DEPARTMENT OF HOMELAND SECURITY

Office of Inspector General 

U.S. Immigration and Customs 

Enforcement 

Visa Security Program 

OIG-08-79 July 2008 
 

 

 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

July 24, 2008 

Preface 

The Department of Homeland Security (DHS) Office 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, and 

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

efficiency, and effectiveness within the department. 

This report addresses the management, value added, and expansion of the U.S. 

Immigration and Customs Enforcement Visa Security Program. It is based on interviews 

with employees and officials of relevant agencies, direct observations, and a review of 

applicable documents. 

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

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

our hope that this report will result in more effective, efficient, and economical 

operations. We express our appreciation to all of those who contributed to the 

preparation of this report. 

Richard L. Skinner 

Inspector General 
 

Table of Contents/Abbreviations 

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

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

Results of Review ......................................................................................................................9 

Law Enforcement Expertise and Resources Add Layer of Security to Visa Process..........9 

 Risk-based Framework Prioritizes Visa Security Program Expansion Efforts .................14 

Visa Security Program Management Should Enhance Performance Measurement .........21 

Visa Security Officer Training Prepares Agents for Deployment.....................................26 

Management Comments and OIG Analysis ............................................................................28 

Appendices 

Appendix A: Purpose, Scope, and Methodology.............................................................36 

Appendix B: Management Comments to the Draft Report.............................................37 

Appendix C: Department of State Comments to the Draft Report..................................42 

Appendix D: Major Contributors to this Report..............................................................52 

Appendix E: Report Distribution ....................................................................................53 

Abbreviations 

ARSO–I Assistant Regional Security Officer–Investigations
 

DHS Department of Homeland Security 

DOS Department of State 

FLETC Federal Law Enforcement Training Center 

FY Fiscal Year 

ICE U.S. Immigration and Customs Enforcement 

NSDD–38 National Security Decision Directive–38 

OIA Office of International Affairs 

OIG Office of Inspector General 

SAO Security Advisory Opinion 

TECS Treasury Enforcement Communications System
 

VSP Visa Security Program
 

VSU Visa Security Unit 
OIG 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Visa Security Program was established in the Homeland 

Security Act of 2002 to increase the security of the visa process at 

U.S. embassies and consulates. The program enhances national 

security by preventing terrorists, criminals, and other ineligible 

applicants from receiving visas, and maximizing the visa process 

as a counterterrorism tool. We reviewed U.S. Immigration and 

Customs Enforcement (ICE) management of the program, the 

coordination between ICE special agents and Department of State 

officers overseas, and how the addition of ICE special agents has 

affected visa security. We also reviewed expansion plans and 

predeployment training. 

The program assigns experienced special agents to Visa Security 

Units overseas to review visa applications, initiate investigations, 

and provide advice and training to consular officers. Agents bring 

valuable resources to posts and add a layer of security to the visa 

process. 

ICE is improving its management of the program continually. For 

example, officials developed a risk-based framework to prioritize 

program expansion and site selection. In addition, they developed 

automated tools to facilitate some program activities and limit the 

amount of manual data entry performed by agents. Program 

managers also constantly update the program’s training course to 

keep up with changing trends and address participant suggestions. 

However, some program areas could be improved. We are 

recommending that program managers enhance recording, 

tracking, monitoring, verification, analysis, and reporting of visa 

security activities in the current tracking system while developing 

a new tracking system. In addition, program managers must 

provide training and guidance to field personnel on new 

procedures and document the program’s training course 

curriculum. ICE agreed with our findings and concurred with our 

recommendations. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Background 

Foundation for the Visa Security Program 

Nineteen terrorists applied for and obtained legitimate U.S. visas in the 

months prior to September 11, 2001, facilitating their entry into the United 

States. The resulting events of 9/11 illustrate the importance of a secure 

visa process to our national security. The Visa Security Program (VSP) 

was established to increase the security of the visa process. 

Section 428 of the Homeland Security Act of 2002 authorizes the Secretary 

of Homeland Security to issue regulations, administer, and enforce 

immigration and nationality laws relating to visas, and to refuse individual 

visas according to law.1

 In addition, Section 428 authorizes the Secretary 

to assign Department of Homeland Security (DHS) personnel to visa 

issuing diplomatic posts to review individual visa applications, initiate 

investigations of visa security-related matters, and provide advice and 

training to consular officers.2 Section 428 specifically requires that DHS 

personnel be assigned to Saudi Arabia to review all visa applications 

submitted in Saudi Arabia prior to adjudication.3 VSP began operations in 

Saudi Arabia in October 2003. 

Pursuant to Section 428, DHS and Department of State (DOS) developed a 

memorandum of understanding concerning Section 428 implementation. 

The September 2003 memorandum delineates the roles and 

responsibilities of the departments regarding the visa issuance process and 

visa security activities, as well as the coordination between the two at 

overseas posts. 

History of the Visa Security Program 

DHS created a Visa Security Unit (VSU) within its Border and 

Transportation Security Directorate to implement and manage Section 428 

requirements. On October 31, 2003, DHS announced the reorganization 

of its international activities, including the establishment of an Office of 

International Affairs (OIA) within ICE. In January 2004, as part of the 

reorganization, the VSU transferred to ICE OIA and assumed 

responsibility for the operational requirements of Section 428, including 

visa security operations both overseas and in the United States. 

Responsibility for visa policy initially remained with the Border and 

1 P.L. 107-296, Section 428(b)(1) 

2

 Section 428 (e)(1) and (e)(2) 

3

 Section 428 (i) 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Transportation Security Directorate, but the DHS Directorate of Policy 

assumed this responsibility in 2005 when the DHS Secretary eliminated 

the Border and Transportation Security Directorate. 

ICE OIA initially was established within the ICE Office of Investigations. 

Following an internal ICE reorganization in February 2007, ICE OIA 

moved out of the Office of Investigations and now reports directly to the 

Office of the Assistant Secretary. 

Once the mandated VSU offices in Saudi Arabia were open, managers 

assessed other potential overseas locations for program expansion. Senior 

DOS officials at some posts approved establishing a VSU at their post; 

others resisted. Program expansion in 2004 also was retarded by 

insufficient appropriated funds. In October 2005, VSUs were established 

in Manila, Philippines; Abu Dhabi and Dubai in the United Arab Emirates; 

and Islamabad, Pakistan. VSU Cairo began operations in Egypt in 

January 2007. VSU operations began in Caracas, Venezuela, and 

Montreal, Canada, in March and May 2007, respectively. VSU Hong 

Kong was established in China in September 2007. In November 2007, 

VSU operations began in Casablanca, Morocco. 

Visa Security Program Operations 

The VSP mission is to enhance national security and public safety by 

preventing terrorists, criminals, and other ineligible applicants from 

receiving U.S. visas, and maximizing the visa process as a 

counterterrorism tool. The program’s goals include: 

1) Preventing known threats to national security from exploiting the 

visa process; 

2) Identifying “not yet known” threats to national security—threats 

that do not appear in any government databases or watchlists; 

3) Applying law enforcement expertise and capabilities to the visa 

process; 

4) Identifying and addressing systemic threats and vulnerabilities in 

the visa process; and, 

5) Supporting the timely processing of visas for legitimate applicants. 

VSP accomplishes these goals by assigning ICE special agents with 

expertise in immigration law and counterterrorism to visa issuing U.S. 

diplomatic posts overseas to perform visa security activities. While DOS 

consular officers continue to adjudicate all visa applications, the VSP 

complements the DOS visa screening process with law enforcement 

resources not available to consular officers to ensure ineligible applicants 

do not receive U.S. visas. 

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The primary visa security activity conducted by ICE special agents 

assigned to VSUs is the screening and vetting of visa applicants to 

determine the applicant’s risk profile and visa eligibility. Screening is a 

largely automated process of checking applicant biographic information 

against the Treasury Enforcement Communications System (TECS). 

TECS is an automated enforcement and inspections system that provides a 

large database of information for law enforcement and border inspection 

purposes, and serves a case management function for ICE. TECS supports 

DHS and other federal users, and can exchange information automatically 

with several U.S. government systems, including the DOS Consular 

Lookout and Support System. Screening identifies those applicants whose 

name or date of birth matches a record in a government database or 

watchlist. According to VSP performance data, VSUs screened more than 

502,250 visa applicants in Fiscal Year (FY) 2007. 

Screened applicants with exact or possible matches are then vetted prior to 

determining eligibility for a visa. Vetting involves additional research and 

investigation of the visa applicant by an ICE special agent. Vetting could 

include conducting more in-depth searches in law enforcement databases 

and other information systems, examining documents, interviewing the 

applicant, and consulting with consular, law enforcement, or other 

officials as needed. Agents assigned to VSUs also might perform in-depth 

analysis of the visa applicant and the applicant’s sponsors, associates, 

family members, and business. This analysis might involve using a 

variety of information systems, investigative tools and techniques, and 

collateral requests to domestic ICE offices. In addition to visa applicants 

with potential matches, agents also vet some applicants whose names did 

not match watchlists; these additional vettings are based on post-specific 

case selection guidelines. According to VSP performance data, VSUs 

vetted more than 135,500 visa applicants in FY 2007. 

In addition to screening and vetting visa applicants, ICE special agents 

assigned to VSUs initiate investigations of activity involving threats to 

national security and immigration fraud, generate leads, and provide 

support for domestic ICE investigations. Participation in law enforcement 

and other working groups at post provides a forum for ICE special agents 

to disseminate information on threats, trends, and intelligence to other law 

enforcement and intelligence agencies at post. ICE special agents also 

conduct liaison with host country law enforcement officials to share and 

receive information. 

As required by Section 428, ICE special agents assigned to VSUs provide 

advice and training to consular officers about security threats relating to 

the adjudication of visa applications. Several VSU officials said that most 

U.S. Immigration and Customs Enforcement Visa Security Program 

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of this advice and training occurs informally as consular officers consult 

with ICE special agents on individual visa applications. ICE special 

agents assigned to VSUs provide interpretation and expertise in 

responding to questions regarding an applicant’s eligibility for a visa, 

which enhances the consular officer’s ability to identify threats when 

adjudicating visas. 

In addition to informal discussions with consular officers, ICE special 

agents assigned to VSUs identify and monitor the threat environment and 

trends in the visa applicant pool specific to their post and host country. 

They then develop formal, targeted training and briefings to inform 

consular officers and others about threats to the visa process. Examples of 

topics covered in these briefings include fraud trends in specific visa 

categories and how to identify fraudulent documents and imposters. Nonconsular embassy personnel, host country airport officials, and others also 

benefit from this advice and training. According to VSP performance 

data, VSUs conducted 83 formal training sessions for consular officers, 

non-consular embassy personnel, and others in FY 2007. 

 Coordination with the Department of State 

VSP officials regularly interact and coordinate with DOS officials at 

headquarters and overseas posts during the program expansion and site 

selection process and when establishing new VSUs. Interaction also 

occurs in the course of conducting day-to-day visa security operations. 

Bureaus of Consular Affairs and Diplomatic Security 

The Bureau of Consular Affairs is responsible for visa operations, 

the welfare and protection of U.S. citizens abroad, issuing 

passports to citizens, protecting U.S. border security, and 

facilitating legitimate travel to the United States. Consular officers 

overseas are responsible for issuing nonimmigrant and immigrant 

visas. More than 6.4 million nonimmigrant visas and 

approximately 431,000 immigrant visas were issued in FY 2007. 

The Office of Consular Fraud Prevention Programs formulates, 

coordinates, and promulgates policies and practices related to 

passport and visa anti-fraud programs. The Consular Fraud 

Prevention Program directs the consular anti-fraud program and 

develops and provides anti-fraud training for passport agents, 

consular officers, DHS, and representatives of other federal 

agencies. The program also provides instruction for consular 

officers in visa sections abroad on the operational aspects of the 

fraud function. 

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The Bureau of Diplomatic Security is the security and law 

enforcement arm of DOS. The Diplomatic Security Criminal 

Investigative Division conducts criminal investigations of visa and 

passport fraud, both domestically and abroad. These federal 

felonies are often committed in connection with more serious 

crimes, such as international terrorism, narcotics trafficking, 

organized crime, alien smuggling, money laundering, pedophilia, 

and murder. Countless people attempt to obtain U.S. visas 

illegally each year. Diplomatic security investigates and 

coordinates international visa fraud cases including fraudulent 

issuance, procurement, counterfeiting, and forgery of U.S. visas. 

Diplomatic security works closely with consular affairs on visa 

fraud cases. 

The Diplomatic Security Overseas Criminal Investigator Program 

has placed 33 special agents at embassies abroad specifically to 

conduct passport and visa fraud investigations. A 2004 

memorandum of understanding between consular affairs and 

diplomatic security covers their work. Agents, known as Assistant 

Regional Security Officers–Investigations, or ARSO–Is, are 

assigned to those embassies where high volumes of fraudulent 

documents have been detected. Their mission includes 

investigating visa and passport fraud in order to protect the visa 

adjudication process by disrupting criminal and terrorist mobility. 

Working with Consular Officers at Overseas Posts 

The consular section of U.S. embassies and consulates is 

responsible for adjudicating visa applications and issuing visas to 

non-U.S. citizens who need a visa to travel to the United States. In 

processing a visa application, consular officers review the 

application, conduct automated name checks against watchlists of 

known terrorist or criminal suspects, obtain fingerprints, and 

interview the visa applicant. The consular officer then decides to 

approve or deny the application, or to request additional security 

checks or information before adjudicating the application. 

ICE special agents assigned to VSUs conduct visa security 

activities in addition to the consular process. When establishing a 

VSU at an overseas post, VSP officials work closely with consular 

officials to determine how best to incorporate VSU activities into 

the visa process while minimizing their effect on the flow of the 

issuance process. The logistics of the consular visa process can 

vary slightly by post depending on several factors, including the 

volume or type of visa applications or the number of available 

U.S. Immigration and Customs Enforcement Visa Security Program 

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consular officers. Therefore, VSUs remain flexible and work with 

each individual post to coordinate the optimal procedures and 

timing for performing visa security activities as well as receiving 

referrals regarding individual visa applicants from consular 

officers. 

ICE special agents assigned to VSUs also coordinate with the 

consular section’s designated fraud prevention manager. At many 

posts, fraud prevention responsibilities are a collateral duty 

assigned to a consular officer at post; other posts have full-time 

fraud prevention managers, or fraud prevention units, who 

concentrate on detecting fraud in visa applications. If a consular 

officer or fraud prevention manager suspects a fraud case could 

have links to terrorism, the case is referred to the VSU. In 

addition, if the VSU investigates such a case and determines it 

involves fraud but no links to terrorism, the VSU returns the case 

to the consular section for further fraud investigation by the fraud 

prevention manager. 

The Security Advisory Opinion Process 

Consular officers perform additional security checks—called 

Security Advisory Opinions (SAO)—prior to adjudicating 

applications that meet specific criteria for extra scrutiny. The SAO 

process is a multi agency review process managed by DOS. 

Consular officers electronically submit requests to DOS for a 

specific type of SAO. Depending on the type of SAO requested, 

the request is forwarded to other government agencies, such as the 

Federal Bureau of Investigation or Central Intelligence Agency. 

After running name checks on the applicant, the respective 

agencies provide the resulting information to DOS for a 

determination on whether the applicant should be granted a visa. 

Currently, VSP headquarters is involved in the SAO process when 

DOS disagrees with another agency’s determination regarding the 

applicant. In these cases, VSP headquarters reviews the 

information and acts as a mediator to reach a resolution on the 

applicant’s eligibility for a visa. 

In May 2007, Congress appropriated funds to the VSP to establish 

an SAO review unit within VSP headquarters. VSP management 

officials currently are assessing how best to incorporate VSP more 

fully into the SAO process. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Working with Diplomatic Security at Overseas Posts 

The Bureau of Diplomatic Security is the security and law 

enforcement arm of DOS. Diplomatic security protects people, 

facilities, and information at U.S. diplomatic posts around the 

world and at domestic DOS locations. Regional security officers 

coordinate each post’s Law Enforcement Working Group. 

Diplomatic security agents conduct a variety of investigations 

including investigations of passport and visa fraud. Under the 

ARSO-I program, diplomatic security assigns ARSO–Is to conduct 

passport and visa fraud investigations in consular sections at posts 

with high occurrences of fraudulent travel documents. 

DOS officials said that ARSO–Is usually investigate suspected 

fraud rings or criminal enterprises. If an ARSO–I suspects a link 

to terrorism and there is a VSU at post, the ARSO–I coordinates 

with the VSU for further investigation of the potential terrorism 

aspects of the case. In these types of cases, the VSU and ARSO–I 

might conduct a joint investigation under their respective 

authorities in a task force-like effort. 

Approval of Permanent Positions at Overseas Posts 

Through the National Security Decision Directive–38 (NSDD–38) 

process, DOS chiefs of mission consider VSP requests to establish 

permanent positions at overseas posts. The NSDD-38 process is 

an important tool DOS uses to regulate the size of the staffs at 

embassies. It requires agencies proposing changes in the size, 

composition, or mandate of their staffs to take a “lean approach” 

that aligns with the embassy’s performance plan goals, security 

situation, attendant costs, and administrative support implications. 

DOS evaluates several factors, including whether adding DHS 

personnel at post is necessary to perform the job, the availability of 

both classified and unclassified office space, and personnel 

security. VSP officials receive an indication of the likelihood of 

the chief of mission approving an NSDD–38 request during 

consultations with DOS officials during the VSP site selection 

process. 

If approval of a new VSU at a post is deemed to be likely, DHS 

approves the proposed VSP positions and submits a formal 

NSDD–38 application to the DOS Office of Management and 

Rightsizing. The chief of mission then has 21 days to consider and 

respond to the NSDD–38 request. We were told DOS responds to 

approximately 25% of ICE NSDD–38 requests within 21 days. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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ICE interacts with DOS during the NSDD–38 process to respond 

to questions or provide additional information. 

Results of Review 

Law Enforcement Expertise and Resources Add Layer of Security 

to Visa Process 

Incorporating regular law enforcement screening and vetting of visa 

applicants into the visa process adds an additional layer of security to the 

DOS consular visa adjudication process. Consular officers interview visa 

applicants to verify and complete information on applications, conduct 

automated name checks against watchlists of known terrorists and 

criminals, and obtain fingerprints and a digital photograph of the 

applicant. The VSP complements these efforts by assigning ICE special 

agents to posts to screen visa applicants and further vet selected applicants 

to identify terrorist or criminal suspects who are “not yet known” or 

identified as such and stop them from reaching the United States. 

Visa Security Activities Require Agents to Be Present at Post 

Some DOS headquarters officials have said that ICE special agents 

do not need to be posted overseas to conduct their visa security 

activities. The DOS officials said ICE special agents are able to 

access the law enforcement databases and information systems 

used in the screening and vetting process remotely. 

VSP managers said that experienced law enforcement agents 

assigned overseas provide unique added value at overseas posts. 

ICE special agents assigned to VSUs use their expertise in 

immigration and nationality law, investigations, document 

examination, intelligence research, and counterterrorism to 

complement the consular visa adjudication process with law 

enforcement vetting and investigation. In addition, ICE special 

agents assigned to VSUs at post focus on identifying “not yet 

known” terrorists and criminal suspects and preventing them from 

reaching the United States. To perform visa security activities 

effectively requires ICE special agents to be assigned to overseas 

posts. 

While the initial VSU screening process is automated, the vetting 

process requires a hands-on presence at post. During the vetting 

process, ICE special agents need access to relevant documents, 

such as the visa application and passport, as well as financial, 

U.S. Immigration and Customs Enforcement Visa Security Program 

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employment, or other supporting documents. For example, three 

long-term residents of a country with a VSU applied for visas to 

visit the United States. Consular and VSU system checks resulted 

in no alerts on the applicants. An ICE special agent assigned to a 

VSU reviewed the visa application packages, including 

employment records, and determined that the applicants had 

merged their personal bank accounts with their employer’s bank 

account. Through further investigation, the agent identified a link 

from the employer to a company identified by the Department of 

Treasury’s Office of Foreign Assets Control as a Specially 

Designated Global Terrorist and Foreign Terrorist Organization. 

Because an agent was assigned to the VSU at post, a potential 

terrorism link was identified, the applicants’ visas were denied, 

and further investigation could be performed to identify other 

related companies. 

In addition to the visa application package, ICE special agents 

assigned to VSUs at overseas posts have access to the visa 

applicant in order to conduct a law enforcement interview. An 

agent might decide to interview a visa applicant to verify or 

expand on specific details of the application, or because the 

applicant might be able to provide additional information for an 

ongoing investigation. For example, an applicant applied for a 

student visa at a VSU post, and based on available information, the 

consular officer initially approved the application. Because the 

applicant fit VSU post-specific case selection criteria, the agent 

thoroughly vetted and interviewed the applicant. The interview of 

the applicant provided information on the applicant’s uncle, who 

was a subject of a Joint Terrorism Task Force investigation. On 

the pretense of establishing the applicant’s eligibility for a student 

visa, the ICE special agent interviewed the uncle. Because the 

VSU was at post, new information was provided for the Joint 

Terrorism Task Force investigation, and as a result of the agent’s 

recommendation, the applicant’s student visa application was 

denied by the consular officer. 

Other VSU activities also require that ICE special agents be 

assigned to VSUs at overseas posts. Agents must be in the host 

country to appreciate fully the local threat conditions. Agents use 

their experience, as well as consultations with consular officers, 

other law enforcement or intelligence officials at post, and host 

country officials to identify and monitor threats, trends, and tactics. 

In addition, ICE special agents assigned to VSUs receive non-visa 

special requests to perform basic screening and vetting of 

individuals who are not visa applicants. These special requests 

could come from other DHS components, the DOS Regional 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Security Officer, or other officials at post. ICE special agents at 

posts also have cleared derogatory information on some visa 

applicants, allowing their visas to be approved. 

ICE special agents assigned to VSUs at overseas posts have 

produced a variety of visa security results. As a result of screening 

and vetting activities, agents recommended denial of 750 visa 

applications in FY 2007. Agents also identified 49 “not yet 

known” terrorists and created 68 watchlist nominations, 933 

lookouts, and 557 subject records in FY 2007. The following table 

provides a breakdown of selected VSU results for each post for FY 

2007. 

Selected FY 2007 Post-by-Post VSU Results 

Post 

Recommended 

Denials2 

“Not Yet 

Knowns” 

Identified 

Watchlist 

Nominations 

Lookouts 

Created 

Subject 

Records 

Created 

Abu Dhabi 95 0 1 101 59 

Cairo1

 263 0 0 20 31 

Caracas1

 16 0 0 18 31 

Dubai 35 0 0 41 16 

Islamabad 5 3 18 235 133 

Manila 283 37 41 395 96 

Montreal1

 14 1 0 6 29 

Riyadh 39 8 8 117 162 

Totals 750 49 68 933 557 1 Totals for these posts do not include all of FY 2007. VSU operations began in 

Cairo, Caracas, and Montreal in January, March, and May 2007, respectively. 2

 Includes Prescreen, SAO, and Post-Adjudication VSU Recommended Denials. 

Visa Security Units Bring Valuable Resources to Consular 

Officers 

Consular officers have access to two key DOS information 

systems, the Consular Consolidated Database and the Consular 

Lookout and Support System, which they use during the visa 

adjudication process. However, they do not have access to the 

principal DHS law enforcement information system, TECS. ICE 

special agents assigned to VSUs bring access to DHS and other 

law enforcement systems—which often contain sensitive law 

enforcement information, including information related to ongoing 

investigations—to post. Agents provide information, as well as 

interpretation of the information, from these systems to assist 

consular officers in making an adjudication decision. 

Some of the potentially derogatory information in TECS 

automatically replicates into the DOS Consular Lookout and 

Support System. Consular officers receive alerts when an 

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applicant’s name, date, and place of birth or passport number, date, 

and place of issue appear to be sufficiently similar to data in their 

lookout system. These applications then receive additional 

scrutiny to resolve the eligibility issues that pertain to the 

information. Both ICE and DOS officials said that consular 

officers regularly consult with agents regarding information they 

find on individual applicants. ICE special agents assigned to 

VSUs interpret and explain for consular officers the law 

enforcement-related alerts that occur, and can often further 

investigate a specific visa applicant at the request of a consular 

officer. 

Consular and other DOS officials at posts we visited said they 

were glad to have ICE special agents assigned to VSUs at their 

posts. Many said they were initially concerned that agents would 

be looking over the shoulders of consular officers and checking 

their work. However, they said they were pleasantly surprised to 

discover that this was not the case and that agents bring additional 

resources to post to support existing consular operations. Several 

consular officials said that ICE special agents assigned to VSUs 

add a second line of defense to ensure that terrorists, criminals, and 

other ineligible applicants do not receive U.S. visas. 

DOS officials also said that if consular officers had access to 

TECS and other DHS systems, they would be able to obtain the 

information they need to adjudicate visa applications on their own. 

ICE officials agree that DOS personnel should have access to some 

DHS systems, but said that agents would still be necessary to 

interpret most search results. ICE officials also said that there 

would be sensitivity and disclosure issues involved with giving 

consular officers unrestricted access to DHS systems that include 

information relating to ongoing criminal investigations, and 

information entered by other federal law enforcement agencies. 

With regard to TECS access, a VSP official said that U.S. Customs 

and Border Protection controls access, not ICE, and therefore, 

DOS would need to work with U.S. Customs and Border 

Protection to gain TECS access for consular officers. 

Visa Security Program Is Not Negated by Presence of ARSO–I 

at Post 

A VSU and an ARSO–I can be present at the same post without 

overlapping duties because each has a different mission. VSUs 

focus primarily on counterterrorism; ARSO-Is focus primarily on 

passport and visa fraud. Because terrorists use fraudulent means to 

obtain legitimate travel documents to enter the United States, 

U.S. Immigration and Customs Enforcement Visa Security Program 

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VSUs review suspected fraudulent visa applications to determine 

whether there is a terrorism link, seemingly giving the appearance 

of overlapping responsibilities with the ARSO–I. However, if no 

link to terrorism is identified, VSU and DOS officials said the 

VSU coordinates with the ARSO–I for further fraud investigation. 

Likewise, if an ARSO–I reviewing a suspected fraudulent visa 

application detects a possible terrorism link, the ARSO-I 

coordinates with the VSU for further investigation of the terrorism 

aspect of the case. Both bring their respective expertise and 

resources and, as appropriate, conduct joint investigations. 

At the two VSU posts we visited that also had an ARSO–I, both 

VSU and DOS officials said that there is room for both programs 

and more than enough work for each. VSU and DOS officials at 

one post said that everyone at post “knows their own lane and stays 

in it,” referring cases or conducting joint investigations as 

appropriate. VSP and ARSO–I headquarters management officials 

said they regularly consult regarding overseas operations and 

coordination, and that they support a task force mentality between 

the programs at posts where both are present. 

Another VSU post we visited was expecting the addition of an 

ARSO–I shortly after our visit. Consular officials at that post said 

they were looking forward to having an ARSO–I at post and hoped 

it would reduce some of the basic fraud referrals to the VSU, 

freeing the VSU to focus on counterterrorism efforts. Both VSU 

and DOS officials at the post said they did not expect any problems 

with the VSU and ARSO–I working together. 

Visa Security Program Management Should Analyze 

Performance Measures that Support Need to Assign Agents to 

Overseas Posts 

While ICE special agents need to be present at post to perform visa 

security activities, the connection between the activities they 

perform at post and the results of those activities has not been 

analyzed or demonstrated fully. VSP management should monitor 

and analyze additional performance measures to demonstrate better 

the need to assign agents to overseas posts. 

Technologically, the automated initial screening could be 

conducted remotely; however, ICE special agents would still be 

necessary at posts as described above. The initial visa applicant 

screening begins with importing visa applicant data from the DOS 

Consular Consolidated Database into the VSP Tracking System. 

The VSP Tracking System electronically converts and groups the 

U.S. Immigration and Customs Enforcement Visa Security Program 

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applicant data, which is exported in the new format from the VSP 

Tracking System to TECS for automated screening. ICE special 

agents assigned to the VSU at post then vet the screening results, 

including reviewing the visa application documents or 

interviewing the visa applicant. Agents record their activities in 

the VSP Tracking System, including whether they reviewed visa 

application documents or interviewed the visa applicant. 

Each VSU creates a monthly statistical report of its screening and 

vetting activities from the VSP Tracking System and sends it to 

headquarters for review. However, while agents record whether 

they review visa application documents or interview applicants on 

a worksheet within the VSP Tracking System, these statistics are 

not included in the data sent monthly to VSP headquarters. Also, 

because only aggregate monthly data is sent, VSP headquarters 

does not monitor or analyze the effect of document reviews or 

interviews conducted at post on agent decisions and outcomes, 

such as recommended denials, watchlist nominations, subject 

records, or lookouts. Such analysis could provide both a 

quantitative and qualitative justification for the need to assign ICE 

special agents to VSUs at overseas posts. VSP headquarters could 

then use the results of the analysis during the site selection and 

expansion process with DOS and to support requests for additional 

funding from Congress. 

We recommend that the Assistant Secretary for Immigration and 

Customs Enforcement: 

Recommendation #1: Develop and implement a plan to monitor 

and analyze case-specific visa security activities conducted at post 

and their effect on Visa Security Program results. 

Risk-based Framework Prioritizes Visa Security Program 

Expansion Efforts 

Expanding VSP to new locations is a priority for VSP management. With 

visas issued at more than 200 U.S. diplomatic posts around the world and 

limited funding and personnel, VSP officials developed a risk-based 

framework to identify the highest risk locations and prioritize deployment 

of VSP resources to new locations. VSP management also focuses on 

selecting the best candidates for overseas assignments. According to the 

VSP Five-Year Expansion Plan, by initially concentrating expansion to the 

highest risk posts, VSP will cover 75% of the highest risk visa activity by 

2013. However, VSP expansion depends on DOS chief of mission 

U.S. Immigration and Customs Enforcement Visa Security Program 

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approval, and chiefs of mission at some posts have resisted the addition of 

a VSU. 

Visa Security Program Follows Risk-based Framework to 

Prioritize and Select Expansion Locations 

The VSP site evaluation process prioritizes program expansion 

based on risk to concentrate expansion to the highest threat 

locations first. The framework for selecting new VSU site 

locations involves four steps: 

1) Performing an initial quantitative risk analysis of all visaissuing posts; 

2) Consulting regularly with DOS, law enforcement, and 

intelligence agencies; 

3) Conducting site assessments of potential sites; and, 

4) Completing a final evaluation of potential sites and site 

selection. 

Initial Risk Analysis 

VSP officials first perform an initial quantitative risk analysis to 

assess the level of risk at each visa issuing post by examining 

several threat and vulnerability factors relevant to the visa security 

mission. These factors include visa activity, corruption, arrests and 

criminal removals by nationality, special interest aliens applying 

for visas, and DOS threat assessments for each post. VSP program 

officials obtain relevant data for each threat and vulnerability 

factor from well-established information sources, such as TECS, 

the Yearbook of Immigration Statistics, or the DOS Consular 

Consolidated Database. 

Because different information sources use different scoring 

systems, ICE adjusts them as appropriate so that a high level of 

threat or vulnerability always receives a high score in the analysis. 

For example, a higher number of arrests for a nationality 

corresponds to a higher threat level for that country, so no 

adjustment is necessary; however, for corruption, a lower score 

corresponds to higher vulnerability, so VSP officials adjust the 

scoring to show high levels of corruption with a high vulnerability 

score. ICE uses the numeric value from the source data or 

converts the source information into numeric values to facilitate 

quantitative analysis. 

For each threat and vulnerability factor, ICE organizes the posts 

into four groups based on the numeric values, with approximately 

U.S. Immigration and Customs Enforcement Visa Security Program 

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25% of posts being placed in each group. The first group 

represents the highest threat or vulnerability, the second group the 

second highest threat or vulnerability, and so on. ICE then assigns 

each group a numeric value. For example, VSP officials analyze 

the number of arrests for nationals of countries with visa issuing 

posts as one threat factor in the initial risk analysis. VSP officials 

rank the countries by number of arrests from highest to lowest, 

divide them into four groups, and assign each group a numeric 

value. This process is repeated for each threat and vulnerability 

factor in the initial risk analysis. After each threat and 

vulnerability factor is quantitatively analyzed, VSP officials 

aggregate each post’s scores for all factors to determine the overall 

quantitative risk score for each post. 

Using the overall quantitative scores, each post is assigned an 

overall risk rating in one of four groups—critical, high, medium, or 

low. The initial risk analysis provides a basis for VSP 

management to focus in greater detail on posts in the highest risk 

group during the next steps in the site selection process. 

Consultations 

Throughout the site selection process, VSP coordinates with DOS 

officials in consular affairs and diplomatic security, and with other 

law enforcement and intelligence agencies at both headquarters 

and potential VSU posts. These consultations further refine and 

reorder the list of potential sites. 

Site Assessments 

VSP then performs site visits, which provide an opportunity for 

VSP officials to meet with DOS, law enforcement, and other 

members of the embassy community to familiarize them with the 

VSP. VSP officials assess a number of qualitative factors, such as 

whether current conditions at the post support the critical- or highthreat level indicated by the initial risk analysis for the post and the 

opportunity to partner with other law enforcement agencies at post. 

In addition, VSP evaluates the logistics of establishing a VSU, 

such as whether the visa security mission can be accomplished 

with limited personnel, consistent with the ICE staffing model and 

DOS staffing concerns, and whether appropriate space is available 

at post. Using professional judgment based on interdepartmental 

consultations and site assessments, VSP officials assign a high, 

medium, or low score to each qualitative factor for the posts 

receiving further consideration. VSP then translates the scores to 

numeric values. 

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Final Evaluation and Site Selection 

Finally, VSP evaluates the risk factors and the information 

obtained through consultations and site assessments, both 

individually and as they relate to each other, to determine which of 

the posts under consideration will be proposed for deployment. 

During this final evaluation, VSP also considers the regional need 

for a VSU given the presence of other VSUs in the area and the 

level of interest in a VSU expressed by key DOS officials at each 

post. VSP officials assign these factors a high, medium, or low 

qualitative score, which translate to numeric values for each post. 

VSP officials then sum the overall initial quantitative risk analysis 

score and the numeric values for the qualitative site assessment and 

final evaluation factors to reach a ranking of the narrower list of 

posts under consideration. VSP officials use the final ranking to 

determine which sites will be proposed to the ICE Assistant 

Secretary for possible expansion. 

After the ICE Assistant Secretary approves the proposed sites, ICE 

begins the DHS nomination process, which involves obtaining 

approval from the DHS Chief Financial Office, Office of Policy, 

General Counsel, and Deputy Secretary. ICE then formally 

requests DOS approval of permanent personnel positions at the 

proposed posts using the NSDD–38 process. 

VSP explains the basic site selection process in a number of 

documents, including the Five-Year Expansion Plan. Some 

descriptions are more detailed than others. However, the program 

does not have a detailed, factor-by-factor explanation for the initial 

quantitative risk analysis or qualitative site assessment and final 

evaluation processes. Such an explanation would include the 

source for each factor, how the score for each factor is calculated, 

and, as appropriate, how or why a score is weighted. 

VSP officials document their initial risk analysis, including the 

source data and any calculations or weighting performed to reach 

the individual factor score as well as the overall quantitative risk 

score for each post. In addition, VSP officials document their 

judgment regarding the qualitative site assessment and final 

factors. However, the quantitative analysis, in particular, is 

complex and the documentation can be difficult to follow. In 

addition, agents and other staff rotate in and out of VSP 

headquarters, and responsibility for updating and maintaining the 

initial risk analysis and site selection matrix changes. We believe a 

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detailed, factor-by-factor explanation for the quantitative and 

qualitative factors analyzed during the site selection process would 

facilitate information updates to the analysis as well as help 

incoming staff understand the risk assessment and site selection 

process. 

We recommend that the Assistant Secretary for Immigration and 

Customs Enforcement: 

Recommendation #2: Develop a detailed, factor-by-factor 

explanation of the process for analyzing the quantitative and 

qualitative factors in the site selection process from the initial risk 

analysis through site selection, including source(s) for each factor 

and how the score for each factor is calculated. 

VSP officials developed the VSP Five-Year Expansion Plan, 

which explains expected expansion plans for the next 5 years, 

including preliminary budget projections. The ICE Assistant 

Secretary, DHS headquarters, the Homeland Security Council, and 

the Office of Management and Budget have approved the plan. In 

addition, the National Strategy for Homeland Security, issued in 

October 2007, includes expanding law enforcement personnel 

overseas who focus on assessing national security threats and 

fraudulent documents used in the visa application process. VSP 

expansion also is supported in the National Implementation Plan 

for Counterterrorism. 

VSP officials stressed that the VSP Five-Year Expansion Plan is 

dynamic, and that locations identified for expansion in the plan 

could change because the risk environment is constantly changing. 

Several factors will affect program expansion, including the site 

assessment process, DHS nomination of locations to DOS, the 

DOS NSDD–38 process, and the process for deploying officers to 

DOS approved posts. The expansion plan also depends on 

receiving necessary funding. Because of the time and 

interdepartmental coordination involved in VSP expansion, fiscal 

year funds could lapse when deployments are delayed and funds 

are not spent. Therefore, ICE proposed that VSP funding for FY 

2009 and beyond be designated as “no year funds.” Such funding 

would provide VSP with the flexibility to adjust to changing risks 

or opportunities at potential sites and to continue planned 

deployments after surmounting extended delays. We support this 

proposal. 

The deployment process for establishing a new VSU varies 

depending on whether ICE Operations has an established presence 

U.S. Immigration and Customs Enforcement Visa Security Program 

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at post. If ICE is not currently present at a post, the process 

requires more effort from ICE OIA headquarters. In the past, ICE 

OIA arranged for office furniture, computers, and system access at 

a new VSU post, but occasionally deployed VSU personnel prior 

to the arrival of the office equipment. Now, ICE OIA ensures 

office equipment has arrived prior to deploying VSU personnel. 

VSP sends a forward team of VSP headquarters or experienced 

VSU personnel from existing VSUs to establish the new VSU. 

The team sets up the VSU office space and works with DOS 

consular officers to define how visa security activities will be 

incorporated into the existing consular adjudication process at the 

post. 

Selecting and Deploying the Right Agents 

ICE OIA selects experienced agents with expertise in immigration 

and nationality law, investigations, document examination, 

counterterrorism, and intelligence research to serve in VSUs 

abroad. On average, agents have 10 years of law enforcement 

experience. VSP uses a competitive recruiting process to select the 

best-qualified candidates for VSU positions. The ICE OIA shift 

out of the ICE Office of Investigations removed an approval layer 

for selecting personnel, which has made the selection process 

faster for permanent positions. Once selected, the agent must 

complete DOS predeployment requirements and ICE VSU 

training, and be released by his or her current Special Agent in 

Charge before deploying to the assigned overseas post. 

VSP management expects many future VSU deployments will 

include locations in high security risk areas with difficult living 

conditions. These types of positions could be difficult to fill. A 

senior VSP official said the ICE Assistant Secretary recently 

approved an incentive package to help future recruiting efforts and 

ensure positions continue to be filled with the best qualified 

officers. ICE OIA is developing rules for the use of the incentives 

and, once approved, VSP will use incentives to recruit for hard-tofill positions as necessary. 

In addition to filling permanent VSU positions, VSP is building a 

pool of trained agents to be available for temporary duty 

assignments to cover leave, training, and gaps between permanent 

agents at any VSU. When VSP program managers identify a 

temporary duty assignment need, they query the pool of trained 

agents for interest and expected availability for the assignment. A 

VSP program manager then requests that the Special Agent in 

Charge of the selected agent’s permanent office release the agent 

U.S. Immigration and Customs Enforcement Visa Security Program 

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for temporary duty. To encourage Special Agents in Charge to 

release a VSU-trained agent for a temporary duty assignment, VSP 

requests that Special Agents in Charge agree to release an agent for 

a future VSU temporary duty assignment at the time the agent’s 

request to attend the ICE VSU training course is approved. 

Occasionally, due to domestic mission requirements, Special 

Agents in Charge of some offices have been unable to release 

VSU-trained agents for temporary assignments. VSP management 

said that so far, this has not been an issue and that program 

managers have been able to find other agents to fill the 

assignments. 

Visa Security Program Expansion Depends on Chief of 

Mission Approval 

VSP expansion is dependent on a post’s ambassador approving the 

addition of permanent employees to the post to perform visa 

security activities. During site assessment trips and the NSDD–38 

process, VSP officials interact with DOS officials to promote the 

program and respond to concerns about how the program will fit 

into the post’s mission. 

NSDD–38 requires that agencies seeking new positions at a post 

request approval for each new position from the post’s chief of 

mission. In making a decision, the ambassador considers DOS 

rightsizing efforts and security issues. He or she also weighs the 

post’s limited ability to host a larger workforce given space 

constraints—severe at many embassies—and competing requests 

from other agencies. 

Several DOS officials at VSU posts we visited said they have 

responded positively to questions from counterparts at other posts 

at which opening a new VSU was being considered. However, if 

an ambassador decides not approve a VSU at his or her post, the 

NSDD–38 could be denied at that post, even though Section 428 

authorizes the program at each visa-issuing diplomatic or consular 

post unless the DHS Secretary determines that assigning personnel 

to a specific post would not promote homeland security. Four 

chiefs of mission have denied VSP expansion to their respective 

posts. An agency can formally appeal an ambassador’s denial of 

an NSDD–38 request to the Secretary of State. ICE initiated 

formal NSDD–38 resolution procedures with the DOS Under 

Secretary for Management for one post in November 2005; the 

NSDD–38 request for that post was denied. Based on information 

received during this process, DHS did not formally appeal the 

NSDD–38 denial to the Secretary of State. We were told that ICE 

U.S. Immigration and Customs Enforcement Visa Security Program 

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has informally appealed other NSDD–38 denials as well. 

Regardless, both ICE and DOS headquarters officials said that in 

reality, the ambassador makes the final decision on expanding 

positions at post. 

Although word of mouth about VSP reportedly is becoming more 

positive by DOS overseas, DOS occasionally sets conditions on the 

VSU that fall outside of the parameters of the DHS-DOS 

memorandum of understanding. VSP officials said they continue 

to coordinate with DOS at these posts to address concerns and try 

to move forward with VSP expansion. 

Visa Security Program Should Enhance Performance 

Measurement 

Visa security activities performed by the VSUs produce a number of law 

enforcement and counterterrorism results, which are tracked and reported 

by VSP headquarters. VSP uses three methods to track and report 

program activities and performance, including the VSP Tracking System. 

While the VSP Tracking System facilitates VSU activities and tracks 

performance, the tracking system has limitations that keep VSP 

management from fully analyzing VSU activities. In addition, VSP 

management does not verify that agents’ entries are standardized and 

accurate. 

Visa Security Program Tracks and Reports Activities and 

Results 

VSU activities produce several law enforcement and 

counterterrorism results. For example, agents recommend refusal 

of visas, create lookouts and subject records in law enforcement 

and other government databases, and nominate individuals as 

appropriate for entry onto watchlists. In addition, ICE special 

agents assigned to VSUs identify trends and tactics used by 

potential terrorists or criminals, create intelligence reports, initiate 

investigations, support domestic ICE investigations, and remove 

inaccurate derogatory information from law enforcement systems. 

The VSP uses three primary methods to track and report VSU 

activities and performance. First, overseas VSU posts report 

significant cases and activities in weekly operational reports using 

the existing ICE operational reporting structure. As appropriate, 

significant VSU activities are included in reports to the Assistant 

Secretary. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Second, agents assigned to VSUs use TECS to record 

enforcement-related activities, including cases opened and closed, 

lookouts and subject records, reports of investigations, leads 

generated, and hours spent working on a variety of activities such 

as supporting existing investigations. Agents use VSU-specific 

codes to identify their activities in TECS as VSU activities. We 

were told that management officials are able to review VSU 

activities in TECS by individual VSU or by VSP as a whole, but 

that these reports are reviewed infrequently. 

Finally, because existing systems, such as TECS, could not support 

some of the operational requirements of VSP activities, VSP 

developed the VSP Tracking System. The VSP Tracking System 

facilitates routine automated screening functions related to visa 

applicants, allows agents to record their activities, and captures 

VSP performance data for analysis and reporting. 

VSP Tracking System Facilitates Activities; Records 

Performance 

ICE special agents use the VSP Tracking System to keep track of 

their activities; record comments, concerns, and the results of their 

screening and vetting activities; and report accomplishments. In 

addition, the VSP Tracking System includes tools that minimize 

manual work and data entry by agents. For example, using an 

automated tool in the DOS Consular Consolidated Database, ICE 

special agents at VSUs receive visa applicant data from the 

Consular Consolidated Database in the VSP Tracking System to 

begin the screening process. The VSP Tracking System then 

automatically converts the data into a new format allowing agents 

to export applicant data to TECS for screening. 

The applicant summary area of the VSP Tracking System 

automatically records the imported visa applicant data and the 

results of the DOS visa adjudication, including the consular 

officer’s interview comments and decision to approve or deny the 

visa. Agents record their screening and vetting activities and 

decision for each applicant in the vetting worksheet portion of the 

tracking system. The vetting worksheet provides sections for 

agents to record their activities, such as document review, system 

checks, or interviews, as well as a section for recording comments 

about their findings and resolution of alerts or derogatory 

information on an applicant. Finally, agents record their decision 

to recommend that a visa be approved or denied, and when denied, 

the reason for denial on the vetting worksheet within the VSP 

Tracking System. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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In addition, each VSU uses the VSP Tracking System to aggregate 

and create a monthly statistical report of its activities and 

performance metrics, which is sent to VSP headquarters. VSP 

headquarters officials said they review the monthly reports to 

assess and manage workload and staffing levels, track progress, 

and report performance to senior ICE officials and oversight 

entities. 

VSP Tracking System Limits Analysis of Visa Security Unit 

Activities 

Limitations of the VSP Tracking System keep VSP management 

and agents in the field from fully analyzing VSU activities. The 

VSP Tracking System is a stand-alone database at each VSU. ICE 

special agents at VSUs said that being able to view activities of 

other VSUs in the VSP Tracking System would better inform their 

own activities and make it possible to analyze trends and patterns 

across posts at the field level. Also, as stated earlier, it is difficult 

for VSP management to monitor or analyze the full range of VSU 

performance because VSP headquarters cannot access post data 

through the VSP Tracking System, and VSU monthly reports 

contain only aggregate data on selected performance measures. 

In addition, it is a significant impediment that the data file used by 

the VSP Tracking System at each post can hold only a finite 

number of records. Once the capacity of the data file is reached, 

the VSU creates another copy of the database. Depending on the 

volume of applicants at a given VSU—2,000 per day at one VSU; 

100 per day at another—VSUs reach the maximum number of 

records over different periods of time. Each VSU ultimately must 

maintain multiple versions of the database. VSU officials said 

they have identified trends and patterns at their posts, but that it 

was difficult to use the VSP Tracking System to conduct the 

analysis due to the fragmentation of their data among multiple 

copies of the database. 

Several VSP officials said they would like to see a tracking system 

that would allow both VSP headquarters and field personnel to 

access VSU data from all posts. A senior VSP official said that 

senior ICE officials should also be able to access the system. VSP 

headquarters officials said they are in the early stages of 

developing requirements for a new system; however, most VSU 

officials in the field said they did not know that a new system is 

planned. We agree that a new tracking system would benefit the 

operations and performance measurement of visa security 

U.S. Immigration and Customs Enforcement Visa Security Program 

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activities. Including the system’s end users in determining system 

requirements would help ensure the system will fulfill the needs of 

both headquarters and field personnel. 

We recommend that the Assistant Secretary for Immigration and 

Customs Enforcement: 

Recommendation #3: Develop and implement a global data 

system to allow recording, search, analysis, and storage of visa 

security activities from all Visa Security Units. The system should 

be accessible by headquarters and field personnel and should 

generate the reports that managers require to manage and improve 

the Visa Security Program. 

Visa Security Program Management Should Verify Standard 

and Accurate Recording of Visa Security Activities 

When VSP headquarters receives the monthly performance reports 

from each VSU, headquarters officials review the data for 

completeness. VSP officials said they ensure that all required 

fields are filled and that the statistics reported by each post do not 

appear to be significantly or unexpectedly different from that 

post’s reports for previous months. However, headquarters 

officials cannot be assured that posts are recording their activities 

accurately or in a standard manner 

ICE special agents receive training on the VSP Tracking System 

during the VSU training course. Included in the training is a 

discussion on recording screening and vetting activities and 

findings on the vetting worksheet. The August 2007 course, which 

we observed, briefly covered the fields on the vetting worksheet 

but did not explain specifically which fields should be checked for 

specific activities or how specific activities should be recorded. 

Rather, course participants were told they could use the “Help” 

button next to each field to see an explanation of when that field 

should be used. When we reviewed the help buttons on the vetting 

worksheet in the VSP Tracking System, several buttons did 

provide more detailed information on when to use the field, such as 

“In-Depth System Check.” Other buttons, such as “Cleared 

Applicant,” were not set up or were open to interpretation 

regarding when to use the field. 

At the VSUs we visited, agents provided slightly different 

explanations of where screening ends and vetting begins at each 

post. Some explanations differed from the explanation given at the 

VSU training course. According to the VSU training instructors, 

U.S. Immigration and Customs Enforcement Visa Security Program 

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screening ends after the initial TECS screening of visa applicants, 

and vetting begins when agents examine the applicant’s 

information or resolve concerns about the applicant. In addition, 

VSU field personnel said that different VSUs complete some fields 

in the vetting worksheet differently. For example, one VSU 

official said that three VSUs held a conference call and discovered 

that each had been completing the “Cleared Applicant” field 

differently. Their discussion clarified the purpose of the field. 

Different interpretations of vetting worksheet fields could lead to 

differences in how visa security activities are recorded, thus 

undermining the accuracy or reliability of the information. 

We also observed visa security activities being recorded differently 

at the VSUs we visited. For example, at one post, agents decided 

to record in the tracking system information only on recommended 

denials rather than all applicants who were vetted. At another post, 

several fields were set as defaults so they would always be checked 

on the vetting worksheet, such as “In-Depth System Check.” 

However, a VSU official at one post said that in-depth checks 

involved more extensive checks at one post and less extensive 

checks at another post. In addition, some posts added brief notes 

to explain findings and resolutions while others added notes much 

more sparingly. Neither method is incorrect; however, a more 

completely documented entry is generally more valuable. 

Detailed guidance for recording screening and vetting activities 

would set clear expectations of the information that should be 

entered in each field on the vetting worksheet. Such procedures 

also would decrease instances of individual posts determining how 

to record their activities and which activities to record. By 

establishing a process to verify that posts are following the 

guidance, VSP management would reduce any questions regarding 

the validity or reliability of VSP performance data. 

We recommend that the Assistant Secretary for Immigration and 

Customs Enforcement: 

Recommendation #4: Develop detailed guidance to clarify 

expectations for recording Visa Security Unit activities in the VSP 

Tracking System and to ensure all Visa Security Units record the 

same activity the same way. 

Recommendation #5: Disseminate and provide training on the 

guidance to Visa Security Unit personnel to implement and 

reinforce expectations for recording Visa Security Unit activities in 

the VSP Tracking System. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Recommendation #6: Develop and implement a plan to verify 

that ICE personnel are complying with expectations for and are 

accurately recording Visa Security Unit activities. 

Visa Security Officer Training Prepares Agents for Deployment 

Prior to deployment, ICE special agents attend the Visa Security Officer 

Training Program at the Federal Law Enforcement Training Center 

(FLETC). The course, which lasts 3 to 4 weeks, covers topics that prepare 

experienced special agents to deploy to VSUs at overseas posts. Topics 

include the visa process, counterterrorism, terrorist trends and tactics, 

fraudulent documents, national security law, interviewing techniques, and 

presentation skills. Students also receive hands-on instruction and practice 

on a variety of law enforcement information systems and the VSP 

Tracking System, including visa applicant screening and vetting 

procedures. The course concludes with a typical day scenario, which 

provides students the opportunity to practice visa security functions. 

Agents complete their training on the job after they arrive at their 

individual posts. 

VSP headquarters officials instruct course participants on visa applicant 

screening and vetting procedures and the VSP Tracking System. During 

the August 2007 course session, we observed in-depth coverage of visa 

applicant screening procedures from retrieving applicant information from 

the Consular Consolidated Database to screening applicants through TECS 

and receiving potential matches. 

However, instruction on vetting an applicant and accurately recording 

vetting results in the VSP Tracking System was covered in less depth. For 

example, multiple step-by-step examples of downloading applicant 

information from DOS and running the information through TECS were 

demonstrated, but instructors did not follow these examples through the 

vetting process or recording of results in the VSP Tracking System. 

Several course participants said that seeing course instructors complete the 

entire screening and vetting process for a few visa applicants before they 

began the typical day scenario would have been helpful. 

Both recent and past participants in the Visa Security Officer Training 

Program said the course is good preparation for performing VSP 

functions, and that VSP management has been responsive to suggestions 

for changes to future sessions of the course. For example, the August 

2007 session added training on interview techniques following suggestions 

from several past participants of the course. Several August 2007 trainees 

offered their suggestions for improving the course to VSP headquarters 

U.S. Immigration and Customs Enforcement Visa Security Program 

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officials both during a class session and in written evaluations at the end 

of the course. VSP headquarters officials were receptive to in-course 

suggestions provided by August 2007 participants. The officials said that 

several suggestions, such as increasing the time spent on the VSP 

Tracking System or spreading instruction on screening and vetting 

procedures more evenly throughout the course, were under consideration 

for future sessions. 

Based on suggestions of trainees and to address program changes and 

changing terrorist tactics, VSP management regularly adjusts the content 

of the course by adding or removing course sections. We were able to 

review binders containing the course curriculum for past sessions, but the 

course curriculum for the most recent session was undocumented. A VSP 

headquarters official said that personnel rotations resulted in the loss of 

electronic versions of past course curricula, and that VSP headquarters is 

in the process of updating and documenting the current course curriculum. 

A documented course curriculum, which includes the goals and objectives 

of each course section, would facilitate instructor and class speaker 

preparation. VSP should complete the documentation of the course 

curriculum and continue to update the curriculum as changes are made to 

future sessions. 

ICE special agents do not usually receive language training prior to 

deploying to an overseas post, as supported by Section 428. However, at 

the five VSU posts we visited, we observed that not having foreign 

language skills did not appear to hinder agent performance of visa security 

activities. At some posts, most interviews were conducted in English, or 

ICE had selected an agent with existing language skills for that country. 

At other posts, a consular officer or locally engaged staff member attended 

the interview and translated as necessary. In addition, senior VSP officials 

said that for posts requiring language skills, they either select an agent 

with existing skills or provide language training prior to deployment. 

In addition to the Visa Security Officer Training Program at FLETC, ICE 

special agents assigned to permanent positions at overseas posts attend 

ICE OIA Outbound Orientation prior to deployment. This 3-day session 

provides deploying ICE personnel with a series of briefings on ICE 

operations overseas, reporting requirements, what to expect when living 

overseas, and the administrative support they will receive from ICE OIA 

headquarters. The session also gives participants an opportunity to meet 

their individual country desk officers and ICE OIA mission support 

personnel. As required by DOS, permanently deploying ICE personnel 

also attend the DOS Safety Overseas Seminar, which addresses issues 

faced by U.S. officials living overseas. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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We recommend that the Assistant Secretary for Immigration and Customs 

Enforcement: 

Recommendation #7: Document the current course curriculum for the 

Visa Security Officer Training Course and update it as changes are made. 

Management Comments and OIG Analysis 

ICE responded to each of the recommendations in our draft report. See 

Appendix B for ICE’s response. Of the seven recommendations in our 

report, one recommendation is resolved and open; the remaining six 

recommendations are resolved and closed. 

In addition, we received two responses from DOS. The responses from 

the DOS Office of Policy, Rightsizing, and Innovation and the Bureau of 

Consular Affairs appear in full in Appendix C. We also received technical 

comments from the DOS Bureau of Diplomatic Security and have made 

changes to the report as appropriate. Our analysis of the DOS responses 

follows our analysis of ICE’s response to the report recommendations. 

Recommendation #1: Develop and implement a plan to monitor and 

analyze case-specific visa security activities conducted at post and their 

effect on Visa Security Program results. 

Summary of ICE Response: ICE concurred with this recommendation 

and discussed the development of a new, centralized, and globally 

accessible tracking system, which will allow for case-specific analysis at 

posts. The current tracking system will be maintained and updated until 

the new tracking system is developed. 

OIG Evaluation: We concur with ICE’s plan to include the ability to 

conduct case-specific analysis in the new tracking system under 

development, as well as ICE’s interim plan to monitor and analyze casespecific activities using the current tracking system. This recommendation 

is resolved and closed. No further reporting is necessary. 

Recommendation #2: Develop a detailed, factor-by-factor explanation of 

the process for analyzing the quantitative and qualitative factors in the site 

selection process from the initial risk analysis through site selection, 

including source(s) for each factor and how the score for each factor is 

calculated. 

Summary of ICE Response: ICE concurred with this recommendation. 

ICE VSP has reviewed the site selection process, making changes to the 

categories and criteria included and refreshing data. This process will 

U.S. Immigration and Customs Enforcement Visa Security Program 

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occur at the end of each fiscal year. ICE will continue to use wellestablished information sources, and will incorporate classified 

information into the selection process as appropriate. In addition, VSP is 

coordinating with the DOS Office of the Coordinator for Counterterrorism 

to further refine the site selection process. 

OIG Evaluation: We concur with the actions taken by ICE. This 

recommendation is resolved and closed. No further reporting is necessary. 

Recommendation #3: Develop and implement a global data system to 

allow recording, search, analysis, and storage of visa security activities 

from all Visa Security Units. The system should be accessible by 

headquarters and field personnel and should generate the reports that 

managers require to manage and improve the Visa Security Program. 

Summary of ICE Response: ICE concurred with the recommendation. 

ICE has allocated funding to develop a centralized and globally accessible 

tracking system. ICE VSP is working with the ICE Office of the Chief 

Information Officer to develop the new tracking system. 

OIG Evaluation: We concur with ICE’s actions to begin development of 

a centralized and globally accessible tracking system. This 

recommendation is resolved, but will remain open pending the completion 

of the new tracking system. 

Recommendation #4: Develop detailed guidance to clarify expectations 

for recording Visa Security Unit activities in the VSP Tracking System 

and to ensure all Visa Security Units record the same activity the same 

way. 

Summary of ICE Response: ICE concurred with the recommendation. 

In September 2007, ICE VSP sent guidance clarifying visa security 

activity recording procedures and expectations to all VSU posts. 

OIG Evaluation: We have reviewed the September 2007 guidance, and 

concur that it clarifies recording procedures and VSP headquarters 

expectations. This recommendation is resolved and closed. No further 

reporting is necessary. 

Recommendation #5: Disseminate and provide training on the guidance 

to Visa Security Unit personnel to implement and reinforce expectations 

for recording Visa Security Unit activities in the VSP Tracking System. 

Summary of ICE Response: ICE concurred with the recommendation. 

In addition to the guidance sent to posts in September 2007, ICE VSP 

distributed detailed screen shots from the VSP Tracking System that 

U.S. Immigration and Customs Enforcement Visa Security Program 

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instruct VSU personnel on how to accurately record VSU activities. In 

addition, ICE VSP is incorporating a step-by-step training module into the 

VSO Training Program at FLETC. 

OIG Evaluation: We concur with the actions taken by ICE. This 

recommendation is resolved and closed. No further reporting is necessary. 

Recommendation #6: Develop and implement a plan to verify that ICE 

personnel are complying with expectations for and are accurately 

recording Visa Security Unit activities. 

Summary of ICE Response: ICE concurred with this recommendation. 

As part of its Site Inspections Program, ICE OIA will conduct regular 

checks to identify tracking inconsistencies and provide necessary 

guidance. 

OIG Evaluation: We concur with ICE’s action plan. This 

recommendation is resolved and closed. No further reporting is necessary. 

Recommendation #7: Document the current course curriculum for the 

Visa Security Officer Training Course and update it as changes are made. 

Summary of ICE Response: ICE concurred with the recommendation 

and described steps taken to update the course curriculum and to ensure 

that future curriculum changes are made as necessary. 

OIG Evaluation: We concur with the actions taken by ICE. This 

recommendation is resolved and closed. No further reporting is necessary. 

Analysis of the Department of State Responses 

We appreciate receiving responses to our report from DOS. We note that 

we invited DOS OIG to participate in this review; however, after 

participating in our interviews during our first VSU site visit, DOS OIG 

decided not to participate further in the review. Therefore, we limited the 

scope of our review to ICE activities with regard to the VSP. 

Because ICE special agents interact regularly with DOS personnel and 

processes when performing VSP activities, we attempted to provide basic 

descriptions of the various programs and DOS personnel with which ICE 

special agents interact. We acknowledge that many of the DOS programs 

and personnel have responsibilities beyond what we describe; however, 

we chose to discuss activities relevant to interactions between ICE and 

DOS with regard to the VSP. To review DOS programs or personnel 

would be outside of our authority. 

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Office of Policy, Rightsizing, and Innovation 

The DOS Office of Policy, Rightsizing, and Innovation expressed concern 

with the VSP Five-Year Expansion Plan and that DOS had not had the 

opportunity to review the plan. Much of the plan is summarized in pages 

15-18 of our report. The ICE Assistant Secretary, DHS headquarters, the 

White House Homeland Security Council, and the Office of Management 

and Budget have reviewed and approved the plan. In March 2007, the 

plan was delivered to DOS Consular Affairs, and in July 2007, it was 

delivered to the DOS Office of the Coordinator for Counterterrorism for 

review. 

The office also indicated that it believed our report should have provided 

specifics about the posts at which DHS wished to open visa security units 

but where DOS disagreed. While we believe our report describes the 

issue, we do not want to insert ourselves into the specifics of debates 

which occurred in the past. Neither do we agree with the proposition 

expressed in their response that a visa waiver country is necessarily 

outside the scope of the visa security program. Many visas are processed 

in visa waiver countries, including to third-country nationals from 

countries of concern. 

Policy, Rightsizing, and Innovation also expressed concern with involving 

DOS employees in the interview process “who are not allowed access to 

the information contained in the database that precipitated and supports 

the interview requirement.” First, ICE special agents may decide to 

interview a visa applicant based on information from sources other than 

TECS. Second, at most VSUs, ICE special agents must explain to the 

consular officer or section chief why they want to bring the visa applicant 

in for an interview. ICE special agents assigned to one VSU were not 

allowed to conduct their interview with the visa applicant; rather, the 

adjudicating consular officer was required to conduct the interview while 

the ICE special agent observed. At most other VSUs we visited, if 

language translation was necessary, the ICE foreign service national 

investigator assisted, not DOS locally engaged staff. 

Finally, the Office of Policy, Rightsizing, and Innovation wrote that DHS 

assigns “personnel who are not authorized to perform the depth and 

variety of responsibilities that would facilitate immigration and refugee 

decisions....” This complaint, which we have also heard in the field, 

suggests a misunderstanding of the structure of DHS. The work that was 

formerly performed by the U.S. Immigration and Naturalization Service is 

now performed by three organizations: U.S. Citizenship and Immigration 

Services, ICE, and U.S. Customs and Border Protection. Employees of 

any one component are neither authorized nor properly trained to perform 

functions that fall within the purview of the other two. DHS employees 

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who can perform only a limited variety of immigration responsibilities are 

a result of the legislation that created the department. 

Alternatively, Consular Affairs believes ICE VSP has inappropriately 

expanded the roles and authorities of agents assigned to VSUs. All ICE 

special agents are authorized to enforce specific areas of law and maintain 

these responsibilities when posted overseas. Agents assigned to VSUs 

also maintain these authorities, but are required to spend at least 80% of 

their time on visa security activities. 

Bureau of Consular Affairs 

Consular Affairs provided comments on several areas of our report. 

Where appropriate, we have made changes to the language of our report. 

Our analysis of their comments follows. 

Consular Affairs suggests that we make a recommendation that DHS 

prioritize the NSDD–38 requests of its various components, including 

ICE. This has been occurring since 2004. DHS Management Directive 

3400 requires that all DHS component requests for new positions abroad 

be approved by the DHS Deputy Secretary before they are submitted to 

the Department of State. 

Consular Affairs’ belief that we imply the chief of mission decides 

whether to approve a VSU at post based on personal preferences indicates 

a misreading of our report. Pages 8 and 20-21 of our report shows that we 

indicate agencies seeking new positions at post must request approval 

from the post’s chief of mission using the NSDD–38 process. We also 

note a number of criteria the chief of mission considers in determining 

whether to approve the request, including space, costs, and security issues. 

However, as DOS headquarters and post personnel, ICE OIA personnel, 

and even the Consular Affairs response indicate, VSP expansion does, in 

fact, depend on chief of mission approval. VSP management continues to 

collaborate with DOS in gaining the chief of mission’s approval as it 

expands the program to additional locations. 

Consular Affairs also questions our statement that “DOS occasionally sets 

conditions on the VSU that fall outside of the parameters of the DHS-DOS 

memorandum of understanding.” The DHS-DOS memorandum of 

understanding delineates the roles and responsibilities of both departments 

regarding the visa issuance process and visa security activities, as well as 

their coordination at overseas posts. However, at least two posts 

attempted to establish separate agreements outlining how the process 

would work and how the two departments would coordinate at those posts. 

VSP officials worked with DOS officials at each post to resolve the issues 

and successfully opened VSUs at both posts. As we note on page 27, ICE 

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provides language training or selects an agent with pre-existing language 

skills for those posts with specific language requirements. 

Consular Affairs interpreted our original draft language relating to start-up 

difficulties to imply that DOS had not provided necessary office 

equipment to new VSUs. We have reworded the discussion of ICE OIA’s 

deployment process on page 19 of our report to avoid confusion. 

Consular Affairs also expressed concern with the VSP mission and goals 

and with the program’s explanation of how law enforcement expertise is 

applied to the visa process. Consular Affairs states that the VSP mission 

and goals expand its authority beyond Section 428. We disagree with this 

assertion. A program’s mission statement typically goes beyond quoting 

the specific language of the law authorizing the program. VSP’s mission 

and strategic goals can be tied to the language of Section 428. We did not 

observe ICE special agents assigned to VSUs or VSP headquarters 

expanding the scope of their authorities during our fieldwork. As noted 

earlier, ICE special agents are authorized to enforce several U.S. statutes, 

and they draw on these and their law enforcement experience in screening 

and vetting visa applicants, creating lookouts, and initiating investigations 

in the performance of their visa security responsibilities. 

ICE special agents assigned to VSUs do not adjudicate visa applications. 

They screen and vet visa applicants and evaluate eligibility from the DHS 

perspective, and then recommend approval or denial to the adjudicating 

consular officer. In addition, VSP management approves each post’s case 

selection guidelines. At VSUs we visited, several consular officers 

indicated a general understanding of the types of applicants the VSU 

would be interested in vetting. 

Consular Affairs indicated that a major impediment to program expansion 

is “a lack of persuasive evidence of the value of the program.” While VSP 

management has tracked a variety of performance measures, reports have 

not been produced to show how specific activities performed by agents at 

post have resulted in specific outcomes. We recommend that VSP 

develop and implement a plan to conduct such analysis in 

Recommendation 1 of our report. 

Consular Affairs implies that consular officers conduct the same type of 

screening and vetting that ICE special agents assigned to VSU perform. 

This is not the case. ICE agents conduct much more in-depth checks on 

visa applicants than do consular officers. For example, consular officers 

run system checks on the visa applicant’s name only; ICE agents would 

also run system checks on additional information provided on the visa 

application itself, such as associates or addresses. 

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Consular Affairs also suggests that VSP should conduct the automated 

screening activities domestically and incorporate the screening into the 

SAO process. As noted in our report, we disagree. The initial screening 

could technically be done from anywhere—as could the name-checking 

performed by consular officers—but the vetting process requires that 

agents be assigned to post in order to have access to the applicant and the 

application documents. In addition, VSUs screen 100% of nonimmigrant 

visa applicants and many also screen at least a portion of immigrant visa 

applicants. To incorporate this into the SAO process would essentially 

require an SAO for every visa applicant, which would create significant 

delays to the consular visa adjudication process. 

Consular Affairs indicated a desire to receive reports on VSU activities 

and access to the new tracking system being developed by the VSP and we 

fully support that request. VSP management said they plan to provide 

access to additional parties, including relevant DOS personnel. We expect 

VSP management will continue to collaborate with DOS in this area. We 

do not believe the recommendation needs to be reworded. 

Consular Affairs also indicated concern that some information on 

terrorists or criminals is not automatically transferring from TECS into the 

Consular Lookout and Support System. TECS is not simply a database of 

law enforcement information on terrorists and criminals. It also serves as 

a case management system for ICE and, therefore, contains information on 

sensitive active investigations and ongoing cases. Information on open 

investigations would not be routinely released to outside systems. 

Consular Affairs said there is a “common understanding” that a significant 

portion of VSU denial recommendations are not terrorism related. VSP 

management recently required VSU personnel to begin recording the 

reason for denial recommendations in the VSP Tracking System when 

they recommend that a specific visa application be denied. As Consular 

Affairs noted earlier in its comments, the process of adjudicating visa 

applications is “firmly grounded in law” and is the responsibility of 

consular officers. However, it could be useful if the immigration 

professionals in a Visa Security Unit sometimes convey non-terrorist 

information they develop to consular officers, who then properly deny an 

application they might otherwise have approved. 

Consular Affairs indicated they had seen few examples of VSU personnel 

providing expert advice and training on specific security threats. Section 

428(e)(2)(A) refers to security threats “relating to the adjudication of 

individual visa applications or classes of applications.” As we discuss in 

our report, terrorists use fraudulent means to attempt to gain entry into the 

United States. VSU personnel have provided training to consular officers 

to improve their ability to detect instances of such fraud, including how to 

U.S. Immigration and Customs Enforcement Visa Security Program 

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identify imposters and fraudulent documents. They have also provided 

advice, as appropriate, to consular officers at specific posts where fraud 

trends in specific visa categories have been identified. VSU personnel 

report the number and topics of training provided as well as the number of 

attendees in their monthly reports to VSP headquarters. 

Consular Affairs also questioned the extent to which ICE special agents 

assigned to VSUs have expertise or training in counterterrorism. In 

selecting agents for assignment to VSUs, ICE OIA selects agents with 

experience in counterterrorism as well as immigration and other areas. On 

average, agents assigned to VSUs have 10 years of law enforcement 

experience. In addition, agents receive counterterrorism briefings as part 

of the Visa Security Officer Training Program they attend at FLETC prior 

to deploying to a VSU. 

Consular Affairs suggested adding terrorist threat indicators to the initial 

risk assessment for site selection. As noted above, VSP program 

managers regularly review and update the initial risk assessment, adding 

and removing fields as appropriate. We do not believe an additional 

recommendation is necessary. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix A 

Purpose, Scope, and Methodology 

We reviewed the ICE Visa Security Program in response to DOS 

OIG concerns of possible overlaps of responsibility between DHS 

and DOS personnel at embassies where both are present. 

Specifically, the objectives of our review were to determine 

whether: (1) ICE’s management of VSP policies, procedures, and 

existing operations is effective and efficient; (2) the interaction and 

coordination at U.S. embassies among ICE special agents, DOS 

regional security officers, and DOS consular officers is effective 

and without overlaps in responsibilities; (3) the presence of ICE 

special agents has affected visa security; (4) ICE special agents 

need to be assigned overseas to perform VSP activities; and (5) 

VSP training adequately prepares ICE special agents to perform 

VSP duties. Finally, we examined VSP expansion plans to 

determine whether the process for selecting new sites is prioritized 

appropriately given the limited resources available for expansion. 

We reviewed statutes, regulations, and memoranda of 

understanding related to the VSP. We also reviewed strategic 

plans, expansion plans, weekly reports, monthly reports and 

performance data, budget records, and training materials. We 

examined VSP procedures, guidance, and case files. 

We conducted more than 85 interviews of more than 95 officials 

within DHS OIA, ICE OIA, and DOS at headquarters and overseas 

posts. We conducted overseas site visits to VSU posts in Manila, 

Philippines; Islamabad, Pakistan; Abu Dhabi, United Arab 

Emirates; Dubai, United Arab Emirates; and Cairo, Egypt. In 

addition to interviews at posts, we observed the consular visa 

process and VSU visa security activities. DOS OIG personnel 

participated in our interviews during our first VSU site visit. 

We audited the Visa Security Office Training Program at FLETC 

in Glynco, Georgia during August 2007. We observed a VSP 

briefing to a DOS consular class at the DOS Foreign Service 

Institute. Finally, we observed an ICE OIA Outbound Orientation 

session for ICE agents deploying to overseas posts. 

Fieldwork began in March 2007 and ended in November 2007. 

This 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 Efficiency. 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix C 

Department of State Comments to the Draft Report 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix C 

Department of State Comments to the Draft Report 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

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Appendix C 

Department of State Comments to the Draft Report 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix D 

Major Contributors to this Report 

Douglas Ellice, Chief Inspector 

Jennifer A. Lindsey, Inspector (Team Leader) 

 Susan Fischer, Inspector 

 Razili Datta, Inspector 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

 Assistant Secretary for Immigration and Customs Enforcement 

ICE OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

U.S. Immigration and Customs Enforcement Visa Security Program 

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Appendix E

Report Distribution 

Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web 

site at www.dhs.gov/oig. 

OIG Hotline 

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

criminal or noncriminal misconduct relative to department programs or 

operations: 

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

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

• Email us at DHSOIGHOTLINE@dhs.gov; or 

•	 Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, Attention: 

Office of Investigations - Hotline, 245 Murray Drive, SW, Building 410, 

Washington, DC 20528, 

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