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entitled 'Homeland Security: INS Cannot Locate Many Aliens Because It 
Lacks Reliable Address Information' which was released on November 21, 
2002.



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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:



Homeland Security:



GAO-03-188:



Contents:



Letter:



Results in Brief:



Background:



Congress Provided the Framework for INS to Locate Aliens:



INS’s Alien Address Records Are Not Reliable:



Lack of Publicity, No Enforcement of Penalties, and Inadequate 

Processing Procedures Contribute to INS’s Unreliable Address 

Information:



INS’s Actions to Improve Alien Address Reliability:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: Scope and Methodology:



Appendix II: An Historical Overview of INS’s Alien Registration 
Programs, 

1940-1981:



The Alien Registration Program of 1940:



The Alien Address Report Program of 1950:



Alien Registration Programs Shared Common Program Elements:



Appendix III: Comments from the Department of Justice:



Appendix IV: GAO Contacts and Staff Acknowledgments:



Contacts:



Acknowledgments:



Tables:



Table 1: Examples of Requests for Alien Registration Data INS Approved 

and Their Intended Use:



Table 2: Examples of Requests for Alien Registration Data INS Denied 

and Their Intended Use:



Table 3: Examples of Requests for Alien Address Report Program Data INS 

Approved and the Intended Uses:



Figures:



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



Figure 2: Requirements and Penalties for Registration and Address 

Reporting from June 28, 1940 to June 28, 2002:



Figure 3: INS’s Alien Address Report Provided for Collecting Aliensí 

SSNs:



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



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



Figure 6: Number of Aliens Who Reported During the Alien Address Report 

Program, 1951-1980:



Figure 7: The Post Office Department Cancelled Stamps with a Reminder 

That Aliens Must Report Their Addresses:



Figure 8: INS’s 1953 Sign Placed in Post Offices Instructing Aliens to 

Report Their Addresses:



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:



United States General Accounting Office:



Washington, DC 20548:



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.[Footnote 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 

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.[Footnote 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.



Results in Brief:



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.



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 anti-

terrorism 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 

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.



Background:



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.[Footnote 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 I-94 departure records, and as a result, INS could 

not identify all of the aliens who had left the country.[Footnote 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.



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



[See PDF for image]



Source: INS.



[End of figure]



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[Footnote 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.

[Footnote 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.[Footnote 7] The Congress has required that the entry-

exit system be implemented at airports and seaports by December 31, 

2003.



Congress Provided the Framework for INS to Locate Aliens:



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.[Footnote 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 self-defense 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.”[Footnote 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.[Footnote 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.[Footnote 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.[Footnote 12] In 1981, 

the Congress eliminated the requirements that aliens annually report 

their addresses and that nonimmigrants report their address every 90 

days.[Footnote 13] 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.[Footnote 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.[Footnote 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.[Footnote 16]



Figure 2: Requirements and Penalties for Registration and Address 

Reporting from June 28, 1940 to June 28, 2002:



[See PDF for image]



[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.



[End of figure]



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.[Footnote 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.[Footnote 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.[Footnote 

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.



INS’s Alien Address Records Are Not Reliable:



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.[Footnote 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 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 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.[Footnote 21] As shown in 

figure 3, INS formerly collected aliens’ SSNs on the Form I-53 as part 

of the alien address reporting program.



Figure 3: INSís Alien Address Report Provided for Collecting Aliens’ 

SSNs:



[See PDF for image] 



Source: INS.



[End of figure]



When the program ended in 1981,[Footnote 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.[Footnote 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, and Inadequate 

Processing Procedures Contribute to INS’s Unreliable Address 

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.



INS Does Not Publicize 

the Address Notification Requirement:



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 of Federal Regulations.[Footnote 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.



INS Is Not in a Position To Enforce the Removal Penalty:



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.[Footnote 25] We also found a few cases where an alien was 

prosecuted for failure to give notice of an address or change of 

address. [Footnote 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 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.[Footnote 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.



INS Lacks Procedures and Controls Needed To Ensure Alien Address 

Information Is Complete:



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.[Footnote 28] However, INS lacks written procedures 

and automated controls to help ensure that reported changes of address 

are recorded in all automated databases.



INS Does Not Update Address Information in All Automated Databases:



INS has at least 16 different automated databases that capture alien 

identity and address information.[Footnote 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.



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



[See PDF for image] 



Source: GAO’s analysis.



[End of figure]



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.



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



[See PDF for image]



Source: GAO’s analysis.



[End of figure]



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.[Footnote 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 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.



INS’s Actions to Improve Alien Address Reliability:



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.



Conclusions:



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.



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.



Recommendations

for Executive Action:



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.



* 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.



Agency Comments and Our Evaluation:



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 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 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



Signed by Richard M. Stana



[End of section]



Appendix I: Scope and Methodology:



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[Footnote 31]; 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.



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.



[End of section]



Appendix II: An Historical Overview of INS’s Alien Registration 

Programs, 1940-1981:



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.



The Alien Registration Program of 1940:



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. 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.



The Alien Address Report Program of 1950:



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.[Footnote 32] 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.



Figure 6: Number of Aliens Who Reported During the Alien Address Report 

Program, 1951-1980:



Note: The 1952 data are approximate.



[See PDF for image]



Source: GAO’s analysis of INS’s data.



[End of figure]



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.



Alien Registration Programs Shared Common Program Elements:



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.



Program Requirements Were Publicized Nationwide:



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.



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.



[See PDF for image]



Source: Provided courtesy of John Hotchner, Past President, American 

Philatelic Society.



[End of figure]



Figure 8: INS’s 1953 Sign Placed in Post Offices Instructing Aliens to 

Report Their Addresses:



[See PDF for image]



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

Library.



[End of figure]



Program Responsibility and Data Were Centralized:



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 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.



Alien Registration Information Was Searchable:



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.



Table 1: Examples of Requests for Alien Registration Data INS Approved 

and Their Intended Use:



Requesting agency: Treasury Department; Intended use: Freeze funds of 

aliens with enemy nationalities.



Requesting agency: Federal Communications Commission; Intended use: 

Identify licensed radio operators.



Requesting agency: Civil Aeronautics Board; Intended use: Identify 

alien pilots.



Requesting agency: Selective Service System; Intended use: Identify 

aliens who failed to register for the draft.



Requesting agency: War and Navy Departments; Intended use: Identify 

aliens applying for employment in wartime industries.



Requesting agency: Office of Export Control and Defense Board; Intended 

use: Identify aliens engaged in exporting.



Requesting agency: Securities and Exchange Commission; Intended use: 

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.



[End of table]



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: Welfare organizations; Intended use: Citizenship and 

nationality of persons applying for aid.



Requester: Relatives; Intended use: Locate missing relatives who were 

aliens.



Requester: Creditors; Intended use: Locate alien debtors.



Requester: Attorneys; Intended use: Divorce and/or custody proceedings.



Requester: Prisoners of war; Intended use: 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.



[End of table]



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,



“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: Congress; Intended use: About 100 requests per year 

for alien data.



Requesting agency: State and local governments; Intended use: Requests 

for alien data.



Requesting agency: Department of Justice: Office of Special 

Investigations; FBI; Drug Enforcement Administration; Department of 

Treasury; Customs Service; Secret Service; Intended use: Locate aliens.



Requesting agency: Department of State: Cuban/Haitian Task Force; 

Intended use: Allocate state refugee funding, identify unaccompanied 

minors, and validate and correct refugees’ files.



Requesting agency: Department of Health and Human Services: 

Office of Refugee Resettlement; Intended use: Allocate state and local 

refugee funding.



Requesting agency: Department of Commerce: Bureau of the Census; 
Intended 

use: 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.



[End of table]



Change of Address and Annual Address Reporting Violations Were 

Investigated:



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.”[Footnote 33] 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 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.[Footnote 34] We also found a few cases 

where an alien was prosecuted for failure to give notice of an address 

or change of address.[Footnote 35]



[End of section]



Appendix III: Comments from the Department of Justice:



U.S. Department of Justice:



Washington, D.C. 20530:



November 7, 2002:



Mr. Richard M. Stana, Director, Justice Issues, Tax Administration and 

Justice Team, U.S. General Accounting Office:



441 G Street, N. W. Washington, D C. 20548:



Dear Mr. Stana:



On October 9, 2002, the General Accounting Office (GAO) provided the 

Department of Justice (DOJ) copies of its draft report entitled 

“Homeland SECURITY: INS Cannot Locate Many Aliens Because It Lacks 

Reliable Address Information.” The Immigration and Naturalization 

Service (INS) is pursuing vigorously a long-range strategy to manage 

alien addresses. These efforts include establishing an Address Issues 

Task Force, designating a specific unit to handle address issues, and 

conducting a study of the operational and functional address needs of 

the INS in order to develop and maintain an address repository of alien 

addresses. While the INS and the Department generally concur with the 

report recommendations and will proceed in accordance with them, we 

would like to describe actions already taken and discuss some of the 

more significant constraints in proceeding with the recommendations as 

proposed.



Recommendation: Identify and implement an effective means to publicize 

the change of address notification requirements nationwide. As part of 

its publicity effort, INS should make sure aliens have notification on 

how to comply with this requirement, including where information is 

available and the location of change of address forms.



The INS concurs with this recommendation. As previously discussed with 

GAO representatives, INS’ long-term strategy includes a nation-wide 

effort to publicize the address reporting requirements.



The GAO draft report, however, does not appear to recognize past 

efforts by the Department of Justice and the INS to publicize the 

change of address requirements of the Act. For example, the GAO draft 

report points to the NPRM published by the Department of Justice on 

June 13, 2002, as indicative of the need for nation-wide publicity of 

these requirements. The proposed rule:



establishing the National Security Entry - Exit Registration System set 

out the address notification requirements. 67 FR 40581, 40583 (June 13, 

2002). The final rule, promulgated on August 12, 2002, reiterated this 

requirement and further explained the requirements and how those 

requIrements related to the National Security Entry-Exit Registration 

System 67 FR 52584, 52587-52588 (Aug. 12, 2002). These points were 

reiterated in the Attorney General’s implementing Notices published 

pursuant to the final rule.



Moreover, the Attorney General has promulgated a specific NPRM to 

ensure that aliens are aware of and comply with the change of address 

notification requirements in light of a Board of Immigration Appeals 

decision that pointed out the shortcomings of the current system. 67 FR 

48818 (July 26, 2002). This proposed rule would amend the regulations 

of the INS by requiring every alien who is applying for immigration 

benefits to acknowledge having received notice that he or she is 

required to provide a valid current address to the Service, including 

any change of address within 10 days of the change; that the Service 

will use the most recent address provided by the alien for all 

purposes, including the service of a Notice to Appear if the Service 

initiates removal proceedings; and, if the alien has changed address 

and failed to provide the new address to the Service, that the alien 

will be held responsible for any communications sent to the most recent 

address provided by the alien. This rule will satisfy the requirements 

for advance notice to the alien of the obligation to provide a current 

address to the Service, and of the consequences that may result for 

failure to do so, including the entry of an in absentia removal order 

against the alien in accordance with 8 CFR 3.26 if the alien fails to 

appear at a removal hearing. This advance notice will avoid the kind of 

problems that have arisen in the past where aliens have failed to 

provide a new address. See Matter of G-Y-R-, 23 I&N Dec. 181 (BIA 

2001). The INS is currently analyzing the comments received on this 

NPRM, but the type and number of comments received clearly indicates 

that this NPRM and other actions already taken, have made the 

requirements of the law very clear to the immigration community.



In each of these instances, both the Department and the INS have 

publicized the requirements that aliens report changes of address to 

the INS, not only through official statements and press releases 

directed to a wide range of media outlets, but through community 

relations efforts directed to the specific immigrant populace. We 

believe that the GAO report would be more informative if it reflected 

more of the efforts that have already been undertaken.



Recommendation: 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 CFR.



The INS generally concurs with this recommendation. As previously 

discussed with GAO representatives, INS’ long-term strategy includes 

wide distribution of change of address forms and the submission of 

forms through the Internet and other media. INS will examine all 

possible distribution sources, including the United States Postal 

Service.



GAO should understand that the requirements of the law have been widely 

publicized in recent months, with, as GAO correctly points out, over 

700,000 forms being filed within the two months following the 

publication of the notification of address requirements rule. Form AR-

11 is currently available on the internet through the INS website. See:



http://www.ins. usdoj.gov/graphics/formsfee/forms/files/ar-1 1.pdf 

(English edition). We should note that this form is also available in 

Spanish, Chinese and Russian.



The INS also agrees that it is prudent and efficacious to provide the 

forms at all United States Post Offices. However, that process is one 

that will require renegotiation with the United States Postal Service. 

Although current INS regulations recognize this process, the provision 

of large numbers of forms at this moment may not be the most efficient 

means of gathering the information. As noted in the proposed rules 

cited above, the INS is currently revising a number of forms, including 

Form ARA 1, to ensure better compliance. After that revision takes 

place and the Attorney General approves a final rule, it will be 

important to ensure that the new forms are distributed as widely as 

possible and to assist aliens in complying with the law.



Recommendation: In connection with updating automated databases, 

establish procedures and controls that permit INS to verify receipts of 

change of address records and have a certificate of no record, when 

aliens do not comply with the change of address notification 

requirement.



The INS concurs. When in place, the alien address repository will 

provide a confirmation of receipt to aliens submitting change of 

address information. When conducting a search within the system, INS 

will have the address repository return the alien’s last recorded 

address or an appropriate “no record” certification to the searcher 

when the system does not contain an address for the given alien. INS 

agrees that the address repository must provide accurate and timely 

information to search requests.



Recommendation: Revise INS’ operation instructions to make clear that 

noncompliance with address reporting requirements can be the sole basis 

for removal, as provided in 8 USC 1306(b).



The INS concurs, but for different reasons than underlie the 

recommendation. INS agrees that failure to report changes of address 

under 8 USC 1306(b) can form the sole basis for removal. However, 

recognizing the shortcomings of the current address file, INS believes 

it is more important to develop a comprehensive address file system and 

ensure that recordkeeping will support removal before attempting to 

undertake removals solely on this basis.



Congress has mandated the development of a comprehensive, universal 

entry - exit system by 2005. The INS supports that goal and believes 

that management information must be brought into line with that goal. 

At the point that at which adequate assurance that an alien is on 

sufficient Notice of the responsibility to file a change of address, 

together with adequate assurance that any change of address has been 

properly accounted for, the INS will consider revisiting internal 

operating instructions and more aggressive enforcement of 8 USC 

1306(b). At this time, it would be premature to change the operating 

instructions and invite unnecessary litigation.



We should also note that section 266(b) includes a criminal sanction 

and that the revision of these internal operating procedures, when the 

are implemented, will not perforce result in additional criminal 

prosecutions. The penalties for willful failure to file a notice of a 

change of address are generally not conducive to the filing of criminal 

charges. Section 266(b) of the Immigration and Nationality Act (8 

U.S.C. § 1306(b)) provides that an alien who wilfully fails to file a 

notice of change of address may be imprisoned for 30 days and fined 

$200. In light of ever increasing demands for the scarce prosecutorial 

resources of the United States Attorneys and judicial resources of the 

United States District Courts, merely changing internal operating 

instructions and making referrals will not provide greater enforcement 

or deterrent and compliance value. As a general rule, the United States 

Attorneys will decline to prosecute such minor offenses. If enforcement 

of the requirement to file a notice of change of address is to be 

effective, these penalties would need to be substantially increased. 

Only then will a change in operating procedures and referring cases to 

the United States Attorneys be effective.



Recommendation: Provide a field on the address change form that an 

alien can use to report an SSN or indicate that they do not have one, 

with appropriate certifications and safeguards as required by law.



The INS concurs. The INS is currently reviewing and revising Form AR-

11, as well as other forms for collection of changes of address 

information. Many aliens in the United States do not have a social 

security number, so inclusion of a social security number in these 

forms will have a limited benefit. However, fNS believes that this 

added identifying is worth making the change and will attempt to do so, 

consistent with all of the legal requirements for utilizing social 

security numbers.



I hope you will consider our concerns in preparing the final GAO report 

on this subject. If you have any questions regarding the Department’s 

comments, you may contact Vickie L. Sloan, Director, Audit Liaison 

Office, on (202) 514-0469.



Sincerely,



Robert F. Diegelman, Acting Assistant Attorney General for 

Administration



Signed by Robert F. Diegelman



Appendix IV: GAO Contacts and Staff Acknowledgments:



Contacts:



Richard M. Stana (202) 512-8777

Evi L. Rezmovic (202) 512-8777:



Acknowledgments:



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.





FOOTNOTES



[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. 



[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. 



[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. 



[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).



[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.



[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).



[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.



[17] 67 Fed. Reg. 40581 (June 13, 2002).



[18] 67 Fed. Reg. 52584 (August 12, 2002).



[19] 67 Fed. Reg. 48818 (July 26, 2002).



[20] According to an Executive Office for U.S. Attorneys’ report, “a 

small percentage” of aliens were located and declined to be 

interviewed.



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



[22] INS collected but did not process alien address reports in 1981.



[23] Not every alien is required to have an SSN. 



[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). 



[27] INS Operations Instructions 265.1(a), TM 105 revised 11/17/82, p. 

4341.



[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.



[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.



[31] In 1976, the I&N Reporter was renamed the “INS Reporter.”



[32] INS received annual address reports in 1981, but did not process 

them.



[33] “Survey of the Alien Registration Division,” letter of 

Commissioner Harrison to E.B. Wilber, Bureau of the Budget, March 6, 

1944.



[34] 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) 



[35] 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). 



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