Federal Register / Vol. 83, No. 147 / Tuesday, July 31, 2018 / Notices 36947 

1 80 FR 70241. In the 2015 Notice, the test was 

referred to as the ‘‘Test to Collect Biometric 

Information at the Otay Mesa Port of Entry.’’ 

2This PIA is available at: https://www.dhs.gov/ 

publication/dhscbppia-027-southwest-borderpedestrian-exit-field-test. 

14. Competitive pilotage; 

15. Recuperative rest for pilots; 

16. Legislative changes; 

17. Lake Ontario/Saint Lawrence 

River Traffic Challenges; 

18. Public comment period. 

A copy of all meeting documentation 

will be available at https://

dco.uscg.afpims.mil/Our-Organization/ 

Assistant-Commandant-for-PreventionPolicy-CG-5P/Marine-TransportationSystems-CG-5PW/Office-of-Waterwaysand-Ocean-Policy/Office-of-Waterwaysand-Ocean-Policy-Great-LaskesPilotage-Div/ by September 4, 2018. 

Alternatively, you may contact Mr. 

Vincent Berg as noted in the FOR

FURTHER INFORMATION CONTACT section 

above. 

Public comments or questions will be 

taken throughout the meeting as the 

Committee discusses the issues and 

prior to deliberations and voting. There 

will also be a public comment period at 

the end of the meeting. Speakers are 

requested to limit their comments to 5 

minutes. Please note that the public 

comment period will end following the 

last call for comments. Contact the 

individual listed in the FOR FURTHER

INFORMATION CONTACT section above, to 

register as a speaker. 

Dated: July 26, 2018. 

Michael D. Emerson, 

Director, Marine Transportation Systems. 

[FR Doc. 2018–16365 Filed 7–30–18; 8:45 am] 

BILLING CODE 9110–04–P 

DEPARTMENT OF HOMELAND 

SECURITY 

U.S. Customs and Border Protection 

Notice of Availability of Updated 

Privacy Impact Assessment for the 

Southwest Border Pedestrian Exit 

Field Test 

AGENCY: U.S. Customs and Border 

Protection, DHS. 

ACTION: Notice of availability. 

SUMMARY: U.S. Customs and Border 

Protection (CBP) has made available an 

updated Privacy Impact Assessment 

(PIA) for the Southwest Border 

Pedestrian Exit Field Test. This updated 

PIA, which changes the retention period 

for certain biometric data gathered 

during the test, was published on the 

Department of Homeland Security 

(DHS) Privacy Office’s website on 

March 5, 2018. 

FOR FURTHER INFORMATION CONTACT: 

Debra Danisek, Privacy Officer, U.S. 

Customs and Border Protection, at 

debra.danisek@cbp.dhs.gov or (202) 

344–1191. 

SUPPLEMENTARY INFORMATION: U.S. 

Customs and Border Protection (CBP) 

conducted a test to collect certain 

biometric information at the Otay Mesa 

port of entry from December 2015 

through June 2016 (‘‘Southwest Border 

Pedestrian Exit Field Test’’). This test 

was announced in a notice published in 

the Federal Register on November 13, 

2015 (‘‘2015 Notice’’).1 CBP published a 

Privacy Impact Assessment (PIA) for 

this test on the Department of Homeland 

Security (DHS) Privacy Office’s website 

on November 6, 2015.2 The purpose of 

the test was to determine if collecting 

biometrics in conjunction with 

biographic data upon exit from the 

United States would assist CBP in 

matching subsequent border crossing 

information records with previously 

collected entry records. The biometrics 

collected provide CBP with a baseline of 

images collected in a live environment 

that can be compared with existing 

images. CBP stated in the 2015 Notice 

and in the PIA that it would retain data 

collected during the test for one year. 

Since the conclusion of the Southwest 

Border Pedestrian Exit Field Test, CBP 

has continued to explore the best 

collection methods and modalities for a 

biometric entry-exit program. CBP has 

found that the data collected in the 

Southwest Border Pedestrian Exit Field 

Test continues to have value because it 

provides CBP with a rich source of data 

for ongoing analysis in its efforts to 

implement an effective biometric entryexit program. CBP and its vendors are 

able to use this data for analysis prior 

to expending additional time and 

resources to test various systems in the 

field. Therefore, CBP revised its 

retention policy for this data and 

published an updated PIA on the DHS 

Privacy Office’s website on March 5, 

2018. The updated PIA provides that 

CBP is retaining the biometric data 

gathered under the Southwest Border 

Pedestrian Exit Field Test until April 

2020. It further provides that CBP is not 

storing the associated biographic 

information. 

The updated PIA is available at: 

https://www.dhs.gov/publication/ 

dhscbppia-027-southwest-borderpedestrian-exit-field-test. 

Dated: July 26, 2018. 

Debra Danisek, 

CBP Privacy Officer, Privacy and Diversity 

Office, Office of the Commissioner. 

[FR Doc. 2018–16351 Filed 7–30–18; 8:45 am] 

BILLING CODE 9111–14–P 

DEPARTMENT OF HOMELAND 

SECURITY 

U.S. Customs and Border Protection 

Notice of Issuance of Final 

Determination Concerning Subdermal 

Needle Electrodes 

AGENCY: U.S. Customs and Border 

Protection, Department of Homeland 

Security. 

ACTION: Notice of final determination. 

SUMMARY: This document provides 

notice that U.S. Customs and Border 

Protection (‘‘CBP’’) has issued a final 

determination concerning the country of 

origin of Rhythmlink International, 

LLC’s Subdermal Needle Electrode. 

Based upon the facts presented, CBP has 

concluded that the country of origin of 

the Subdermal Needle Electrode is the 

United States or Japan, depending on 

the country of origin of the needle 

electrode used in the assembly of the 

Subdermal Needle Electrode, for 

purposes of U.S. Government 

procurement. 

DATES: The final determination was 

issued on July 13, 2018. A copy of the 

final determination is attached. Any 

party-at-interest, as defined in 19 CFR 

177.22(d), may seek judicial review of 

this final determination no later than 

August 30, 2018. 

FOR FURTHER INFORMATION CONTACT: 

James Kim, Valuation and Special 

Programs Branch, Regulations and 

Rulings, Office of Trade (202) 325–0158. 

SUPPLEMENTARY INFORMATION: Notice is 

hereby given that on July 13, 2018, 

pursuant to subpart B of Part 177, U.S. 

Customs and Border Protection 

Regulations (19 CFR part 177, subpart 

B), CBP issued a final determination 

concerning the country of origin of 

Rhythmlink International, LLC’s 

Subdermal Needle Electrode, which 

may be offered to the U.S. Government 

under an undesignated government 

procurement contract. This final 

determination, HQ H296072, was issued 

under procedures set forth at 19 CFR 

part 177, subpart B, which implements 

Title III of the Trade Agreements Act of 

1979, as amended (19 U.S.C. 2511–18). 

In the final determination, CBP 

concluded that the assembly and 

processing in China does not result in 

a substantial transformation. Therefore, 


daltland on DSKBBV9HB2PROD with NOTICES
36948 Federal Register / Vol. 83, No. 147 / Tuesday, July 31, 2018 / Notices 

the country of origin of Rhythmlink 

International, LLC’s Subdermal Needle 

Electrode is the United States or Japan, 

depending on the country of origin of 

the needle electrode used in the 

assembly of the Subdermal Needle 

Electrode, for purposes of U.S. 

Government procurement. 

Section 177.29, CBP Regulations (19 

CFR 177.29), provides that a notice of 

final determination shall be published 

in the Federal Register within 60 days 

of the date the final determination is 

issued. Section 177.30, CBP Regulations 

(19 CFR 177.30), provides that any 

party-at-interest, as defined in 19 CFR 

177.22(d), may seek judicial review of a 

final determination within 30 days of 

publication of such determination in the 

Federal Register. 

Dated: July 13, 2018. 

Alice A. Kipel, 

Executive Director, Regulations and Rulings, 

Office of Trade. 

HQ H296072 

July 13, 2018 

OT:RR:CTF:VS H296072 JK 

CATEGORY: Origin 

David S. Robinson 

Nexsen Pruet, PLLC 

4141 Parklake Avenue 

Suite 200 

Raleigh, NC 27612 

RE: U.S. Government Procurement; Title 

III, Trade Agreements Act of 1979 (19 

U.S.C. § 2511); Subpart B, Part 177, CBP 

Regulations; Subdermal Needle 

Electrode; Substantial Transformation 

Dear Mr. Robinson: 

This is in response to your 

correspondence of March 29, 2018, 

requesting a final determination on 

behalf of Rhythmlink International, LLC 

(‘‘Rhythmlink’’), pursuant to subpart B 

of Part 177, U.S. Customs and Border 

Protection (‘‘CBP’’) Regulations (19 

C.F.R. § 177.21 et seq.). 

This final determination concerns the 

country of origin of the Subdermal 

Needle Electrode. We note that 

Rhythmlink is a party-at-interest within 

the meaning of 19 C.F.R. § 177.22(d)(1) 

and is entitled to request this final 

determination. 

FACTS: 

Rhythmlink is headquartered in 

Columbia, North Carolina and 

manufactures and distributes medical 

devices and provides custom packaging, 

private labeling, custom products, and 

contract manufacturing to its customers. 

The subject merchandise is a 

Subdermal Needle Electrode 

(‘‘Product’’), a high-tensile strength 

stainless steel wire cleared by the U.S. 

Food & Drug Administration (‘‘FDA’’) 

for performing both stimulating and 

recording electrical conductor 

functions. The Product serves as a 

physical connection between a patient 

and medical diagnostic equipment that 

records and/or elicits neurophysical 

biopotentials. The FDA classifies and 

designates the Product as a ‘‘needle 

electrode,’’ defined in FDA regulations 

as ‘‘a device which is placed 

subcutaneously to stimulate or to record 

electrical signals.’’ See 21 C.F.R. 

§ 882.1350. 

Rhythmlink’s fully assembled, 

packaged Product consists of the 

following six component parts: the 

needle electrode, the leadwire, a 

miniscule amount of solder, a heat 

shrink tube, a protective cover for the 

needle, and packaging. Rhythmlink sells 

the Product in varying lengths and 

styles, and end users can customize the 

color of the connecting leadwire. The 

leadwire acts as an electrical conductor 

that transfers low voltage electrical 

signals from the needle electrode to 

medical diagnostic equipment. You 

state that the functionality of the 

Product is common to all lengths and is 

unchanged by the color of the preconnected leadwire. You also state that 

other varieties of needle electrodes are 

available in the market that are not preconnected to a leadwire. Such needle 

electrodes may connect to a leadwire 

without soldering by using alligator 

clips and other removable connectors. 

Other varieties of needle electrodes may 

utilize wireless transmission, 

eliminating the need for a leadwire 

altogether. 

You state that Rhythmlink conducts 

all of the engineering and design of the 

Product in the United States. The 

engineering and design of the 

Subdermal Needle Electrode include the 

following steps: research and 

development; design control; IP 

generation; regulatory clearances; 

specifications; engineering drawings; 

work instructions; tooling, fixtures, and 

equipment designs; functional 

verification testing; sterilization 

validation; packaging, sterile barrier and 

shelf life validation; and process 

validations. 

Rhythmlink outsources the actual 

manufacturing and production of the 

FDA-compliant needle electrodes (prior 

to being attached to other components) 

to a contract manufacturer of medical 

devices. The contract manufacturer 

manufactures the needle electrode 

entirely in either the United States or 

Japan using either U.S. or Japanese 

stainless steel material. You state that its 

production processes are largely 

proprietary and that the manufacturing 

costs are unknown. Under the 

manufacturing process of the needle 

electrode, a stainless steel wire is cut to 

precise lengths, and the cut wire 

undergoes precise facet grinding, 

passivation, and electropolishing. The 

needle electrode is manufactured to 

Rhythmlink’s precise specifications, 

with three facets ground onto the front 

end to meet sharpness and insertion 

force requirements. Finally, it is 

packaged and shipped. The country of 

origin of the needle electrode is marked 

as either the United States or Japan, 

depending on the country in which it 

was manufactured. 

The Korean-origin leadwire is a 

commercially available 26-gauge twisted 

copper wire comprising 19 strands of 

38-gauge copper wire with medical 

grade PVC covering. The leadwire is 

available in a total of 35 color options. 

The Korean supplier of this wire cuts 

the wire, crimps a socket pin, attaches 

a connector to one end of the wire, and 

ships the wire to China. 

The needle electrodes from the United 

States or Japan are exported to China for 

additional assembly and processing. 

The ‘naked’ end of the Korean leadwire 

is soldered to the needle electrode using 

Chinese-origin solder, which is a mix of 

tin and copper and represents a quarter 

of a percent of the Product’s cost. You 

state that the soldering process takes 

roughly a second, substantiated by a 

video you provided of the process, and 

that six operators can professionally 

solder 30,000 Products in a day. The 

soldered Product undergoes ultrasonic 

cleaning and drying (spin and 

convention drying) in bulk. A Japaneseorigin heat shrink tube, available in 

almost 40 different diameters, is added 

to protect the solder joint. A U.S.-origin 

protective needle cover is placed over 

the needle electrode to prevent 

accidents. Finally, the product is 

packaged in a Tyvek pouch and 

cardboard packaging of Chinese-origin 

and re-exported to the United States. 

In the United States, the Product is 

subject to sterilization and a 

randomized sampling and testing 

protocol prior to sale. 

You provided a catalog of 

Rhythmlink’s products, which includes 

the Subdermal Needle Electrode. You 

also provided a detailed process map 

depicting the various processing steps 

involved in the engineering, 

manufacture, and sale of the Product, 

along with information on the country 

in which each step occurs and the skill 

and technology level required for each 

step. In addition, you provided 

component specifications for the 

Product. 


daltland on DSKBBV9HB2PROD with NOTICES
Federal Register / Vol. 83, No. 147 / Tuesday, July 31, 2018 / Notices 36949 

ISSUE: 

What is the country of origin of the 

Subdermal Needle Electrode for 

purposes of U.S. Government 

procurement? 

LAW AND ANALYSIS: 

CBP issues country of origin advisory 

rulings and final determinations as to 

whether an article is or would be a 

product of a designated country or 

instrumentality for the purposes of 

granting waivers of certain ‘‘Buy 

American’’ restrictions in U.S. law or 

practice for products offered for sale to 

the U.S. Government, pursuant to 

subpart B of Part 177, 19 C.F.R. § 177.21 

et seq., which implements Title III of the 

Trade Agreements Act of 1979, as 

amended (19 U.S.C. § 2511 et seq.) 

(‘‘TAA’’). 

Under the rule of origin set forth 

under 19 U.S.C. § 2518(4)(B): 

An article is a product of a country or 

instrumentality only if (i) it is wholly the 

growth, product, or manufacture of that 

country or instrumentality, or (ii) in the case 

of an article which consists in whole or in 

part of materials from another country or 

instrumentality, it has been substantially 

transformed into a new and different article 

of commerce with a name, character, or use 

distinct from that of the article or articles 

from which it was so transformed. 

See also 19 C.F.R. § 177.22(a). 

In rendering advisory rulings and 

final determinations for purposes of 

U.S. Government procurement, CBP 

applies the provisions of subpart B of 

Part 177 consistent with Federal 

Acquisition Regulations. See 19 C.F.R. 

§ 177.21. In this regard, CBP recognizes 

that the Federal Acquisition Regulations 

restrict the U.S. Government’s purchase 

of products to U.S.-made or designated 

country end products for acquisitions 

subject to the TAA. See 48 C.F.R. 

§ 25.403(c)(1). The Federal Acquisition 

Regulations define ‘‘U.S.-made end 

product’’ as: 

. . . an article that is mined, produced, or 

manufactured in the United States or that is 

substantially transformed in the United 

States into a new and different article of 

commerce with a name, character, or use 

distinct from that of the article or articles 

from which it was transformed. 

48 C.F.R. § 25.003. 

A substantial transformation occurs 

when an article emerges from a process 

with a new name, character or use 

different from that possessed by the 

article prior to processing. A substantial 

transformation will not result from a 

minor manufacturing or combining 

process that leaves the identity of the 

article intact. See United States v. 

Gibson-Thomsen Co., 27 C.C.P.A. 267 

(1940); National Juice Products 

Association v. United States, 628 F. 

Supp. 978 (Ct. Int’l Trade 1986). 

Courts have held that when the 

properties and uses of a product are 

predetermined by the material from 

which it was made, no substantial 

transformation occurs. For example, in 

Superior Wire v. United States, 669 F. 

Supp. 472 (Ct. Int’l Trade 1987), aff’d, 

867 F.2d 1409 (Fed. Cir. 1989), wire rod 

in coils was shipped to Canada where 

it was drawn into wire. The tensile 

strength of the final product was 

increased by approximately 30 to 40 

percent as the rod was reduced in crosssectional area by about 30 percent and 

was elongated. The court determined 

that the drawing operation did not 

result in a substantial transformation, 

pointing out that the properties of the 

wire rod and its uses were determined 

by the chemical content of the rod and 

the cooling processes used in its 

manufacture, and that the wire rod 

dictated the final form of the finished 

wire. 

For purposes of this ruling, we 

assume that the country of origin of the 

stainless steel wire used to manufacture 

the needle electrode is the United States 

or Japan. You assert that the assembly 

and processing that occurs in China, a 

non-designated country, does not 

substantially transform the U.S. or 

Japanese-origin needle electrode, 

claimed to be the essential character of 

the Product, into a new and different 

article of commerce. 

In HQ 555774, dated December 10, 

1990, Customs, a predecessor of CBP, 

ruled that Japanese-origin wire cut to 

varying length and electrical connectors 

crimped onto the ends of the wire in the 

United States did not constitute 

substantial transformation. Customs 

found that the essential character and 

use of the wire before and after the 

processing was the same, i.e., to conduct 

electrical current. 

In HQ H248851, dated July 8, 2014, 

CBP held that an Israeli-origin CO2 tube 

was not substantially transformed in 

China when cut to length and attached 

to four other components from Israel 

and China. CBP found that the CO2 tube 

performed the essential function of the 

finished product, which was the 

delivery of breath for monitoring the 

CO2 level in a patient’s breath. By way 

of the assembly process in China, the 

CO2 tube was attached to other 

components that facilitated its function 

and did not lose its individual identity 

in the process. 

Like the operations described in HQ 

555774 and HQ H248851, the assembly 

and processing that occur in China are 

simple and minor processes that leave 

the identity of the needle electrode 

intact. The soldering of the leadwire to 

the needle electrode occurs in roughly 

one second. The remaining processing 

of the Product, consisting of cleaning 

and drying, adding a heat shrink and 

protective cover, and packaging, are 

likewise simple and minor operations 

involving highly repetitive, low-skill 

functions. 

As in Superior Wire, the properties 

and uses of the Product are 

predetermined by the qualities of the 

needle electrode itself, which do not 

change as a result of the Chinese 

assembly and processing operations. 

The Product’s main function is to 

penetrate the skin or other membrane to 

allow medical diagnostic equipment to 

record or stimulate neurophysical 

biopotentials. While the presence of a 

pre-connected leadwire does provide 

convenience for the end user, by 

eliminating the need to use removable 

connectors for attaching a leadwire, the 

needle electrode is nonetheless capable 

of performing its main function without 

a pre-connected leadwire. Prior to any 

Chinese assembly or processing, the 

needle electrode already meets the 

definition of the FDA regulated ‘‘needle 

electrode.’’ As in HQ H248851, the 

attachment of the leadwire and other 

components to the needle electrode may 

facilitate its function, but the needle 

electrode does not lose its individual 

identity in the process. As a result, we 

find that the U.S. or Japanese-origin 

needle electrode, rather than the 

Korean-origin leadwire, determines the 

essential character of the Product. 

We find that the name, character, and 

use of the needle electrode remain 

unchanged after the attachment of the 

leadwire and other components. 

Accordingly, we find that the needle 

electrode is not substantially 

transformed as a result of the Chinese 

assembly and processing operations. 

HOLDING: 

The country of origin of the 

Subdermal Needle Electrode for U.S. 

Government procurement purposes is 

the United States or Japan, depending 

on the country of origin of the needle 

electrode. 

Notice of this final determination will 

be given in the Federal Register, as 

required by 19 C.F.R. § 177.29. Any 

party-at-interest other than the party 

which requested this final 

determination may request, pursuant to 

19 C.F.R. § 177.31, that CBP reexamine 

the matter anew and issue a new final 

determination. Pursuant to 19 C.F.R. 

§ 177.30, any party-at-interest may, 

within 30 days after publication of the 

Federal Register notice referenced 

above, seek judicial review of this final 


daltland on DSKBBV9HB2PROD with NOTICES
36950 Federal Register / Vol. 83, No. 147 / Tuesday, July 31, 2018 / Notices 

determination before the Court of 

International Trade. 

Sincerely, 

Alice A. Kipel 

Executive Director 

Regulations and Rulings 

Office of Trade 

[FR Doc. 2018–16281 Filed 7–30–18; 8:45 am] 

BILLING CODE P 

DEPARTMENT OF HOMELAND 

SECURITY 

[Docket No. DHS–2018–0003] 

Privacy Act of 1974; System of 

Records 

AGENCY: Department of Homeland 

Security. 

ACTION: Notice of a new system of 

records. 

SUMMARY: In accordance with the 

Privacy Act of 1974, the Department of 

Homeland Security (DHS) proposes to 

consolidate two legacy systems of 

record, Department of Homeland 

Security/U.S. Citizenship and 

Immigration Services-002 Background 

Check Service and Department of 

Homeland Security/U.S. Citizenship 

and Immigration Services-003 Biometric 

Storage System into the new DHS 

system of records titled, ‘‘Department of 

Homeland Security/U.S. Citizenship 

and Immigration Services-018 

Immigration Biometric and Background 

Check System of Records.’’ This system 

of records notice (SORN) allows the 

DHS U.S. Citizenship and Immigration 

Services (USCIS) to collect and maintain 

biographic, biometric, and background 

check records on applicants, petitioners, 

sponsors, beneficiaries, or other 

individuals in connection with a benefit 

request. USCIS uses biometric and 

associated biographic information to 

verify identity, conduct criminal and 

national security background checks 

against internal and external 

government systems, and to support 

domestic and foreign data sharing 

agreements. The categories of 

individuals, categories of records, and 

the routine uses of these legacy systems 

of records notices have been 

consolidated and updated to better 

reflect the Department’s biometric and 

biographic criminal background checks; 

identity enrollment, verification, and 

resolution; document production record 

systems; and data sharing efforts. 

Additionally, DHS is issuing a Notice 

of Proposed Rulemaking (NPRM) to 

exempt this system of records from 

certain provisions of the Privacy Act, 

elsewhere in the Federal Register. This 

new system will be included in DHS’s 

inventory of record systems. 

DATES: Submit comments on or before 

August 30, 2018. This system will be 

effective upon publication. Routine uses 

will become effective August 30, 2018. 

ADDRESSES: You may submit comments, 

identified by docket number DHS– 

2018–0003 by one of the following 

methods: 

• Federal e-Rulemaking Portal: http:// 

www.regulations.gov. Follow the 

instructions for submitting comments. 

• Fax: 202–343–4010. 

• Mail: Philip S. Kaplan, Chief 

Privacy Officer, Privacy Office, 

Department of Homeland Security, 

Washington, DC 20528–0655. 

Instructions: All submissions received 

must include the agency name and 

docket number DHS–2018–0003 for this 

notice. All comments received will be 

posted without change to http://

www.regulations.gov, including any 

personal information provided. 

Docket: For access to the docket to 

read background documents or 

comments received, go to http://

www.regulations.gov. 

FOR FURTHER INFORMATION CONTACT: For 

general questions, please contact: 

Donald K. Hawkins, (202) 272–8030, 

USCIS.PrivacyCompliance@

uscis.dhs.gov, Privacy Officer, U.S. 

Citizenship and Immigration Services, 

20 Massachusetts Avenue NW, 

Washington, DC 20529. For privacy 

questions, please contact: Philip S. 

Kaplan, (202) 343–1717, Privacy@

hq.dhs.gov, Chief Privacy Officer, 

Privacy Office, Department of Homeland 

Security, Washington, DC 20528–0655. 

SUPPLEMENTARY INFORMATION: 

I. Background 

DHS USCIS has relied on two 

preexisting DHS/USCIS Privacy Act 

SORNs for the maintenance of USCIS 

biometric and background check 

records: ‘‘DHS/USCIS 002 Background 

Check Service,’’ 72 FR 31082 (June 5, 

2007), and ‘‘DHS/USCIS–003 Biometric 

Storage System,’’ 72 FR 17172 (April 6, 

2007). Such records will be covered by 

one new system of records named 

‘‘DHS/USCIS–018 Immigration 

Biometric and Background Check (IBBC) 

System of Records.’’ USCIS processes 

and adjudicates most immigration 

benefit requests and other immigration 

request forms (e.g., applications and 

petitions) for DHS. This new system of 

records notice consolidates and covers 

all of USCIS’s biometric and associated 

biographic information it collects 

pursuant to that mission. The purpose 

of this system is to verify identity and 

conduct criminal and national security 

background checks in order to establish 

an individual’s eligibility for an 

immigration benefit or other request, 

and support domestic and international 

data sharing efforts. USCIS determines 

eligibility by capturing biometric and 

associated biographic data from benefit 

requestors, beneficiaries, and other 

categories of individuals to facilitate 

three key operational functions: (1) 

Verify an individual’s identity; (2) 

conduct criminal and national security 

background checks; and (3) produce 

benefit cards and documents as a proof 

of benefit. 

Most individuals who file benefit 

requests for themselves or on the behalf 

of others (i.e., petitioner, applicants, 

beneficiaries, and requestors) are subject 

to background, identity, and security 

checks to ensure eligibility for the 

requested benefit. Other individuals in 

connection with immigration benefit 

requests or other requests (i.e., 

household members, sponsors) may also 

be subject to certain background, 

identity, and security checks. The 

biometric collection process begins with 

the capture of biometric data at an 

authorized biometric capture site, 

including USCIS offices, Application 

Support Centers, or U.S. consular offices 

and military installations abroad. USCIS 

requires applicants, petitioners, 

sponsors, beneficiaries, or other 

individuals in connection of a benefit 

request to submit their biometrics along 

with associated biographic information 

to USCIS for background, identity, and 

security checks. The types of 

background checks USCIS conducts 

vary by the benefit or request type. 

Standard background checks may 

include, but are not limited to: 

Biometric based checks: 

• Federal Bureau of Investigation 

(FBI) Next Generation Identification 

(NGI) Biometric Check; 

• DHS Office of Biometric and 

Identity Management (OBIM) 

Automated Biometric Identification 

System (IDENT) Biometric Check; 

• Department of Defense (DoD) 

Automated Biometric Identification 

System (ABIS) Biometric Check; 

Biographic name-based checks: 

• FBI Central Records System (CRS) 

and Universal Index (UNI) Name Check; 

• U.S. Customs and Border Protection 

(CBP) TECS Name Checks; 

• Department of State (DOS) Consular 

Lookout and Support System (CLASS); 

and 

• DOS Security Advisory Opinion 

(SAO). 

USCIS may also perform interagency 

checks with intelligence community 

partners for certain benefits. The results 

of these checks are used to inform 


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