DEPARTMENT OF HOMELAND SECURITY

Offi ce of Inspector General

Offi ce of Inspections, Evaluations, 

& Special Reviews

A Review of the Secure Electronic Network 

for Travelers Rapid Inspection Program

OIG-04-14 April 2004

Notice: The Department of Homeland Security, Offi ce of Counsel to the Inspector General, 

has reviewed this report and excised information according to the Freedom of Information 

Act, 5 U.S.C. Section 552, as amended. 

Offi ce of Inspector General

U.S. Department of Homeland Security

Washington, DC 20528

Preface

The Department of Homeland Security (DHS) Offi ce of Inspector General (OIG) was established 

by the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of audit, inspection, investigative, and special reports 

prepared by the OIG as part of its DHS oversight responsibility to identify and prevent fraud, 

waste, abuse, and mismanagement.

This report assesses the strengths and weaknesses of the program or operation under review. It 

is based on interviews with employees and offi cials of relevant agencies and institutions, direct 

observations, and a review of applicable documents.

The recommendations herein, if any, have been developed to the best knowledge available to the 

OIG, and have been discussed in draft with those responsible for implementation. It is my hope 

that this report will result in more effective, effi cient, and economical operations. I express my 

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

 Clark Kent Ervin

 Inspector General

A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 1

Contents

 Introduction ......................................................................................................................................3 

Results in Brief ................................................................................................................................3 

Background ......................................................................................................................................4 

Purpose, Scope, and Methodology ...................................................................................................8 

Finding .......................................................................................................................................... 10 

Expedited Border Crossings .................................................................................................. 10 

Low Risk Travelers ................................................................................................................ 11 

Continued Eligibility of SENTRI Enrollees ........................................................................... 20 

SENTRI Program Management and Oversight ...................................................................... 27 

Future SENTRI Expansion ..................................................................................................... 30 

Appendices

Appendix A: SENTRI Background Checks and System Queries ........................................ 33 

Appendix B: Management Comments ................................................................................. 33 

Appendix C: OIG Evaluation of Management Comments.......................................41 

Appendix D: Recommendations ........................................................................................... 48 

Appendix E: Major Contributors to this Report ................................................................... 49 

Appendix F: Report Distribution ......................................................................................... 50 

Abbreviations

AFIS – Automated Finger Print System

CBP – Customs and Border Protection

CIS – Central Index System 

CLASS – Consular Lookout and Support System
Page 2 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Contents

CSC – Computer Sciences Corporation

DACS – Deportable Alien Control System

DCL – Dedicated Commuter Lanes

DHS – Department of Homeland Security

FBI – Federal Bureau of Investigation

GES – Global Enrollment System

IBIS – Interagency Border Inspection System

INS – Immigration and Naturalization Service

NAILS – National Automated Immigration Lookout System

NCIC – National Crime Information Center

NLETS – National Law Enforcement Telecommunications System

OIG – Offi ce of Inspector General

POE – Port of Entry

PortPASS – Port Passenger Accelerated Service System

SENTRI – Secure Electronic Network for Travelers Rapid Inspection

TECS – Treasury Enforcement Communications System 

USCS – United States Customs Service

US-VISIT – United States Visitor and Immigrant Status Indicator Technology

WIN/AFIS – Western Identifi cation Network/Automated Finger Print System
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 3

OIG

Department of Homeland Security

Offi ce of Inspector General

Introduction

The Secure Electronic Network for Travelers Rapid Inspection (SENTRI) 

program permits pre-enrolled travelers to enter the United States by personal 

vehicle from Mexico with minimal inspection by Customs and Border Protection 

(CBP) offi cers. Such reduced border inspection facilitates a more rapid entry 

into the United States. The SENTRI program is open to both United States 

citizens and non-citizens; participation is voluntary, fee based, and only for noncommercial vehicles. SENTRI is available at three southern land ports of entry 

(POE). CBP offi cers must assess the safety and security risks associated with 

travelers and their eligibility to enter the United States before the travelers are 

enrolled. CBP, within the Border and Transportation Security Directorate of the 

Department of Homeland Security (DHS), is responsible for SENTRI program 

operations. 

The OIG determined that this report contained highly sensitive information that 

must be protected from general public disclosure. Therefore, this report has been 

redacted, removing the sensitive information. 

Results in Brief

Program operations were adequate to ensure border security at all three SENTRI 

land POE. We concluded that the SENTRI program is generally accomplishing 

the two basic objectives for which it was established: to accelerate the inspection 

of pre-enrolled low-risk travelers at designated southern United States land POEs; 

and to maintain border integrity, security, and law enforcement responsibilities. 

However, certain program defi ciencies must be corrected to enhance the 

program’s overall effectiveness. Specifi cally, we have several concerns with the 

SENTRI program that involve program management and oversight at the national 

level. These concerns begin with the enrollment process and include the lack 

of uniform thresholds for criminal offenses, fi nancial solvency, and residency, 

as well as apparent inconsistencies with application approvals and denials. 

Problems exist in resolving derogatory information from the background checks, 
Page 4 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

and with the separation of CBP offi cer duties in the enrollment process. We 

noted problems with updating SENTRI system records after initial enrollment, 

documenting violations, administering penalties, establishing criteria for the 

frequency of random compliance inspections, and documenting the results of 

compliance inspections. Taken as a whole, our concerns indicate weak program 

management that could jeopardize the program’s integrity and border security. 

Moreover, a senior manager of the United States Visitor and Immigrant Status 

Indicator Technology (US-VISIT) program told us that SENTRI might play 

a cornerstone role in US-VISIT. Although SENTRI’s precise relationship to 

US-VISIT has not been settled, the data on pre-screened travelers contained in 

SENTRI will be useful to US-VISIT’s operation, and US-VISIT is scheduled 

to be implemented at the 50 busiest land POEs this year, including the POEs 

where SENTRI now operates. Consequently, some convergence between the 

two is foreseeable, and SENTRI should be strengthened in accordance with our 

recommendations for the additional reason that it may support US-VISIT.

We are recommending that CBP establish (1) minimum and objective thresholds 

for violations, arrests, and convictions to evaluate applicants; (2) establish 

procedures for resolution of hits generated by background checks; (3) establish 

minimum thresholds when determining fi nancial solvency and residence; (4) 

establish separation of duties in the enrollment process; (5) perform routine 

and timely system queries to monitor a participant’s continued eligibility; (6) 

provide a plan and schedule to achieve lookout system connectivity; (7) document 

resolution of secondary inspections and establish appropriate compliance check 

rates; (8) identify and record violations resulting in penalties; (9) develop 

performance data to evaluate and improve the program’s overall effectiveness and 

contribution to border security; and (10) fi nalize guidance and standard operating 

procedures to insure uniform program implementation.

Background

SENTRI is a land border management program that allows CBP to accelerate 

the inspection of pre-enrolled travelers at designated southern United States 

land POEs, while maintaining border integrity, security, and law enforcement 

responsibilities. The SENTRI program is open to both United States citizens and 

non-citizens. Participation is voluntary, fee based, and is only for use with noncommercial vehicles. The current enrollment period is two years.1

 

1

 On February 28, 2003, the enrollment period for the SENTRI program was extended from one to two years. 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 5

To enroll in and use the SENTRI program, applicants must demonstrate that 

they pose low risk to border security and are eligible to enter the United States 

lawfully. The program incorporates: (1) pre-enrollment of the applicant 

that includes an initial interview with CBP offi cers; (2) various agency law 

enforcement database and criminal record background checks; (3) adjudication 

of the application; (4) an inspection of the applicant’s vehicle; and, (5) a fi nal 

interview with CBP offi cers. 

The SENTRI program currently operates at three land POEs on the southern 

border: Stanton Street Bridge, El Paso, Texas; Otay Mesa, California; and San 

Ysidro, California. SENTRI enrollees use the SENTRI Dedicated Commuter 

Lanes (DCL) at these POEs to gain expedited entry into the United States. 

Currently, there are three DCLs at the Stanton Street Bridge, one at Otay Mesa, 

and two at San Ysidro. There are two Enrollment Centers, one at the Ysleta POE 

in El Paso, Texas that services the Stanton Street Bridge POE, and another in Otay 

Mesa, California, which services both the Otay Mesa and San Ysidro POEs. 

The SENTRI program involves enrollment of three components: the driver of 

the vehicle, passengers authorized to be in the vehicle, and the vehicle itself. 

Enrollees, both drivers and passengers, are issued Port Passenger Accelerated 

Service System (PortPASS) identifi cation cards, and the vehicle is issued a 

transponder that is affi xed to the windshield. Only SENTRI enrollees and preregistered vehicles may use SENTRI DCLs. 

A critical component of the SENTRI program is the Global Enrollment System 

(GES). GES is SENTRI’s computer system that contains electronic fi les for all 

enrollees. GES supports management of the SENTRI program in determining 

eligibility; processing the applicant; verifying or denying enrollment, and 

performing system administration, including updating records. Information 

contained in GES includes digitized photographs of the driver and all authorized 

passengers, their citizenship and immigration status, and vehicle identifi cation 

information.

 r crossings made by all enrollees. 

, enrollees are referred to secondary inspection to 

ensure the enrollee’s compliance with SENTRI program rules and regulations. In 

addition, offi cers may place an interdiction or “lookout” message in GES to alert 

the CBP offi cer that the vehicle or any occupant is wanted for various alleged 

violations of law or inadmissibility.

(b)(2)High (b)(2)High
Page 6 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Originally developed and implemented by Electronic Data Systems (EDS), 

Computer Sciences Corporation (CSC) is the current CBP contractor supporting 

GES. GES is a local stand-alone system at each Enrollment Center; there is 

no link or shared information through GES between the Enrollment Centers, 

other land POEs, or CBP headquarters. The integration of enrollment systems 

into a single GES is planned. CBP offi cials said the integration is planned for 

September 2004. 

GES provides information to the CBP offi cer in advance of an enrollee’s arrival at 

the inspection booth. The system automatically identifi es the driver, vehicle, and 

authorized passengers. The SENTRI inspection process consists of: (1) accessing 

enrollee information, digitized photographs of enrollees, and vehicle identifi cation 

information maintained in the GES; (2) accessing data by enrollee identifi cation 

number when the enrollee slides his/her PortPASS card through a magnetic 

stripe reader; and (3) a visual comparison, by CBP offi cers, of the vehicle and its 

passengers against GES displayed data. 

When the enrollee approaches the border in a SENTRI DCL, the radio frequency 

of the transponder queries GES. Each transponder has a unique radio signal 

that correlates to a specifi c record in GES. Once identifi ed, a signal is sent to 

GES to locate data about the vehicle and its authorized occupants. This data is 

temporarily stored for later use. As the vehicle continues through the DCL, a 

second set of sensors is activated and within seconds sends the temporarily stored 

information to the GES computer monitor in the inspection booth. The CBP 

offi cer then has all of the required information needed to validate the vehicle 

and authorized occupants. The following information is displayed on the GES 

screen: the license number and state issuing the plate; the make, model, color, 

and identifi cation number of the vehicle; and digitized pictures of the approved 

SENTRI enrollees with their names and citizenship. 

Simultaneously, automatic digital license plate readers and computers perform 

queries on the vehicle against law enforcement databases. License plate data is 

automatically available to the CBP offi cer by viewing the Treasury Enforcement 

Communication System (TECS)2

 computer that is also located in their booth. In 

addition, the offi cer may manually access TECS to perform name queries.3 This 

combination of information provides offi cers with updated data concerning the 

vehicle, driver, and any possible association with criminal activity. 

2

 CBP headquarters told us that, in the future, TECS would be referred to as the Interagency Border Inspection System (IBIS). We choose 

to use the term “TECS” throughout this report because SENTRI fi eld offi cials currently use this term at land POEs. 3

 Automatic digital license plate readers exist on all travel lanes, not just the DCLs, and are linked to TECS, not to SENTRI’s GES.
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 7

Upon reaching the booth, the driver of the vehicles stop and slide his or her 

PortPASS cards through a magnetic stripe card reader. Based on initial program 

development information, the original intent of the PortPASS card was to access 

enrollee identifi cation data when the card was passed through a magnetic stripe 

reader. However, in practice, the PortPASS card and the card reader system are 

not tied to any component of SENTRI’s GES. Once the CBP offi cer visually 

verifi es the occupants of the vehicle against the GES information and reviews 

applicable admissibility documents, the enrollee and passengers may enter the 

United States. If CBP offi cers are unable to make positive verifi cation of the 

vehicle or occupants, they may send the vehicle and its occupants to a more 

intensive, secondary inspection.4 

To monitor the continued eligibility of an enrollee, the entire SENTRI enrollment 

database is reviewed in TECS on a 24-hour basis. The purpose of this review is 

to compare enrollee names against current law enforcement databases to identify 

criminal activity or immigration violations that have occurred since enrollment. 

When the review is complete, CBP offi cers manually review the TECS reports 

and, when warranted, manually place an interdiction in the enrollee’s GES 

electronic fi le so that offi cers have this information available on the GES monitor 

in the inspection booth. By running the daily TECS review, any new adverse 

information would be immediately available to offi cers on the GES monitor in 

the inspection booth. CBP offi cers may then take appropriate actions when the 

SENTRI traveler approaches the inspection booth. 

The SENTRI program is fee based. Payment of fees may be made by credit 

card, personal check, money order, or United States currency.5

 There is a $25.00 

application fee and a $24.00 fi ngerprint fee collected at the time of the initial 

interview. Both fees are non-refundable. A fi nal system fee of $80.00 is collected 

at the time of the fi nal interview and vehicle inspection. If an enrollee wishes to 

register more than one vehicle for use in the SENTRI DCL (maximum of four 

vehicles), or an enrollee wishes to register as a passenger in more than one vehicle 

(maximum of eight persons per vehicle), an additional fee of $42.00 per vehicle 

is assessed. The two-year enrollment renewal fee is $105.00. The renewal 

process is similar to the initial application; however, renewal applications may 

be submitted by mail and an enrollee interview by CBP offi cers is not required, 

4

 During a secondary inspection, the vehicle and its occupants are directed to an area away from SENTRI DCLs and regular lanes where 

CBP offi cers may perform a more intensive questioning of the travelers, verifi cation of their admissibility documents by querying various 

databases, and an inspection of the vehicle. 

5

 The Enrollment Center at Ysleta in El Paso, Texas does not accept credit cards.
Page 8 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

unless CBP offi cials deem it necessary. If an enrollee does not renew enrollment, 

the transponder is deactivated, DCL use is not permitted, and the PortPASS and 

transponder are recovered by CBP. If a PortPASS card or vehicle transponder is 

lost, damaged, or stolen, enrollees are charged $25.00 to replace a PortPASS card 

and $42.00 to replace a vehicle transponder. 

SENTRI was fi rst implemented as a pilot program at the Otay Mesa, California 

land POE on November 1, 1995. It later became operational at the Stanton Street 

Bridge land POE in El Paso, Texas in September 1999, and at the land POE in 

San Ysidro, California during September 2000. For calendar year 2002, both San 

Ysidro and El Paso ports ranked in the top fi ve busiest United States land border 

gateways, processing approximately 29 million northbound personal vehicles 

in regular lanes and SENTRI DCLs.6

 As of December 17, 2003, there were 

approximately 66,000 enrollees in the SENTRI program; 17,509 in Texas; and, 

48,357 in California.7 The primary users of SENTRI DCLs were United States 

citizens (62 percent) and citizens of Mexico (36 percent), and the countries of 

Japan, Korea, Canada, Spain, China, the United Kingdom, Argentina, and others 

comprising the remaining 2 percent. 

Prior to the creation of DHS on March 1, 2003, the Immigration and 

Naturalization Service (INS) and the United States Customs Service (USCS), 

through a memorandum of understanding, dated August 11, 1994, shared 

responsibility for this program. Historically, INS was primarily responsible for 

program funding, while staffi ng was a shared responsibility of both services. 

Now that legacy INS and USCS components have merged into CBP, both will 

share responsibility for SENTRI program oversight, implementation, funding, and 

staffi ng. 

Purpose, Scope, and Methodology

Our review of the SENTRI program was designed to determine whether program 

protocols and eligibility criteria have been established and observed in the 

evaluation and assessment for determining an applicant’s low risk for enrollment. 

Specifi cally, we examined the processes and procedures to prevent and detect 

fraud, identify mala fi de applicants, and interdict violators. The review assessed 

6

 U.S. Department of Transportation, Bureau of Transportation Statistics, special tabulation, July 2003. Based on the following primary 

data sources: U.S. Department of Treasury, U.S. Customs Service, Offi ce of Field Operations, Operations Management Database 

(Washington, DC: 2002).

7

 Data provided by the CBP contractor, CSC, for the El Paso, Texas and Otay Mesa, California Enrollment Centers, December 17, 2003.
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 9

the integrity of the SENTRI program and evaluated whether uniform and 

consistent diligence is applied to ensure that only qualifi ed applicants are enrolled 

in and remain enrolled in the program. We analyzed the following:

 Documentation pertinent to the SENTRI program, including draft program 

guidance, a draft directive, draft standard operating procedures (dated 

August 10, 2003), policy memorandums, Federal Register notices, Internet 

websites, and various news articles.

 “Inspection of the Secure Electronic Network for Travelers’ Rapid 

Inspection,” Report Number 1-2000-019, Inspections Division, Offi ce of 

the Inspector General, United States Department of Justice, June 2000.

 Code of Federal Regulations Title 8—Aliens and Nationality, Part 103—

Powers and Duties; Availability of Records, Part 235—Inspection of 

Persons Applying for Admission, Part 286—Immigration and User Fee. 

 Land Border Ports of Entry: Vulnerabilities and Ineffi ciencies in the 

Inspections Process, General Accounting Offi ce report, GAO-03-1084R, 

August 18, 2003.

We interviewed CBP headquarters offi cials and staff at all SENTRI land POEs 

and Enrollment Centers. We conducted site visits at Otay Mesa and San Ysidro, 

California and El Paso, Texas. We also interviewed CBP’s contractor for 

SENTRI, CSC, and obtained program data contained in GES. 

At each Enrollment Center, we reviewed 300 SENTRI applicant fi les in the 

following categories: 90 approved fi rst time enrollment fi les, 90 enrollment 

renewal fi les that had been approved; 45 denied fi rst time enrollment fi les, 45 

denied enrollment renewal fi les, and 30 revocation fi les. We reviewed these fi les 

to determine content, uniformity, and consistency of documentation requested of 

applicants and reviewed by CBP offi cers to determine an applicant’s risk level and 

continued eligibility. 

Our fi eldwork was conducted from November 2003 to January 2004. The review 

was conducted under the authority of the Inspector General Act of 1978, as 

amended, and according to the Quality Standards for Inspections issued by the 

President’s Council on Integrity and Effi ciency.
Page 10 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Findings

Expedited Border Crossings 

The SENTRI program has clearly achieved one of it primary objectives–to 

accelerate the inspection of pre-enrolled low risk travelers at designated southern 

United States land POEs. Typically, the time an enrollee will spend waiting to 

cross the border in a DCL from Mexico into the United States, as compared to 

waiting times experienced by border crossers in regular lanes, is considerably 

less for three distinct and measurable reasons: enrollees have previously 

submitted pertinent information about their citizenship or immigration status and 

admissibility; their status has been verifi ed and background checks performed 

to determine a lower risk associated with the enrollees; and, CBP offi cers have 

access to this critical information at time of entry. However, to the traveler, the 

attraction of SENTRI is not the small savings of time during examination by CBP 

offi cers. The greater attraction is the access to comparably less congested traffi c 

lanes reserved for SENTRI participants, which thereby enables them to avoid the 

frequent travel delays that arise at the POEs.

Because CBP offi cers already have considerable information about SENTRI users 

before they get to the inspection booth, they do not have to spend as much time 

reviewing documents and asking questions during the inspection. CBP estimates 

the waiting time for an enrollee using SENTRI DCLs averages about 10, seconds 

as compared to a waiting time of 30 to 40 seconds in regular lanes. During our 

site visits to all SENTRI land POEs, we confi rmed the same average time savings. 

From January 1, 2003, to December 12, 2003, approximately 3.5 million vehicles 

were processed through all SENTRI DCLs.8

 To illustrate the impact of a 20-

second increase in inspection time, we calculated that CBP would need much 

more time to inspect the 3.5 million vehicles in regular lanes than it would need 

to process the same number of vehicles through SENTRI DCLs. If the same 

number of vehicles were processed through regular inspection lanes, it would take 

the approximate equivalent of 2.22 additional years to inspect these vehicles.9

 

Although other variables could affect the equation, the reduction of 2.22 years, in 

8

 Data provided by the CBP contractor, CSC, December 17, 2003.

9

 3.5 million vehicles x 20 seconds = 70,000,000 seconds = 2.22 years. 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 11

inspection time may translate into a signifi cant resource savings for CBP as well 

as a signifi cant saving of time for travelers.

Low Risk Travelers 

We have several concerns with program management practices associated with 

SENTRI applicant risk determination; specifi cally, the lack of uniform thresholds 

for criminal offenses, fi nancial solvency, and residency, as well as apparent 

inconsistencies with application approvals and denials. Also, problems exist 

in resolving derogatory information from the background checks and with the 

separation of CBP offi cer duties in the overall enrollment process. However, we 

did not identify any cases of improper enrollment in the SENTRI program and 

found that all required background checks were conducted. 

Eligibility and Pre-enrollment 

To be eligible for enrollment in SENTRI, all applicants must meet one of the 

following citizenship or immigration status qualifi cations:

 A citizen of the United States

 A lawful permanent resident of the United States

 A citizen of Mexico who is admissible into the United States as a nonimmigrant and holds a valid non-immigrant visa or border-crossing card, 

who crosses the border at a designated SENTRI DCL land POE

 A citizen of Canada and a landed immigrant who is admissible into 

the United States as a non-immigrant, and who crosses the border at a 

designated SENTRI DCL land POE

 A citizen of another country who is admissible into the United States as a 

non-immigrant or other category authorizing temporary entry to the United 

States, which may include those having received a waiver of special 

registration processing, who crosses the border at a designated SENTRI 

DCL land POE

The enrollment process begins when an applicant submits the Form I-823, 

Application - Alternative Inspection Services, to the SENTRI Enrollment 

Center in person or by mail.10 All SENTRI program applicants must submit a 

completed Form I-823 before enrollment is considered, irrespective of whether 

10 Form I-823 is also submitted at each enrollment renewal and when updating existing enrollment records, such as to report a change in 

vehicle or addition or deletion of an enrollee.
Page 12 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

they intend to use SENTRI DCLs as a driver of a vehicle or as a passenger. With 

the application, applicants must provide originals of the following applicable 

citizenship or immigration documents:

 Evidence of United States citizenship 

 A valid passport, visa, or other entry document11

 Evidence of lawful permanent residence in the United States

Applicants must further provide original documents to establish:

 Employment or fi nancial solvency 

 Residence

Some examples of documents that may be submitted to establish employment 

or fi nancial solvency are salary pay stubs, bank statements, parental support 

certifi cations, or business licenses. Residency may be established with utility 

bills, or rental or mortgage payment receipts. If an applicant is applying for 

enrollment of a vehicle, originals of the following documents must also be 

provided:

 A valid driver’s license issued by the state where residence is established

 Current vehicle registration 

 Current automobile insurance

Once an application is completed, CBP offi cers conduct an initial interview 

with the applicant to determine potential eligibility. The initial interview is an 

opportunity for the CBP offi cer to evaluate the completeness of the I-823, to 

review and verify supporting documentation, to elicit and ascertain additional 

information from the applicant, and to resolve any confl icting information. Upon 

successful completion of the initial interview, the enrollment fee of $49.00 is 

collected, an applicant’s fi ngerprints are taken,12 copies of all documents are made, 

a hard copy fi le is created, and an applicant is pre-enrolled in GES. 

If, during the initial interview, the CBP offi cer believes that false information or 

documentation has been presented, or the applicant is not eligible for participation 

in SENTRI, the offi cer confers with the Enrollment Center supervisor to initiate 

action to resolve issues or to deny the application. 

11 Even applicants from the 27 Visa Waiver countries allowed 90-day entries into the United States under the Visa Waiver Permanent 

Program Act of 2000, Public Law 106-396, must have a visa to enroll in SENTRI.

12 Minor applicants under the age of 14 are not fi ngerprinted. 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 13

During the pre-enrollment process, CBP offi cers enter biographic information into 

GES, which creates a permanent PortPASS identifi cation number that is assigned 

to the applicant. This identifi cation number is printed on the PortPASS card and 

issued to the applicant at the fi nal interview. At pre-enrollment, CBP offi cers have 

input access into GES for the following screens: Applicant Name and Date of 

Birth, Type of Application, Applicant Biographic Information, Applicant Passport/

Visa Information, and Applicant Status.

CBP has established an internal control for immigration documents to capture 

instances where an applicant’s visa or immigration status will expire within the 

two-year SENTRI enrollment period. CBP offi cers manually place a fl ag in GES 

when an immigration document expires before the initial enrollment period; in 

such cases the enrollment is authorized only for the period of admissibility into 

the country afforded the applicant. This information is automatically accessible to 

the CBP offi cer when the traveler uses the SENTRI DCL. 

Every applicant record at pre-enrollment is categorized as “pending” until all 

criminal and other background checks are completed.13 As of December 17, 2003, 

the total number of pending pre-enrollments at both Enrollment Centers was 

approximately 4,100. The majority of pre-enrollments in the pending category are 

processed within 60 days or less. 

Background Checks

CBP uses an array of background checks to identify low risk travelers and to 

confi rm other information presented by the applicant. Fingerprints taken at the 

initial interview are sent to the Federal Bureau of Investigation’s (FBI) National 

Crime Information Center and to the Western Identifi cation Network/Automated 

Finger Print System for criminal and terrorist background checks. In addition, the 

following background checks are performed for all SENTRI program applicants 

18 years or older to fi nd any possible criminal or immigration violations.14 

 Central Index System (CIS) 

 Deportable Alien Control System (DACS) 

 National Automated Immigration Lookout System (NAILS)

13 At pre-enrollment, applicants are not authorized to use SENTRI DCLs.

14 A detailed explanation of SENTRI background checks and system queries is outlined in Appendix A.
Page 14 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

 Interagency Border Inspection System (IBIS)

For applicants who are enrolling a vehicle, additional background checks are 

performed for all SENTRI program applicants 18 years or older to confi rm 

vehicle registration information, driver license records, border crossing, and 

address:

 Treasury Enforcement Communications System (TECS)

 National Law Enforcement Telecommunication System(NLETS) 

As various background checks are completed, CBP offi cers note the completion 

and results of these checks in the Applicant’s Daily Log. When all of the 

background checks are completed, the applicant’s fi le is reviewed to determine 

eligibility for the SENTRI program.

Application Adjudication 

Only CBP offi cers can make the determination to enroll an applicant into the 

SENTRI program. Enrollment in SENTRI is granted only to low risk travelers. If 

an applicant’s low risk was not demonstrated or cannot be established through the 

application procedure, the applicant is ineligible for the program. CBP offi cers 

consider several factors when evaluating applications and determining low risk. 

Applicants may not be low risk if they:

 Have provided false, misleading, or incomplete information on the 

application

 Have been convicted of a criminal offense or have pending criminal 

charges

 Have violated customs, immigration, or other federal law, or the laws of 

another country

 Are inadmissible to the United States

 Are associated with high risk groups,15 activities, or CBP cannot determine 

criminal or residence history 

 Are subject to processing at entry that requires repeated secondary 

referrals16 

15 High-risk groups may include people known by law enforcement agencies to have engaged in or been convicted of criminal violations 

of law such as alien smuggling and narcotics traffi cking. An applicant’s association with a person engaged in or convicted of criminal 

violations may be grounds for the denial of the application.

16 For example, those who are subject to additional registration requirements, such as those under the National Security Entry Exit 

Registration System, which requires visitors to the United States from specifi c countries to register upon arrival and departure.
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 15

Using the above criteria, CBP offi cers use considerable discretion in determining 

that an applicant is low risk. For example, if an applicant submits misleading 

or false information on the application or omits information, CBP offi cers are 

able to consider whether this action appears to be unintentional or results from 

a misunderstanding. In addition, CBP offi cers consider whether this corrected 

or omitted information would have been prejudicial to eligibility had it been 

included on the application. 

When an applicant admits to having a criminal history, CBP offi cers may 

consider whether it was for an arrest or a conviction. If an arrest, there may 

be consideration of the number of arrests, the nature of offenses, and when 

they occurred. If a conviction, they may consider whether it was a felony or a 

misdemeanor, the sentence imposed and served, when it occurred, whether a 

waiver of inadmissibility was granted, whether there was any form of relief or 

leniency by the court, and any evidence of rehabilitation. 

Minimum Thresholds for Adjudicating Applications 

CBP has not established thresholds for allowable violations, arrests, or 

convictions before an application must be denied. CBP offi cers use considerable 

discretion in determining an applicant’s low risk. While we agree that rigid 

standards may not be useful, CBP has not provided its offi cers with guidelines to 

assist them when reviewing applications. CBP offi cers generally understood what 

types of criminal backgrounds, i.e., narcotics or alien smuggling violations, are 

immediate causes for application denial. They were uncertain, however, about 

what type and how many minor offenses might be allowed before an application 

should be denied. For example, at one Enrollment Center, an applicant who had 

multiple immigration arrests and violations had been approved for enrollment. 

Further evidence of the discretion permitted in approving applications is revealed 

by an examination of the denial rates at both Enrollment Centers. From the 

beginning of the program at each land POE to December 17, 2003, there were 

4,122 total applications for enrollment that were denied for the reasons stated in 

the chart on the following page.17 

17 Data provided by the CBP contractor, CSC, December 17, 2003.
Page 16 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

 Denied Applications

Reasons for Denial Ysleta Enrollment 

Center El Paso, TX

Otay Mesa Enrollment 

Center, Otay Mesa CA Total

A - IBIS Hit INS 1 142 143

B - IBIS Hit Customs 3 58 61

C - IBIS Hit NCIC 13 275 288

D - IBIS Hit CLASS 1 32 33

E - Ineligible Country 0 3 3

F - Non-Business Traveler 0 13 13

G - Non-Frequent Traveler 0 110 110

H - Smuggling Customs 0 40 40

I - Smuggling INS 0 233 233

J - Others 57 2,133 2,190

K - Out of Status 0 269 269

L - Failure to Disclose 

Criminal History 3 518 521

M - Failure to Disclose 

Immigration History 1 217 218

Total Denials 79 4,043 4,122

From the beginning of the program at each Enrollment Center to December 17, 

2003, the total number of applications (80,292) made for enrollment in SENTRI 

was 19,820 at the Ysleta Enrollment Center in El Paso, Texas; and, 60,472 at the 

Otay Mesa Enrollment Center in California. Using these fi gures and the total 

denied applications, the applicant denial rate at Ysleta was approximately 0.4 

percent, versus a denial rate at Otay Mesa of approximately 6.7 percent. Also, 

we examined some of the characteristics of the populations applying at the 

two Enrollment Centers. We concluded that the two populations applying for 

enrollment at both Enrollment Centers had similar citizenship and immigration 

status. We would expect the denial rates at the two Enrollment Centers to be 

similar. Instead, the denial rate varied by more than six percent between the 

Enrollment Centers. This suggests that the two Enrollment Centers are applying 

different standards. We attribute this variance to CBP offi cials’ not clearly 

defi ning program eligibility criteria. 

Thresholds should be established to provide CBP offi cers, Enrollment Center 

supervisors, and senior port offi cials with the ability to make low risk applicant 

determination within defi nable, defensible, consistent, and measurable 

parameters. This guidance should include thresholds that defi ne denial criteria 

for the types and numbers of minor violations and offenses that may be permitted 

before an application must be denied. Establishing thresholds is important to 

ensure the integrity of the SENTRI program. Uniform application of set ..............
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 17

 standards reduces “port shopping” by mala fi de applicants and provides more 

 equitable treatment for all applicants. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 1: Provide a statement of program eligibility criteria that 

establishes a minimum and objective threshold for violations, arrests, and 

convictions to evaluate applicants seeking enrollment or an enrollment extension 

in SENTRI.

Adjudicating Background Checks

If the background checks uncover derogatory information, the CBP offi cer must 

ensure that the check has correctly identifi ed the applicant. Some “hits” prove to 

be erroneous because of similarities in names, misspellings, incorrect addresses, 

or other such reasons. The match may correctly identify the applicant, but there 

may be mitigating reasons that justify continuing the application process. In any 

case, the information must be resolved favorably for the application process to go 

forward.

Both Enrollment Centers processed background checks in a uniform and 

consistent manner and performed all appropriate system queries as outlined in 

draft program guidelines. We identifi ed, however, some discrepancies involving 

the resolution of hits received on the background checks and record keeping. 

For example, of the 88 approved fi rst time enrollment fi les we reviewed at the 

Ysleta Enrollment Center in El Paso, Texas, 10 fi les or approximately 11 percent, 

had background check printouts indicating a hit or match, but no indication of 

how the hit was favorably resolved, or even whether it was resolved. Further, 

the printouts sometimes did not contain the name of the applicant, so it was 

impossible to tell how or whether the printout pertained to the applicant. 

More complete documentation should be included in the fi les to describe how 

background check hits were adjudicated to support a favorable resolution 

adequately and to avoid the possible perception that negative information was not 

satisfactorily resolved before the application was approved. At the Otay Mesa 

Enrollment Center in California, of the 90 approved fi rst time enrollment fi les we 

reviewed, all background checks returning derogatory information were resolved 

and noted in the fi le. 
Page 18 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 2: Establish procedures for all SENTRI Enrollment Centers 

that defi ne how CBP offi cers resolve hits generated by background checks and 

how they document such resolution in the applicant fi les

Eligibility Criteria for Employment, Financial Solvency, and Residence

Eligibility criteria used by CBP offi cers to determine the employment or fi nancial 

solvency and the residency of applicants is not uniform. For example, at the 

Otay Mesa Enrollment Center, applicants must establish employment or fi nancial 

solvency by meeting a $12,000 per year income threshold for enrollment 

consideration, and provide fi nancial documents for the last three months. At 

the Ysleta Enrollment Center, however, there is no established threshold for 

employment or fi nancial solvency, and fi nancial documents are requested for only 

one month. Similarly, when determining residency, Otay Mesa applicants are 

requested to provide documentation for three months, but Ysleta applicants are 

requested to provide documentation for only one month. 

Establishing employment or fi nancial solvency and residency are critical 

elements to ensuring the integrity of the SENTRI program and border security. 

Financially insolvent applicants or applicants without a permanent residence are 

more likely to become aliens illegally residing in the United States. In addition, 

such applicants may be more likely to enter the United States to engage in 

criminal or terrorist activity. Uniform and consistent thresholds can reduce the 

opportunity to misrepresent fi nancial status and place of residence. Uniform 

employment, fi nancial solvency, and residency requirements must be established 

so that applicants for enrollment are not held to different standards by different 

Enrollment Centers. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 3: Develop a uniform minimum economic threshold to 

establish employment or fi nancial solvency, and develop a uniform timeframe 

for documents requested to establish both employment or fi nancial solvency and 

residency. 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 19

Separation of Duties in the Enrollment Process

An additional control to help ensure the integrity of the SENTRI enrollment 

process is the separation of duties between CBP offi cers performing the various 

enrollment functions. One Enrollment Center has an established business 

practice that CBP offi cers conducting initial interviews, performing background 

checks, and adjudicating applications may not render the fi nal approval for 

the same application. This separation of duties is intended to reduce the 

opportunities for fraud, abuse, and corruption. Involving more than one CBP 

offi cer in the process reduces the chance that a corrupt offi cer can improperly 

review, adjudicate, or approve an ineligible applicant for enrollment. Having 

another offi cer review the completeness of an application for fi nal enrollment 

approval also serves as an internal quality control mechanism to ensure various 

enrollment functions are properly conducted. At the other Enrollment Center, 

the same CBP offi cer is permitted to conduct the initial interview and perform 

background checks and application adjudication, as well as approve the 

application for fi nal enrollment. The CBP offi cer making the fi nal enrollment 

decision should not be the same offi cer conducting the initial applicant interview 

and performing background checks and application adjudication. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 4: Establish a policy to require the separation of duties 

to ensure that the CBP offi cer conducting an initial interview and performing 

background checks and application adjudication is not the same offi cer approving 

the application for fi nal enrollment. 

Vehicle Inspection and Final Interview

If CBP determines that an applicant is not qualifi ed for participation in SENTRI, 

the application is denied. Applicants must wait 90 days from the date of the 

denial to reapply. When CBP offi cers favorably adjudicate the application, the 

applicant is contacted for a fi nal interview. Final interviews are not scheduled 

until all background checks are completed and a decision to grant enrollment 

has been made. If the applicant is also applying for enrollment of a vehicle, the 

vehicle is inspected when the fi nal interview is conducted. At fi nal enrollment, 

CBP offi cers conduct a fi nal interview with the applicant, the vehicle is 

physically inspected, and a fi nal system fee is collected. 
Page 20 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

All vehicles must conform to the required program maximum standards, i.e., 

wheel base length 142 inches and maximum height of 75 inches and pass a 

seven-point inspection. The vehicle inspection targets the areas most often 

used for smuggling large quantities of narcotics and other contraband. CBP has 

determined these target areas through local research and post-seizure analysis 

along the southern border. When available, CBP offi cers will use K-9 narcotics 

detection dogs in the vehicle inspection process. The vehicle may be x-rayed 

if deemed necessary; however, x-ray vehicle inspection is rarely performed for 

SENTRI. 

Upon successful completion of the fi nal interview and vehicle inspection, CBP 

offi cers enroll the applicant in the SENTRI DCL program. Final enrollment 

includes:

 Providing an orientation packet to the enrollee that includes a copy of 

 SENTRI DCL rules, CBP publications “Know Before You Go” and 

 “Notice to Travelers,” DCL and Enrollment Center hours of operations, 

 and an explanation of actions that will lead to suspension or revocation of 

 SENTRI DCL privileges;

 Having the enrollee sign a form acknowledging SENTRI DCL rules were 

 explained;

 Taking a digital photograph of the enrollee, printing a SENTRI DCL 

 PortPASS card, and issuing it;

 Affi xing a radio frequency identifi cation transponder to the windshield of 

 the vehicle; and

 Verifying pre-enrollment information on the I-823 with information 

 contained in GES and updating any changes.

In addition, enrollees are told that any device or identifi cation issued in order 

to participate in the SENTRI program remains the property of the federal 

government. When the fi nal enrollment process is completed, the enrollee may 

begin using SENTRI DCLs to gain entry to the Unites States. 

Continued Eligibility of SENTRI Enrollees

We have concerns about program management practices that are intended to 

ensure that SENTRI enrollees continue to be eligible for participation in the 

program. Specifi cally, problems exist with updating SENTRI system records, 

documenting violations, administrating penalties, establishing criteria for 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 21

conducting random compliance inspections, and documenting the results of 

compliance inspections. 

Updating the Global Enrollment System

A major strength of the SENTRI enrollment process is that CBP conducts an 

array of law enforcement database and criminal record background checks prior 

to enrollment. Equally important is CBP’s ongoing monitoring of an enrollee’s 

continued eligibility to remain in the SENTRI program after initial enrollment. 

CBP must have immediate knowledge of an enrollee’s involvement in criminal 

activity, immigration violations, or other behavior that would make the 

enrollee ineligible for continued participation in the program. CBP obtains 

this information by running the entire SENTRI enrollment database from GES 

every 24 hours in TECS, which compares the names in GES with its current 

law enforcement, immigration, and terrorist information contained in TECS. 

TECS returns a report to both Enrollment Centers that identifi es matches. When 

a match occurs, an interdiction notice is entered into GES. The next time the 

enrollee enters a SENTRI DCL, the interdiction notice is displayed and the 

inspecting CBP offi cer may stop the vehicle to conduct an inquiry or refer the 

enrollee to secondary inspection, if necessary. 

While current TECS information is accessible by the CBP offi cer at the time of 

inspection, it is not displayed on the GES monitor in the inspection booth. The 

CBP offi cer must conduct a separate query in TECS to obtain that information. 

Entering the data into GES makes the information immediately accessible to the 

CBP offi cer in the inspection booth. This information not only serves to prevent 

ineligible SENTRI travelers from continuing to use the SENTRI program, but it 

also provides an additional measure of safety for the offi cers. 

The current process to update GES with TECS information is time consuming 

and labor intensive, as it is an entirely manual process. Once GES data is 

uploaded into TECS, the resulting reports must be manually reviewed, and new 

information regarding each affected enrollee has to be manually entered into 

GES. 

In addition, problems exist with the TECS report. When the enrollment 

database is run against TECS, all records since the enrollee’s initial application 

are returned, not just new information available since the last update. This 

comparison generates a very lengthy printed report. Because of the report’s 
Page 22 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Appendix 1

Purpose, Scope, and Methodology

length, CBP offi cers have diffi culty distinguishing new information from that 

which has been previously reported. If the new information is not identifi ed and 

entered into GES, there is no assurance that the inspecting CBP offi cer will obtain 

the information using the manual TECS query process available in the inspection 

booth. In addition, CBP offi cials told us that the TECS updates are not always 

current. In some situations, due to technical problems, TECS may generate a 

report without having actually run the update. CBP offi cers reviewing the TECS 

report have no way of knowing whether the update was actually conducted. 

CBP offi cials said an interim system upgrade is planned for TECS to return 

only enrollee records since the last system request for information was made. 

This upgrade is intended to reduce the length of the report and to increase the 

inspection offi cer’s ability to distinguish relevant information for manual input 

into GES. CBP offi cials said the fi elding of this upgrade is planned for July 

2004. 

The Ysleta Enrollment Center in El Paso, Texas is conducting TECS queries only 

at initial enrollment and enrollment renewal. It is not conducting any ongoing 

or routine queries to monitor an enrollee’s continued eligibility. Draft program 

guidelines stipulate that the entire enrollment database must be updated through 

TECS on a 24-hour basis. By not performing these queries daily, the integrity of 

the SENTRI program and border security is compromised. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 5: Implement policy, guidance, and procedures for routine 

and timely system queries to monitor continued eligibility of SENTRI program 

enrollees. 

Recommendation 6: Provide the OIG with a plan and schedule for achievement 

under which GES, or any successor system, will establish real time connectivity 

with TECS.

Conducting Compliance Inspections

Each SENTRI POE conducted secondary inspections through a combination 

of random computer and offi cer-generated referrals. Of the vehicles processed 

through each SENTRI DCL from January 1, 2003, to December 12, 2003, 

Stanton Street Bridge in El Paso, Texas performed percent secondary 

inspections; Otay Mesa, California performed percent; and, San Ysidro, (b)(2)High

(b)(2)High
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 23

California performed percent. Vehicles processed and secondary inspections 

conducted by land POE in SENTRI DCLs are summarized below.18 

18 GES data for SENTRI DCLs tracks secondary inspections, but does not distinguish between successful and unsuccessful inspections. Data 

provided by the CBP contractor, CSC, December 17, 2003. These fi gures cover January 1, 2003 to December 12, 2003. 19The Homeland Security Advisory System uses fi ve colors: Red=Severe, Orange=High, Yellow=Elevated, Blue=Guarded, and Green=Low, 

to alert the public an governmental organizations to the risk of terrorist activities.

Secondary Inspections in SENTRI DCLs

Port of Entry Total Vehicles 

Processed in DCLs

Total Secondary 

Inspections in DCLs

El Paso, TX 1,251,265 

Otay Mesa, CA 623,029 

San Ysidro, CA 1,600,401 

Total 3,474,695 

Each SENTRI POE used different criteria to establish the number of computer 

and manually generated random compliance inspections. For example, CBP 

fi eld offi cials told us that at the Stanton Street Bridge land POE, the computer 

generated compliance inspection rate was tied to the National Homeland Security 

Advisory System.19 

 

 In 

contrast, we were told that the frequency of e inspections in Otay 

Mesa and San Ysidro land POEs runs from percent. There was no 

indication that these percentages are tied to any alert system. 

While we do not offer an opinion about what the appropriate compliance 

inspection rate should be, we are concerned that the criteria for establishing 

the rates was so different at the POEs and was not based on any risk or threat. 

Despite what we were told at the POEs, CBP headquarters offi cials were emphatic 

that only headquarters and not the POEs set compliance inspection rates. Further, 

while the Stanton Street Bridge land POE used the National Homeland Security 

Advisory System as a guide, the “percent” and “ percent” compliance 

inspection rates were selected arbitrarily. 

Also, CBP does not document the results of secondary inspections in GES. 

No records were available in GES to describe the resolution or the outcome 

of secondary inspections, regardless of the reason the secondary referral was 

initiated. Accordingly, CBP program offi cials do not have suffi cient performance 

data to alert them to trends, actions, or violations that may have impact on the 

program’s effectiveness and security. 

(b)(2)High

(b)(2)High

(b)(2)High

(b)(2)High

(b)(2)High

(b)(2)High

(b)(2)High (b)(2)High
Page 24 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Establishing compliance inspection rates that are not based on risk, threat, or 

analysis of the results of previous compliance inspections weakens the integrity of 

the SENTRI program. Setting compliance inspection rates higher than required 

wastes valuable CBP resources and unnecessarily inconveniences the traveling 

public. Setting compliance inspection rates too low weakens the enforcement of 

SENTRI regulations and potentially compromises border security.

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 7: Establish a program to document the results of all 

secondary inspections, analyze the results, and use the analysis to establish 

appropriate compliance inspection rates. 

Recommendation 8: Establish guidance to the POEs to allow for temporary 

modifi cation of compliance inspection rates based on local threat level concerns. 

SENTRI Violations and Penalties

If an enrollee commits a violation, depending on its severity, CBP offi cers and 

supervisors may issue a verbal or written warning, a suspension for up to 90 days, 

or a permanent revocation from the program. 

Examples of violations considered minor by CBP that would warrant a written 

warning are:

 Transporting an unauthorized passenger

 Placing a transponder on an unauthorized vehicle

 Having an expired enrollment (less than 30 days)

 Not possessing a valid PortPASS card

 Traveling in an unauthorized vehicle

If subsequent violations or other minor violations of a similar nature occur, 

suspension of enrollment is considered. Examples of violations, not considered 

minor that would warrant a suspension of up to 90 days are:

 Violating any provision indicated on the I-823

 Permitting an unauthorized person to use an authorized vehicle

 Refusing or neglecting to obey any proper order of CBP offi cers or other 

 port offi cer

 Using an expired PortPASS
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 25

 A law enforcement agency requests suspension because of an ongoing 

 investigation

If an enrollee receives three suspensions, the enrollee is removed from the 

program for two years from the date of the last suspension. 

Examples of violations that warrant a permanent revocation of an enrollee’s 

participation in SENTRI are:

 Inadmissibility to the United States

 Meets one or more of the denial categories that would have resulted in 

 initial ineligibility

 Documented violation or fi ne imposed as a result of importation of . 

 controlled or restricted merchandise, including samples, or undeclared 

 monetary instruments

When a violation occurs, the CBP offi cer takes possession of the PortPASS card 

and vehicle transponder, explains the violation to the enrollee, and directs the 

enrollee to the Enrollment Center Supervisor to discuss the violation and penalty.20 

The inspecting CBP offi cer then prepares a written report of the incident that 

includes a description of the violation and a recommendation for suspension. The 

report is given to the Enrollment Center supervisor for review. 

Only the Enrollment Center supervisor approves suspensions and permanent 

revocations. The supervisor may determine that a suspension is not warranted 

and may issue a verbal or written warning to the enrollee and return the PortPASS 

card and transponder. If a suspension is approved, a letter is prepared and given 

to the enrollee, in person or by mail, stipulating the reason for suspension and 

its duration. The suspension is documented in the enrollee’s hard copy fi le and 

entered into GES. Enrollees do not have the right to appeal a suspension or 

revocation decision. 

We performed an analysis of GES revocation data for each Enrollment Center.21 

We categorized enrollees as “Other” when the reason for suspension or revocation 

was not defi ned or the fi le contained the entry “suspension – no longer in 

program.” We placed 967 enrollees in the “Other” category. 

20 If the enrollee is otherwise admissible to the United States or is a United States citizen, the enrollee is allowed to enter the Unites States. 21 The data provided to us included enrollees who elected not to renew enrollment in the program. We ommitted all enrollees from our 

analysis where there was a clear indication the enrollee did not renew enrollment. 
Page 26 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

 San Ysidro and Otay Mesa California Land POEs Revocations22

Violations Total 

Violations Fine 30 Day 60 Day 90 Day > 90 

Days

Permanent 

Revocation

Total 

Penalties

Criminal 112 0 0 0 2 0 67 69

SENTRI 167 0 3 2 45 2 42 94

Immigration 547 0 2 1 14 11 180 208

Customs 105 2 1 0 35 0 30 68

Agriculture 68 32 1 1 10 0 19 63

Other 204 0 0 0 13 0 51 64

Total 1203 34 7 4 119 13 389 566

 Stanton Street Bridge Land POE El Paso, Texas Revocations23

Violations Total 

Violations Fine 30 Day 60 Day 90 Day > 90 

Days

Permanent 

Revocation

Total 

Penalties

Criminal 23 0 0 0 0 0 23 23

SENTRI 2 0 0 0 00 2 2

Immigration 10 0 0 0 0 0 10 10

Customs 0 0 0 0 00 0 0

Agriculture 0 0 0 0 00 0 0

Other 763 0 0 0 00 0 0

Total 798 0 0 0 0 0 35 35

22 The GES revocation data, from January 2001 to December 2003, was provided to us on December 10, 2003, by the Otay Mesa 

Enrollment Center in California.

23 The GES revocation data, from September 1999 to December 2003, was provided to us on December 17, 2003, by the Ysleta Enrollment 

Center in El Paso, Texas.

Even though CBP offi cials told us there is a “zero tolerance” for enrollees’ 

violating either SENTRI DCL rules or other US regulations and laws, there was 

a signifi cant difference between the total number of violations recorded in GES 

and the total number of penalties imposed. For both Enrollment Centers there 

were 2,001 total violations recorded in GES, but only 601 penalties imposed. 

For approximately 70 percent of the reported violations, there was no GES 

record of penalties imposed. Also, the only penalties that the Ysleta Enrollment 

Center in El Paso, Texas was recording were permanent revocations. For the 

violations recorded in GES, we did not conduct a review of all enrollee fi les to 

verify whether penalties were administered. We concluded, however, that the 

Enrollment Centers were not documenting SENTRI program violations and 

penalties imposed in GES in a uniform and consistent manner. 

Furthermore, the 967 violations, or approximately 48 percent, that we placed in 

the “Other” category were not adequately described in GES. The draft program 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 27

guidelines do not address what information should be recorded in the hard copy 

or the GES electronic fi le of an enrollee concerning violations, verbal and written 

warnings, and suspensions. 

CBP’s failure to provide adequate guidance on what information should be placed 

in GES for SENTRI program violations and related penalties hamper its ability 

to monitor the program effectively. CBP program offi cials are unable to identify 

systemic problems with program enforcement and potential program weaknesses. 

In addition, without the ability to monitor program enforcement, there can be no 

assurance that SENTRI violators are appropriately penalized or removed from the 

program. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 9: Establish policies and procedures that require CBP offi cers 

to identify and record SENTRI violations and the resulting penalties imposed that 

will alert CBP offi cers to such information when accessing GES. 

SENTRI Program Management and Oversight

We have several concerns about the SENTRI program that involve program 

management and oversight at the national level. The concerns begin with the 

enrollment process and include the lack of uniform thresholds for criminal 

offenses, fi nancial solvency, and residency, as well as apparent inconsistencies 

with application approvals and denials. After initial enrollment, problems exist 

with updating GES, documenting SENTRI violations, administering penalties, 

establishing criteria for conducting random compliance inspections, and 

documenting the results of compliance inspections. These concerns may not 

be signifi cant individually, but taken as a whole, they indicate weak program 

management that could jeopardize the program’s integrity and border security. 

CBP fi eld offi cials said that they have been disappointed recently in the level of 

CBP headquarters’ direction and interest in the SENTRI program. Furthermore, 

they told us that the program has suffered because of high turnover in the program 

manager position, a lack of knowledge of program operations, and the low 

priority given to the program. 

Additionally, CBP fi eld offi cials told us that there was little communication with 

CBP headquarters. According to fi eld offi cials, there has been a lack of oversight, 
Page 28 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

guidance, and direction provided to SENTRI fi eld managers to collect, track, 

and analyze meaningful performance data for use in evaluating the program’s 

effectiveness. For example, CBP fi eld offi cials at both Enrollment Centers 

told us that their limited contact with CBP headquarters usually concerned the 

number of applications made, increases in enrollment, backlogs in processing, 

and DCL waiting times. While these are valuable performance measures, 

they represent only a portion of the data that should be collected to evaluate 

the SENTRI program. These measures are focused on the customer service 

aspects of the program and ignore the even more important law enforcement and 

border security concerns. In addition, the program currently operates with draft 

standard operating procedures and guidelines, even though the program has been 

operational at the Otay Mesa, California land POE since November 1995; at the 

Stanton Street Bridge land POE in El Paso, Texas since September 1999; and at 

the land POE in San Ysidro, California since September 2000. 

We were impressed by the capabilities of GES to record and report signifi cant 

program information. We were disappointed, however, with CBP’s not making 

full use of the capabilities of GES. Data quality problems due, in part, to lack of 

program guidance is also evident. Further, SENTRI program managers do not 

have access to GES at CBP headquarters and do not request GES reports from the 

Enrollment Centers. 

We identifi ed several examples of GES performance data that was not collected 

but that could have been used by SENTRI program managers to improve the 

program. For example, there is no performance data available to evaluate how 

the number of violations in SENTRI DCLs compares to the number of violations 

in regular lanes, or to assess why the percentage used for conducting compliance 

inspections at land POEs in SENTRI DCLs is not uniform. In addition, data is 

not maintained as to the reasons secondary inspections are conducted in SENTRI 

DCL, e.g., system compliance check, random check, or CBP offi cer referral; 

the resolution or outcome of secondary inspections is not tracked; violations of 

SENTRI rules and other violations are not consistently recorded in GES at land 

POEs; and, there is no clear breakdown for reasons why the majority of applicants 

are denied enrollment or denied enrollment renewal. With program guidance and 

oversight in the use of GES, GES reports could become a more useful tool for 

program managers to identify and resolve ineffi cient and ineffective aspects of the 

program, as well as to address law enforcement and security vulnerabilities.

Performance data also relates to how a POE manages traffi c volume. Because 

of space limitations at the POEs, SENTRI DCLs are not usually created through 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 29

new construction. Normally, a new DCL is created by the re-designation of a 

regular inspection lane to a DCL. If CBP does not properly project potential 

SENTRI traffi c volume and does not designate suffi cient DCLs, the vehicle traffi c 

in the DCLs could back up, creating waiting times as long as those in the regular 

inspection lanes. This would defeat the purpose of the SENTRI program and 

reduce SENTRI usage. Conversely, if the DCLs do not get suffi cient use, then 

resources are inappropriately taken from the regular inspection lanes, creating 

additional traffi c problems in those lanes.

There is also a need for a formal SENTRI training program for CBP offi cers 

assigned SENTRI duties. We were told that the training program at the POEs 

consisted of two to three days of on-the-job training with another CBP offi cer. 

New offi cers do not receive written SENTRI polices or procedures. The current 

SENTRI standard operating procedures were in draft, and did not always refl ect 

current program operations. Institutional knowledge of the program was not 

captured in training documents and is lost when experienced offi cers rotate out of 

SENTRI program positions. 

Enhanced program oversight by CBP is needed. The development of performance 

data is necessary and prudent to evaluate the program’s effectiveness. 

Furthermore, guidance and standard operating procedures should be fi nalized 

and a standardized training program developed to ensure uniform and consistent 

program implementation at all SENTRI POEs to minimize local variances. In 

doing so, the contributions made by the program to strengthen and secure our 

border will be better realized; at the same time, any potential vulnerabilities or 

weaknesses can be suffi ciently addressed. 

We recommend that the Commissioner of Customs and Border Protection:

Recommendation 10: Develop a program to collect, track, and analyze SENTRI 

performance data to evaluate SENTRI’s effectiveness and effi ciency.

Recommendation 11: Finalize guidance and standard operating procedures, 

which should include a standardized training program, to ensure uniform and 

consistent program implementation at all SENTRI land POEs. 
Page 30 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Future SENTRI Expansion

After the attacks of September 11, 2001, securing our border is one of the major 

priorities for DHS senior management, programs, and operations. DHS is 

addressing possible vulnerabilities through a myriad of initiatives. CBP offi cials 

told us that they intend to expand the SENTRI program from three land POEs to 

an additional four POEs. Before any expansion effort is undertaken, however, 

CBP should address recommendations made in this report, so current program and 

operational variances are not duplicated at expansion sites.

CBP offi cials told us that program expansion is projected to begin in March 2004 

and should be complete by late summer of 2004. CBP will fund the expansion 

with approximately $60 million from fi scal year 2003 appropriations that were 

redirected from the US-VISIT program. Expansion of SENTRI is planned for 

the following land POEs: San Ysidro, CA - two additional vehicle lanes and one 

pedestrian lane; Calexico, CA - one vehicle lane; Nogales, AZ - one vehicle lane; 

Ysleta crossing in El Paso, TX - two vehicle lanes; Laredo, TX - one vehicle 

lane; and Brownsville, TX - one vehicle lane. The expansion will also include 

the construction of new Enrollment Centers at Brownsville and Laredo, TX and 

Calexico, CA. 

To make the expansion of SENTRI more successful, CBP should develop 

performance data at existing locations to realize the universe of current enrollees 

fully and the market that is served by the program. This exercise would 

ensure prudent oversight of funding resources to maximize human capital and 

infrastructure development devoted to the expansion. The expansion sites 

proposed by CBP rank in the top ten land passenger gateways for incoming 

passenger vehicles from Mexico.24 But what CBP has not determined is the 

size of the potential SENTRI enrollee population. Possessing this knowledge 

would enable SENTRI program managers to budget appropriate resources for the 

expansion sites. 

For example, in calendar year 2002, approximately 20.5 million passenger 

vehicles used the San Ysidro and Otay Mesa land POEs in regular lanes and 

SENTRI DCLs. The current enrollment total at both land ports is 48,357. GES 

recorded 2,223,430 vehicles processed from January 1, 2003, to December 12, 

2003, through SENTRI DCLs. Using this data we then calculated that the average 

24 Department of Transportation, Bureau of Transportation Statistics 2002.
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 31

SENTRI enrollee makes approximately 46 border crossings through DCLs each 

year. In reality, however, some enrollees use the DCLs infrequently, while others 

use them daily. The difference in usage patterns has potential signifi cant resource 

implications. The more that is known about the enrollees’ travel patterns, the 

better CBP’s ability to perform meaningful analysis, gain an understanding of the 

population served by SENTRI, and project future growth. 

CBP offi cials said that at expansion sites, rather than using SENTRI’s existing 

technology, the use of NEXUS program photographic identifi cation or 

proximity card technology would be tested for use and applicability.25 It is our 

understanding that the major difference between the two technologies is that 

with SENTRI, the vehicle transponder activates a signal that queries GES for 

information about the vehicle and its authorized occupants, not the PortPASS 

card. With NEXUS, the proximity card activates a signal that queries GES for 

information about the enrollee.26 

There are widely differing opinions regarding the introduction of proximity 

card technology on the southern border. Some CBP fi eld and US-VISIT Offi ce 

offi cials expressed grave concerns about eliminating a key element - the vehicle 

- from the enrollment process. They contend that without the vehicle enrolled 

in the program, incidents of smuggling would likely increase. Other CBP fi eld 

offi cials, however, did not view eliminating the vehicle from the enrollment 

process as a security or law enforcement concern. However, CBP headquarters 

offi cials said the fi eld offi cials were misinformed and that there is every intention 

to continue the use of the vehicle transponder with the proximity card technology. 

With both technologies, however, GES remains the integral stand alone system 

and the entire enrollment database must be submitted to TECS for information 

to update an enrollee’s continued eligibility and low risk. Once queried, CBP 

offi cers would still need to review TECS results manually and then place an 

interdiction in the enrollee’s GES electronic fi le for it to be seen on the DCL 

monitor by the offi cers. CBP offi cials told us that they eventually intend to make 

system changes that would allow GES information to be linked at all SENTRI 

land POEs and that a direct query would be made of TECS each time an enrollee 

uses a DCL for border crossing. With these proposed changes, the SENTRI 

program operations will be greatly enhanced by providing the enrollee with an 

25 NEXUS is a CBP northern border program to expedite travel. This program streamlines border inspection for preapproved low-risk 

travelers by using a joint enrollment process and one card for expedited entry to both Canada and the United States.

26 As expansion is planned at existing SENTRI sites, proximity card technology will be tested to ensure that transponder transmission do 

not interfere with proximity card transmission signals during the changeover period.
Page 32 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

added benefi t to use multiple land border POEs, and, providing CBP offi cers 

with “real time” information concerning the continued eligibility and low risk of 

enrollees. 

While the planned expansion of SENTRI provides additional incentive for 

implementing our recommendations, the role that SENTRI may play in US-VISIT 

makes implementation imperative. US-VISIT offi cials told us that SENTRI 

would most likely be a cornerstone of the US-VISIT program, irrespective of 

whether NEXUS, SENTRI, or both technologies are applied. US-VISIT will 

provide the capability of recording the entry and exit of non-United States citizens 

into and out of the United States and will provide offi cials with information about 

persons who are in the United States in violation of the terms of their admission. 

The US-VISIT system envisions using information, coupled with biometric 

identifi ers, such as photographs and fi ngerprints, to create an electronic checkin/check-out system for people who come to the United States to work, study, or 

visit. Current US-VISIT deployment plans have focused on air POEs. US-VISIT 

offi cials have not yet developed plans for deployment of US-VISIT to land POEs, 

but one offi cial told us that SENTRI would be an integral part of US-VISIT at 

land POEs. This makes correcting the identifi ed weaknesses in the SENTRI 

program even more urgent so as not to hamper US-VISIT by these weaknesses.
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 33

Appendix A

SENTRI Background Checks and System Queries

Federal Bureau of Investigation (FBI) is sent fi ngerprints of SENTRI 

applicants. The FBI will then make internal query of numerous databases. The 

National Crime Information Center (NCIC) is an online service provided by 

the FBI to law enforcement and criminal justice agencies to record or retrieve 

information on individuals, vehicles, and property involved in or associated 

with crimes. The system objectives are to identify wanted individuals under 

investigation or of interest to CBP. The SENTRI program uses this information to 

verify criminal history or records.

Western Identifi cation Network/Automated Finger Print System (WIN/

AFIS) is a central database of arrest records and contains fi ngerprint images 

and text data from ten print fi ngerprint cards. Law enforcement personnel can 

compare fi ngerprints of apprehended individuals or latent fi ngerprints against it 

to determine identity. It allows CBP to maintain and search criminal fi ngerprint 

records. The SENTRI program uses this information to verify criminal history or 

records.

Central Index System (CIS) is a centralized text-based system that identifi es 

the location of an alien’s A-fi le. It contains information on lawful permanent 

residents, naturalized citizens, violators of immigration laws, and others. It 

includes biographical and status information about the alien, such as name, date 

of birth, alien number, country of birth, citizenship, various fi le control data, dates 

of immigration actions, and identifying numbers. It also contains selected data 

from other databases, such as NAILS and DACS, and links those databases to 

CIS. CIS is intended to be a “pointer” system that will lead to the alien’s A-fi le, 

which should contain complete information on the alien, or to other databases. 

The SENTRI program uses this information to verify the immigration status of an 

applicant.

Deportable Alien Control System (DACS) is a centralized text database and is 

used mainly to track aliens through the removal process. It contains information 

about aliens who have been detained or placed on a docket for deportation or 

exclusion. DACS includes the status or disposition of individual deportation 

cases, as well as statistical and summary data of deportation cases by type, status 

and other characteristics of the case, as well as biographical data about the alien. 

The SENTRI program uses this information to verify the immigration status of an 

applicant.

National Automated Immigration Lookout System (NAILS) is a central 

repository for all immigration lookout information and is comprised of 
Page 34 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

information supplied by automated systems within the Department of State and 

on-line entry of CBP personnel. The system objectives are to permit CBP to 

identify and access accurate information quickly on people who are not eligible 

for entry into the US. The SENTRI program uses this information to verify 

admissibility of an applicant into the United States.

Interagency Border Inspection System (IBIS) is a shared database of lookout 

and enforcement data contributed from many federal agencies, including the 

Departments of State and Agriculture. The system objectives are to identify 

and intercept persons attempting illegal entry into the United States and to 

facilitate lawful travelers and enhance border enforcement. Immigration lookout 

information is provided through the National Automated Immigration Lookout 

(NAILS) data and downloaded to IBIS nightly. It also provides access to the 

FBI’s National Crime Information Center (NCIC) and allows users to interface 

with all fi fty states via the National Law Enforcement Telecommunications 

Systems (NLETS). The SENTRI program uses this information to determine 

admissibility into the United States. 

Treasury Enforcement Communications System (TECS) stores information 

about people of interest to law enforcement agencies, so that their entry into 

the United States may be monitored or, if necessary, prevented. TECS contains 

inspection data on travelers who have entered or attempted entry into the US. 

The SENTRI program uses this system to verify information provided by the 

applicant. System queries include: SQ11 – driver’s license, SQ13 - vehicle 

information, SQPQ - license plate record of border crossing, and SQAD - address 

check. 

National Law Enforcement Telecommunication System (NLETS) is a 

computer based message switching system that links together state, local, and 

federal law enforcement agencies for the purpose of information exchange. The 

SENTRI program uses this information to verify motor vehicle and driver’s 

license data. System queries include: DQ – driver’s license and RQ - vehicle 

registration.

Consular Lookout and Support System (CLASS) is a Department of State 

name checking system for visa and passport applications. The visa database 

contains names of aliens for visa name checking, and the passport database 

contains names of United States citizens for which there is a lookout. The 

SENTRI program uses this information to verify the status of an applicant.

Appendix A

SENTRI Background Checks and System Queries
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 35

Appendix B

Management Comments

April 29, 2004

MEMORANDUM FOR CLARK KENT ERWIN

 INSPECTOR GENERAL

 DEPARTMENT OF HOMELAND SECURITY

FROM: Seth M. M. Stodder 

 Director, Offi ce of Policy and Planning 

SUBJECT: Response to the Offi ce of Inspector General Review of the Secure Electronic 

Network for Travelers Rapid Inspection Program 

Thank you for providing us with a copy of your draft report entitled “The Secure Electronic Network 

for Travelers Rapid Inspection Program (SENTRI)”, and the opportunity to discuss the issues in this 

report.

Customs and Border Protection (CBP) agrees with the Department of Homeland Security (DHS), 

Offi ce of Inspector General’s (OIG) overall observations that CBP needs to take steps to enhance the 

SENTRI program’s overall effectiveness. CBP has taken, and will continue to take, prudent steps to 

address these factors. Attached are comments specifi c to the recommendations, as well as technical 

comments that relate to statements that need to be clarifi ed prior to fi nalization of this report.

At this time CBP has not identifi ed any information that would warrant protection under the Freedom of 

Information Act and the applicable exemption. 

If you have any questions regarding this response, please have a member of your staff contact Ms. 

Cecelia Neglia at (202) 927-9369.

Attachment

Response to OIG Draft Report
Page 36 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Appendix B

Management Comments

The Secure Electronic Network for Travelers Rapid Inspection Program 

(ISP Report Number 18)

Response to Recommendations

Recommendation 1: Provide a statement of program eligibility criteria that establishes a minimum and 

objective threshold for violations, arrests and convictions to evaluate applicants seeking enrollment or an 

enrollment extension in SENTRI.

Response: In the SENTRI Directive, Offi ce of Field Operations (OFO) will address program eligibility 

criteria that establishes a minimum and objective threshold for violations, arrests and convictions to 

evaluate applicants seeking enrollment or an enrollment extension in SENTRI.

Due Date: January 1, 2005 

Recommendation 2: Establish procedures for all SENTRI Enrollment Centers that defi ne how CBP 

offi cers will resolve hits generated by background checks and how they will document such resolution in 

the applicant fi les.

Response: In the SENTRI Directive, OFO will establish procedures for all SENTRI Enrollment Centers 

that defi ne how CBP offi cers are to resolve hits generated by background checks and how they will 

document such resolution in the applicant fi les. 

Due Date: January 1, 2005 

Recommendation 3: Develop a uniform minimum economic threshold to establish employment or 

fi nancial solvency and develop a uniform timeframe for documents requested to establish employment, 

fi nancial solvency and residency. 

Response: In the SENTRI Directive, OFO will defi ne a uniform minimum economic threshold to 

establish employment or fi nancial solvency and develop a uniform timeframe for documents requested 

to establish employment, fi nancial solvency and residency.

OFO agrees to establish proof of residency for SENTRI, but does not wish to establish a fi nancial 

minimum for enrollment. Financial concerns should be addressed on a case-by--case basis.

Due Date: January 1, 2005 
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 37

Recommendation 4: Establish a policy to require the separation of duties to ensure that the CBP offi cer 

conducting an initial interview and performing background checks and application adjudication is not 

the same offi cer approving the application for fi nal enrollment. 

Response: In the SENTRI Directive OFO will establish a policy to require the separation of duties 

to ensure whenever possible that the CBP offi cer conducting an initial interview and performing 

background checks and application adjudication is not the same offi cer approving the application for 

fi nal enrollment.

OFO uses CBP offi cers, who are already assigned to the port of entry to work the enrollment centers. 

Therefore, a limited number of offi cers can be pulled from port operations to work the centers. 

Whenever possible, OFO can direct the centers to use different offi cers, but due to the enormous volume 

of applicants, it may not always be possible to use two different offi cers.

Though it is desirable to have two offi cers’ independent assessment of each applicant’s eligibility, this 

requirement places a higher standard on enrollment in SENTRI than exists for granting US visas, border 

crossing cards, or US citizenship (and other benefi ts).

Due Date: January 1, 2005 

Recommendation 5: Implement policy, guidance, and procedures for routine and timely system queries 

to monitor continued eligibility of SENTRI program enrollees. 

Response: CBP is in the process of developing a method to query each SENTRI participant at the time 

of border crossing. This will be a full person subject query, identical to queries done during secondary 

examination, and will look at all TECS records (CBP violators/terrorist watchlists/etc.) and will query 

the National Crime Information Center (NCIC) for warrants. This will be an automated query, which 

will respond to the inspector at the primary booth. 

Due Date: January 1, 2005

Recommendation 6: Provide the OIG with a plan and schedule for achievement under which Global 

Enrollment System (GES), or any successor system, will establish real time connectivity with TECS.

Response: It must be understood that “integrated” means that GES and TECS will be closely linked, but 

that there are no plans to make GES a part of TECS. With that in mind, GES 4.0, a planned upgrade to 

the current GSA used for SENTRI, will be implemented in September 2004 and will provide GES users 

with automatic query capability in TECS and in other systems such as NCIC. This query capability 

will enable a full series of queries to be performed automatically on enrollment and at any set intervals 

during the applicant’s membership. GES 4.0 will incorporate the primary subject query capability. GES 

Appendix B

Management Comments
Page 38 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

4.0 is an independent system, which will migrate from a regional series of databases to a true global 

system in September 2004.

Due Date: January 1, 2005

Recommendation 7: Establish a program to document the results of all secondary inspections, analyze 

the results, and use the analysis to establish appropriate compliance inspection rates. 

Response: Secondary results are recorded in TECS under IO04. However, a modifi cation to IO04 will 

have to be made to designate exams specifi cally for NEXUS or SENTRI. A query function to bring up 

the designated NEXUS or SENTRI exams will also have to be developed. 

OIT will have to commit personnel to develop the IO04 enhancements and OFO will have to fund the 

design and production of the enhancement. Currently, OFO has no identifi ed funding in FY 2004 or 

2005 to complete these enhancements. 

However, instructions for recording results of secondary referrals, which is standard operating 

procedure, will be repeated in the updated SENTRI directive to the fi eld offi ces. When the SENTRI 

referrals can be separated from overall port referrals, the analysis of results will have a better basis. The 

directive will include guidance for modifying compliance referral rates based on local spikes in noncompliance or national threat levels. 

Due Date: Updated Directive: January 1, 2005; new program to separate SENTRI referrals from 

others; December 31, 2006 (This is an estimated date. An actual date cannot be given until funding is 

appropriated for this enhancement.) 

Recommendation 8: Establish guidance to the POEs to allow for temporary modifi cation of compliance 

inspection rates based on local threat level concerns. 

Response: The SENTRI Directive will provide guidance for modifying compliance referrals and be 

based on local or national threat level concerns.

Due Date: January 1, 2005

Recommendation 9: Establish policies and procedures that require CBP offi cers to identify and record 

SENTRI violations and the resulting penalties imposed that will alert CBP offi cers to such information 

when accessing GES. 

Response: The problem here is to be able to compare violations in SENTRI with violations in other, 

non-SENTRI lanes. This will give a clear picture of whether the SENTRI population is truly low-risk. 

Appendix B

Management Comments
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 39

Appendix B

Management Comments

The solution to this will come at the end of FY06, assuming that GES 5.0 is funded. All violations at a 

port of entry, whether SENTRI or otherwise, are recorded in TECS. This is a CBP requirement. One of 

the plans for GES 5.0 is to establish a very close connectivity to Treasury Enforcement Communication 

System (TECS). One aspect of this connectivity is planned as the ability to track SENTRI violations in 

TECS (by identifying them in the various types of records kept in TECS), and to have GES 5.0 capable 

of ordering reports comparing the various types of violations (number/type/severity) occurring in 

SENTRI and the non-SENTRI lanes at the port.

This ability will be available in GES 5.0. In the meantime, when a SENTRI vehicle is referred to 

secondary, the applicants are queried by name in TECS. Any previous violation will show up in this 

query. The SENTRI Directive will instruct offi cers to follow this procedure for SENTRI, which is 

standard operating procedure, (until GES is available for the purpose.) 

Due Date: January 1, 2005 for Directive instructions on TECS; September 30, 2007 for new 

capabilities for GES.

Recommendation 10: Develop a program to collect, track, and analyze SENTRI performance data to 

evaluate SENTRI’s effectiveness and effi ciency. 

Response: The measurements by which to evaluate SENTRI performance will be reexamined and 

selected to evaluate effectiveness as well as effi ciency. The selected measurements will be collected 

twice yearly and the program as a whole, as well as individual sites will be evaluated. 

Due Date: January 1, 2005

Recommendation 11: Finalize guidance and standard operating procedures, which should include a 

standardized training program, to ensure uniform and consistent program implementation at all SENTRI 

land POEs. 

Response: OFO will work with OIT to develop a National training program. The training program will 

be in the form of a SENTRI User Guide available to all CBP offi cers via the CBPnet. 

OIT will have to commit personnel to develop the SENTRI User Guide and OFO will have to fund the 

design and production of the user guide. Currently, OFO has no identifi ed funding in FY 2004 or 2005 

for the design and production of the user guide. 

Due Date: December 31, 2006 
Page 40 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Technical Comments

Page 5, 2nd paragraph: “that system administration functions delete records.” It should be noted that 

enrollment records cannot be deleted and that only user access can be deleted. 

Page 5, 3rd paragraph: “that GES generates a random compliance check. The compliance check is 

generated by the validation system, not GES. GES merely stores a count of record crossings so that if a 

traveler is not inspected for 50 crossings, they will then be referred to secondary.

Page 5, 3rd paragraph: “that GES generates a random compliance check.” The compliance check is 

generated by the validation system, not GES. GES merely stores a count of record crossings so that if a 

traveler is not inspected for 50 crossings, they will then be referred to secondary.

Page 6, 1st paragraph: “that license plate readers perform queries on vehicle and occupants.” Occupant 

query is not performed, only vehicle.

Page 6, 2nd paragraph: Is incorrect. The original intent of the PortPASS card was that it be scanned so 

that the driver would be required to stop for a long enough period that the inspector could assess all 

occupants. This card swipe was later integrated into SENTRI as the trigger for opening the gate. Also, 

the PortPASS card is not used as an identity document at all. The card does allow tracking of travelers 

and vehicles along the northern border, a capability that will be implemented along the southern border 

this summer.

Appendix B

Management Comments
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 41

We evaluated CBP’s written comments and have made changes to the draft report 

where deemed appropriate. Below is a summary of CBP’s written response to the 

report’s recommendations and our analysis of their response.

Recommendations

1. Provide a statement of program eligibility criteria that establishes a 

minimum and objective threshold for violations, arrests, and convictions 

to evaluate applicants seeking enrollment or an enrollment extension in 

SENTRI.

CBP’s plan to modify the SENTRI Directive to include program eligibility criteria 

that establishes a minimum and objective threshold for violations, arrests, and 

convictions to evaluate applicants seeking enrollment or an enrollment extension 

in SENTRI is responsive to this recommendation. However, we are concerned 

that CBP does not intend to modify the SENTRI Directive until January 1, 2005. 

We believe the directive should be updated and distributed sooner. Please provide 

us with a copy of the revised SENTRI Directive by August 1, 2004. 

Recommendation 1 - Resolved - Open. 

2. Establish procedures for all SENTRI Enrollment Centers that defi ne how 

CBP offi cers resolve hits generated by background checks and how they 

document such resolution in the applicant fi les.

CBP’s plan to establish procedures, in the SENTRI Directive, for all SENTRI 

Enrollment Centers that defi ne how CBP offi cers are to resolve hits generated by 

background checks and how they will document such resolution in the applicant 

fi les is responsive to this recommendation. We are concerned, however, that 

CBP does not intend to modify the SENTRI Directive until January 1, 2005. We 

believe the directive should be updated and distributed sooner. Please provide us 

with a copy of the revised SENTRI Directive by August 1, 2004. 

Recommendation 2 - Resolved - Open. 

3. Develop a uniform minimum economic threshold to establish employment 

or fi nancial solvency, and develop a uniform timeframe for documents 

requested to establish both employment or fi nancial solvency and residency. 

Appendix C

OIG Evaluation of Management Comments
Page 42 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

CBP plans to defi ne a uniform minimum economic threshold, in the SENTRI 

Directive, to establish employment or fi nancial solvency and develop a uniform 

timeframe for documents requested to establish employment, fi nancial solvency, 

and residency. CBP agrees to establish proof of residency for SENTRI, but does 

not wish to establish a fi nancial minimum for enrollment because they believe 

fi nancial concerns should be addressed on a case-by-case basis. CBP’s plan is 

responsive to this recommendation. We are concerned, however, that CBP does 

not intend to modify the SENTRI Directive until January 1, 2005. We believe the 

directive should be updated and distributed sooner. Please provide us with a copy 

of the revised SENTRI Directive by August 1, 2004. 

Recommendation 3 - Resolved - Open. 

4. Establish a policy to require the separation of duties to ensure that the 

CBP offi cer conducting an initial interview and performing background 

checks and application adjudication is not the same offi cer approving the 

application for fi nal enrollment. 

CBP plans to establish, in the SENTRI Directive, a policy to require the 

separation of duties to ensure, whenever possible, that the CBP offi cer conducting 

an initial interview and performing background checks and application 

adjudication is not the same offi cer approving the application for fi nal enrollment. 

CBP commented that offi cers assigned to POEs also work the SENTRI 

Enrollment Centers. Because of this dual role there are a limited number of 

offi cers that can be pulled from port operations to work the centers. CBP can 

direct the Enrollment Centers to use different offi cers, but due to the enormous 

volume of applicants, it may not always be possible to use two different offi cers. 

CBP further commented that it is desirable to have two offi cers’ independent 

assessment of each applicant’s eligibility, but this requirement places a higher 

standard on enrollment in SENTRI than exists for granting U.S. visas, border 

crossing cards, or U.S. citizenship.

CBP’s plan is responsive to this recommendation. We are concerned, however, 

that CBP does not intend to modify the SENTRI Directive until January 1, 

2005. We believe the directive should be updated and distributed sooner. CBP’s 

assertion that our recommendation places a higher standard on enrollment 

in SENTRI than exists for granting US visas, border crossing cards, or US 

citizenship (and other benefi ts), is not entirely correct. The processes for 

granting these benefi ts have other built in management control measures to 

Appendix C

OIG Evaluation of Management Comments
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 43

avoid or identify procedural errors and fraud. For example, the granting of U.S. 

citizenship requires supervisory approval in certain cases, e.g., any applicant with 

potentially disqualifying criminal histories, before a fi nal decision is rendered. In 

addition, according to the January 2003 Citizenship and Immigration Services’ 

Adjudicator’s Field Manual:

“...an integral part of any quality control program is supervisory 

review. All Records and Adjudication Supervisors are required to 

review and be familiar with the work performed by subordinates, and 

to work on improving the quality of the work produced.” 

Further, all citizenship applications are subject to a re-verifi cation process to 

ensure that all steps in the processing of the citizenship application have been 

followed. Finally, the quality assurance (QA) staff at each fi eld offi ce performs 

QA inspections of citizenship applications to ensure proper procedures were 

followed. 

With regard to granting U.S. visas by Department of State consular offi cers, 

three or more persons are usually involved in the application approval process. 

Supervisory consular offi cers review the “visa refusal rate” of each consular 

offi cer on a daily basis. This review will quickly identify a consular offi cer 

that appears to be granting visas too liberally. In addition, supervisory consular 

offi cers regularly survey approved visa applications to ensure compliance with 

procedures and law.

A CBP process that requires supervisory review for certain specifi ed SENTRI 

enrollment applications before a decision was made and a quality assurance 

review of all approved SENTRI enrollment applications would be responsive to 

the intent of our recommendation. Please provide us with a copy of the revised 

SENTRI Directive by August 1, 2004. 

Recommendation 4 - Resolved - Open. 

5. Implement policy, guidance, and procedures for routine and timely system 

queries to monitor continued eligibility of SENTRI program enrollees. 

CBP is in the process of developing a method to query each SENTRI participant 

at the time of border crossing. This will be a full person subject query, identical 

to queries done during secondary examination, and will look at all TECS records 

(CBP violators, terrorist watchlists, etc.) and will query NCIC for warrants. The 

Appendix C

OIG Evaluation of Management Comments
Page 44 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

query is also intended to be automated and responsive to the CBP offi cer at the 

primary booth. CBP plans to implement this function by January 1, 2005. CBP’s 

plan is responsive to this recommendation. Please provide us with documentation 

that the full person subject query has been implemented by January 1, 2005. 

Recommendation 5 - Resolved - Open. 

6. Provide the OIG with the plan and schedule for achievement under which 

GES, or any successor system, will establish real time connectivity with 

TECS. 

CBP commented that “integrated” means GES and TECS will be closely linked, 

but there are no plans to make GES a part of TECS. During September 2004, 

CBP plans an upgrade to the current GES version used for SENTRI. This 

upgraded version, GES 4.0, will provide GES users with automatic query 

capability in TECS and in other systems such as NCIC. CBP intends the 

capability will enable a full series of queries to be performed automatically 

on enrollment, at any set interval during the applicant’s membership, and will 

incorporate the primary subject query capability. CBP plans to migrate GES 4.0 

from an independent system of regional databases to a true global system.

CBP’s plan is responsive to this recommendation. Please provide us with 

documentation that establishes the upgraded functionality of GES and its 

migration from an independent system to a true global system by October 1, 2004. 

Recommendation 6 - Resolved - Open. 

7. Establish a program to document the results of all secondary inspections, 

analyze the results, and use the analysis to establish appropriate compliance 

inspection rates. 

CBP responded that secondary results are recorded in TECS, but a modifi cation 

would be needed to designate these secondary exams specifi cally for NEXUS or 

SENTRI. CBP would need to develop, design, and produce the enhancements, 

but no funding has been identifi ed to complete these tasks. CBP intends to make 

these modifi cations so that SENTRI referrals can be separated from overall port 

referrals to secondary and they will have a better basis for an analysis of results by 

December 31, 2006. By January 1, 2005, CBP plans to repeat the instructions in 

the SENTRI Directive for recording results of secondary referrals. The directive 

Appendix C

OIG Evaluation of Management Comments
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 45

will include guidance for modifying compliance referral rates based on local 

spikes in non-compliance or national threat levels. 

CBP’s plan is responsive to this recommendation. We are concerned, however, 

that CBP does not intend to modify the SENTRI Directive until January 1, 2005. 

We believe the directive should be updated and distributed sooner. From CBP’s 

response, it is not clear when the directive will include guidance for modifying 

compliance referral rates based on local spikes in non-compliance or national 

threat levels. Please provide us with a copy of the revised SENTRI Directive by 

August 1, 2004, and clarify when guidance for modifying compliance referral 

rates will be included in the directive. 

Recommendation 7 - Resolved - Open. 

8. Establish guidance to the POEs to allow for temporary modifi cation of 

compliance inspection rates based on local threat level concerns. 

CBP’s plan to provide guidance for modifying compliance referrals that are based 

on local or national threat level concerns is responsive to this recommendation. 

We are concerned, however, that CBP does not intend to modify the SENTRI 

Directive until January 1, 2005. We believe the directive should be updated 

and distributed sooner. Please provide us with a copy of the revised SENTRI 

Directive by August 1, 2004. 

Recommendation 8 - Resolved - Open. 

9. Establish policies and procedures that require CBP offi cers to identify and 

record SENTRI violations and the resulting penalties imposed that will alert 

CBP offi cers to such information when accessing GES. 

CBP commented that recording all POE violations in TECS is a requirement, 

whether SENTRI or otherwise, but there is a problem with comparing SENTRI 

violations with violations in non-SENTRI lanes. CBP plans, by September 30, 

2007, to establish a very close connectivity with TECS and the GES 5.0 version 

if funding is provided. With this version, CBP would track SENTRI violations 

in TECS and be capable of ordering reports comparing the number, type, and 

severity of violations occurring in SENTRI lanes and non-SENTRI lanes. Having 

this ability would provide a clearer picture of whether the SENTRI population is 

truly low-risk. 

Appendix C

OIG Evaluation of Management Comments
Page 46 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Until GES is available for this purpose, when a SENTRI vehicle is referred 

to secondary, CBP offi cers are querying the names of the applicants in TECS 

and any previous violation will show up in this query. CBP plans to update the 

SENTRI Directive, by January 2005, instructing offi cers to follow this standard 

operating procedure for SENTRI. 

CBP’s plan is responsive to this recommendation. We are concerned, however, 

that CBP does not intend to modify the SENTRI Directive until January 1, 2005. 

We believe the directive should be updated and distributed sooner. Please provide 

us with a copy of the revised SENTRI Directive by August 1, 2004. 

Recommendation 9 - Resolved - Open. 

10. Develop a program to collect, track, and analyze SENTRI performance 

data to evaluate SENTRI’s effectiveness and effi ciency. 

By January 1, 2005, CBP plans to reexamine the measurements used to evaluate 

SENTRI performance. The selected measurements will be collected twice a year 

to evaluate effectiveness and effi ciency at individual sites and for the program as a 

whole. CBP’s plan is responsive to this recommendation. Please provide us with 

these measurements by January 1, 2005.

Recommendation 10 - Resolved - Open. 

11. Finalize guidance and standard operating procedures, which should 

include a standardized training program, to ensure uniform and consistent 

program implementation at all SENTRI land POEs. 

CBP plans to fi nalize the SENTRI Directive by January 2005 and will develop a 

national training program in the form of a SENTRI User Guide available to all 

CBP offi cers via the CBPnet. CBP stated that it does not have funding to develop 

or publish the SENTRI User Guide in its FY 2004 budget or in its FY 2005 

budget request. We view the capability to develop guidance, standard operating 

procedures, and training curriculum as explicit functions and the responsibility for 

management of any program. We are unable to understand why CBP maintains 

that it will require a special funding appropriation to develop the SENTRI User 

Guide.

Appendix C

OIG Evaluation of Management Comments
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 47

CBP’s plan is responsive to this recommendation. We are concerned, however, 

that CBP does not intend to update and complete the SENTRI Directive until 

January 1, 2005. We believe the directive should be updated and distributed 

sooner. Please provide us with a copy of the revised SENTRI Directive by August 

1, 2004. 

Recommendation 11 - Resolved - Open. 

Appendix C

OIG Evaluation of Management Comments
Page 48 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Recommendations

1. Provide a statement of program eligibility criteria that establishes a minimum 

and objective threshold for violations, arrests, and convictions to evaluate 

applicants seeking enrollment or an enrollment extension in SENTRI.

2. Establish procedures for all SENTRI Enrollment Centers that defi ne how CBP 

offi cers resolve hits generated by background checks and how they document 

such resolution in the applicant fi les.

3. Develop a uniform minimum economic threshold to establish employment or 

fi nancial solvency, and develop a uniform timeframe for documents requested to 

establish both employment or fi nancial solvency and residency. 

4. Establish a policy to require the separation of duties to ensure that the CBP 

offi cer conducting an initial interview and performing background checks and 

application adjudication is not the same offi cer approving the application for fi nal 

enrollment. 

5. Implement policy, guidance, and procedures for routine and timely system 

queries to monitor continued eligibility of SENTRI program enrollees. 

6. Provide the OIG with the plan and schedule for achievement under which 

GES, or any successor system, will establish real time connectivity with TECS. 

7. Establish a program to document the results of all secondary inspections, 

analyze the results, and use the analysis to establish appropriate compliance 

inspection rates. 

8. Establish guidance to the POEs to allow for temporary modifi cation of 

compliance inspection rates based on local threat level concerns.

9. Establish policies and procedures that require CBP offi cers to identify and 

record SENTRI violations and the resulting penalties imposed that will alert CBP 

offi cers to such information when accessing GES. 

10. Develop a program to collect, track, and analyze SENTRI performance data 

to evaluate SENTRI’s effectiveness and effi ciency.

11. Finalize guidance and standard operating procedures, which should include 

a standardized training program, to ensure uniform and consistent program 

implementation at all SENTRI land POEs. 

Appendix D

Recommendations
A Review of the Secure Electronic Network for Travelers Rapid Inspection Program Page 49

David M. Hiles, Chief Inspector, Department of Homeland Security, Offi ce of 

Inspections, Evaluations, and Special Reviews

Marcia Moxey Hodges, Senior Inspector, Department of Homeland Security, 

Offi ce of Inspections, Evaluations, and Special Reviews

Vivian Dupuy, Inspector, Department of Homeland Security, Offi ce of 

Inspections, Evaluations, and Special Reviews

Cathy Girouard, Inspector, Department of Homeland Security, Offi ce of 

Inspections, Evaluations, and Special Reviews

Appendix E

Major Contributors to this Report
Page 50 A Review of the Secure Electronic Network for Travelers Rapid Inspection Program

Department of Homeland Security

Chief of Staff

Deputy Secretary

Customs and Border Protection, Audit Liaison

DHS OIG Liaison

DHS Public Affairs

Offi ce of Management and Budget

Homeland Bureau Chief

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees as Appropriate

Appendix F

Report Distribution

Additional Information and Copies

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

fax your request to (202) 254-4285, 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 the OIG Hotline at 1-800-323-8603; 

write to Department of Homeland Security, Washington, DC 20528, Attn: Offi ce of Inspector General, 

Investigations Division – Hotline. The OIG seeks to protect the identity of each writer and caller.