    Homeland Security: INS Cannot Locate Many Aliens Because It Lacks
    Reliable Address Information (21-NOV-02, GAO-03-188).

    Following the terrorist attacks of September 11, 2001, the
    federal government's need to locate aliens in the United States
    was considerably heightened. Without reliable alien address
    information, the government is impeded in its ability to find
    aliens who represent a national security threat or who could help
    with the nation's anti-terrorism efforts. Requesters from both
    the Senate and House asked GAO to review the reliability of INS's
    alien address information and identify the ways it could be
    improved.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-03-188
        ACCNO:   A05546
      TITLE:     Homeland Security: INS Cannot Locate Many Aliens Because
    It Lacks Reliable Address Information
         DATE:   11/21/2002
      SUBJECT:   Aliens
    	     Counterterrorism
    	     Data collection
    	     Data integrity
    	     Information resources management
    	     Law enforcement
    	     National defense operations
    	     Records management
    	     Reporting requirements
    	     National preparedness
    	     Immigrants
    	     INS Nonimmigrant Information System
    	     INS Computer Linked Application
    	     Information Management System

    	     INS Deportable Alien Control System

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    GAO-03-188

    Report to Congressional Requesters

    United States General Accounting Office

    GAO

    November 2002 HOMELAND SECURITY

    INS Cannot Locate Many Aliens Because It Lacks Reliable Address
    Information

    GAO- 03- 188

    Why GAO Did This Study

    Following the terrorist attacks of September 11, 2001, the federal
    government*s need to locate aliens in the United States was considerably
    heightened. Without reliable alien address information, the government is
    impeded in its ability to find aliens who represent a national security
    threat or who could help with the nation*s anti- terrorism efforts.
    Requesters from both the Senate and House asked GAO to review the
    reliability of INS*s alien address information and identify the ways it
    could be improved.

    November 2002

    HOMELAND SECURITY

    INS Cannot Locate Many Aliens Because It Lacks Reliable Address
    Information

    The full report, including GAO's objectives, scope, methodology, and
    analysis is available at www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 188.
    For additional information about the report, contact Richard M. Stana at
    (202) 512- 8777.

    Highlights of GAO- 03- 188, a report to the Honorable Strom Thurmond,
    United States Senate, and George W. Gekas, Chairman, Subcommitee on
    Immigration, Border Security, and Claims, Committee on the Judiciary,
    House of Representatives

    What GAO Recommends

    GAO recommendations to the Attorney General include instructing the
    Commissioner of INS to do the following:

    Publicize the change of address notification requirement.

    Establish procedures and controls to ensure that alien address information
    in all automated databases is complete, consistent, accurate, and current.

    Establish procedures and controls that permit INS to enforce the penalty
    provisions for noncompliance with the change of address notification
    requirement.

    Evaluate alternative approaches and their costs for obtaining or
    assembling complete alien address information.

    United States General Accounting Office

    What GAO Found

    Recent events have shown that INS*s alien address information could not be
    fully relied on to locate many aliens who were of interest to the United
    States. For example, the Department of Justice sought to locate and
    interview 4,112 aliens who were believed to be in the country and who
    might have knowledge that would assist the nation in its anti- terrorism
    efforts. However, as shown below, almost half of these aliens could not be
    located and interviewed because INS lacked reliable address information.

    The reliability of INS*s alien address information is contingent, in part,
    on aliens* compliance with the requirement that they notify INS of any
    change of address. However, lack of publicity about the requirement that
    aliens should file change of address notifications, no enforcement of
    penalties for noncompliance, and inadequate processing procedures for
    changes of address also contribute to INS*s alien address information
    being unreliable. Because INS does not publicize the change of address
    requirement, some aliens may not be aware of it and may not comply with
    it. Alternatively, some aliens who are aware of the requirement may not
    comply because they do not wish to be located. These aliens have little
    incentive to comply given that INS does not enforce the penalties for
    noncompliance. On the basis of our review of available data, INS does not
    appear to have enforced the removal penalty for noncompliance since the
    early 1970s. When aliens do comply with the requirement, INS lacks
    adequate processing procedures and controls to ensure that the alien
    address information it receives is recorded in all automated databases.

    Addressing these problems should help improve the reliability of INS*s
    alien address information but would not necessarily result in a system
    that would allow INS to reliably locate all aliens, because some aliens
    will not likely comply. INS has recognized the need to increase the
    reliability of its alien address information and is taking some steps to
    improve it.

    DOJ Sought to Locate and Interview 4,112 Aliens

    55% of aliens were located and interviewed

    2,261 1,851 45% of aliens could not be located

    and interviewed Source: GAO*s analysis of the Executive Office for U. S.
    Attorneys* interview project data as of March 20, 2002.

    G A O Accountability Integrity Reliability

    Highlights

    Page i GAO- 03- 188 Homeland Security Letter 1

    Results in Brief 2 Background 4 Congress Provided the Framework for INS to
    Locate Aliens 8 INS*s Alien Address Records Are Not Reliable 12 Lack of
    Publicity, No Enforcement of Penalties, and Inadequate

    Processing Procedures Contribute to INS*s Unreliable Address Information
    16 INS*s Actions to Improve Alien Address Reliability 23 Conclusions 24
    Recommendations for Executive Action 25 Agency Comments and Our Evaluation
    26

    Appendix I Scope and Methodology 29

    Appendix II An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981 31

    The Alien Registration Program of 1940 31 The Alien Address Report Program
    of 1950 32 Alien Registration Programs Shared Common Program Elements 34

    Appendix III Comments from the Department of Justice 42

    Appendix IV GAO Contacts and Staff Acknowledgments 46 Contacts 46
    Acknowledgments 46

    Tables

    Table 1: Examples of Requests for Alien Registration Data INS Approved and
    Their Intended Use 38 Table 2: Examples of Requests for Alien Registration
    Data INS

    Denied and Their Intended Use 38 Table 3: Examples of Requests for Alien
    Address Report Program

    Data INS Approved and the Intended Uses 39 Contents

    Page ii GAO- 03- 188 Homeland Security Figures

    Figure 1: INS*s Form AR- 11 Is Available in Six Languages 6 Figure 2:
    Requirements and Penalties for Registration and Address

    Reporting from June 28, 1940 to June 28, 2002 10 Figure 3: INS*s Alien
    Address Report Provided for Collecting

    Aliens* SSNs 15 Figure 4: INS*s Processing of the Form AR- 11 20 Figure 5:
    INS*s Processing of Other Change of Address Forms 21 Figure 6: Number of
    Aliens Who Reported During the Alien

    Address Report Program, 1951- 1980 33 Figure 7: The Post Office Department
    Cancelled Stamps with a

    Reminder That Aliens Must Report Their Addresses 35 Figure 8: INS*s 1953
    Sign Placed in Post Offices Instructing Aliens

    to Report Their Addresses 36

    Abbreviations

    CLAIMS 3 Computer Linked application Information Management System DACS
    Deportable Alien Control System DOJ Department of Justice FBI Federal
    Bureau of Investigation INS Immigration and Naturalization Service NIIS
    Nonimmigrant Information System SSN Social Security number

    Page 1 GAO- 03- 188 Homeland Security

    November 21, 2002 The Honorable Strom Thurmond United States Senate

    The Honorable George W. Gekas Chairman, Subcommittee on Immigration,
    Border Security, and Claims Committee on the Judiciary House of
    Representatives

    Following the terrorist attacks of September 11, 2001, the federal
    government*s need to locate aliens who represented a national security
    threat or who could help with the nation*s anti- terrorism efforts was
    considerably heightened. 1 The Immigration and Naturalization Service
    (INS) is the federal agency that is responsible for maintaining address
    information for aliens who are in the United States and was called upon to
    help by providing current addresses for aliens who were being sought by
    the Department of Justice (DOJ). However, efforts to locate these aliens
    were impeded by INS*s lack of current address information.

    Because of growing concern over the government*s need to locate aliens,
    you asked us to determine what was impeding INS from using its alien
    address information to reliably locate aliens in the United States. This
    report discusses (1) the statutory framework that requires aliens to
    report their addresses and any address changes, (2) the reliability of
    INS*s alien address records to locate aliens who were sought by DOJ, and
    (3) the principal factors affecting the reliability of INS*s alien address
    records. You further asked for historical background information on prior
    alien registration requirements and programs, which is included in
    appendix II.

    To determine the statutory framework that requires aliens to report their
    addresses and any address changes, we identified and reviewed the laws and
    regulations, congressional testimony and reports, and prior GAO reports.
    To determine whether INS*s alien address information can be used to
    reliably locate aliens in the United States, we reviewed INS documentation
    and data, observed processing of the change of address

    1 References in this report to aliens, unless otherwise specified, refer
    to those immigrants and nonimmigrants in the United States who are
    required to provide address information.

    United States General Accounting Office Washington, DC 20548

    Page 2 GAO- 03- 188 Homeland Security

    forms in INS headquarters, and interviewed INS managers and staff and a
    representative of the U. S. Postal Service. We also interviewed senior
    representatives from the Executive Office for U. S. Attorneys, Federal
    Bureau of Investigation (FBI), the Secret Service, and the Foreign
    Terrorist Tracking Task Force. 2 To identify the principal factors
    affecting the reliability of INS*s alien address records, we analyzed the
    information we obtained during the review. To obtain information on the
    historical background of the alien registration requirement and programs,
    we reviewed INS historical documentation and data and interviewed INS
    managers and staff. See appendix I for a more detailed discussion of our
    scope and methodology.

    We performed our work from October 2001 through September 2002 in
    accordance with generally accepted government auditing standards. We
    requested comments on a draft of this report from the Attorney General.

    Since 1940, the Congress has provided a statutory framework that requires
    aliens entering or residing in the United States to provide identifying
    and address information. This information is provided to INS. While the
    law requires aliens who remain in the United States for 30 days or longer
    to apply for registration, INS usually registers aliens at the time of
    their entry into the country. Registration documents provide an alien*s
    identity and address where the alien can be located. The law requires that
    an alien report any change of address within 10 days of moving. Thus, if
    aliens comply with the requirement, INS should be able to record and
    maintain an address history for each alien, including their current
    address. If an alien fails to comply with the change of address
    notification requirement, it can result in the alien*s prosecution for a
    misdemeanor. As provided in law, irrespective of whether the alien is
    charged with or convicted of a misdemeanor, an alien, who fails to notify
    the Attorney General in writing of each change of address and new address
    within 10 days from the date of such change, shall be taken into custody
    and removed from the United States unless the alien can establish to the
    satisfaction of the Attorney General that the failure was reasonably
    excusable or was not willful.

    2 On October 29, 2001, the President directed the Attorney General to
    create the Foreign Terrorist Tracking Task Force (Homeland Security
    Presidential Directive * 2, National Security Presidential Directives).
    The task force is to ensure that federal agencies coordinate their
    programs so that aliens associated with, suspected of being engaged in, or
    supporting terrorist activity are to be denied entry into and removed from
    the United States. Results in Brief

    Page 3 GAO- 03- 188 Homeland Security

    Recent events have shown that INS*s alien address information cannot be
    relied on to locate aliens. For example, as part of the nation*s
    antiterrorism effort, the Attorney General directed all U. S. Attorneys in
    November 2001 to locate and request voluntary interviews with about 4,800
    nonimmigrant aliens who were believed to be in this country. U. S.
    Attorneys, in cooperation with the Foreign Terrorist Tracking Task Force,
    obtained the names and addresses for these aliens from INS. The task force
    further supplemented INS*s alien address information by obtaining address
    information from public source databases. The aliens* names and addresses
    were then forwarded to the U. S. Attorneys in order that they could locate
    and request interviews with them. U. S. Attorneys determined that 681
    aliens had left the country. By the end of February 2002, even with the
    information from public source data bases, 1,851, or about 45 percent, of
    the 4, 112 aliens who were believed to still be in the country had not
    been located and interviewed. Two other DOJ efforts to locate aliens have
    met with even less success.

    Lack of publicity, no enforcement of penalties for not filing change of
    address notifications, and inadequate processing procedures and controls
    explain in part why INS*s alien address information is unreliable.
    Unreliable address information can also be attributed, in part, to aliens*
    failure to report changes of address to the INS. Some aliens may be
    unaware that they need to file a change of address form and do not comply.
    This may be understandable given that INS does not publicize the change of
    address requirement. Aliens may be aware that they need to file but do not
    comply because they have little incentive to do so. On the basis of our
    review of available data, INS does not appear to have enforced the removal
    penalty for noncompliance since the early 1970s. According to INS
    officials, INS cannot and does not enforce the penalty provisions of the
    law because it cannot determine and certify from its change of address
    records whether an alien failed to file the change of address
    notification. When aliens are aware of and comply with the requirement to
    file a change of address notification, INS*s address information may still
    be unreliable. INS lacks adequate procedures and controls to ensure that
    the alien address information it receives is completely processed.
    Addressing these problems should help improve the reliability of INS*s
    address information but would not necessarily result in a system that
    would allow INS to reliably locate all aliens. This is because the
    accuracy and reliability of INS*s address information is contingent on
    aliens* compliance and some aliens may not comply.

    In April 2002, INS established an Address Issues Task Force to review and
    assess how alien address information is processed. The task force

    Page 4 GAO- 03- 188 Homeland Security

    recommended a multi- phased strategy to improve operational efficiency. As
    of September 11, 2002, INS had accepted the task force*s recommendations.
    The Executive Associate Commissioner for Management was designated as the
    lead agency official for address issues, an Address Issues Office was
    established, and the Commissioner approved a Senior Level Advisory Group
    for address issues. INS has also taken the first steps toward establishing
    a centralized address repository and plans to implement the task force*s
    other recommendations.

    We are making seven recommendations to the Attorney General to promote
    compliance through publicity and enforcement and to improve INS*s
    identification and processing of aliens* address information. We provided
    DOJ with a draft of this report for comment, and it generally concurred
    with five, and did not comment on two of them. DOJ*s comments are included
    as appendix III.

    INS regulates immigration to the United States and oversees immigrants,
    who intend to remain permanently in the United States, and nonimmigrants,
    who intend to remain in the United States temporarily. INS receives and
    maintains alien address information for benefits administration, law
    enforcement, and national security purposes. Through registration and
    change of address notifications, aliens provide their identity and an
    address where they can be located while in the United States to INS, which
    can share this information to help law enforcement officials identify and
    locate aliens. 3

    Generally, INS registers aliens at the time of their entry, using 1 of 12
    different INS forms, including the Arrival and Departure Record (Form I-
    94). For example, aliens arriving in the United States are generally
    required to complete a two- part Form I- 94. The first part records
    aliens* arrivals. The second part is to be surrendered when aliens leave
    the country. INS is to match the first and second parts of the Form I- 94
    to identify those aliens who have left the country. However, as reported
    by DOJ*s Inspector General in 1997 and 2002, INS lacked many Form

    3 Registration is a shared responsibility between the Departments of State
    and Justice. The Attorney General is responsible for registering aliens
    who remain in the United States for 30 days or more and who have not
    otherwise registered, such as during the visa application process
    administered by the Department of State. The Attorney General is also
    responsible for collecting change of address information and issuing
    certificates of registration. Background

    Page 5 GAO- 03- 188 Homeland Security

    I- 94 departure records, and as a result, INS could not identify all of
    the aliens who had left the country. 4

    Aliens are required to report their change of address to INS within 10
    days of moving. Failure to report a change of address can result in an
    alien being taken into custody and placed in removal proceedings before an
    immigration judge with the Executive Office for Immigration Review. To
    place an alien in proceedings, INS is to serve the alien with a Notice to
    Appear, which cites the charge( s) and the date and location where the
    hearing is to be held. At the conclusion of the hearing, the immigration
    judge may order the alien to be removed or may grant relief from removal.
    Either INS or the alien may appeal the immigration judge*s decision to the
    Board of Immigration Appeals.

    As shown in figure 1, INS has a prescribed change of address form, (i. e.,
    Form AR- 11) that is available in six languages (English, Spanish,
    Chinese, Russian, Korean, and Vietnamese) and is to be used by all aliens
    to report their new addresses.

    4 See Department of Justice, Office of the Inspector General, Immigration
    and Naturalization Service Monitoring of Nonimmigrant Overstays, Report
    Number I- 97- 08 (Washington, D. C.: Sept. 1997); and Follow- Up Report On
    INS Efforts To Improve The Control of Nonimmigrant Overstays, Report No.
    I- 2002- 006, (Washington, D. C.: Apr. 2002).

    Page 6 GAO- 03- 188 Homeland Security

    Figure 1: INS*s Form AR- 11 Is Available in Six Languages

    Source: INS. Russian Chinese

    Korean Vietnamese Spanish

    USA English (postcard)

    Page 7 GAO- 03- 188 Homeland Security

    Prior to the terrorist attacks on September 11, 2001, the Congress
    mandated that INS improve its ability to identify aliens who arrive and
    depart the United States and who overstay their visas. In Section 110 of
    the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 5
    and amendments to that section, the Congress reinforced the importance of
    the government being able to identify which lawfully admitted
    nonimmigrants remained in the United States beyond their authorized
    period. This section directs the Attorney General to develop an integrated
    entry and exit control system that will collect the records of arrival and
    departure for every alien entering and leaving the United States. The 1996
    act also authorized the establishment of an electronic student tracking
    system to verify and monitor the foreign student and exchange visitor
    information program. 6 The deadline for implementing the new electronic
    student tracking system is January 1, 2003.

    According to proposed rules issued by DOJ on June 13, 2002, the events of
    September 11 point to the need to implement measures that would provide
    the government with information on certain aliens who are in the country,
    whether they are in compliance with their authorized limits of stay, and
    their activities and whereabouts. The USA Patriot Act (P. L. 107- 56),
    enacted in October 2001, directs the Attorney General to implement the
    entry- exit system *with all deliberate speed and as expeditiously as
    practicable* and authorized funds to fully implement INS*s new foreign
    student tracking system. The Enhanced Border Security and Visa Entry
    Reform Act (P. L. 107- 173), enacted in May 2002, also authorized funds
    for implementing the foreign student tracking system. 7 The Congress has
    required that the entry- exit system be implemented at airports and
    seaports by December 31, 2003.

    5 P. L. 104- 208, codified at 1365a. 6 Section 641, codified at 8 U. S. C.
    1372. 7 The Congress is considering the inclusion of INS in the Office of
    Homeland Security.

    Page 8 GAO- 03- 188 Homeland Security

    Since the 1940 passage of the Alien Registration Act, the Congress has
    required aliens to register and provide address information so that the
    government can track aliens* past and current locations and locate aliens
    when necessary. 8 As part of the effort to protect the nation in
    anticipation of World War II, the Congress required aliens to register, be
    fingerprinted, and notify the Attorney General of each change of address,
    thereby providing INS with the means to identify, track, and locate aliens
    while they are in the United States. According to the legislative history
    of the Alien Registration Act, the act was considered to be *a measure of
    selfdefense to provide for the fingerprinting and registration of all
    aliens in the United States*( and)* a safeguard to know something about
    their activities and their movements here.* 9

    Although some requirements of the law have varied since 1940, the Congress
    has continuously required immigrant and nonimmigrant aliens entering or
    living in the United States to provide identifying and current address
    information and has provided penalties for failing to register or file
    address information. As shown in figure 2, the Alien Registration Act of
    1940 required immigrant and nonimmigrant aliens to register with the
    government. 10 Immigrants were required to report changes of address
    within 5 days, and nonimmigrants were required to report their address
    every 90 days irrespective of whether they had moved. In 1950, the
    Congress increased the reporting requirements for immigrants by requiring
    them to annually report their addresses. 11 In 1952, the Congress extended
    the annual address reporting and change of address notification
    requirements to all aliens and also extended from 5 to 10 days the amount
    of time aliens were provided to file a change of address. 12 In 1981, the
    Congress eliminated the requirements that aliens annually report their
    addresses and that nonimmigrants report their address every 90 days. 13

    8 Diplomats, representatives of international organizations and their
    families, and individuals remaining in the United States for less than 30
    days are not required to register. 9 86 Cong. Rec. H. 9033 (June 22, 1940)
    (statement of Rep. C. E. Hancock, one of the House managers). 10 Ch. 439,
    54 Stat. 670 (1940).

    11 The Internal Security Act of 1950 required alien residents to annually
    report their addresses. Ch. 1024, 64 Stat. 987. The law also extended
    coverage to nonimmigrants who had overstayed their visas and any alien in
    an illegal status.

    12 Immigration and Nationality Act, Ch. 477, 66 Stat. 163 (1952). 13
    Immigration and Nationality Act Amendments of 1981, P. L. No. 97- 116, 95
    Stat. 1611 (1981). Congress Provided

    the Framework for INS to Locate Aliens

    Page 9 GAO- 03- 188 Homeland Security

    Although the Congress eliminated these requirements, it vested the
    Attorney General with discretionary authority, upon 10 days* notice, to
    require aliens from any country or countries, or any class or group, who
    are required to be registered, to provide their current address and such
    additional information as may be required. 14 These changes represent the
    latest amendments to the laws governing alien registration and address
    reporting. The Congress currently requires aliens to provide address
    information through registration and change of address reporting
    requirements. 15

    In addition to the registration and change of address requirements, the
    Congress has continuously provided penalties for aliens who failed to
    comply with these requirements, as shown in figure 2. The misdemeanor
    penalty enacted in 1940 for failing to file a change of address notice was
    a fine of up to a $100 and/ or imprisonment for up to 30 days. In 1952,
    the misdemeanor penalty was increased to a $200 fine and/ or imprisonment
    for up to 30 days and a removal penalty was added, irrespective of whether
    the alien is charged with or convicted of a misdemeanor. The law provides
    that an alien, who fails to notify the Attorney General in writing of each
    change of address and new address within 10 days from the date of such
    change, shall be taken into custody and removed from the United States
    unless the alien can establish to the satisfaction of the Attorney General
    that the failure was reasonably excusable or was not willful. As of
    September 2002, this penalty remained in effect. 16

    14 The Attorney General*s discretionary authority in 8 U. S. C. 1305( b)
    extends to *the natives of any one or more foreign states, or any class or
    group thereof* referred to here as aliens. 15 The current requirements for
    alien registration and change of address are codified at 8 U. S. C. 1301-
    1306. 16 The current penalties for noncompliance with registration and
    change of address requirements are codified at 8 U. S. C. 1306.

    Page 10 GAO- 03- 188 Homeland Security

    Figure 2: Requirements and Penalties for Registration and Address
    Reporting from June 28, 1940 to June 28, 2002

    Legislation and dates of applicability

    Immigrants Nonimmigrants Register a

    No requirement Yes

    Yes Yes Yes

    Yes Yes Yes Yes

    Yes Yes b Yes No No

    requirement No requirement

    No penalty

    Deportation c No requirement No

    requirement No

    requirement No

    requirement No

    requirement No

    Within 10 days Within 5

    days Unchanged Unchanged

    Within 10 days of January 1st

    Within 30 days of January 1st

    Within 30 days of January 1st Within 10

    days Unchanged Unchanged File change of

    address notice Register a Report address every 90 days File change

    of address notice Annually report

    their address Annually report

    their address

    Penalties for noncompliance Registration and address reporting
    requirements

    Alien Registration Act of 1940 (June 28, 1940 to September 22, 1950)

    Fine not to exceed $100 and/ or imprisonment for

    not more than 30 days Fine not to exceed $100 and/ or imprisonment for

    not more than 30 days Unchanged Unchanged

    Unchanged Unchanged Unchanged Fine not to exceed $1,000

    and/ or imprisonment not more than 6 months

    for willful failure or refusal to comply with the registration
    requirements

    Fine not to exceed $200 and/ or imprisonment not more than 30 days.

    Removal of the alien from the United States. d

    Fine not to exceed $200 and/ or imprisonment not more than 30 days.

    Removal of the alien from the United States. d

    Fine not to exceed $200 and/ or imprisonment not more than 30 days.

    Removal of the alien from the United States. d Failure to register Failure
    to file change

    of address notice Failure to annually

    report address Failure to report

    address every 90 days Internal Security

    Act 1950 (September 23, 1950 to June 26, 1952)

    Immigration and Naturalization Act (June 27, 1952 to December 28, 1981)
    Immigration and Nationality Act Amendments of 1981 (Dec. 29, 1981 to June
    28, 2002)

    Page 11 GAO- 03- 188 Homeland Security

    a All aliens 14 years of age or older who remain in the United States for
    30 days or more must register. A parent or legal guardian must register an
    alien who is under 14 years of age. Exceptions to the registration
    requirements are provided for aliens who remain in the United States for
    less than 30 days, foreign government officials and their family members,
    and representatives of international organizations and their family
    members. b Required by regulation 8 C. F. R. 119. 3 (1950).

    c The requirement to report an address every 90 days was by regulation (8
    C. F. R. 119.3), a condition of entry. Violation of a condition of entry
    could result in an alien*s deportation. d An alien is to be removed from
    the United States unless the alien establishes to the satisfaction of

    the Attorney General that the violation was reasonably excusable or was
    not willful. Source: GAO*s analysis.

    On June 13 and July 26, 2002, DOJ reiterated that certain aliens are
    legally obligated to file a change of address form with INS within 10 days
    of moving to a new address to be used for enforcement and other purposes.
    On June 13, 2002, DOJ issued a proposed rule concerning the registration
    and monitoring of certain nonimmigrants. 17 Specifically, the proposed
    rule would impose registration requirements on nonimmigrants from Iran,
    Iraq, Libya, Sudan, and Syria; certain nonimmigrant aliens from other
    countries that the State Department and INS determine to be an elevated
    national security risk; and aliens fitting specific criteria who are
    identified by INS inspectors at points of entry into the United States.
    Individuals falling into these categories would be required to provide
    specific information at regular intervals to ensure that they were in
    compliance with the terms of their visas and admission and that they
    departed at the end of their authorized stay. The proposed rule reminded
    aliens that they are required to submit to INS changes of address and that
    failure to do so could result in their removal. The final rule was
    published and became effective on September 11, 2002. 18

    On July 26, 2002, INS issued a proposed rule requiring every alien who is
    applying for immigration benefits to acknowledge having received notice of
    the requirement to provide a valid current address to INS, including any
    change of address within 10 days of the change. 19 INS plans to use the
    most recent address information for all purposes, including the service of
    a Notice to Appear if INS initiates removal proceedings.

    17 67 Fed. Reg. 40581 (June 13, 2002). 18 67 Fed. Reg. 52584 (August 12,
    2002). 19 67 Fed. Reg. 48818 (July 26, 2002).

    Page 12 GAO- 03- 188 Homeland Security

    Despite these laws and regulations, INS*s address information cannot be
    relied upon to locate many aliens who are in the United States. Since
    September 11, 2001, DOJ has made several different attempts to locate
    aliens as part of its anti- terrorism efforts. These efforts have not been
    fully successful. In addition, the alien identifying and address
    information maintained by INS may not allow law enforcement officials to
    verify the identity of an alien being sought in cases where several aliens
    have the same name but are located at different addresses. Senior
    representatives of the FBI, the Secret Service, and the Foreign Terrorist
    Tracking Task Force told us that the ability to locate aliens within the
    United States is crucial to their respective missions. According to a
    senior representative of the task force, the ability to locate aliens in
    this country is also crucial to the nation*s success in fighting the war
    on terrorism.

    On November 9, 2001, as part of the nation*s anti- terrorism effort, the
    Attorney General directed all U. S. Attorneys to locate and request
    voluntary interviews with 4,793 nonimmigrant aliens who might have had
    knowledge of foreign terrorists or their organizations. To assist the U.
    S. Attorneys, the Foreign Terrorist Tracking Task Force asked INS to
    provide current address information for the aliens who were to be sought
    for interviews. INS obtained the address information from the Nonimmigrant
    Information System (NIIS), an automated database that contains address and
    identity information on nonimmigrants who were inspected upon their entry
    into the United States. Because the task force considered INS*s address
    information to be of questionable reliability, it consulted public source
    databases and supplemented INS*s information in order to provide the most
    current address information for these aliens to the U. S. Attorneys. U. S.
    Attorneys determined that 681 aliens had left the country. As of February
    26, 2002, even with the information from public source data bases, 1,851,
    or 45 percent, of the 4,112 aliens believed to be in the country had not
    been located and interviewed while 2,261, or 55 percent, had been located
    and interviewed. 20

    As a second example, INS investigators determined that INS*s address
    information was inaccurate for 45 aliens who may have known some of the
    terrorists responsible for the September 11th attacks. According to the
    Assistant District Director for Investigations in San Diego, he was
    advised that at least two of the terrorists had student visas and were
    supposed to

    20 According to an Executive Office for U. S. Attorneys* report, *a small
    percentage* of aliens were located and declined to be interviewed. INS*s
    Alien Address

    Records Are Not Reliable

    Page 13 GAO- 03- 188 Homeland Security

    be attending school in the San Diego area. He requested that INS
    headquarters provide him with a list of aliens with student visas who had
    entered the United States within the last 2 years and, at the time of
    their entry, indicated they were going to the San Diego area. From a list
    of 700 aliens, INS investigators identified 45 whom they wanted to locate.
    According to INS investigators who sought to locate these aliens, INS*s
    address information for all 45 student aliens was inaccurate as none of
    them were located at the addresses that INS had provided. Efforts to
    supplement INS*s address information with the schools* address information
    provided accurate addresses for 10 students. It is possible that some or
    all of the 35 aliens that INS could not locate had left the country.

    As a third example, in January 2002, the Deputy Attorney General directed
    INS and other DOJ components to establish an Absconder Apprehension
    Initiative to locate and remove aliens who had been ordered removed but
    who had failed to leave the United States. Of the estimated 314,000 aliens
    with final orders of removal still at large in the United States, INS
    identified 5,046 who were from countries in which there has been an Al
    Qaeda terrorist presence or activity. To locate and apprehend these
    aliens, INS, in cooperation with the FBI, the Foreign Terrorist Tracking
    Task Force, and U. S. Attorneys, used INS address data and supplemented
    these data with address information from public source databases.
    According to a senior INS official, as of June 24, 2002, 4,334, or 86
    percent, of the 5, 046 alien absconders had not been apprehended, while
    712, or 14 percent, had been apprehended. It is possible that some of the
    aliens who had not been located may have left the country.

    These examples illustrate one inherent limitation of an address reporting
    requirement that relies on self reporting, as the reliability and
    completeness of the address information is dependent on the extent to
    which aliens comply with the reporting requirement. Those aliens who wish
    to remain illegally in the country would not likely comply as it could
    lead to their removal. In these examples, many aliens were not found even
    after INS*s address information was supplemented with address information
    from public source databases or schools, which could indicate that some
    aliens may be able to avoid detection.

    In addition, aliens* identifying and address information maintained by INS
    may not allow law enforcement officials to verify the identity of an alien
    being sought in cases where several aliens have the same name but are
    located at different addresses. Senior officials from the FBI, the Secret
    Service, and the Foreign Terrorist Tracking Task Force stressed the need
    to be able to verify an alien*s identity in order to determine the correct

    Page 14 GAO- 03- 188 Homeland Security

    address. These officials recommended that INS collect aliens* Social
    Security numbers (SSNs) in order to verify an alien*s identity. The law
    provides authority for the Attorney General to require aliens to provide
    their SSNs. 21 As shown in figure 3, INS formerly collected aliens* SSNs
    on the Form I- 53 as part of the alien address reporting program.

    21 8 U. S. C. 1304( f).

    Page 15 GAO- 03- 188 Homeland Security

    Figure 3: INS*s Alien Address Report Provided for Collecting Aliens* SSNs

    Source: INS.

    Page 16 GAO- 03- 188 Homeland Security

    When the program ended in 1981, 22 INS eliminated the Form I- 53 and did
    not revise the change of address form (Form AR- 11) to provide for aliens
    to report their SSNs. Collecting aliens* SSNs can help verify an
    individual*s identity and provide ready access to records, such as drivers
    licenses and financial records, that are searchable using SSNs. Having
    aliens* SSNs would also afford the federal government a better opportunity
    to locate aliens through automated databases that are searchable using
    SSNs. 23 Revising the Form AR- 11, to include a field that an alien can
    use to report a SSN or indicate that he or she does not have one, would
    provide one method for collecting this information.

    Lack of publicity, no enforcement of penalties for not filing a change of
    address notification, and inadequate procedures and controls for
    processing change of address notifications explain in part why INS cannot
    maintain current and reliable address information. Unreliable address
    information can also be attributed, in part, to aliens* failure to report
    changes of address to the INS. Since INS does little to actively publicize
    the requirement, aliens may not know of the requirement and may not file
    the notification. Alternatively, aliens may know of the requirement and
    choose not to file the notification. INS is not in a position to enforce
    the penalty, and aliens who knowingly do not file change of address
    notifications are not likely to face any adverse consequences. When aliens
    file the notification, INS may have unreliable address information because
    it lacks adequate procedures and controls to ensure that aliens* address
    information is processed properly so that all automated databases are
    updated.

    Aliens cannot comply with the requirement to file a change of address
    notification if they are not aware of the need to file or if they lack
    ready access to the form. To promote compliance with the change of address
    notification requirement, INS needs to make aliens aware that the
    requirement exists. However, according to INS officials, INS does not
    publicize the requirement, and INS does not inform aliens of the
    requirement when they enter the country. Furthermore, for those aliens who
    know about and seek to comply with the filing requirement, INS has not
    made the Form AR- 11 available at post offices as required by the Code

    22 INS collected but did not process alien address reports in 1981. 23 Not
    every alien is required to have an SSN. Lack of Publicity, No

    Enforcement of Penalties, and Inadequate Processing Procedures Contribute
    to INS*s Unreliable Address Information

    INS Does Not Publicize the Address Notification Requirement

    Page 17 GAO- 03- 188 Homeland Security

    of Federal Regulations. 24 According to a senior postal service official,
    INS*s change of address notification forms are not available in post
    offices because INS has not made arrangements with the U. S. Postal
    Service to provide and distribute the form. INS provides the Form AR- 11
    at its field offices, through its form centers, and on its Web site at
    www. ins. usdoj. gov.

    According to INS officials, INS is not in a position to place aliens in
    removal proceedings for failing to file a change of address notification
    because their address records are not maintained in a manner that will
    permit INS to certify that an alien has not complied with the law. Aliens
    may be aware of the requirement but may have little incentive to comply
    given that, based on our review of available data, INS does not appear to
    have enforced the removal penalty for noncompliance since the early 1970s.

    INS*s historical records from 1950 through 2002 do not provide the number
    of aliens who were placed in removal proceedings for failing to file a
    change of address notification. According to an official with the
    Executive Office for Immigration Review, its records date from 1988 and
    contain no cases where aliens were charged and placed in removal
    proceedings for failing to file a change of address notification. A review
    of federal cases and cases brought on appeal from the Executive Office for
    Immigration Review to the Board of Immigration Appeals indicates just a
    few instances where INS charged an alien with failure to file a
    notification of address or change of address in a removal proceeding. 25
    We also found a few cases where an alien was prosecuted for failure to
    give notice of an address or change of address. 26

    Senior INS investigators cited two reasons for INS*s lack of enforcement.
    The principal reason cited was that INS*s change of address records are

    24 8 C. F. R. 265.1. 25 For example, Matter of Winter, 12 I. and N. 638,
    (BIA, Feb. 9, 1968), Sevitt v. Del Guercio,

    150 F. Supp. 56 (S. D. Cal. 1957). 26 For example, U. S. v. Ushi Shiroma,
    123 F. Supp. 145 (D. Haw. 1954), U. S. v. Ginn, 222 F. 2d 289 (3rd Cir.
    1955). In addition, during the period of time when annual address report
    requirements were in effect, we identified several Board of Immigration
    Appeals and federal court cases relating to the enforcement of this
    provision. See U. S. v. Sacco, 428 F. 2d 264 (9th Cir. 1970), Patsis v.
    Immigration & Naturalization Service, 337 F2d 733 (8th Cir. 1964), Matter
    of S, 7 I. and N. 536, (BIA, Aug. 19, 1957), Matter of M, 5 I. and N. 216,
    (BIA, May 6, 1953), Matter of B, 5 I. and N. 692, (BIA, Mar. 2, 1954). INS
    Is Not in a Position To

    Enforce the Removal Penalty

    Page 18 GAO- 03- 188 Homeland Security

    not maintained in a manner that permits the agency to determine whether an
    alien has complied with the requirement. In order to place an alien in
    removal proceedings, INS is required to certify that the alien did not
    comply with the filing requirement by issuing a certificate of no record.
    According to a senior official with INS*s Office of General Counsel, if
    the certificate is to be legally sustainable, INS must be able to check
    all change of address records to be certain that the alien did not comply.
    However, INS lacks procedures and controls for maintaining complete and
    current change of address records. As a result, INS cannot determine
    whether an alien has complied and, therefore, cannot issue certificates of
    no record with the required degree of certainty. According to a 1944 INS
    report, INS was able to determine if an alien had complied with the change
    of address requirement because it maintained all address verification
    cards within the Alien Registration Division in headquarters. As a result,
    INS personnel could review the change of address records to determine if
    an alien had provided a change of address. If no change of address card
    for a specific alien was in INS*s centralized file, INS could determine
    that it did not have a record showing that the alien had reported a change
    of address. Senior INS records officials said that it would be impossible
    to reliably reconstruct years of change of address records in order to
    create a complete, current, and centralized system of address records
    because they could not be certain that some change of address records had
    not been lost, misplaced, misfiled, or destroyed.

    The second reason cited for INS*s lack of enforcement was that the
    agency*s internal policy discourages enforcement of this type of case.
    INS*s Operations Instructions provide internal guidance to its employees.
    The Operations Instructions governing the enforcement of the penalties for
    failure to comply with the reporting requirement states that noncompliance
    shall not normally serve as the sole basis for initiating prosecution or
    removal proceedings. 27 In contrast, under the law, noncompliance can be
    the sole basis for removal unless the alien can establish that the
    violation was not willful or was reasonably excusable. This internal
    policy has been in effect since March 8, 1972. According to a senior INS
    investigative official, this policy may have been established because INS
    could not reliably determine if an alien had or had not filed a change of
    address notification. Senior INS investigative officials said they
    interpret the instruction as preventing enforcement of the penalties.

    27 INS Operations Instructions 265. 1( a), TM 105 revised 11/ 17/ 82, p.
    4341.

    Page 19 GAO- 03- 188 Homeland Security

    When aliens do submit Forms AR- 11, INS must update its automated
    databases for the estimated 111,500 change of address notifications it
    receives annually. 28 However, INS lacks written procedures and automated
    controls to help ensure that reported changes of address are recorded in
    all automated databases.

    INS has at least 16 different automated databases that capture alien
    identity and address information. 29 For example, when an alien enters the
    country as a visitor, his or her name and intended address are to be
    recorded in the automated NIIS. If the alien subsequently applies to
    adjust his or her visa status, the application for adjustment is to be
    recorded in the automated Computer Linked Application Information
    Management System (CLAIMS 3). Consequently, an alien*s name and address
    may appear in more than one INS automated system. In this example, if the
    alien then moved and filed a change of address notification, INS would
    have to update both NIIS and CLAIMS 3 to ensure that the most current
    address information was recorded and that the address data across
    different automated databases was consistent. However, INS does not update
    all databases that contain alien address information and does not have the
    ability to update address information in NIIS.

    28 The Comptroller General*s standards for federal internal controls
    specify that control activities should be established to ensure
    transactions are completely and accurately recorded in a timely manner.

    29 Some of the automated databases that contain address information are:
    the Employment Authorization Document System; Marriage Fraud Amendment
    System; Computer Linked Application Information Management System 3 and 4;
    Deportable Alien Control System; Re- engineered Naturalization Application
    Casework System; Refugees, Asylum, and Parole System; Integrated Card
    Production System; Global Enrollment System; Arrival Departure Information
    System; Enforcement Case Tracking System; Student and Schools System;
    General Counsel Electronic Management System; Student Exchange Visitor
    Information System; Asylum Pre- screening System; and the Nonimmigrant
    Information System. INS Lacks Procedures and

    Controls Needed To Ensure Alien Address Information Is Complete

    INS Does Not Update Address Information in All Automated Databases

    Page 20 GAO- 03- 188 Homeland Security

    Figure 4: INS*s Processing of the Form AR- 11

    Source: GAO*s analysis.

    As shown in figure 4, INS*s prescribed change of address form is the Form
    AR- 11 that is to be used by all aliens to report their new address.
    Aliens are to complete a Form AR- 11 and mail it to INS headquarters in
    Washington, D. C. Upon receipt, INS staff determine where each alien*s
    file is located and forward the change of address card to the appropriate
    INS office. INS does not create paper- based files for most nonimmigrant
    aliens. Consequently, if INS headquarters staff cannot associate a Form
    AR- 11 with an alien*s file, the card is placed in a box and held until a
    technician can do further research on them. These cards are not forwarded
    to any INS office and are not used to update automated databases. The
    forms that are sent to district offices or INS*s National Records Center
    may not be used to update any database as there are no written procedures
    or automated controls that require or would provide for updating all
    databases. Change of address forms that are sent to the service centers
    are to be used to update the CLAIMS 3 database. No other databases that
    may also contain the alien*s address are updated.

    Databases to be updated

    Consults Central Index System

    to determine location of alien's file

    INS Headquarters

    Form AR- 11

    Front Back

    Box under desk (no file)

    None INS Records Center

    (inactive file) None Service Centers

    (pending benefit application) CLAIMS 3 District Offices

    (active file) None

    Page 21 GAO- 03- 188 Homeland Security

    Figure 5: INS*s Processing of Other Change of Address Forms

    Source: GAO*s analysis.

    I- 855 I- 104

    I- 697A INS location where

    form is to be sent

    Naturalization applicants Legalization and seasonal or replenishment

    agricultural worker applicants Alien's sponsors Aliens who are required

    by the Attorney General to register their address

    Unspecified Unspecified

    Asylum Offices

    I- 865 1- 800- 375- 5283 National Customer

    Service Center INS Service

    Centers

    Databases to be updated

    CLAIMS 3 CLAIMS 3

    CLAIMS 4 Re- egineered Naturalization Application Casework

    System ( RNACS) American Baptist

    Church Class Members

    INS Service Centers

    Refugees, Asylum and Parole (RAPS)

    and

    Page 22 GAO- 03- 188 Homeland Security

    In addition to the Form AR- 11, INS has four other change of address forms
    and a 1- 800 telephone number that are generally to be used by aliens who
    qualify or have applied for a specific immigration benefit. As shown in
    figure 5, the different forms are to be sent to INS*s service centers or
    asylum offices for processing. At the service centers and asylum offices,
    some but not all automated databases are required to be updated with the
    new address information. 30 Consequently, for those aliens who submit a
    change of address form, the consistency of their address information may
    vary between or among different INS automated databases.

    Irrespective of the change of address form that is used, all databases are
    not updated because INS does not have adequate written procedures or
    automated controls that require or provide for updating address
    information in all automated databases in which the alien*s name and
    address information appears. INS could establish automated controls such
    as a single automated address database from which other INS databases
    download alien address information. Alternatively, INS could establish
    automated linkages whereby updating address information in one automated
    database would automatically update address information in all databases.
    In either case, INS would need to record the date that the change of
    address was received in order to identify which address was most current
    and to determine whether an alien had filed a change of address within the
    required 10 days. Furthermore, INS*s written procedures do not require all
    databases with address information to be updated. INS has drafted but not
    yet implemented field office processing procedures for the Form AR- 11.
    These draft procedures do not require that all automated databases be
    updated.

    Potential alien address inconsistencies among INS databases may have
    hampered DOJ*s efforts to locate aliens. For example, if any of the 4,793
    aliens who were being sought for interviews by U. S. Attorneys had
    submitted changes of address, their new addresses would not have been
    recorded in the database that was used to search for their current
    addresses. These aliens* address information was provided to the Foreign
    Terrorist Tracking Task Force by INS from the NIIS database that is not
    updated when INS receives changes of address. Consequently, these 4,793
    aliens* address information was only as current as the date of their last
    entry into the United States. In a similar example, the Alien Absconder

    30 The majority of alien sponsors, who are to complete Form I- 865, are U.
    S. citizens. Only those sponsors who are aliens would need to have their
    addresses updated.

    Page 23 GAO- 03- 188 Homeland Security

    Initiative obtained address information on aliens who were ordered removed
    but who failed to depart the country from INS*s Deportable Alien Control
    System (DACS). As with the NIIS database, change of address information
    submitted to INS is not used to update address information in DACS. As a
    result, INS may have had current address information for some of these
    aliens, but was not able to provide it because all INS databases are not
    updated.

    In April 2002, INS established an Address Issues Task Force to review and
    assess how alien address information is processed. The task force
    identified numerous issues regarding the capture, processing, and
    recording of aliens* addresses. In May 2002, the task force prepared a
    White Paper that developed a concept of operations for handling address
    information and recommended a multi- phased strategy to improve
    operational efficiency. INS*s concept of operations includes capturing and
    electronically storing alien address information in a timely manner,
    providing access to appropriate personnel through a single facility that
    provides easy sharing and updating of address information, and providing
    clear direction to aliens concerning their responsibility to provide
    current address information. To implement this concept of operations, the
    task force recommended a short-, medium-, and long- term strategy
    including the designation of a lead agency official for address issues, a
    reduction in the number of change of address forms, making the updating of
    address information a priority, issuing a request for information to
    identify best practices, developing a single centralized address
    repository, and developing compliance policies to monitor the process.

    As of September 11, 2002, INS had accepted the task force*s
    recommendations. The Executive Associate Commissioner for Management was
    designated as the lead agency official for address issues, an Address
    Issues Office was established, and the Commissioner approved a Senior
    Level Advisory Group for address issues. INS has also taken the first
    steps toward establishing a centralized address repository and plans to
    implement the task force*s other recommendations. According to the
    Executive Associate Commissioner for Management, INS has received about
    700,000 change of address notifications since July 22, 2002, when the
    Attorney General announced the planned publication of a proposed rule
    that, in part, restated that aliens are required to notify INS of changes
    of address. To handle this unexpected deluge of change of address forms,
    INS has made arrangements with one of its contractors to electronically
    image and capture these forms. INS expects that the changes of address it
    has received will form the basis for a new central address repository.
    INS*s Actions to

    Improve Alien Address Reliability

    Page 24 GAO- 03- 188 Homeland Security

    The Congress has provided a statutory framework that requires aliens
    entering or residing in the United States to provide identifying and
    address information to INS. If aliens comply with the requirement, INS
    should be able to record and maintain an address history for each alien
    and locate the alien if needed. If an alien fails to comply with the
    change of address notification requirement, it can result in the alien*s
    prosecution for a misdemeanor and removal from the country.

    INS should have a practical, reliable system to ensure that it has current
    address information for aliens in the United States who are required to
    register and provide any address changes. However, INS has not taken steps
    to ensure that aliens know about their responsibility to notify INS of new
    addresses, does not have an adequate system for handling change of address
    forms it receives, cannot determine whether aliens are in compliance, and
    has not sought to enforce the removal penalty against violators.

    Since the events of September 11, 2001, it may be even more important for
    the federal government to know where aliens are located. Without this
    information, INS and law enforcement officials cannot quickly locate
    certain aliens who could help with the nation*s anti- terrorism efforts or
    who represent a national security threat. Because its alien address
    information is unreliable, INS has had numerous difficulties locating
    aliens who represented a national security threat or who could help with
    the nation*s anti- terrorism efforts.

    There are several steps that INS can take to begin the process of
    improving its system for maintaining alien address information. These
    involve implementing a publicity campaign to make more aliens aware of
    their responsibilities; making arrangements with the U. S. Postal Service
    to make forms available in post offices; establishing internal controls
    for ensuring that data from aliens* change of address forms are consistent
    in all automated databases and permit the issuance of a certificate of no
    record; and clarifying internal guidance to establish that noncompliance
    can be the sole basis for removal. INS has begun to take action to
    implement the Address Issues Task Force recommendations that will help to
    improve INS*s alien address information. As of October 2002, INS had
    designated a lead agency official for address issues. Furthermore, INS
    planned to reduce the number of change of address forms, make the updating
    of address information a priority, issue a request for information to
    identify best practices, develop a centralized address repository, and
    develop compliance policies to monitor the process. Conclusions

    Page 25 GAO- 03- 188 Homeland Security

    Taking these steps should help improve the reliability of INS*s address
    information, but they would not likely result in a system that would allow
    INS to locate all aliens. To a large extent, the accuracy and reliability
    of INS*s address information is contingent on aliens* compliance. It is
    reasonable to assume that INS will never be able to know where every alien
    is located at any point in time because some aliens who are in the United
    States illegally may not want INS to know where they are and, therefore,
    will not likely comply with the address reporting requirement. It is also
    likely that some aliens will not know about the requirement or may simply
    forget to file the forms. Moreover, for INS to maintain a reliable system
    that is based solely on alien self- reporting would seem an almost
    impossible task without a significant infusion of resources. There may be
    alternative cost- effective approaches for obtaining or assembling more
    complete and accurate alien address information, particularly for those
    aliens who do not comply with the change of address notification
    requirement, that meets the needs of INS and the law enforcement
    community. These approaches include, but are not limited to, conducting a
    nationwide alien address registration pursuant to the Attorney General*s
    discretionary authority, requesting legislative reinstatement of the alien
    address reporting program, matching INS address data with those of federal
    and/ or state agencies, and purchasing address information from
    commercially available sources. These approaches may expedite the
    acquisition and/ or reduce the cost of acquiring complete and reliable
    alien address information.

    In order to promote compliance with the change of address notification
    requirements through publicity and enforcement and to improve the
    reliability of its alien address data, we recommend that the Attorney
    General direct the INS Commissioner to:

     Identify and implement an effective means to publicize the change of
    address notification requirement nationwide. As part of its publicity
    effort, INS should make sure that aliens have information on how to comply
    with this requirement, including where information may be available and
    the location of change of address forms.

     Develop procedures for distributing change of address forms to include
    making arrangements with the U. S. Postal Service to provide for placing
    change of address forms in all post offices, as required by the Code of
    Federal Regulations. Recommendations

    for Executive Action

    Page 26 GAO- 03- 188 Homeland Security

     Establish written procedures and controls to ensure that alien address
    information in all automated databases is complete, consistent, accurate,
    and current.

     In connection with updating automated databases, establish procedures
    and controls that permit INS to verify receipts of change of address
    records and issue a certificate of no record, when aliens do not comply
    with the change of address notification requirement.

     Revise INS*s operating instructions to make clear that noncompliance
    with address reporting requirements can be the sole basis for removal, as
    provided at 8 U. S. C. 1306( b).

     Provide a field on change of address forms that an alien can use to
    report a SSN or indicate that they do not have one, with the appropriate
    notifications and safeguards required by law.

     Evaluate alternative approaches and their associated costs for obtaining
    or assembling complete alien address information, particularly for those
    aliens who do not comply with the change of address notification
    requirement.

    DOJ*s Acting Assistant Attorney General for Administration provided us
    with written comments on a draft of this report. In its comments, DOJ
    generally concurred with five of our seven recommendations and will
    proceed in accordance with them. Specifically, DOJ agreed to publicize
    address notification requirements; widely distribute change of address
    forms, which would include U. S. post offices; establish procedures and
    controls to permit INS to enforce the penalty provisions for noncompliance
    with the change of address notification requirement; revise INS*s internal
    operating instructions; and provide for aliens to report their Social
    Security number or indicate they do not have one on the change of address
    form. DOJ also described actions it has already taken and some of the more
    significant constraints in proceeding with the recommendations we
    proposed.

    The constraints DOJ cited included (1) the need to revise the change of
    address form and renegotiate an agreement with the U. S. Postal Service
    before distributing the forms; (2) the need to develop a comprehensive
    address file system to ensure that record keeping will support removal
    proceedings, and (3) the likelihood that revising internal operating
    instructions will not result in additional criminal prosecutions for
    failing to Agency Comments

    and Our Evaluation

    Page 27 GAO- 03- 188 Homeland Security

    file a change of address notice because U. S. Attorneys generally decline
    to prosecute minor offenses.

    We recognize that there are practical and time sequential considerations
    associated with implementing our recommendations; however, these
    considerations should not obviate the need to improve the government*s
    ability to locate aliens by increasing the reliability of INS*s alien
    address information. We agree that change of address forms should be
    revised before they are distributed and that an agreement with the U. S.
    Postal Service needs to be reached before the forms can be placed in post
    offices. We further agree that INS*s alien address records need to be
    complete, consistent, accurate, and current before they can reasonably be
    expected to support removal proceedings. Also, we would not expect an
    increase in criminal prosecutions for failing to file a change of address
    notice. However, INS investigative officials viewed the revision of INS*s
    internal operating instructions as a necessary condition precedent to
    placing noncomplying aliens in removal proceedings. We view these
    considerations not as constraints but as reasonable steps that must be
    taken to implement our recommendations.

    DOJ did not comment on our recommendations to (1) establish written
    procedures and controls to ensure that alien address information in all
    automated databases is complete, consistent, accurate, and current or (2)
    evaluate alternative approaches and their associated costs for obtaining
    or assembling complete alien address information, particularly for those
    aliens who do not comply with the change of address notification
    requirement.

    DOJ provided us with technical comments, which we incorporated in the
    report as appropriate. DOJ*s comments are reproduced in appendix III.

    We are sending copies of the report to the Chairmen and Ranking Minority
    Members of the Senate and House Committees on the Judiciary; the Chairman
    and Ranking Minority Member of the Subcommittee on Immigration, Senate
    Committee on the Judiciary; the Ranking Minority Member of the
    Subcommittee on Immigration and Claims, House Committee on the Judiciary;
    the Attorney General; the Commissioner of INS; the Director of the FBI;
    the Director of the Secret Service; the Director of the Foreign Terrorist
    Tracking Task Force; the Director of the Office of Management and Budget;
    the Director of the Office of Homeland Security; and other interested
    parties. We will also make copies available

    Page 28 GAO- 03- 188 Homeland Security

    to others upon request. In addition, the report will be available at no
    charge on the GAO Web site at http:// www. gao. gov.

    If you or your staffs have any questions about this report, please contact
    Evi Rezmovic or me at (202) 512- 8777. Key contributors to this report are
    listed in appendix IV.

    Richard M. Stana Director, Justice Issues

    Appendix I: Scope and Methodology Page 29 GAO- 03- 188 Homeland Security

    To determine the statutory framework that requires aliens to report their
    addresses and any changes, and to provide historical background
    information on prior alien registration requirements and programs, we
    reviewed laws, regulations, and Immigration and Naturalization Service
    (INS) publications and reports, including 8 U. S. C. 1301- 1306 from 1940
    to 2002, 8 C. F. R. 264- 5; INS Annual Reports from 1941 to 1982; the
    Administrative History of the INS During World War II; a 1943 Report to
    the Attorney General on Alien Registration; a 1944 Report of Survey of the
    Alien Registration Division; the INS Monthly Review from May 1944 to April
    1952; the I& N Reporter from January 1956 to Winter 1977- 1978 1 ; the INS
    Information Bulletin from August 22, 1951, through January 28, 1953; INS*s
    Operating Instructions from April 19, 1954, to January 2002; and INS*s
    internal publicity and operation files for the Alien Address Report
    Program for 1977 through 1982. We reviewed prior reports on alien address
    information issued by the Congressional Research Service, the Department
    of Justice (DOJ) Office of the Inspector General, and us. We interviewed a
    representative of the U. S. Postal Service to determine if change of
    address forms were available in post offices. We also observed and
    documented the processing of change of address forms in INS headquarters,
    reviewed documentation from a 1995 INS task force that was responsible for
    identifying ways to improve the change of address program, and interviewed
    INS records and computer managers and senior representatives of the
    Executive Office for U. S. Attorneys.

    To determine whether INS*s alien address information can be used to
    reliably locate aliens in the United States, we reviewed documentation and
    interviewed senior investigators in INS*s National Security Unit and the
    San Diego District and senior representatives from the Federal Bureau of
    Investigation (FBI), the Secret Service, and the Foreign Terrorist
    Tracking Task Force. We did not independently review the accuracy and
    reliability of INS*s databases, nor did we independently review the task
    forces* attempts to locate aliens. We also did not independently verify
    the data provided to us by (1) INS on the numbers of alien absconders who
    were sought and apprehended, and (2) the Executive Office for U. S.
    Attorneys on the numbers of nonimmigrants who were sought, had departed
    the country, or who were located and interviewed.

    1 In 1976, the I& N Reporter was renamed the *INS Reporter.* Appendix I:
    Scope and Methodology

    Appendix I: Scope and Methodology Page 30 GAO- 03- 188 Homeland Security

    To identify the principal factors affecting the reliability of INS*s alien
    address information, we developed audit findings by analyzing the
    information we obtained during the review.

    We performed our work from October 2001 through September 2002 in
    accordance with generally accepted government auditing standards.

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 31 GAO- 03- 188 Homeland Security

    From 1940 through 1944, INS*s Alien Registration Division administered the
    registration provisions of the Alien Registration Act of 1940. The act
    required all aliens, except for foreign government officials and their
    families, to be registered and fingerprinted. In 1950, the Congress
    established an annual address reporting requirement for resident aliens
    that was expanded in 1952 to cover all aliens who were required to be
    registered. INS assigned responsibility for the Alien Address Report
    Program to the Records Division, which administered the program until it
    was ended in 1981.

    In implementing the Alien Registration Act of 1940, INS sought to create
    an inventory of aliens in the United States to include their locations and
    to maintain current address information. Beginning August 27, 1940, INS,
    in cooperation with the Post Office Department, registered and
    fingerprinted aliens in the United States who were required to register.
    As of December 31, 1940, 4, 921,452 aliens had been registered. Aliens in
    the United States were required to submit (1) an official registration
    form, which contained information such as name, country of birth, address,
    occupation, and immigration status, and (2) a fingerprint card. INS
    reviewed the registration documents and if they were found acceptable, a
    registration receipt card bearing the individual number, name, and address
    of the registrant was issued and mailed. Fingerprint cards were forwarded
    to the FBI to identify aliens with criminal records. INS considered the
    requirement that resident aliens notify of a change of address within 5
    days to be important because it provided the only statutory method for
    keeping these aliens* locations current. As of February 1, 1943, INS
    received about 1,850,000 notifications of changes of address. In a 1943
    report to the Attorney General on alien registration, the INS Commissioner
    reported that the information collected by the Alien Registration Program
    had been essential to preserving the nation*s internal security.

    In 1944, the Commissioner requested that a survey of the Alien
    Registration Division be undertaken to determine if the division*s
    functions should be integrated into the central office or should continue
    to be maintained separately. The survey concluded that it would be more
    efficient to integrate the division*s functions into the central office,
    and accordingly, the division was eliminated on December 31, 1944. One of
    the reasons cited for eliminating the division was the inability to
    maintain current address information for aliens who were in the country.
    According to the survey report, an estimated 5 to 40 percent of the
    registered aliens had moved without filing changes of address as required,
    and the U. S. Appendix II: An Historical Overview of INS*s

    Alien Registration Programs, 1940- 1981 The Alien Registration Program of
    1940

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 32 GAO- 03- 188 Homeland Security

    Attorneys had refused to prosecute these violations. In addition, the act
    did not require that aliens* deaths and departures be reported to the
    Alien Registration Division and many were not reported. As a result, the
    survey concluded that it was impossible to maintain a file of aliens*
    address cards with any degree of accuracy.

    Prior to 1950, INS had reported that aliens* address information, gathered
    during the 1940 registration, was out of date because aliens were not
    filing change of address notices, as required. In 1950, the Congress
    required all resident aliens in the United States on January 1st to report
    their addresses to INS. In addition, resident aliens were still required
    to file a change of address notice if they moved. INS established the
    Alien Address Report Program. INS created Alien Address Report Cards (Form
    I- 53) and placed them in about 42,000 U. S. Post Offices and 450
    Immigration offices nationwide, so aliens could report their addresses to
    INS. In 1951, nearly 2.4 million resident aliens reported. Of that number,
    INS identified over 50,000 individual aliens for whom INS had no record.
    These cases were referred to INS field offices for investigation. INS also
    found a fairly high incidence of noncompliance by comparing the address
    reports to alien records at the central office. INS referred at least
    120,000 noncompliance cases to its field offices for investigation. By
    1980, aliens who annually reported their addresses to INS had increased to
    nearly 5.4 million. 1 Figure 6 shows the number of annual address reports
    INS received between 1951 and 1980, the last year that complete data were
    available before the annual address reporting requirement was eliminated.

    1 INS received annual address reports in 1981, but did not process them.
    The Alien Address

    Report Program of 1950

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 33 GAO- 03- 188 Homeland Security

    Figure 6: Number of Aliens Who Reported During the Alien Address Report
    Program, 1951- 1980

    Note: The 1952 data are approximate. Source: GAO*s analysis of INS*s data.

    According to congressional and internal INS documentation, the program was
    eliminated (1) to save between $542,000 and $800,000, (2) because the
    address information was used primarily for statistical purposes, and (3)
    because the Office of Management and Budget wanted to reduce the public*s
    annual reporting burden by about 470,000 person- hours.

    5.4 5.1 5 5 4.8 4.7

    4.6 4.6 4.4 4.2 4.2 4 3.9

    3.7 3.5 3.4 3.3 3.2

    3.1 3 3 2.9 2.9 2.8 2.6 2.5 2.5 2.5 2.4 2.4

    0 1

    2 3

    4 5

    6 1951 1953 1955 1957 1959 1961 1963 Millions

    1965 1967 1969 1971 1973 1975 1977 1979 1980 Years

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 34 GAO- 03- 188 Homeland Security

    Both the Alien Registration Program and the Alien Address Report Program
    shared common program elements, including (1) publicizing the program
    requirements nationwide, (2) centralizing management responsibility, (3)
    centralizing nationwide alien address information which provided the
    capability to conduct searches, and (4) investigating cases of alleged
    violations of the requirements to file a change of address notification
    and/ or an annual address report.

    INS had about 2 months to publicize the registration requirements from the
    time the law was enacted on June 28, 1940, until registration commenced on
    August 27, 1940. In congressional testimony, the Director of the Alien
    Registration Division said that government and private organizations
    conducted an educational campaign to publicize the registration
    requirements. Furthermore, according to the Director, the education effort
    was deemed to be effective because most aliens were found to have
    registered. In many cases, those who failed to register misunderstood the
    requirement.

    For the Alien Address Report Program, INS undertook extensive publication
    of the filing requirements each year. Through a memorandum of
    understanding with the U. S. Postal Service, INS placed forms and signs in
    about 42,000 post offices nationwide to instruct aliens about the annual
    address reporting requirement. In addition, as shown in figure 7, the Post
    Office Department cancelled postage stamps with a cancellation that read,
    *Aliens must report their addresses during January.* Further, INS placed
    public service advertisements on radio and television to remind aliens of
    the annual filing requirement. INS also prepared a poster to remind aliens
    of the reporting requirement and placed it in railroad, airline, and bus
    terminals. According to an INS official who worked in the program, the
    nationwide publicity was responsible for ensuring that there was broad
    public awareness that aliens were required to report their addresses to
    INS during January of each year. Alien Registration

    Programs Shared Common Program Elements

    Program Requirements Were Publicized Nationwide

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 35 GAO- 03- 188 Homeland Security

    Figure 7: The Post Office Department Cancelled Stamps with a Reminder That
    Aliens Must Report Their Addresses

    Note: This is a copy of the original envelope; however, the name and
    return address have been redacted for privacy reasons.

    Source: Provided courtesy of John Hotchner, Past President, American
    Philatelic Society.

    XXXXXXXXXXXXXXXXXXXXXXXXXXXXXX XXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
    XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
    XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 36 GAO- 03- 188 Homeland Security

    Figure 8: INS*s 1953 Sign Placed in Post Offices Instructing Aliens to
    Report Their Addresses

    Source: GAO photograph of the original in the INS History Office Library.

    To administer the provisions of the Alien Registration Act, INS
    established the Alien Registration Division, which was responsible for
    managing all aspects of the alien registration program. The four principal
    objectives of the division were to

     develop and maintain an index of information on aliens,  verify the
    accuracy of information provided by aliens,  maintain the currency of the
    records, and  produce requested or required data. The Alien Registration
    Division received and processed the forms required by the act.
    Registration forms were inspected upon arrival and, if they were complete,
    they were numbered, coded, and microfilmed for Program Responsibility

    and Data Were Centralized

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 37 GAO- 03- 188 Homeland Security

    preservation. On December 31, 1944, the Alien Registration Division was
    disbanded, and the alien registration files were forwarded to INS*s field
    offices.

    In 1950, when INS established the Alien Address Report Program, it placed
    responsibility for administering the program in the office with
    responsibility for records administration. This office, the Records,
    Administration and Information Branch, was responsible for receiving and
    processing all annual reports and responding to inquiries from within and
    outside the agency. By 1978, INS had automated the processing of the
    annual address reports using a contractor.

    Requiring all aliens to register in 1940 was intended to enable the
    government to obtain comprehensive and detailed information on all
    noncitizens in the United States for the first time in the history of the
    nation. The nationwide information could be searched using different
    criteria and was used by INS for purposes such as conducting background
    checks on naturalization applicants. According to an internal INS report,
    prior to alien registration, INS was hampered in these investigations by a
    lack of sufficient information. The alien registration information
    remedied this situation. In addition to using the data for their own
    purposes, INS began receiving war time requests for information from other
    federal agencies. However, before information could be released, it
    required the approval of the Attorney General as the act required that all
    registration information be kept confidential.

    Examples of the requests that INS received and were granted by the
    Attorney General are shown in table 1. Alien Registration

    Information Was Searchable

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 38 GAO- 03- 188 Homeland Security

    Table 1: Examples of Requests for Alien Registration Data INS Approved and
    Their Intended Use

    Requesting agency Intended use

    Treasury Department Freeze funds of aliens with enemy nationalities
    Federal Communications Commission Identify licensed radio operators Civil
    Aeronautics Board Identify alien pilots Selective Service System Identify
    aliens who failed to register for

    the draft War and Navy Departments Identify aliens applying for employment

    in wartime industries Office of Export Control and Defense Board Identify
    aliens engaged in exporting Securities and Exchange Commission Identify
    aliens in violation of securities

    acts Note: Information on the date the specific request was made and the
    specific information that was requested were not available.

    Source: GAO*s analysis of INS data.

    However, all requests for alien registration data were not granted. Table
    2 shows some examples of requests that were denied. INS documentation does
    not provide the reasons for the denials.

    Table 2: Examples of Requests for Alien Registration Data INS Denied and
    Their Intended Use

    Requester Intended use

    Welfare organizations Citizenship and nationality of persons applying for
    aid Relatives Locate missing relatives who were aliens Creditors Locate
    alien debtors Attorneys Divorce and/ or custody proceedings Prisoners of
    war Locate relatives

    Note: Information on the date the specific request was made and the
    specific information that was requested were not available.

    Source: GAO*s analysis of INS data.

    In cases where relatives were trying to find an alien, INS would notify
    the alien that his or her relatives were seeking to locate him or her.
    They would not release the alien*s location to the relatives. In a 1943
    report to the Attorney General on the alien registration program, the INS
    Commissioner said,

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 39 GAO- 03- 188 Homeland Security

    *Primarily intended as a safeguard, the Act has made it possible to
    provide war agencies and agencies concerned with the internal security of
    the nation with the specific and essential information about individual
    aliens and groups of aliens. At the same time, it has afforded the
    Government an opportunity to gather basic sociological data about our
    alien population that has long been needed for legislative and educational
    purposes.*

    As with the 1940 alien registration program, INS centrally received and
    processed the alien address report program information. However, where the
    1940 registration program sorted punched cards using tabulation equipment,
    the 1950 program eventually established an automated database and entered
    nationwide address- related information into it, thus enabling INS to
    readily conduct searches. INS collected information that was used by
    agencies to locate aliens, identify alien migration patterns, develop
    investigative leads, estimate the naturalization workload, correspond with
    aliens, and plan resource allocation. As shown in table 3, INS also
    received requests from the Congress and federal, state, and local
    government agencies.

    Table 3: Examples of Requests for Alien Address Report Program Data INS
    Approved and the Intended Uses

    Requesting agency Intended use

    Congress About 100 requests per year for alien data State and local
    governments Requests for alien data Department of Justice: Office of
    Special Investigations FBI Drug Enforcement Administration Department of
    Treasury:

    Customs Service Secret Service

    Locate aliens Department of State:

    Cuban/ Haitian Task Force Allocate state refugee funding, identify
    unaccompanied minors, and validate and correct refugees* files Department
    of Health and Human Services:

    Office of Refugee Resettlement Allocate state and local refugee funding
    Department of Commerce:

    Bureau of the Census Estimate illegal alien population, identify Cuban
    refugee locations, and track alien migration

    Note: Information on the date the specific request was made and the
    specific information that was requested were not available.

    Source: GAO*s analysis of INS data.

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 40 GAO- 03- 188 Homeland Security

    In 1941, INS organized the Special Inspections Division to enforce the
    Alien Registration Act of 1940. The Division was responsible, among other
    things, for identifying aliens who had failed to register or report a
    change of address. However, enforcing the change of address provisions
    proved difficult for INS because U. S. Attorneys generally declined to
    prosecute the cases.

    One potential method used by INS investigators to identify possible
    violators of the change of address requirement involved mail that was
    returned to INS by the Post Office Department. For example, INS mailed
    registration receipt cards to aliens who had submitted acceptable
    registration documents. Of about 5 million cards that were sent out,
    480,000 were returned by the Post Office. Following a second mailing,
    160,000 of the 480,000 were again returned by the Post Office. The 160,000
    aliens, whose cards were returned, could have been investigated as
    potential violators of the change of address filing requirement. INS
    identified many violations of the change of address requirement; however,
    U. S. Attorneys generally refused to prosecute the offenders. According to
    the INS Commissioner in a letter to the Bureau of the Budget at that time,

    *Although a penalty is provided for failure to notify change of address,
    practically every United States Attorney has refused to prosecute unless
    it is shown that such failure was willful. As a matter of fact, the
    majority of the United States Attorneys have issued blanket waivers of
    prosecution in these cases and have requested this Service not to present
    them unless it is shown that the violation was willful. During the
    calendar year 1943, some 7,488 investigations were conducted of aliens who
    failed to notify change of address; 4,287 such cases were presented to the
    United States Attorneys, and only 19 convictions were obtained. It is not
    possible to make an accurate estimate of how many registrants have failed
    to report changes of address.* 2 According to the 1944 Survey of the Alien
    Registration Division to the INS Commissioner, INS staff estimated that
    between 5 and 40 percent of the registered aliens had not notified INS of
    their new address.

    INS does not appear to have enforced the removal penalty for noncompliance
    since the early 1970s. INS*s historical records from 1950 to 2002 do not
    identify the number of aliens who were placed in removal proceedings for
    failing to file a change of address notification. According to an official
    with Executive Office for Immigration Review, their records date from 1988
    and contain no cases where aliens were charged and

    2 *Survey of the Alien Registration Division,* letter of Commissioner
    Harrison to E. B. Wilber, Bureau of the Budget, March 6, 1944. Change of
    Address and

    Annual Address Reporting Violations Were Investigated

    Appendix II: An Historical Overview of INS*s Alien Registration Programs,
    1940- 1981

    Page 41 GAO- 03- 188 Homeland Security

    placed in removal proceedings for failing to file a change of address
    notification. A review of federal cases and cases brought on appeal from
    the Executive Office for Immigration Review to the Board of Immigration
    Appeals indicates just a few instances where INS charged an alien with
    failure to file a notification of address or change of address in a
    removal proceeding. 3 We also found a few cases where an alien was
    prosecuted for failure to give notice of an address or change of address.
    4

    3 For example, Matter of Winter, 12 I. and N. 638, (BIA, Feb. 9, 1968),
    Sevitt v. Del Guercio,

    150 F. Supp. 56 (S. D. Cal. 1957) 4 For example, U. S. v. Ushi Shiroma,
    123 F. Supp. 145 (D. Haw. 1954), U. S. v. Ginn, 222 F. 2d 289 (3rd Cir.
    1955). In addition, during the period of time when annual address report
    requirements were in effect, we identified several BIA and federal court
    cases relating to the enforcement of this provision. See U. S. v. Sacco,
    428 F. 2d 264 (9th Cir. 1970), Patsis v. Immigration & Naturalization
    Service, 337 F2d 733 (8th Cir. 1964), Matter of S, 7 I. and N. 536, (BIA,
    Aug. 19, 1957), Matter of M, 5 I. and N. 216, (BIA, May 6, 1953), Matter
    of B, 5 I. and N. 692, (BIA, Mar. 2, 1954).

    Appendix III: Comments from the Department of Justice

    Page 42 GAO- 03- 188 Homeland Security

    Appendix III: Comments from the Department of Justice

    Appendix III: Comments from the Department of Justice

    Page 43 GAO- 03- 188 Homeland Security

    Appendix III: Comments from the Department of Justice

    Page 44 GAO- 03- 188 Homeland Security

    Appendix III: Comments from the Department of Justice

    Page 45 GAO- 03- 188 Homeland Security

    Appendix IV: GAO Contacts and Staff Acknowledgments

    Page 46 GAO- 03- 188 Homeland Security

    Richard M. Stana (202) 512- 8777 Evi L. Rezmovic (202) 512- 8777

    In addition to the above, James M. Blume, Leah S. DeWolf, Jan B.
    Montgomery, Ann H. Finley, Elizabeth Anne Laffoon, Leo M. Barbour, Mary
    Catherine Hult, Kimberly A. Hutchens, Maureen R. Shields and Jay Jennings
    made key contributions to this report. Appendix IV: GAO Contacts and Staff

    Acknowledgments Contacts Acknowledgments

    (440095)

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