REGISTERED SEX 

OFFENDERS

Sharing More 

Information Will 

Enable Federal 

Agencies to Improve 

Notifications of Sex 

Offenders’ 

International Travel

Report to Congressional Requesters

February 2013

GAO-13-200

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-200, a report to 

congressional requesters 

February 2013 

REGISTERED SEX OFFENDERS

Sharing More Information Will Enable Federal 

Agencies to Improve Notifications of Sex Offenders’ 

International Travel

Why GAO Did This Study

In recent years, certain individuals who 

had been convicted of a sex offense in 

the United States have traveled 

overseas and committed offenses 

against children. GAO was asked to 

review what relevant federal 

agencies—including DOJ, DHS, and 

the Department of State—are doing 

with regard to registered sex offenders 

traveling or living abroad. This report 

addresses the following questions: (1) 

How and to what extent does the 

federal government determine whether 

registered sex offenders are leaving or 

returning to the United States? (2) How 

and to what extent have federal 

agencies notified foreign officials about 

registered sex offenders traveling 

internationally? GAO analyzed August 

and September 2012 data from the 

U.S. Marshals, USNCB, and ICE on 

registered sex offenders who traveled 

internationally. GAO also interviewed 

relevant agency officials and surveyed 

officials from all 50 states, 5 territories, 

and the District of Columbia to 

determine the extent to which they 

identify and use information on 

traveling sex offenders. 

What GAO Recommends

GAO recommends that ICE consider 

receiving the automated notifications 

and DOJ and DHS take steps to

ensure that USNCB and ICE (1) have 

information on the same number of 

traveling registered sex offenders and 

(2) have access to the same level of 

detail about each traveling registered 

sex offender. USNCB within DOJ and 

DHS concurred with our 

recommendations. 

What GAO Found

Three federal agencies—U.S. Marshals, International Criminal Police 

Organization (INTERPOL) Washington – U.S. National Central Bureau (USNCB), 

and U.S. Immigration and Customs Enforcement (ICE)—use information from 

state, local, territorial, and tribal jurisdictions, as well as passenger data from the 

U.S. Customs and Border Protection (CBP), to identify registered sex offenders 

traveling outside of the United States. Similarly, these agencies may be notified 

of registered sex offenders traveling to the United States through several means, 

including tips from foreign officials or when CBP queries the registered sex 

offender’s biographic information at a port of entry and finds that the offender has 

a criminal history. However, none of these sources provides complete or 

comprehensive information on registered sex offenders leaving or returning to 

the United States. For example, CBP does not routinely query individuals who 

leave the United States by commercial bus, private vessel, private vehicle, or by 

foot, in which case CBP may not be able to determine if any of these individuals 

are registered sex offenders. In addition, foreign officials do not always monitor 

when a registered sex offender is returning to the United States. The Federal 

Bureau of Investigation (FBI), working with other agencies, is developing a 

process that will address some of these limitations. Specifically, the FBI will send 

an automated notice to the U.S. Marshals and law enforcement officials in the 

jurisdictions where the sex offender is registered that the offender is traveling, to 

the extent that the offender’s biographical information is queried at the port of 

entry. However, because ICE has not requested to receive the automated 

notifications, ICE will not be notified of registered sex offenders who leave the 

country via a land port of entry whose biographical information is queried.

USNCB and ICE have notified foreign officials of some registered sex offenders

leaving and returning to the country, but could increase the number and content 

of these notifications. USNCB notifies its foreign INTERPOL counterparts about 

registered sex offenders traveling internationally, and ICE notifies its foreign law 

enforcement counterparts about traveling sex offenders who had committed an

offense against a child. USNCB provides more detailed information than ICE 

because USNCB uses offenders’ self-reported travel information that some 

jurisdictions collect, which may include details such as hotel information. Since 

ICE uses passenger data, it does not have these details. Also, data from August 

1 to September 30, 2012, showed that the two agencies had significant 

differences in the number of offenders they identified in notifications. USNCB 

sent notifications on 105 traveling sex offenders that ICE did not, and, 

conversely, ICE sent notifications on 100 traveling sex offenders that USNCB did 

not. In part this is because the two agencies rely on different information sources

and do not share information with one another. Taking steps to ensure that these 

agencies have all available information on the same registered sex offenders 

traveling internationally could help ensure that the agencies are providing more 

comprehensive information to their foreign counterparts to help inform public 

safety decisions.

View GAO-13-200. For more information, 

contact Eileen R. Larence at (202) 512-6510 

or larencee@gao.gov. 
Page i GAO-13-200 Registered Sex Offenders 

Letter 1 

Background 6

Federal Agencies Collect Information on Traveling Registered Sex 

Offenders, but the Information Could be More Comprehensive 10

ICE and USNCB Notify Foreign Officials about Some Registered 

Sex Offenders Traveling Abroad, but Improved Information 

Sharing Could Increase the Number and Content of These 

Notifications 23

Conclusions 29

Recommendations for Executive Action 30

Agency Comments and Our Evaluation 30

Appendix I Objectives, Scope, and Methodology 33

Appendix II Registered Sex Offenders Traveling Internationally Who Were 

Refused Entry by Foreign Countries 39

Appendix III Comments from the Department of Homeland Security 40

Appendix IV Comments from the Department of Justice 43

Appendix V Contact and Staff Acknowledgments 45

Tables

Table 1: Functions of the Federal Agencies that Play a Role in 

Identifying Traveling Registered Sex Offenders 9

Table 2: Mechanisms by Which Federal Agencies Become Aware of 

Registered Sex Offenders Returning to the United States 

and Their Limitations 15

Table 3: Extent to Which the Planned Automated Notification Is 

Intended to Address Limitations to Identifying Registered 

Sex Offenders Traveling Internationally 18

Contents 
Page ii GAO-13-200 Registered Sex Offenders 

Table 4: Type of Information Jurisdictions, NTC, and the 

Automated Notification Provide or Will Provide on 

Registered Sex Offenders Traveling Internationally 21

Figures

Figure 1: Primary Methods by Which the U.S. Marshals Service, 

U.S. Immigration and Customs Enforcement and U.S. 

National Central Bureau Receive Information on 

Registered Sex Offenders Traveling Internationally 13

Figure 2: Notifications Sent by U.S. Immigration and Customs 

Enforcement and U.S. National Central Bureau to Foreign 

Countries on Registered Sex Offenders Traveling 

Internationally, August 1, 2012 to September 31, 2012 26

Figure 3: Number of Registered Sex Offenders Referred by the 

National Targeting Center (NTC) to the U.S. Marshals and 

U.S. Immigration and Customs Enforcement (ICE), and 

Number Refused Entry by Foreign Destination Country, 

October 1, 2011, to September 27, 2012 39
Page iii GAO-13-200 Registered Sex Offenders 

Abbreviations

APB Advisory Policy Board

APIS Advance Passenger Information System

CA Bureau of Consular Affairs

CBP U.S. Customs and Border Protection

DHS Department of Homeland Security

DOD Department of Defense

DOJ Department of Justice

DS Bureau of Diplomatic Security

FBI Federal Bureau of Investigation

IAFIS Integrated Automated Fingerprint Identification

 System

ICE U.S. Immigration and Customs Enforcement

INTERPOL International Criminal Police Organization

IWG International Tracking of Sex Offenders Working Group

MPS Metropolitan Police Service

NCIC National Crime Information Center

NSOR National Sex Offender Registry

NSOTC National Sex Offender Targeting Center

NTC CBP National Targeting Center

PNR Passenger Name Record 

SMART Office Office of Sex Offender Sentencing, Monitoring,

 Apprehending, Registering, and Tracking

SOCA Serious Organised Crime Agency

SORNA Sex Offender Registration and Notification Act of 2006

U.K. United Kingdom

USNCB INTERPOL Washington - U.S. National Central Bureau

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Page 1 GAO-13-200 Registered Sex Offenders 

United States Government Accountability Office 

Washington, DC 20548

February 14, 2013

The Honorable F. James Sensenbrenner, Jr.

Chairman

The Honorable Robert C. Scott

Ranking Member

Subcommittee on Crime, Terrorism, Homeland Security, and 

Investigations

Committee on the Judiciary

House of Representatives

The Honorable Christopher H. Smith

Chairman, Subcommittee on Africa, Global Health, Global Human Rights, 

and International Organizations

Committee on Foreign Affairs

House of Representatives

In recent years, certain individuals who had previously been convicted of 

a sex offense in the United States subsequently traveled overseas and 

committed an offense against a child or attempted to transport a child 

from overseas to commit a sex crime. For example, in 2008, an individual 

with a prior U.S. sex offense conviction received a prison sentence for 

engaging in illicit sexual activity with a 15-year-old girl in Ciudad Juarez, 

Chihuahua, Mexico, in exchange for money and crack cocaine. Also, in 

2009, an individual who had previously been convicted of a sex offense 

against a minor in the United States was convicted of a child sex tourism 

crime, where the individual sexually abused a minor while traveling 

abroad.1

Given the risk that some individuals previously convicted of a sex offense 

may pose, in July 2006, Congress passed and the President signed the 

Sex Offender Registration and Notification Act of 2006 (SORNA), which 

provided a new set of sex offender registration and notification standards, 

including criminal penalties for those who fail to comply with these 

standards.2

 

1

For the purpose of this report, a child sex tourist is an individual who travels to another 

country for the purpose of engaging in illicit sexual activity with a child.

These standards require convicted sex offenders to register 

2

Pub. L. No. 109-248, tit. I, 120 Stat. 587, 590-611. 

 
 

Page 2 GAO-13-200 Registered Sex Offenders 

and keep the registration current in the state, territorial, or tribal 

jurisdictions in which they live, work, and attend school, and for initial 

registration purposes only, the jurisdiction in which they were convicted. 

Registration generally entails convicted sex offenders appearing in 

person to provide the jurisdiction with personal information, such as name 

and date of birth, among other information. Jurisdictions then use this 

information to track these offenders following their release into the 

community in an effort to ensure public safety. Further, SORNA directs 

the Attorney General, in consultation with the Secretary of State and the 

Secretary of Homeland Security, to establish a system for informing 

domestic jurisdictions about persons entering the United States who are 

required to register under SORNA.3 The act also made it a federal crime 

for a sex offender to travel in foreign commerce and knowingly fail to 

register or update a registration.4 Moreover, the Department of Justice 

(DOJ) promulgated guidelines governing implementation of SORNA that 

have resulted in some jurisdictions’ requiring sex offenders to inform local 

and state officials in the jurisdictions where they reside of their plans to 

travel internationally.5 You requested that we review what relevant federal 

agencies—including DOJ, the Department of Homeland Security (DHS), 

and the Department of State (State)—are doing with regard to sex 

offenders who were convicted and subsequently registered in the United 

States and who are traveling or living abroad.6

(1) How and to what extent does the federal government determine 

whether registered sex offenders are leaving or returning to the United 

States?

Specifically, this report 

addresses the following questions:

(2) How and to what extent have federal agencies notified foreign 

officials about registered sex offenders traveling internationally?

 

3

42 U.S.C. §16928. 

4

18 U.S.C. § 2250(a). 

5

Supplemental Guidelines for Sex Offender Registration and Notification, 76 Fed. Reg. 

1630 (Jan 11, 2011).

6

For the purpose of this report, we only included U.S. persons (i.e., U.S. citizens or lawful 

permanent residents) and foreign nationals who were registered as sex offenders in the 

United States at the time of their travel outside of or back to the United States. We did not 

include U.S. persons or foreign nationals who are not already registered as sex offenders 

in the United States, such as those who committed sex offenses abroad and may have to 

register under SORNA upon their return to the United States. 
 

Page 3 GAO-13-200 Registered Sex Offenders 

To address both objectives, we identified relevant legislation, regulations, 

and other guidance that directs federal agencies’ efforts to identify 

registered sex offenders leaving or returning to the United States. We 

also obtained documentation and testimonial evidence from members of 

the International Tracking of Sex Offenders Working Group (IWG), which 

is composed of representatives from various agencies within DOJ, DHS, 

State, and the Department of Defense (DOD) and was tasked with 

developing mechanisms for identifying registered sex offenders leaving 

and returning to the country.7

We also interviewed and surveyed relevant state, local, and territorial 

officials to determine what role, if any, they play in informing the federal 

government of registered sex offenders leaving the country, and how, if at 

all they become aware of registered sex offenders returning to the 

country, and how they use that information to help ensure public safety. 

We first conducted a screening survey of officials the SMART Office 

identified as being responsible for implementing SORNA in each of the 

jurisdictions—the 50 states, 5 U.S. territories, and the District of 

Columbia.

We also interviewed agency officials from 

three of the federal departments represented on the IWG. The agencies 

within DOJ include the Office of Sex Offender Sentencing, Monitoring, 

Apprehending, Registering, and Tracking (SMART Office); Federal 

Bureau of Investigation (FBI); United States Marshals Service (U.S. 

Marshals); and International Criminal Police Organization (INTERPOL)

Washington - United States National Central Bureau (USNCB). The 

agencies within DHS include U.S. Customs and Border Protection (CBP) 

and U.S. Immigration and Customs Enforcement (ICE). The agencies 

within State include the Bureau of Consular Affairs and Bureau of 

Diplomatic Security.

8

 

7

DOD was excluded from our review because, under SORNA, the departments 

responsible for dealing with registered sex offenders traveling abroad were identified as 

DOJ, DHS, and State. 

These officials included representatives of state police 

departments or attorney general offices. Subsequently, of those 

jurisdictions that responded that they require sex offenders to provide 

advance notice of international travel, we selected 4 jurisdictions—

8

The 5 U.S. territories included in our review are American Samoa, Commonwealth of the 

Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. We did not 

include federally recognized Indian tribes eligible under SORNA because we will analyze 

tribal jurisdictions’ efforts to implement SORNA and identify registered sex offenders 

leaving and returning to the United States in a separate review.
 

Page 4 GAO-13-200 Registered Sex Offenders 

Maryland, Florida, Michigan, and Arizona—to conduct site visits and 1 

jurisdiction (New Mexico) to conduct telephone interviews. 9 During the 

site visits, we obtained additional information on how jurisdictions 

implemented and enforced the requirement and shared information on 

traveling registered sex offenders with relevant federal agencies. We 

chose these jurisdictions to achieve variation in (1) the extent of 

international travel from the jurisdiction; (2) percentage of the population 

that is composed of sex offenders; and (3) whether the state has land and 

sea ports of entry, in addition to airports, to cover the various modes by 

which sex offenders could enter and leave the country.10

We also developed and administered a second survey of the same 

officials from the 56 jurisdictions to obtain more detailed information on 

the extent to which jurisdictions require registered sex offenders to 

provide advance notice of international travel and inform federal agencies 

of registered sex offenders leaving the country. The survey also included 

questions related to jurisdictions’ perspectives on any challenges or 

improvements needed regarding receiving or providing information about 

sex offenders leaving or returning to the United States, in addition to other 

During the site 

visits, we met with officials from the following federal, state, and local law 

enforcement agencies: U.S. Marshals, ICE, and CBP (at air, land, and 

sea ports of entry); state agencies responsible for maintaining the state 

sex offender registry; and local law enforcement agencies responsible for 

registering and monitoring sex offenders. While the perspectives from the 

officials we interviewed during site visits cannot be generalized to all 

jurisdictions, they provided valuable insights about registered sex 

offenders traveling internationally.

 

9

During our site visit to Arizona, the Arizona agency officials responsible for sex offender 

registration clarified that the State of Arizona does not require sex offenders to provide 

advance notice of their international travel unless the sex offenders are planning to 

permanently reside abroad. Consequently, to maintain consistency with our selection 

criteria, we selected the next state jurisdiction that matched our selection criteria for site 

visits—New Mexico. State officials in New Mexico did not respond to our request to meet 

with them; however, we were able to conduct telephone interviews with relevant CBP and 

U.S. Marshals officials in this state.

10Ports of entry—including air, sea, and land ports of entry—are government-designated 

locations where CBP inspects persons and goods to determine whether they may be 

lawfully admitted or entered into the country.
 

Page 5 GAO-13-200 Registered Sex Offenders 

issues related to the implementation of SORNA. We received responses 

from 52 out of 56 jurisdictions.11

Additionally, we obtained and analyzed data from the U.S. Marshals, ICE, 

and USNCB, which are the three agencies identified as having 

responsibility for taking action based on the information they obtain on 

registered sex offenders leaving or returning to the country to help ensure 

public safety. We obtained and analyzed data the three agencies 

received from August 1 through September 30, 2012 on registered sex 

offenders traveling internationally.

12

Moreover, we contacted federal and foreign officials in select countries—

Australia, Canada, Mexico, the Philippines, Thailand, and the United 

Kingdom—to obtain information on how they learn of registered sex 

offenders traveling from the United States to those countries; how, if at 

all, they use this information to help ensure public safety; and any 

limitations or benefits of receiving this information. We selected Mexico, 

the Philippines, and Thailand because, on the basis of data we obtained 

from ICE, these are among the countries most frequented by child sex 

We also analyzed the data to 

determine the extent to which there was any fragmentation (i.e., 

circumstances in which more than one federal agency is involved in the 

same broad area of national interest) or duplication (i.e., two or more 

agencies or programs are engaged in the same activities or provide the 

same services to the same beneficiaries) with regard to notices sent to 

foreign officials. We also assessed whether there were any benefits or 

drawbacks to any fragmentation or duplication. We assessed the 

reliability of the data the agencies provided by questioning knowledgeable 

agency officials and reviewing the data for obvious errors and anomalies. 

We determined that the data were sufficiently reliable for our purposes.

 

11We did not receive survey responses from the following jurisdictions: American Samoa, 

New Hampshire, Oregon, and Washington. For further details on the web survey, see 

GAO, Sex Offender Registration and Notification Act: Jurisdictions Face Challenges to 

Implementing the Act, and Stakeholders Report Positive and Negative Effects, 

GAO-13-211 (Washington, D.C.: Feb. 7, 2013), and for the e-supplement containing the 

questions and results of the web survey see GAO, Sex Offender Registration: Survey of 

States and Territories on Implementation of the Sex Offender Registration and Notification 

Act (GAO-13-234SP, February 2013), an E-supplement to GAO-13-211 (Washington, 

D.C.: Feb. 7, 2013).

12We chose this time period because we wanted to assess the effectiveness of a process 

the U.S. Marshals instituted in August 2012 for sharing information with USNCB on 

registered sex offenders traveling outside of the United States. 
 

Page 6 GAO-13-200 Registered Sex Offenders 

tourists. We selected Australia, Canada, and the United Kingdom 

because they are known to have national sex offender registries, similar 

to those of the United States, and have expressed an interest in receiving 

information from the U.S. government on sex offenders traveling there. 

Appendix I provides additional detail on our objectives, scope, and 

methodology.

We conducted this performance audit from January 2012 to February 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our analysis based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our analysis based on our audit 

objectives.

The purpose of SORNA is to protect the public from sex offenders and 

offenders against children by providing a comprehensive set of sex 

offender registration and notification standards. These standards require 

convicted sex offenders, prior to their release from imprisonment or within 

3 days of their sentencing if the sentence does not involve imprisonment, 

to register and keep the registration current in the jurisdictions in which 

they live, work, and attend school, and for initial registration purposes 

only, the jurisdiction in which they were convicted. Registration generally 

entails the offender appearing in person at a local law enforcement 

agency and the agency collecting information such as name, address, 

Social Security number, and physical description of the offender, among 

other items. The registration agency also is to document, among other 

items, the text of the provision of law defining the criminal offense for 

which the offender is registered; the criminal history of the offender, 

including dates of all arrests and convictions; and any other information 

the Attorney General requires. In addition, implementing jurisdictions are 

to maintain a jurisdiction-wide sex offender registry and adopt registration 

requirements that are at least as strict as those SORNA established. The 

length of time that convicted sex offenders must continue to update their 

registration is life, 25 years, or 15 years, depending on the seriousness of 

the crimes for which they were convicted and with possible reductions for 

maintaining a clean record. The frequency with which sex offenders must 

update or verify their information—either quarterly, semiannually, or 

annually—also depends on the seriousness of the crime. Once sex 

Background

Sex Offender Registration 

Requirement
 

Page 7 GAO-13-200 Registered Sex Offenders 

offenders register or update their registration in their jurisdictions, under 

the act, implementing jurisdictions are to provide the new information to 

FBI’s National Sex Offender Registry (NSOR). NSOR is a national 

database within the FBI’s National Crime Information Center (NCIC) that 

federal, state, local, territorial, and tribal law enforcement officials can 

access to obtain information on registered sex offenders throughout the 

United States. Jurisdictions’ receipt of certain federal grant funds is 

conditioned upon whether they have “substantially implemented” SORNA, 

and, as we have previously reported, jurisdictions are in various stages of 

implementing the act.13

Pursuant to the Attorney General’s authority to interpret and implement 

SORNA, the SMART Office developed SORNA guidelines specifically 

related to registered sex offenders traveling internationally.14 For 

example, under DOJ’s National Guidelines, each jurisdiction in which a 

sex offender is registered as a resident is instructed to require the sex 

offender to inform the jurisdiction if the sex offender intends to commence 

residence, employment, or school attendance outside of the United 

States.15 The jurisdiction needs to then (1) notify all other jurisdictions in 

which the offender is required to register through immediate electronic 

forwarding of the sex offender’s registration information, and (2) notify the 

U.S. Marshals—the primary federal agency responsible for investigating 

sex offender registration violations under SORNA—and update the sex 

offender’s registration information in the national databases pursuant to 

the procedures under SORNA § 121(b)(1). Also, under DOJ’s 

Supplemental Guidelines, jurisdictions are directed to have sex offenders 

report international travel 21 days in advance of such travel and submit 

information concerning such travel to the appropriate federal agencies 

and databases.16

 

13For a description of requirements jurisdictions must meet in order to “substantially 

implement” SORNA, and the extent to which jurisdictions have meet these requirements, 

see 

Furthermore, per the SMART Office’s SORNA 

Implementation Document, in order to provide the most helpful 

information to U.S. Marshals and other law enforcement agencies, DOJ’s 

GAO-13-211. 

1442 U.S.C. §§ 16912(b), 16914(a)(7).

15The National Guidelines for Sex Offender Registration and Notification, 73 Fed. Reg. 

38,030 (July 2, 2008). 

16See 76 Fed. Reg. at 1637. 

Federal Requirements for 

Registered Sex Offenders 

Traveling Internationally
 

Page 8 GAO-13-200 Registered Sex Offenders 

guidelines require jurisdictions to collect passport information in addition 

to other travel information, such as itinerary details, purpose of travel, 

criminal records, and contact information within the destination country, 

regarding a registered sex offender’s intended international travel.17

Currently, according to officials from the SMART Office, DOJ will not 

reduce grant funds for jurisdictions that have not yet implemented the 

supplemental guidelines on registered sex offenders traveling 

internationally, because DOJ is allowing jurisdictions additional time to 

implement the supplemental guidelines as part of its assessment of 

whether jurisdictions have “substantially implemented” SORNA.

Under SORNA, the responsibility for establishing a system for informing 

jurisdictions about persons entering the United States who are required to 

register is divided among three federal departments— DHS, DOJ, and 

State—with DOJ being the lead agency. Additionally, in 2008, the SMART

Office created the IWG, which consists of multiple agencies within DOJ, 

DHS, and State, to discuss issues related to identifying registered sex 

offenders traveling internationally.18

 

17DOJ, SORNA Implementation Document (Washington D.C.: Mar. 27, 2012). This 

document is the SMART Office’s most recent guidance related to registered sex offenders 

traveling internationally. It directs jurisdictions to collect passport information from sex 

offenders prior to their international travel, among other things.

Although not required to do so under 

SORNA, ICE’s Homeland Security Investigations (HSI) division, 

consistent with its objective to target transnational sexual exploitation of 

children, developed the Angel Watch program. The purpose of this 

program is to provide advance notice to foreign officials when a registered 

sex offender who committed a crime against a child is traveling from the 

United States to a foreign country. Table 1 describes the functions of the 

federal agencies that play a role in identifying registered sex offenders 

traveling internationally.

18Although SORNA requires DOJ, in consultation with DHS and State, to establish a 

system to inform domestic jurisdictions about persons entering the United States who are 

required to register under SORNA, the IWG adopted the expanded language provided in 

DOJ’s National Guidelines for Sex Offender Registration and Notification on sex offenders 

traveling internationally. The guidelines aimed to establish a mechanism to inform 

jurisdictions about sex offenders leaving the country in order to effectively carry out the 

SORNA requirement, since such offenders will be required to resume registration if they 

later return to the United States.

Federal Agencies That Play 

a Role in Identifying 

Registered Sex Offenders 

Traveling Internationally
 

Page 9 GAO-13-200 Registered Sex Offenders 

Table 1: Functions of the Federal Agencies that Play a Role in Identifying Traveling Registered Sex Offenders

Federal department Federal agency General function 

DOJ SMART Office, Office of 

Justice Programs 

Provides guidance and technical assistance to jurisdictions and public and private 

organizations in activities related to sex offender registration. Maintains the Dru 

Sjodin National Sex Offender Public Website, which is a national online registry 

portal that the public can use to access information on registered sex offenders.

U.S. Marshals Investigates sex offender registration violations and provides operational support 

to help state, local, tribal, and territorial law enforcement identify, locate, and 

prosecute non-compliant sex offenders. Provides assistance to jurisdictions in the 

identification and location of sex offenders relocated as a result of a major 

disaster.

U.S. Marshals 

National Sex 

Offender Targeting 

Center (NSOTC)

Functions as an interagency intelligence and operations center to assist with 

identifying, investigating, locating, apprehending, and prosecuting non-compliant, 

unregistered fugitive sex offenders. Assists states, tribes, and territories in 

enforcing the registration requirements. 

USNCB As the designated representative to the International Criminal Police Organization 

(INTERPOL) on behalf of the Attorney General, USNCB facilitates the exchange 

of information to assist law enforcement agencies in the United States and 

throughout the world in detecting and deterring international crime (including sex 

crimes) and terrorism through a network of 190 member countries.

DHS CBP Inspects travelers entering the United States at air, land, and sea ports of entry. 

When travelers (U.S. persons and foreign nationals) enter the country through 

ports of entry, CBP officers conduct a screening procedure referred to as a 

primary inspection where officers take steps to ensure that the traveler is in 

compliance with all U.S. legal requirements. CBP officers process travelers 

deemed admissible at the primary inspection. Other travelers not readily deemed 

admissible or requiring additional scrutiny are referred to a secondary inspection 

for a more in-depth interview by a CBP officer. This inspection involves a closer 

inspection of travel documents and possessions (which could include determining 

whether the traveler possesses child pornography), additional questioning, and 

background checks through law enforcement database systems such as NCIC or 

TECS, among other things.a At the end of the secondary inspection, CBP may 

release, refuse entry to, or detain the person while CBP further reviews 

compliance or admissibility.

NTC Receives travelers’ data such as name, date of birth, and travel information from 

air carrier or cruise ship companies to (1) provide tactical targeting information 

aimed at interdicting terrorists, criminals, and prohibited items; and (2) match 

travelers and goods against known patterns of illicit activity.

ICE Investigates sexual exploitation of children, among other responsibilities, and 

operates the Angel Watch program, which identifies convicted child predators 

who attempt to travel internationally to countries known as destinations for child 

sex tourism.

State Bureau of Consular 

Affairs (CA)

Issues passports to U.S. citizens, adjudicates visas for foreign nationals, and 

interprets visa laws and regulations, among others. Determines whether visa 

should be issued to foreign nationals who have committed crimes of moral 

turpitude, which could include certain sex offenses. 

Bureau of Diplomatic 

Security (DS)

Works with foreign police and security organizations to coordinate U.S. law 

enforcement initiatives and investigations, among others.

Source: GAO analysis based on information provided by federal agencies.
 

Page 10 GAO-13-200 Registered Sex Offenders 

a

TECS is CBP’s key database system for border enforcement and sharing of travelers’ information 

and provides a real-time interface with NCIC. 

Three federal agencies—U.S. Marshals, USNCB, and ICE—use 

information from state, local, territorial, and tribal jurisdictions, as well as 

passenger data from CBP, to determine whether registered sex offenders 

are traveling outside of the United States. Similarly, five federal 

agencies—USNCB, ICE, U.S. Marshals, Consular Affairs, and CBP—may 

be notified of registered sex offenders traveling to the United States 

through several means, including tips from foreign officials or when CBP 

queries the registered sex offender’s biographic information at a port of 

entry and finds that the offender has a criminal history. However, none of 

these sources provides complete or comprehensive information on 

registered sex offenders leaving or returning to the United States. For 

example, because CBP’s passenger data are based on information from 

private or commercial air, commercial vessels, and voluntary reporting 

from rail and commercial bus lines; and CBP does not routinely query 

individuals who leave the United States by commercial bus, private 

vessel, private vehicle, or by foot, it is unable to provide information on all 

individuals leaving the country. In addition, foreign officials do not always 

monitor when a registered sex offender is returning to the United States. 

The FBI is establishing an automated notification process that is expected 

to address some of these limitations. However, because ICE has not 

requested to receive the automated notifications, ICE will not be notified 

of registered sex offenders who leave the country via a land port of entry.

Officials from the U.S. Marshals and USNCB said that they use 

information from state, local, territorial, and tribal jurisdictions, and 

officials from the U.S. Marshals and ICE said that they use air and sea 

passenger data from CBP, to determine whether registered sex offenders 

are traveling internationally, but both mechanisms have limitations.19

 

19To a lesser extent, the U.S. Marshals reported using information gathered from ongoing 

investigations to determine whether a registered sex offender is leaving the United States. 

Depending on the case, the U.S. Marshals may receive this information from state, local, 

or territorial law enforcement, or other federal agencies. 

Federal Agencies 

Collect Information 

on Traveling 

Registered Sex 

Offenders, but the 

Information Could be 

More Comprehensive

Limitations in the 

Information Federal 

Agencies Receive on 

Registered Sex Offenders 

Leaving the Country from 

State and Local 

Jurisdictions and CBP 

Passenger Data
 

Page 11 GAO-13-200 Registered Sex Offenders 

The information that the U.S. Marshals and USNCB receive from 

jurisdictions about registered sex offenders traveling internationally is 

limited, in part because (1) some jurisdictions do not require sex 

offenders to inform them of international travel and (2) those jurisdictions 

that do require notice must rely on sex offenders to self-report this 

information. Consistent with the Attorney General’s authority under 

SORNA to require sex offenders to provide additional information for 

inclusion in the jurisdiction’s registry than what the act requires, DOJ’s 

Supplemental Guidelines added that registered sex offenders must 

provide jurisdictions 21 days advance notice of any international travel, 

and jurisdictions are to notify the U.S. Marshals of any registered sex 

offenders traveling internationally. According to the U.S. Marshals, to 

support these jurisdictions’ efforts to provide more complete and 

consistent information, in February and March 2012, the SMART Office 

asked jurisdiction registry officials, and the U.S. Marshals and USNCB 

asked relevant jurisdictional law enforcement agencies, to submit a 

Notification of International Travel form to the U.S. Marshals. This form 

includes the traveler’s name, passport number, travel information, 

criminal record, and contact information in the destination country.

However, not all jurisdictions have elected to implement the DOJ 

guideline requiring registered sex offenders to provide advance notice of 

international travel. Specifically, of the 50 jurisdictions that responded to 

our survey question about advance notice of international travel 

requirements, 28 reported that they require sex offenders to provide such 

advance notice, whereas the other 22 do not, primarily because their 

jurisdiction’s laws do not permit them to do so.20

 

20According to senior officials from the SMART Office, generally, jurisdictions have had to 

amend their existing sex offender registration and notification laws to include the 21-day 

advance notice of international travel. However, some jurisdictions are able to make an 

administrative decision that will permit them to collect this information. 

For example, 1 

jurisdiction said that because its statute requires registered sex offenders 

to notify the registry within 72 hours after international travel, officials are 

not authorized to collect this information in advance. Moreover, some 

jurisdictions have difficulty obtaining information on traveling registered 

sex offenders on a consistent basis because jurisdictions must rely on 

sex offenders to self-report, and jurisdictions have limited mechanisms in 

place to enforce the self-reporting requirement. For example, sex offender 

registry officials in 1 jurisdiction we visited said that they would not know 

that a registered sex offender failed to self-report international travel 

Information from Jurisdictions
 

Page 12 GAO-13-200 Registered Sex Offenders 

unless they conducted an address verification operation, which would 

enable them to determine that the sex offender is traveling. Senior 

officials from the SMART Office stated that they are pleased that 28 

jurisdictions have already implemented the advance notice provision, 

considering that the guidance for the provision was not released until 

January 2011. These officials also stated that they continue to provide 

technical assistance to jurisdictions seeking to implement this provision.

Information on registered sex offenders traveling internationally that the 

U.S. Marshals and ICE obtain from CBP’s review of passenger data also 

has limitations. CBP, as part of DHS, has the mission to secure the 

United States’ borders while facilitating legitimate trade and travel. To 

help fulfill that mission, CBP established NTC, which, among other things, 

receives and reviews air and sea passenger data to determine whether 

persons entering or leaving the country via a commercial airline or 

cruiseline are on the terrorist watchlist, are wanted, or have a warrant out 

for their arrest.21

 

21NTC uses passenger data collected from the Passenger Name Record (PNR) and the 

Advance Passenger Information System (APIS). PNR data are collected when an 

individual books a flight, for example, from a travel agency or airline. Pursuant to 

regulations, APIS data are collected and sent by airlines as individuals check in for the 

flight and no later than the moment the aircraft’s doors are closed and secured for the 

flight (or no later than 30 minutes prior to that moment, if transmitted in batches), and by 

cruise lines 60 minutes prior to the ship’s departure from the United States and, for 

incoming vessels, at least 24 hours (at least 96 hours for voyages of 96 hours or more) 

prior to arrival at the U.S. port of entry.

NTC officials stated that in 2009, they met with the U.S. 

Marshals to determine how they could support efforts under way at the 

newly formed NSOTC. NTC agreed to review passenger data to 

determine whether any persons leaving the country are registered sex 

offenders. Since then, according to NTC officials, they have provided the 

U.S. Marshals information, such as name, date of birth, destination, and 

offense, on all registered sex offenders NTC identifies from passenger 

data so that the U.S. Marshals can verify that the sex offender did not 

violate any registration requirements. NTC officials stated that they also 

use this information to identify registered sex offenders who remain in a 

foreign country for an extended period of time and return to the United 

States for short periods of time, because this may be an indication that 

the individual is circumventing SORNA requirements by falsely reporting 

their place of residency. NTC provides this information to ICE and U.S. 

Marshals for possible investigation or other law enforcement action. 

Figure 1 shows the primary methods by which the U.S. Marshals, ICE, 

Information from CBP’s Review 

of Passenger Data 
 

Page 13 GAO-13-200 Registered Sex Offenders 

and USNCB receive information on registered sex offenders traveling 

internationally.

Figure 1: Primary Methods by Which the U.S. Marshals Service, U.S. Immigration 

and Customs Enforcement and U.S. National Central Bureau Receive Information 

on Registered Sex Offenders Traveling Internationally

While the information NTC provides may be helpful, it has limitations. 

First, CBP collects and analyzes information on individuals leaving the 

United States via private or commercial airline, commercial vessel, and 

voluntary reporting from rail, but does not routinely query individuals who 

leave the United States by commercial bus line, private vessel, private 

vehicle, or by foot . Since travelers departing by commercial rail, 

commercial bus line, private vessel, private vehicle or by foot are not 

required to report travel information in advance of their travel, CBP may 

be unable to provide advance targeting and analysis of these individuals. 

However, a CBP officer may access information on these individuals by

querying their biographical information during special outbound 

operations at port of entry. It is CBP’s policy that CBP officers query 

individuals leaving the country only if there is a special operation 

underway, such as an operation to verify the amount of currency taken 

out of the United States.22

 

22Under 31 U.S.C. § 5316, an individual who transports, attempts to transport, or causes 

to be transported (including by mail or other means) currency or other monetary 

instruments (e.g. , traveler checks) in an aggregate amount exceeding $10,000 or its 

foreign equivalent at one time from the United States to any foreign country, or into the 

United States from any foreign country, must file a report with CBP.

According to NTC officials, CBP officers at the 

land port of entry are not required to provide NTC with the results of their 

queries because they are only required to pass information related to 
 

Page 14 GAO-13-200 Registered Sex Offenders 

individuals on the terrorist watchlist. Therefore, NTC is generally not able 

to inform the U.S. Marshals and ICE about registered sex offenders 

leaving the country through means such as land ports or on a privately 

chartered boat. 

Second, to determine whether a registered sex offender is on a particular 

flight, NTC determines whether any of the passenger data, such as name 

and date of birth, match any of the data in the FBI’s NCIC. However, 

NCIC may not always have complete information to enable NTC to 

determine if there is a match, in part because jurisdictions may enter 

information incorrectly or not at all because certain fields are not 

mandatory. In this case, NTC checks electronic public sex offender 

registries—which are not always up to date—to collect missing 

information, or calls relevant registry officials—which could take additional 

time.

Five federal agencies—USNCB, ICE, the U.S. Marshals, Consular Affairs, 

and CBP— have several mechanisms in place to identify registered sex 

offenders returning to the United States. For example, USNCB officials 

stated that their foreign counterparts, to the extent that they are aware, 

may notify U.S. officials of registered sex offenders returning to the United 

States. In addition, U.S. Marshals officials stated that they sometimes 

receive information from NTC on registered sex offenders returning to the 

United States. According to NTC officials, they are able to provide this 

information to the U.S. Marshals analyst stationed at NTC to the extent 

that the sex offender’s entire itinerary and flight information are 

available.23

 

23In September 2010, a U.S. Marshals analyst was assigned to work at NTC on a part 

time basis in order to identify potential SORNA violations, such as instances in which a 

registered sex offender is in violation of his or her registration requirements through 

international travel without proper notification. The U.S. Marshals analyst began working 

at NTC on a full time basis starting in June 2012.

However, these mechanisms do not identify all of the

registered sex offenders returning to the United States all of the time. For 

example, even though USNCB may receive information on some 

returning registered sex offenders through its foreign counterparts, the 

information these officials provide is based on anonymous tips or 

offenders’ self-reported information. According to USNCB officials, even 

though hundreds of registered sex offenders traveled outside of the 

United States from August through September 2012, as we discuss later 

Limitations in Information 

on Registered Sex 

Offenders Returning to the 

Country Provided by 

Foreign Officials and from 

Reviews of Criminal 

History Records
 

Page 15 GAO-13-200 Registered Sex Offenders 

in this report, USNCB rarely received notifications of these registered sex 

offenders returning to the United States.24

Table 2: Mechanisms by Which Federal Agencies Become Aware of Registered Sex Offenders Returning to the United States 

and Their Limitations

Table 2 describes the 

mechanisms by which federal agencies become aware of registered sex 

offenders traveling back to the United States and the limitations of those 

mechanisms.

Federal agency

Mechanisms in place to identify U.S.-registered sex 

offenders Limitations to the mechanisms in place

U.S. Customs and Border 

Protection (CBP)

National Targeting Center (NTC) obtains the sex 

offender’s full flight itinerary, including the return trip, if 

available, prior to when the sex offender leaves the 

United States. 

Receives an alert that the traveler has a National Crime 

Information Center (NCIC) record when CBP officers 

query traveler’s biographic information at air or sea 

ports of entry. 

Not all sex offenders may have booked 

their return trip in advance.

U.S. Immigration and Customs 

Enforcement (ICE)

Receives sex offender’s full flight itinerary, including the 

return trip, if available, from NTC prior to when the sex 

offender leaves the country.

Not all sex offenders may have booked 

their return trip in advance.

U.S. Marshals Receives sex offender’s full flight itinerary, including the 

return trip, if available, from NTC prior to when the sex 

offender leaves the country.

Limited to those registered sex offenders 

for whom NTC had returning trip 

information. 

U.S. National Central Bureau 

(USNCB)

Notified by foreign INTERPOL counterparts. Limited to anonymous tips or self-reported 

information INTERPOL counterparts 

receive. 

U.S. Consular Affairs May identify individuals with an outstanding warrant 

when reviewing a U.S. citizen’s application for a 

passport renewal or replacement submitted while the 

person is in another country.

Notified when consular officers abroad verify criminal 

records in NCIC of a foreign national who applied for a 

U.S. visa. 

Limited to registered sex offenders who 

need to renew or replace their passports 

and have outstanding warrants.

If Consular Affairs grants the visa, the 

agency is not aware of when the registered 

sex offender is actually traveling to the 

United States. 

Source: GAO analysis based on information on traveling registered sex offenders that federal agencies provided.

 

24According to USNCB officials, USNCB is only able to track registered sex offenders 

returning to the United States when another INTERPOL counterpart reports that 

information to USNCB. Otherwise, USNCB does not systematically track when registered 

sex offenders return to the United States. 
 

Page 16 GAO-13-200 Registered Sex Offenders 

To help ensure that relevant federal agencies are more consistently 

notified of registered sex offenders leaving or returning to the United 

States, in 2008, the SMART Office established the IWG.25 The IWG is 

charged with developing an international tracking system to identify 

registered sex offenders leaving and returning to the country and 

immediately relay this information to appropriate domestic law 

enforcement agencies for any additional action as needed, such as to 

initiate an investigation. Specifically, FBI officials stated that, in 

collaboration with other IWG member agencies, they are developing a 

process that will send an automated notification to the U.S. Marshals’ 

NSOTC and registry and law enforcement officials in the jurisdictions

where the sex offender is registered: (1) when a registered sex offender 

has purchased an airline or cruise ticket for international travel, (2) 1 

week before the registered sex offender is scheduled to travel by 

commercial air or sea transport, and (3) when a CBP officer queries that 

person’s biographic information at a U.S. port of entry, such as any U.S. 

airport.26

The automated notification, if implemented as intended, will provide the 

U.S. Marshals and relevant jurisdictions with information on registered 

sex offenders returning to the United States whose biographic information 

is queried by CBP officers at air, sea, and land ports of entry, assuming 

these offenders enter the country legally and their identifying information 

in NCIC, such as date of birth, is accurate and complete. In addition, FBI 

officials stated that the automated notification is expected to provide 

relevant jurisdictions with information on sex offenders registered in their 

jurisdiction who did not self-report international travel. This will help law 

enforcement officers to avoid using resources to search for sex offenders 

who they thought had absconded, when the offender had actually left the 

country on personal travel.

 

25For more details on the federal agencies represented on the IWG, see appendix I.

26The automated notification will be sent whenever a registered sex offender engages in 

travel with a U.S. nexus; that is, entering, transiting through, or exiting a U.S. port of entry 

by commercial air or sea transport. The system will send notices for registered sex 

offenders exiting a U.S. port of entry by land or private boat only to the extent that CBP 

queries these travelers’ biographic information. FBI officials responsible for implementing 

the automated notification stated that a notification will also be triggered if a change is 

made to the Offender Status Field in NCIC to indicate the offender is traveling or has 

moved outside of the United States.

An Automated Notification 

Process Currently Under 

Development Is Intended 

to Address Some 

Challenges with 

Identifying Registered Sex 

Offenders Leaving and 

Returning to the United 

States
 

Page 17 GAO-13-200 Registered Sex Offenders 

According to FBI officials, the FBI vetted the automated notification 

proposal through its Advisory Policy Board; the FBI Director approved the 

proposal in June 2012; and FBI officials estimate that they will be able to 

implement the automated notification as early as March 2013.27

While the automated notification will address some of the limitations 

discussed previously, it will not address all of them. For example, 

according to FBI officials, the automated notification will provide notice to 

the U.S. Marshals and jurisdictions of all registered sex offenders leaving 

or returning to the United States for whom CBP officers query their 

biographic information at a port of entry. Consequently, the automated 

notification will not provide notice of a registered sex offender who plans 

to leave the country via a land port of entry because CBP generally does 

not query information for these travelers. CBP officials explained that 

CBP officers may query biographic information for individuals leaving the 

United States through a land port of entry—such as in the case of a 

special operation to verify the amount of currency taken out of the 

country—but generally do not do so because of regulatory, policy, and 

infrastructure limitations in monitoring individuals leaving the United 

States.

FBI 

officials responsible for implementing the automated notification said that 

they are currently working with CBP to include additional information from 

CBP’s systems in the automated notifications, such as the specific ports 

of entry and the mode of transportation offenders are using. The FBI will 

not delay implementation of the automated notification to incorporate the 

additional information from CBP; instead, the FBI will incorporate this 

information into the automated notifications at a later date, if necessary.

28

 

27The Advisory Policy Board (APB) is comprised of representatives from federal agencies 

that participate in the FBI’s Criminal Justice Information Services Division programs and 

tribal and local law enforcement and criminal justice agencies, and it establishes 

guidelines for systems maintained by FBI’s Criminal Justice Information System. APB 

working groups provide input on systems proposals and recommendations to the FBI 

Director for implementation. 

 Table 3 discusses the extent to which the planned automated 

notification is intended to address the federal government’s current 

limitations in identifying registered sex offenders traveling internationally.

28According to FBI officials responsible for implementing the automated notification, they 

have had preliminary discussions with Canadian Police Information Center officials as to 

whether every person that enters Canada through the U.S.-Canada land border will be 

queried in NCIC.
 

Page 18 GAO-13-200 Registered Sex Offenders 

Table 3: Extent to Which the Planned Automated Notification Is Intended to Address Limitations to Identifying Registered Sex 

Offenders Traveling Internationally

Limitations to identifying registered sex offenders 

traveling internationally

Automated notification 

intended to address 

limitation?

Efforts to address limitations not addressed 

by the automated notification 

Registered sex offenders leaving the United States

Some jurisdictions do not collect information on 

registered sex offenders’ international travel, and, 

therefore, are not able to notify relevant federal 

agencies.

Yes

Jurisdictions that do collect information on registered 

sex offenders’ international travel may not receive 

complete information because they rely on sex 

offenders to self report or on community members to 

provide tips about the sex offenders’ travel.

Yes

The U.S. Customs and Border Protection (CBP) does 

not have a mechanism to routinely query travelers 

leaving the United States by land ports or private boat in 

order to determine whether they are registered sex 

offenders.

No The Department of Justice’s Sex Offender 

Sentencing, Monitoring, Apprehending, 

Registering, and Tracking Office (SMART Office) 

provides technical assistance to jurisdictions 

seeking to implement the requirement that 

registered sex offenders provide 21-day advance 

notice of international travel, including travel by 

land ports or private boats.

NTC relies on National Crime Information Center 

(NCIC) data to determine if any traveler leaving the 

country via a commercial or private airplane or a 

commercial ship is a registered sex offender; however, 

some NCIC data may be incorrect or incomplete, thus 

making it difficult for NTC to determine if there is a 

match.

No The automated notification will also rely on NCIC 

data, and, therefore, may have similar 

limitations. The International Tracking of Sex 

Offenders Working Group (IWG) continues to 

encourage registry officials to enter in a timely 

and complete manner all of the mandatory and 

optional information that NCIC will accept.

Registered sex offenders returning to the United 

States 

The. U.S. National Central Bureau (USNCB) relies on 

self-reported information offenders provide to foreign 

law enforcement about returning to the United States.

Yes

CBP generally does not notify relevant federal or 

jurisdiction officials of registered sex offenders returning 

to the United States unless the offender is wanted or 

has a warrant.

Yes

Source: GAO analysis based on information on traveling registered sex offenders that federal agencies provided.

The fact that the automated notification will not address all limitations will 

likely remain for the foreseeable future because they are inherent to wellestablished processes for entering and exiting the country. For example, 

according to senior CBP officials responsible for field operations, 

conducting inspections that would enable them to collect information on 
 

Page 19 GAO-13-200 Registered Sex Offenders 

all travelers exiting the country via a land port of entry would require 

policy, regulatory, procedural, and major infrastructure changes.29

The automated notification, when operational, is also intended to help 

ensure jurisdictions are more consistently notified of registered sex 

offenders returning to the United States, which may enable them to take 

public safety measures they deem appropriate. Of the 56 sex offender 

registry officials who responded to our survey questions about the extent 

to which federal agencies provided notice of registered sex offenders 

returning to the United States, 17 reported that they received notice of 

registered sex offenders returning to the United States from at least one 

federal agency.30 Federal officials we interviewed identified several 

reasons why they do not consistently provide this information to sex 

offender registry officials in the jurisdictions. For example, CBP officers at 

3 of the 10 ports of entry stated that it would not be feasible to notify 

jurisdiction officials of all the registered sex offenders they identified 

because of the number of travelers returning through their ports of entry.31

 

29 We have previously reported in GAO, Overstay Enforcement: Additional Mechanisms 

for Collecting, Assessing, and Sharing Data Could Strengthen DHS’s Efforts but Would 

Have Costs,

Also, according to USNCB officials, they generally do not notify 

jurisdiction officials of returning registered sex offenders unless the 

foreign country provides USNCB with this information. Further, U.S. 

Marshals officials stated that they share information on returning 

registered sex offenders with state and local law enforcement agencies if 

the planned return date of a sex offender leaving the country is known.

GAO-11-411 (Washington, D.C.: April 15, 2011) that DHS is required to 

collect information for certain foreign nationals leaving the country but concluded that it 

could not do so at land ports of entry without incurring a major impact on land facilities. 

30Of the 17 jurisdictions that reported receiving information on registered sex offenders 

entering the United States from a federal agency, 10 reported receiving information from 

the U.S. Marshals and USNCB, respectively; 8 reported receiving it from ICE; and 2 

reported receiving it from CBP and State, respectively. Some of the responses reflect 

jurisdictions receiving information from more than one federal agency.

31Of the 3 ports of entry, CBP officers from 1 port of entry also stated that it would be 

feasible to notify jurisdictions of those registered sex offenders identified at secondary 

inspection. Of the remaining 7 ports of entry, 3 stated that it would feasible to notify 

jurisdictions of registered sex offenders returning to the United States, if these offenders 

are identified at the secondary inspection, and 4 ports of entry did not discuss the 

feasibility of notifying jurisdictions. 
 

Page 20 GAO-13-200 Registered Sex Offenders 

Jurisdictions could possibly use information on registered sex offenders 

traveling to their jurisdictions from abroad to help them identify the current 

location of these offenders. For example, officials from one local law 

enforcement agency we visited stated that receiving such notifications 

would help officers verify whether the offenders have returned from 

foreign travel when officers conduct address verifications. In addition, this 

information would help jurisdictions fulfill their requirements under 

SORNA to protect the public from sex offenders. Once the automated 

notification system is operational, jurisdictions that have registered the 

sex offender and entered a record into NCIC will be notified that an 

offender has returned to the United States. Having this information will 

allow these jurisdictions to implement public safety measures more 

consistently.

To help ensure that they obtain as complete information as possible 

regarding registered sex offenders traveling internationally, the U.S. 

Marshals and ICE will continue to request information from jurisdictions or 

NTC even after the automated notification is operational. Currently, the 

U.S. Marshals and ICE do not consistently receive information on 

registered sex offenders entering or leaving the country via a land port of 

entry because NTC does not have this information and jurisdictions 

receive this information only to the extent that sex offenders self-report it. 

The automated notification will fill this information gap, in part, by sending 

notices about registered sex offenders entering and leaving the country 

via a land port of entry, to the extent that CBP queries the biographical 

information of the offender, in addition to providing notices about 

registered sex offenders traveling internationally via commercial air and 

sea transport. Although the automated notification will provide information 

on a greater number of traveling registered sex offenders than the 

number that jurisdictions and NTC provide, as shown in table 4, NTC 

provides more details on a specific traveler than the automated 

notification. Further, jurisdictions that collect offenders’ self reported data 

may also be able to provide more details. Therefore, according to U.S. 

Marshals officials, they find it beneficial to continue to receive information 

from each of these two sources.

ICE Has Not Made Plans to 

Receive Information from 

the Automated

Notification, a Fact That 

May Preclude It from 

Obtaining Information on 

Some Traveling Sex 

Offenders
 

Page 21 GAO-13-200 Registered Sex Offenders 

Table 4: Type of Information Jurisdictions, NTC, and the Automated Notification 

Provide or Will Provide on Registered Sex Offenders Traveling Internationally

Type of information provided Jurisdictionsb NTC

Automated 

notificationc

Name ● ● ●

Date of birth ● ● ●

Passport number ● ● ○d

FBI numbera ● ● ○d

Photograph ● ●

Criminal history ● ●

Whether Victim is a Minor ● ● ○d

Port of entry through which the offender will 

leave or enter the country

● ● ●

Full flight itinerary (for round-trip flights, if 

available)

● ●

Whether the flight is inbound or outbound ● ●

Names of travel companions ● ●

Where the offender will stay while in country 

(e.g., hotel information)

●

Source: GAO analysis based on information provided by federal agencies.

a

The FBI number is a unique identification number assigned to each individual who has a record in 

the FBI’s Integrated Automated Fingerprint Identification System (IAFIS), a nationwide database of 

fingerprint and criminal history records of individuals who have been arrested. 

b

A jurisdiction may not always provide all types of information. 

c

Additional information from NCIC will be provided to the extent it is available. 

d

This information may be provided to the extent it is available in NCIC. 

According to an ICE section chief responsible for the Angel Watch 

program, ICE has not requested to receive the automated notifications 

because it prefers to rely on information NTC provides, which meets 

ICE’s specific needs. In particular, an NTC analyst, after identifying a 

registered sex offender with plans to travel internationally via commercial 

air or sea transport, conducts further analysis to determine whether the 

offender committed a crime against a child. This ICE chief stated that ICE 

does not want information on all types of registered sex offenders, which 

is what the automated notification would provide, but only on those who 

have committed crimes against children, in accordance with ICE’s 

mission to investigate the sexual exploitation of children. However, by not 

requesting to receive the automated notification, ICE will not have 
 

Page 22 GAO-13-200 Registered Sex Offenders 

information on registered sex offenders who committed offenses against 

children, left the country via a land port of entry, and had their 

biographical information queried at the port.32 According to the FBI, in 

order to receive the automated notification, ICE would have to submit a 

request to FBI’s Advisory Policy Board; and given that the board meets 

twice a year, it could take approximately 1 year or more for the board to 

approve an agency’s request to receive alerts from the system. The FBI 

also explained that the automated notification will not be able to 

distinguish between traveling registered sex offenders who committed 

offenses against children and those who committed offenses against 

adults because the notifications are derived from NCIC data, and the age 

of the victim is not a required field in this system.33 Therefore, if ICE were 

to receive the automated notification, ICE would have to determine on its 

own whether the offenders leaving the country through a land port of 

entry committed an offense against a child. However, according to NTC 

officials, about 90 percent of the registered sex offenders they identified in 

fiscal year 2012 who planned to travel internationally via commercial air 

or sea transport had committed offenses against children. We have 

previously reported that collaborating agencies can look for opportunities 

to address resource needs by leveraging each others’ resources, which 

could include receiving the automated notification, and obtaining 

additional benefits that would not be available if they were working 

separately.34

 

32The number of sex offenders who left the country via a land port of entry whose 

biographical information was queried at the port is unknown because CBP does not 

routinely track this information. 

By electing not to receive the automated notifications, ICE 

will not receive information on registered sex offenders traveling to 

Canada or Mexico via a land port of entry whose biographical information 

is queried. This is of particular concern considering that, according to ICE, 

Mexico is one of the countries to which registered sex offenders travel 

most frequently. If ICE were to receive alerts from the automated 

notification, we recognize that some effort would be required to determine 

whether sex offenders leaving the country through a land port of entry 

committed an offense against a child. However, the level of effort 

33According to the FBI officials, the requirement for mandatory or optional fields in NCIC is 

dictated by legislation and the user community through the Criminal Justice Information 

Services Advisory Process; and thus, it may not be feasible to change the fields in NCIC. 

34GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 
 

Page 23 GAO-13-200 Registered Sex Offenders 

required, and whether or not the benefits of the effort would outweigh the 

cost, cannot be determined at this time.

USNCB and ICE inform foreign officials when registered sex offenders 

are traveling to their countries to enable these officials to take actions that 

they deem appropriate to ensure public safety. USNCB and ICE notify 

their own unique counterparts in foreign countries about traveling sex 

offenders for similar purposes, such as enabling them to make decisions 

as to whether they will admit sex offenders into their country. In addition 

USNCB and ICE notify these counterparts for different purposes. For 

example, ICE counterparts may monitor the whereabouts of sex offenders 

while they are in the foreign country. USNCB and ICE base such 

notifications on different information sources; USNCB uses information it 

receives from the U.S. Marshals and jurisdictions, and ICE uses 

information it receives from NTC’s passenger data reviews as part of 

ICE’s Angel Watch program.35 However, the U.S. Marshals do not 

consistently share information with USNCB on traveling sex offenders, 

and USNCB and ICE do not share the information they receive on 

traveling sex offenders with each other. As a result, USNCB and ICE 

were not able to notify their foreign counterparts about a large number of 

registered sex offenders traveling internationally from August to 

September 2012, and some of the notifications were not as 

comprehensive as possible.

USNCB notifies its INTERPOL counterparts in other countries about 

registered sex offenders traveling internationally. Similarly, ICE, through 

its Angel Watch program, notifies its foreign law enforcement 

counterparts about sex offenders traveling internationally who had 

committed an offense against a child. According to USNCB and ICE 

officials, USNCB and ICE send these notices to different agencies within

the foreign countries, but for similar purposes—to enable foreign officials 

to decide whether they want to admit the registered sex offender into their 

country or take other public safety measures they deem appropriate. For 

example, with regard to the United Kingdom, USNCB notifies its 

 

35U.S. Marshals officials explained that a U.S. Marshals analyst detailed to NTC manually 

fills out the Notification of International Travel form for each traveling registered sex 

offender identified by NTC’s passenger data reviews, and sends these forms to the U.S. 

Marshals investigator detailed to USNCB. 

ICE and USNCB 

Notify Foreign 

Officials about Some 

Registered Sex 

Offenders Traveling 

Abroad, but Improved 

Information Sharing 

Could Increase the 

Number and Content 

of These Notifications

USNCB and ICE Notify 

Their Respective Foreign 

Counterparts of Registered 

Sex Offenders Traveling 

Internationally for Similar 

as well as Unique Purposes
 

Page 24 GAO-13-200 Registered Sex Offenders 

INTERPOL counterpart—the United Kingdom National Central Bureau—

which is hosted by the Serious Organised Crime Agency (SOCA), a law 

enforcement body that fights organized crime. SOCA officials then make 

decisions about how to use this information. They could share it with 

agencies such as the United Kingdom (U.K.) Border Agency, which is 

responsible for refusing entry to persons who do not qualify, or the U.K. 

Metropolitan Police Service (MPS), which interviews registered sex

offenders to establish exactly what their plans are while in the United 

Kingdom and where they will be staying upon entry or if admitted. On the 

other hand, according to ICE officials, ICE notifies the sex offender unit 

within the U.K. Metropolitan Police Service as well as the U.K. Border 

Agency directly through its attachés posted abroad about registered sex 

offenders traveling to the United Kingdom who committed an offense 

against a child. Of the six countries included in our review, three generally 

do not admit registered sex offenders, and in one country, even though it 

generally admits registered sex offenders, foreign law enforcement 

officials monitor the activity of the sex offender while in country. For 

example, ICE Angel Watch program officials reported that in 2012, an ICE 

attaché notified foreign officials in advance that a registered sex offender 

was traveling from the United States to their country; and as a result, the 

foreign officials denied entry to the registered sex offender. Appendix II 

provides information on registered sex offenders traveling internationally 

who were refused entry by foreign countries.

USNCB and ICE identified reasons why it is advantageous that they both 

notify foreign officials of sex offenders traveling internationally. USNCB 

officials explained that they have been trying to encourage their 

INTERPOL counterparts to inform them about individuals convicted of sex 

offenses in their countries who are traveling to the United States. 

Therefore, it is important for USNCB to provide such notifications if it 

expects its counterparts to reciprocate. ICE officials explained that it is 

important for their ICE attachés to inform their foreign law enforcement 

counterparts about traveling registered sex offenders to assist the 

counterparts with tracking offenders visiting that country, such as by 

developing a shared spreadsheet designed to help the country establish 

its own sex offender registry, and to monitor sex offenders’ activities while 

in that country.
 

Page 25 GAO-13-200 Registered Sex Offenders 

USNCB provides more comprehensive information on sex offenders’ 

travel plans to its INTERPOL counterparts than ICE provides to its foreign 

law enforcement counterparts, and the additional information that USNCB 

has could help support ICE’s mission. USNCB bases its notifications on 

information that it receives from jurisdictions that require registered sex 

offenders to provide advance notice of international travel, whereas ICE 

bases its notifications on information it receives from NTC’s analysis of 

commercial air and sea passenger data. As previously discussed, 

jurisdictions that require advance notice may collect more information on 

each sex offender’s travel plans—such as hotel information—than NTC 

does.

In addition, neither USNCB nor ICE has provided its foreign counterpart 

with as many notices of traveling registered sex offenders as it potentially 

could. Specifically, as shown in figure 2, from August 1 through 

September 30, 2012, USNCB notified its counterparts of 105 offenders 

that ICE did not provide to its counterparts. Further, 82 of these 105 

notifications (78 percent) were for registered sex offenders who had 

committed offenses against children. Similarly, ICE notified its 

counterparts of 100 offenders that USNCB did not provide to its 

counterparts.

Federal Agencies Do Not

Share All Available 

Information They Have on 

Traveling Registered Sex 

Offenders with One 

Another, thus Limiting the 

Number and Content of 

Notifications Sent to 

Foreign Officials
 

Page 26 GAO-13-200 Registered Sex Offenders 

Figure 2: Notifications Sent by U.S. Immigration and Customs Enforcement and 

U.S. National Central Bureau to Foreign Countries on Registered Sex Offenders 

Traveling Internationally, August 1, 2012 to September 31, 2012

There are several reasons why USNCB and ICE generally do not have 

information to share on the same sex offenders traveling internationally. 

First, USNCB generally does not receive information on traveling sex 

offenders from NTC, whereas ICE does. This is in part because the U.S. 

Marshals has not passed on all of the information it has obtained from 

NTC on registered sex offenders to USNCB. We have previously reported 

that collaborating agencies should consider if participants have full 

knowledge of the relevant resources in their agency.36

 

36GAO, Managing for Results: Key Consideration for Implementing Interagency 

Collaborative Mechanisms,

Consistent with 

this guidance, in March 2012, the U.S. Marshals assigned one of its 

investigators to be co-located with USNCB officials in order to provide 

USNCB with information on sex offenders for whom USNCB would send 

GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). 
 

Page 27 GAO-13-200 Registered Sex Offenders 

green notices to its foreign INTERPOL counterparts.37 U.S. Marshals 

officials then realized that they had additional information on traveling 

registered sex offenders that could be of interest to USNCB, and starting 

in August 2012, the U.S. Marshals investigator was to begin providing 

USNCB information on traveling registered sex offenders that the U.S. 

Marshals receives from NTC.38 However, we found that from August 

through September 2012, the U.S. Marshals only provided USNCB with 

information on 39 of the 169 traveling sex offenders of whom the U.S. 

Marshals was aware based on information from NTC.

39

According to U.S. Marshals officials, the U.S. Marshals analyst posted at 

NTC may not be informing USNCB about all registered sex offenders 

traveling internationally that NTC has identified because the analyst’s 

primary purpose is to identify and pursue potential SORNA violations—

instances in which a registered sex offender is in violation of registration 

requirements by traveling internationally without providing advance 

notice. As a result, by the time the analyst finishes looking into potential 

SORNA violations, some of the registered sex offenders that NTC 

identified may have already completed their international travel; the U.S. 

Marshals investigator posted at USNCB would not notify USNCB about 

these offenders because the opportunity would have passed for USNCB 

to provide advance notice to its foreign counterparts about these 

offenders. 

Officials further explained that it takes time to complete the Notification of 

International Travel form for each traveling sex offender that NTC 

identifies, which may also prevent the investigator from notifying USNCB 

prior to the sex offender initiating travel. U.S. Marshals officials also 

 

37A green notice is one of INTERPOL’s system color-coded notices that provide warnings 

about subjects who may travel internationally and present a possible threat to public 

safety or to commit a criminal offense based on previous criminal convictions or history. 

38In particular, the U.S. Marshals analyst posted at NTC is to complete the Notification of 

International Travel form for registered sex offenders identified by NTC as traveling 

internationally and send the form to the U.S. Marshals investigator posted at USNCB.

39During this same time period, the U.S. Marshals provided USNCB with information that it 

had received from jurisdictions on an additional 56 traveling sex offenders, and 

information that it had received from other sources on an additional 4 traveling sex 

offenders. However, we were not able to assess the extent to which U.S. Marshals 

provided USNCB with the information it obtained from jurisdictions and other sources 

because we were not able to obtain the necessary data prior to when this report was to be 

issued. 
 

Page 28 GAO-13-200 Registered Sex Offenders 

stated that they would generally not provide USNCB with information on 

registered sex offenders whose international travel is less than 3 days. 

However, USNCB officials stated that they send notifications to their 

counterparts on all traveling registered sex offenders, regardless of travel 

duration or ability to provide advance notice.

U.S. Marshals officials explained that they did not receive any additional 

resources to help bridge the gap between the information that NTC and 

USNCB obtain on registered sex offenders traveling internationally, but 

volunteered to help remedy this issue with limited existing resources.

While the U.S. Marshals’ intentions are commendable, USNCB still does 

not have access to information on most of the registered sex offenders 

traveling internationally that NTC identifies, thus precluding USNCB from 

notifying its foreign counterparts about these individuals and enabling 

them to make informed public safety decisions.

A second reason why USNCB and ICE do not have information on the 

same traveling sex offenders could be that USNCB receives information 

on registered sex offenders traveling internationally from jurisdictions, 

whereas ICE does not. Third, according to a senior ICE official, ICE may 

have received information on additional traveling sex offenders, but did 

not send notifications via Angel Watch because of constrained manpower 

or insufficient information on the child exploitation conviction, among 

other things. 

According to USNCB officials, they copy several other federal agencies 

on their notifications to foreign officials, including FBI’s Innocent Images 

National Initiative and the State Department’s Bureau of Diplomatic 

Security (DS) which may choose to take further action.40

 

40FBI’s Innocent Images National Initiative was developed in 1995 because of the 

increase in the number of investigations that involved sex offenders using computers to 

share pornographic images of minors. The initiative teams FBI agents and local police in 

task forces to conduct undercover investigations of suspected offenders.

For example, DS 

officials stated that they share information on registered sex offenders 

traveling internationally with their regional security officers, who may 

inform other U.S. government and foreign law enforcement officials incountry, as they deem appropriate. However, USNCB officials reported 

that they do not coordinate their notifications with ICE, in part because 

their understanding was that ICE was interested in registered sex 

offenders traveling internationally only if the offender was the subject of 
 

Page 29 GAO-13-200 Registered Sex Offenders 

an ICE investigation; USNCB officials stated that they were not aware 

that ICE’s primary interest in obtaining information on these offenders 

was to notify their foreign law enforcement counterparts.

We have previously reported that collaborating agencies can look for 

opportunities to address resource needs by leveraging each others’ 

resources and obtaining additional benefits that would not be available if 

they were working separately.41

Taking steps to ensure that USNCB and ICE have information on the 

same registered sex offenders traveling internationally—which could 

entail, for example, the two agencies copying one another on notifications 

to their foreign counterparts, or USNCB receiving information directly from 

NTC—could help ensure that USNCB and ICE are providing more 

comprehensive information on traveling registered sex offenders to their 

foreign counterparts to help inform public safety decisions.

According to senior ICE officials 

responsible for the Angel Watch program, the additional information 

USNCB collects and provides to its counterparts could also help support 

ICE’s efforts. In particular, these officials stated that the relevant ICE 

attaché could share the additional information with that person’s foreign 

counterpart to support efforts to deny entry or monitor activity of 

registered sex offenders. USNCB officials stated that it would be feasible 

to include Angel Watch program officials on the notifications USNCB 

sends to foreign counterparts.

Cases in which individuals who had previously been convicted of a sex 

offense in the United States subsequently traveled overseas to commit an 

offense against a child underscore the importance of sex offender 

registration and notification standards to help ensure public safety in the 

United States and abroad. Some of the limitations federal agencies have 

faced with regard to identifying registered sex offenders leaving and 

returning to the United States are expected to be addressed by the 

automated notification the FBI is currently developing. However, ICE has 

not requested to receive the automated notification, which may preclude it 

from identifying entire categories of sex offenders, such as those entering 

and returning to the United States via a land port of entry whose 

biographical information is queried. USNCB, U.S. Marshals, and ICE 

 

41GAO-06-15. 

Conclusions
 

Page 30 GAO-13-200 Registered Sex Offenders 

have taken steps to coordinate their efforts to identify registered sex 

offenders traveling internationally, such as participating in the IWG and 

collocating staff. However, despite these efforts, these agencies still do 

not have access to all of the information on traveling registered sex 

offenders that they could potentially receive. Sharing additional 

information could help ensure that these agencies are providing more 

comprehensive information on traveling registered sex offenders to their 

foreign counterparts to help inform public safety decisions.

Given ICE’s objective to target the transnational sexual exploitation of 

children, after the automated notification becomes operational, the 

Director of ICE should direct ICE Homeland Security Investigations 

officials to coordinate with FBI Criminal Justice Information Services

officials to collect and analyze information that will enable ICE to 

determine if the benefits of receiving the automated notifications 

outweigh the costs. The type of information ICE may consider collecting 

as part of this analysis could include the number of notifications

generated for sex offenders leaving the country via a land port of entry.

To ensure that USNCB and ICE are providing more comprehensive 

information to their respective foreign counterparts regarding registered 

sex offenders traveling internationally, we recommend that the Attorney 

General and the Secretary of Homeland Security take steps to help 

ensure that USNCB and ICE have information on the same number of 

registered sex offenders as well as the same level of detail on registered 

sex offenders traveling internationally. Such steps could include USNCB 

and ICE copying each other on their notifications to their foreign 

counterparts or USNCB receiving information directly from NTC.

We provided a draft of this report for review and comment to DHS, DOJ, 

and State. We received written comments from DHS and USNCB, within

DOJ, which are reproduced in full in appendices III and IV, respectively. 

DHS generally agreed with our recommendations in its comments, and 

USNCB agreed with our recommendations with additional observations. 

State did not provide written comments on the draft report. We also 

received technical comments from DHS and DOJ, which were 

incorporated throughout our report as appropriate. 

In its written comments, USNCB agreed with our recommendation that 

the Attorney General and the Secretary of Homeland Security take steps 

to help ensure that USNCB and ICE have the same information on 

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
 

Page 31 GAO-13-200 Registered Sex Offenders 

registered sex offenders traveling internationally. USNCB noted that it has 

already begun the process of establishing points of contact with the 

appropriate ICE personnel so that USNCB can include ICE in its 

dissemination of sex offender notifications. USNCB also identified 

additional actions which were beyond the scope of our review, such as 

the need for technical improvements to streamline data sharing and 

foreign notification processes. In addition, USNCB stated that there needs 

to be an impetus for all states to substantially implement the guidelines 

set forth by the SMART Office on traveling registered sex offenders. 

During the course of our review, officials from the SMART Office stated 

that they have taken some actions, such as conducting workshops and 

providing technical assistance, to encourage jurisdictions to implement 

the requirement for registered sex offenders to report international travel 

21 days in advance of such travel. 

DHS agreed with our recommendations that ICE should assess whether 

receiving the automated notifications would benefit their mission to target 

transnational sexual exploitation and that DOJ and DHS should take 

steps to ensure that USNCB and ICE have the same information on 

traveling registered sex offenders. However, in its letter, DHS questioned 

whether the automated notifications would be of use to the Angel Watch 

program because the timing of some of the notifications would not enable 

ICE to notify foreign officials in advance that a sex offender is traveling to 

their country, in which case the foreign officials could choose not to admit 

the offender. Nevertheless, in addition to admissibility decisions, foreign 

law enforcement officials with whom we spoke stated that they use the 

information they receive from ICE for multiple purposes, including 

determining how frequently the sex offender travels to that country, where 

the offender stays while in country, and where to direct their resources to 

monitor sex offenders. 

DHS also raised concerns that given the hundreds of thousands of 

individuals leaving the United States via the southwest border on a daily 

basis, handling notifications on sex offenders leaving the country through 

this border may be untenable. However, it is uncertain how many of these 

individuals are sex offenders and how many of them will be queried by 

CBP when exiting the country. Therefore, it will be important for ICE to 

implement our recommendation so that once the automated notification 

process is underway, ICE can obtain the necessary information to 

determine if the number of notifications of sex offenders exiting the 

country through a land port of entry is manageable. 
 

Page 32 GAO-13-200 Registered Sex Offenders 

We are sending copies of this report to the appropriate congressional 

committees, the Attorney General, the Secretary of Homeland Security, 

the Secretary of State, and other interested parties. This report is also 

available at no charge on GAO’s web site at http://www.gao.gov. 

If you or your staff have any questions, please contact me at (202) 512-

6510 or larencee@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Staff acknowledgments are provided in appendix V.

Eileen R. Larence

Director, Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-200 Registered Sex Offenders 

Since 2006, Congress has passed legislation and the Department of 

Justice (DOJ) has promulgated regulations to help ensure that federal, 

state, local, territorial, and tribal officials are aware of when registered sex 

offenders travel internationally. To determine the extent to which these 

officials have procedures in place to implement these requirements, we 

addressed the following questions:

(1) How and to what extent does the federal government determine 

whether registered sex offenders are leaving or returning to the United 

States?

(2) How and to what extent have federal agencies notified foreign 

officials about registered sex offenders traveling internationally?

To address both objectives, we identified legislation, regulations, and 

other guidance that directs federal agencies’ efforts to identify registered 

sex offenders leaving or returning to the United States. Section 128 of the 

Sex Offender Registration and Notification Act of 2006 (SORNA), directs 

the Attorney General, in consultation with the Secretary of State and the 

Secretary of Homeland Security, to establish a system for informing 

domestic jurisdictions about persons entering the United States who are 

required to register under SORNA (referred to as registered sex 

offenders).1

In order to assess how federal agencies obtain information on registered 

sex offenders leaving and returning to the United States, we obtained 

documentation from and interviewed members of the International 

Tracking of Sex Offenders Working Group (IWG), which is composed of 

Further, SORNA makes it a federal crime for a sex offender 

required to register under SORNA to travel to foreign countries and 

knowingly fail to register or update a registration in the United States. 

Additionally, under DOJ guidance, jurisdictions are required to have 

registered sex offenders report international travel 21 days in advance 

and to submit information concerning such travel—such as expected 

itinerary, departure and return dates, and means and purpose of travel—

to the appropriate federal agencies.

 

1

For this report, jurisdictions refer to U.S. states, the District of Columbia, and the 5 U.S. 

territories. For the purpose of this report, we only included U.S. persons (i.e., U.S. citizens 

or lawful permanent residents) and foreign nationals who were registered as sex offenders 

in the United States at the time of their travel outside of or back to the United States. We 

did not include U.S. persons or foreign nationals who are not already registered as sex 

offenders in the United States, such as those who committed sex offenses abroad and 

may have to register under SORNA upon their return to the United States.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-200 Registered Sex Offenders 

representatives from various components within DOJ, the Department of 

Homeland Security (DHS), the Department of State (State), and the 

Department of Defense (DOD). The IWG was tasked with developing 

mechanisms to comply with statutory and regulatory requirements for 

identifying registered sex offenders leaving and returning to the United 

States. We reviewed the IWG’s proposals for such mechanisms, which 

were documented in a white paper prepared by the IWG in December 

2010. 2

• Department of Justice

We then interviewed officials from three of the federal 

departments represented on the IWG to obtain information on the 

mechanisms by which they identify registered sex offenders leaving and 

returning to the country, any limitations of these mechanisms, and what 

steps could be taken to address these limitations. Those agencies are the 

following:

• Office of Sex Offender Sentencing, Monitoring, Apprehending, 

Registering, and Tracking (SMART Office)

• Federal Bureau of Investigation (FBI)

• United States Marshals Service (U.S. Marshals)

• International Criminal Police Organization (INTERPOL) 

Washington – U.S. National Central Bureau (USNCB)

• Department of Homeland Security

• U.S. Customs and Border Protection (CBP)

• U.S. Immigration and Customs Enforcement (ICE)

• Department of State

• Bureau of Consular Affairs (CA)

• Bureau of Diplomatic Security (DS)

We excluded DOD from our review because under SORNA, the 

departments responsible for dealing with registered sex offenders 

traveling abroad were identified as DOJ, DHS, and State.

We also interviewed and surveyed relevant state, local, and territorial 

officials to determine what role, if any, they play in informing the federal 

 

2

IWG, International Tracking of Sex Offenders Working Group White Paper: An Interim 

Report of the Collaborative Effort to Develop a System for Tracking Registered Sex 

Offenders as They Depart and Enter the United States, as Required by 42 U.S.C. §16928

(Washington, D.C.: December 2010).
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-200 Registered Sex Offenders 

government of registered sex offenders leaving the country, and how, if at 

all they become aware of registered sex offenders returning to the 

country, and how they use that information to help ensure public safety. 

We first conducted a screening survey of officials from all 56 

jurisdictions—the 50 states, the District of Columbia, and the 5 territories, 

excluding tribal territories, that are eligible to implement SORNA.3 We 

contacted jurisdiction officials identified by the SMART Office as being 

responsible for implementing SORNA in the jurisdictions to determine 

whether they require registered sex offenders to provide advance notice 

of international travel and whether they share information with relevant 

federal agencies on registered sex offenders leaving or returning to the 

country. These officials included representatives of state police 

departments or attorney general offices. We pretested the survey with 2 

jurisdictions, distributed the survey by e-mail, and received responses 

from all 56 jurisdictions. Subsequently, of those jurisdictions that 

responded that they require sex offenders to provide advance notice of 

international travel, we selected 4 jurisdictions—Maryland, Florida, 

Michigan, and Arizona—to conduct site visits and 1 jurisdiction (New 

Mexico) to conduct interviews.4 During the site visits we obtained 

additional information on how they implemented and enforced the 

requirement and shared information with relevant federal agencies. We 

chose these jurisdictions based on (1) variation in the extent of 

international travel from the jurisdiction; (2) percentage of the population 

that is composed of sex offenders; and (3) whether the state has land and 

sea ports of entry, in addition to airports, to cover the various modes by 

which sex offenders could enter and leave the country.5

 

3

For this report, the 5 territories include: American Samoa, Commonwealth of the 

Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. We did not 

include federally-recognized Indian tribes eligible under SORNA because we will analyze 

tribal jurisdictions’ efforts to implement SORNA and identify registered sex offenders 

leaving and returning to the United States in a separate review.

During the site 

4

During our site visit to Arizona, the Arizona agency officials responsible for sex offender 

registration clarified that the State of Arizona does not require sex offenders to provide 

advance notice of their international travel unless the sex offenders are planning to 

permanently reside abroad. Consequently, to maintain consistency with our selection 

criteria, we selected the next state jurisdiction that matched our selection criteria for site 

visits—New Mexico. State officials in New Mexico did not respond to our request to meet 

with them; however, we were able to conduct telephone interviews with relevant CBP and 

U.S. Marshals officials in this state.

5

Ports of entry—such as air, sea, or land ports of entry—are government-designated 

locations where CBP inspects persons and goods to determine whether they may be 

lawfully admitted or entered into the country.
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-13-200 Registered Sex Offenders 

visits, we met with officials from the following federal, state, and local law 

enforcement agencies: U.S. Marshals, ICE, and CBP (at air, land, and 

sea ports of entry), state agencies responsible for maintaining the state 

sex offender registry, and local law enforcement agencies responsible for 

registering and monitoring sex offenders. During the site visits, we 

determined what actions were taken by state jurisdictions after the federal 

government informed them of sex offenders returning to their jurisdiction, 

particularly if the jurisdiction was not aware that the individual had left the 

country. Furthermore, we gathered information from jurisdictions on any 

actions that can be taken to improve their efforts to identify registered sex 

offenders leaving or returning to the United States. While the perspectives 

from the officials we interviewed during site visits cannot be generalized 

to all jurisdictions, they provided valuable insights about registered sex 

offenders traveling internationally.

We also developed and administered a second survey of the same 

officials from the 56 jurisdictions to obtain more detailed information on 

the extent to which jurisdictions implement the 21-day advance notice 

requirement and inform federal agencies of registered sex offenders 

leaving the country. The survey also included questions related to 

jurisdictions’ perspectives on any challenges or improvements needed 

regarding receiving or providing information about sex offenders leaving 

or returning to the United States, in addition to other issues related to the 

implementation of SORNA. To develop this survey, we designed draft 

questionnaires in close collaboration with a GAO social science survey 

specialist and conducted pretests with 4 jurisdictions to help further refine 

our questions, develop new questions, clarify any ambiguous portions of 

the survey, and identify any potentially biased questions. Log-in 

information for the web-based survey was e-mailed to all participants, and 

we sent two follow-up e-mail messages to all nonrespondents and 

contacted the remaining nonrespondents by telephone. We received 

responses from 52 out of 56 jurisdictions.6

Additionally, during our interviews with the IWG agencies, we asked 

whether any of these agencies use the information they obtain on 

registered sex offenders leaving and returning to the country to help 

 

6

We did not receive survey responses from the following jurisdictions: American Samoa, 

New Hampshire, Oregon, and Washington. For further details on the web survey, 

GAO-13-211 and for the e-supplement containing the questions and results of the web 

survey see GAO-13-234SP.
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-200 Registered Sex Offenders 

ensure public safety. For the three agencies identified as having 

responsibility for taking action based this information—U.S. Marshals, 

ICE, and USNCB, we obtained and analyzed data on the number of 

registered sex offenders they received from August 1 through September 

30, 2012 of registered sex offenders traveling internationally. We chose 

this time period because we wanted to assess the effectiveness of a 

process the U.S. Marshals instituted in August 2012 for sharing 

information with USNCB on registered sex offenders traveling outside of 

the United States. We then asked USNCB and ICE to provide us with the 

notifications they sent to foreign officials about the registered sex 

offenders who traveled outside of the United States for the same time 

period. We also analyzed the data to determine the extent to which there 

was any fragmentation (i.e. circumstances in which more than one federal 

agency is involved in the same broad area of national interest) or 

duplication (i.e. two or more agencies or programs are engaged in the 

same activities or provide the same services to the same beneficiaries) 

with regard to the notices. Specifically, we analyzed and compared the 

data provided by U.S. Marshals, ICE and USNCB to determine the extent 

to which the information these agencies had on sex offenders who 

planned to travel outside of the country was similar or different. We also 

assessed the similarities and differences in the notifications sent by 

USNCB and ICE to their foreign counterparts. We assessed the reliability 

of the data the agencies provided by questioning knowledgeable agency 

officials and reviewing the data for obvious errors and anomalies. We 

determined that the data were sufficiently reliable for our purposes.

Furthermore, we contacted federal and foreign officials in select countries 

to obtain information on how they learn of registered sex offenders 

traveling from the United States to the countries in which they are located; 

how, if at all, they use this information to help ensure public safety; and 

any limitations or benefits of receiving this information. The countries we 

selected are Australia, Canada, Mexico, the Philippines, Thailand, and 

the United Kingdom. We selected Mexico, the Philippines, and Thailand 

because, on the basis of data we obtained from ICE, these are among the 

countries most frequented by child sex tourists—that is, individuals who 

travel to another country for the purpose of engaging in inappropriate 

sexual activity with a child. We selected Australia, Canada, and the 

United Kingdom because they are known to have national sex offender 

registries, similar to those of the United States, and have expressed an 

interest in receiving information from the U.S. government on sex 

offenders traveling to their countries. For each of these countries, we 

reached out to the ICE attachés stationed in country as well as a 

representative from the country’s national law enforcement agency. The 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-13-200 Registered Sex Offenders 

perspectives of these officials are not representative, but provide valuable 

insights.

We conducted this performance audit from January 2012 to February 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our analysis based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our analysis based on our audit 

objectives.
Appendix II: Registered Sex Offenders 

Traveling Internationally Who Were Refused 

Entry by Foreign Countries

Page 39 GAO-13-200 Registered Sex Offenders 

CBP’s National Targeting Center (NTC) reviews air and sea passenger 

data to identify registered sex offenders who plan to travel internationally. 

NTC shares this information with the U.S. Marshals and ICE. The U.S. 

Marshals then refers these travelers to USNCB, and USNCB sends 

notifications to its counterparts via INTERPOL to foreign countries so that 

these countries can take action they deem appropriate to help ensure 

public safety, such as refusing entry. Figure 3 shows, according to NTC, 

how many registered sex offenders NTC identified and referred to 

USNCB (through the U.S. Marshals) who were ultimately refused entry by 

the foreign country during fiscal year 2012.

Figure 3: Number of Registered Sex Offenders Referred by the National Targeting Center (NTC) to the U.S. Marshals and U.S. 

Immigration and Customs Enforcement (ICE), and Number Refused Entry by Foreign Destination Country, October 1, 2011, to 

September 27, 2012

Appendix II: Registered Sex Offenders 

Traveling Internationally Who Were Refused 

Entry by Foreign Countries
Appendix III: Comments from the Department 

of Homeland Security

Page 40 GAO-13-200 Registered Sex Offenders 

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 41 GAO-13-200 Registered Sex Offenders 
Appendix III: Comments from the Department 

of Homeland Security

Page 42 GAO-13-200 Registered Sex Offenders 
Appendix IV: Comments from the Department 

of Justice 

Page 43 GAO-13-200 Registered Sex Offenders 

Appendix IV: Comments from the 

Department of Justice
Appendix IV: Comments from the Department 

of Justice 

Page 44 GAO-13-200 Registered Sex Offenders 
Appendix V: Contact and Staff 

Acknowledgments

Page 45 GAO-13-200 Registered Sex Offenders 

Eileen R. Larence, (202) 512-8777 or larencee@gao.gov

In addition to the contact named above, Kristy Brown, Assistant Director; 

Su Jin Yon, Analyst-in-Charge; and Alicia Loucks made significant 

contributions to the report. Other key contributors were Susan Baker, 

Gary Bianchi, Frances Cook, Anthony DeFrank, Heather Dunahoo, 

Michele Fejfar, Eric Hauswirth, Richard Eiserman, Lara Miklozek, Linda 

Miller, Anthony Moran, Sheena Smith, Julie Spetz, and John Vocino.

Appendix V: Contact and Staff 

Acknowledgments 

GAO Contact

Acknowledgments

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