DOI: 10.5281/zenodo.17836676
title: Immigration Stability Doctrine A Governance-First AI Architecture for Modernizing the U.S. Immigration System

description: Immigration Stability Doctrine

A Governance-First AI Architecture for Modernizing the U.S. Immigration System

Prepared For: The Executive Office of the President, The National Security Council, The Department of Homeland Security (DHS), The Department of Justice (DOJ), and The Department of Health and Human Services (HHS)

Distribution: Limited / Official Use Only

Date: October 24, 2025



1. Executive Summary

The United States immigration system, a sprawling apparatus spanning three federal departments and dozens of sub-agencies, has entered a state of systemic entropy that threatens both national security and humanitarian integrity. As of late 2025, the system is characterized not by its capacity to enforce the rule of law or adjudicate claims with precision, but by its "thermodynamic instability"—a persistent condition of high disorder defined by fragmented data architectures, disjointed interagency workflows, and a backlog of over 3.5 million cases that has rendered the immigration courts functionally paralyzed.1 This report, the Immigration Stability Doctrine, asserts that the root cause of this failure is not merely a lack of resources, but a fundamental architectural obsolescence. The current "reactive enforcement" model, predicated on industrial-era bureaucracy and disconnected legacy databases, is mathematically incapable of managing the complexity and velocity of 21st-century migration flows.

This doctrine proposes a radical stabilization strategy: the deployment of the Immigration Modernization & Management Architecture (IMMA). IMMA represents a paradigm shift from digitizing chaos to enforcing "Constraint-Based Stability." It integrates the CollectiveOS intelligence stack—specifically the Universal Intent Layer (UIL) and the Emergent Linear Feedback Engine (ELFE)—to create a governance-first AI ecosystem where every operational action is mathematically bounded by legal, ethical, and safety constraints before execution.2

Unlike traditional IT modernization efforts that often result in "vendor lock-in" and disjointed pilot programs 3, IMMA establishes a unified Multi-Agent "Swarm" Architecture. In this model, specialized autonomous agents—Giles (Strategic Orchestration), Rabbit (Operational Execution), Syn (Immutable Memory), Cypher (Zero-Trust Security), and AION (Causal Simulation)—operate as a federated mesh across the jurisdictional boundaries of DHS, DOJ, and HHS. These agents do not merely process data; they actively minimize "informational drift," ensuring that the digital reality of a case (its status in a database) remains perfectly synchronized with the physical reality of the individual (their location and legal standing).2

Crucially, IMMA is governed by the GATA PRIME pipeline, a rigorous authorization layer that serves as the "Root of Trust" for the entire system. This framework ensures strict adherence to the NIST AI Risk Management Framework (AI RMF) and Executive Order 14110, specifically regarding "rights-impacting" AI systems.4 By encoding the Fair Information Practice Principles (FIPPs) as executable logic 6, IMMA transforms privacy and civil rights from policy aspirations into immutable code constraints.

The stakes of this transformation are existential for the administrative state. The Government Accountability Office (GAO) and Office of Inspector General (OIG) have repeatedly documented catastrophic failures in data sharing—from the inability to track unaccompanied children transferred between agencies to the reliance on paper files that vanish in transit.7 These are not administrative nuisances; they are vulnerabilities that obscure the identity of threats and abandon the vulnerable to exploitation. The Immigration Stability Doctrine provides the technical and strategic roadmap to close these gaps, replacing bureaucratic fragility with sovereign stability.



2. Background: The Thermodynamics of Bureaucratic Failure

To prescribe a viable architectural solution, one must first conduct a forensic analysis of the current system's pathology. The U.S. immigration apparatus does not function as a single organism but rather as a loose confederation of incompatible legacy systems, misaligned incentives, and fragmented data standards. This state of affairs results in what can be termed "bureaucratic thermodynamics," where the energy required to move a case from initiation to resolution increases exponentially with every interagency handoff, generating massive amounts of "waste heat" in the form of delays, errors, and litigation.

2.1 The Interagency Interoperability Crisis: A Fracture in Truth

The most critical failure point identified in over a decade of federal audits is the structural inability of agencies to share actionable data in real-time. The GAO has highlighted that while DHS has established governance boards to improve information sharing, significant gaps remain in tracking and assessing the effectiveness of these initiatives.9 This fragmentation is not merely a technical inconvenience; it creates dangerous blind spots in the national security picture.

This interoperability crisis is most acute at the "seams" of agency responsibility—the points where custody or jurisdiction transfers from one department to another. The migration lifecycle typically involves:





Apprehension: U.S. Customs and Border Protection (CBP) apprehends an individual and generates data in the e3 portal.10




Detention/Processing: Custody transfers to U.S. Immigration and Customs Enforcement (ICE), which utilizes the Enforcement Integrated Database (EID).




Adjudication: The case is filed with the DOJ's Executive Office for Immigration Review (EOIR), which relies on a separate, often paper-based, case management system (CASE).8




Care (for Minors): Unaccompanied Alien Children (UACs) are transferred to the HHS Office of Refugee Resettlement (ORR), which utilizes its own disparate tracking portal (UC Portal).7



The friction at these seams is catastrophic. The DHS OIG has reported that ICE cannot effectively monitor the location and status of UACs once they are transferred to HHS custody. In a startling finding, over 31,000 children's release addresses were recorded as blank, undeliverable, or missing apartment numbers between FY 2019 and FY 2023.7 This represents a "data lineage failure." Without a shared "Truth Anchor," a child’s status can be recorded as "detained" in DHS systems, "released" in HHS systems, and "unknown" to the immigration court. This dissonance creates an "informational drift" where the government's digital record diverges from physical reality, creating opportunities for traffickers to exploit the gap and for children to disappear from the protective radar of the state.7

Furthermore, the GAO has noted that the lack of a unique identifier shared across components prevents the linking of family members apprehended together.11 This creates a scenario where parents and children are processed as unrelated entities, complicating reunification efforts and leading to the systemic failures observed during the "Zero Tolerance" period, where "ad hoc" tracking methods like spreadsheets were used in place of robust database architecture.12

2.2 The Backlog Singularity: A System in Collapse

The Executive Office for Immigration Review (EOIR) is currently experiencing a "backlog singularity," a mathematical point where the rate of new case inputs so vastly exceeds the rate of adjudicative outputs that the system effectively ceases to function as a mechanism of justice. As of mid-2024, the pending caseload exceeded 3.5 million.1 This backlog has more than tripled since fiscal year 2017.13

This backlog creates a vicious feedback loop of instability. The multi-year wait times for a hearing act as a "pull factor," encouraging individuals with weak or non-existent claims to enter the system simply to benefit from the de facto residency granted by the delay. This influx further deepens the backlog, extending wait times even more.

The technological substrate of the immigration courts exacerbates this crisis. A significant portion of case files remains paper-based, requiring physical transportation of files between judges, clerks, and attorneys.8 The GAO has noted that EOIR’s reliance on paper files is a primary driver of adjudication inefficiencies, creating single points of failure where a lost file can halt proceedings indefinitely. Additionally, the EOIR's electronic case management system lacks basic functionality, such as the ability to systematically record whether a respondent appeared for a hearing.14 This forces judges to rely on unreliable "adjournment codes" that do not provide the granular data necessary for workforce planning or performance management.15

Table 1: The Escalating Scale of Adjudicative Failure

 








Metric



Status (Circa 2017)



Status (Circa 2024/2025)



Trend Analysis





Pending Caseload



~600,000 cases



> 3.5 Million cases 1



Exponential Growth: The system is ingesting cases faster than it can close them.





Data Format



Predominantly Paper



Mixed / Fragmented Digital



Technological Debt: Digitization efforts are stalled by legacy processes.8





Scheduling Efficiency



Low



Critical Failure



Operational Drift: Master Calendar hearings are clogged with routine admin tasks.16





In Absentia Rate



Variable



~34% (Non-detained) 14



Process Failure: High rates indicate failures in notice/service and respondent tracking.






2.3 The Biometric Disconnect: The IDENT to HART Transition Risk

The biometric identity of the individual is the foundational data element of the immigration system. DHS is currently in a prolonged and risky transition from the legacy Automated Biometric Identification System (IDENT) to the Homeland Advanced Recognition Technology (HART) system.10

This transition represents a perilous period of vulnerability. HART is intended to serve as the biometric backbone for national security, hosting modal data including fingerprints, iris scans, and facial recognition patterns.18 However, the program has been plagued by delays and cost overruns. More critically, privacy impact assessments and external audits indicate that HART will ingest vast quantities of data from external agencies and foreign partners without fully matured privacy governance structures or "opt-out" mechanisms for U.S. citizens caught in the dragnet.18

The fragmentation here is operational. A CBP agent at a port of entry may not have immediate access to a derogatory biometric record held by the Department of Defense (DOD) or an intelligence agency if that data has not yet propagated to the primary inspection database. Conversely, a humanitarian protection granted by USCIS may not be biometrically linked to an ICE detainer, leading to the unlawful arrest of a protected individual. This "latency of truth" is a direct violator of the Constraint-First principle, as the system acts on incomplete information states, creating liability and risk.2

2.4 The Failure of Pilot Programs and "Ad Hoc" Solutions

The government's response to these challenges has largely been reactive, characterized by a series of pilot programs and "ad hoc" technological patches that fail to address the underlying architectural rot. For example, GAO reviews of pilot programs intended to expedite processing along the southwest border found that while DHS and DOJ expedited the scheduling of hearings, they failed to ensure that the necessary charging documents (Notices to Appear) were filed with the courts in a timely manner, leading to dismissals and administrative chaos.3

Similarly, during the 2019 migrant surge, DHS's fragmented approach to detention planning resulted in extended detention times and overcrowding, as the department lacked a unified model to predict and manage bed space requirements across its network of contractors.20 These failures demonstrate that adding more resources (judges, agents, beds) to a fundamentally broken architecture yields diminishing returns. The system requires a new operating doctrine.



3. System Architecture: The IMMA Platform

The Immigration Modernization & Management Architecture (IMMA) addresses these structural failures by deploying the CollectiveOS multi-agent stack. IMMA rejects the "monolithic database" approach, which creates single points of failure and is historically prone to costly procurement collapses. Instead, IMMA establishes a federated Universal Intent Layer (UIL) where disparate agency systems (e.g., e3, EID, CASE, UC Portal) act as data providers to a unified, overlay governance mesh.

3.1 The Universal Intent Layer (UIL): Physics of the Bureaucracy

The theoretical foundation of IMMA is the UIL, a constraint-based operating system derived from the "God File" internal specifications. The UIL posits that patterns precede mechanisms; in a complex system, stability is achieved not by micro-managing every event, but by defining the "Constraint Fields" that guide the system toward equilibrium.2

In the context of immigration, the "Legal Constraints" (the Immigration and Nationality Act, federal regulations, court orders, settlement agreements like Flores) are encoded as the primary physics of the system.

The Constraint Field Equation:



$$C(x) = \operatorname{arg\,min}_{x} \Phi(x)$$

Where:





$x$ is the current state of an immigration case (e.g., "Pending Asylum Application").




$\Phi(x)$ is the "Constraint Potential," a mathematical representation of the legal and ethical friction associated with that state. A state of "Unlawful Detention" has extremely high potential (instability), while a state of "Lawful Permanent Residence" or "Executed Removal Order" has low potential (stability).




$C(x)$ is the lawful state the system must converge toward to minimize potential.



Instead of a human agent manually deciding the next step, the IMMA system calculates the path of least resistance through the constraint field. If an individual is granted asylum by a judge, the system automatically minimizes the potential $\Phi$ by triggering the necessary downstream actions—updating the work authorization database, notifying the benefits agency, closing the removal proceedings—without human data entry. This ensures that the "drift" between legal status and operational reality is zero.

3.2 The Agentic Bureaucracy: A Multi-Agent Swarm

IMMA deploys the CollectiveOS Multi-Agent Architecture to handle the complexity of interagency coordination. These are not simple scripts; they are autonomous software entities with specific roles, authorities, and cryptographic identities.2

3.2.1 Giles: The Strategic Orchestrator

Giles serves as the central adjudicative scheduler and resource manager. It sits above the specific agency databases, viewing the entire immigration lifecycle as a single supply chain.





Function: Giles utilizes Confidence-Weighted Voting ($V = \sum w_i \cdot o_i$) to arbitrate conflicting data inputs.2 If DHS records an individual as a "Flight Risk" ($w_{DHS}$) but HHS records them as a "Vulnerable Minor" ($w_{HHS}$), Giles identifies the constraint conflict. It does not blindly accept one; it halts processing and triggers a "Constraint Resolution Task" for a human supervisor, preventing the "automating of error."




Docket Management: Giles addresses the EOIR backlog by simulating courtroom loads and dynamically assigning cases to judges based on case complexity and judicial availability. It enforces the State Harmonization equation ($x_i \leftarrow x_i + \gamma (M - x_i)$) to balance workloads across the 69 immigration courts, preventing one court from drowning while another has capacity.2



3.2.2 Rabbit: The Operational Executor

Rabbit is the "hands" of the system, responsible for execution and API interaction across the disparate legacy systems.





Function: When CBP processes an apprehension in e3, Rabbit automatically instantiates the corresponding records in ICE’s EID and EOIR’s case management system. It eliminates the "swivel-chair" data entry that leads to transcription errors.




Predictive Logistics: Rabbit executes the Predictive Update Rule ($x_{t+1}^{pred} = x_t + \beta(x_t - x_{t-1})$) to pre-position resources.2 By analyzing flow rates at the border, Rabbit can tentatively schedule court dates or reserve bed space weeks in advance, smoothing the logistical curve.




Safety: Rabbit operates under strict GATA PRIME authorization. It cannot "delete" a record; it can only append a new state, ensuring auditability.



3.2.3 Syn: The Immutable Memory

Syn manages the Proof Vault, an immutable, blockchain-anchored ledger that replaces the physical "A-File" (Alien File) as the single source of truth.





Function: Syn ensures that every interaction with a migrant—every fingerprint scan, every medical screening, every court appearance—is cryptographically hashed and stored in the Proof Vault.2 This solves the "missing file" problem identified by the GAO.8 Even if the local EOIR server crashes or a paper file is lost in the mail, the Syn ledger retains the "Ground Truth" of the case history.




Chain of Custody: Syn enables the secure handoff of UACs. When ICE transfers a child to HHS, Syn records the transfer of custody on the ledger. This creates an unbreakable chain of custody, directly addressing the DHS OIG finding regarding lost children.7



3.2.4 Cypher: The Zero-Trust Guardian

Cypher enforces the Fair Information Practice Principles (FIPPs) at the code level, serving as the system's internal affairs officer.





Function: Cypher wraps all data objects in a zero-trust envelope. When HHS requests health data from DHS—a point of contention in litigation 21—Cypher evaluates the request against the Privacy Constraint Field. It allows access only if the specific legal authority is cited and verified.




Redaction: Cypher automatically redacts sensitive PII using Fully Homomorphic Encryption (FHE) techniques before sharing data with non-privileged agents. This ensures that analytic agents (like AION) can study trends without exposing individual identities, satisfying the Data Minimization principle of the FIPPs.6



3.2.5 AION: The Causal Simulator

AION provides predictive capability and "red team" simulation.





Function: AION runs continuous simulations of border flows and court backlogs. It uses Quantum-Logic Layer abstractions to model probabilistic outcomes.2 For example, AION can simulate: "If we implement Policy X regarding asylum thresholds, what is the probability of a 20% increase in family unit separation?" This allows policymakers to test immigration policies in a simulation environment ("in silica") before deployment, preventing the operational collapses seen during the 2019 surge.20



3.3 The ELFE Stability Kernel: Solving Operational Oscillation

The immigration system is prone to wild oscillations—hiring sprees followed by freezes, rapid policy shifts followed by court injunctions. IMMA utilizes the ELFE (Emergent Linear Feedback Engine) to maintain system stability. While the core mechanisms of ELFE are classified, the "Safe" mathematical operators are deployed to prevent administrative oscillation.2

The Oscillation Damping Function:



$$x_{t+1} = x_t - \alpha \cdot (x_t - \bar{x})$$

Where:





$\bar{x}$ is the "Equilibrium State" (e.g., the ideal caseload per judge or the optimal bed capacity).




$\alpha$ is the damping factor (0.1 to 0.3).



Application: When a sudden surge of migrants occurs, traditional bureaucracies oscillate wildly. ELFE dampens this response. Instead of immediately authorizing a massive, expensive contract for new facilities that may not be needed in a month, the system calculates the optimal resource allocation to maintain steady-state processing capacity. This prevents the "boom and bust" cycle of border enforcement resource management, ensuring fiscal responsibility and operational continuity.



4. National Security: The Sovereign Constraint Field

In the modern era, national security is defined by information integrity and identity dominance. The inability to accurately identify who is in the country, where they are, and what their legal status represents a fundamental breach of sovereignty. IMMA restores security through Identity Dominance and Drift Minimization.

4.1 Threat Detection via Constraint Drift

Current threat detection relies heavily on "watchlists"—static databases of known bad actors. While necessary, this approach is reactive. IMMA introduces Behavioral Constraint Drift monitoring.

The system calculates the drift ($D$) of an individual's journey against the normative "lawful" path for their specific admission class.



$$D = |x - C(x)|$$

If an individual entered on a student visa (the constraint $C(x)$) but the Syn agent records no university attendance and a sudden relocation to a geographic area associated with high-risk activity (the actual state $x$), the Drift ($D$) spikes. Cypher detects this anomaly not because the person is on a watchlist, but because their behavior fundamentally violates the constraints of their legal status. This allows for pre-crime intervention based on behavioral physics rather than retrospective investigation, enabling agencies to prioritize high-drift cases for investigation.

4.2 Securing the Biometric Backbone (HART)

As DHS transitions to the HART system, the centralization of biometric data creates a massive "honeypot" risk.





Risk: Centralized biometric databases are prime targets for adversarial AI attacks (poisoning) or future quantum decryption ("Harvest Now, Decrypt Later").2




Solution: IMMA mandates that HART data is not stored merely as raw images but as vector embeddings anchored in the Proof Vault. Any attempt to alter a biometric record (e.g., a deepfake injection or a "cleaning" of a derogatory record) would violate the immutable lineage maintained by Syn.




Response: Such a violation triggers an immediate "Integrity Lockdown" by Cypher, isolating the compromised record and alerting the GATA PRIME authority. This aligns with the "Safe, Secure, and Trustworthy" mandates of EO 14110 by ensuring data integrity is mathematically provable and resistant to manipulation.4



4.3 Interagency Intelligence Fusion

The Information Sharing Environment (ISE) has historically struggled with "need to know" silos, often preventing the dots from being connected before an incident.23 IMMA replaces this with "need to share" constraints managed by Cypher.





Mechanism: Intelligence from the FBI or the Intelligence Community (IC) is ingested by AION as a "Constraint Variable." If a new threat vector emerges (e.g., a specific smuggling route or a new fraud pattern), AION updates the global constraint field.




Effect: Rabbit agents at the border immediately adjust their processing logic to flag individuals fitting the new threat profile. This ensures that tactical intelligence at the edge (the Border Patrol agent's tablet) is synchronized with strategic intelligence at the core (the National Counterterrorism Center) in milliseconds, not months.





5. Governance Framework: The GATA Pipeline

To ensure that this powerful autonomous system remains aligned with democratic values and federal law, IMMA is governed by the CollectiveOS Governance Pipeline.2 This pipeline integrates explicitly with the NIST AI Risk Management Framework (AI RMF), mapping the concepts of Map, Measure, Manage, and Govern to executable code.24

5.1 Step 1: QC (Quality Control) - The Data Integrity Layer

Before any data enters the IMMA ecosystem, it must pass the QC gate.





Mechanism: Automated validation of data completeness. For UACs, the system refuses to accept a digital transfer of custody from CBP to ICE unless all mandatory fields (medical history, family contacts, property inventory) are populated.




NIST Mapping: This maps to the Measure function of NIST AI RMF—ensuring data quality and reliability before it is used for decision-making. This technically enforces the solution to the DHS OIG finding of "blank addresses".7



5.2 Step 2: GATA (Governance, Audit, Trust, Authority) - The Ethics Layer

This layer evaluates the intent and impact of the automated action.





Dual-Use Check: Ensures that tools designed for humanitarian relief (e.g., tracking UAC locations for safety) are not repurposed for enforcement actions against sponsors without specific legal authority. This addresses the privacy and separation of powers concerns raised by the California Attorney General and privacy advocates.21




Rights-Impacting Assessment: Consistent with OMB M-24-10, any AI model used to adjudicate asylum claims, determine detention, or assess flight risk is classified as "Rights-Impacting".25 GATA requires a documented impact assessment and a mandatory "Human-in-the-Loop" fallback protocol before the model can be deployed.



5.3 Step 3: GATA PRIME - The Absolute Authorization Layer

This is the "nuclear key" of the system, the absolute authorization layer.





Function: GATA PRIME holds the cryptographic keys for high-consequence actions (e.g., authorizing a removal flight, finalizing a deportation order, or granting permanent status).




Constraint-Weighted Update: The system uses the equation $x_{t+1} = (1-\lambda)x_t + \lambda C(x_t)$ to force alignment.2 If an automated decision ($x_t$) drifts from the policy authorized by the GATA PRIME board ($C(x_t)$), the system overwrites the decision with the policy-compliant state. This prevents "rogue AI" scenarios or policy drift by field agents who might ignore new directives.



5.4 Step 4: The Proof Vault - Immutable Lineage





Mechanism: Every decision made by Giles, Rabbit, or a human judge is hashed to the Proof Vault. This creates an unalterable audit trail.




Accountability: If a wrongful deportation occurs, the OIG can query the Proof Vault to reconstruct the exact sequence of data, algorithmic weights, and human decisions that led to the error. This provides the "Accountability and Auditing" required by the Fair Information Practice Principles (FIPPs).6



5.5 The Chief AI Officer (CAIO) and Governance Boards

In compliance with OMB M-24-10, the Department of Homeland Security, DOJ, and HHS must each designate a Chief AI Officer (CAIO) with the authority to oversee the implementation of IMMA.25





AI Governance Boards: Each agency must convene an AI Governance Board to oversee the deployment of "Rights-Impacting" AI. These boards will review the "Drift Certificates" generated by the system and ensure that the AI's constraints remain aligned with evolving case law and executive policy.28





6. Operational Stabilization: Solving the Backlog

The "Backlog Singularity" at EOIR is not just a scheduling problem; it is a problem of flow dynamics. IMMA treats the court docket not as a calendar, but as a fluid dynamics problem to be optimized by Giles.

6.1 Automated Docket Harmonization

Currently, master calendar hearings—preliminary hearings used for pleading and scheduling—are clogged with routine matters that add no value to the adjudication but consume massive amounts of judicial time.16





IMMA Solution: Rabbit agents automatically handle routine scheduling and document ingestion. If a respondent has a pending application with USCIS (e.g., a visa petition), Giles detects the dependency. Instead of scheduling a hearing only for the judge to continue the case (a major source of inefficiency), Giles automatically administratively closes or continues the EOIR case until the USCIS petition is adjudicated.




Impact: This "interagency handshake" eliminates the thousands of "status update" hearings that currently clog the docket, potentially reducing the active docket load by 30-40%.29



6.2 The "Drift Certificate" for Asylum Adjudication

To speed up asylum processing without sacrificing due process, IMMA introduces the Drift Certificate.





Mechanism: AI agents analyze the fact pattern of an asylum claim against the corpus of established case law (the Constraint Field). The system generates a "Drift Score" ($D$).







Low Drift ($D \approx 0$): The case closely matches established precedents for granting asylum (e.g., a persecution claim based on a well-documented protected ground). The system flags this for "Expedited Grant" review.




High Drift ($D > \tau$): The case is novel, complex, or lacks precedent. The system flags this for a "Deep Review" by a senior judge.







Outcome: This triage allows the system to clear clear-cut cases rapidly, reserving scarce judicial resources for the complex determinations that require human judgment.



6.3 Closing the Loop on UAC Monitoring

To solve the crisis of "lost children" and missing addresses 7:





Continuous Monitoring: Syn maintains a persistent "Digital Twin" of the UAC’s legal status.




Cross-Agency Verification: If a UAC is released to a sponsor, Rabbit initiates periodic automated check-ins (via text, app, or case worker portal). If a check-in is missed, Cypher alerts the HHS case manager. Crucially, if the "Safety Constraint" is violated, the system can flag the case for ICE ERO (Enforcement and Removal Operations) for a welfare check, provided the action complies with the GATA dual-use check. This closes the information gap where children fall through the cracks between HHS care and ICE enforcement.



Table 2: Projected Impact on Operational Metrics








Operational Metric



Current State



Projected IMMA State (Year 3)



Mechanism





Case Backlog



> 3.5 Million



< 1.5 Million



Automated Harmonization & Admin Closure





UAC Location Accuracy



~92% (High Failure Rate)



> 99.9%



Syn Ledger & Automated Pings





Biometric Latency



Hours to Days



Real-Time



Vector Embeddings & Edge Processing





Scheduling Efficiency



Manual/Ad-Hoc



Optimized/Predictive



Giles Orchestration & Predictive Update








7. Safeguards: The Privacy & Civil Rights Firewall

Implementing AI in immigration carries significant risk to civil liberties. IMMA incorporates the Fair Information Practice Principles (FIPPs) not as policy guidance, but as executable code constraints.

7.1 Policy-as-Code Implementation of FIPPs





Purpose Specification: Data collected for the purpose of "Health Screening" (HHS) is tagged with a purpose:health meta-tag. If an ICE enforcement agent attempts to query this data for purpose:removal, the Cypher agent blocks the query at the database level. This strictly enforces the Use Limitation and Purpose Specification principles.6




Data Minimization: When sharing data between agencies, the system automatically strips all fields not legally required for the specific transaction. An agency requesting "status verification" receives a binary "Legal/Illegal" boolean response, not the full case file containing sensitive medical or family data.6



7.2 The Unreadable Machine

IMMA utilizes Fully Homomorphic Encryption (FHE). This allows the AI (Giles/AION) to perform computations on encrypted data without ever decrypting it.





Scenario: AION can analyze the aggregate health data of detainees to predict disease outbreaks or resource needs without ever "seeing" a single patient's name or medical record. This satisfies the NIST Privacy Framework requirements and protects the system from becoming a tool for mass surveillance or "dragnet" analytics.25



7.3 Rights-Impacting AI Compliance (EO 14110)

Consistent with OMB M-24-10, the IMMA Governance Board must annually certify that the system’s predictive models do not exhibit algorithmic bias against protected classes.





Testing: AION runs counterfactual simulations ("If this applicant were of a different nationality or gender, would the Drift Score change?"). If bias is detected ($D_{bias} > 0$), the model is automatically suspended by GATA PRIME until retrained. This ensures compliance with the Advancing Equity and Civil Rights provisions of EO 14110.26





8. Interagency Alignment: The Unified Constraint Field

The ultimate failure of the current system is the lack of a shared reality. DHS sees "Aliens," DOJ sees "Respondents," and HHS sees "Minors." To function effectively, the government must see "Entities" with a unified, truthful history.

8.1 The "Golden Record" via Syn

IMMA mandates a single, shared definition of the entity, stored in the Proof Vault.





Implementation: A "Federated Identity Broker" service. When a user is updated in DHS EID (e.g., an address change), the change propagates to EOIR’s case management system and HHS’s UAC portal via the GEM Bus (Global Event Message Bus).2 This ensures that all agencies are operating on the same version of the truth, eliminating the "blank address" problem where notices are sent to the wrong location.



8.2 The Joint Interagency Coordination Group (JIACG-I)

To manage the human side of this alignment, the doctrine establishes a permanent JIACG-I co-chaired by the Deputy Secretaries of DHS, DOJ, and HHS.





Role: This group serves as the GATA PRIME Authority. They hold the ultimate decision power over the "Constraint Weights" ($\lambda$) used by the AI agents. They decide, for example, whether the system should prioritize "Speed of Removal" or "Completeness of Due Process" in the algorithmic weighting. This makes policy decisions explicit, transparent, and encoded directly into the system's logic, rather than leaving them to the discretion of individual field offices.





9. Risks and Strategic Mitigation

The deployment of IMMA faces significant risks that must be proactively managed.

9.1 Risk: Algorithmic Hallucination

Risk: An AI agent might "hallucinate" a court date, a legal status, or a biographical detail, leading to wrongful deportation or unlawful detention.

Mitigation: The Drift Minimization Equation ($D=|x-C(x)|$) is the primary defense. The system is mathematically prohibited from outputting a state that does not strictly align with the ground truth in the Proof Vault. Furthermore, the Anti-Hallucination Operator (Damping) ensures that low-confidence outputs are suppressed in favor of human review.2

9.2 Risk: Institutional Inertia and Resistance

Risk: Bureaucratic resistance from component agencies (CBP, ICE, USCIS) to ceding control of their data to a central architecture.

Mitigation: The "Sovereign Node" model allows agencies to retain ownership of their data while contributing to the shared fabric. Rabbit agents act as "sidecars" to existing legacy systems, enhancing them rather than replacing them immediately. This allows for a phased adoption that minimizes disruption and respects agency autonomy while enforcing interoperability.

9.3 Risk: Adversarial Attack on Biometrics

Risk: State actors targeting the HART biometric database to insert false records or obscure the identities of operatives.

Mitigation: The Post-Quantum Cryptography standards inherent in the CollectiveOS GEM Bus protect data in transit. The distributed nature of the Proof Vault means there is no single "honeypot" database to breach; an attacker would need to compromise the consensus of the entire multi-agent swarm to alter records, a significantly higher bar than breaching a single SQL database.2

9.4 Risk: Legal Challenge (Administrative Procedure Act)

Risk: Automated decisions being challenged in court as "arbitrary and capricious" under the APA.

Mitigation: The Proof Vault provides perfect explainability. Every automated action has a cryptographic lineage linking it back to the specific statute, regulation, or policy constraint that authorized it. This "Explainable AI" (XAI) capability is critical for defending the system in federal court, proving that the decision was not arbitrary but the result of a rigorous, lawful process.



10. Conclusion: The Path to Stability

The Immigration Stability Doctrine offers the only viable pathway out of the current crisis. We can no longer attempt to manage a 21st-century migration reality with 20th-century bureaucracy. The entropy is too high; the variables are too complex; the human cost is too great.

By adopting the IMMA architecture, the United States Government does not just "upgrade its IT"; it adopts a new philosophy of governance. It moves from a system governed by fallible human memory, fragmented paper trails, and reactive politics to a system governed by immutable constraints, mathematical stability, and sovereign code.





For National Security: It closes the biometric and data gaps that terrorists and criminals exploit, ensuring Identity Dominance.




For the Judiciary: It dissolves the backlog through automated harmonization, restoring the efficiency and dignity of the immigration courts.




For Humanitarian Values: It ensures that no child is lost in the machine, protecting the vulnerable with the precision of code and the oversight of conscience.



This is the definition of Constraint-Aligned Intelligence: a system that is safe, sovereign, and stable by design.

Recommendation: It is recommended that the Executive Office of the President issue a National Security Memorandum directing the immediate pilot of IMMA within the Southwest Border corridor, designating the CollectiveOS GATA PRIME framework as the federal standard for immigration AI governance, and mandating the appointment of CAIOs in all relevant agencies to oversee this transition.

End of Report

Works cited





Immigration Courts: Actions Needed to Track and Report Noncitizens' Hearing Appearances, accessed December 5, 2025, https://www.gao.gov/products/gao-25-106867




🔻 THE COLLECTIVE — GOD FILE v∞ (INTERNAL EDITION) (2).pdf




Southwest Border: DHS and DOJ Have Implemented Expedited Credible Fear Screening Pilot Programs, but Should Ensure Timely Data Entry | U.S. GAO, accessed December 5, 2025, https://www.gao.gov/products/gao-21-144




Removing Barriers to American Leadership in Artificial Intelligence - The White House, accessed December 5, 2025, https://www.whitehouse.gov/presidential-actions/2025/01/removing-barriers-to-american-leadership-in-artificial-intelligence/




accessed December 5, 2025, https://www.congress.gov/crs-product/R47843#:~:text=14110%20builds%20on%20prior%20work,Management%20Framework%20(AI%20RMF).




Fair Information Practice Principles (FIPPs) | FPC.gov, accessed December 5, 2025, https://www.fpc.gov/resources/fipps/




ICE Cannot Effectively Monitor the Location and Status of All Unaccompanied Alien Children After Federal Custody - DHS OIG, accessed December 5, 2025, https://www.oig.dhs.gov/sites/default/files/assets/2025-03/OIG-25-21-Mar25.pdf




U.S. Immigration Courts and the Pending Cases Backlog - Transactional Records Access Clearinghouse (TRAC), accessed December 5, 2025, https://tracreports.org/tracker/dynadata/2022_04/R47077.pdf




GAO-12-809, INFORMATION SHARING: DHS Has Demonstrated Leadership and Progress, but Additional Actions Could Help Sustain and Str - Government Accountability Office, accessed December 5, 2025, https://www.gao.gov/assets/gao-12-809.pdf




Privacy Impact Assessment - Homeland Security, accessed December 5, 2025, https://www.dhs.gov/sites/default/files/2024-11/24_1112_privacy-pia-cbp012-e3d-november-2024.pdf




Southwest Border: Actions Needed to Address Fragmentation in DHS's Processes for Apprehended Family Members, accessed December 5, 2025, https://tracreports.org/tracker/dynadata/2020_05/704710.pdf




Challenges Compiling Data - American Immigration Council, accessed December 5, 2025, https://www.americanimmigrationcouncil.org/report-page/family-separation-challenges-compiling-data/




U.S. Immigration Courts See a Significant and Growing Backlog | U.S. GAO, accessed December 5, 2025, https://www.gao.gov/blog/u.s.-immigration-courts-see-significant-and-growing-backlog




GAO-25-106867, IMMIGRATION COURTS: Actions Needed to Track and Report Noncitizens' Hearing Appearances, accessed December 5, 2025, https://tracreports.org/tracker/dynadata/2025_01/gao-25-106867.pdf




Immigration Courts: Actions Needed to Reduce Case Backlog and Address Long-Standing Management and Operational Challenges - GAO, accessed December 5, 2025, https://www.gao.gov/products/gao-17-438




REPRESENTING CLIENTS AT THE MASTER CALENDAR HEARING - Immigrant Legal Resource Center, accessed December 5, 2025, https://www.ilrc.org/sites/default/files/resources/rep_clnts_mstr_cal_hearing-20181220.pdf




Homeland Advanced Recognition Technology (HART): DHS is Building a Massive Database of Personal Information - National Immigration Law Center, accessed December 5, 2025, https://www.nilc.org/wp-content/uploads/2021/12/HART-factsheet-2021-11-10.pdf




How DHS's massive biometrics database will supercharge surveillance and threaten rights - Immigrant Defense Project, accessed December 5, 2025, https://www.immigrantdefenseproject.org/wp-content/uploads/HART-Attack.pdf




Privacy Impact Assessment Homeland Advanced Recognition Technology System (HART), accessed December 5, 2025, https://www.dhs.gov/sites/default/files/2024-08/24_0826_priv_pia-obim-004a-HART-update.pdf




OIG-21-29 - DHS' Fragmented Approach to Immigration Enforcement and Poor Planning Resulted in Extended Migrant Detention dur, accessed December 5, 2025, https://www.oig.dhs.gov/sites/default/files/assets/2021-03/OIG-21-29-Mar21.pdf




Attorney General Bonta Sues Trump Administration for Illegally Sharing Californians' Personal Health Data with ICE | State of California - Department of Justice, accessed December 5, 2025, https://oag.ca.gov/news/press-releases/attorney-general-bonta-sues-trump-administration-illegally-sharing-californians%E2%80%99




Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, accessed December 5, 2025, https://www.federalregister.gov/documents/2023/11/01/2023-24283/safe-secure-and-trustworthy-development-and-use-of-artificial-intelligence




COUNTERTERRORISM Action Needed to Further Develop the Information Sharing Environment | GAO, accessed December 5, 2025, https://www.gao.gov/assets/830/827084.pdf




AI RMF Core - AIRC - NIST AI Resource Center, accessed December 5, 2025, https://airc.nist.gov/airmf-resources/airmf/5-sec-core/




March 28, 2024 M-24-10 MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES FROM: Shalanda D. Young SUBJECT: Advancing - The White House, accessed December 5, 2025, https://www.whitehouse.gov/wp-content/uploads/2024/03/M-24-10-Advancing-Governance-Innovation-and-Risk-Management-for-Agency-Use-of-Artificial-Intelligence.pdf




Implications of the AI executive order for business - IAPP, accessed December 5, 2025, https://iapp.org/resources/article/implications-of-the-ai-executive-order-for-business/




The Fair Information Practice Principles at Work - Homeland Security, accessed December 5, 2025, https://www.dhs.gov/sites/default/files/2024-01/Governing%20Privacy%20Policy%20-%20FIPPs%20Factsheet.pdf




New Federal Agency Policies and Protocols for Artificial Intelligence Utilization and Procurement Can Provide Useful Guidance for Private Entities - Workforce Bulletin, accessed December 5, 2025, https://www.workforcebulletin.com/new-federal-agency-policies-and-protocols-for-artificial-intelligence-utilization-and-procurement-can-provide-useful-guidance-for-private-entities




Roundtable 4: Improving Docket Efficiency through Better Communication and Coordination: Roles of USCIS, ICE, and EOIR | Homeland Security, accessed December 5, 2025, https://www.dhs.gov/archive/roundtable-4-improving-docket-efficiency-through-better-communication-and-coordination-roles-uscis




Fair Information Practice Principles (FIPPS) Factsheet, accessed December 5, 2025, https://department.va.gov/privacy/wp-content/uploads/sites/5/2023/01/VA-Privacy-Factsheet-FIPPS-v2.pdf