DHS OIG, OIG-25-40, CBP Faces Limitations Detecting and Preventing Aliens' Use of Fraudulent Documents to Enter the United States (2025)

OIG-25-40 September 12, 2025 FINAL REPORT CBP Faces Limitations Detecting and Preventing Aliens' Use of Fraudulent Documents to Enter the United States OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Washington, DC 20528 | www.oig.dhs.gov MEMORANDUM FOR: FROM: SUBJECT: September 12, 2025 The Honorable Rodney S. Scott Commissioner U.S. Customs and Border Protection Joseph V. Cuffari, Ph.D. Inspector General CBP Faces Limitations Detecting and Preventing Aliens' Use of Fraudulent Documents to Enter the United States Attached for your action is our final report, CBP Faces Limitations Detecting and Preventing Aliens' Use of Fraudulent Documents to Enter the United States. The report contains five recommendations aimed at improving capabilities to identify fraudulent documentation. Your office concurred with all five recommendations, and we incorporated the formal comments provided by your office. Based on information provided in your response to the draft report, we consider recommendations 1 and 5 open and resolved.

Once your office has fully implemented the recommendations, please submit a formal closeout letter to us within 30 days so that we may close the recommendations. The memorandum should be accompanied by evidence of completion of agreed-upon corrective actions and of the disposition of any monetary amounts. Please send your response or closure request to [email protected]. Recommendations 2, 3, and 4 are closed and resolved.

Consistent with our responsibility under the Inspector General Act, we will provide copies of our report to congressional committees with oversight and appropriation responsibility over the Department of Homeland Security. We will post the report on our website for public dissemination. Please contact me with any questions, or your staff may contact Craig Adelman, Deputy Inspector General, Office of Audits, at (202) 981-6000. Attachment OIG Project No. 24-021-AUD-CBP DHS OIG HIGHLIGHTS CBP Faces Limitations Detecting and Preventing Aliens’ Use of Fraudulent Documents to Enter the United States September 12, 2025 Why We Did This Audit As the Nation’s largest Federal law enforcement agency, CBP is charged with securing our borders and facilitating international travel and trade.

In fiscal year 2024, CBP encountered over 2.9 million people at and between U.S. ports of entry. We conducted this audit to determine the extent to which CBP has the capability to identify and prevent individuals from entering the United States using fraudulent documents. What We Recommend We made five recommendations to improve CBP’s ability to identify and report instances of fraudulent document use. What We Found U.S. Customs and Border Protection (CBP) faces limitations detecting and preventing entry of aliens carrying fraudulent documents, increasing the risk that criminals, terrorists, and other national security threat actors may enter the United States.

Although CBP has capabilities to help officers identify fraudulent documents, unclear training requirements and unresolved technology gaps hinder detection, especially at land port of entry vehicle lanes where CBP has not fully implemented facial comparison technology. We found that CBP officers did not consistently report incidents of aliens using fraudulent documents. In some cases, officers allowed individuals presenting fraudulent documents to enter into the United States, although aliens who present fraudulent documents are inadmissible and subject to detention and removal. • We reviewed a sample of 60 immigration files and found 28 (47 percent) were missing available information about the use of fraudulent documents, which precludes U.S. Immigration and Customs Enforcement and U.S. Citizenship and Immigration Services from having necessary information to properly adjudicate immigration cases. • We reviewed 60 cases where aliens encountered at and between ports of entry were suspected of having fraudulent documents and, although inadmissible, 47 (78 percent) of aliens were allowed to enter the United States. Data Access: CBP denied OIG’s request for direct, read-only access to its BorderStat application and ACADIS training database and administrative website, instead only providing data extracts.

CBP Response For Further Information: Contact OIG Public Affairs at (202) 981-6000 or [email protected]. CBP concurred with our five recommendations and already has acted resulting in the closure of three recommendations. www.oig.dhs.gov OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Table of Contents Background .......................................................................................................................................... 1 Results of Audit..................................................................................................................................... 3 Training and Technology Gaps Hinder CBP Efforts to Identify Fraudulent Documents .......

3 CBP Did Not Always Record and Report Fraudulent Document Information ..................... 10 Conclusion .......................................................................................................................................... 12 Recommendations ............................................................................................................................. 13 Management Comments and OIG Analysis .......................................................................................

13 Appendix A: Objective, Scope, and Methodology ............................................................................. 16 DHS OIG’s Access to DHS Information ................................................................................... 18 Appendix B: CBP Comments on the Draft Report ............................................................................. 19 Appendix C: CBP Document Types and Descriptions .......................................................................

24 Appendix D: Office of Audits Major Contributors to This Report ...................................................... 25 Appendix E: Report Distribution ........................................................................................................ 26 Abbreviations AMO CBP FDAU ICE OFO OPLA U.S.C. USBP USEC Air and Marine Operations U.S. Customs and Border Protection Fraudulent Document Analysis Unit U.S. Immigration and Customs Enforcement Office of Field Operations Office of the Principal Legal Advisor United States Code United States Border Patrol Unified Secondary www.oig.dhs.gov OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Background As the Nation’s largest Federal law enforcement agency, U.S. Customs and Border Protection (CBP) is charged with securing our borders and facilitating international travel and trade. One of CBP’s top priorities is to protect air, land, and maritime environments against illegal entry, illicit activity, or other threats.

Several CBP offices are responsible for protecting the Nation: • Office of Field Operations (OFO), operating at U.S. ports of entry, is responsible for determining the nationality and identity of each applicant for admission and for preventing the entry of inadmissible aliens,1 including criminals, terrorists, and drug traffickers. • U.S. Border Patrol (USBP), operating between U.S. ports of entry, is primarily responsible for detecting and preventing individuals and contraband from illegally entering the United States. • Air and Marine Operations (AMO) is responsible for interdicting unlawful people and cargo approaching U.S. borders, investigating criminal networks, providing domain awareness in the air and maritime environments, and responding to national taskings. According to CBP, its officers encountered over 2.9 million people at and between U.S. ports of entry in fiscal year 2024. All individuals arriving at or apprehended between air, land, or maritime U.S. ports of entry are subject to inspection.2 Also, CBP agents may inspect individuals within a reasonable distance from any external boundary at vehicle checkpoints located inside the United States, or any vessel within the territorial waters of the United States.3 During the inspections, these officers and agents may conduct interviews, review information in various law enforcement databases, and examine travel and identification documents to determine an alien’s admissibility.4 When assessing admissibility, officers and agents consider 1 The Immigration and Nationality Act of 1952 uses the term “alien” to describe “any person not a citizen or national of the United States,” 8 United States Code (U.S.C.) § 1101(a)(3). See also, 8 U.S.C. § 1182(a) for classes of inadmissible aliens.

2 8 U.S.C. § 1225(a)(3). All aliens (including alien crewmen) who are applicants for admission or otherwise seeking admission or readmission to or transit through the United States shall be inspected by immigration officers. 3 8 Code of Federal Regulations § 287.1(a)(2) defines the term reasonable distance as “within 100 air miles from any external boundary of the United States or any shorter distance which may be fixed by the chief patrol agent for CBP, or the special agent in charge for [U.S. Immigration and Customs Enforcement] ICE, or, so far as the power to board and search aircraft is concerned any distance fixed pursuant to paragraph (b) of this section.” 8 Code of Federal Regulations § 287.1(a)(1) notes that the term “external boundary” means the land boundaries and the territorial sea of the United States extending 12 nautical miles from the baselines of the United States determined in accordance with international law. 4 8 U.S.C. § 1182(a) identifies classes of aliens ineligible for visas or admission to the United States for health, criminal, public charge, illegal entrant, and a range of other immigration-related grounds. www.oig.dhs.gov 1 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security factors including if the alien is seeking admission to the United States or other immigration benefit by fraud or willful misrepresentation of a material fact.5 Officers and agents also assess whether the alien has falsely claimed to be a U.S. citizen or impersonated an individual holding valid immigration status.6 Aliens who do not possess valid documents to enter, pass through, or remain in the United States are inadmissible and subject to detention and expedited removal.

According to The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States (issued July 22, 2004),7 terrorists consider travel documents as important as weapons, as these documents may be used to circumvent border security. CBP regards the use of fraudulent documents, such as counterfeit or altered passports or birth certificates, to circumvent border security as a challenge. For example, in June 2021, CBP reported four incidents in which eight individuals attempted to evade apprehension by presenting fraudulent passports and social security cards at a USBP checkpoint.8 OFO officers and USBP agents document information associated with alien encounters in their Unified Secondary (USEC) and e3 systems, respectively.9 The information recorded generally includes biographic and biometric data such as an individual’s name, date of birth, photograph, and fingerprints, as well as the date, location, and circumstances of each encounter. Officers and agents must note in USEC and e3 whether they identify fraudulent documents during an alien encounter.

CBP’s Fraudulent Document Analysis Unit (FDAU) serves as the central repository and point of analysis for all fraudulent travel and identity documents found or recovered by CBP. The FDAU also collects intelligence to help CBP establish policies and procedures to reduce the use of 5 8 U.S.C. § 1182(a)(6)(C)(i) provides that “[a]ny alien who, by fraud or willfully misrepresenting a material fact, seeks to procure (or has sought to procure or has procured) a visa, other documentation, or admission into the United States or other benefit provided under [the Immigration and Nationality Act] is inadmissible.” 8 U.S.C. § 1324c makes it unlawful for any person or entity to knowingly forge, counterfeit, alter, or falsely make any document; use, attempt to use, possess, obtain, accept, or receive or to provide any such document; use, attempt to use, provide, or attempt to provide any document lawfully issued to a person other than the possessor; or accept, receive, or provide any document lawfully issued to a person other than the possessor. Such actions may result in civil or criminal penalties. 6 Those attempting to impersonate the rightful holder of a genuine document (imposters) were included within the scope of this audit.

Appendix C lists CBP document types and descriptions. 7 The National Commission on Terrorist Attacks Upon the United States (also known as the 9-11 Commission) was created by Public Law 107-306, November 27, 2002, to examine and report on the facts and causes relating to the terrorist attacks of September 11, 2001. 8 Laredo Sector Border Patrol Arrests Undocumented Individuals with Fake Documents, June 4, 2021, https://www.cbp.gov/newsroom/local-media-release/laredo-sector-border-patrol-arrests-undocumented- individuals-fake. 9 These systems facilitate the screening of individuals’ biographic and biometric information using law enforcement and immigration databases. www.oig.dhs.gov 2 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security fraudulent documents.

The FDAU creates informational reports, identifies trends, and develops and delivers training. We conducted this audit to determine the extent to which CBP has the capability to identify and prevent individuals from entering the United States using fraudulent documentation.10 Results of Audit Although CBP has means to identify fraudulent documents, it does not always prevent the entry of aliens carrying such documents. Existing capabilities help officers identify fraudulent documents, but unclear training requirements and unresolved technology gaps hinder detection, especially at land port of entry vehicle lanes where CBP has been unable to fully implement facial comparison technology. Although aliens presenting fraudulent documents are inadmissible and subject to detention and removal, CBP officers may permit them to enter or be released into the United States.

We found that CBP officers did not consistently report to ICE and CBP’s FDAU incidents of aliens using fraudulent documents. We reviewed a sample of 60 immigration files and determined 28 (47 percent) were missing available information about the use of fraudulent documents. These deficiencies pose potential risks and vulnerabilities. For example, CBP may not be communicating information necessary to adjudicate immigration cases and identify fraud trends.

More importantly, CBP may not be identifying and preventing all individuals who could pose a threat to national security from entering and remaining in the United States. Training and Technology Gaps Hinder CBP Efforts to Identify Fraudulent Documents CBP officers and agents use a variety of tools and system capabilities, including facial comparison technology, document scanners, fingerprint readers, black lights, and magnifying loupes, to help identify fraudulent documents and impostors. Figure 1 provides a list of CBP capabilities used to establish identity and detect fraudulent documents. 10 We used CBP’s definition of a fraudulent document, which is any document that has characteristics of something that has been willfully created or used with the specific intent to deceive or cheat an authority to obtain a benefit for gain or permission improperly.

Additionally, we included any documents individuals use to facilitate entry into the United States at a port of entry or when they are encountered between ports of entry to support identification. This included documents that were fraudulent, counterfeit, altered, used by an imposter, or otherwise illegitimate. www.oig.dhs.gov 3 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 1. CBP Capabilities with Descriptions and Photos Used to Establish Identity and Detect Fraudulent Documents Description Photo Capability Facial Comparison Technology and Fingerprint Readers A photo of individuals may be taken at or between ports of entry. CBP systems attempt to match the photo with manifests and government databases.

If no match is found, a document scan is performed. Fingerprints may also be taken to help establish identity and screen for derogatory information. Document Scanners Document scanners, such as passport readers and driver’s license scanners, populate information in CBP’s system to facilitate the screening process. These scanners may work in conjunction with facial comparison technology, if necessary.

Law Enforcement Databases and Online Resources Biographic and biometric data is queried for links to any derogatory information. Some officers and agents have access to these systems via mobile phone. Black Lights and Magnifying Loupes Some locations use these tools to examine security features of documents. Video Spectrum Comparator Located at the FDAU and select ports of entry, this equipment allows officers to study documents using a variety of lighting and viewing conditions.

Source: DHS OIG photos and analysis of CBP information www.oig.dhs.gov 4 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security From FYs 2022 to 2024, OFO officers and USBP agents identified a total of 7,754 fraudulent documents, including fraudulent birth certificates, driver’s licenses, social security cards, passports, and others. Table 1 shows the number of fraudulent documents USBP and OFO identified over this period. Table 1. CBP Fraudulent Documents Identified FY 2022–FY 2024* CBP Organization USBP OFO Totals FY 2022 787 2,328 3,115 FY 2023 476 1,824 2,300 FY 2024 435 1,904 2,339 Totals 1,698 6,056 7,754 *These figures represent documents used by individuals to facilitate entry into the United States at a port of entry or when individuals are encountered between ports of entry to support identification.

Any fraudulent document cases originating from an AMO encounter would be turned over to USBP and captured in their respective systems. Source: DHS OIG analysis of CBP data CBP Did Not Ensure Officers Completed Periodic Training We found officers and agents receive training on how to identify fraudulent documentation when they first join CBP. However, they did not always receive periodic follow-up training from FDAU- certified trainers, as required.11 Initial training focuses on identifying imposters, examining security features of documents, using technology, and detecting fraud, among other related topics. However, FDAU officials noted that continuous training is important because fraud tactics and document security features change over time.

The effectiveness of an officer or agent using fraud detection capabilities depends on preparation and consistent training. The volume and complexity of government-issued documents also necessitates continued training to enable CBP officers and agents to detect fraud. For example, identity and travel documents can have a variety of security features, including holograms, color-shifting ink, and unique images, as shown in Figure 2. Document types and security features vary widely depending on the state, Federal agency, or foreign government creating and issuing them.

11 According to CBP Directive No. 3340-053, Fraudulent Travel Document Processing, June 2022, officers and agents receive periodic fraudulent document training by FDAU-certified trainers. www.oig.dhs.gov 5 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 2. U.S. Passport Security Features Source: U.S. Department of State Although CBP policy requires periodic training, it does not identify specific courses or the frequency with which they should be taken. OFO attempted to establish an annual mandatory training requirement for two fraudulent document courses: Fraudulent Document and Imposter Detection Course and Fraud Document Trends Training. Yet in doing so, OFO did not follow CBP guidance that requires an Assistant Commissioner or equivalent to approve internally mandated training for their workforce; OFO’s Executive Director of Admissibility and Passenger Programs designated the courses as mandatory.12 Because the requirement was not approved at the appropriate level, the courses did not appear in CBP’s training system as mandatory for OFO officers.

As a result, not all OFO officers completed the two courses. Figure 3 shows the number of OFO officers who completed the two fraudulent document training courses from FY 2021 to FY 2023.13 12 Mandatory Designation: Fraudulent Document and Imposter Detection Training #079710; Fraudulent Document Trends #G0715003-13, July 1, 2019. 13 Based on the memorandum, Mandatory Designation: Fraudulent Document and Imposter Detection Training #079710; Fraudulent Document Trends #G0715003-13, July 1, 2019, CBP had intended that the training requirement apply to all officers, agriculture specialists, and supervisors working at a port of entry, preclearance facility, or international mail/cargo facility. Because the memorandum was invalid, Figure 3 shows the total OFO staff and training completions. www.oig.dhs.gov 6 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 3.

OFO Officers Completing Fraudulent Document Refresher Training 40,000 35,000 30,000 25,000 20,000 15,000 10,000 5,000 0 Fraud Document Trends Training Fraudulent Document and Imposter Detection Course Total OFO Staff FY 2021 FY 2022 FY 2023 Source: DHS OIG analysis of OFO data Neither USBP nor AMO established training requirements for agents to complete fraudulent document training on a continuous basis. Several USBP and AMO agents said they had not received training on fraudulent documents since joining CBP and expressed a desire for additional training. Such training is important because the document scanners officers and agents currently use do not identify whether any document presented for admission contains all applicable security features. For example, we observed document scanners that populate traveler biographic information into CBP systems for screening purposes, but they do not specifically identify security features such as holograms, color-shifting ink, or unique images, which an officer or agent may identify through visual and physical inspection.

Further, in certain environments such as USBP vehicle checkpoints and AMO inspections, access to capabilities described in Figure 1 may be limited or unavailable. The limitations of technology highlight the importance of continuous training for officers and agents on how to identify fraudulent documents. Lack of Facial Biometric Comparison Limits Identity Confirmation Effectiveness CBP’s inability to fully implement facial recognition technology at land port of entry vehicle lanes also hinders detection of fraudulent documents. According to CBP, facial biometric comparison technology is an effective identity verification solution, and the Intelligence Reform and Terrorism Prevention Act of 200414 directed the Secretary of Homeland Security to develop a plan to accelerate the full implementation of an automated biometric entry and exit data system.

14 Public Law 108-458, § 7208 (c)(1) (2004). www.oig.dhs.gov 7 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Nevertheless, in a 2024 DHS OIG report,15 we found that CBP did not have facial comparison technology at all land port of entry vehicle lanes and instead manually compared the faces of travelers in vehicles against travel documents, potentially limiting the efficiency and effectiveness of processing. We concluded the deficiency occurred because CBP was unable to identify a viable camera solution to reliably capture vehicle travelers’ facial images in real time. We recommended CBP continue to conduct technology testing until a solution is identified to perform biometric matching at land port of entry vehicle lanes. This recommendation remains open.

During our site visit at the Nogales, Arizona port of entry, an individual using fraudulent documents successfully passed through primary vehicle inspection but was subsequently flagged during an additional inspection procedure.16 Several Factors May Permit Aliens to Enter or be Released into the United States with Fraudulent Documents We reviewed 60 cases where aliens encountered at and between ports of entry were identified as having suspected fraudulent documents. Although inadmissible and apparently candidates for expedited removal under 8 U.S.C. § 1225(b)(1), 47 of these aliens were allowed to enter the United States. Of the remaining 13 cases, 4 aliens were detained pending further disposition or removal proceedings, 6 were removed, and 3 were admitted after CBP resolved its concern regarding suspected fraudulent documents. When aliens arrive at a port of entry or are apprehended between ports of entry, CBP officers or agents process the aliens and attempt to verify their identity and admissibility.17 Aliens who do not possess valid documents to enter, pass through, or remain in the United States are deemed inadmissible, are subject to detention, and may be placed in expedited removal under 8 U.S.C. § 15 DHS Needs to Improve Its Screening and Vetting of Asylum Seekers and Noncitizens Applying for Admission into the United States, OIG-24-27, June 7, 2024.

16 After a vehicle passes through vehicle primary inspection at the Nogales port of entry, Anti-Terrorism Contraband Enforcement Teams perform an additional inspection. 17 In our June 2024 report, DHS Needs to Improve Its Screening and Vetting of Asylum Seekers and Noncitizens Applying for Admission into the United States, OIG-24-27, we found DHS could not access all data from Federal partners to ensure complete screening and vetting of noncitizens seeking admission into the United States. We recommended the Director of the Office of Biometric Identity Management work with the Department of Defense to develop and implement a plan to address Automated Biometric Identification System data access restrictions. www.oig.dhs.gov 8 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security 1225(b)(1).18 However, officers and agents may allow these aliens to enter and be released19 into the United States in certain circumstances, provided they have not committed certain criminal offenses20 and for other reasons, including: • The alien intends to apply for asylum or expresses a fear of future persecution or torture in their home country. When this occurs, CBP officers and agents will refer the alien for a credible fear interview.

If an asylum officer determines the alien’s claim is credible, despite being subject to mandatory detention,21 the alien may be paroled into the country temporarily for “urgent humanitarian reasons” or “significant public benefit” to await adjudication of their claim.22 • CBP officers and agents may, in their discretion, parole aliens into the United States temporarily for “urgent humanitarian reasons” or “significant public benefit.”23 • CBP officers and agents may release aliens due to detention space limitations. In these circumstances, aliens may be released into the country on their own recognizance to await hearings or reviews of their claims to admission. In addition to being subject to expedited removal, aliens with fraudulent documents may be charged criminally. In our review of 60 cases, some aliens were charged as inadmissible under 8 U.S.C. § 1182 but not for other Federal offenses related to the use of fraudulent documents.24 CBP officers and agents exercise prosecutorial discretion regarding aliens subject to arrest or criminal prosecution on a case-by-case basis.

According to multiple CBP officials, criminal 18 Aliens who do not present identification may be released into the United States. In our September 30, 2024, report, CBP, ICE, and TSA Did Not Fully Assess Risk Associated with Releasing Noncitizens without Identification into the United States and Allowing Them to Travel on Domestic Flights (REDACTED), we found that CBP did not fully assess risks associated with releasing aliens without identification into the United States. We recommended that CBP conduct a comprehensive analysis of the risks associated with releasing aliens into the country without identification and develop and implement policies and procedures to mitigate those risks. 19 Aliens may be served Form I-862, Notice to Appear, upon release.

See 8 U.S.C. § 1229. This form is used to initiate removal proceedings before an immigration judge of the U.S. Department of Justice. It includes alleged violations of the Immigration and Nationality Act and related removal charges. The form also notes if an asylum officer determined the alien demonstrated a credible fear of persecution or torture.

20 Pursuant to 8 U.S.C. § 1226(a), an alien may be arrested and detained pending a decision on whether the alien is to be removed from the United States. Aliens who have been convicted of certain crimes such as an aggravated felony, a firearms offense, or a crime involving moral turpitude are subject to mandatory detention. See 8 U.S.C. § 1226(c). 21 Pursuant to 8 U.S.C. § 1225(b)(1)(B)(iii)(IV), any alien subject to the procedures under this clause shall be detained pending a final determination of credible fear of persecution and, if found not to have such fear, until removed.

22 Pursuant to 8 U.S.C. § 1182(d)(5)(A), aliens may be paroled into the United States on a case-by-case basis for urgent humanitarian reasons or significant public benefit. 23 Id. 24 Other potentially applicable statutes include 18 U.S.C. § 1546, Fraud and Misuse of Visas, Permits, and other Documents, and 18 U.S.C. § 1543, Forgery or False Use of a Passport. www.oig.dhs.gov 9 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security prosecution depends on the circumstances of each case and guidelines established by the U.S. Department of Justice. As a result, CBP officers and agents may be required to prove to local U.S. Attorneys that a potential subject of future prosecution presented the fraudulent document as a form of identification, admitted the document was fraudulent, described how they obtained the document, and admitted they knew the document was fraudulent. Since the time of our site visits, CBP officials noted changes in processes for releasing aliens into the United States.

Executive Order 14165, Securing Our Borders, terminated the practice of “catch-and-release,” whereby illegal aliens were routinely released into the United States shortly after their apprehension for violation of immigration law. The Executive Order also states that the Secretary of Homeland Security must take all appropriate actions to detain, to the fullest extent permitted by law, aliens apprehended for violations of immigration law until their successful removal from the United States.25 CBP Did Not Always Record and Report Fraudulent Document Information We found that CBP personnel did not consistently record information about aliens’ use of fraudulent documents on required forms or enter the information into an Alien Registration file (A-file) — the record created upon encounter and used to document an alien’s interactions with CBP, ICE, and U.S. Citizenship and Immigration Services. We reviewed a sample of 60 A-files (30 each from OFO and USBP) involving fraudulent documents presented or used from FY 2022 through March 31, 2024, as identified by CBP, and found that 28 (47 percent) did not contain available information about the aliens’ use of fraudulent documents. The forms that OFO officers prepared contained a standard “Claimed Documents” section that forms prepared by USBP agents did not.

The Claimed Documents fields included the document number, such as the passport number, and any concerns with the document presented, such whether it was counterfeit or used by an imposter. • Of the 30 A-files USBP identified as being associated with fraudulent documents, 28 did not contain information about the aliens’ use of fraudulent documents.26 Without all relevant information about fraudulent documents recorded on forms or entered into an A-file, decisionmakers in the adjudication and removal processes may be left unaware an individual is suspected of committing fraud. Without access to information suggesting an alien may have possessed or used fraudulent documents previously, adjudicators and/or Office of the 25 Executive Order 14165, Securing Our Borders, January 20, 2025. 26 Although the 30 A-files each contained a Form I-213, Record of Deportable/Inadmissible Alien, the form did not always contain information about the use of fraudulent documents. USBP agents did include this information on Form I-44, Border Patrol Report of Apprehension or Seizure, and other forms designed to capture this information, such as Form G-166F, Report of Investigation, for 29 of the 30 cases they identified as being associated with document fraud.

However, these forms were not included in the A-files we reviewed. www.oig.dhs.gov 10 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Principal Legal Advisor (OPLA) attorneys very likely would be less prepared to fully explore relevant facts and circumstances of each case. For example, asylum may be granted to individuals suspected by CBP of committing fraud, and/or people whose credibility is undermined by failure to disclose prior use of a fraudulent document(s) during adjudication of their asylum application. Given there is no USBP requirement to record fraudulent documents on Form I-213, and that 28 of the 30 USBP files we reviewed were missing this information, it is likely the same type of information is missing from other A-files and therefore not available to OPLA when litigating immigration cases. Officers and Agents Did Not Always Send Seized Fraudulent Documents to the FDAU We found that officers and agents did not always send confiscated fraudulent documents to the FDAU, as required by CBP policy,27 and in some cases returned them to aliens who were likely released into the United States.

The FDAU provided documentation that it had received confiscated fraudulent documents for 37 of the 60 cases we reviewed (62 percent).28 Of the 23 cases without documents, 22 were OFO and 1 was USBP. 27 According to CBP Directive No. 3340-053, Fraudulent Travel Document Processing, June 2022, “It is the policy of CBP to remove from circulation all fraudulent travel and identity documents…. All travel and identity documents encountered by CBP that are determined to be fraudulent must be forwarded to the Fraud Detection and Analysis Unit … where a travel or an identity document cannot be turned over to FDAU, an image of the document should be forwarded via email…. Once a travel or identity document is entered into the system of record, it must be forwarded to the FDAU within 14 calendar days.” 28 Some cases contained multiple documents.

We selected one document from each of the 60 cases to determine if the FDAU received the document. www.oig.dhs.gov 11 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 4. Fraudulent Documents Presented by OFO Officers to DHS OIG at a Port of Entry That Should Have Been Sent to the FDAU During site visits, we also found instances of fraudulent documents seized by officers and agents that were not sent to the FDAU. For example, we observed 9 fraudulent documents at Imperial Beach Border Patrol Station and 33 at San Ysidro port of entry that agents and officers found abandoned in the field. We also observed two fraudulent documents at the USBP Interstate 19 Checkpoint that were seized from an individual.

Figure 4 illustrates examples of fraudulent documents observed at a port of entry that should have been sent to the FDAU. Following our site visits, we notified these offices of the FDAU procedures, and officials said that the documents would be sent to the FDAU and they would comply with forwarding procedures in the future. We found that CBP does not provide consistent training on the FDAU’s processes and procedures, which may account for OFO and USBP not providing documents to the FDAU. USBP agents do not receive training on the FDAU’s responsibilities or on processes for sending fraudulent documents to the FDAU.

OFO officers receive initial training but are not required to attend available recurrent training on the FDAU’s responsibilities and how to send fraudulent documents to this office. Source: DHS OIG photograph We found varying knowledge of the requirements among officers and agents during our site visits. At the Otay Mesa port of entry, OFO officers demonstrated their process for preparing documents to ship to the FDAU. At the San Ysidro port of entry, an officer told us that confiscated documents were stored in bins and drawers.

Some USBP agents said that they were not aware of the FDAU’s existence and also said they returned fraudulent documents to aliens who were likely released into the country. By not sending fraudulent documents to the FDAU, CBP may be missing opportunities to gather strategic information that helps leadership design policies and procedures to reduce fraudulent document use. Moreover, fraudulent documents returned to travelers may be used for illicit travel and other criminal activity such as insurance fraud, money laundering, and tax evasion. Conclusion The risks to our Nation associated with terrorists using methods such as altered and counterfeit passports and visas, and immigration and identity fraud to circumvent border security are well documented, as noted over 20 years ago by the 9/11 Commission.

To protect national security, CBP needs to improve its ability to identify and report instances of fraudulent document use. www.oig.dhs.gov 12 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Recommendations Recommendation 1: We recommend the Commissioner of CBP establish clear, mandatory, and recurring fraudulent document training requirements for officers and agents. Such training should be updated periodically to keep pace with emerging tactics in fraudulent document methods. Recommendation 2: We recommend the Chief, U.S. Border Patrol, develop and implement a process to ensure agents accurately record all instances involving aliens attempting to enter the United States by presenting or otherwise using fraudulent documents on forms and ensure such forms are added to aliens’ A-files. Recommendation 3: We recommend the Executive Assistant Commissioner, Office of Field Operations develop and implement a process to ensure Forms I-213, Record of Deportable/Inadmissible Alien, are added to aliens’ A-files, when applicable.

Recommendation 4: We recommend the Chief, U.S. Border Patrol work with ICE’s Office of the Principal Legal Advisor to ensure information on fraudulent document use associated with pending immigration cases is shared, as appropriate. Recommendation 5: We recommend the Commissioner of CBP develop and implement controls to ensure CBP officers and agents send documents to the Fraud Detection and Analysis Unit, as required. Management Comments and OIG Analysis CBP provided management comments to the draft report and concurred with our recommendations. Appendix B contains CBP’s management comments in their entirety.

CBP also provided technical comments on the draft report, which we incorporated into the report as appropriate. We closed Recommendations 2, 3, and 4 after reviewing additional documentation that CBP provided. We consider Recommendations 1 and 5 open and resolved. A summary of CBP’s response and our analysis follows.

CBP Response to Recommendation 1: Concur. According to a CBP official, on October 10, 2024, CBP’s FDAU updated its web-based Fraudulent Document and Impostor Detection training, which CBP’s Admissibility and Passenger Programs will recommend that the Commissioner require as a mandatory yearly course for field personnel. Further, the USBP Law Enforcement Operations Directorate, Immigration Prosecutions and Custody Operations Division, will work with USBP Headquarters personnel, as appropriate, to include Fraudulent Document and Impostor Detection training as annual required training for USBP personnel. Estimated Completion Date: January 30, 2026. www.oig.dhs.gov 13 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security OIG Analysis: These actions are responsive to the recommendation, which we consider open and resolved.

We will close the recommendation when CBP provides documentation demonstrating that the Commissioner of CBP has established clear, mandatory, and recurring fraudulent document training requirements for officers and agents that is updated periodically to keep pace with emerging tactics in fraudulent document methods. CBP Response to Recommendation 2: Concur. On February 21, 2025, USBP’s Law Enforcement Operations Directorate distributed an email reminder to all sectors regarding seizing fraudulent documents. The email included associated policies and addressed proper seizure requirements as well as the processing of seized documents.

In addition, on June 2, 2025, USBP enhanced its apprehension processing system of record, the e3 Processing Module, and the information that populates into the narrative section on DHS Form I-213, which in turn is included in an alien’s A- File. Currently, once the fraudulent document checkbox is selected in the e3 Processing Module, text will auto-populate in the narrative section of Form I-213 and refer the reader to review the Form I-44 associated with the fraudulent document seizure. This reference to Form I-44 in the Form I-213 describes the seized document, how it was encountered, whether it was sent to the FDAU. On June 2, 2025, the USBP Headquarters System Division issued field guidance to all USBP sectors that reflected the e3 Processing Module enhancement and required agents to document the seizure in Form I-44.

CBP provided documentation of these efforts to us on June 23, 2025. CBP requested that we consider this recommendation closed and resolved, as implemented. OIG Analysis: These actions are responsive to the recommendation, which we consider closed and resolved. CBP Response to Recommendation 3: Concur.

On July 30, 2025, CBP met with us and discussed existing policy and clarified that the three Form I-213s cited in the report were included in aliens’ A-files. CBP provided supporting documentation on July 30, 2025, August 1, 2025, and August 14, 2025. CBP requested that we consider this recommendation closed and resolved, as implemented. OIG Analysis: These actions are responsive to the recommendation, which we consider closed and resolved.

CBP Response to Recommendation 4: Concur. According to a CBP official, all required notifications are currently made as appropriate for cases involving a fraudulent document, and all evidence is discoverable at the Assistant U.S. Attorney’s and ICE OPLA’s request. To enhance prosecutorial effectiveness, on February 28, 2025, USBP adopted a new approach that emphasizes the importance of utilizing every available Federal, state, and local charge to strengthen its cases. As part of this approach, USBP expands on all prosecution charges www.oig.dhs.gov 14 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security available, including those based on fraudulent documents, while working with the Assistant U.S. Attorney’s Office.

Further, the previously noted e3 Processing Module enhancement on the Form I-213 describes in greater detail in the alien’s A-file the fraudulent document and if the fraudulent document was sent to the FDAU. USBP advised OPLA on August 1, 2025, regarding the potential use of fraudulent documents in cases we identified in the report. USBP will continue to work with OPLA to review individual immigration cases during removal proceedings on a targeted basis. (CBP noted that reviewing records for fraudulent document associations for the 5,417,433 active immigration cases for aliens apprehended by CBP without a final order as of May 20, 2025, would detract from current mission priorities.) CBP provided documentation of these efforts to us on August 4, 2025.

CBP requested that we consider this recommendation closed and resolved, as implemented. OIG Analysis: We consider these actions responsive to the recommendation, which we consider closed and resolved. CBP Response to Recommendation 5: Concur. The FDAU will work through CBP’s Admissibility and Passenger Programs to draft a memorandum and guidance for the field as a reminder of fraudulent document requirements.

In addition, USBP’s Law Enforcement Operations Directorate also sent reminder guidance of the FDAU requirement to all USBP sector personnel on February 21, 2025. CBP provided the most current guidance for the Fraudulent Document Policy to us on August 25, 2025. Estimated completion date: January 30, 2026. OIG Analysis: We consider these actions responsive to the recommendation, which we consider open and resolved.

We will close the recommendation when we receive evidence that CBP has developed and implemented controls to ensure CBP officers and agents send documents to the FDAU, as required. www.oig.dhs.gov 15 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix A: Objective, Scope, and Methodology We conducted this audit to determine the extent to which CBP has the capability to identify and prevent individuals from entering the United States using fraudulent documentation. In this report, we used CBP’s definition of a fraudulent document, which is any document that has characteristics of something that has been willfully created or used with the specific intent to deceive or cheat an authority to obtain a benefit for gain or permission improperly. Additionally, we included any documents individuals use to facilitate entry into the United States at a port of entry or when they are encountered between ports of entry to support identification. This included documents that were fraudulent, counterfeit, altered, used by an imposter, or otherwise illegitimate.

To answer our objective, we reviewed and analyzed applicable Federal laws and regulations, CBP policies and procedures, prior audit reports and reviews, and congressional testimonies. We interviewed CBP officials from AMO, OFO, and USBP in Headquarters in the Washington, D.C. metro area and in field offices across the country. We visited the FDAU facility in Sterling, Virginia, to interview subject matter experts, observe operations, and examine examples of fraudulent documents. We met with officials from U.S. Citizenship and Immigration Services, ICE OPLA, and the U.S. Department of Justice’s Executive Office of Immigration Review to discuss the immigration adjudication process.

We included AMO Marine Interdiction Agents who may review travel and identity documentation during vessel encounters and inspections and excluded AMO air operations from the scope of this audit. We visited 17 CBP facilities and observed CBP capabilities to detect fraudulent documents; identified if the site had any fraudulent documents in its possession; and conducted interviews with officers, agents, supervisors, and other personnel. Those locations include: San Diego, California Tucson, Arizona • San Ysidro Port of Entry • Otay Mesa Port of Entry • Tecate Port of Entry • San Diego International Airport • San Diego Seaport • San Diego Area Detention/Transit Staging Area • USBP San Diego Sector Headquarters • Chula Vista USBP Station • • AMO San Diego Marine Unit Imperial Beach USBP Station • Nogales Port of Entry • Sasabe Port of Entry • Tucson Soft-Sided Facility • Tucson International Airport • Tucson Sector Headquarters • Nogales USBP Station • USBP Interstate 19 Checkpoint www.oig.dhs.gov 16 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security We conducted remote interviews with officers and supervisors from the Port of Buffalo and Hartsfield-Jackson Atlanta International Airport. We obtained data from OFO’s USEC system and USBP’s e3 system.

OFO uses a reporting tool called BorderStat to generate a variety of reports, including information in USEC on fraudulent documents OFO encountered. To assess the reliability and completeness of the data, we met with subject matter experts to discuss the data and obtain walkthroughs of the systems; observed officers accessing and using the systems during site visits; reviewed policies, procedures, and documentation on the use of the systems; and traced the data fields to the underlying supporting documents. We reviewed 60 cases involving the use of fraudulent documentation, and we verified the data fields reported in the systems matched the information obtained through interviews and other analyses. Based on these procedures, we determined the data from USEC and e3 was sufficiently complete and reliable for the purposes of this audit.

We judgmentally selected 60 cases (out of 4,818 cases documented in USEC and e3 from October 1, 2021, to March 31, 2024) of fraudulent documentation used by individuals to determine whether CBP communicated that information to those in the adjudication process (i.e., U.S. Citizenship and Immigration Services, ICE OPLA) and to the FDAU as policy requires. We selected those cases based on risk factors such as whether the individual was released into the United States and the location of encounter. We reviewed documentation associated with each case within the USEC and e3 systems, analyzed the circumstances surrounding the use of fraudulent documents, inquired as to whether CBP sent the document to the FDAU, and traced the data fields to the underlying supporting documents. We also obtained the A-file associated with each case from U.S. Citizenship and Immigration Services to determine whether it included information on the use or possession of a fraudulent document.

Although the results of this analysis cannot be generalized to all CBP cases, we believe the evidence gathered during the audit in aggregate provides a reasonable basis for our conclusions and recommendations. We obtained data from OFO’s ACADIS training system, which maintains personnel and training records. We obtained personnel and training records for all OFO officers working at a port of entry from FYs 2021 to 2023. We reviewed officer completion records for the Fraudulent Document and Imposter Detection and Fraud Document Trends Training courses.

To assess the reliability and completeness of the data, we met with subject matter experts to discuss the data and obtain walkthroughs of the systems; observed an officer access the system during a site visit; and reviewed documentation on the use of the systems. Based on these procedures, we determined the data from ACADIS was sufficiently complete and reliable for the purposes of this audit. www.oig.dhs.gov 17 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security We assessed CBP’s internal controls significant to the audit objective. We identified and reported deficiencies in the control environment, control activity, and risk assessment components of internal control. Because we limited our review to addressing our audit objective, our work may not have identified all internal control deficiencies that may have existed at the time of this audit.

We conducted this audit from February 2024 through February 2025 pursuant to the Inspector General Act of 1978, 5 U.S.C. §§ 401–424, and according to generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. DHS OIG’s Access to DHS Information During this audit, CBP denied DHS OIG’s request for direct, read-only access to the data contained in the BorderStat application.

Additionally, CBP denied DHS OIG’s request for direct, read-only access to the data contained in the ACADIS training database and the ACADIS Administrative Website. In lieu of system access, CBP provided DHS OIG with data extracts from both BorderStat and ACADIS. CBP provided timely responses to all other requests for information. www.oig.dhs.gov 18 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix B: CBP Comments on the Draft Report www.oig.dhs.gov 19 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 20 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 21 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 22 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 23 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix C: CBP Document Types and Descriptions Type of Document Description Genuine Document A document issued by a government authority to a person who has Fraudulent Document Counterfeit Document Altered Document Imposter Fantasy Document Travel Document Identity Document satisfied specific requirements for its issuance and who is legally entitled to the given benefit Any document that has characteristics of something that has been willfully created or used with the specific intent to deceive or cheat an authority to obtain a benefit for gain or permission improperly A subtype of fraudulent document where the document is created in imitation of a genuine document A subtype of fraudulent document where the genuine document is changed, made different, or modified to match the intended user A person who bears a resemblance to the rightful holder of a genuine document A document that is created to resemble a recognized, government- issued travel document such as a passport, diplomatic identification, or driver’s license; however, it is not issued by a government authority and therefore not recognized as a legitimate form of identification Any document issued by a government or international treaty organization, as evidence of citizenship and/or identity, to facilitate movement across international borders Any document that may be used to prove a person’s identity either on its own or in combination with other documents Source: CBP Directive No. 3340-053, Fraudulent Travel Document Processing, June 2022 www.oig.dhs.gov 24 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix D: Office of Audits Major Contributors to This Report Peter Charboneau, Auditor Tinh Nguyen, Assistant Inspector General, Audits www.oig.dhs.gov 25 OIG-25-40 OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix E: Report Distribution Department of Homeland Security Secretary Deputy Secretary Chief of Staff Deputy Chiefs of Staff General Counsel Executive Secretary Director, GAO/OIG Liaison Office Under Secretary, Office of Strategy, Policy, and Plans Assistant Secretary for Office of Public Affairs Assistant Secretary for Office of Legislative Affairs CBP Liaison Office of Management and Budget Chief, Homeland Security Branch DHS OIG Budget Examiner Congress Congressional Oversight and Appropriations Committees www.oig.dhs.gov 26 OIG-25-40 To view this and any other DHS OIG reports, Please visit our website: www.oig.dhs.gov Additional Information For further information or questions, please contact the DHS OIG Office of Public Affairs via email: [email protected] DHS OIG Hotline To report fraud, waste, abuse, or criminal misconduct involving U.S. Department of Homeland Security programs, personnel, and funds, please visit: www.oig.dhs.gov/hotline If you cannot access our website, please contact the hotline by phone or mail: Call: 1-800-323-8603 U.S. Mail: Department of Homeland Security Office of Inspector General, Mail Stop 0305 Attention: Hotline 245 Murray Drive SW Washington, DC 20528-0305