American Samoa: Performing a Risk Assessment Would Better Inform U.S. Agencies of the Risks Related to Acceptance of Certificates of Identity
Published: 2010-06-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: American Samoa is a U.S. insular area that operates its customs and immigration programs according to its own laws and independent of the United States. As such, U.S. agencies, such as U.S. Customs and Border Protection, have no roles in operating the customs or immigration programs in American Samoa. U.S. officials have raised questions about how American Samoa operates its customs and immigration programs, and if this introduces any risks to the security of American Samoa or the rest of the United States. GAO was asked to review American Samoa's customs and immigration programs and this report discusses (1) the operations of American Samoa's customs and immigration programs, and (2) the extent to which U.S. and American Samoa agencies have identified potential risks in American Samoa's customs and immigration programs. GAO reviewed available statutes, regulations, policies, and procedures governing American Samoa and U.S. customs and immigration programs. GAO also visited American Samoa and interviewed U.S. and American Samoan officials to obtain insights.
section_title: What GAO Found
paragraphs: American Samoa operates its own customs and immigration programs, which have separate organizational structures and functions and are based on local laws, regulations, policies, and procedures. Its Customs Division, within the American Samoa Department of Treasury, inspects passengers, baggage, and cargo, and collects excise taxes. The immigration program is administered by the Immigration Office and the Immigration Board, which both report to the American Samoa Attorney General. The Immigration Office is responsible for document issuance, operations, and enforcement, while the Immigration Board holds hearings to decide on issues such as alien work authorization. The Office of the Attorney General is responsible for, among other things, issuing Certificates of Identity (CI), which American Samoans may use to demonstrate their nationality when traveling to the rest of the United States. American Samoa and U.S. government agencies report that American Samoa's operations of its customs and immigration programs may pose risks to American Samoa and the rest of the United States, but U.S. agencies have not conducted a risk assessment. Regarding customs, potential risks to American Samoa are lost revenues and the possible aiding of criminal activities. While the Customs Division has written policies and procedures to govern duties and responsibilities, American Samoa and U.S. law enforcement officials are concerned that American Samoa Customs officials have accepted bribes for improperly inspecting containers, which could result in lost tax revenues. American Samoan and U.S. officials have identified no concerns to the rest of the United States from American Samoa's operations of its customs program. Regarding immigration, the principal concern to American Samoa is that current enforcement practices of immigration laws have led to the potential for alien exploitation and human trafficking. The American Samoa legislature is proposing changes that may address these issues, but it is too soon to tell what impact these changes, if passed, will have. U.S. officials state that the potential risk to the rest of the United States from American Samoa's current immigration operations is illegal immigration into the rest of the United States as a result of travelers obtaining false documentation, such as a CI, in American Samoa. While Department of State officials are aware of allegations of illegal immigration from aliens fraudulently obtaining CIs, and are working with law enforcement officials in American Samoa on an ongoing investigation into such allegations, this investigation will address the security of the process for obtaining U.S. passports and will not address the reported vulnerabilities in the process for issuing CIs. U.S. agencies have not performeda risk assessment to determine the threat, vulnerabilities, and consequences associated with aliens using false documents to travel to the rest of the United States from American Samoa. Performing a risk assessment could better position U.S. agencies to understand the extent of threats, vulnerabilities, and consequences associated with the use of CIs, and better inform decisions on which documents would be considered acceptable for those wishing to travel to the rest of the United States from American Samoa.

section_title: Letter
paragraphs: American Samoa, a U.S. insular area, operates both its customs and  immigration programs independent of the United States government. As  such, the American Samoa government regulates such activities as the  importation of cargo and the entry of aliens to American Samoa according  to its local customs and immigration laws, which are different than United  States’ customs and immigration laws. Because American Samoa is the  only insular area that operates both its own customs and immigration  programs, this has raised questions about whether this arrangement  introduces any risks to the security of American Samoa or the rest of the  United States. As a result, you requested that we review aspects of  American Samoa’s customs and immigration programs. In particular, this  report discusses American Samoa’s operations of its customs and  immigration programs; and the extent to which federal and American  Samoa agencies have identified potential risks, if any, to American Samoa  or the rest of the United States as a result of the operations of American  Samoa’s customs and immigration programs.
In order to understand the operations of American Samoa’s customs and  immigration programs, we reviewed available U.S. and American Samoa  immigration and customs statutes; regulations, policies, and procedures  for American Samoa’s customs program; and training and passenger  screening guidelines for U.S. customs and immigration programs. To  supplement the document reviews and analyses, we visited American  Samoa and interviewed American Samoa government officials in the  executive, legislative, and judicial branches of government—including  leaders and staff directly involved with administering and enforcing  American Samoa’s customs and immigration programs—in order to  enhance our understanding of American Samoa’s customs and  immigration operations and procedures. We also observed the  performance of certain functions within American Samoa’s Office of the  Attorney General and the Immigration Office, which included observing  the processes for applying for and issuing Certificates of Identity (CI) and  American Samoa alien identification (ID) cards; as well as operations at  the Customs Division of the American Samoa Department of Treasury,  which included a cargo container inspection at the seaport. These  observations provided us with first-hand accounts of procedures, as well  as a better understanding of the logistics involved within these specific  functions. Additionally, we received data from the American Samoa  Department of Legal Affairs for calendar years 2007 through 2009 on  various indicators, including the number and types of documents used by  airline passengers traveling from American Samoa to Hawaii, the number  of registered aliens in American Samoa, and the number of alien  overstayers and expired alien ID cards. To determine the sufficiency of the  data, we asked the Department of Legal Affairs a series of questions  related to database usage, controls, and safeguards and determined that  the data were sufficiently reliable for our reporting purposes.
To understand the potential risks, if any, to American Samoa and the rest  of the United States as a result of the operation of American Samoa’s  customs and immigration programs, we reviewed available U.S. and  American Samoa risk or threat assessments, and interviewed American  Samoa law enforcement and government officials, and compared these  findings to the Standards for Internal Control in the Federal  Government. Additionally, we interviewed officials within U.S. agencies  who may have knowledge or interaction with American Samoa’s customs  or immigration programs, such as certain Department of Homeland  Security (DHS) components, including U.S. Customs and Border  Protection (CBP), Immigration and Customs Enforcement, the  Transportation Security Administration, U.S. Citizenship and Immigration  Services (USCIS), and the U.S. Coast Guard in both Washington, D.C., and  Honolulu, Hawaii, as Hawaii is the first port of entry for flights arriving  from American Samoa. We also met with officials from the Department of  the Interior’s (DOI) Office of Insular Affairs in Washington, D.C., and in  American Samoa; and with officials from the Federal Bureau of  Investigation (FBI) in Honolulu, Hawaii, and in American Samoa who have  the potential for interaction with the government of American Samoa on a  regular basis. We also met with officials from the Department of State’s  Bureau of Consular Affairs, Bureau of Diplomatic Security, and Honolulu  Passport Office to further understand any potential risks. Additionally, in  evaluating the potential risks to American Samoa and the rest of the  United States as a result of the operation of American Samoa’s customs  and immigration programs, we used the Internal Control Standards for risk  assessments and DHS’s risk management framework.
We conducted this performance audit from June 2009 to June 2010 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 findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: American Samoa, the only inhabited U.S. insular area in the southern  hemisphere, is located about 2,600 miles southwest of Hawaii (see fig. 1).  American Samoa consists of five volcanic islands and two coral atolls,  covering a land area of 76 square miles—slightly larger than Washington,  D.C. The capital of American Samoa, Pago Pago, is located on the main  island of Tutuila, which is mostly rugged terrain with relatively little level  land. Most of American Samoa’s economic activity—primarily tuna  canning and government operations—takes place on Tutuila in the Pago  Pago Bay area. In late September 2009, one of American Samoa’s two tuna  canneries closed operations and American Samoa also experienced an  earthquake and tsunami, which caused considerable damage.
American Samoa According to the latest data available, American Samoa had a population  of about 63,780 in 2005. At that time, the foreign-born population (non- U.S. citizens or nationals), mostly from the independent state of Samoa,  comprised approximately one-third of American Samoa’s total population  (see fig. 2). The American Samoa Department of Commerce estimated  that in 2008, 45 percent to 55 percent of the total population was foreign  born. Unlike residents born in Guam, the Commonwealth of the Northern  Mariana Islands, or the U.S. Virgin Islands, residents born and raised in  American Samoa are U.S. nationals and not U.S. citizens, though they may  become naturalized U.S. citizens. Like residents of these other insular  areas, though, residents of American Samoa have many of the rights of  citizens of the 50 states, but cannot vote in U.S. presidential elections and  do not have voting representation in the final approval of legislation by the  full Congress. Residents of American Samoa vote for a congressional  delegate who has all congressional privileges, including a vote in  committee, except a vote in the House of Representatives.
American Samoa does not have an organic act that establishes the  relationship between American Samoa and the United States; however,  two deeds of cession were initially completed between Samoan chiefs, or  matai, and the United States in 1900 and 1904 and ratified by the federal  government in 1929. In these deeds, the United States pledged to promote  peace and welfare, to establish a good and sound government, and to  preserve the rights and property of the people. The U.S. Navy was initially  responsible for federal governance of American Samoa. Then, in 1951,  federal governance was transferred to the Secretary of the Interior, which  continues today. The Secretary of the Interior exercises broad powers  with regard to American Samoa, including “all civil, judicial, and military  powers” of government in American Samoa. American Samoa has had its  own constitution since 1960, and since 1983, the local American Samoa  constitution may only be amended by an act of Congress. The American  Samoa constitution provides for three separate branches of government— the executive, the legislative, and the judicial. Nearly 40 American Samoa  departments, offices, and other entities within the executive branch of the  American Samoa government provide public safety, public works,  education, health, commerce, and other services. The legislature, or Fono,  is comprised of 18 senators and 20 representatives. The American Samoa  judiciary consists of a High Court and a District Court under the  administration and supervision of the Chief Justice.
subsections: section_title: U.S. Customs and Immigration Laws Generally Do Not Apply in American Samoa
paragraphs: In general, U.S. customs and immigration laws do not govern the customs  and immigration programs in American Samoa. With respect to customs  law, federal regulations define the customs territory of the United States to  include the 50 states, the District of Columbia, and Puerto Rico. As a  result, U.S. customs requirements applicable to the U.S. customs territory  do not apply in U.S. insular areas, including American Samoa. For  example, in general, goods imported into American Samoa are not  inspected by federal customs officials and are not subject to federal tariffs.
Although American Samoa is not considered part of the customs territory  of the United States, it is not treated as a foreign country either. Rather, as  a U.S. insular area, it is accorded special status with respect to goods  exported from American Samoa into the customs territory of the United  States. The Harmonized Tariff Schedule provides exemptions to the  general rates of duties for certain goods imported into the rest of the  United States from American Samoa. For example, goods grown in  American Samoa or produced or manufactured in American Samoa from  materials grown in American Samoa may be imported into the rest of the  United States duty-free, so long as the goods do not contain foreign  materials worth more than 70 percent of the goods’ total value.
With respect to federal immigration law, the Immigration and Nationality  Act defines the United States to include the continental United States,  Alaska, Hawaii, Puerto Rico, the U.S. Virgin Islands, Guam, and the  Commonwealth of the Northern Mariana Islands. As a result, U.S.  immigration requirements for entering and working in the United States  generally do not apply in American Samoa, and the American Samoa  government, rather than the U.S. government, governs the admission of  aliens to American Samoa.
section_title: Because U.S. Customs and Immigration Laws Generally Do Not Apply in American Samoa, There Is Little, If Any, Interaction between American Samoa and U.S. Customs and Immigration Agencies
paragraphs: Because U.S. customs and immigration laws generally do not apply in  American Samoa, and because of the resulting separate authorities for  American Samoa and U.S. customs and immigration programs, American  Samoa customs and immigration agencies and officials have little, if any,  interaction with the customs or immigration programs and officials in the  United States. Multiple U.S. agencies have responsibilities over customs  and immigration functions in the United States and at the ports of entry— including CBP, USCIS, and the Department of State’s Bureau of  Consular Affairs—but none of these entities have a presence or staff in  American Samoa. There are, however, several U.S. agencies that interact  with the government of American Samoa and have staff based in American  Samoa. For example, the FBI has a resident office in American Samoa  which, since being established in December 2005, has addressed a growing  number of crimes in American Samoa, including public corruption of high- ranking government officials, fraud against the government, civil rights  violations, and human trafficking. Additionally, DOI has staff in American  Samoa that help issue and monitor federal grants provided to the  government of American Samoa. For example, in fiscal year 2008, the  American Samoa government expended approximately $114.4 million in  grants from several U.S. agencies, over $15.5 million of which was  provided by DOI, but based on our review of budget documents, none of  those funds were used to support American Samoa’s customs or  immigration programs.
Individuals born in American Samoa are U.S. nationals but not citizens,  unless they become naturalized U.S. citizens. Travel between American  Samoa and the rest of the United States is considered travel between two  U.S. border locations under Department of State regulations and, as a  result, passports are not required for U.S. citizens or noncitizen nationals.  U.S. nationals may travel to the rest of the United States with a  government-issued photo ID and documentation establishing U.S.  nationality. Although travel from American Samoa to the rest of the United  States is considered domestic for purposes of passport requirements,  because Honolulu, Hawaii, is the travelers’ first encounter with U.S.  customs and immigration officials, all passengers from American Samoa  are screened by CBP officers upon arrival at the Honolulu International  Airport to establish their identity and nationality and, if they are not U.S.  citizens or nationals, their admissibility to the United States. A U.S.  citizen or national may satisfy CBP of his or her identity and nationality by  showing a U.S.-issued passport or military ID card, a birth certificate in  combination with a photo ID, or an American Samoa-issued CI.
While they do not have any staff based in American Samoa, staff from the  Department of State’s Bureau of Consular Affairs and USCIS interact with  American Samoa residents applying for U.S. passports or naturalization,  respectively. U.S. nationals who live in American Samoa may apply for  U.S. passports through a Department of State-approved passport  acceptance agent at the U.S. Post Office in American Samoa. Noncitizen  nationals are subject to the same application requirements as U.S. citizens  and must show proof of their status as U.S. nationals. The passport  applications and supporting materials are sent to the Department of State’s  Honolulu Passport Office for processing and adjudication. If there is  suspicion of fraudulent documentation within an application package (e.g.,  a suspicious birth certificate) the Honolulu Passport Office determines the  validity of submitted documents and requires applicants to submit  additional documents until staff are satisfied as to the documents’  authenticity. According to the Department of State, in 2008, over 3,300 U.S.  passports were issued to individuals who listed American Samoa as their  place of birth.
USCIS reported that it received between 100 and 300 applications for  naturalization from noncitizen nationals from American Samoa—who may  reside elsewhere in the United States—each fiscal year from 2002 through  2009. Noncitizen nationals may naturalize if they reside in any U.S. state  for 3 months, pass an English and civics test, and take an oath of  allegiance.  They must also pay the $675 fee for naturalization.
section_title: American Samoa Operates Its Own Customs and Immigration Programs
paragraphs: American Samoa operates its own customs and immigration programs,  which have separate organizational structures and functions and are based  on American Samoa laws, regulations, policies, and procedures. American  Samoa’s Customs Division, within the Department of Treasury, inspects  passengers, baggage, and cargo, and collects excise taxes. American  Samoa’s immigration program is managed by the Immigration Office and  the Immigration Board, both of which report to the Attorney General of  American Samoa. The Immigration Office is responsible for alien ID  issuance, daily immigration operations, and enforcement; while the  Immigration Board holds weekly hearings and makes decisions on issues,  such as aliens’ work authorizations and transfers of aliens’ sponsorships.  In addition to these functions that pertain to processing applications from  aliens who want to live or work in American Samoa, the Office of the  Attorney General also has responsibility for issuing CIs for U.S. nationals,  which includes U.S. citizens and noncitizen nationals, wishing to travel to  the rest of the United States.
subsections: section_title: American Samoa’s Customs Division Inspects Passengers and Cargo and Collects Excise Taxes
paragraphs: Under the authority of the American Samoa Department of Treasury, the  overall function of the Customs Division is to administer and enforce all  excise tax laws, and to intercept illicit imports of narcotics, weapons,  ammunition and other contraband at the ports of entry. It is authorized to  develop policies and procedures necessary for the proper functioning of  the Customs Division. American Samoa customs law provides that all  persons entering or leaving American Samoa may be searched by a  customs officer and all merchandise or baggage imported or brought into  American Samoa is to be inspected by a customs officer. Additionally, all  passengers and crew members, regardless of citizenship, must make a  customs entry and declaration upon arrival in American Samoa and all  items acquired abroad must be declared in writing. Any vessel arriving in  American Samoa is required to provide certain documents, such as  manifests, and is subject to being boarded and examined by American  Samoan customs officials. All imports that arrive in American Samoa are  to be taken into custody and released by the Customs Division after being  inspected. According to port administration officials, approximately 1,000  vessels come through the Pago Pago seaport annually and about 50 cargo  containers, on average, arrive at the seaport each day and have to be  inspected prior to release by the Customs Division. American Samoa  customs law states that cargo containers may be inspected on location at  the official point of entry or removed to other locations, such as the  respective places of business, for inspection. As such, cargo containers  may not be opened by importers until officially inspected and released by  the Customs Division in writing. Importers are required to pay certain  excise taxes on goods and no imports are to be released until all fees and  excise taxes have been paid in full. An excise tax of 5 percent is imposed  on items imported for commercial use or resale in American Samoa and  certain items, such as alcohol, tobacco, and motor vehicles, are taxed at  higher rates prescribed by law. All monies due pursuant to excise tax  laws are collected by the Customs Division and are to be deposited with  the Treasurer of American Samoa.
The Customs Division’s fiscal year 2009 budget was $1.2 million and it has  55 employees who work within its six branches, as shown in figure 3. The  Customs Division’s collection of excise taxes generated over $18.5 million  in revenue for the government of American Samoa in fiscal year 2009—    22 percent of the government’s total general fund revenues for that year.  Typically, excise tax revenues are to be deposited into the general fund  and available for appropriation by the American Samoa legislature, or  Fono.
The Customs Division maintains standard operating procedures that  provide written policies and procedures that define duties,  responsibilities, and privileges for Customs Division staff and also detail  consequences for violating the laws of American Samoa and the written  policies and procedures. Additionally, the Customs Division developed a  Code of Conduct that articulates the standards of behavior and conduct  required of employees in an effort to ensure that the integrity of the  Customs Division is maintained. According to the Chief Customs Officer,  all Customs officers rotate functions every 3 to 6 months to help prevent  complacency and corruption. He added that Customs supervisors are also  required to perform random inspections to ensure Customs officers are  sufficiently inspecting the imported cargo containers.
According to the Chief Customs Officer, because the Customs Division  does not have an automated computer system for tracking cargo container  arrivals and inspections, all Customs Division functions are tracked  manually. He stated that it would be extremely beneficial to be able to  automate the system that tracks the offloading and inspections of cargo  containers and the collection of excise taxes. He added that he is in the  process of determining the most suitable automated system for the  American Samoa Customs Division and once he finds a system that suits  their needs, he intends to submit an application for a technical assistance  grant from DOI.
section_title: American Samoa’s Immigration Office and Immigration Board Administer the Immigration Program and the Attorney General Approves the Issuance of Certificates of Identity
paragraphs: American Samoa’s immigration program is responsible for, among other  things, managing aliens arriving in American Samoa. Aliens may enter  American Samoa for up to 30 days on visitor or business entry permits  and certain aliens may apply to reside in American Samoa for more than  30 days based on family relationships with American Samoans (or  permanent residents in American Samoa) or for employment reasons.  Immigration law in American Samoa provides for 12 separate  classifications of aliens to remain in American Samoa for more than 30  days; however, some of the categories are subject to numerical limits.  Any aliens entering and remaining in American Samoa must have  sponsors. In general, American Samoa’s immigration program has many  of the same elements as the U.S. immigration program, such as numerical  limits on the number of aliens that may enter, or preferences for specific  categories of aliens; however, American Samoa’s immigration program  also has some unique aspects, such as special allowances for aliens from  the Independent State of Samoa. Additional information on American  Samoa’s immigration program, including alien categories and numerical  limitations, is provided in appendix I.
American Samoa’s immigration program is administered by the  Immigration Office and the Immigration Board, both of which are housed  within the Department of Legal Affairs and are under the authority and  guidance of the Attorney General of American Samoa, as shown in figure  4. The Immigration Office, and the sections that report to it, are  responsible for the daily operations of immigration functions, including  issuing immigration ID cards, as well as tracking and enforcing quotas on  aliens. The Immigration Board has responsibility, among other things, for  approving applications for alien work permits and for authorizing aliens to  remain in American Samoa and register as lawfully present. The Office of  the Attorney General, also within the Department of Legal Affairs, is  responsible for issuing CIs for U.S. nationals who wish to travel to the rest  of the United States, among other things.
The American Samoa Immigration Office, in concert with the Immigration  Board, administers the processes by which aliens may enter American  Samoa. The Immigration Office is headed by the Chief Immigration Officer  with a staff of 40 employees. In fiscal year 2009, the Immigration Office  had a budget of $805,000 and generated $1.78 million in total revenue from  the various application and entry fees it collected. According to  Immigration Office officials, their functions include inspecting documents  for all persons entering American Samoa, receiving applications for entry  permits and petitions for aliens to remain in American Samoa, and  enforcing immigration laws. Further details on the various functions of  the Immigration Office are contained in the sections that follow.
All persons entering or leaving American Samoa may be searched by one  or more immigration officers and asked to provide documentation, such as  a valid passport or travel document. Immigration officers have authority,  under certain circumstances, to interrogate, search, and arrest certain  arriving passengers. According to the American Samoa Department of  Commerce, in calendar year 2008, 72,999 individuals traveled to American  Samoa, of which 6,995 arrived for employment reasons.
According to Immigration Office officials, every alien with a classification  that allows the alien to remain in American Samoa for longer than 30 days  is registered and has an alien ID card that is valid for 1 or 3 years,  depending on the alien’s classification. Immigration officials explained  that safeguards are in place regarding alien ID cards. For example, each  alien ID card has a hologram image that is designed to make the card more  difficult to counterfeit.
Since 2003, the Immigration Office has used a computer system to  maintain the records of lawfully present aliens and permanent residents.  This computerized system is able to track the registration of aliens and the  issuance of most entry permits. American Samoan government officials  added that the Immigration Office has a separate computer system, funded  by a 2003 grant from DOI’s Office of Insular Affairs, which maintains data  on passengers who arrive and depart American Samoa via the airport or  seaport through scanning or entering data from the passengers’ travel  documents into the system. The officials noted, though, that the two  separate computerized systems—one for tracking alien registrations and  one for tracking arrivals and departures—do not have any links between  them, so that the data from the immigration system that tracks the  registration of aliens and issuance of entry permits are not automatically  updated or matched with data on arriving and departing passengers. The  officials indicated they could benefit from additional upgrades to the  systems to allow them to be linked and added that they are in the early  process of developing a proposal for obtaining funding from DOI for  upgrading the computer systems.
Investigating Violations of Immigration Law  The Immigration Office staffs an Investigation Section that is responsible  for investigating and charging aliens who are in violation of American  Samoa immigration laws. Court officials we met with in American Samoa  stated that in an effort to assist with enforcement, the American Samoa  District Court requires an immigration officer to be present during  criminal proceedings to verify the immigration status of defendants.  According to court officials we met with, approximately 60 percent of the  defendants who have appeared in District Court in recent months for a  variety of criminal offenses are aliens.
subsections: section_title: Immigration Board Duties and Responsibilities
paragraphs: The American Samoa Immigration Board hears cases and determines, for  example, if aliens are authorized to remain in American Samoa and  register as lawfully present aliens. The board, consisting of five members  who are appointed by the Governor with consent and approval of the  legislature, is overseen by the Attorney General. A board member can be  appointed no more than twice, and the appointment term is 5 years. The  Immigration Board holds hearings once a week and hears cases, such as  requests for work authorizations and transfers of sponsorship.  Immigration Board members refer cases to the Attorney General for  review of its decisions if the Attorney General directs the board to do so or  if the chair or the majority of the board believes the case should be  referred. In addition to reviews of board decisions by the Attorney  General, the High Court of American Samoa has appellate jurisdiction over  decisions of the Immigration Board.
section_title: Office of the Attorney General’s Process for Issuing Certificates of Identity
paragraphs: The Office of the Attorney General is responsible for issuing CIs for U.S.  nationals who wish to travel to the rest of the United States, among other  things. Officials from the Office of the Attorney General told us that,  historically, the CI was intended to be used in the event of an emergency,  such as medical treatment needed that could only be obtained off-island,  or the unexpected death of a family member in the United States, and the  traveler could not obtain a passport in time to travel. However, because  the CI is easier and faster to obtain by people in American Samoa, it has  become more convenient to use CIs for travel than obtaining a U.S.  passport. An authorizing official within the Office of the Attorney General  stated that they encourage people to apply for a U.S. passport because,  while it costs more up front, it is valid for 10 years compared to the CIs,  which are valid for 6 months. The official noted, though, that the CIs have  been a source of revenue to the government that would be lost if the CIs  were entirely replaced by passports. For example, the Office of the  Attorney General provided us data that showed that for fiscal year 2009,  CIs generated over $350,000 for the government of American Samoa from  fees associated with issuing over 7,100 CIs.
According to officials from the Office of the Attorney General, in order to  apply for a CI, a U.S. national must fill out the application and provide  documentation of U.S. nationality, such as his or her birth certificate as  issued from the American Samoa Vital Statistics Office; a form of  government-issued photo ID, such as a voter ID, driver’s license, military  card, or expired passport; and submit a passport-sized photo and the $50  processing fee. Additionally, if an individual is under the age of 18, the  parents or legal guardians are required to provide their own ID, and an ID  for the child, such as a school ID with a photo. If individuals change their  names due to a marriage or divorce, official documentation is required.
As shown in figure 5, once all application materials are complete, officials  within the Office of the Attorney General explained that they instruct each  applicant to pay the $50 fee to the cashier in the Immigration Office. The  applicant is provided a receipt that shows proof the $50 fee was paid and  the receipt includes the CI application number so the payment can be tied  to the correct CI application. The applicant then brings the receipt, the  completed CI application, and supporting materials to the CI Office  outside the Office of the Attorney General to be processed by the staff.  According to the Deputy Attorney General, applications for CIs are  generally processed and issued in 1 to 2 business days. In comparison, it  takes about 4 to 6 weeks for the Department of State to process and issue  a U.S. passport. According to staff of the Office of the Attorney General,  there is no computerized system to track CI applications or issuance and  all records maintained are paper-based and manually filed. certificte, photo ID, nd passport-ized complete?
Prepre CI pcket for pprovl. Typemp with officil.
The letter-sized CI document features an attached photo of the individual,  two circular “Attorney General, Govt. of American Samoa” stamps, as well  as a unique CI identification number featured in the upper left-hand  corner, as depicted in figure 6. There are three individuals within the  Office of the Attorney General with authorization to stamp CIs. Both the  stamped seals and the ID numbers on the CI are in red ink. The CIs are  signed—generally by the Attorney General or Deputy Attorney General— for approval prior to being provided to the applicants.
section_title: U.S. and American Samoan Officials Report Concerns about American Samoa’s Operations of Its Customs and Immigration Programs, but No U.S. Agency Has Performed a Risk Assessment
paragraphs: U.S. and American Samoa agencies report that American Samoa’s  operations of its customs and immigration programs may pose risks to  American Samoa and the rest of the United States, but no U.S. agency has  performed a risk assessment. According to U.S. and American Samoan  government officials we met with, potential risks from the customs  program’s operations primarily affect American Samoa, whereas potential  risks related to the immigration program’s operations affect both  American Samoa and the rest of the United States. According to these  officials, potential risks to the government of American Samoa from its  customs operations include lost revenues and the possible aiding of  criminal activities based on allegations of inadequate enforcement.  Regarding American Samoa’s immigration program, U.S. and American  Samoan government officials stated their principal concerns are that  current enforcement practices may lead to (1) exploitation of aliens by  sponsors, (2) incidents of human trafficking, (3) overstays by aliens, and  (4) exceeding numerical limits of aliens. In contrast, the potential risks  identified by U.S. officials for the rest of the United States are more  limited. In particular, U.S. officials identified little to no potential risks to  the rest of the United States based on American Samoa’s customs  operations. According to U.S. officials we met with, the potential risk to  the rest of the United States from American Samoa’s immigration  operations is illegal immigration into the rest of the United States as a  result of travelers fraudulently obtaining documentation, such as a CI, in  American Samoa. However, U.S. officials we met with, including CBP,  acknowledged that they do not know the magnitude of fraudulently issued  CIs or the potential threat and consequences to the United States as a  result of fraudulently issued CIs because no assessment has been  performed of the risks posed by the continued use of the CIs as identity  and nationality documents for U.S. nationals.
subsections: section_title: Potential Risks to American Samoa Are Related to Inadequate Enforcement of Existing Customs and Immigration Laws
subsections: section_title: Inadequate Enforcement of Customs Laws Leads to the Potential for Aiding Criminal Activities and Lost Revenues
paragraphs: A threat assessment issued by the government of American Samoa in  December 2005 reported that inadequate enforcement of customs laws has  led to incidents related to insufficient container inspections; allegations of  Customs officers accepting bribes; and the smuggling of drugs, firearms,  and other illegal contraband. American Samoan law enforcement officials  we met with told us these same concerns still exist. The Customs  Division’s Code of Ethics and Conduct states that, “it is the duty of the  customs officer to enforce the laws of American Samoa and that a failure  to properly conduct inspections of merchandise is a violation of the  Standard Operating Procedures and Policies and will result in disciplinary  action.” According to the Chief Customs Officer, since June 2002, a total of  six officers have been removed from duty for violations associated with  corruption, misconduct, or drug or alcohol use. Another effect of  inadequate enforcement of customs laws is that there is the potential for  lost revenues for the government if proper excise taxes are not collected  on goods imported in each imported cargo container. While the Customs  Division has written policies and procedures, and also has certain internal  controls in place—such as rotating staffs’ responsibilities so that the same  customs officers do not always inspect containers at the same  businesses—there is no automated computer system within the Customs  Division to track cargo manifests, container inspections, verification of  deposits, parcel taxes at the post office, or interisland ferry excise taxes.  The Chief Customs Officer recognizes this is a weakness and told us that  an automated computer system would help the division track cargo  container inspections and undervalued or undeclared merchandise and  contraband, and that he is working to obtain a computerized system that  would be appropriate for American Samoa’s volume of container traffic.
section_title: Current Immigration Enforcement Practices Have Led to the Potential for Human Trafficking, Alien Overstays, and Exceeding Alien Quotas
paragraphs: According to federal officials from DOI and the FBI, as well as American  Samoan government officials we met with, current enforcement practices  of immigration laws have led to a variety of concerns, including the  exploitation of aliens by sponsors, incidents of human trafficking, alien  overstays, and exceeding numerical limits on aliens. Additionally,  American Samoa government’s 2005 threat assessment reported a lack of  management and oversight control by immigration officials with regard to  the enforcement of policies and procedures.
As of March 31, 2010, the Immigration Office reported 20,282 aliens in  American Samoa for employment reasons, which is about 58 percent of  the estimated 34,874 aliens in American Samoa. In general, aliens entering  and remaining in American Samoa, including those who enter for  employment reasons, must have a sponsor. According to FBI and  American Samoa government officials, there are instances in which  employment sponsors exploit aliens under the threat of revoking their  sponsorship and having them deported. As reported in the 2005 threat  assessment, a number of immigrants from Taiwan, China, and the  Philippines, were pursuing employment opportunities and allowed to enter  American Samoa under the sponsorship of owners of a variety of  businesses, and were forced into servitude or prostitution once they  arrived (i.e. human trafficking).
Among the most notable cases of human trafficking in American Samoa is  U.S. v. Lee, which was one of the largest human trafficking cases ever  prosecuted by the U.S. Department of Justice. This 2001 case involved  about 200 Chinese and Vietnamese victims who were recruited to work in  an American Samoa garment factory. In 2003, Lee was convicted in the  U.S. District Court of Hawaii of involuntary servitude, conspiring to violate  civil rights, extortion, and money laundering. The 2005 threat assessment  reported that the full dimension of the problem of human trafficking in  American Samoa is difficult to measure, but noted that intelligence  showed there continue to be victims of human trafficking in American  Samoa and that human trafficking is a major source of profit for organized  crime syndicates. According to the threat assessment, human trafficking is  a difficult issue for local law enforcement because there is no American  Samoa human trafficking law or avenue for prosecution locally. The  legislature in American Samoa is considering legislation to criminalize  human trafficking and categorize it as a felony in American Samoa law but,  to date, no such legislation has been enacted.
According to FBI and American Samoan government officials, there are  also instances in which numerical limits on aliens are not adequately  enforced and aliens overstay their visits. Immigration law in American  Samoa allows for 12 separate classifications of aliens to reside in  American Samoa for more than 30 days; however, some of the categories  are subject to numerical limits. The extent of this issue is unknown, as the  Immigration Office does not have documented policies and procedures  that define how the office is to enforce the numerical limits. If an alien  enters American Samoa on a 30-day entry permit and stays longer than the  30-day period, he or she is tracked in the Immigration Office database as  an overstayer, according to Immigration Office officials. According to data  from the Immigration Office, there were over 2,600 alien overstayers for  fiscal year 2009. Immigration Office officials explained that often the  overstayers expect to have their residency authorized within that 30-day  time frame, but they do not understand that it takes longer. Additionally,  7,572 aliens had expired ID cards as of March 2010, which means the  aliens’ ID cards had expired and had not been renewed. Immigration  officials told us they track these individuals, make contact with their  sponsors, and try to determine the reason they have not renewed their  cards.
The American Samoa legislature, in addition to its actions on human  trafficking legislation, is also considering draft legislation that will make  changes to existing immigration law. Some of the proposed changes  include creating a Department of Immigration as its own stand-alone  department, outside of the Department of Legal Affairs, and to make it  subject to annual audits by the territorial auditor. The draft legislation also  includes reductions to the numerical limits on aliens. Further, the  standards for sponsoring an alien for employment reasons would change  to require additional proof of the need for the alien workers and a written  contract defining the agreement between sponsors and aliens. While these  legislative efforts would appear to address some of the concerns identified  by American Samoan and U.S. law enforcement officials, the legislation is  not final and so it is too soon to tell what impact the legislation, if passed,  will have on addressing the identified concerns.
section_title: U.S. Government Officials Report a Potential Risk Is Aliens Unlawfully Gaining Entry to the Rest of the United States via American Samoa
paragraphs: U.S. government officials we met with representing DHS, the Department  of State, and the FBI stated that a potential risk to the United States  associated with American Samoa administering its own customs and  immigration programs is illegal immigration into the rest of the United  States as a result of travelers obtaining false documentation in American  Samoa. The potential for illegal entry by aliens into the rest of the United  States from American Samoa raises questions as to whether current  practices in American Samoa can be used by criminals and terrorists to  jeopardize the security of the United States. As stated in CBP’s Fiscal Year  2009-2014 Strategic Plan, illegal immigration compromises national  security as aliens unlawfully gaining entry to the United States create a  pathway for illegal entry and a demand for false documentation and  identities. This is a threat to national security as terrorists might exploit  the same vulnerabilities that such aliens currently use. Furthermore, a  January 2010 presidential memorandum stated that DHS should  aggressively pursue enhanced screening technology, protocols, and  procedures, especially in regard to aviation and other transportation  sectors, and strengthen international partnerships and coordination on  aviation security issues.
According to data provided by the American Samoa Department of Legal  Affairs, as shown in table 1, while a majority of U.S. nationals and citizens  traveling to Hawaii from American Samoa during the past 3 years have  traveled with a U.S. passport (an average of 72.2 percent), the second most  commonly used document for travel by U.S. nationals and citizens was the  CI (an average of 19.5 percent).
Honolulu, Hawaii, is the only location within the United States to which  flights from American Samoa arrive. Upon arrival in Honolulu, passengers  from American Samoa are inspected by CBP to establish their identity and  nationality, and if the passenger is an alien, admissibility. For U.S. citizens  and noncitizen nationals, identity and nationality may be established, to  the satisfaction of a CBP officer, through the use of one or more  documents, such as a U.S.-issued passport or military ID, a birth certificate  with photo ID, or an American Samoa-issued CI. In addition, the CBP  officers use other techniques to verify a person’s identity and nationality,  including asking questions and observing behavioral cues. According to  CBP, once a U.S. citizen or noncitizen national has sufficiently  demonstrated his or her identity and nationality to the CBP officer, he or  she is no longer subject to inspection for admissibility. As with other  airline passengers who arrive from outside the United States and have not  been previously screened by CBP, if there is any suspicion of fraudulent  documents or intent, CBP officers may investigate the travelers from  American Samoa further and refer the travelers for additional, more in- depth questioning by CBP, or additional investigation by U.S. Immigration  and Customs Enforcement or Department of State officers. Honolulu- based CBP officers we spoke with who screen passengers arriving from  American Samoa could not identify any incidents in recent years in which  a passenger from American Samoa was determined to be traveling with a  fraudulent CI, or of a passenger being referred for additional inspection  because of a suspected fraudulent CI. The CBP officers also stated that  they have not identified any counterfeit U.S. passports used by passengers  arriving from American Samoa. However, while a CI or U.S. passport may  appear legitimate, it could have been improperly obtained through the use  of fraudulent identity documents, such as a false birth certificate or  driver’s license, as reported to us by American Samoan and U.S. law  enforcement officials, and such instances would be difficult for CBP to  detect.
In November 2009, charges were filed in the High Court of American  Samoa against the Manager of the Office of Motor Vehicles for conspiracy  to commit forgery based on evidence that driver’s licenses had been issued  fraudulently. Additionally, the American Samoa Department of Homeland  Security and Office of Independent Prosecutor, with assistance from the  resident FBI agent, initiated a full-scale investigation centered on alleged  improprieties in the Office of the Attorney General and the Immigration  Office. In January 2010, the Office of the Attorney General and the  Immigration Office were served search warrants to provide investigators  with records related to certain aliens in American Samoa, including all  ledgers related to CIs. While CBP has no direct knowledge of problems  regarding the use of CIs or passports that may have been obtained using  fraudulent documents, the Department of State has recently changed its  passport adjudication procedures as a result of these allegations.  Department of State officials we spoke with told us that the potential for  fraudulently obtaining CIs appeared to be a vulnerability within the  passport application process and, as a result, they no longer accept CIs as  the only form of identification to support a U.S. passport application.  Applicants may submit their locally-issued American Samoa identification,  but they will also need to provide additional documentation. Additionally,  the Department of State no longer allows the Office of the Attorney  General to serve as a location for accepting passport applications. Rather,  applications for U.S. passports are only accepted through passport  acceptance agents at the U.S. Post Office in Pago Pago. Moreover, as a  result of evidence from the Independent Prosecutor’s investigation, the  Department of State has undertaken an investigation to determine whether  passports were issued to individuals living in American Samoa in recent  years who are neither U.S. citizens nor noncitizen nationals. According to  State Department officials, while this investigation will serve to enhance  the security of the process for obtaining U.S. passports, it will not address  the reported vulnerabilities in the process for issuing CIs.
subsections: section_title: A Risk Assessment Could Better Inform U.S. Agencies of the Risks Associated with Aliens Fraudulently Obtaining Documents to Travel to the Rest of the United States
paragraphs: CBP officials we met with in Honolulu, Hawaii, who screen passengers  arriving from American Samoa, stated that instead of using the CI as a  document to establish identity and nationality for U.S. nationals arriving  from American Samoa, it would be easier to screen passengers and  prevent fraud if there was a more secure document establishing identity  and nationality for those travelers. However, U.S. agency officials we met  with, including CBP, acknowledged that they do not know the magnitude  of fraudulently issued CIs or the potential threat and consequences to the  United States as a result of fraudulently issued CIs because no assessment  has been performed of the risks posed by the continued use of CIs as an  identity document to facilitate travel by U.S. nationals. The CBP officials  stated that no such risk assessment has been performed because CBP  does not generally initiate risk assessments of issues or programs related  to areas that are considered a part of the United States, such as American  Samoa, although such an assessment could help to better define and  understand the potential risks.
The federal government’s Internal Control Standards call for the  establishment of internal controls to provide for an assessment of the risks  an agency faces from both external and internal sources. Additionally,  risk management plays an important role in homeland security. Federal  law has charged DHS with coordinating homeland security programs  through the application of a risk management framework. DHS, within its  National Infrastructure Protection Plan (NIPP), established criteria for  risk assessments. Risk assessments help decision makers identify and  evaluate potential risks so that countermeasures can be designed and  implemented to prevent or mitigate the potential effects of the risks. The  NIPP characterizes risk assessment as a function of three elements          (1) threat—the likelihood that a particular asset, system, or network will  suffer an attack or an incident; (2) vulnerability—the likelihood that a  characteristic of, or flaw in, an asset, system, or network’s design,  location, security posture, process, or operation renders it susceptible to  destruction, incapacitation, or exploitation by terrorist or other intentional  acts, mechanical failures, and natural hazards; and (3) consequence—the  negative effects on public health and safety, the economy, public  confidence in institutions, and the functioning of government, both direct  and indirect, which can be expected if an asset, system, or network is  damaged, destroyed, or disrupted by a terrorist attack, natural disaster, or  other incident. Given the concerns raised regarding allegations of  fraudulently obtained documents and potential illegal immigration into the  United States, performing a risk assessment could better position U.S.  agencies to understand the extent of the threat, vulnerabilities, and  consequences associated with travelers fraudulently obtaining CIs and  using them as identity documents when coming to the rest of the United  States from American Samoa.
section_title: Conclusions
paragraphs: While the majority of travelers to Honolulu, Hawaii, from American Samoa  in recent years have traveled with passports, and CBP has no data on  known use of fraudulent CIs to travel to the rest of the United States from  American Samoa, federal officials have stated that illegal immigration into  the United States by aliens using CIs fraudulently obtained in American  Samoa is a concern. Moreover, the Department of State is aware of  additional allegations concerning aliens who may have fraudulently  obtained U.S. passports and has recently begun a new investigation.  According to CBP, illegal immigration compromises national security, as  aliens unlawfully gaining entry create a pathway for illegal entry and a  demand for false documentation and identities. However, no U.S. agency  has performed a risk assessment of the documents used to establish  identity and nationality by travelers coming from American Samoa and the  impact, in particular, that continued use of the CI as an identification and  nationality document may have on American Samoa and the rest of the  United States. Such a risk assessment could better position relevant U.S.  agencies to understand the extent of threats, vulnerabilities, and  consequences associated with the use of CIs, and better inform decisions  on which documents should continue to be used for those wishing to  travel to the rest of the United States from American Samoa.
section_title: Recommendation for Executive Action
paragraphs: To better understand the extent and significance of the possible risks  associated with aliens in American Samoa fraudulently obtaining  documents to travel to the rest of the United States and potentially pursue  U.S. citizenship, we recommend that the Secretary of DHS, in consultation  with the Secretary of the Departments of State and the Interior, perform a  risk assessment to (1) determine the extent of the threats, vulnerabilities,  and consequences associated with aliens fraudulently obtaining CIs and  using them to travel to the rest of the United States from American Samoa:  and (2) make a determination as to whether CIs should continue to be an  acceptable identification document that establishes nationality for U.S.  nationals wishing to travel to the rest of the United States from American  Samoa.
section_title: Agency and Third Party Comments and Our Evaluation
paragraphs: We requested comments on a draft of this report from DHS, DOI, the  Department of State, and the Department of Justice, as well the American  Samoa government—to include the Office of the Governor, leaders of the  legislature, the Department of Treasury, and the Department of Legal  Affairs. DOI and the leaders of the American Samoa legislature  summarized their comments in letters, which are reprinted in appendixes  II and III, respectively. DOJ notified us through e-mail that it had no  comments and DHS notified us through e-mail that it concurred with the  recommendation. In addition to these responses, U.S. Customs and Border  Protection, the Department of State, and the American Samoa Department  of Treasury’s Customs Division each provided technical comments, which  have been incorporated into the report, as appropriate. The American  Samoa government’s Office of the Governor and its Department of Legal  Affairs did not provide comments.
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If you or your staffs have any questions about this report, please contact  Stephen L. Caldwell at (202) 512-8777, or caldwells@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. GAO staff who made key  contributions to this report are listed in appendix IV.
section_title: Appendix I: Additional Details on American Samoa’s Immigration Program
paragraphs: This appendix includes additional details on American Samoa’s  immigration program, such as information on visitors and aliens seeking to  reside in American Samoa for more than 30 days. In general, American  Samoa’s immigration program has many of the same elements as the U.S.  immigration program, such as numerical limits on the number of aliens  who may enter, preferences for specific categories of aliens based on the  grounds of their classification (e.g., family relationship or specific skills),  and the ability of aliens to apply for classification as permanent residents.  However, American Samoa’s immigration program also has some unique  aspects, such as special allowances for aliens from the Independent State  of Samoa, including higher numerical limitations and a guest worker  program specifically for Samoans, the broad sponsorship requirements for  aliens, and the inability of aliens to naturalize or become U.S. nationals.
subsections: section_title: Visitors
paragraphs: Visitors may enter American Samoa for tourism or business purposes for  up to 30 days on a visitor or business entry permit. Such tourists or  business persons must have a valid passport or other travel document and  a round-trip ticket to their point of origin or onward passage to a  destination beyond American Samoa. Upon approval of the Attorney  General or his or her designee, aliens with 30-day permits may stay for an  additional 30 days.
section_title: Aliens Seeking to Reside in American Samoa for More Than 30 Days
paragraphs: Aliens may enter and reside in American Samoa based on their  relationship with American Samoans (or permanent residents in American  Samoa) or for employment reasons. Table 2 below summarizes the  classifications and the major characteristic of each classification.
Certain aliens may enter and reside in American Samoa based on their  relationship with American Samoans or permanent residents in American  Samoa. For example, individuals born outside of American Samoa, one of  whose parents was born in American Samoa of Samoan ancestry, are  considered American Samoan and may obtain an AA classification if those  individuals register with the Immigration Board within 3 years of their 18th  birthday. Such individuals must have a sponsor. Sponsors must be either  an American Samoan or U.S. national who resides in American Samoa or a  business licensed in American Samoa, and sponsors are responsible for  the alien’s medical bills, taxes, and public debts, among other things.
Aliens who are immediate relatives of American Samoans may obtain a BA  classification in American Samoa. Such relatives include children and  spouses of American Samoans and parents of American Samoans at least  21 years of age. Other aliens who have certain family relationships with  American Samoans may request an alien classification in American Samoa.  These aliens must have a sponsor, are subject to numerical limitations,  and approval for a classification is granted in order of preference. See  table 3 for the classifications, in order of preference, with the numerical  limitation of aliens from each category per fiscal year.
subsections: section_title: Employment-Based Classifications
paragraphs: Aliens may also apply to come to American Samoa for employment  reasons. For example, aliens who are members of the professions or  persons of exceptional ability in the sciences or the arts may apply for a P4  classification, and aliens who are capable of performing skilled or  unskilled labor for which there is a shortage of employable and willing  people in American Samoa may apply for a P5 classification. Aliens  applying for these classifications are subject to numerical limitations and  category preferences, as shown in table 3. For P4 aliens, their employer  serves as their sponsor, and they may apply to the Immigration Board for  permission to transfer sponsorship to another employer. Aliens with the  P5 classification are primarily domestic or agricultural workers, and they  must reside with and engage in domestic or agricultural work for their  sponsors. According to Immigration Board policy, after 1 year, they may  apply to the board for authorization for outside employment. American  Samoans may sponsor only one P5 alien unless they can demonstrate to  the Immigration Board that more than one person is required for domestic  work due to the age or infirmity of the sponsor or a member of the  sponsor’s family or, with respect to agricultural workers, that the sponsor  needs more than one agricultural worker and the sponsor can afford the  care of the workers in all ways while they are in American Samoa.
There are two employment-based classifications that are not subject to the  numerical limitations. First, there is a special provision category for aliens  who are employed by the American Samoa government, the United States  government or who are members of skilled, professional, or specialized  labor that by Immigration Board order are waived from the numerical  limitations upon a showing of extenuating circumstances. Special  provision aliens are sponsored by their employers and they may transfer  sponsorship to another employer only with the approval of the  Immigration Board. There is also a guest worker program specifically for  aliens from Samoa who work for the tuna cannery in American Samoa.  Guest workers do not need work authorization and do not have a  separate sponsorship requirement, as their classification is tied to their  employment, and the cannery is the only eligible employer.
section_title: Permanent Resident Classification
paragraphs: Some aliens may also apply for classification as permanent residents. In  order to become a permanent resident, a person must either (1) be  physically and legally present in American Samoa for a continuous period  of at least 20 years and of good moral character; (2) at the time of being  legally adopted by an American Samoan be 21 years of age or younger or  be legally adopted by an American Samoan prior to December 31, 1980; (3)  have been legally married to an American Samoan or a United States  citizen and have resided in American Samoa for at least 10 years; or (4) be  a brother or sister of an American Samoan or a married son or married  daughter of an American Samoan and have resided in American Samoa for  at least 10 years. There is a numerical limitation of 50 aliens who may be  approved for classification as permanent residents based on the residency  requirement alone.  There is no numerical limitation for those applying for  permanent resident classification based on the other three categories.
section_title: Appendix II: Comments from the Department of the Interior
section_title: Appendix III: Comments from Leaders of the American Samoa Legislature
section_title: Appendix IV: GAO Contact and Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact named above, Christopher Conrad, Assistant  Director, and Amy Sheller Martin, Analyst-in-Charge, managed this review  and Michele Lockhart made significant contributions to the work. Jenny  Chanley assisted with design and methodology, Emil Friberg and Richard  Hung provided additional technical and issue area expertise, Barbara Hills  helped to develop the report graphics, Lara Kaskie provided assistance in  report preparation, and Tracey King provided legal support and analysis.
section_title: Related GAO Products
paragraphs: American Samoa and Commonwealth of the Northern Mariana Islands:  Wages, Employment, Employer Actions, Earnings, and Worker Views  Since Minimum Wage Increases Began. GAO-10-333. Washington, D.C.:  April 8, 2010.
U.S. Insular Areas: Opportunities Exist to Improve Interior’s Grant  Oversight and Reduce the Potential for Mismanagement. GAO-10-347.  Washington, D.C.: March 16, 2010.
Poverty Determination in U.S. Insular Areas. GAO-10-240R. Washington,  D.C.: November 10, 2009.
Medicaid and CHIP: Opportunities Exist to Improve U.S. Insular Area  Demographic Data That Could Be Used to Help Determine Federal  Funding. GAO-09-558R. Washington, D.C.: June 30, 2009.
Addressing Significant Vulnerabilities in the Department of State’s  Passport Issuance Process. GAO-09-583R. Washington, D.C.: April 13,  2009.
Transportation Security: Comprehensive Risk Assessments and Stronger  Internal Controls Needed to Help Inform TSA Resource Allocation.  GAO-09-492. Washington, D.C.: March 27, 2009.
Department of State: Undercover Tests Reveal Significant Vulnerabilities  in State’s Passport Issuance Process. GAO-09-447. Washington, D.C.:  March 13, 2009.
American Samoa: Issues Associated with Some Federal Court Options.  GAO-08-1124T. Washington, D.C.: September 18, 2008.
Commonwealth of the Northern Mariana Islands: Managing Potential  Economic Impact of Applying U.S. Immigration Law Requires  Coordinated Federal Decisions and Additional Data. GAO-08-791.  Washington, D.C.: August 4, 2008.
American Samoa: Issues Associated with Potential Changes to the  Current System for Adjudicating Matters of Federal Law. GAO-08-655.  Washington, D.C.: June 27, 2008.
Border Security: Security of New Passports and Visas Enhanced, but  More Needs to Be Done to Prevent Their Fraudulent Use. GAO-07-1006.  Washington, D.C.: July 31, 2007.
U.S. Insular Areas: Economic, Fiscal, and Financial Accountability  Challenges. GAO-07-119. Washington, D.C.: December 12, 2006.
Risk Management: Further Refinements Needed to Assess Risks and  Prioritize Protective Measures at Ports and Other Critical  Infrastructure. GAO-06-91. Washington, D.C.: December 15, 2005.
U.S. Insular Areas: Multiple Factors Affect Federal Health Care Funding.  GAO-06-75. Washington, D.C.: October 14, 2005.
American Samoa: Accountability for Key Federal Grants Needs  Improvement. GAO-05-41.Washington, D.C.: December 17, 2004.