Department of Homeland Security 

Office of Inspector General 

Information Sharing 


on Foreign National: 


Overseas Screening 


(Redacted)
 

OIG-11-68 April 2011 
April 7, 2011

Office ofInspector General

U.S. Department of Homeland Security

Washington, DC 25028

Homeland

Security

Preface

The Department ofRomeland Security (DRS) Office oflnspector General (OIG) was

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

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

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

efficiency, and effectiveness within the department.

This report addresses the strengths and weaknesses of DRS information sharing on

foreign nationals overseas. 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. We

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

express our appreciation to all ofthose who contributed to the preparation ofthis report.

(}f~ J.L, k. ~~ K. Edwards

Acting Inspector General
Table of Contents/Abbreviations 

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

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

Results of Review ..............................................................................................................16
 

Valuable DHS Information-Sharing Initiatives Represent Progress, But 


Integration Is Advancing Slowly ........................................................................17 


Recommendations........................................................................................................21 


Recommendations........................................................................................................24 


Recommendation .........................................................................................................25 


Management Comments and OIG Analysis ................................................................25 


NTC-P Can Improve Effectiveness by Improving Working Conditions .....................29 


Recommendation .........................................................................................................32 


Recommendation .........................................................................................................34 


Recommendations........................................................................................................36 


Recommendations........................................................................................................38 


Management Comments and OIG Analysis ................................................................38 


Existing Small-Scale Vetting and Interdiction Programs Are Effective and Merit 


Expansion............................................................................................................43 


Recommendation .........................................................................................................45 


Recommendation .........................................................................................................47 


Recommendation .........................................................................................................49 


Management Comments and OIG Analysis ................................................................49 


DHS Officers Need Assistance Navigating Fragmented Data Systems ......................51 


Recommendations........................................................................................................54 


Recommendation .........................................................................................................56 


Management Comments and OIG Analysis ................................................................56 


Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................59 


Appendix B: Management Comments to the Draft Report .......................................61 


Appendix C: Authorities for Information Sharing on Foreign Nationals ..................74 


Appendix D: Visa Waiver Program Countries ..........................................................77 


Appendix E: DHS Data Systems...............................................................................78 


Appendix F: Major Contributors to this Report........................................................89 


Appendix G: Report Distribution ..............................................................................90 


Information Sharing on Foreign Nationals: Overseas Screening 


Page i
 
 

Abbreviations 

ADIS Arrival and Departure Information System 

APIS Advance Passenger Information System 

ATS-P Automated Targeting System – Passenger 

ATT Advance Targeting Team 

BASS Biometrics-at-Sea System 

CBP U.S. Customs and Border Protection 

CDC Centers for Disease Control and Prevention 

CIO Chief Information Officer 

CIS Central Index System 

CLAIMS3 Computer-Linked Application Information Management System 3 

CLAIMS4 Computer-Linked Application Information Management System 4 

DHS Department of Homeland Security 

EARM Enforce Alien Removal Module 

ENFORCE Immigration Enforcement Operational Records System 

ESTA Electronic System for Travel Authorization 

FBI Department of Justice Federal Bureau of Investigation 

FLETC Federal Law Enforcement Training Center 

FY Fiscal Year 

HRM Human Resources Management 

HSIN Homeland Security Information Network 

IAP Immigration Advisory Program 

ICE U.S. Immigration and Customs Enforcement 

ICE-PIC ICE Pattern Analysis and Information Collection System 

IDENT Automated Biometric Identification System 

ISRS Image Storage and Retrieval System 

NTC-P National Targeting Center - Passenger 

OIG Office of Inspector General 

PNR Passenger Name Record 

RAPS Refugees, Asylum, and Parole System 

SEVIS Student and Exchange Visitor Information System 

TDY Temporary Duty 

TECS TECS (not an acronym) 

TSA Transportation Security Administration 

TSC Terrorist Screening Center 

TSDB Terrorist Screening Database 

TWIC Transportation Worker Identification Credential 

USCG U.S. Coast Guard 

USCIS U.S. Citizenship and Immigration Services 

US-VISIT U.S. Visitor and Immigrant Status Indicator Technology 

VWP Visa Waiver Program 

Information Sharing On Foreign Nationals: Overseas Screening 


Page ii
 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Department of Homeland Security has implemented several 

programs to screen foreign nationals while they are still overseas. 

These programs rely on biographical, biometric, and documentary 

information in the department’s and other federal data systems. We 

evaluated whether levels of cooperation, resources, and technology 

were adequate for department officers to assess the risks posed by 

foreign nationals who seek to enter the United States. We also 

reviewed plans to consolidate and improve information in the 

department’s data systems. 

The department has made progress in evaluating admissibility of 

foreign nationals before they travel to the United States. The level of 

cooperation among components that conduct overseas screening is 

high. Headquarters support offices have long-term plans to streamline 

access to information in the department’s data systems, and improve 

screening and data analysis capabilities. 

However, Department of Homeland Security initiatives face serious 

resource and technological challenges. Information is fragmented 

among more than 17 data systems, and officers must conduct laborintensive, system-by-system checks to verify or eliminate each 

possible match to terrorist watch lists and other derogatory 

information. The U.S. Customs and Border Protection National 

Targeting Center – Passenger is the operational core of the 

department’s overseas screening efforts. The center is challenged by 

insufficient staff and difficult working conditions. Effective smallscale screening and interdiction programs need sufficient resources to 

meet operational needs and congressional mandates. We are making 

18 recommendations to standardize the technology used to share 

information in departmental data systems, enable federal officers to 

obtain and use the most current and complete data available, and 

improve information sharing procedures. Departmental components 

concurred with 17 of the 18 recommendations. However, for five 

recommendations with which components concurred, including three 

that would increase productivity for thousands of DHS employees, 

components said that they would need to request additional resources 

in the next federal budget cycle to implement the recommendations. 

Information Sharing on Foreign Nationals: Overseas Screening 


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Background 

On December 25, 2009, Umar Farouk Abdulmutallab, a Nigerian 

national, presented a valid U.S. visa to Dutch authorities and 

boarded Northwest Flight 253 from Amsterdam to Detroit. 

Abdulmutallab was not on the Terrorist Screening Database 

(TSDB) no fly or selectee lists, and was permitted to board. 

However, officers in Detroit were directed to conduct further 

screening on arrival because U.S. Customs and Border Protection 

(CBP) noted en route derogatory information that had been 

transmitted from the State Department to its data systems.1 During 

the flight, Abdulmutallab attempted to detonate explosives carried 

on his person. The size and complexity of the Department of 

Homeland Security (DHS) preflight screening program expanded 

in response to the December 2009 bombing attempt, with more 

scrutiny of travelers and upgraded preflight screening software. 

The capability of DHS to identify and prevent threats depends on 

technologies that can access and evaluate information rapidly. 

DHS recognized the importance of accurate and timely information 

sharing well before these incidents occurred. On February 1, 2007, 

the DHS Secretary instructed DHS components to give “the 

highest priority to the sharing of potential terrorism, homeland 

security, law enforcement, and related information” and to 

“standardize the technology used to describe, access, exchange, 

and manage information in our automated systems.”2 On July 2, 

2009, the White House reiterated this message in a memorandum 

to all Cabinet-level federal agencies, and said that achieving 

“effective information sharing and access” was a top priority. The 

memorandum noted that “[s]ignificant progress has been made in 

recent years. ... But there is more work to be done.”3 

This report focuses on only one aspect of information sharing: 

DHS efforts to screen foreign nationals while they are still 

overseas. We will review other facets of information sharing on 

foreign nationals, specifically border security and domestic 

programs, in separate reports. However, this report discusses some 

1

 Statement of Janet A. Napolitano, Secretary, United States Department of Homeland Security, United 

States Senate Committee on Homeland Security and Governmental Affairs, January 20, 2010.

2

 Memorandum from DHS Secretary Michael A. Chertoff to All Department of Homeland Security 

Components, DHS Policy for Internal Information Exchange and Sharing, February 1, 2007. 3

 Memorandum from John O. Brennan, Assistant to the President for Homeland Security and 

Counterterrorism, to cabinet level officials, Strengthening Information Sharing And Access, July 2, 2009. 

Information Sharing On Foreign Nationals: Overseas Screening 


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more general issues related to DHS data systems. Addressing 

these issues may improve information sharing in areas beyond the 

screening of foreign nationals while they are overseas. 

Information sharing within DHS on foreign nationals is the 

responsibility of five of the seven major DHS operational 

components, as well as support offices. (See Figure 1.) The 

operational components are CBP, U.S. Citizenship and 

Immigration Services (USCIS), U.S. Coast Guard (USCG), U.S. 

Immigration and Customs Enforcement (ICE), and Transportation 

Security Administration (TSA), each of which is actively involved 

in sharing information throughout DHS and with other federal, 

state, local, and tribal partners. There are four support offices with 

a role in information sharing: 

�	 The Counterterrorism Section in the Office of Operations 

Coordination and Planning; 

�	 The Office of Policy, which includes the Screening 

Coordination Office, the Office of International Affairs and 

the Office of Policy Development; 

�	 The Border and Immigration Analysis Division in the Office 

of Intelligence and Analysis; and 

�	 The U.S. Visitor and Immigrant Status Indicator 

Technology (US-VISIT) Program in the National Protection 

and Programs Directorate. 

In addition, there are two support offices with a role in DHS data 

systems integration: 

�	 The Information Sharing Intelligence Enterprise 

Management Division in the Office of Intelligence and 

Analysis; and 

�	 The Office of Chief Information Officer in the Office of 

Management. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Figure 1: DHS Components Responsible for Information Sharing on 

Foreign Nationals 

Source: Office of Inspector General (OIG) 

In the past decade, the U.S. government has expanded its legal 

authority to screen foreign nationals while they are overseas. This 

authority allows the State Department and DHS to collect and 

share biographical, biometric, and documentary information on 

foreign nationals who apply for a visa or seek to travel to the 

United States. Legal authorities for sharing information on foreign 

nationals are listed in Appendix C, and include the following: 

�	 Aviation and Transportation Security Act of 2001: adds 

mandatory manifest and passenger name record and other 

aviation screening requirements.4 

�	 Enhanced Border Security and Visa Entry Reform Act of 2002: 

requires biometric-based visas and travel documents, electronic 

transmission of passenger manifests, and DHS tracking of 

foreign students.5 

4 P.L. 107-71. 

5 P.L. 107-173. 

Information Sharing On Foreign Nationals: Overseas Screening 


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�	 Homeland Security Act of 2002: provides the DHS Secretary 

authority to access all information related to threats against the 

United States, and to assign DHS officers to high-risk 

consulates to review visas.6 

�	 Intelligence Reform and Terrorism Prevention Act of 2004: 

requires in-person interviews for most visas, Immigration 

Advisory Program officers to be located at foreign airports, 

integration of DHS and other federal data systems, and DHS 

control of preflight watch list screenings (Secure Flight).7 

�	 Implementing Recommendations of the 9/11 Commission Act of 

2007: requires Visa Waiver Program countries to share 

information on threats and on lost and stolen passports. 

Applicants from a Visa Waiver Program country must obtain 

an Electronic System for Travel Authorization (ESTA) 

approval before they travel to the United States.8 

DHS screening programs require access to information collected and 

maintained in a range of databases and data systems. These include 

databases from other federal agencies, for example: 

�	 The Department of State, which tracks information on visa 

applicants; 

�	 The Department of Justice Federal Bureau of Investigation 

(FBI), which tracks known and suspected terrorists and known 

criminals, also leads the interagency Terrorist Screening Center 

(TSC), which maintains the consolidated TSDB watch list of 

known and suspected terrorists; and 

�	 The Centers for Disease Control and Prevention (CDC), which 

tracks individuals with diseases that would pose a serious 

health threat to fellow air travelers. 

Screening programs also include DHS data systems, ranging from systems 

developed in the 1980s to modern specialized single-purpose systems, 

which manage information on specific categories of foreign nationals, 

such as students and Visa Waiver Program applicants. We identified 17 

major DHS data systems that manage information on international travel 

and the status of foreign nationals. Systems that manage information on 

international travel include both U.S. citizens and foreign nationals. 

Systems that manage information on foreign nationals can include 

individuals who have obtained, or could in the future obtain, lawful 

6 P.L. 107-296. 

7 P.L. 108-458. 

8 P.L. 110-53. 

Information Sharing On Foreign Nationals: Overseas Screening 


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permanent resident status, or citizenship through naturalization. (See 

Figure 2 and Appendix E.) 

Information Sharing On Foreign Nationals: Overseas Screening 


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Figure 2: DHS Systems For Travel And Immigration Screening 

DHS INFORMATION SYSTEMS 

Owner Manages Information On Foreign Nationals (who may become US citizens) 

US-VISIT ADIS 

�� Arrival and Departure Information System 

�� Collects, matches, and reports on U.S. arrivals and departures 

USCIS CIS 

�� Central Index System 

�� Documents status of applicants/petitioners seeking immigration benefits 

USCIS CLAIMS3 

�� Computer-Linked Application Information Management System 3 

�� Tracks immigrant and nonimmigrant applications / petitions 

USCIS CLAIMS4 

�� Computer-Linked Application Information Management System 4 

�� Tracks naturalization applications 

ICE EARM 

�� Enforce Alien Removal Module 

�� Tracks detained aliens, aliens in removal proceedings, and case histories 

ICE ENFORCE 

�� Immigration Enforcement Operational Records System 

�� Tracks immigration enforcement actions and cases 

CBP ESTA 

�� Electronic System for Travel Authorization 

�� Screening mechanism for applications from visa waiver travelers for travel 

authorization 

US-VISIT IDENT 

�� US-VISIT Automated Biometric Identification System 

�� Enrolls and stores biometrics of foreign nationals 

USCIS ISRS 

�� Image Storage and Retrieval System 

�� Provides query and retrieval of biometric image sets, biographical data 

USCIS RAPS 

�� Refugees, Asylum, and Parole System 

�� Tracks affirmative applicants for asylum status 

ICE SEVIS 

�� Student and Exchange Visitor Information System 

�� Tracks and monitors students, exchange visitors, and dependents 

Manages Information on Travelers (including US citizens) 

CBP APIS 

�� Advance Passenger Information System 

�� Transmits air and sea passenger manifests 

TSA Secure Flight 

�� Secure Flight 

�� Watch list matching for flights into, out of, within, and over the United States 

Aggregates / Analyzes Information 

CBP ATS-P 

�� Automated Targeting System – Passenger 

�� Provides an enforcement and decision support tool 

ICE ICE-PIC 

�� ICE Pattern Analysis and Information Collection System 

�� Provides an information analysis tool 

ICE Intel Fusion / Avalanche 

�� Intel Fusion / Avalanche / Virtual Investigative & Intelligence System 

�� Provides access to TECS, ENFORCE, encounters, and arrests 

Manages Law Enforcement Information (including US citizens) 

CBP TECS 

�� TECS (not an acronym) 

�� Collects, analyzes, and shares law enforcement information 

Source: Database documentation, demonstrations 

Information Sharing On Foreign Nationals: Overseas Screening 


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DHS Screens Air And Sea Passengers Pre-departure 

DHS initiates extensive screening of airline passengers before they 

board, and the process continues while they are en route to the 

United States. Screening is conducted with information passengers 

provide as they make reservations, purchase tickets, and check in 

for travel. Screening is also conducted on flight crews, including 

cargo flights. Figure 3 lists the minimum information that must be 

provided to DHS and the deadlines to provide the information for 

air travel. 

During the period of our review, Secure Flight was operational and 

had begun deploying to U.S. aircraft operators and foreign air 

carriers. As of June 22, 2010, Secure Flight completed 

deployment for all U.S. aircraft operators’ domestic and 

international flights. As of November 23, 2010, Secure Flight 

completed deployment to all covered foreign air carriers originally 

scheduled for implementation. Secure Flight requires airlines to 

collect and submit passengers’ full name (as it appears on the 

government-issued identification they plan to use when traveling), 

date of birth, gender, and, if available, a Redress Number for 

travelers whose names are a false positive match to information on 

the TSDB watch list. For reservations made prior to 72 hours 

before departure, aircraft operators are required to transmit Secure 

Flight Passenger Data to TSA at approximately 72 hours before 

departure time. For reservations made within 72 hours of 

departure time, aircraft operators are required to submit Secure 

Flight Passenger Data as soon as the reservation is made. Secure 

Flight is designed to perform real-time matching for all flights, 

including next-day or same-day flights. Based on the results of the 

watch list matching process, cleared passengers will be able to 

receive a boarding pass. If a passenger is identified as a Selectee, 

they will receive a boarding pass that designates them for enhanced 

screening at the security checkpoint prior to boarding the aircraft. 

If the aircraft operator receives an “Inhibited” response for a 

passenger, the aircraft operator cannot issue a boarding pass for 

that passenger to board the aircraft and TSA will facilitate the 

notification of the appropriate law enforcement authorities.9 

The deadlines for submitting advance passenger information 

depend on the method of transmission. Carriers that do not submit 

passenger manifests electronically must make a batch submission 

9 49 CFR Parts 1540, 1544, and 1560, Secure Flight Program; Final Rule, Federal Register, Volume 73, 

Number 209, Tuesday, October 28, 2008. 

Information Sharing On Foreign Nationals: Overseas Screening 


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of passengers checked in for the flight and receive a non-electronic 

response from DHS on whether the passengers are cleared. 

Carriers may, with CBP certification, transmit manifest 

information electronically through a transmission system 

configured for batch transmissions and receive an electronic 

response from DHS systems on whether the passengers are cleared. 

Both manual and electronic batch submissions must be completed 

no later than 30 minutes before departure. Carriers may also, with 

CBP certification, transmit manifest information on individual 

passengers as they check in for a flight and receive an electronic 

response from DHS systems on whether each individual passenger 

has cleared. Information may be sent to CBP via this method, 

known as Advance Passenger Information System (APIS) Quick 

Query, until the doors of the aircraft are secured. (See APIS 

graphic in Appendix E.) 

Information Sharing On Foreign Nationals: Overseas Screening 


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Record 

(PNR)10 

Information System 

(APIS)11 

(Fully Implemented 

December 2010)12 

DHS System Owner DHS System Owner DHS System Owner 

� CBP � CBP � TSA

 May Include Must Include13 Must Include 

�

�

�

�

Traveler’s name 

Contact details 

Travel itinerary 

Reservation details 

�

�

�

�

�

�

Traveler’s name 

Date of birth 

Gender 

Country of citizenship 

Travel document 

number 

United States address 

(required only of 

foreign nationals) 

�

�

�

�

Traveler’s name as 

it appears on a 

travel document 

Date of birth 

Gender 

Redress Number (if 

available)

 Must Be Provided Must Be Provided14 Must Be Provided 

� Up to 72 hours 

before departure, as 

available 

�

�

30 minutes before the 

aircraft is secured 

(batch submissions) 

Up to securing the 

aircraft (APIS Quick 

Query) 

� Automated, up to 

72 hours before 

departure, or with 

electronic 

confirmation (if 

within 72 hours) 

 

 

 

 

 

 

Figure 3: Air Passenger Notification Procedures 

Passenger Name Advance Passenger Secure Flight 

Sources: Statute, regulations, CBP and TSA websites 

The CBP National Targeting Center – Passenger (NTC-P) screens 

lists of all inbound and some outbound international passengers 

and crew against the terrorist watch list, TSDB, the Centers for 

Disease Control and Prevention public health “do not board” list, 

and other information on high risk individuals available in DHS 

and other federal databases. For flights, when a traveler is 

identified on a no fly or do not board list, or is inadmissible based 

on information in a TSDB record or other evidence in DHS 

systems, CBP officers stationed overseas can assist the airlines in 

determining a course of action. CBP officers do not have the 

authority overseas to prohibit travel; however, carriers must 

comply with no fly and public health do not board cases. Carrier 

compliance with recommendations against boarding based on 

inadmissibility is strong, and carriers can be denied landing, 

10 49 U.S.C. Section 44909(c)(3), 19 CFR Section 122.49d. 

http://www.cbp.gov/xp/cgov/travel/clearing/pnr/ 11 8 U.S.C. Section 1221, 19 CFR Section 122.49a (b). 

http://www.cbp.gov/xp/cgov/travel/inspections_carriers_facilities/apis/ 12 49 U.S.C. Section 44903(j)(2), 49 CFR Section 1546.101. 

http://www.tsa.gov/what_we_do/layers/secureflight/

13 8 U.S.C. Section 1221, 19 CFR Section 122.49a (b) (3). 

14 19 CFR Section 122.49a (b)(1) & (2). 

http://www.cbp.gov/linkhandler/cgov/travel/inspections_carriers_facilities/apis/apis_faqs.ctt/apis_faqs.doc 

Information Sharing On Foreign Nationals: Overseas Screening 


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sanctioned, or fined if necessary. Host government support for 

U.S. compliance requirements is also strong. 

Screening of vessels, including passenger and cargo ships and their 

crews, is a shared responsibility of CBP and the USCG. 

Commercial vessel arrival APIS data is required 96 hours before 

entering the United States at the earliest, and 24 hours before 

entering the United States at the latest, so passengers may already 

be on board when APIS information is transmitted and screening 

begins. The USCG and CBP coordinate in screening passenger 

and crew manifests of all vessels that are required to provide 

advance notice of information against the same databases as are 

used for flights. There is generally more time to screen 

commercial and cargo vessels than flights, which allows DHS to 

alert other interested federal partners while the ship is still en route 

to the U.S. 

Information Sharing Drives Visa and Visa Waiver Programs 

In addition to CBP and USCG screening programs listed above, 

there are other DHS programs to assist with screening foreign 

nationals overseas. Foreign nationals from most countries must 

obtain a visa from the Department of State to travel to the United 

States. Visa applicants provide biographical, biometric, and travel 

document information to consular officers overseas, and are 

interviewed to evaluate eligibility for a visa. Applicant 

fingerprints are enrolled in the DHS US-VISIT Automated 

Biometric Identification System (IDENT), which checks the 

fingerprints against existing records, and sends an alert if 

subsequent relevant derogatory information becomes available. 

When these travelers arrive at a U.S. port of entry, CBP officers 

check their biometric information for matches to records of known 

or suspected terrorist, criminals, and immigration violators in DHS 

and other federal data systems. 

There are 36 countries that have visa waiver agreements with the 

United States (see Appendix D). Each country is subjected to a 

periodic independent intelligence assessment to maintain 

eligibility. The Visa Waiver Program allows most nationals from 

these countries who visit the United States for short-term business 

or tourism to travel without a visa. Security for the Visa Waiver 

Program was tightened in 2007, pursuant to the Implementing 

Recommendations of the 9/11 Commission Act of 2007, when 

participating countries were required to share certain information 

with the United States. This information includes biographic and 

Information Sharing On Foreign Nationals: Overseas Screening 


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some biometric information on known or suspected terrorists and 

on criminals convicted of felonies that would render them 

ineligible to enter or remain in the United States. Participating 

countries must also share information on lost and stolen issued 

passports, and the passport number for each stolen or missing 

blank passport. Visa Waiver Program travelers are required to 

submit their fingerprints and be photographed upon arrival in the 

United States. Most visa holders enroll in IDENT when they apply 

for a visa, and on arrival to the United States, their prints are 

verified. 

The Implementing Recommendations of the 9/11 Commission Act 

of 2007 required that Visa Waiver Program travelers obtain an 

electronic travel authorization through the ESTA website. ESTA 

was introduced in August 2008 and became mandatory in January 

2010. ESTA requires applicants to provide biographic and 

passport information and answer questions about eligibility for 

admission to the United States, and recommends that such 

information be submitted at least 72 hours before travel to resolve 

potential derogatory information.15 Via ESTA, CBP screens 

applicants against data contained in law enforcement databases, 

including TSDB and FBI’s database of criminal records, as well as 

State Department visa revocations, DHS information on visa 

overstays, and other information in DHS and federal data systems. 

When there is no potentially derogatory information provided by 

the applicant or located in the databases, ESTA automatically 

approves the travel authorization. When the applicant volunteers 

information on criminal convictions or terrorist activity, the ESTA 

application is automatically denied. When there is potentially 

derogatory information on the application or in the data systems 

that is not conclusive, such as a possible match to watch list 

information, targeting specialists at the NTC-P evaluate the 

information against data in other systems to determine whether to 

authorize travel, and may then either manually approve or deny the 

application. Based on the Immigration and Nationality Act, 

commercial air carriers may be fined if they bring passengers with 

a denied ESTA, or without travel authorization through ESTA. 

CBP advises passengers and airlines that denials must be resolved 

through the Department of State. 

15 http://www.cbp.gov/xp/cgov/travel/id_visa/business_pleasure/vwp/faq_vwp.xml 

Information Sharing On Foreign Nationals: Overseas Screening 


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DHS Officers Overseas Assist Screening Foreign Nationals 

The most comprehensive overseas screening is CBP’s preclearance program. Pre-clearance provides a full immigration and 

customs screening overseas.16 As appropriate for nationality and 

visa category, CBP officers in pre-clearance locations enroll 

travelers’ fingerprints in IDENT and can verify whether there is 

any derogatory information associated with this biometric 

information. They check DHS and other federal databases for 

terrorist and other derogatory information, and conduct screening 

interviews. CBP officers conducting pre-clearance have the same 

authority as CBP officers at domestic ports of entry to deny entry 

into the United States, and once pre-cleared, a passenger is 

admitted to the United States and does not need to be inspected 

again on arrival. CBP pre-clearance in Canada was established in 

1952, and expanded to the Caribbean in 1960. Pre-inspection for 

immigration was extended to Ireland in 1986, which later received 

full pre-clearance authorization.17 Pre-clearance operations are not 

likely to be expanded widely, as the cost to inspect all travelers 

overseas is high, and the program requires agreements from host 

governments and significant reconfiguration of the airline, sea, or 

rail terminals. 

ICE visa security units overseas assist State Department efforts to 

deny visas to inadmissible foreign nationals and secure the visa 

issuance process. In accordance with the Homeland Security Act 

of 2002, the Visa Security Program assigns experienced special 

agents to high-risk consular posts to review visa applications, 

initiate visa security-related investigations, and provide advice and 

training to consular officers.18 In a 2008 report, we concluded that 

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.”19 In 

Fiscal Year (FY) 2009, visa security units screened close to 

905,000 visa applicants. Of 301,700 applications that required 

16 http://www.cbp.gov/xp/cgov/toolbox/contacts/preclear_locations.xml
 17 At the time of our review, some locations which were authorized to conduct full pre-clearance, including
 

the Dublin airport and the Vancouver train station, conducted only pre-inspection for immigration. Dublin
 

will introduce full pre-clearance in 2011. 
 18 P.L. 107-296, Section 428 (e)(1) and (e)(2). 


19 DHS OIG, U.S. Immigration and Customs Enforcement Visa Security Program, OIG-08-79, July 2008, 


p. 1. 

Information Sharing On Foreign Nationals: Overseas Screening 


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further review, ICE collaborated with Department of State to 

recommend refusal of more than 1,000 applicants.20 

Other DHS officers stationed at embassies and consulates use DHS 

data systems to conduct adjudications or assist in law enforcement 

investigations. USCIS obtains biographical and biometric 

information and conducts extensive systems checks for most 

refugees before they are authorized to travel to the United States. 

USCIS conducts adjudications on applications for foreign nationals 

who request immigration benefits outside the United States. These 

include military naturalizations, adoptions, and petitions for alien 

relatives. They also include requests for waivers from aliens who 

have been determined inadmissible for offenses such as minor 

criminal convictions or visa overstays. USCIS Overseas 

Verification Program officers in Frankfurt, Germany; Monterrey, 

Mexico; and New Delhi, India, provide an additional layer of 

scrutiny for some cases through verification of facts, statements, 

events, and certain documents that relate to the eligibility of 

petitioners or applicants to receive immigration benefits from 

USCIS. 

In addition, the Department of State, CBP, ICE, and USCIS share 

responsibility to assist lawful permanent residents who have lost 

their documents. If their identity and status can be verified, lawful 

permanent residents can obtain a transportation letter, which 

allows them to travel to the United States to replace their 

permanent resident card. Finally, ICE officers overseas cooperate 

with host governments to investigate money laundering, human 

trafficking, and smuggling of aliens, narcotics, or weapons. To 

assist these investigations, ICE checks whether DHS and other 

federal data systems have information on the identities and 

locations of suspected terrorists or criminals. 

In addition to pre-clearance operations and DHS officers operating 

at embassies and consulates, the CBP Immigration Advisory 

Program (IAP) is a valuable counterterrorism, law enforcement, 

and facilitation asset for foreign partners and airline stakeholders. 

The Intelligence Reform and Terrorism Prevention Act of 2004 

called for CBP to identify 50 foreign airports for expansion of the 

program by December 31, 2006. The process to identify the 

20 Testimony of ICE Assistant Secretary John Morton before the U.S. Senate Committee on Homeland 

Security and Governmental Affairs, April 21, 2010, available at 

http://hsgac.senate.gov/public/index.cfm?FuseAction=Hearings.Hearing&Hearing_ID=b5908d92-992b47b4-a7c0-efa6a663327f 

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foreign airports has been repeated annually, to reflect changes in 

travel patterns and threats.21 Officers have been deployed to 10 

foreign airports in eight countries and there are negotiations with 

foreign governments to deploy IAP to additional locations.22 Their 

mission is to intercept high-risk and improperly documented 

travelers who seek to board a flight to the United States. They 

work with the NTC-P to identify potential high-risk passengers, 

and review travel documents and conduct interviews for U.S.­

bound travelers. They observe the airport environment to gather 

information, and exchange it with local security officials. 

Additionally, officers facilitate legitimate travel. They can assist 

U.S. citizens and lawful permanent residents who have lost travel 

documents, or Visa Waiver Program nationals who have made 

errors on their ESTA applications. In FY 2009, officers 

recommended 2,776 passengers not board flights for the United 

States, with cost avoidance for air carriers of $4,535,850, and 

$4,117,138 for CBP in expenses for secondary inspections at ports 

of entry. The recommendations against boarding also avoided 

costs for ICE and Department of Justice immigration judges for 

detention and removal proceedings. 

For ports that do not have a CBP officer present, CBP Regional 

Carrier Liaison Groups provide assistance. Regional Carrier 

Liaison Groups in New York, Miami, and Honolulu maintain close 

ties with airlines that serve Europe and Africa, the Americas, and 

Asia, respectively. Where there are no CBP officers stationed 

overseas, the regional CBP liaison can call the airline to obtain 

more information or recommend against boarding. 

USCG migrant interdictions at sea represent another opportunity to 

prevent unauthorized access to the United States. In most 

instances the USCG, in consultation with the USCIS Refugee 

Affairs Division, the State Department, other concerned federal 

partners, and countries of origin, will repatriate intercepted 

migrants who are not in need of international protection. However, 

the USCG has piloted a successful Biometrics-at-Sea System 

(BASS). BASS confirms the identities of illegal migrants while 

they are temporarily detained at sea. As the USCG collects a 

migrant’s information, it is compared to biometric data and the 

21 P.L. 108-458.
 

22 The locations are Amsterdam, Netherlands; Warsaw, Poland; London (Heathrow), United Kingdom;
 

London (Gatwick), United Kingdom; Manchester, United Kingdom; Tokyo, Japan; Frankfurt, Germany; 


Seoul, South Korea; Madrid, Spain; and Paris, France. The Paris, France location was added after 


completion of our field work.
 

Information Sharing On Foreign Nationals: Overseas Screening 


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data matched against information in IDENT. Hand-held biometric 

devices are used to enroll the fingerprints and transmit them by 

maritime satellite communications service. Currently, the program 

is limited to the western coast of Puerto Rico, where Dominicans 

and a small number of Cubans attempt passage, and a small 

operation off the southwestern coast of Florida, where the caseload 

is more varied. Biometric verification has deterred large-scale 

illegal migration. Between 2007, when the use of biometrics 

began, and 2009, the USCG collected more than 2,500 biometric 

enrollments. Of them, about 25% yielded a positive match, and 

there were approximately 250 successful prosecutions. 

Interdictions during this period dropped by 75% where biometrics 

were checked, and the USCG estimated that boat interdictions in 

these regions might drop from the pre-2006 level of 11,000 to 

fewer than 1,000 in 2010. 

In addition, the USCG is conducting an operational demonstration 

of biometrics use to reduce security risks from foreign flag 

liquefied natural gas ships arriving in the United States from 

regions with elevated terrorist activity. Ship crews are required to 

have current U.S. visas and are subject to biometric identification. 

Biometric and biographic information from the ship's manifest and 

visa records is screened for derogatory information prior to the 

ship's arrival in U.S. waters. Upon arrival, the ship is boarded to 

ensure no stowaways or other unknown persons are on board and 

crewmember identities are verified using fingerprint biometrics. 

Biometric verification ensures that no individuals known or 

suspected of association with violent extremism or posing other 

criminal or security threats are on board. 

Results of Review 

DHS databases, developed over decades to fulfill a complex range of 

antiterrorism, law enforcement, immigration, and traveler screening missions, are 

fragmented. Consolidating most systems is not a practical goal given divergent 

operational requirements and funding constraints. Cooperation among the 

operational components that first encounter foreign nationals overseas has helped 

overcome some of the challenges that DHS data systems present. Short-term 

improvements can be implemented if DHS expands storage of biometrics in 

IDENT and improves the ESTA website. More complex planning should take 

place through the Shared Mission Communities fostered by the Office of 

Intelligence and Analysis Information Sharing Governance Board. 

Information Sharing On Foreign Nationals: Overseas Screening 


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The NTC-P is the operational core of DHS antiterrorism passenger screening 

efforts for air and land borders, and partners with the USCG on screening 

maritime borders. Its responsibilities and workload have increased substantially 

in response to border security threats. CBP officers often must respond to a 

potential threat within 30 minutes before a flight departs; however, fragmented 

DHS data systems make assessing passengers a labor-intensive process. Serious 

staff shortages, extensive mandatory overtime, and high turnover at the NTC-P 

could lead to human error due to fatigue or inexperience. Recruitment and 

retention could be improved if the NTC-P increases its staff, rebuilds the NTC-P 

analytical functions, and provides a clearer career path for targeting specialists. 

DHS has three small-scale programs operating at a limited number of locations 

that enhance assessment of foreign nationals for those locations: the ICE Visa 

Security Program, the CBP Immigration Advisory Program, and the USCG 

BASS. These programs prevent entry into the United States by dangerous and 

inadmissible foreign nationals, prior to their arrival in the United States, and 

therefore merit additional funding and expansion. 

DHS officers who work overseas must routinely use up to 17 different DHS 

systems. A single sign-on to some of these systems would improve productivity. 

A portal on the DHS intranet could streamline access to web-based DHS systems 

and could assist officers to verify that their queries locate accurate and current 

information. Web-based training on immigration law, DHS programs, and DHS 

data systems could also assist overseas officers, who are expected to cover a 

broader range of immigration-related issues than their domestic counterparts. 

Valuable DHS Information-Sharing Initiatives Represent 

Progress, But Integration Is Advancing Slowly 

DHS Components Share Information on Foreign Nationals 

Despite Challenging Conditions and Fragmented Systems 

DHS has a complex mission to track and evaluate foreign 

nationals. DHS must guard against terrorism; secure borders and 

control land, sea, and air ports of entry; facilitate legitimate travel; 

and provide eligible applicants with immigrant and nonimmigrant 

benefits. DHS databases are a disparate range of systems 

developed over decades to fulfill these missions. The foreign 

nationals DHS tracks range from lawful permanent residents to 

Visa Waiver Program applicants overseas. Data systems were 

built with different requirements for privacy, records retention, and 

protection of law enforcement–sensitive information. Different 

operational missions require varying levels of information: a CBP 

IAP officer who advises an air carrier against boarding a passenger 

Information Sharing On Foreign Nationals: Overseas Screening 


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on the TSDB no fly watch list needs more timely information but 

less detail than an ICE officer who searches for possible associates 

of a human smuggler. 

Within DHS, funding to improve and integrate data systems comes 

primarily from the budgets of individual operational components. 

In addition, operational components that have had limited success 

with past modernization projects are cautious. For example, after 

several unsuccessful attempts to migrate all of its records to a new 

system, the USCIS planned upgrade will transfer limited historical 

information into its new system under the "Transformation" 

process. ICE plans to replace its Immigration Enforcement 

Operational Records System (ENFORCE) databases one at a time 

rather than to upgrade the whole system at once. 

The long-term vision for DHS information sharing on foreign 

nationals is to provide authorized DHS users with a real-time 

overview of all information about an individual by aggregating 

information on each individual from all relevant DHS data systems 

in what is termed a Person Centric View. In the long term, DHS 

would also have the analytical software to conduct trend and data 

analysis on real-time information across systems. However, given 

the complexity of these goals and limited funding, the headquarters 

components that will coordinate implementation of this plan told 

us that it is likely that DHS will continue to operate with a 

fragmented patchwork of legacy and single-purpose systems for at 

least three to five more years. 

DHS components have cooperated to improve information sharing 

on foreign nationals. For example, components that plan to 

upgrade major data systems, such as the USCIS immigration case 

tracking databases and CBP TECS, have solicited suggestions 

from users in other components. Several DHS headquarters 

offices, including the Information Sharing and Collaboration 

Branch, the Screening Coordination Office, and the 

Counterterrorism Section in the Office of Operations Coordination 

and Planning, have coordinated with operational components to 

identify best practices and data gaps. 

DHS has also recently given more authority to the Office of 

Intelligence and Analysis, the Office of the Chief Information 

Officer, and the Screening Coordination Office to begin integration 

of data systems and prioritize expenditures. The DHS Information 

Sharing Governance Board and the government-wide Interagency 

Policy Council on Information Sharing and Access are among the 

Information Sharing On Foreign Nationals: Overseas Screening 


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institutional forums where better coordination of information 

sharing will be developed. Most of these initiatives are in the early 

stages, as the functions of hundreds of DHS data systems must be 

mapped. There is general agreement among these DHS 

stakeholders on a methodology to integrate information, which will 

assist planning. Integration will focus on the development or 

adaptation of software that can search and analyze existing data 

systems in real time. With the exception of USCIS 

Transformation, there will be few attempts to consolidate 

information from existing data systems. 

Close cooperation among operational components that first 

encounter foreign nationals overseas has helped overcome some of 

the challenges presented by DHS data systems. Many of the 

officers we interviewed attributed successful working relations to 

the personalities and professionalism of their colleagues, rather 

than the effect of formal policies that require information sharing. 

The overseas officers we interviewed cooperated well when their 

missions overlapped. In addition, overseas officers obtained 

informal assistance from the NTC-P and DHS officers familiar 

with immigration law and the more complex databases. We also 

observed strong working relationships among the NTC-P, Regional 

Carrier Liaison Groups, and IAP officers, who often must work 

together to resolve potential no fly and do not board matches in 30 

minutes or less. For interdictions at sea, the USCG, US-VISIT, 

and CBP have developed an effective program to share 

information on migrants who make repeated attempts to enter the 

United States without permission. 

Centralization of IDENT Biometrics Screening Is Essential to 

Information Sharing 

We consider that the most important building block for successful 

information sharing within DHS is the US-VISIT biometric 

fingerprint IDENT, because fingerprints establish a unique identity 

for each foreign national even when biographic information and 

travel documents change. The ability to establish and verify 

identity through fingerprint enrollment is the most accurate means 

to track known and suspected terrorists, criminals, and migrants 

with false or multiple identities, as well as to facilitate legitimate 

travel and benefits administration. DHS has designated IDENT as 

its primary repository of biometric information in the enforcement 

of civil and criminal laws, and national security and intelligence 

activities. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Most foreign nationals who: (1) apply for a visa or refugee status 

overseas; (2) arrive at an international airport in the United States; 

(3) apply for an immigration benefit; or (4) are detained, are 

enrolled in IDENT. The USCG enrolls some interdicted migrants, 

and CBP enrolls some land border crossers. In 2009, IDENT 

largely completed its transition from a two-fingerprint enrollment 

system to a full ten-fingerprint enrollment, which provides greater 

interoperability with FBI biometric systems. Ten-fingerprint 

compatibility allows DHS to query fingerprints against prior 

enrollments under other names or identities in the United States, or 

in countries that share fingerprint information from criminal 

records. IDENT is also used to compare fingerprints lifted from 

terrorist safe houses or battlefields. The governments of the 

United States, Australia, Canada, New Zealand, and the United 

Kingdom now compare fingerprints via their biometric databases 

to identify fugitives and individuals who have falsified identities. 

IDENT has fundamentally transformed information sharing. 

Congressional mandates to expand US-VISIT biometric enrollment 

—most notably exit controls at borders—will require significant 

increases in funding and infrastructure.23 However, realistic 

shorter-term projects could be accomplished with existing 

technology and more limited funding, but they have been delayed 

because US-VISIT has not been able to secure signatures on 

agreements or because logistical challenges have not been 

resolved. IDENT is the primary repository for biometrics for 

foreign nationals throughout the federal government. However, 

some DHS biometrics are not automatically integrated into 

IDENT, such as fingerprints obtained through TSA’s 

Transportation Worker Identification Credential (TWIC) program, 

which is required for unescorted access to secure areas of 

designated maritime ports.24 Some individuals who are issued 

TWIC credentials, which can include truck drivers and dock 

workers as well as USCG documented merchant mariners, are 

foreign nationals or naturalized citizens. Biometric information 

should be checked automatically against other biometric-based 

information available in IDENT from DHS and the State 

Department. 

IDENT checks known or suspected terrorist biometrics against FBI 

biometric systems, but some biometric and biographic records in 

the National Counterterrorism Center are not yet automatically 

23 P.L. 108-458 

24 P.L. 107-295 

Information Sharing On Foreign Nationals: Overseas Screening 


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checked against US-VISIT. The Department of Defense is 

addressing logistical impediments to its ability to share biometrics 

in its Automated Biometric Identification System, to compare 

Department of Defense fingerprints automatically, rather than on a 

case-by-case basis, and is looking to build directly into IDENT. 

Each of these initiatives would eliminate or reduce potential gaps 

in the information currently available to the federal government on 

potential terrorists, criminals, and unauthorized foreign nationals. 

Recommendations 

We recommend that the Office of Policy, and U.S. Visitor and 

Immigrant Status Indicator Technology: 

Recommendation #1: Coordinate and work with the DHS people 

screening programs which collect biometrics to use US-VISIT 

IDENT for their biometric storage and matching requirements. 

Recommendation #2: Work with other federal agencies to share 

biometrics of foreign nationals collected by those agencies with 

DHS US-VISIT IDENT. 

Upgrades to ESTA Website Would Reduce Deficits 

In addition to relatively modest changes to IDENT, information 

sharing could be substantially improved if DHS invested in 

improvements to the ESTA website to reduce inefficiencies created 

by inaccurate data submissions. CBP officers reported numerous 

submission errors on the ESTA applications because applicants 

misunderstood the eligibility questions. As shown in the ESTA 

website extract (Figure 4), the application includes a series of 

questions about admissibility to the United States, but a full 

definition of the grounds for inadmissibility requires applicants to 

click on a hyperlink. An official from the CBP ESTA program 

noted that travelers routinely answer certain questions incorrectly 

because users do not read these definitions. Most notably, 

Question A, on communicable diseases and Question G, on 

immunity from prosecution, are inappropriately marked “Yes.” 

Applicants may mark that they have communicable diseases, but 

they are not diseases the Department of Health and Human 

Services would consider to be of public health significance and are 

therefore grounds for inadmissibility.25 Applicants may mark that 

they have a physical disorder because they are in a wheelchair, 

25 8 U.S.C. 1182 (a) (1) (A) (iii) (I). 

Information Sharing On Foreign Nationals: Overseas Screening 


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while the regulations bar travel only by individuals who present a 

threat to property, safety, or welfare.26 Applicants who mark that 

they have asserted immunity from prosecution may be in a civil 

dispute with a neighbor but have not committed a serious crime in 

the United States.27 

Figure 4: Visa Waiver Program Country Website Interface – 

Admissibility Questions 

Source: ESTA website user interface (www.cbp.gov) 

When ESTA applicants mark “Yes” for a question that is known to 

be widely misunderstood, the NTC-P ESTA division, the ESTA 

program management office at CBP headquarters, IAP officers, or 

the Regional Carrier Liaison Group may attempt to reconcile the 

issue through research of immigration and criminal records. They 

may also discuss the concerns with the applicant or airline, which 

may be able to provide additional biographic or documentary 

information to resolve them. If there is no additional derogatory 

information, a CBP officer may manually approve the ESTA 

application. IAP officers report that when they have cleared higher 

priority cases, they spend considerable time on ESTA cases. They 

try to resolve cases that appear to be based on a misunderstanding 

of the application, but the volume is too high to resolve all cases, 

26 8 U.S.C. 1182 (a) (1) (A) (iii). 

27 8 U.S.C. 1182 (a) (2) (E). 

Information Sharing On Foreign Nationals: Overseas Screening 


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and some applicants are not permitted to travel on that day and 

must instead seek an appointment with the State Department to 

apply for a visa. ESTA program managers have tried to address 

the issue through information provided in hyperlinks, and through 

asking applicants to verify their “Yes” response to Question A, but 

they told us that major improvements to the ESTA website will not 

be introduced until ESTA transitions to a fee-based program and 

collects sufficient funds to make database changes.28 

In addition, the ESTA data entry interface allows applicants to 

enter incorrect passport numbers, for example substituting a letter 

“O” for a zero, so the ESTA travel authorization approval that the 

applicant brings to the airport may not match the machine-readable 

passport. ESTA program managers told us that through experience 

and communication with visa waiver governments they have 

identified passport numbering conventions that could be used to 

catch some incorrect data entry by applicants. Immigration 

Advisory Program officers reported that it can be difficult for air 

carriers to locate an approved ESTA within their system, and to 

decide whether or not to rely on the printed approval. In these and 

other instances where there appears to be an innocent error, such as 

a misspelling or a transposition of a date of birth, CBP may direct 

travelers to apply for a new ESTA approval at the airport. 

When CBP, travelers, and airlines are aware that there is a 

relatively high incidence of innocent errors in ESTA applications, 

the benefit of doubt that is extended to travelers can leave the 

system more open to potential abuse. The ESTA program will 

transition to a fee-based application process, and will therefore 

need to develop an application that can be amended rather than 

discarded and replaced when there are errors. With a new design, 

the ESTA program has an opportunity to limit some common data 

entry and matching challenges. As discussed in more detail later in 

the report, the ESTA program also generates cases of applicants 

who may have correctly marked “Yes” on an application, but 

whose applications CBP can resolve if it has the staff resources. 

For example, CBP may determine that it is not necessary to deny 

the ESTA application of persons who self-report that they were 

denied a student visa a decade ago, but against whom there is no 

other derogatory information. Improvements to the website would 

allow CBP to devote more resources to these cases and reduce the 

need to refer such applicants to a consulate for resolution. 

28 The ESTA program implemented a fee of $14 in September 2010, after we completed field work. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Recommendations 

We recommend that U.S. Customs and Border Protection: 

Recommendation #3: Amend the Electronic System for Travel 

Authorization website to address the most common areas of 

confusion that participating travelers from Visa Waiver Program 

countries have with regulatory language when they complete 

Electronic System for Travel Authorization applications. 

Recommendation #4: Amend the Electronic System for Travel 

Authorization website to limit potential for incorrect applicant 

information and inappropriate denials. 

Shared Mission Communities Can Assist Long-Term DHS 

Data Systems Improvements 

CBP can improve ESTA. Improvements to IDENT require only 

cooperation between US-VISIT, TSA, and headquarters staff 

responsible for negotiating interagency agreements. However, 

more complex upgrades to and coordination among data systems 

owned by CBP, ICE, TSA, and USCIS, and used throughout 

federal, state, local, and tribal governments, would best be planned 

in the context of the Shared Mission Communities. Shared 

Mission Communities provide an official DHS forum for 

components to integrate their activities and are effective because 

they can raise issues that require financial commitments or a 

binding decision to the Information Sharing Governance Board. 

The Under Secretary for Intelligence and Analysis, who chairs the 

Information Sharing Governance Board, was recently designated 

the lead on initiatives to prioritize financial commitments and 

efforts to consolidate information in DHS data systems. 

The work of the two current Shared Mission Communities—Law 

Enforcement and Intelligence—has improved information sharing 

on foreign nationals. A third Shared Mission Community on 

Border Security would provide immigration and border 

management components a framework to improve information 

sharing and identify gaps and redundancies in the information 

available in DHS data systems. 

In its 2009 Annual Report, the Information Sharing Governance 

Board recognized the accomplishments of the Law Enforcement 

and Intelligence Shared Mission Communities. The board 

Information Sharing On Foreign Nationals: Overseas Screening 


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recommended establishment of others, including Infrastructure 

Protection, Incident Management, Border Security, and 

Transportation Security. The Shared Mission Communities can be 

used to “identify, promote, and champion resource alignment” to 

support shared missions, and as a “forum for discussion of 

mission-specific issues to ensure that the mission voice is 

represented in departmental information sharing decisions.”29 

Shared Mission Communities can include many of the same 

components, and even many of the same offices within 

components. For example, CBP, ICE, TSA, the USCG, and 

USCIS could be integral to several Shared Mission Communities. 

The value of a Border Security Shared Mission Community is that 

it can focus on specific issues and strategies, including targeting, 

screening, biometric enrollment, and possible expansion of exit 

controls. A Border Security Shared Mission Community could 

also be a forum for obtaining resources to extend the use of some 

of the most sophisticated DHS targeting and analysis software, 

such as the CBP Automated Targeting System–Passenger (ATS-P), 

and geospatial software developed by the CBP Border Patrol. 

Recommendation 

We recommend that the Office of Intelligence and Analysis: 

Recommendation #5: Submit a proposal to the Information 

Sharing Governance Board to consider establishing a Border 

Security Shared Mission Community. 

Management Comments and OIG Analysis 

Management Comments: The Office of Policy, and U.S. Visitor 

and Immigrant Status Indicator Technology, concurred with 

Recommendation #1 [Coordinate and work with the DHS people 

screening programs which collect biometrics to use US-VISIT 

IDENT for their biometric storage and matching requirements]. 

The Office of Policy stated that on May 25, 2007, a memorandum 

was issued to the Chief Information Officers (CIOs) of ICE, CBP, 

USCIS, TSA, and US-VISIT, directing that all DHS programs that 

require the collection and use of fingerprints to vet individuals, 

shall use the target biometric service as defined by the Homeland 

Security Enterprise Architecture –IDENT. The Office of Policy 

29 Information Sharing Governance Board Annual Report 2009, May 8, 2009, p. 10. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 25
 
advised that IDENT for biometric storage and matching is being 

used by USCIS, CBP, and ICE. Also, the Office of Policy said 

that TSA is transitioning to US-VISIT’s IDENT for similar 

purposes. 

OIG Analysis: This recommendation is resolved and open. The 

Office of Policy’s actions planned are responsive to the 

recommendation. The Office of Policy shows a level of 

commitment in implementing guidelines requiring DHS 

components that collect biometric information to use IDENT for 

their storage and matching requirements. Please provide detailed 

information, such as reports, memorandums or technical plans, as 

well as timelines, on TSA’s plan for transitioning to using USVISIT IDENT for biometric storage and matching. 

Management Comments: The Office of Policy, and U.S. Visitor 

and Immigrant Status Indicator Technology, concurred with 

Recommendation #2 [Work with other federal agencies to share 

biometrics of foreign nationals collected by those agencies with 

DHS US-VISIT IDENT]. The Office of Policy stated that DHS 

has ongoing efforts with other federal agencies, especially those 

within the Intelligence and Defense communities, to check and 

store the fingerprint biometrics they capture within IDENT. 

OIG Analysis: This recommendation is resolved and open. 

Please provide copies of meeting minutes or other records to 

document that the Office of Policy has met and continues to meet 

with other federal agencies to effect automated checking and 

storage of biometric information on foreign nationals within 

IDENT. Please include information on any barriers to 

implementation, such as resource needs or technological 

challenges. 

Management Comments: CBP concurred with 

Recommendation #3 [Amend the ESTA website to address the 

most common areas of confusion that participating travelers from 

Visa Waiver Program countries have with regulatory language 

when they complete ESTA applications]. CBP said that the 

changes recommended in the report were completed in the ESTA 

website on September 8, 2010, after our fieldwork was completed, 

in a major upgrade to the website. In addition to adding fee 

provisions, CBP said that it made additional changes to help Visa 

Waiver Program (VWP) applications, for example: 1) Those who 

mistakenly answer yes to Question A or G can now reapply and 

receive an approval without CBP intervention; and 2) the 

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programming rules for some country passports have been refined 

to help prevent applicants from being turned around at the airport 

or denied entry upon arrival in the United States. A more complete 

list of examples is provided in the management comments in 

Appendix B. 

OIG Analysis: This recommendation is resolved and open. The 

changes described appear to meet our requirements. We request an 

update with additional details on two of the described changes. 

For the reapplication with Questions A and G, please describe how 

CBP determines that the original answer was simply a mistake, and 

whether the fee is waived for a reapplication. For the upgraded 

programming rules for some country passports, please provide a 

few specific examples so that we understand the methodology. 

These responses can be provided in an informal email. As soon as 

we receive this information, we will consider this recommendation 

resolved and closed. We commend CBP for the rapid response to 

these areas of confusion. 

Management Comments: CBP concurred with Recommendation 

#4 [Amend the ESTA website to limit potential for incorrect 

applicant information and inappropriate denials]. CBP said that it 

continues to make significant changes to the ESTA website as 

necessary. CBP said that it carefully monitors the ESTA 

applications to ensure that applicants are not trying to work around 

the system. With the implementation of the fee CBP said that it 

anticipates fewer applicants gaming the system, as they will be 

required to pay for each new application. CBP noted that ESTA is 

a system that is generated by the applicants in the general public. 

CBP said as long as the general public enters information, there 

will be entry errors, most often with passport numbers. Until the 

public becomes aware of these data elements, there will be 

mistakes. CBP said that it continues to monitor customer feedback 

and make amendments to the website as needed. 

OIG Analysis: This recommendation is resolved and open. 

Please provide an update on some of the amendments that have 

been made to the website from CBP monitoring of the 

applications, or in response to customer comments. We agree that 

some entry errors will remain inevitable with the public entering 

information. We are not persuaded that the small incremental 

costs of multiple ESTA applications will deter persons ineligible 

for the Visa Waiver Program from attempting to avoid applying for 

a visa. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Management Comments: The Office of Intelligence and 

Analysis, and CBP, did not concur with Recommendation #5 

[Submit a proposal to the Information Sharing Governance Board 

to consider establishing a Border Security Shared Mission 

Community]. The Office of Intelligence and Analysis stated that a 

Border Security Shared Mission Community would duplicate other 

organizations’ activities underway and would not measurably 

improve information sharing among DHS components with 

relevant equities in border security beyond that which is already 

occurring. The Office of Intelligence and Analysis stated these 

organizations include the Border Intelligence Fusion Section, 

composed of participants from DHS and other interagency 

partners; and the State of the Border, which focuses on Southwest 

Border law enforcement activities with plans to expand the area of 

focus to Northern Border and coastal environments. 

OIG Analysis: This recommendation is unresolved and open. 

We believe the actions planned by the Office of Intelligence and 

Analysis are not responsive to the recommendation. Although the 

Office of Intelligence and Analysis consulted with CBP, these 

views may not represent the other entities responsible for border 

security. The actions as described do not provide sufficient details 

regarding how all components integrally involved with border 

security information sharing, such as ICE and USCIS, are 

represented in the Border Intelligence Fusion Section and the State 

of the Border organizations. As described, these organizations 

appear to focus on the details of current operations, and are limited 

to land and coastal borders. They do not appear to have a mandate 

to address longer-term coordination of data system upgrades 

necessary to enhance border security. It is possible that one of 

these organizations could assume the responsibilities for a unified 

information sharing role as the Border Security Shared Mission 

Community. 

This recommendation will remain unresolved and open until the 

Office of Intelligence and Analysis submits a proposal to the 

Information Sharing Governance Board to consider establishing a 

Border Security Shared Mission Community. The decision would 

include all DHS components with a border security nexus, to 

determine if there is consensus on whether to establish a Border 

Security Shared Mission Community. The Border Security Shared 

Mission Community would include components such as USCIS 

with relevant data systems. If the Information Sharing Governance 

Board decides not to establish this Shared Mission Community at 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 28
 
that time, we will consider the recommendation resolved and 

closed. 

NTC-P Can Improve Effectiveness by Improving Working 

Conditions 

NTC-P Counterterrorism Screening Relies on Fragmented 

Data Systems and Incomplete Information 

The NTC-P is the operational core of DHS antiterrorism passenger 

screening efforts for air and land borders. The NTC-P partners 

with the USCG when screening passengers and crews for maritime 

border threats. The NTC-P provides significant travel screening 

assets and resources to DHS officers and federal partners. Its 

responsibilities and workload increase with every new potential 

threat. In response to the December 2009 bombing attempt, the 

NTC-P must now review possible hits against an expanded TSDB 

watch list and additional Department of State visa revocations. In 

addition, the NTC-P increased its pre-departure screening of 

international flights. Although the primary responsibility of the 

NTC-P is to screen travelers’ flights and vessels, it also receives 

and responds to hundreds of calls daily from law enforcement and 

intelligence officers for information housed in DHS data systems. 

Adequate resources, which include staff and data systems, are 

essential if the NTC-P is to respond quickly to information on 

potential threats. 

Many federal data systems contain relevant data on foreign 

nationals. These systems are not well integrated and were 

originally designed for other purposes, which makes screening 

passengers against potentially derogatory information a laborintensive process. NTC-P targeting specialists use as many as four 

computer monitors with different databases open concurrently to 

resolve possible matches identified through the targeting software, 

ATS-P. They must continually transfer information from one 

system into another. When possible matches cannot be resolved, 

targeting specialists must log into numerous additional databases to 

determine whether a traveler is an individual in a watch list record, 

or whether potentially derogatory information is accurate. 

To determine the accuracy of any given possible match, it might be 

necessary to query TECS, APIS, ESTA, Student and Exchange 

Visitor Information System (SEVIS), ENFORCE, USCIS systems 

and verify information contained in Central Index System (CIS), 

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Computer-Linked Application Information Management System 3 

(CLAIMS3), Image Storage and Retrieval System (ISRS), and USVISIT IDENT and Arrival and Departure Information System 

(ADIS). It may also be necessary to check databases owned by 

other federal agencies, such as the Department of State Consular 

Consolidated Database, and commercial databases, such as those 

used for credit reporting. Figure 5 illustrates some of the 

difficulties NTC-P targeting specialists must overcome when they 

use the systems to evaluate possible derogatory information. 

Figure 5: Difficulties in Navigating DHS Data Systems 

Sample System Check Processes 

To search systems requires understanding how the database is structured: 

� IDENT is organized by fingerprint identification number 

� CIS is organized by case number or alien number 

� ENFORCE is organized by event 

In some cases it is necessary to check one DHS or State Department database to 

obtain a record locator to query another database: 

� Using SEVIS may require checking the State Department visa issuance 

database first 

� Most checks of IDENT require obtaining a fingerprint identification 

number from another DHS database such as CLAIMS3 

DHS databases match biographic information with different methods and levels 

of accuracy: 

� Systems like ATS-P can identify near matches (John Smith, Jonathan 

Smith, and Jon Smythe) 

� Systems like SEVIS are searchable only within a visa type 

Databases have known idiosyncrasies that require further checks for false 

positive and false negative matches: 

� ESTA matches ethnic Irish names starting with the letter “O’” 

(O’Reilly may match against O’Keefe) 

� Users of the older USCIS systems report that sometimes an exact name 

spelling will not locate a record 

When a data system is programmed to transfer information to another system, 

experienced users check the records in both systems, because sometimes only 

part of the original data has been transferred: 

� Information in ATS-P needs to be checked against TECS 

� CIS needs to be checked against Image Storage and Retrieval System 

(ISRS) 

Targeting specialists and officers using DHS systems for research need to 

understand the methodology used to include data in specific databases: 

� APIS does not always accurately reflect who has actually traveled, and 

must be checked against Arrival and Departure Information System 

(ADIS) 

� TECS includes individuals against whom potentially derogatory 

information was resolved 

Source: DHS database demonstrations, training materials, interviews 

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In addition, while CBP has developed new targeting programs as 

threat patterns emerge, the programs are not yet fully reliable. For 

example, we observed a targeting specialist working in the new 

pre-departure screening program developed after the December 

2009 bombing attempt. Although the officer refreshed the screen 

as the program required, relevant passenger names appeared after 

the plane had departed. Complex, labor-intensive system checks 

and potentially inaccurate search results present a serious 

vulnerability because the operating environment at the NTC-P is 

also time-sensitive. 

Under current regulations, DHS has access to passenger ticketing 

information, Passenger Name Record (PNR), collected by airlines 

up to 72 hours in advance of departure (see figure 3 above). CBP 

receives PNR data periodically and conducts analysis as necessary 

until 8 hours before departure. PNR data are unverified and may 

be incomplete. With limited biographical information, it can be 

difficult to resolve possible matches against derogatory 

information in DHS and other federal databases. 

With APIS, airlines may provide a manifest with full information 

on all passengers as late as 30 minutes before a flight departs, or if 

certified to use APIS Quick Query, may transmit information on 

individual passengers as late as when the aircraft door is closed for 

departure. If a passenger purchases a ticket less than 8 hours 

before the flight, the APIS manifest transmission will be the first 

notification CBP receives. In that limited amount of time, the 

NTC-P is not always able to identify individuals, other than TSDB 

no fly matches, who should not have been allowed to board. The 

consequences to date have been passenger offloads with flight 

delays, flight diversions, and passengers denied admission on 

arrival and placed in costly removal proceedings. 

As of November 23, 2010, Secure Flight completed deployment 

for all U.S. aircraft operators and foreign air carriers with 

commercial flights into, out of, and within the United States, and 

will establish a timeline to expand to flights in transit over the 

continental United States. Secure Flight watch list matching may 

enhance the security of commercial air travel by improving the 

watch list matching process. Securing the distribution of watch list 

data and expediting law enforcement identification should reduce 

the number of misidentified passengers. Although, Secure Flight 

provides a discrete set of information necessary for effective 

screening sooner, the information is self-reported. APIS 

information is generally the first verified data DHS receives. The 

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NTC-P may require country of citizenship and travel document 

information from APIS to resolve whether the passenger is a 

possible match to the TSDB watch list. 

For passengers whose status must be resolved by the NTC-P, the 

center may request assistance from preclearance operations, and 

Immigration Advisory Program and Regional Carrier Liaison 

Group officers, to obtain additional information from travelers or 

airlines, or to intercept a passenger when a possible match cannot 

be resolved before the flight departs. However, the NTC-P and 

Regional Carrier Liaison Group officers told us that 30 minutes is 

insufficient to resolve possible matches and reach carriers to 

intercept or offload a passenger, particularly when they have 

matches on several flights scheduled to leave at the same time. 

In 2006, when DHS evaluated changes to regulations on passenger 

manifests, it considered whether to require airlines to provide APIS 

information earlier. However, the study estimated that it could 

cost airlines $1.9 billion over a decade to provide more timely 

information. Technology upgrades would be necessary to transmit 

PNR data more frequently to CBP data systems. Response times 

could be improved somewhat with increased staff at the NTC-P, 

Regional Carrier Liaison Groups, and Immigration Advisory 

Program, and more carrier liaison training and outreach. The 

NTC-P managers and Regional Carrier Liaison Group officers we 

interviewed said that they did not have sufficient staff and travel 

budgets to maintain optimal relationships with foreign carriers. 

Recommendation 

We recommend that U.S. Customs and Border Protection: 

Recommendation #6: Assess options for obtaining Advance 

Passenger Information System data from carriers earlier, and 

Passenger Name Record data from reservation systems more 

frequently, in a manner that is cost-effective. 

Additional Liaisons Will Contribute to NTC-P Effectiveness 

DHS components have provided the NTC-P with the liaison 

personnel it has requested. Additional support from other federal 

agencies would enhance the ability of the NTC-P to screen 

matches quickly and accurately. Liaisons provide the NTC-P with 

immediate access to restricted databases managed by their host 

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organizations. Liaisons also interpret complex case information in 

those databases, and can ensure a rapid threat response from their 

agency. Non-DHS personnel detailed to the NTC-P can also 

conduct research for their own investigations with information 

from NTC-P experts or DHS databases. The NTC-P currently has 

DHS liaisons from several components: ICE, TSA Office of 

Intelligence, TSA Federal Air Marshal Service, the USCIS Fraud 

Detection and National Security Directorate, and the USCG. 

However, there are relatively few liaisons from other federal 

government agencies. For example, the FBI sought the May 2010 

Times Square bombing suspect when he was identified through the 

NTC-P review of APIS passenger manifests. This illustrates the 

need for close cooperation between the NTC-P and FBI. However, 

the FBI does not currently have a NTC-P liaison. NTC-P 

managers told us that there had been an FBI presence in the past 

and they are currently negotiating to re-establish a liaison. The 

Centers for Disease Control and Prevention also does not have 

staff at the NTC-P. Centers for Disease Control and Prevention’s 

public health do not board list, which currently includes fewer than 

100 names, provides information on individuals believed to pose a 

potential health threat. However, any potential health threat that 

includes individuals who were not yet on the list can require the 

NTC-P and Centers for Disease Control and Prevention to locate 

every passenger on an airplane or vessel. NTC-P managers said 

that a liaison could conduct many of the database queries that 

targeting specialists currently conduct. The Department of State 

provides one full-time liaison, but NTC-P managers said that on 

evenings and weekends when their liaison is no longer on site it 

can be difficult to obtain information to respond to visa revocation 

issues. 

Other federal members of the intelligence community do not have 

a liaison at the NTC-P, so the NTC-P relies on CBP members of 

the TSC and Joint Terrorism Task Forces to conduct liaison on 

their behalf. The time-sensitive nature of the NTC-P mission 

merits onsite support. 

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Recommendation 

We recommend that U.S. Customs and Border Protection: 

Recommendation #7: Request liaisons from the Department of 

Justice Federal Bureau of Investigation and the Department of 

Health and Human Services Centers for Disease Control and 

Prevention, key partners for no fly and do not board cases, to 

participate at the National Targeting Center – Passenger. 

NTC-P Staffing Challenges Persist 

Policy changes in response to the recent bombing attempts 

increased the NTC-P workload. To assess whether the NTC-P had 

sufficient staff, we interviewed senior NTC-P managers, Watch 

Commanders, and targeting specialists. We also interviewed 

former NTC-P senior managers, former detailed and permanent 

staff, and officials from the Regional Carrier Liaison Groups and 

overseas operations who work closely with the NTC-P. We 

reviewed assessments that the NTC-P conducted on staff 

resources, recruitment, and retention, surveys they conducted with 

current staff, and exit interviews. Additionally, two inspectors 

observed operations at the NTC-P for a week. 

We concluded that the NTC-P does not have sufficient staff to 

manage the workload. From March 2009 to March 2010, there 

were 54,041 FBI TSDB watch list possible matches, and the 

volume will rise with expansion of the TSDB no fly and selectee 

watch lists. In calendar year 2009, the NTC-P resolved 47,103 

ESTA cases. The number of these cases will grow considerably in 

2010 because it is now mandatory for participating travelers from 

Visa Waiver Program countries to apply for an approved ESTA 

travel authorization in advance of travel to the United States. The 

NTC-P responds to hundreds of calls daily from federal law 

enforcement, intelligence, and immigration officers. It also has 

desks that: (1) cover visa revocations and do not board cases; (2) 

support Immigration Advisory Program officers; (3) screen 

inbound and outbound flights; and (4) support screening 

coordination with foreign governments, which include Canada and 

the United Kingdom. 

NTC-P managers estimated that they would need about 230 

additional staff to effectively manage the caseload. This staffing 

level would enable additional targeting specialists to work on each 

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of the NTC-P desks and still cover training and leave requirements. 

Before the December 2009 bombing attempt, the NTC-P 

announced 25 vacancies, but hiring did not occur due to budget 

restrictions. Since then, the NTC-P obtained some temporary duty 

(TDY) employees from CBP ports of entry and from the CBP 

Border Patrol to supplement existing staff. The NTC-P has 

recently advertised for an additional 20 temporary positions to be 

spread throughout the multiple shifts. The NTC-P would need to 

increase the number of positions further to have sufficient staff for 

each shift. 

The NTC-P currently addresses its staffing shortages with heavy 

use of overtime (200%), administratively uncontrollable overtime, 

and TDY staff recruited from the field offices. In some cases, 

targeting specialists work up to four additional hours after their 

original shift without advance notice. Every day we observed a 

Watch Commander call staff at home throughout the morning to 

try to find staff to work additional overtime hours to cover highpriority desks. Reliance on mandatory overtime to address staffing 

shortfalls for an extended period has become ineffective, as staff 

turnover and sick leave usage is prevalent. 

The NTC-P has also moved staff from lower vetting priorities to 

cover possible no fly and do not board matches. The cases that 

now receive lower priority include aggravated felons who attempt 

to enter the United States, visa revocation cases, and ESTA 

denials. If the NTC-P misses a match to derogatory information 

and therefore does not prevent the traveler from boarding, these 

inadmissible aliens arrive at domestic ports of entry. Inadmissible 

aliens who arrive at ports of entry add to the workload of DHS 

officers, immigration judges, and government attorneys. All 

inadmissible aliens must be questioned and detained for removal, 

and many must be placed in removal proceedings before an 

immigration judge, with an ICE attorney to represent the 

government in the proceedings. In addition, the NTC-P is 

mandated to notify federal, state, tribal, and local law enforcement 

when an individual under a warrant attempts to flee the country, 

but staff conduct these searches only when time permits. 

Additional staff would allow the NTC-P to resume these essential 

law enforcement functions, respond adequately to crisis situations, 

provide screening for national security special events, and assist 

staff who must vet multiple hits on short notice. 

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Staff constraints have also led the NTC-P to curtail its information 

collection and data analysis. CBP officers at ports of entry, and 

Immigration Advisory Program officers at overseas airports, 

collect and report information on travelers who have been 

questioned due to an unresolved TECS record. The information 

can include names, telephone numbers, addresses, and second 

passports or identity documents in other names. When checked, 

these leads can provide a key link between travelers who were 

interviewed and known or suspected terrorists or criminals, or 

organized immigration fraud. We observed a targeting specialist 

on the Advance Targeting Team (ATT) conducting link analysis 

on potential associates of a financial fraud ring; the officer said 

that the team can work these cases only when their time was not 

devoted to higher priority screening. 

Time for other than higher priority screening is increasingly rare 

for NTC-P staff. Other CBP units that conducted link and trend 

analysis on passengers, such as the Regional Carrier Liaison 

Group, told us they no longer are able to do much analysis given 

their expanding workload. Officials we interviewed throughout 

DHS singled out the skills of the more experienced targeting 

specialists at the NTC-P, and the screening software used by 

CBP—ATS-P—as the most sophisticated analysis resources 

currently available in DHS. NTC-P managers said they could 

rebuild the NTC-P ATT link and data analysis capabilities with a 

staff of 230 officers. We consider this a reasonable investment in 

the ability of DHS to “connect the dots” in terrorism and criminal 

cases. 

Recommendations 

We recommend that U.S. Customs and Border Protection: 

Recommendation #8: Increase full-time or temporary duty staff 

to a minimum of 230 Customs and Border Protection officers at 

the National Targeting Center – Passenger. 

Recommendation #9: Dedicate full-time or temporary duty staff 

at the National Targeting Center – Passenger to expand the 

Advance Targeting Team so that the team can conduct data 

analysis and follow up on leads other Customs and Border 

Protection Officers develop. 

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NTC-P Staff Recruitment and Retention Needs Improvement 

Increasing the number of positions at the NTC-P will alleviate 

staffing shortages only if the NTC-P also addresses chronic 

difficulties with recruiting and retaining staff. Current and former 

NTC-P staff and managers commented that additional NTC-P 

responsibilities since the December 2009 bombing attempt have 

added stress to an already strained workforce. Managers informed 

us that in 2008, the NTC-P conducted a study of its recruitment 

and retention problems, but did not implement recommendations 

due to insufficient staff to cover proposed changes. The NTC-P 

has discontinued programs and initiatives which could improve 

work-life balance and staff retention if reinstated. For example, in 

surveys, exit interviews, and staff meetings, targeting specialists 

identified the availability of an alternate work schedule, which 

exchanges a longer workday for an extra day off each week or each 

pay period, as a strong retention incentive. 

Current and former staff and senior managers at the NTC-P told us 

that recruitment and retention at the NTC-P are more difficult 

because targeting specialists do not have a clear career path for 

advancement either at the NTC-P or elsewhere in CBP. Studies 

that the NTC-P conducted in 2008 on staff retention confirmed this 

assessment, as targeting specialists cited the need for a promotional 

path as a factor in choosing to leave. The career path of targeting 

specialists stops at a non-supervisory position. It can be difficult 

for specialists to demonstrate relevant experience to compete for 

supervisory positions. NTC-P managers currently offer temporary 

supervisory assignments to provide such experience, but staff 

shortages limit these assignments. 

The level of responsibility, the need to operate under stressful 

conditions, and time constraints at the NTC-P are comparable to 

the work officers at the same grade level performed at CBP 

headquarters. However, NTC-P managers said that most field 

managers do not recognize a tour of duty at the NTC-P as 

comparable to a headquarters tour of duty. Current NTC-P 

managers said that additional training for more experienced staff 

on the databases and underlying immigration laws would benefit 

the NTC-P and enhance the skills of targeting specialists for 

promotion to other CBP positions. Current and former NTC-P 

managers said that if the NTC-P created more analytical positions 

with the ATT, it would provide an incentive for the best targeting 

specialists to remain, either with the opportunity for a temporary 

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assignment to conduct data analysis or as a more permanent career 

path. 

Recommendations 

We recommend that U.S. Customs and Border Protection: 

Recommendation #10: Develop and implement work/life balance 

programs that will promote staff retention at the National 

Targeting Center – Passenger. 

Recommendation #11: Develop a program for career 

advancement within the National Targeting Center – Passenger 

that includes necessary cross-training opportunities and a career 

ladder to better enable qualified analysts and targeting specialists 

to compete for advancement to senior analyst or supervisory 

positions. 

Management Comments and OIG Analysis 

Management Comments: CBP concurred with Recommendation 

#6 [Assess options for obtaining APIS data from carriers earlier, 

and PNR data from reservation systems more frequently, in a 

manner that is cost-effective]. CBP said that it will conduct an 

assessment to identify options for obtaining APIS data earlier in 

the travel process and provide anticipated benefits and impacts 

with each to determine if the benefits gained from such a change 

outweigh the impacts. CBP noted that it had previously proposed 

requiring APIS data 60 minutes prior to departure, but numerous 

comments from the industry indicated that this option would place 

an unreasonable burden on carrier operations. CBP said that it 

would assess the current times for PNR data provisions to identify 

if modifications in these timeframes would provide PNR 

information more timely for increased targeting efficiency. CBP 

stated that the air carrier industry has also previously indicated 

they would like to reduce the number of times they provide PNR 

data due to costs, which presents challenges for increasing the 

frequency of accessing PNR data. 

OIG Analysis: This recommendation is resolved and open. 

Please provide an update on CBP’s assessment of these options, 

including information on the likely costs of both options. We 

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recognize that CBP may conclude from its cost-benefit analysis 

that such improvements are not financially feasible. 

Management Comments: CBP concurred with Recommendation 

#7 [Request liaisons from the Department of Justice Federal 

Bureau of Investigation and the Department of Health and Human 

Services Centers for Disease Control and Prevention, key partners 

for no fly and do not board cases, to participate at the NTC-P]. 

CBP stated that the NTC-P and Centers for Disease Control and 

Prevention are in discussions with Centers for Disease Control and 

Prevention liaison to establish a presence at the NTC-P. CBP 

stated that communication/IT infrastructure for FBI liaison is 

currently being installed. 

OIG Analysis: This recommendation is resolved and open. 

Please provide an update on the efforts CBP has taken to secure 

liaisons from these agencies. We recognize that CBP does not 

have the authority to require other federal agencies to provide 

liaisons, and will close this recommendation based on CBP’s 

efforts rather than on a specific outcome. 

Management Comments: CBP concurred in part with 

Recommendation #8 [Increase full-time or TDY staff to a 

minimum of 230 Customs and Border Protection officers at the 

NTC-P]. CBP stated that the 230 CBP officers mentioned in the 

recommendation includes managerial, supervisory, administrative, 

and support staff, and is an estimate subject to change based on 

fluctuating targeting dynamics. CBP noted that the NTC-P is also 

in the process of attempting to get additional permanent officer 

positions and is trying to reduce the number of TDY officers at the 

NTC-P. CBP said that the NTC-P has identified the need for 55­

75 new permanent officer positions and new, permanent 

managerial, support and administrative positions to support the 

additional staff. CBP said that the 55-75 new CBP officer 

positions are required to adequately staff new or enhanced 

targeting programs including, Pre-Departure screening, ATT 

initiatives, Outbound targeting, Visa re-vetting, and expanded 

Immigration Advisory Program operations. CBP said that the 

officers would be spread across three shifts, to cover a 24-hour 

period. CBP said that the allocation of officers to specific shifts 

and targeting programs is continually evaluated and it is not 

possible to provide a definitive or static number of officers 

required per shift due to the fluid nature of the workflow and everchanging threat streams. CBP said that the due date is dependent 

upon the availability of personnel to fill the NTC-P vacancies, as 

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well as the availability of funding to hire and move selected 

officers. CBP noted that in addition to other variables, staff 

attrition makes it very difficult to maintain a static number of 

personnel. 

OIG Analysis: Based on the specific information CBP provided, 

we consider this recommendation resolved and open. We request 

that CBP provide the following information: 1) any unanticipated 

funding or staffing constraints, such as a hiring freeze, that affected 

staffing; 2) the dates of any announcements for additional 

permanent staff; 3) the number of permanent staff in CBP officer 

positions; 4) the number of TDY staff; and 5) statistics or a 

management report on the workload at the NTC-P. We recognize 

that the NTC-P must remain flexible in its staffing: for example, 

improvements to the ESTA website may reduce the ESTA 

caseload. We also recognize that CBP cannot control all of the 

factors that affect staffing levels, such as funding and attrition. 

DHS directives pertaining to resolution by components of OIG 

recommendations require CBP to update this information every 90 

days. If it can be demonstrated that the NTC-P is making good 

progress towards the goal of 230 staff, or that there are factors 

outside the control of CBP that prevent adequate staffing levels, 

we will close the recommendation. 

Management Comments: CBP concurred with Recommendation 

#9 [Dedicate full-time or TDY staff at the NTC-P to expand the 

ATT so that the team can conduct data analysis and follow up on 

leads other Customs and Border Protection Officers develop]. 

CBP said that permanent staffing solutions for the ATT are 

included in the request for 55-75 new CBP officer positions noted 

above. CBP noted that the due date is dependent upon the 

availability of personnel to fill NTC-P vacancies, as well as the 

availability of funding to actually hire and move selected officers. 

CBP said that in addition to other variables, staff attrition makes it 

difficult to maintain a static number of personnel on any given 

targeting program, such as the ATT, so it is unlikely that a 

definitive “due date” is attainable or realistic. 

OIG Analysis: This recommendation is resolved and open. We 

request that CBP provide evidence of the number of CBP officers 

working for the ATT. Evidence might include an organizational 

chart with the names of assigned officers, a staffing roster, or a list 

compiled specifically for us. We recognize that the NTC-P must 

remain flexible in its staffing, and that CBP cannot control all of 

the factors that affect staffing levels. When the NTC-P is making 

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good progress towards increasing the staffing of the ATT, we will 

close the recommendation. 

Management Comments and OIG Analysis 

Management Comments: CBP concurred with Recommendation 

#10 [Develop and implement work/life balance programs that will 

promote staff retention at the NTC-P]. CBP said that subsequent 

to a Retention Study and Analysis completed in 2008, the National 

Targeting Center-Passenger implemented an active campaign to 

improve its retention rate and enhance its recruiting efforts. CBP 

said that at the request of the NTC-P, CBP-Human Resources 

Management (HRM) provided a report on Recruitment and 

Retention Strategies and provided recommendations to assist with 

these efforts. CBP said that the DHS 5-Step workforce planning 

model was used as a guide for the NTC-P as it continued its 

growth process. CBP said that in support of its Retention Study, 

the NTC-P conducted two internal surveys, in 2008 and 2009. 

CBP said that at the request of the NTC-P, HRM also completed 

independent exit surveys for the same years. CBP said that the 

Office of Field Operations Human Capital Division meets on a 

regular basis with NTC-P management to ensure that its staffing 

levels are maintained and that any recruitment issues are resolved 

expeditiously. CBP said that the study and surveys revealed a need 

to concentrate on the following: Job Satisfaction, Leadership and 

Management Knowledge, Employee Training, Quality of Life 

Concerns, Awards Performance, Employee Recognition, and 

Career Enhancement Opportunities. CBP said that as a result, the 

NTC-P implemented the following successful changes: 

1.	 Improved its hiring processing and posting vacancy 

announcements 

2.	 Implemented an Awards Recognition Day 

3.	 Initiated an employee designed newsletter 

4.	 Developed an Employee of the Month Program 

5.	 Established permanent shifts with rotating long weekends 

6.	 Established a permanent Training Team 

7.	 Provided employees with multiple programs – e.g. IAP, 

ESTA, TSDB and Visa Revocation Unit, and Outbound for 

periodic rotations 

8.	 Promoted external activities – e.g. Bring Your Child to 

Work Day, Combined Federal Campaign, blood drives, and 

food drives 

9.	 Increased career ladder to the GS-13 level 

10. Participated in the Student Career Experience 

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CBP said that since the NTC-P continues to grow in its 

responsibilities and staffing, the staff retention efforts remain one 

of its most important programs. CBP said that therefore, the NTCP will continue to survey the staff on a yearly basis and implement 

changes that are within its control. 

OIG Analysis: This recommendation is resolved and open. 

During the period of our review, we were aware that NTC-P had 

sought comments from current and former employees on work/life 

balance concerns, and had developed innovative programs such as 

those described above. During the period of our review, many had 

been suspended or curtailed because of staffing shortages. We 

request that CBP provide examples of the implementation of items 

2, 4, 5, and 9. Evidence might include an agenda for item 2; a list 

of three recent Employee of The Month recipients for item 4; an 

assignment roster for a completed two-week period for item 5; and 

a position description and list of employees who have been 

promoted on the career ladder to a GS-13 for item 9. We 

commend the staff and management of the NTC-P for striving to 

identify and address work/life balance issues during a period of 

increasing workloads and limited resources. 

Management Comments: CBP concurred with 

Recommendation #11 [Develop a program for career advancement 

within the NTC-P that includes necessary cross-training 

opportunities and a career ladder to better enable qualified analysts 

and targeting specialists to compete for advancement to senior 

analyst or supervisory positions]. CBP said that the Leadership 

Organization Development Division within CBP Office of 

Training and Development will work with the Office of Field 

Operations on this effort, to develop a CBP Succession 

Management System. CBP said that NTC-P staff will take a major 

role in defining jobs, competencies required, training and 

development needed to meet competency levels, and the means for 

assessing when a certain level of competence is achieved. CBP 

said that it is in the first phase of codifying the Succession 

Management procedures for senior leader and leader pools, and the 

next step will be to address supervisory and non-supervisory 

procedures during FY 2011. CBP said that the effort for all levels 

involves a significant amount of information from all CBP 

Assistant Commissioner offices, including the Steering Committee 

members who are the subject matter experts on the positions, 

experiences, and training required to hold those positions, and the 

experiences which indicate an individual will be competitive for 

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his or her next job. CBP said that the Office of Training and 

Development will provide the templates for the information that 

must be collected and validated; program offices must complete 

the data collection and analysis. 

OIG Analysis: This recommendation is resolved and open. CBP 

is requested to provide a summary on progress toward developing 

career development opportunities within the NTC-P. We 

commend CBP for its strategic vision for leadership development 

and succession. 

Existing Small Scale Vetting and Interdiction Programs Are 

Effective and Merit Expansion 

DHS has introduced several programs to improve information sharing on 

foreign nationals before they reach U.S. ports of entry. Two programs 

mandated by Congress, the ICE Visa Security Program and the CBP 

Immigration Advisory Program, are deployed to a limited number of 

locations. The USCG BASS initiative is a voluntary collaboration 

between the USCG, US-VISIT, CBP Border Patrol, and the United States 

Attorney’s Offices in Puerto Rico and the Southern District of Florida. 

However, additional funding is required for expansion. These programs, 

which interdict dangerous and inadmissible foreign nationals before they 

reach the United States, merit additional resources. 

ICE Visa Security Units Provide Investigative Expertise, But 

Deployment Overseas Is Slow 

The legislatively mandated Visa Security Program assists the 

Department of State’s effort to screen and vet visa applicants. The 

procedures ICE special agents use in visa security units to resolve 

a case are comparable to those used at the NTC-P. Evaluation of 

visa applicant information in DHS data systems is a complex 

process. It may be necessary to query multiple DHS data systems 

to resolve a case. An agent may need to review biometrics, 

information pertaining to previous U.S. arrivals and departures, 

immigrant benefit applications, prior interviews at ports of entry, 

immigration court records, and ongoing investigations. These 

records are stored in several different data systems. Access to 

fragmented DHS systems, and the specialized experience ICE 

special agents employ when they research and evaluate the data, 

strengthen the visa process. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Our 2008 report described some Department of State resistance to 

the visa security program and to the deployment of ICE agents 

overseas.30 However, subsequent to that report, the Department of 

State has demonstrated an increased level of support. We observed 

one operational visa security unit in our overseas field work and 

visited another country where ICE opened a visa security unit in 

late 2010. ICE agents reported that consular officers now forward 

some cases to ICE for an opinion before they make a visa decision, 

and rely more on ICE to screen and vet visa applications overseas. 

Although the program provides an additional tool to secure the visa 

process, visa security unit deployment overseas has been slow. 

ICE has established visa security units at only 19 of the 57 highrisk posts identified through risk analysis and consultations with 

the Department of State.31 Funding constraints and the complex 

process to obtain approval for additional overseas DHS staff will 

slow further expansion. 

The deployment of visa security units overseas has been a 

challenge, but ICE has introduced technologies and procedures that 

enable agents to screen and vet some applications at ICE 

headquarters. In February 2010, ICE launched web-based Visa 

Security Program tracking software that enables headquarters to 

track fieldwork and assign cases worldwide. The Visa Security 

Program has agents at headquarters who review security advisory 

opinions, which are third agency checks the Department of State 

requests on a small number of visa applications with security 

implications. Shared data systems at the NTC-P allow the Visa 

Security Program liaison to share information on security advisory 

opinion cases. When systems malfunction at an embassy and 

another field office cannot cover the workload, the Visa Security 

Program at headquarters has the technology to provide some 

backup. 

30 DHS OIG, U.S. Immigration and Customs Enforcement Visa Security Program, OIG-08-79, July 2008, 

pp. 20–21. 

31 Riyadh, Saudi Arabia (2003), Dhahran, Saudi Arabia (2003), Abu Dhabi, United Arab Emirates (2005), 

Dubai, United Arab Emirates (2005), Islamabad, Pakistan (2005), Manila, Philippines (2005), Cairo, Egypt 

(2007), Caracas, Venezuela (2007), Montreal, Canada (2007), Hong Kong, SAR (2007), Casablanca, 

Morocco (2008), Frankfurt, Germany (2008), Amman, Jordan (2009), and Jakarta, Indonesia (2009). An 

office in Jeddah, Saudi Arabia, was closed in 2005 but re-opened in February 2010. London, United 

Kingdom, Tel Aviv and Jerusalem, Israel, and Sanaa, Yemen, were added in 2010, after we completed our 

fieldwork. 

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This capability could be used to expand international coverage for 

the Visa Security Program. When DHS and the Department of 

State agree to establish a new visa security unit overseas, it can 

take months to arrange the overseas deployment. During this 

period, some of the ICE agents scheduled to be deployed should 

work in the Visa Security Program headquarters to screen and vet 

applicants from the newly designated country’s caseload. At the 

request of the Department of State, ICE agents should screen 

applicants from some of the other countries designated high-risk 

posts where ICE will not be able to establish a visa security unit in 

the near future. The agents should provide backup to field offices 

when there are system malfunctions or unusually high volumes of 

applications. The Visa Security Program headquarters support 

element would not provide all the functionality of a Visa Security 

Program in an embassy or consulate overseas. The ICE agent 

would not have access to original documents or the informal faceto-face exchange with consular officers. However, the 

headquarters support element could address some risks at posts 

without a visa security unit. 

Recommendation 

We recommend that U.S. Immigration and Customs Enforcement: 

Recommendation #12: Establish a Visa Security Program 

headquarters support element to screen and vet visa applications 

for: 1) consular posts already designated for future visa security 

unit expansion; 2) high-risk consular posts where expansion is not 

imminent; and 3) Visa Security Units experiencing technical 

difficulties. 

While a Valuable Asset, the Immigration Advisory Program Is 

Not at Its Full Potential 

The CBP Immigration Advisory Program is a valuable 

counterterrorism, law enforcement, and facilitation asset for DHS, 

foreign partners and airlines. IAP officers intercept high-risk 

passengers who seek to board flights to the United States. Officers 

also monitor airport security and observe and talk to passengers 

bound for the United States, and observe airport authorities as they 

conduct security checks and baggage searches. When time 

permits, officers assist foreign nationals to resolve ESTA 

application issues or assist airlines that cannot locate approvals in 

the airline system. Officers may also assist legitimate travelers 

Information Sharing On Foreign Nationals: Overseas Screening 


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who have lost documents, which reduces the caseloads of consular 

officers and DHS staff who would otherwise need to draft 

transportation letters. 

The IAP does not operate at its full potential. Federal law requires 

CBP to identify 50 locations for expansion. Negotiations are 

ongoing to place officers at additional airports. As with the Visa 

Security Units, the complex process to obtain approval for 

additional overseas assignment of DHS staff slows the addition of 

Immigration Advisory Program officers. CBP has deployed 

officers to 10 airports in eight countries for the IAP. In the 

locations we visited, the teams were understaffed for the expanded 

workload that resulted from the December 2009 bombing attempt. 

Additions to the TSDB watch list and State Department visa 

revocations require resolution of more possible hits. Officers are 

asked to interview more U.S. citizens and permanent residents to 

determine whether they should be allowed to board and to obtain 

information on prior travel. With the introduction of mandatory 

ESTA applications in January 2010, the need to resolve 

inappropriate ESTA denials has grown. 

Additional IAP resources are needed because of the large number 

of departure gates at major international airports, the distances 

between those gates, the number of departures from the busier 

airports, and the need to station an officer at the gate to observe 

passengers in the event of a no-fly case. Officers must prioritize 

cases without full information. For example, they must often 

decide between a possible match to a TSDB hit and a likely match 

involving a visa revocation. 

IAP team leaders start their days by reviewing possible NTC-P 

matches before leaving home. While working in the airport, 

officers have limited access to DHS computer systems and 

databases. Data entry may not be completed until after the last 

flights have departed and they have returned home. Team leads 

remain on call overnight, on weekends, and when on leave locally. 

Two of the four IAP teams we visited operated with 6-month TDY 

staff. Even with experienced temporary officers, the teams can 

find it difficult to establish and maintain working relationships 

with local security officials. 

At each of the four sites we reviewed, the program would benefit 

from at least one additional permanent or TDY CBP officer. This 

would provide more backup for team leads, allow teams to better 

manage multiple simultaneous hits, expand screening interviews, 

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and improve liaison with local officials. It would also enable CBP 

to assist legitimate travelers to resolve document problems when 

asked by the local consulate, host government, or airline. Officers 

currently have time to take on only a few such cases a day. 

With expanded support for ESTA applicants, the IAP might fund 

staff to assist with ESTA applications, which would also provide a 

surge capacity for resolving terrorist and criminal cases. Officials 

from three of the four IAP sites we reviewed said there were more 

ESTA cases than current staff could manage. The Implementing 

Recommendations of the 9/11 Commission Act of 2007, which 

established ESTA, permits CBP to collect fees, set at a level that 

will ensure recovery of the full costs of providing and 

administering the system. Soon CBP will need to transition to a 

fee-based structure for ESTA.32 Assisting with ESTA cases is one 

IAP responsibility, and CBP should consider whether ESTA fees 

might fund some additional IAP positions. 

Recommendation 

We recommend that U.S. Customs and Border Protection: 

Recommendation #13: Assess and report on the feasibility of 

using Electronic System for Travel Authorization fees to fund 

some Immigration Advisory Program positions in airports from 

which visa waiver nationals depart. 

Connectivity Issues Hamper the USCG BASS 

The BASS represents an innovative information-sharing venture 

by the USCG and US-VISIT. If the identity, nationality and 

potential security or criminal threat of an interdicted person could 

be positively established at sea, it would be possible to make 

informed decisions about which migrants to bring to U.S. territory. 

Specifically, the USCG would bring only those migrants who 

needed international protection or whom the U.S. Attorney’s 

Office agreed to prosecute as criminals, smugglers, or repeat 

offenders. While biometric technology is central to the success of 

this program, cooperation between federal agencies and with the 

migrants’ countries of origin, is also essential. 

32 A fee of $14 for each ESTA application was introduced in September 2010, after field work was 

completed for this report. 

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BASS uses a hand-held biometric device that records two 

fingerprints and a photograph; a computer to process the 

fingerprints; a second computer to transmit the encrypted data to 

shore; and maritime satellite communications service to transmit 

the data. The transmitted fingerprints are compared to biometrics 

already stored in IDENT and any new identities are enrolled. As 

our inspectors observed during a visit to a cutter, biometric 

enrollment is a difficult, time-consuming process. The USCG 

usually works in rough seas as it transfers migrants from their 

flimsy seacraft onto the cutter while simultaneously maintaining 

order, providing food and medical assistance to the migrants, and 

operating delicate and slow BASS equipment. When the BASS 

equipment works properly and there are about 40 migrants on 

board, it can take 24 hours to process biometric enrollments, 

transmit data, and determine which migrants will be prosecuted or 

repatriated. Conditions are not usually optimal. Under adverse 

conditions, it can take 2 to 3 days to process 40 migrants. 

Crewmembers who process biometric enrollment of migrants often 

work around the clock until data transmission is completed and 

return with little rest to perform other duties. 

Using biometrics acquired at sea to identify potentially dangerous 

aliens or aliens who have repeatedly attempted to enter the US for 

criminal prosecution, has proven to be an effective deterrent to 

maritime migration. However, on our site visit to Puerto Rico we 

noted several challenges that seriously hinder efficiency, such as 

outdated or insufficient technology. For example, the most 

significant challenge for the BASS is the timely transfer of 

biometric information to IDENT to avoid unduly prolonging the 

period migrants are held at sea for processing. The primary data 

link on USCG cutters utilizes maritime satellite communications. 

The existing equipment has a transmission speed of about 64 

kilobits per second. USCG crews reported the transmission of 

biometric data is inconsistent due to the erratic speed of service. 

When connectivity is sporadic, transmission of data can take 6 to 7 

hours and in rare cases 24 hours. If the system malfunctions, the 

biometric crew must re-fingerprint migrants and then process and 

retransmit the biometric data. USCG officials said that a contract 

was submitted for upgrading to a faster satellite communications 

service, but problems with the contract and availability of funds 

delayed the upgrade. 

The two-print hand-held device that collects biometric information 

is not optimal for maritime conditions, as migrants intercepted at 

sea may be dehydrated, or their fingers may have been immersed 

Information Sharing On Foreign Nationals: Overseas Screening 


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in sea water, which can make it more difficult to collect two good 

readable fingerprints. With 10 prints, the chances of matching 

prints to an existing IDENT record increases. Additionally, the 

data from portable two-print devices may not match latent 

fingerprints from crime scenes. However, the USCG cannot 

switch to portable ten-print devices because the satellite service 

does not have sufficient bandwidth. 

Moreover, USCG cutters that operate off the eastern coast of 

Puerto Rico do not have satellite communication equipment. After 

they collect data from interdicted migrants, the cutters return to 

shore to transmit the information. The USCG must decide whether 

to bring an interdicted migrant onto U.S. territory or lose custody 

when it does not know what information is available in DHS 

databases. Given that the caseload off the eastern coast of Puerto 

Rico is more varied than the largely Dominican population 

interdicted on the western shore, the USCG may miss the 

opportunity to detain migrants who pose a serious risk to the 

United States. 

Although the USCG captures and transmits fewer biometrics off 

the coast of south Florida, operable satellite communication is 

essential in this area as well. USCIS refugee officers conduct 

protection screening interviews for interdicted migrants on the 

cutters at sea. The officers use USCG satellite communication to 

transmit their preliminary protection decisions to USCIS 

headquarters for review. There are frequently delays in the 

transmission of data, in some cases for more than eight hours, 

which can slow migrant processing. 

Recommendation 

We recommend that the U.S. Coast Guard: 

Recommendation #14: Upgrade current maritime satellite 

communication equipment to provide high-speed transmission 

capabilities. This would enable cutters that interdict migrants to 

conduct 10-print biometric enrollment. 

Management Comments and OIG Analysis 

Management Comments: ICE concurred with Recommendation 

#12 [Establish a Visa Security Program headquarters support 

element to screen and vet visa applications for: 1) consular posts 

Information Sharing On Foreign Nationals: Overseas Screening 


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already designated for future visa security unit expansion; 2) highrisk consular posts where expansion is not imminent; and 3) Visa 

Security Units experiencing technical difficulties]. ICE stated that 

the Visa Security Program has established a Security Advisory 

Opinion Unit which serves as the headquarters support element. 

ICE stated that the unit does conduct screening and vetting of 

consular posts designated for future expansion and provides 

support to overseas ICE Attaché offices conducting visa security 

operations when they have technical difficulties. ICE stated that 

the Security Advisory Opinion Unit supports all consular issuing 

posts worldwide and expects to add two additional analysts in 

January 2011. Additionally, ICE stated that it is pursuing 

cooperation from the Department of State and Customs and Border 

Protection for the enhancement of existing technologies to increase 

the efficiency of screening and vetting operations. ICE stated that 

it strongly believes that conducting operations remotely is not a 

substitute for deploying ICE Special Agents to consular issuing 

posts to work cooperatively with Department of State personnel 

issuing visas and feels this is required in order to fulfill its mandate 

in the Homeland Security Act of 2002. 

OIG Analysis: This recommendation is resolved and open. We 

agree that deploying Special Agents to the field is preferable to 

relying solely on the headquarters unit, when funding and logistics 

permit. We request ICE provide an update on the level of 

increased coverage by the headquarters Security Advisory Opinion 

Unit. 

Management Comments: CBP concurred with Recommendation 

#13 [Assess and report on the feasibility of using ESTA fees to 

fund some Immigration Advisory Program positions in airports 

from which visa waiver nationals depart]. CBP stated that the 

ESTA fee must ensure recovery of the full costs of providing and 

administering the system. CBP said that the ESTA fee statute was 

written narrowly in scope with strict limitations that prevent CBP 

from recovering excess money. CBP said that in developing the 

ESTA fee, CBP evaluated many different costs and completed an 

extensive fee analysis to determine what costs could be included in 

the fee. CBP said that the analysis was submitted to the Office of 

Management and Budget who reduced the proposed fee amount 

before approving. CBP said that it will consult with the Office of 

Chief Counsel to determine the feasibility of funding Immigration 

Advisory Program positions. 

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OIG Analysis: This recommendation is resolved and open. We 

request a report on the outcome of the consultation with the Office 

of Chief Counsel. We recognize that CBP must comply with legal 

interpretations of the statute and regulations, and that in any event 

ESTA fees would fund only a portion of Immigration Advisory 

Program positions, as ESTA passengers represent only a portion of 

their duties. We will close this recommendation based on CBP’s 

efforts rather than on a specific outcome. 

Management Comments: The USCG concurred with 

Recommendations #14 [Upgrade current maritime satellite 

communication equipment to provide high-speed transmission 

capabilities. This would enable cutters that interdict migrants to 

conduct 10-print biometric enrollment]. The USCG said that it is 

assessing means to improve cutter connectivity and bandwidth for 

segments of the cutter fleet to include BASS-equipped units. The 

USCG said that BASS meets the DHS standard for two-print 

collection. 

OIG Analysis: This recommendation is resolved and open. The 

DHS minimum standard for print collection is two prints, but tenprint collection is widely employed across the Department of 

Defense, Department of Justice, and DHS. USCG should provide 

an update on the USCG’s assessment of the means to improve 

connectivity and bandwidth for segments of the cutter fleet. We 

recognize that funding constraints may affect implementation. 

DHS Officers Need Assistance Navigating Fragmented Data 

Systems 

Data System Shortfalls Impede Overseas Officer Effectiveness 

To determine whether foreign nationals represent a terrorist or 

criminal threat, or are eligible for an immigration benefit, DHS 

officers abroad routinely use more than 17 data management 

systems. A single sign-on to these systems would improve 

productivity and accuracy. Most of the officers we interviewed 

overseas said each DHS data system requires a unique username 

and password. Usernames vary from assigned codes to email 

addresses, and passwords require letters, numbers, and symbols in 

different sequences. Users need to manage multiple usernames 

and passwords to log onto the various systems. Expiration cycles 

for passwords vary from 30 to 90 days, and infrequent use of 

systems with short password cycles often means users are locked 

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out of databases. When users are locked out of databases, it may 

require written authorization from a regional office or headquarters 

to reinstate a lapsed password, which creates a delay. 

In the overseas environment, it is often necessary to log off of one 

data system to log onto another, which—coupled with automatic 

log-offs of open systems after 15 to 20 minutes for security 

purposes—makes checks in multiple systems a time-consuming 

process. Some officers whose passwords have lapsed ask their 

DHS colleagues to conduct searches for them. 

The productivity cost of multiple passwords is difficult to 

calculate. Some officers said they cumulatively spend several 

hours a week logging into and out of data systems, and most 

officers conduct searches on behalf of colleagues. Because it is 

difficult to check across systems, a more serious potential outcome 

is that an officer might not consider all available information on a 

case that initially appears straightforward. The Office of the Chief 

Information Officer confirmed that a single sign-on for the data 

systems used by multiple DHS components is feasible and would 

not constitute a security risk. While overseas officers may have 

the greatest difficulty managing multiple passwords and expiration 

cycles, a single sign-on would also benefit officers domestically. 

The DHS systems most widely used by multiple components 

overseas include the following: 

�	 ADIS 

� ATS-P 


� ESTA
 

�	 ENFORCE / Enforce Alien Removal Module (EARM) 

�	 IDENT 

� Intel Fusion / Avalanche
 

� ISRS
 

�	 SEVIS 

�	 TECS (including data fields formerly known as the 


Interagency Border Inspection System, or IBIS) 


�	 CIS, CLAIMS3, Computer Linked Application Information 

Management System 4 (CLAIMS4), Refugees, Asylum, 

and Parole System (RAPS) 

DHS officers who were familiar with the full range of available 

data systems also reported that it was difficult to navigate the many 

web-based systems used to track foreign nationals. There is 

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currently no consolidated access to the web-based DHS data 

systems. Officers must obtain web addresses individually from 

several offices within each component. A single portal on the 

DHS intranet, the secure Homeland Security Information Network 

(HSIN), would improve efficiency through consolidated access to 

web-based systems. 

A single intranet portal would resolve only some of the challenges 

inherent in the DHS systems. Many key databases, such as TECS 

and CIS, predate today’s internet architecture, and may not be 

adaptable for intranet use. However, a single web-based portal 

could be used to consolidate information for users on what data 

systems exist and how authorized users can obtain access. Several 

officers overseas reported they learned of valuable systems or 

useful search capabilities only through word of mouth or were 

uncertain of the capabilities of systems they did not use. 

The DHS web-based systems that could be consolidated on a 

single intranet portal include the following: 

� ADIS 

� ATS-P 


� ESTA
 

� ENFORCE / EARM 

� IDENT 

� Intel Fusion / Avalanche
 

� ISRS
 

� SEVIS 

DHS officers reported they sometimes lacked confidence that their 

searches had in fact yielded all of the accurate, current information 

in DHS databases. We were told that users need to be aware of the 

structures of the databases, what information is captured for what 

purpose, and whether the accuracy of some search results needs to 

be verified against other sources. While NTC-P targeting 

specialists knew the limitations of the data they used, many 

overseas officers said they did not have enough training and 

experience on the systems, and they addressed a wider range of 

issues than what NTC-P targeting specialists address. For 

example, responsibility for the issuance of transportation letters 

shifts among CBP, ICE, and USCIS, to address workload needs. 

CBP and ICE attachés may need to provide current travel and 

immigration information to local law enforcement to support a 

joint investigation. 

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There is a headquarters initiative underway that could be adapted 

to address this need. In November 2009, the department initiated a 

Bottom Up Review which, among other accomplishments, 

recommends creating an integrated departmental Information 

Sharing Architecture to consolidate and streamline access to 

intelligence, law enforcement, screening, and other information 

across the department.33 To address screening requirements, the 

department identified the need for a Controlled Homeland 

Information Sharing Environment to strengthen information 

sharing on person-centric data. Planning toward this goal includes 

the Screening Coordination Office, the Office of the Chief 

Information Officer, and Intelligence and Analysis, as well as 

representatives from the Privacy Office and the Office of the 

General Counsel, and coordinates through the Information Sharing 

Governance Board. 

Recommendations 

We recommend that the Office of the Chief Information Officer: 

Recommendation #15: Enable officers and analysts to use a 

single sign-on for DHS systems used for screening foreign 

nationals. 

Recommendation #16: Provide additional resources to establish a 

portal on the secure Homeland Security Information Network 

through which authorized DHS users can log on to DHS webbased databases to access information on foreign nationals. 

We recommend that the Office of Policy Screening Coordination 

Office: 

Recommendation #17: Provide additional personnel for the 

Controlled Homeland Information Sharing Environment, which 

supports the Bottom Up Review Initiative for a DHS Integrated 

Information Sharing Architecture. This initiative would assist 

authorized users in navigating DHS data systems to access 

information on foreign nationals. 

33 http://www.dhs.gov/xlibrary/assets/bur_bottom_up_review.pdf 

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Overseas DHS Officers Require Additional Training on 

Immigration Enforcement and Benefits 

DHS overseas staff is expected to understand more of the process 

by which DHS tracks and evaluates foreign nationals than their 

domestic counterparts. The State Department and host 

governments routinely ask overseas staff questions about all DHS 

functions. However, some officers have limited immigration 

backgrounds or experience and minimal pre-deployment training 

on DHS data systems. Insufficient knowledge of immigration 

issues and operational challenges with DHS data systems make it 

difficult to screen and process cases, and limit the ability to share 

valuable information. In most offices we visited overseas, officers 

with an immigration background provided informal assistance to 

many of their colleagues. Officers with experience using legacy 

systems such as TECS, CIS, CLAIMS3, and EARM conducted 

research to assist colleagues. While this practice demonstrates a 

commitment to information sharing, it also has a negative effect on 

productivity. In addition, many officers commented that they did 

not know what all of the relevant DHS data systems were. 

The Office of Policy, Office of International Affairs, has 

recognized that Department of State consular officers and host 

governments expect DHS officers overseas to be able to answer a 

broad range of questions about DHS operations. With the 

exception of legacy immigration officers, most USCIS, ICE, and 

CBP officers have been trained on either immigration benefits or 

immigration enforcement, but not both. USCG International Port 

Security Liaison Officers and International Training Team 

members are not trained in all areas of immigration law, but are 

asked for information by host governments they work with in the 

maritime domain. TSA officers and senior legacy customs service 

officers in CBP and ICE may not have ever received formal 

training on immigration benefits or enforcement. The Office of 

International Affairs concluded that DHS should provide its 

overseas staff with cross-component training. In its International 

Strategic Framework, the Office of International Affairs identified 

providing the necessary skills, knowledge, and training to 

effectively carry out DHS international activities as objectives for 

DHS overseas employees. Cross-training on immigration 

enforcement and benefits would contribute to productivity. 

Training on how to use data systems to obtain accurate, current 

information on foreign nationals could improve efficiency. 

Training staff from CBP, the USCG, ICE, and USCIS may be able 

to assist in the development of an overseas training using materials 

Information Sharing On Foreign Nationals: Overseas Screening 


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developed for domestic officers, or may be able to provide subject 

matter expertise. 

Recommendation 

We recommend that the Office of Policy Office of International 

Affairs: 

Recommendation #18: In consultation with training staff from 

CBP, ICE, and USCIS, develop training designed to provide an 

overview for overseas DHS officers on immigration law, DHS and 

other federal government programs, policies and procedures 

related to foreign nationals, and DHS and other federal data 

systems that house information on foreign nationals. 

Management Comments and OIG Analysis 

Management Comments: CIO concurred with Recommendation 

#15 [Enable officers and analysts to use a single sign-on for DHS 

systems used for screening foreign nationals]. CIO said that it 

generally agreed with the intent of the recommendations as a 

means to improve the effectiveness of Information Sharing on 

Foreign Nationals. CIO said that a change to the text would 

provide additional clarity, and suggested that the text read “Provide 

additional resources to make available the enterprise single sign on 

capability that enables officers and analysts to use a single sign-on 

for the DHS systems used for screening foreign nationals.” 

OIG Analysis: This recommendation is resolved and open. We 

read the CIO comment to mean that it agrees with the intent of this 

recommendation, but will need additional resources. Providing a 

single sign on would improve productivity for thousands of DHS 

employees. When CBP Officers have less than 30 minutes to 

determine whom to board, a single sign on may help avoid costs 

associated with allowing inadmissible aliens to board. To close 

this recommendation, please provide a detailed estimate of the 

resources necessary to provide single sign on capability. Please 

also provide a copy of the CIO budget request and justification for 

additional resources for implementing single sign on by October 

31, 2011. 

Management Comments: CIO concurred with Recommendation 

#16 [Provide additional resources to establish a portal on the 

secure HSIN through which authorized DHS users can log on to 

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DHS web-based databases to access information on foreign 

nationals]. CIO said that it generally agreed with the intent of the 

recommendations as a means to improve the effectiveness of 

Information Sharing on Foreign Nationals. CIO said that a change 

to the text would provide additional clarity, and suggested that the 

text read, “Provide additional resources to establish a capability on 

the DHS HSIN through which authorized DHS users can discover 

information on how to obtain access and log on to DHS web-based 

databases to access information on foreign nationals.” 

OIG Analysis: This recommendation is resolved and open. We 

read the CIO comment to mean that while it agrees with the intent 

of this recommendation, it would need additional resources. 

Establishing a portal on the DHS HSIN would improve 

productivity for thousands of DHS employees. To close this 

recommendation, please provide a detailed estimate of the 

resources necessary to establish a portal. Please also provide a 

copy of the CIO budget request and justification for additional 

resources for implementing single sign on. 

Management Comments: The Office of Policy concurred with 

Recommendation #17 [Provide additional personnel for the 

Controlled Homeland Information Sharing Environment, which 

supports the Bottom Up Review Initiative for a DHS Integrated 

Information Sharing Architecture. This initiative would assist 

authorized users in navigating DHS data systems to access 

information on foreign nationals]. The Office of Policy stated that 

during the next budget request cycle, it will request additional 

personnel for the Controlled Homeland Information Sharing 

Environment. 

OIG Analysis: This recommendation is resolved and open. 

Upgrading the Controlled Homeland Information Sharing 

Environment would improve productivity for thousands of DHS 

employees. Please provide a copy of the Office of Policy budget 

request and justification for additional personnel for the Controlled 

Homeland Information Sharing Environment. 

Management Comments: The Office of Policy concurred with 

Recommendation #18 [In consultation with training staff from 

CBP, ICE, and USCIS, develop training designed to provide an 

overview for overseas DHS officers on immigration law, DHS and 

other federal government programs, policies and procedures 

related to foreign nationals, and DHS and other federal data 

systems that house information on foreign nationals]. The Office 

Information Sharing On Foreign Nationals: Overseas Screening 


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of Policy stated that since April 5, 2010, this initiative has been 

integrated into the DHS International Strategic Framework. The 

Office of Policy provided written guidance under the Homeland 

Security Priority – “Maturing and Unifying the Department,” 

Objective 5.5 states – “Provide DHS employees with the necessary 

skills, knowledge, and training to effectively carry out DHS 

international activities.” 

The Office of Policy also stated that DHS is engaged in ongoing 

efforts to enhance the capabilities of DHS personnel serving in any 

capacity overseas including the establishment of a standard course 

of instruction that would provide an overview of the multiple DHS 

international programs, policies, operations, systems and 

capabilities that they would need to know about or would 

encounter overseas. The Office of Policy stated a key feature 

would be to provide resources for staff, before they are assigned 

overseas, to include protocols, procedures, current issues, and 

perhaps most importantly direct contact for information. 

The Office of Policy advised that the Federal Law Enforcement 

Training Center (FLETC) is now developing a standard DHS 

international pre-deployment training course that will combine 

both the security considerations for DHS officials operating 

overseas and information regarding the DHS roles and missions 

internationally that will provide the individual a good foundation 

of the broad scope of DHS international work. FLETC will 

continue to consult with DHS as they progress to meet this 

requirement. 

OIG Analysis: This recommendation is resolved and open. 

Please provide the draft or final training and guidance provided to 

DHS staff overseas. Please also provide status reports which 

include evidence of consultation with training officers at CBP, 

ICE, and USCIS regarding requirements of the training course, and 

any additional training development initiatives provided by 

FLETC regarding the DHS international pre-deployment training 

course. 

Information Sharing On Foreign Nationals: Overseas Screening 


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Appendix A 

Purpose, Scope and Methodology 

We initiated this review to evaluate how biographic and biometric 

information is shared among DHS components. We focused our 

review on: 

�	 How components check and evaluate information; 

�	 The timeliness and thoroughness of information sharing; 

�	 The strengths and weaknesses of current informationsharing procedures; 

�	 What plans exist to consolidate information and improve 

data analysis; and 

�	 What short-term solutions might be implemented to 


improve information sharing. 


This is the first of a series of reports that will discuss information 

sharing. Although some of our recommendations cover all DHS 

information-sharing programs, we limited the scope of this report 

to initiatives to screen foreign nationals while they are still 

overseas. Additional reports will examine information sharing on 

foreign nationals at the border and in domestic programs. Our 

scope was limited to programs that evaluate foreign nationals. We 

did not review measures for U.S. citizens, except for travel 

screening programs that cover all passengers. We also did not 

evaluate programs that provide physical security overseas nor did 

we review cargo screening. We did not focus on privacy, civil 

rights, and civil liberties, or redress aspects of the systems or 

processes under review. Although the focus of this review was on 

overseas operations, some recommendations were written to 

improve all DHS information-sharing programs. 

We conducted fieldwork for this report from February to June 

2010. We conducted 110 individual and group interviews, which 

included 250 DHS personnel. We interviewed personnel from five 

operational components: CBP, ICE, TSA, the USCG, and USCIS. 

We determined that TSA employees who work in DHS offices 

overseas did not play a significant role in information sharing on 

foreign nationals at the time of our fieldwork, but may do so after 

Secure Flight is fully operational on international flights after 

December 2010. We interviewed personnel from several 

headquarters support offices, including the Office of Policy 

Screening Coordination Office and Office of International Affairs; 

Office of Intelligence and Analysis Border and Immigration 

Analysis Division, Information Sharing and Collaboration Branch 

and National Immigration Information Sharing Office; US-VISIT; 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 59
 
Appendix A 

Purpose, Scope and Methodology 

the Office of Management Office of the Chief Information Officer; 

and the Counterterrorism Section in the Office of Operations 

Coordination and Planning. We interviewed experts from several 

of the major DHS data systems, including US-VISIT, TECS, ATSP, ESTA, ENFORCE, SEVIS, ICE Pattern Analysis and 

Information Collection System (ICE-PIC), CIS, USCIS 

immigration tracking systems, and the USCIS planned upgrade, 

Transformation. We reviewed documentation provided by DHS 

components and viewed many data system demonstrations. 

We conducted site visits to DHS offices in Dublin, Ireland; 

London, United Kingdom; Rome, Italy; The Hague, The 

Netherlands; Athens, Greece; Frankfurt, Germany; and Warsaw, 

Poland. Those sites included four Immigration Advisory Program 

locations, four USCIS field offices, five TSA offices, one 

established and one planned visa security unit, and preclearance 

operations in one location. We also interviewed CBP and ICE 

officers at some embassies and consulates, including ICE agents 

who conduct investigations involving foreign nationals and CBP 

officers who issue transportation letters. Our site visits included 

five established Visa Waiver Program countries, one country 

(Greece) that recently became a visa waiver country, and one 

country (Poland) without visa waivers. Because the Icelandic 

volcano eruptions affected our travel, we interviewed the 

Immigration Advisory Program officers who cover Schiphol 

Airport while the airport was closed. Additionally, we interviewed 

DHS officers in Frankfurt by telephone from DHS offices in The 

Netherlands. After flights resumed, we traveled to Frankfurt for a 

short in-person review of data systems. 

OIG inspectors observed NTC-P staff for one week in March 2010 

and conducted a follow-up visit in May 2010. We observed the 

USCG migrant interdiction program, which included the use of 

USCG cutters and search and rescue helicopters, in Puerto Rico in 

April 2010. We also conducted site visits to the Regional Carrier 

Liaison Group at Miami International Airport in Florida in April 

2010, and at John F. Kennedy International Airport in New York 

in May 2010. 

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. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 60
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 61
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 62
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 63
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 64
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 65
 

l

ESTA is II S)-stcm thai is generated by the applicants in the general public. As long as the

input is pro,-ided b) the general population. IheTe are going to be: inpul emirs about

passport numbers and the like; until the public becomes more: aware ofthese data

clements., IheTe "'ill be mistakes.

CDP continues 10 monitor customer feedbacl and make amendments 10 the website as

-'<d.

DUl'Dale: September 30. 2011

R«ommC'ndalion 6: Assess options for obtairnng Advance Passenger Information

S)'Stcm data from carriers earlier. and Passenger Name Rec;ord dala from n:scn.ation

systems more frequently. in a manner that is cast-cfTecli\c

R~llf!n~C': Concur. eBP ",ill condUC1 an assessmclll to identify options for obtaining

APlS data earlier in the t1a\'d process and pro,ide anlicipaled benefits and impacl$ ",ith

each 10 determine irthe benefits gained from such a change oul....~igh the impacts. CBP

pte\iOllSl)' proposed requiring APIS dala 60 minutes prior to departure. but numerous

COlJlJnl;lll$ from the indusU}' indicated that this option would pl3CC an w=asonable

burden on carrier operations.

ellP will assess the currenllimcs for PNR data provisions to identif)' if modifications in

these: tirneframes would provide PNR information more timely for increased targeting

efficiency. The: air carricr industry has also previously inoJicated they would like to reducc

the number oflimes they provide PNR dau dll(' to COSIS. v.hich present! challenges for

increasing the frequenc)' ofaccessing PNR data.

Oue 1):lIe; June 30. 2011

Recommcndation 7; Request liaisons from the Dc:panment ofJustice Fedeml Bureau of

Invcstigation and the Department of I-Icalth and Iluman ServicCll Centers for Discase

Control and Pre\"ention, key partners for no fly and do not board cases. to participate at

the National Targeting Center· Passenger.

Re<IJon,e: Concur, NTC·I' and CDC are in discussions with CDC Liaison prcsenee at

NTC-I'. Communication/IT infrastructure for FBI liaison is currently being installed.

I>ue D~le; Junc 30. 2011

I{{'commendation II: Increase full-time or tcmporury duty stafTto n minimum 0(230

CUSlamS and Border Protection officers at thc National Targeting Center I'assengcr.

Re'IJon<e: Concur in part. Thc 230 CBI' officers (CI3I'Os) mentioned in the

recommcndation includes managerial. supervisory. administmti\'e. and support starr. and

is an estimate subject to change based on fluctuating targeting dynamics. NTC-P is also

in the proccss of attempting to get additional pennanent CBro F11~ positions and is

If)'ing to reduce the numbcrofTDY offieCTS at NTC-I',
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 66
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 67
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 68
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 69
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 70
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 71
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 72
 
Appendix B 

Management Comments to the Draft Report 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 73
 
 

 

 

Appendix C 

Authorities for Information Sharing on Foreign Nationals 

Authorities for Information Sharing on Foreign Nationals 

Statutory Authority 

Immigration and Nationality Act (as amended) 

� Specifies which foreign nationals are eligible to be admitted lawfully 

into the United States, which are not eligible for security, safety, 

public interest, and public health reasons, and which can apply to 

receive a waiver that allows them to be admitted. (Section 212).34 

Aviation and Transportation Security Act of 2001 (PL 107-71) 

� Provides mandatory manifest and passenger name record 

requirements, among other aviation screening requirements. 

(Section 115).35 

Enhanced Border Security and Visa Entry Reform Act of 2002 (PL 

107-173) 

� Requires enhancements to visa issuance technologies (Title III, 

Section 303) 

o Requires DHS and the Department of State to issue aliens only 

biometric-based, machine-readable, tamper-resistant visas and 

other travel and entry documents. 

o Requires DHS to provide equipment and software to allow 

biometric comparison and authentication at ports of entry.36 

o Requires visa waiver governments to use machine-readable, 

tamper-resistant passports that incorporate biometric and 

document authentication.37 

� Requires DHS to track foreign student or exchange visitor program 

participants (Title V, Section 501). 

� Updates requirements for electronic transmission of passenger and 

crew manifests for flights and vessels that arrive or depart from the 

United States (Title 4, Section 402).38 

Homeland Security Act of 2002 (PL 107-296) 

� Requires, unless otherwise directed by the President, that the DHS 

Secretary shall have access to all information that relates to threats 

of terrorism against the United States that may be collected, 

possessed, or prepared by any agency of the federal government 

(Title II, Section 202). 

� Creates DHS, authorizes the DHS Secretary to administer and 

enforce the Immigration and Nationality Act and other laws that 

relate to visas; refuse visas for individual applicants; assign DHS 

officers to diplomatic posts to perform visa security activities; 

initiate investigations of visa security-related matters; and provide 

advice and training to consular officers (Title IV, Section 428)39 

� Establishes procedures to share federal government information with 

DHS (Title VIII, Section 892). 

34 8 U.S.C. Section 1182. 35 49 U.S.C. Section 114. 

36 8 U.S.C. Section 1365b. 37 8 U.S.C. Section 1187. 38 8 U.S.C. Section 1221. 

39 6 U.S.C. Section 236. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 74
 
Appendix C 

Authorities for Information Sharing on Foreign Nationals 

Intelligence Reform and Terrorism Prevention Act of 2004 (PL 108­

458) 

� Requires guidelines for information sharing and establishes a federal 

Information Sharing Council to identify gaps in technologies, 

programs, and systems used by the federal government to share 

information (Title I, Section 1016) 

� Requires in-person interviews for most visas (Title V, Section 5301)40 

� Requires the Department of State to appoint an anti-fraud specialist to 

each high-fraud consular office that does not have a DHS visa security 

unit (Title VII, Section 7203) 

� Calls for international sharing of information on lost and stolen 

passports and other travel documents (Title VII, Section 7204) 

� Calls for the Immigration Advisory Programs to be established in at 

least 50 foreign airports (Title VII, Section 7206)41 

� Requires integration of all databases and data systems that process or 

contain information on aliens that are maintained by DHS ICE, CBP, 

and USCIS, Department of State Consular Affairs, and Department of 

Justice Executive Office for Immigration Review (Title VII, Section 

7208)42 

� Requires DHS to assume from aircraft operators the function of 

preflight comparisons of airline passenger information to federal 

government watch lists for domestic flights and international flights 

to, from, and over the United States (Secure Flight) (Title IV, Section 

4012(a))43 

Implementing Recommendations of the 9/11 Commission Act of 2007 

(PL 110-53) 

� Requires Visa Waiver Program governments to share information on 

whether their citizens represent a threat to the United States, and 

information on lost and stolen passports (Title VII, Section 711)44 

� Requires Visa Waiver Program nationals to obtain an ESTA approval 

before they travel (Title VII, Section 711) 

� Provides DHS authority to admit into the Visa Waiver Program 

countries that otherwise meet requirements, but have refusal rates up 

to 10% (the prior threshold was 3%), provided countries meet certain 

conditions for security and information sharing (Title VII, Section 

711). 

� Requires DHS to ensure effective coordination, with respect to 

policies, programs, plans, operations, and dissemination of 

intelligence and information related to terrorist travel, among DHS 

operational components and with other federal agencies (Title VII, 

Section 722)45 

40 8 U.S.C. Section 1202. 41 8 U.S.C. Section 1225a (b). 

42 8 U.S.C. Section 1365b. 43 49 U.S.C. Section 44903(j)(2). 

44 8 U.S.C. Section 1187. 45 6 U.S.C. Section 123. 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 75 
 

Appendix C 

Authorities for Information Sharing on Foreign Nationals 

Executive Authority 

Homeland Security Presidential Directive 6, September 16, 2003 

� Establishes policy to develop, integrate and maintain thorough, 

accurate, and current information about individuals known or 

suspected to be engaged in terrorism.46 

Executive Order 13388, October 25, 2005 

� Requires federal agencies to give high priority to detecting and 

preventing terrorist activities, and to the interchange of terrorism 

information.47 

DHS Secretary Memorandum, DHS Policy for Internal Information 

Exchange and Sharing, February 1, 2007 (“One DHS” 

Memorandum) 

� Requires each DHS component to give the highest priority to the 

sharing of potential terrorism, homeland security, law enforcement, 

and related information.48 

White House Memorandum, Strengthening Information Sharing 

and Access, July 2, 2009 

� States, “Achieving effective information sharing and access 

throughout the government is a top priority of the Obama 

administration. This priority extends beyond terrorism-related 

issues, to the sharing of information more broadly to enhance the 

national security of the United States and the safety of the American 

people.”49 

46 http://www.dhs.gov/xabout/laws/gc_1214594853475.shtm 47 http://edocket.access.gpo.gov/2005/pdf/05-21571.pdf 48 Memorandum from DHS Secretary Michael A. Chertoff to All Department of Homeland Security 

Components, DHS Policy for Internal Information Exchange and Sharing, February 1, 2007. 49 Memorandum from John O. Brennan, Assistant to the President for Homeland Security and 

Counterterrorism, to cabinet level officials, Strengthening Information Sharing And Access, July 2, 2009. 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 76 
Appendix D 

Visa Waiver Program Countries 

Visa Waiver Program Countries 

As Of May 2010 

� Andorra 

� Australia 

� Austria 

� Belgium 

� Brunei 

� Czech Republic 

� Denmark 

� Estonia 

� Finland 

� France 

� Germany 

� Greece 

� Hungary 

� Iceland 

� Ireland 

� Italy 

� Japan 

� Latvia 

� Liechtenstein 

� Lithuania 

� Luxembourg 

� Malta 

� Monaco 

� The Netherlands 

� New Zealand 

� Norway 

� Portugal 

� San Marino 

� Singapore 

� Slovakia 

� Slovenia 

� South Korea 

� Spain 

� Sweden 

� Switzerland 

� United Kingdom 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 77
 
Appendix E 

DHS Data Systems 

Definitions and Diagram of DHS Systems 

Arrival and Departure Information System (ADIS) (Owner US-VISIT) 

The Arrival and Departure Information System (ADIS) is used to collect, match, and report in 

US-VISIT on international arrivals and departures of many categories of non-U.S. citizens. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 78
 
Appendix E 

DHS Data Systems 

Advance Passenger Information System (APIS) (Owner CBP) 

The Advance Passenger Information System (APIS) is a widely used electronic data interchange 

system that allows air carriers to transmit traveler data to CBP.50 Complete APIS data for each 

passenger are required no later than 30 minutes before the aircraft is secured for airlines that 

provide a list of passenger names and no later than when the aircraft is secured for electronic 

APIS Quick Query submissions.51 APIS information is maintained as a module within TECS. 

50 

http://www.cbp.gov/linkhandler/cgov/travel/inspections_carriers_facilities/apis/apis_factsheet.ctt/apis_facts 

heet.pdf

51 

http://www.cbp.gov/linkhandler/cgov/travel/inspections_carriers_facilities/apis/apis_faqs.ctt/apis_faqs.doc 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 79
 
Appendix E 

DHS Data Systems 

Automated Targeting System - Passenger (ATS-P) (Owner CBP) 

Automated Targeting System – Passenger (ATS-P) is a web-based enforcement and decision 

support tool used to collect, analyze, and disseminate information. ATS-P receives various data 

from CBP systems, which includes TECS, Passenger Name Records (PNR) from airlines, and 

lookout information from foreign governments. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 80
 
 

 

Appendix E 

DHS Data Systems 

Central Index System (CIS) (Owner USCIS) 

The Central Index System (CIS) contains information on the status of 57 million 

applicant and petitioners who seek immigration benefits, denied and approved refugee 

determinations, as well as the status of other individuals subject to the provisions of the 

Immigration and Nationality Act, to include:52 

� Naturalized citizens 

o Computer-Linked Application Information Management System 4 (CLAIMS4) 

� Individuals who apply for affirmative asylum status, and certain applications for benefits under the 

Nicaraguan Adjustment and Central American Relief Act 

o Refugees Asylum and Parole System (RAPS) 

� United States border crossers 

o Alien Registration Card / Border Crossing Card Interface 

� All USCIS immigration benefits other than naturalization and humanitarian immigration benefits 

o Computer-Linked Application Information Management System 3 (CLAIMS3) 

� Aliens who illegally entered the United States 

o ENFORCE Alien Removal Module (EARM) 

� Aliens who have been issued employment authorization documents 

o Image Storage and Retrieval System (ISRS) 

52 http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_uscis_cis.pdf 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 81 
Appendix E 

DHS Data Systems 

ENFORCE / Enforce Alien Removal Module (EARM) (Owner ICE) 

� Immigration Enforcement Operational Records System (ENFORCE) contains 

modules to manage ICE and CBP law enforcement functions: 

o ENFORCE Apprehension Booking Module tracks apprehension of individuals 

ICE and CBP arrested for violations of customs and immigration laws. 

o ENFORCE Alien Detention Module tracks the detention of subjects in ICE 

custody charged with violations of the Immigration and Nationality Act. 

o ENFORCE Alien Removal Module (EARM) is used to document the processing 

and removal of aliens, track the status of alien removal proceedings, and provide 

information on an alien’s entire detention history. 

� ENFORCE interfaces with TECS, IDENT, USCIS, Refugees, Asylum, and Parole 

System (RAPS), and other DHS systems. 

� ENFORCE also interfaces with the Department of Justice Executive Office of 

Immigration Review database used to place aliens in removal proceedings and 

track their case dispositions. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 82
 
Appendix E 

DHS Data Systems 

Electronic System for Travel Authorization (ESTA) (Owner CBP) 

Electronic System for Travel Authorization (ESTA) is a fully automated electronic travel 

authorization system that determines the eligibility of visitors to travel to the United 

States under the Visa Waiver Program and whether such travel poses a law enforcement 

or security risk. Upon receipt of an ESTA application, CBP examines the application and 

screen applicant data through law enforcement systems.53 

53 http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_cbp_esta.pdf 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 83
 
Appendix E 

DHS Data Systems 

ICE-PIC (Owner ICE) 

Immigration and Customs Enforcement (ICE) Pattern Analysis and Information 

Collection System (ICE-PIC) enables pattern and data analysis to find previously 

unknown relationship data.54 The database program compiles information on immigrants 

and other individuals. ICE-PIC receives information, but does not send information back 

to these systems. Federal, state, local, and tribal law enforcement may use the 

information aggregated in ICE-PIC for queries, data runs, and data analysis.55 

54 http://www.ice.gov/pi/news/factsheets/icepic.htm 55 http://www.dhs.gov/xlibrary/assets/privacy/privacy_data_%20mining_%20report.pdf/ 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 84 
Appendix E 

DHS Data Systems 

IDENT (Owner US-VISIT) 

Automated Biometric Identification System (IDENT) is a DHS-wide system to collect 

and process biometric and limited biographic information for DHS national security, law 

enforcement, immigration, intelligence, and other DHS mission-related functions.56 

IDENT has an automated interface with biometrics in the FBI’s biometric system. Other 

federal agencies can check biometrics against IDENT, but are not automated to send or 

receive updated status information. 

56 http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_usvisit_ident_final.pdf 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 85 
Appendix E 

DHS Data Systems 

Image Storage and Retrieval System (ISRS) (Owner USCIS) 

� Image Storage and Retrieval System (ISRS) is a web-based system that permits 

query and retrieval of biometric image sets and associated biographical data. 

Indexed data fields include the alien registration number, receipt number, 

applicants name and date of birth, and card serial number.57 Image Storage and 

Retrieval System (ISRS) draws its information from the following sources: 

o CLAIMS 3 is a system that tracks and processes the adjudication of 

applications and petitions for immigration benefits and services, except 

asylum and naturalization.58 

o CLAIMS 4 is the case processing system for the adjudication of 

applications for naturalization (N-400).59 

o Refugees, Asylum, and Parole System (RAPS) tracks affirmative asylum 

applications and certain applications for benefits under the Nicaraguan 

Adjustment and Central American Relief Act. 

o IDENT stores fingerprints and photographs of USCIS applicants. 

57 http://dhsconnect.dhs.gov/uscis/org/EXSO/ILink/docView/M450/HTML/M450/0-0-0-7854.html 

58 http://www.dhs.gov/xlibrary/assets/mgmt/e300-uscis-immigra32008.pdf 

59 http://www.dhs.gov/xlibrary/assets/mgmt/e300-uscis-natural42008.pdf 

Information Sharing On Foreign Nationals: Overseas Screening 

Page 86 
Appendix E 

DHS Data Systems 

SEVIS (Owner ICE) 

Student and Exchange Visitor Information System (SEVIS) tracks and monitors 

information on nonimmigrant students, exchange visitors and their dependents, and on 

their associated schools and sponsors. 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 87
 
Appendix E 

DHS Data Systems 

TECS (Owner CBP) 

The TECS database contain temporary and permanent enforcement, inspection, and 

intelligence records relevant to the antiterrorism and law enforcement mission of CBP 

and other federal agencies. TECS also allows direct access to other major law 

enforcement systems, to include the Department of Justice National Crime Information 

Center and the International Justice and Public Safety Information Sharing Network 

(NLETS). 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 88
 
Appendix F 

Major Contributors to this Report 

Douglas Ellice, Chief Inspector, Office of Inspections 

Lorraine Eide, Senior Inspector, Office of Inspections 

Ericka Kristine Odiña, Inspector, Office of Inspections 

Pharyn Smith, Inspector, Office of Inspections 

Michael Brooks, Inspector, Office of Inspections 

LaDana Crowell, Inspector, Office of Inspections 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 89
 
Appendix G 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Policy 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

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 

DHS Component Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Information Sharing On Foreign Nationals: Overseas Screening 


Page 90
 
ADDITIONAL INFORMATION AND COPIES 

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

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

OIG HOTLINE 

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

misconduct relative to department programs or operations: 

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

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

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

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