Department of Homeland Security 

Office of Inspector General 

Customs and Border Protection's 
 


Implementation of the Western 
 


Hemisphere Travel Initiative 
 


at Land Ports of Entry
 
 

OIG-11-16 November 2010 
Office ofInspector General 

U.S. Department of Homeland Security 

Washington, DC 25028 

Homeland 

Security 

NOV 292010 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses Customs and Border Protection's implementation of the Western 

Hemisphere Travel Initiative at land ports of entry and actions needed to be better 

prepared to fully enforce the new document requirement. It is based on interviews with 

employees and officials of relevant agencies and institutions, direct observations, and a 

review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

Anne L. Richards 

Assistant Inspector General for Audits 
Table of Contents/Abbreviations 

Executive Summary .............................................................................................................1 
 


Background..........................................................................................................................2 
 


Results of Audit ..................................................................................................................4 
 


Potential For Substantial Increase in Secondary Inspections ........................................5 
 

Impact of WHTI-Noncompliance on Ports ....................................................................8 
 

CBP Procedures for Processing WHTI-Noncompliant Travelers Have Not Been 
 

Completed .................................................................................................................12 
 


Recommendations........................................................................................................12 
 


Management Comments and OIG Analysis ................................................................13 
 


Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................16 
 


Appendix B: Management Comments to the Draft Report .......................................18 
 


Appendix C: Major Contributors to This Report ......................................................21 
 


Appendix D: Report Distribution ..............................................................................22 
 


Abbreviations 

CBP Customs and Border Protection 
 


DHS Department of Homeland Security 
 


OIG Office of Inspector General 
 


TECS Travelers Enforcement Communication System
 
 

WHTI Western Hemisphere Travel Initiative 
 

OIG
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Western Hemisphere Travel Initiative requires citizens of the 

United States, Canada, Bermuda, and Mexico arriving at land ports of 

entry to present passports or other approved documents to enter the 

United States. Although the Western Hemisphere Travel Initiative 

became effective at land ports on June 1, 2009, Customs and Border 

Protection is not fully enforcing the new document requirement. 

Customs and Border Protection is using informed compliance 

procedures to educate noncompliant travelers about the new document 

requirement. Customs and Border Protection is reporting an average 

compliance rate of 96% at its land border crossings. Our objective was 

to determine whether Customs and Border Protection is prepared to 

fully enforce the Western Hemisphere Travel Initiative’s new 

document requirement at land ports of entry. 

Customs and Border Protection is not prepared to fully enforce the new 

document requirement at land ports of entry. Although Customs and 

Border Protection has acquired and deployed substantial technological 

tools to aid in inspecting travelers, Customs and Border Protection has 

not analyzed the impact that a substantial increase in secondary 

inspection workload will have on secondary inspection staffing and 

infrastructure during full enforcement. The reported Western 

Hemisphere Travel Initiative compliance rates during the initial eightmonth informed compliance period indicate noncompliant travelers 

arriving at the agency’s 39 busiest land ports may increase the 

secondary inspection workloads at these ports by an average of 73% if 

all noncompliant travelers required secondary inspections. 

The agency has not finalized the operating procedures its officers will 

use to verify the identity and citizenship of noncompliant travelers. 

Customs and Border Protection officials told us other priorities have 

precluded them from completing the operating procedures. Until the 

new travel document requirement is fully enforced, the agency 

continues to incur risk that persons falsely claiming to be citizens of the 

United States, Canada, and Bermuda may be admitted to the United 

States. We are making four recommendations to better prepare the 

agency to fully implement the new requirement at land ports of entry. 

CBP agreed with our proposed corrective actions and is in the process of 

implementation. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 1 
Background 

A primary mission of the United States Customs and Border 

Protection (CBP) is preventing terrorists and terrorist weapons 

from entering the United States. On a typical day in fiscal year 

2009, CBP’s Office of Field Operations processed about 700,000 

incoming travelers at land ports of entry. This processing includes 

"primary inspections" to initially determine whether travelers are 

compliant with applicable entry rules and regulations, and when 

needed, "secondary inspections" if a CBP officer determines that 

further inspection processes are necessary to grant a traveler's entry 

into the United States. 

With passage of the Intelligence Reform and Terrorism Prevention 

Act (IRPTA) of 2004, (Public Law 108-458), Congress sought to 

strengthen the processes that allow travelers to enter the United 

States. Section 7209 of the Act noted the existing admission 

procedures allowed many individuals to enter the United States 

with little to no identification and that additional safeguards were 

needed to prevent terrorists from entering the United States. 

IRPTA required the Secretary of Homeland Security, in 

consultation with the Secretary of State, to develop and implement 

a plan to "require a passport or other document, or combination of 

documents, deemed by the Secretary of Homeland Security to be 

sufficient to denote identity and citizenship, for all travel into the 

United States by United States citizens and by categories of 

individuals for whom passport requirements were previously 

waived under section 212(d)(4)(B) of the Immigration and 

Nationality Act." To implement these requirements, the 

Departments of Homeland Security and State published two final 

rules, one related to air travel and the second to land and sea travel. 

These rules are part of what is known as the Western Hemisphere 

Travel Initiative (WHTI). 

Prior to January 31, 2008, U.S. citizens, Canadians, and 

Bermudians were not required to present any form of identification 

to the CBP officer at a land port and could orally declare 

citizenship upon arrival. With the WHTI Land and Sea Final Rule 

becoming effective June 1, 2009, CBP sought to prepare the public 

for the document change during a WHTI transition phase, which 

occurred from January 31, 2008 to May 31, 2009. During this 

transition phase, all United States, Canadian, and Bermudian 

citizens 19 years and older who entered the United States at land 

and sea ports of entry from within the Western Hemisphere were 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 2 
 

 

 

 

required to present a government-issued photo identification along 

with proof of citizenship or a valid passport or other acceptable 

document. Verbal claims of citizenship alone were no longer 

sufficient to establish citizenship for entry into the United States. 

CBP’s primary focus during the transition phase was public 

education, preparation, and awareness. 

Effective June 1, 2009 the Land and Sea Final Rule requires U.S., 

Canadian, and Bermudian citizens, who were previously exempt 

from documentary requirements, to present a passport or other 

WHTI-compliant document for entry into the United States at all 

land ports of entry.1 WHTI compliant documentation consists of: 

•	 U.S., Canadian, Bermudian passports, 

•	 U.S. Passport Card, 

•	 Mexican passport and visa, 

•	 Border Crossing Card issued by the Department of State, 

•	 Enhanced Driver’s Licenses, 

•	 Trusted Traveler Cards (NEXUS, SENTRI, or FAST), 

•	 Form I-872 American Indian Card, or Enhanced Tribal Cards 

(when available), 

•	 Military Identification Cards (for members of the U.S. armed 

forces on official orders), 

•	 U.S. Merchant Mariner Document (for U.S. citizens on official 

maritime business), 

•	 Birth certificate, Canadian Citizenship Card, or a Canadian 

naturalization certificate (for Canadians under age 16 or groups 

of children under age 19), and 

•	 Birth certificate, a Consular Report of Birth Abroad issued by 

the Department of State, or a Certificate of Naturalization (for 

U.S. citizens under age 16 or groups of children under age 19). 

Although the WHTI document requirement at land ports became 

effective on June 1, 2009, CBP is not fully enforcing the 

requirement. CBP’s current WHTI implementation strategy at 

land ports of entry, established in operational guidance dated May 

14, 2009, is informed compliance. Informed compliance seeks to 

encourage compliance through awareness, education, and outreach. 

CBP’s goal is to achieve compliance while not unnecessarily 

inconveniencing those who are uninformed. The guidance further 

1

 Prior to WHTI, at land ports of entry, Mexican citizens were not required to present passports when 

traveling to the Mexican consulate, or when arriving with a valid Border Crossing Card from any 

contiguous territory. As of June 1, 2009, the Mexican passport requirement is waived at land ports only for 

individuals with Border Crossing Cards arriving from Mexico (but not any other territory). 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 3 
states the majority of noncompliant U.S. and Canadian citizens, 

once advised of the requirements will be admitted at primary. 

Under informed compliance, few WHTI-noncompliant travelers 

have undergone secondary inspections solely for failing to present 

a WHTI-approved document. According to the May 14, 2009 

operational guidance, WHTI-noncompliant travelers who the 

primary CBP officer determines to have presented unacceptable 

documentation on at least two previous occasions, when 

operationally feasible, may be referred to secondary for 

verification of identity and citizenship. Based on this guidance, 

CBP officers only referred about 9,000 WHTI-noncompliant 

travelers for a secondary inspection from June 1, 2009 through 

January 31, 2010. 

CBP received $365 million in funding in fiscal years 2008 ($225) 

and 2009 ($140) to implement WHTI at land ports of entry. CBP 

developed Radio Frequency Identification (RFID) enabled 

documents, new software technology for the vehicle primary lanes 

known as the Vehicle Primary Client (VPC), and the RFID 

physical infrastructure at its high volume land ports. DHS 

awarded a contract on January 10, 2008 to begin the process of 

deploying the RFID facilitative technology and infrastructure to 

354 vehicle primary lanes at 39 high-volume land ports, which 

process 95 percent of land border traveler crossings. 

CBP has now deployed the VPC software to all land ports of entry 

and the RFID technology to the top 39 high volume land ports of 

entry covering approximately 95 percent of land border traffic. 

The RFID technology facilitates travel by allowing traveler 

information to be displayed for its officers and automatically 

queries law enforcement databases allowing documents to be 

authenticated to original source information as the vehicle 

approaches the primary inspection area. As a result of WHTI, 

CBP estimates that travel document query rates at the land border 

crossings have increased significantly from 2005 to 2010. 

Results of Audit 

CBP is not prepared to fully enforce the WHTI document 

requirement at land ports of entry. According to CBP, WHTI 

compliance rates have averaged 96% at all border crossings during 

the initial eight-month informed compliance period. However, the 

4% of travelers who do not have WHTI-compliant documents 

could result in a significant increase in secondary inspection 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 4 
workload at many of CBP’s high-volume land ports. This is 

especially true at border crossings in southern states which are 

experiencing a lower than average compliance rate. For example, 

the compliance rate for land ports in the state of Texas during the 

initial eight-month compliance period was reportedly 91%. This 

level of compliance equates to 1.1 million additional travelers that 

could be sent to secondary inspections during this eight-month 

period if WHTI document requirements were strictly enforced. 

Noncompliant travelers could result in CBP’s 39 high-volume land 

ports of entry experiencing an average 73% increase in secondary 

inspection workload under full enforcement. CBP has not 

analyzed the impact that this substantial increase in secondary 

inspection workload will have on secondary inspection staffing and 

infrastructure. 

CBP also has not finalized the operating procedures its officers 

will use to process noncompliant travelers under full enforcement 

including the conditions requiring travelers be sent to secondary 

inspection areas, and the minimum inspection requirements and 

detailed steps needed to verify a noncompliant traveler’s identity 

and citizenship. Customs officials told us other priorities have 

precluded them from completing the operating procedures. 

Finally, CBP has not determined the date when it will move to full 

enforcement of WHTI requirements at land ports of entry. Until it 

initiates full enforcement, CBP continues to not gain the full 

benefits of the WHTI program and continues to incur risk that CBP 

officers may erroneously grant admission to persons falsely 

claiming to be citizens of the U.S., Canada, Bermuda, and Mexico. 

 Potential For Substantial Increase in Secondary Inspections 

CBP provided data showing compliance rates for the first eight 

months of the informed compliance period, June 1, 2009 through 

January 31, 2010. CBP's reported compliance rates averaged 96% 

and are significantly higher at northern border ports, averaging 

98%, than at southern border locations, which are averaging 93% 

compliance. Table 1 shows the numbers of compliant and 

noncompliant travelers and associated compliance rates for land 

border ports of entry. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 5 
WHTI- WHTIBorder State 

Compliant 

Travelers 

noncompliant 

Travelers 

Total 

Travelers 

Compliance

 Rate 

New York 

Michigan 

Washington 

Maine 

Vermont 

Minnesota 

North Dakota 

Montana 

Idaho 

Alaska 

New Hampshire 

Oregon 

Subtotal Northern 

10,542,984 

7,240,330 

5,854,090 

2,624,137 

1,572,884 

928,262 

850,594 

606,156 

289,702 

79,799 

7,015 

1,522 

187,988 

150,944 

41,717 

77,302 

18,159 

36,244 

21,287 

10,787 

4,526 

2,094 

349 

12 

10,730,972 

7,391,274 

5,895,807 

2,701,439 

1,591,043 

964,506 

871,881 

616,943 

294,228 

81,893 

7,364 

1,534 

98.25% 

97.96% 

99.29% 

97.14% 

98.86% 

96.24% 

97.56% 

98.25% 

98.46% 

97.44% 

95.26% 

99.22% 

States 30,597,475 551,409 31,148,884 98.23% 

Texas 

California 

Arizona 

New Mexico 

Subtotal Southern 

11,675,852 

10,068,907 

2,537,494 

119,880 

1,116,780 

499,572 

170,917 

10,805 

12,792,632 

10,568,479 

2,708,411 

130,685 

91.27% 

95.27% 

93.69% 

91.73% 

States 

Total 

24,402,133 

54,999,608 

1,798,074 

2,349,483 

26,200,207 

57,349,091 

93.14% 

95.90% 

Table 1: WHTI Compliance by State During the Informed 

Compliance Period - June 1, 2009 to January 31, 2010 

Despite the high compliance rates, the number of WHTInoncompliant travelers may represent a significant increase in 

secondary workload at some ports when CBP moves to full 

enforcement. During the first eight-months of the informed 

compliance period, 2.3 million travelers were deemed WHTInoncompliant, a potential 3.6 million noncompliant travelers 

annually. Almost half, or 1.1 million, of these WHTInoncompliant travelers arrived at ports in the state of Texas. This 

equates to potentially 1.7 million noncompliant travelers annually 

that may be sent to secondary inspection under full WHTI 

enforcement at Texas ports of entry. 

For example, the Port of El Paso referred 117,124 travelers to 

secondary during the initial eight-month informed compliance 

period. If CBP had been fully enforcing WHTI during this period, 

it may have referred an additional 146,769 WHTI-noncompliant 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 6 
travelers to secondary. This number equates to a 125% increase in 

secondary inspection workload at that port. 

According to an Office of Field Operations official, CBP’s efforts 

to enforce WHTI are hindered because the implementing law, 

IRTPA, lacks an enforcement provision, such as a monetary 

penalty for noncompliance. As a result, CBP says that the only 

action it can take to fully enforce WHTI at land ports of entry is to 

refer WHTI-noncompliant travelers for a secondary inspection, 

thereby delaying their admittance to the U.S. 

The goal of informed compliance is to encourage travelers to 

comply with WHTI. Through this policy, CBP aims to achieve a 

higher rate of compliance over time. However, data from the 

initial eight-month informed compliance period shows compliance 

rates have not improved since the second month, and in some cases 

have decreased for some states. For example, land border ports of 

entry in Arizona reportedly increased from approximately 91.8% 

in June 2009 to 94.1% in July 2009 and were 94% in January 

2010. Exhibit 1 shows how compliance rates generally increased 

from the first to second month of informed compliance and have 

fluctuated very little during subsequent months in six northern and 

southern border crossing states. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 7 
Exhibit 1: Compliance Rates at Select Border Crossing States 

Top 3 Northern and Southern State Border Crossings 

88% 

89% 

90% 

91% 

92% 

93% 

94% 

95% 

96% 

97% 

98% 

99% 

100% 

June '09 July '09 August '09 September '09 October '09 November '09 December '09 January '10 

Month 

WHTI-Compliant Travelers 

Texas California Arizona New York Washington Michigan 

According to an Office of Field Operations official, CBP’s strategy 

for implementing WHTI land is similar to the manner it 

implemented WHTI in the air environment. Specifically, CBP 

implemented WHTI air in two phases designated as "informed 

compliance" and "full enforcement." The informed compliance 

phase of WHTI air lasted from January 23, 2007 to February 18, 

2008, a period of 13 months. CBP believes that it should operate 

informed compliance at land border ports of entry a similar amount 

of time before transitioning WHTI land from informed compliance 

to full enforcement. CBP has been operating informed compliance 

at land ports of entry for 13 months as of July 2010, but does not 

yet have an announced date to move to full enforcement of WHTI 

requirements. 

Impact of WHTI-Noncompliance on Ports 

CBP has not analyzed the impact the potential substantial increase 

in secondary inspection workload will have on secondary 

inspection staffing and infrastructure. CBP has not determined 

whether the ports have sufficient resources, such as CBP officers, 

computer workstations, and parking spaces to accommodate 

WHTI-noncompliant travelers who may be referred to the 

secondary inspection areas. Our analysis determined that CBP 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 8 
may not have enough officers or infrastructure to support an 

average 73% increase in secondary workload. 

When a primary CBP officer conducts an inspection of a traveler 

and the officer determines the traveler needs additional screening, 

the traveler is directed to a secondary inspection area, usually 

located inside an administrative building at the port. The traveler 

is processed by a CBP officer at a computer workstation. The 

processing involves the CBP officer accessing various law 

enforcement databases and reviewing other documents in the 

traveler’s possession to verify their identity and citizenship. In 

addition, if the traveler is entering the U.S. in a personal vehicle, a 

designated parking space in the secondary inspection area will be 

needed. 

CBP Officers 

CBP requested and received 294 CBP officer positions in fiscal 

years 2008 and 2009 to implement WHTI at land border ports. 

CBP estimated there would be a 15% increase in secondary 

inspections due to 100% checking of all traveler documents under 

WHTI. We analyzed WHTI compliance data from the initial 

eight-month informed compliance period and determined that 

while 96% of travelers were reportedly WHTI-compliant, the 4% 

who were not would cause CBP’s secondary inspection workload 

to increase by an average of 73% at its top 39 high-volume ports. 

Accordingly, CBP may have an insufficient number of CBP 

officers at some ports to facilitate full enforcement of WHTI. 

For example, at the Port of El Paso, which encompasses four 

crossings, CBP officers referred 117,124 travelers to secondary 

during the eight-month period we reviewed. During the same 

period, El Paso processed 146,769 WHTI-noncompliant travelers. 

Thus, if CBP were fully enforcing WHTI beginning June 1, 2009, 

El Paso may have referred a total of 263,893 travelers to secondary 

during this period, an increase of 125%. The Port of El Paso 

received 8 additional CBP officer positions to accomplish the 

anticipated increase in inspections due to full enforcement of 

WHTI requirements. Table 2 summarizes the percentage increases 

in secondary inspection workload at CBP’s 39 highest-volume land 

ports of entry. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 9 
Port Total 

Referrals 

WHTInoncompliant 

Travelers 

Projected 

Referrals 

Under Full 

Enforcement 

Percentage 

Increase 

Blaine, WA 125,965 21,027 146,992 16.69% 

Buffalo, NY 278,053 108,648 386,701 39.07% 

El Paso, TX 117,124 146,769 263,893 125.31% 

Brownsville, TX 185,750 245,370 431,120 132.10% 

Calexico/East, 

CA 

90,842 77,720 168,562 85.56% 

Calexico/West, 

CA 

148,916 136,496 285,412 91.66% 

Detroit, MI 226,917 111,044 337,961 48.94% 

Douglas, AZ 

Eagle Pass, TX 

Hidalgo, TX 

Laredo, TX 

78,484 

96,918 

112,071 

204,691 

47,035 

186,765 

126,099 

220,042 

125,519 

283,683 

238,170 

424,733 

59.93% 

192.70% 

112.52% 

107.50% 

Nogales, AZ 

Otay Mesa 

San Ysidro, CA 

81,397 

158,743 

282,094 

43,054 

78,167 

167,285 

124,451 

236,910 

449,379 

52.89% 

49.24% 

59.30% 

25 Remaining 

High-Volume 

Ports 

780,222 437,035 1,217,257 56.01% 

Total 2,968,187 2,152,556 5,120,743 72.52% 

Table 2: Calculated Increase in Secondary Workload at 39 

High-Volume Ports Based on June 2009 to January 2010 Data 

Physical Infrastructure 

CBP’s budgetary justifications for WHTI indicates that CBP 

requested and received $365 million in funding in fiscal years 2008 

($225) and 2009 ($140) to implement WHTI at land ports of entry; 

however, no funds were obtained to increase the capacity of 

secondary inspection areas where the WHTI-noncompliant 

travelers would be sent for verification of identity and citizenship. 

An Office of Field Operations official confirmed that CBP did not 

request or receive funds to increase the capacity of its secondary 

inspection. Thus, ports would be expected to handle any increase 

in secondary inspection workload related to WHTI with existing 

infrastructure, including the current number of computer 

workstations and available parking spaces in secondary inspection 

areas. Our analysis indicated some ports may not be able to handle 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 10 
 

 

 

the increased secondary inspection volume under full enforcement 

of WHTI. 

For example, San Ysidro, the busiest land border crossing in the 

U.S., has 8 computer workstations to process secondary referrals 

and 37 parking spaces for vehicles in its secondary processing 

area. During the first eight months (245 days) of the informed 

compliance period, officers referred 282,094 travelers to secondary 

or 1,151 per day. San Ysidro also processed 167,285 WHTInoncompliant travelers during this same period. Under full 

enforcement of WHTI, the port may have had to refer an additional 

683 travelers per day to secondary. Thus, San Ysidro may need to 

process a total of 1,834 referrals in secondary per day on 8 

computer workstations when CBP fully enforces WHTI. 

Processing this number of travelers with these few computer 

workstations may cause considerable traveler delays in the port’s 

secondary processing area. 

In addition, using historical crossing data for the port, we estimated 

that during the first eight months of the informed compliance 

period, 537 vehicles per day needed parking in the secondary 

inspections area.2 During this same eight month period, parking 

for an additional 319 vehicles per day would have been needed for 

WHTI non-compliant travelers. Thus, under full enforcement, San 

Ysidro would need a parking area to handle 856 cars per day. 

Because the port only has 37 parking spaces in the secondary 

inspection area, parking 856 vehicles per day under full 

enforcement would present a challenge. 

CBP was unable to provide a reason why it did not determine the 

impact that full enforcement of WHTI would have on its secondary 

inspection operations. CBP officials at the ports we visited said 

that their ability to handle any increase in secondary workload will 

ultimately depend on the specific requirements the Office of Field 

Operations places on the ports for conducting secondary 

inspections of WHTI-noncompliant travelers. 

According to CBP data, 241,235 of the 282,094 (85%) travelers referred to secondary inspection at San 

Ysidro arrived in personal vehicles. Based on the historical crossing data, we estimated these travelers 

arrived in 131,637 vehicles or 537 per day (131,637/245). 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 11 

2 
CBP Procedures for Processing WHTI-noncompliant Travelers 

Have Not Been Completed 

CBP has not finalized the procedures that its officers will use to 

process WHTI-noncompliant travelers under full enforcement. 

The Director, WHTI Program Management Office, said the agency 

has begun drafting the procedures for moving the program to full 

enforcement; however, other priorities have precluded CBP 

management from giving final approval to the draft policy and 

procedures. 

The Director, WHTI Program Management Office, said that high 

compliance rates during the initial compliance period do not 

warrant moving to full enforcement at this time. CBP also believes 

it is easier to encourage compliance than to enforce it at this point 

in time. CBP said its primary goal is to continue to encourage and 

promote compliance. 

CBP’s May 14, 2009 operational guidance for the informed 

compliance period does not provide CBP officers with minimum 

inspection requirements and detailed steps they should perform to 

verify the identity and citizenship of WHTI-noncompliant travelers 

during secondary inspection. Failure to include minimum 

requirements in the operating procedures on how CBP officers 

should process these travelers leaves the opportunity for 

inconsistent processing and ultimately increases the risk that 

someone could enter the U.S. under false pretense of citizenship. 

Recommendations 

We recommend the Assistant Commissioner, Office of Field 

Operations: 

Recommendation 1: Determine the impact that full enforcement 

of WHTI document requirements will have on the number of 

travelers referred to secondary inspection, and the impact of the 

referrals on land ports of entry staffing and infrastructure needs. 

Recommendation 2: Develop a strategy to facilitate the 

inspection of WHTI-noncompliant travelers for those ports whose 

current staffing levels and infrastructure make it operationally 

unfeasible to process all WHTI-noncompliant travelers. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 12 
Recommendation 3: Finalize and issue WHTI full enforcement 

operational guidance that includes minimum inspection 

requirements and the specific procedures that CBP officers must 

follow to process WHTI-noncompliant travelers and to establish 

their identity and citizenship. 

Recommendation 4: Establish a firm target date for moving from 

informed compliance to full enforcement of WHTI land document 

requirements. 

Management Comments and OIG Analysis 

In its official comments, CBP indicated the OIG proposed to 

automatically refer all WHTI-noncompliant travelers to secondary 

inspection. While the OIG discussed this issue with CBP during 

the audit, the draft report did not propose this procedure. The 

report states that based on data from the first eight-months of the 

informed compliance phase, there was a potential for substantial 

increase in secondary inspection workload at some ports. Further, 

CBP had not analyzed the impact this potential increase would 

have on secondary inspection staffing and infrastructure. Thus, we 

recommended that CBP conduct an analysis of the impact that the 

WHTI document requirement would have on the number of 

travelers referred to secondary, and that CBP develop a strategy to 

facilitate the inspection of WHTI-noncompliant travelers for those 

ports whose current staffing levels and infrastructure make it 

operationally unfeasible to process all WHTI-noncompliant 

travelers at secondary inspection. 

Prior to receiving CBP’s official comments, it requested the OIG 

consider modifying recommendation Number 2. Specifically, CBP 

expressed concerns that secondary inspection areas may not be the 

most effective law enforcement option and would likely 

compromise its ability to focus on noncompliant travelers of high 

interest to law enforcement. The intent of our recommendation is 

to ensure that CBP develops a strategy to facilitate the inspection 

of WHTI-noncompliant travelers other than at its primary 

inspection points, particularly where current port staffing and 

infrastructure render it operationally unfeasible to refer to a 

secondary inspection. Based on CBP’s proposed action, we 

removed the word “secondary” from the recommendation. 

CBP concurs with all four recommendations. Our summary and 

analysis of CBP’s official response follows. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 13 
Management Response on Recommendation # 1 

CBP concurred: CBP said a preliminary analysis of WHTInoncompliant traveler impact on secondary referrals at two border 

locations indicates that a policy of referring all noncompliant 

travelers to secondary would not be operationally feasible or 

desirable at busy land border ports of entry with a constrained 

physical infrastructure. 

OIG Analysis: We consider the proposed action to be responsive 

to the recommendation. However, this recommendation will 

remain open and unresolved until we receive a corrective action 

plan and the secondary operations impact analysis at the Detroit 

and Laredo ports of entry has been evaluated by the OIG. 

Management Response on Recommendation # 2 

CBP concurred: CBP said it is evaluating methods to facilitate the 

screening of WHTI-noncompliant travelers in a manner that is 

efficient and law enforcement driven. One of the future strategies 

under consideration is a “pulse and surge” enforcement strategy to 

concentrate operational efforts on noncompliant United States 

citizens. The strategy will include providing the noncompliant 

traveler with appropriate WHTI document applications and 

information. CBP also continues to focus on increasing query 

rates of arriving travelers in law enforcement lookout databases, 

including national security databases, within the land border 

environment. CBP plans to complete action on this 

recommendation by May 2011. 

OIG Analysis: We consider the proposed action to be responsive 

to the recommendation. However, this recommendation will 

remain open and unresolved until we receive a corrective action 

plan and a finalized strategy for inspecting WHTI-noncompliant 

travelers. 

Management Response on Recommendation # 3 

CBP concurred: CBP said it will finalize and issue WHTI full 

enforcement operational guidance that includes minimum 

inspection requirements and the specific procedures CBP officers 

must follow to process WHTI-noncompliant travelers in both the 

primary and secondary environments. CBP plans to complete this 

action once it makes the decision to move towards full 

enforcement as determined by operational conditions. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 14 
OIG Analysis: At the Exit Conference, the Director, WHTI 

Program Management Office, indicated that her office had outlined 

the procedures. However, this official indicated the procedures 

cannot be finalized until the analysis described in 

Recommendation 1 is complete, and the procedures obtain 

corporate buy-in by CBP senior executives and possibly the 

Department. We consider this recommendation open and 

unresolved until we receive a corrective action plan with a target 

completion date for completing the WHTI land operational 

guidance. 

Management Response on Recommendation # 4 

CBP concurred: CBP said the Commissioner of CBP, in 

consultation with DHS as appropriate, will establish a firm target 

date for moving to the next enforcement phase of WHTI. The date 

will be determined by operational conditions. 

OIG Analysis: CBP implemented WHTI in the air environment in 

two phases; informed compliance and full enforcement. WHTI air 

remained in the informed compliance phase for a period of 13 

months. During this audit, a CBP official indicated the agency 

should remain in the informed compliance phase for WHTI in the 

land environment for at least a similar amount of time. In March 

2010, the official estimated October 1, 2010 to be the date when 

CBP moved to full enforcement. As of the date of this report, CBP 

has been operating WHTI land under informed compliance for 

over 18 months. We consider this recommendation open and 

unresolved until we receive a corrective action plan with a target 

completion date for moving from informed compliance to full 

enforcement of the WHTI land document requirement. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 15 
Appendix A 

Purpose, Scope, and Methodology 

The objective of our audit was to determine whether CBP is 

prepared to fully enforce WHTI at land ports. Specifically, 

we determined whether CBP developed policies and 

procedures for its officers to use to process noncompliant 

travelers, and whether the agency effectively planned to 

have sufficient resources to process noncompliant travelers 

in secondary inspection areas. 

We obtained and reviewed applicable federal laws and 

regulations including the Intelligence Reform and 

Terrorism Prevention Act of 2004, Land and Sea Final 

Rule, titled, Documents Required for Travelers Departing 

From or Arriving in the United States at Sea and Land 

Ports-of-Entry From Within the Western Hemisphere, 

Customs’ Directive 3340-040A, Primary Processing of 

Travelers and Vehicles Seeking Entry to the United States 

at Land Ports of Entry, CBP’s Inspectors Field Manual, 

and WHTI guidance memos that CBP’s Office of Field 

operations issued to the field. 

We interviewed CBP personnel from the Office of Field 

Operations, including staff from the WHTI Program 

Management Office and staff from CBP’s Office of 

Information Technology. We visited five ports of entry 

with a total of 11 crossings points: San Ysidro, CA, Tecate, 

CA, Otay Mesa, CA, El Paso, TX and Buffalo, New York. 

At each location, we interviewed port management 

officials, observed and interviewed CBP officers 

processing incoming travelers through the primary and 

secondary vehicle and pedestrian lanes. At the vehicle 

primary inspection booths, we observed the performance of 

the RFID technology and VPC software and obtained 

feedback from CBP officers on how the technology 

performed. 

To calculate the percentage increase in secondary workload 

that would result at CBP’s top 39 ports if they referred all 

WHTI-noncompliant travelers to secondary inspection 

areas, we obtained and reviewed WHTI compliance and 

port referral data for the period June 1, 2009 through 

January 31, 2010. We did not verify the reliability of this 

data. We added the WHTI-noncompliant travelers to the 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative 

at Land Ports of Entry 

Page 16 
Appendix A 

Purpose, Scope, and Methodology 

secondary referrals. This total would represent the number 

of referrals that CBP would have processed if CBP was 

fully enforcing the WHTI document requirement. We then 

calculated the percentage increase in workload. 

To determine the port’s infrastructure was capable of supporting a 

significant increase in secondary workload, we analyzed WHTInoncompliant traveler data, and compared it with the number of 

available secondary workstations and parking spaces in the 

secondary inspection area. We observed port operations, the 

physical layout of the secondary areas, and interviewed port 

officials at the five ports we visited. Finally, we asked an official 

from the Office of Field Operations whether CBP requested or 

received any funding to increase the infrastructure capacity of port 

secondary inspection areas for WHTI-noncompliant referrals. 

We conducted this performance audit according to 

generally accepted government auditing standards. Those 

standards require that we plan, evaluate internal controls 

and assess risk, and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our 

audit findings and conclusions based on our audit 

objectives. We believe the evidence obtained provides a 

reasonable basis for our findings based on our audit 

objectives. We conducted our performance audit between 

July 2009 and April 2010 under the authority of the 

Inspector General Act of 1978, as amended. 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 17 
'100 _,m.u.__ 'lW

w•.I:wl,.,... DC lOU_

US. Customs ;md

BonIer Protect101l

Oo,~b.. U, 2010

\lI\IOR,\NDUM FOR RICIIARD I, SKf>.<NER

INSI'ECTOR GENERAl

DEPAKTMS'-'TOf HOMEl.AND SFCURITY

fRO"'" Assi""'" Commi..ioncr. Off><c oflnt.",al Affaits ~:F. u.s. C""""", .00 Bordcr Prnl«'oon IJ' -

SL:UJEcT, Res"""", to til< Ollk. of In,p<<:''''' n<nrntl', Dr1J.fi R<J>ClI1

En'itled, "Cu"oms and Bot<l<:' l'rot... ~",', hnrlo"",ntat;"n

of ,It< Wo""", Horni'!'h<'" Tra' cI In'li,,,"o "' [-"nJ Po<IS ~f1:ntry"

Il>anl you f"" ,be Ol'JIO,uUli'} '0 ",,,icw ond rom"",n' "" tb< dnI11. ",pononti'lOO,

-CUSlom, and l!<>rlkr Prote<l""'" Imrlomenu'ion of ,be I\'..10m Homisp/><rr Trm,,1

Ini,i.Ii,·. 01 Land Ports "fLntt},-

The OOioo of lnsp«toI' Gc:n<nd', (DIG) rrl"'" ".'n 'hal U.S, Customs and Bonk;

Pro'",'i"" {CUP) i, "'" rrrpam:110 fully enfo<oc tb< W<'!I\Om Homi.ph<n: T""'d

Inrti.,i"o (l\'llTl) do'''''''<ot ""Iui",m""t 01 ,he land l'<"'U of.n'ry. Tho DIG ""'osthot

tho number of ,,,,,01... who do not hO\'. WHTI-oomplian' <loc"",.nlS oould ,ncroase

CBP's ,,""kIOl>d in .o."",da,y' rnsp«t"'" III mOlly ofCBp', high volwn<: land port,. Clll'

has >I"'ed 1o the DIG on '''''''''al <>«&>ions thoI, in CBp', opera,ional and 13",

enfo'=' iud"""enl. "full ""for<<m<n'" IIhouId ""'.00 ",illl>01,,,,,11>d< I =Iur""""'"

'0 rrfer .11 WHTI_oonromplian' "a,,,~, to _on<br) Ref"",,1 tn secondary i, not

:alway. "",,"ssary, d<..",blc. '" ,he mool <llki.nt m•.." of """bl;",rn~ ,d<nt"y or<I

oi""""""r "r ",;n~ law enr""",m..,' r",,,,,,O<:<. COI\~ '0 lhe 010', eh''''''''''''''ion.

:alllnl"elcrs muS! ..'i,f}, and wilt conhnLM: to 113"0 '0 ..,,,fl. the: i"'pot'ing offica of

Ihcir rd<n,,'Y. <i'i,,,n;hrp, ond IIdmi"ibihlY pri'" '0 odmi..ion '0 the: Uni,ro Statcs. In

tile o"cn, tha, a I",...la do<:' TlO1 p"'.... a WllTl-compliant <locLIn><Yl'. "'" in'l""ting

offlCo' will u.. all ",,,,iloblo <locwnallary and 'y·,"'rn infom"'-ti"" "" \loll as oral

qoc.,ionin~ and ;,,'p«:tion l«hnlq"", '0 establish id<nritl and <;'iz......ip.

n..,.".... .1", ".1.. thor un,a ,II< full enfo"-'<m<n, ~>=S or< r",ali_ on<!. r.rm

tarllel date is "". (;Up eonlln"", 10 "'" lI"in the full bcrrcr... ofthe: WIlT!

......

_tam, Thi,

JWert"'" 00<s "'" nrP"'" to be groun<k<l in "", <I data Of DIG .ud;, h•. ond CBp

Appendix B 

Management Comments to the Draft Report 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative 

at Land Ports of Entry 

Page 18 
"a"k<, ioclooin~ th<: llOTlCOmplian, If" ole•. i' q""riod >gainnl.", ...fom:mtn( look""t

datablosos inchJdin~ n.1tional """u:ri,~ d.tabio= opon ani,'oJ

l=ly. 'll< "'J'O'I """'''' ,hat C1W <'"",,,,,,,, l<> incur risk tha' CHP omoon may

e"""""o,I)' 11.'""1'1 admi..i'>TI '0 pcr>Ons falsely daimin~ to be "ti",n. of"'" U.s.,

Canada, and Bermuda, A' ..p1air>e<! obo>< and 00 ",p,,,tcd <><us",." to the OIG.

,..,de" arc ncva adrn"'od omil identity. <ili",..hip and odmi..ihilit) on: establi'hed l<>

'00 ""i.faction ofthe ,mpc«m& om,..... CUP tw. Impl<mml<d \\ liT!. and planned for

too "",,"ngeocy of WHTI.noncompli.n( (ra,el"", m a m,",net tha' "'ill RllIk. lbe bo«kr

nlOre sec",..,. Mor"""". OIG """"<<led du:rin~!he bil Confere""e 'hall" auditor> ncv....-

ob"""od a WIITI'non«>mplian, indi"idLml l><i"S adrnillod '0 tile lIM<d Slate> in 0

manntT lha, p<>std ala" enfor<emen' 0' ,.rrori.. ,hre3t, ond tha' thei' ",,,,,,rt;oo of a

po'.n'ial vulnerabililY i' based <"t""I)' 0" h}'potllctical "",oari.... CHP al"" .xpl.,nc<J 10

the OIG thaI OIG's pro!"'''''1 '0 au'.......t"'ally refe' oJl WIlTT.noneomplian' "",..k" to

=onda<)' i"'podio" w'....ld i"dfre<l""e the I." ""for<emen' reoouroes ovoilable to

foo.. on th<»e 'n,olen tha' pooe ,he higl><Sl I.w ""r"",""",,,t mk and ,,,,,,,,by n:d"""

>«OJ·ity" tbe bo«I<r.

I'[e.se se< nil", n:,pomes '0 OIG', =ommenda.ioru belo""

IIt<omm<nda tHl" .1

Detcrm'n< 'll< impae' that foil enforc<:mem of WI lTI docoment r"'lu,remtnt' "ill ha"e

on 'he nomber of'''1\"01<", n:ferml to """'ndary i"""",tion. and tile impa<1 oftile

,.rerral, on lond pons of en'ry ...ffmg and mfTaSt""'o", r.ecd..

em' !'Io>r~'''><: Con<u.: CHP is O\"lll.."ns mell><>o:b to rocil"..e !be .,,,ocnin~ of

\\'ll r1-nonwmplian' lra"el"", In n'her than tl>o ...ondary environmen', ,,'he:n:

8110 "hen il;" "fficient and I." enfor<em<1lt dn'·cn. CHI' ",II perform n secondary

OJ!<'l'tions 'nlpa<' anal)"i. fOf Detroit on<! Laredo 'l""ir.caJly. 11K:>< 10<111;"", tq>re:<Cnt

no"""", and ""uthem horde. Io<otio.... Detroi' has n constrnincd oco<>ndary

inf""t""'u... ond l.aredo has Ie.. ,han oplimal wmplinnoo rat"'. n.e Soal of,h.

e""Wltion will be to on:lI) '" tl>o impact ofimplementinll a <1andard operati"l! proeodure

"oder "hich all WIITI-tI011COIl1plianl indi'idoal' ,",,,old be n:forn:d 10 =<>nda,y,

P"'liminary onal)<i' indicated tha, <llCh 0 policy ,",ould nut be ul"'rnliunall)' f<a<ibl< Of

d..irahlc at bu.y'0 land 1"",10, ports of.nlry "ith • oon>t..incd rh)'sical infTllSlJllo:'ure.

Sinee referml seeondary i. not alw.y. noerS>ar)' to ."ablish iden'i')' and citizonship.

""'i~ protoooob tha' wen: ,mplemen1ed for 1,1:11"11 <nfur<:cment in the air en"ironment

would nero 10 be modif'ed and .peeifi••II) "ilore<! fut too land en"ironment Due Date'

Fobfuary 2011

!'I.,bod [{<rummend.tln" 10. ag....d by 01G on 10113110: De,..lopa strat.gy to

f..ili"'t. the in<p«;"on or WHTI.nonoomphant 'ra,..ler, fOf 'ho"" pon, "h<»e current

''''ffioS lc,.d. ard inf"",'",,'ure make it ol"'",'io,..lIy unfc",lble to pmec.. "II WIlTl·

oonoOnlpliant t"" ..len.

Appendix B 

Management Comments to the Draft Report 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 19 
CUI' It<>p"n.., Cn-.o.... ilh I(,,'hod It«"n,nlonda,ion l.ongoogo: CliP is e,..lllat'"a

"":lhoJ, 10 f"<it,,..,. the .,"..,,,n,nll of WllTl_non«>mpli..,,' f","", '..vele,.. in 'he m.:lIII"oO' """ i,

effioient and I.,,· .nf"",.mcn' drt...... One oflhe .,..cegi., ulld... oo""idemti"" i.

to <:mploy • WllTt "put.. and <mg." ""fore."""" ''''''I!.v---.,simil..- to ou'bound

oper.otio", and d;m:ted by 1"".1 porl managemcnl----(o coneOn'ro,o OflCI'8Iion.1 otTon, on

the: ooncomphlUlt Uni,cd S..."" e,tizc", (USC). and p'""ide the """"""'phlUl' trov<l<r

nilb "!'P"'pri..t. ",'!fTI <locum"", .l'I'lk.tio"" ..... information. In odd't'on. CDP

contin""" 10 foc .. 00' Itmi,cd .nfo",.",.nt resources "'" incn:o,inll query ro'" ";th,n the

I..... border CTIvironme.', as ,I><: I,,,· e.,f"",....", bcnc:r.l i, olear "hen ooml"""J to the

second3ry rcti:mll of on otherwise I.gitimate USC " .....1... "ho i, LIO'nformed. fOTj;otful

or ImpoHri<hcd. Secondar)' "ill "'" he the ""I~' ""'. In "hioh to io"",,' WIlT!·

.I' """,,ompl,...... ..., ,,,,, .1..... OS ""nw mo~ he odm;1tcd "n.,. the primar; ,t1Spn<t'oo or"vc pm«'•.

In oddilloo. (;IW woold liko 10 d3li1'Y that all Wlff!-nono<>mphanl1r.""lon ore

f'1'{'''',,''cd- by COP and ,hen: "" .'",wnS1llnCe> lblI,lJIllk. ,t -ope",uoo.o.Ily

,,,,f,,,,,ihl.·· In .1" '" T".....I<><. ·N ~m;t1m "or;! ;<10"",),...il,·,....,.h,p nM

adm,»-ibihty IU'O .tTcc",'.I~· CSlahh>hed. Th'. c.n he 00"" in .i,he, ,he prima,)' 0'

sccoOOary .nvi",""",nt, wh,oh.....r i. determined '0 be the JTl(JSI otT«t;'. >tid .1Tkient

envlJonm.nL ,\n~' tro"der 'hot warrunlS oddltional q""SllOnma or "'re<n,"~ IS referred 10

~-

It«ommond.'i"n 3: Final,,,,, and issue WHTI full .nfo",,,,,,ent """",'ienal aui<bn<:.

thaI i""lude. minimum in'pn<'ion ""luiremen'" .lId ,he """ifio procedure. ,hoi. CRP

"moe.-. mUOl follow '''~" W1lTl.noncomplionl """.Ie",.

CIlI' "o,pon,o, C"ntur: CIlP "ill r.nali><: and j,,,,,,, opernuoo.o.l guidanc< tho, 'pecific.

procedure, for Cilp om."", 10 follow when ....bli5!>ing identj'l' olld .i"",,,,hll' of

Wlnl-""""ompliant Irn'·cI.... in both the primary and se<on<I.,} en'·lronmt.,IS, as

de'ermined by openuional oolld;tiOO$ "hen ,he deci,,,,,, is made by CDI' l<> mO"e

lo"",do full enfo",emeo'. Due Doto IJecermi""J by opernl'onal wllditions ...-hen the

deci,ion;" made h} CBP 10 movc IO.....ar<b full enf"",c""",'.

ll.commendOl;.n 4: Eswbli.h • firm ""ge' date for mo, ing from inf""""d romp""""o

10 full ""forc.me." of WHlIl;od documen' requirem.n".

CIlI' R"'l"'n,e: Concnr: n.. Commi..ione, ofCliP. in consohation "'ilb DHS ••

appropn.t•. will e.'>blish. firm "'1'lle1 dat. for m",,"~ wthe n",t enforc......nt ph.ue of

WlffI. Ou< o.le: I).term",cd by opero'ioo.o.l oondi,iono.

Appendix B 

Management Comments to the Draft Report 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative

 at Land Ports of Entry 

Page 20 
Appendix C 

Major Contributors to This Report 

Alexander Best, Director 

Robert Ferrara, Audit Manager 

Robert Edwards, Auditor 

Tia Jackson, Program Analyst 

Amanda Beisel, Program Analyst 

Victoria Phan, Program Analyst 

Katrina Holmes, Program Analyst 

Lindsey Cabral, Independent Referencer 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative 

at Land Ports of Entry 

Page 21 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

United States Customs and Border Protection 

Commissioner 

OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Customs and Border Protection Implementation of the Western Hemisphere Travel Initiative 

at Land Ports of Entry 

Page 22 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.