report. Those comments reflected a 

general concurrence with the facts presented in this report. 
__________________________________________________________________________________________ 

U.S. Department of Justice 52 

Office of the Inspector General 

Evaluation and Inspections Division

APPENDIX I: COMPARISON OF FINGERPRINT COLLECTION METHODS 

Rolled prints 

of 10 fingers 

(10 rolled prints)

Flat-pressed prints 

of 10 fingers 

(10 flat prints)

Flat-pressed prints 

of 2 fingers 

(2 flat prints)

Used by 

DOJ: Used as the IAFIS Criminal 

Master File enrollment standard 

DHS: Used to check apprehended 

aliens against IAFIS Criminal Master 

File; used to enroll aliens in the 

IDENT Lookout database; used to 

enroll aliens to be booked in IAFIS 

Criminal Master File (CAR booking); 

used for background checks prior to 

issuing lawful permanent resident 

card or granting citizenship 

DOS: Not used 

DOJ: FBI is currently 

implementing this as the 

standard for civil enrollments and 

conducting background checks 

DHS: Not yet used; will become 

US-VISIT enrollment standard 

DOS: Used on a limited basis 

through pilot projects at selected 

consulates 

NIST recommended standard to 

enroll and search interoperable 

fingerprint identification systems 

DOJ: Not used, but accepted for 

one-to-one verification matches 

DHS: Used to enroll aliens in IDENT 

database as well as for later searches 

of this database; Until US-VISIT 

transition to 10 flat prints, used to 

enroll visitors at ports of entry in 

US-VISIT (if not done by DOS) 

DOS: Until US-VISIT transition to 10 

flat prints, used to enroll visa 

applicants at consulates in US-VISIT 

NIST recommended standard for 

one-to-one verifications only 

Pros 

Provides the most complete 

information for identifying 

individuals 

Search accuracy; results in among 

the fewest false positive hits 

Provide the most information to 

match against latent fingerprints 

Greatest categorization of 

fingerprints reduces search to about 

2 percent of database, enabling the 

most efficient use of processing 

power 

Search accuracy for identifying 

criminals in IAFIS is statistically 

indistinguishable from using 10 

rolled prints 

Takes only 10 to 15 seconds 

longer than taking 2 flat prints 

Less intrusive than 10 rolled 

prints – operator need not touch 

subject 

Fewer false positives than 2 

prints 

Improved categorization of 

fingerprints reduces search to 

about 6 percent of database, 

enabling more efficient use of 

processing power 

Least expensive for equipment and 

labor 

Least intrusive for subjects 

Least objectionable for foreign 

visitors 

Acceptable search time when used to 

check 2-print databases 

Fastest and easiest to take prints of 

acceptable quality (lowest enroll 

reject rate) 

Cons 

Taking 10 rolled prints is time 

consuming and labor intensive 

Most difficult to take prints of 

acceptable quality (highest enroll 

reject rate) 

Requires different/more expensive 

equipment 

Most intrusive (operator must 

physically roll subjects’ fingers) 

Most objectionable to foreign visitors 

More expensive than two flats 

Could be perceived as more 

intrusive than two flats 

Slower IAFIS searches than 10 

rolled 

Provides less information than 10 

rolled prints for identifying latent 

fingerprints 

Least accurate, results in most false 

positive hits and more frequent false 

negatives (i.e., missed identification 

of criminal on file) 

Least categorization makes it 

inefficient for searching 10-print 

databases, such as IAFIS (requires 

searching 70 percent of database) 

Provides least information for 

identifying latent fingerprints, which 

may be from any of 10 fingers 

Possibility of finger sequence errors 
APPENDIX II: INTEROPERABILITY EVENTS IN 2005 

IAFIS/IDENT/US-VISIT 

Interoperability Events in 2005 

March

1 FBI CJIS Division proposes to the DHS an interim interoperability solution 

involving data sharing in near real time. 

14 Department CIO sends letter to Homeland Security Council, transmitting 

December 2004 OIG report and requesting IAFIS/US-VISIT study. 

May 

19 DHS Deputy Secretary sends letter to Homeland Security Council, affirming 

DHS Secretary’s decision to modify US-VISIT to take 10 flat fingerprints for 

enrollment and 2 flat fingerprints and a photograph for verification. 

June 

7 Homeland Security Council concurs with the DHS’s decision to modify USVISIT and concludes that biometric screening of all foreign nationals to the 

United States will be based on 10 flat fingerprints for enrollment and 2 flat 

fingerprints and a photograph for verification. 

21 FBI, DHS, and DOS sign US-VISIT/DOJ FBI Interoperability Integrated 

Project Team Charter. 

24 FBI begins providing updates of fingerprints of Known or Suspected 

Terrorists to DHS on a daily basis as an interim interoperability solution. 

July

13 DHS Secretary publicly announces decision to accept NIST biometric 

standard of 10 flat fingerprints for enrollment and 2 flat fingerprints and a 

photograph for verification. 

September

16 As part of the Fast Capture Fingerprint/Palm Print initiative, the National 

Institute of Justice awards grants to 3 vendors to develop devices designed 

to capture the equivalent of 10 rolled fingerprints in 15 seconds or less. 

October

4 FBI completes enhancement of IAFIS capacity to support up to 20,000 daily 

TPRS and 60,000 daily CAR transactions from the DHS. 

6 JMD provides Congress and OIG with status report on efforts to achieve 

interoperability among IAFIS, IDENT, and US-VISIT. 

November 

30 FBI begins transferring the first set of Wants and Warrants records created 

after November 2005 to the DHS as part of the iDSM. 

December 

4 FBI completes final system enhancements to make TPRS transactions for 

the DHS high priority in IAFIS. 

30 DHS completes deployment of US-VISIT to all ports of entry. 

__________________________________________________________________________________________ 

U.S. Department of Justice 53

Source: OIG 

 

Office of the Inspector General 

Evaluation and Inspections Division