Fraud Detection & National Security

Organization Overview Document

^^ U.S. Citizenship
and Immigration
Services
1/28/2004 v9
Development of The Office of FDNS

CIS has developed The Office of Fraud Detection and National

Security (FDNS) in recognition of the need to:
• Enhance the integrity of the legal immigration system, and
• Identify persons who pose a threat to national security and/or
public safety

"While providing accurate and responsive

service is of paramount importance, we must
not do so at the expense of national security or
public safety! "
— Eduardo Aguirre
Director, CIS

U.S. Citizenship
and Immigration
Services
1/28/2004 v9
 Response to GAO Findings
GAO Recommendation
"...Determine how INS should balance its dual
responsibilities of processing applications in a
timely manner and detecting fraudulent
applications"
"Develop guidance for INS...to use in deciding
which benefit application fraud cases to
pursue"
CIS Response
Establish an organization (FDNS) separate
from Adjudications, dedicated to detecting
and pursuing suspected fraud
Develop joint CIS/ICE benefit fraud strategy
and case referral criteria

"Use [a system], to track and manage benefit Develop and engage a case tracking
fraud investigations..." system to track all fraud cases from referral
to completion

^ U.S. Citizenship ' Source: "Immigration Benefit Fraud. Focused Approach is Needed to Address Problems".
General Accounting Office. January 2002. GAO-02-66
O and Immigration
* Services
1/28/2004 v9
FDNS Mission and Objectives
FDNS MISSION
Enhance the integrity of the legal immigration system by:
• Identifying aliens who pose a threat to national security and/or public safety
• Combating immigration benefit fraud
• Identifying and removing systemic vulnerabilities of statutes, policies,
procedures, forms, other documents, and guidelines that compromise the
integrity of the legal immigration system

FDNS OBJECTIVES
Serve as CIS' lead and primary conduit on fraud detection and law enforcement
(background) check-related efforts
Ensure benefits are not granted to individuals who pose a threat to national
security and/or public safety
Ensure benefits are not granted as a result of fraud-based applications or
petitions
Provide a new capability for proactive fraud detection and enhance current
reactive operation

U.S. Citizenship
and Immigration
Services
1/28/2004 v9
FDNS Addresses Current and Long
Standing Issues
Issues Field Office Visit Observations

• Current processes and systems are inadequate to detect the amount of fraud that
Fraud
exists
Detection « Proactive fraud detection activities are only performed on an ad hoc basis
• Fraud referral process within CIS and between CIS and ICE needs to be standardized
9 IBIS check mandate has created a backlog in the adjudication process and a strain on
resources
Background
Checks " The IBIS process is not consistently applied
» The CIA Name Trace process is in need of reengineering
a Multiple chains of responsibility create a lack of accountability
Lack of " Staff have received little formal training and have not received standard operating
Standardization procedures
• Demand for fraud detection and background check work exceeds the current staffing
capacity

US. Citizenship
and Immigration
Services
1/28/2004 v9
Existing Weaknesses of the Immigration
System
• Some individuals seeking benefits pose a threat to national security and public
safety
• Anti-fraud efforts remain inadequate, reactive, and uncoordinated
• Passive enforcement invites fraud and abuse
• Lack of commitment to combating fraud demoralizes staff and negatively impacts
productivity
• Communication with the law enforcement community remains inefficient
• Law enforcement community support remains inadequate, particularly as it relates
to information sharing and providing documents to informants and other
cooperatives
• No centralized group is responsible for identifying and correcting weaknesses and
other vulnerabilities in policies, procedures, and other activities

U.S. Citizenship
and Immigration
Services 5
1/28/2004 v9
Benefits of FDNS
CIS has a dedicated, specialized organization responsible for:
• Identifying aliens who pose a threat to national security and/or public safety
• Combating immigration benefit fraud
• Identifying and removing systemic vulnerabilities of statutes, policies, procedures, forms, other
documents, and guidelines that compromise the integrity of the legal immigration system
Processes associated with identifying fraud, criminal aliens, and aliens of national interest are
enhanced
Productivity, quality, and efficiency are improved through a combination of centralization,
standardization, and prioritization
Quality of background checks is enhanced as national security/public safety-related hits are resolved
by specialized staff
Backlog reduction effort is supported by enabling adjudicators to concentrate on adjudication, instead
of performing IBIS resolution and verifying fraud
ICE is able to use their limited resources more effectively and efficiently
Fraud-based applications are denied and violators are placed in removal proceedings
Communication between CIS and ICE is better coordinated

U.S. Citizenship
and Immigration
Services 6
1/28/2004 v9
FDNS Organization Structure
Director

Chief Operating Officer

Fraud Branch Operations Branch Background Check (BC) Branch Support Services Branch

Planning and Development Unit Law Enforcement Liaison Unit Planning and Development Unit Technology Support Unit

Intelligence Unit Service Center Fraud Detection UnK I CIA Name Trace Unit FDU Systems Support Section

| Tier 3 Background Check TMr 2 Background Check

Proactive Fraud Detection Section Rosolutfofi Soctton Program Analyst Section
Resolution Untt

Akfe*/A**M*nts Supervisors Administration Untt

Lead-Goneratcd Fraud Section Contractors Training Section

FleM Office Ana-Fraud Units' Contract Support Section

' Not in FDNS chain of command, but follows FDNS established guidelines
D Denotes HQ Positions
U.S. Citizenship D Denotes Field Positions
and Immigration
Services 7
1/28/2004 v9
Branch Missions and Functions
FDNS Branch Branch Mission
Enhance the integrity of the
legal immigration system by
developing policies and
procedures to detect, pursue,
Fraud Branch and deter benefit fraud.
Provide direction and
oversight to FDNS field staff.
Implement and perform
activities to detect, pursue,
Operations and deter benefit fraud, and
Branch resolve national security and
public safety related
background check hits.
Conduct law enforcement
checks to identify derogatory
information on persons
Background seeking benefits who may
Check Branch pose a threat to national
security or public safety.
Provide the coordination,
Support communication, and
Services operational support needed
Branch to facilitate the achievement
of the FDNS mission.
U.S. Citizenship
and Immigration
Services
Branch Functions
> Develop fraud detection policies and procedures
t Develop CIS fraud priorities
> Identify areas of vulnerability and propose solutions
> Perform proactive fraud detection and document significant findings in reports
> Identify fraud indicators for proactive and reactive data mining
> Use pattern recognition and data mining software in anti-fraud activities
Provide oversight and direction to fraud detection and background check staff
Review applications/petitions for fraud and identify fraud trends
Write intelligence reports and assist the Fraud Branch with proactive analysis
Assist LEAs/lntelligence agencies with operational requirements for CIS documents
and subject information
Liaise with DHS components/LEAs on issues impacting background checks
Support ICE in prosecuting cases
Resolve background checks that are national security and public safety related
Develop background check policies and procedures
Coordinate background check process with other internal and external organizations
(e.g., CIA, ICE, FBI)
Conduct background check activities
Perform background check-related data analysis
Provide system requirements for the Background Check System
Perform human and capital resource related functions for FDNS including budget
development and facilities/inventory management
Develop functional requirements and training
Oversee contract management, technology resources and communications
8
1/28/2004 v9
Key FDNS Priorities
Develop FDNS organizational structure, mission, and functions
Develop joint CIS/ICE Anti-Fraud Strategy, case referral criteria, process, and MOU
Develop MOU containing respective CIS and ICE guidelines regarding referral of NS/PS cases
Enhance current reactive (leads-based) data mining and pattern analysis efforts
Develop proactive anti-fraud processes
Develop case management tracking system that will track referrals and case progress
Review the integrity of CIS policies, procedures, operations, and other activities to identify and remove
systemic vulnerabilities
Develop standardized IBIS triage process at each SC and field office
Evaluate the feasibility of centralizing the IBIS process
Develop training modules for fraud detection and background check resolution activities
Serve as primary conduit to/from ICE and other LEAs emphasizing the importance of info sharing between
agencies
Develop centralized/controlled policy and process to provide immigration documents and other benefits to
informants and other LEA cooperatives
Participate in DHS intelligence, LEA information sharing, and Terrorist Support Center working groups

U.S. Citizenship
and Immigration
Services 9
1/28/2004 v9
FDNS Organization Structure
Director

Chief Operating Officer

Fraud Branch Operations Branch Background Check (BC) Branch Support Services Branch

Planning and Development Unit Law Enforcement Liaison Unit Planning and Development Unit Technology Support Unit

Intelligence Unit Service Center Fraud Detection Unit CIA Name Trace Unit FDU Systems Support Section

Ij Proactive Fraud Detection Section

Tier 3 Background Cheek
Resolution Section
Ttor 2 Background Check
Resolution Unit
Program Analyst Section

Aides/Assistants Supervisors Administration Unit

Lead-Generated Fraud Section Contractors Training Section

FWd Office Anti-Fraud Units' Contract Support Section

' Not in FDNS chain of command, but follows FDNS established guidelines
] Denotes HQ Positions
U.S. Citizenship ] Denotes Field Positions
and Immigration
Services 7
1/28/2004 v9
Branch Missions and Functions
FDNS Branch Branch Mission
Enhance the integrity of the
legal immigration system by
developing policies and
procedures to detect, pursue,
Fraud Branch and deter benefit fraud.
Provide direction and
oversight to FDNS field staff.
Implement and perform
activities to detect, pursue,
Operations and deter benefit fraud, and
Branch resolve national security and
public safety related
background check hits.
Conduct law enforcement
checks to identify derogatory
information on persons
Background seeking benefits who may
Check Branch pose a threat to national
security or public safety.
Provide the coordination,
Support communication, and
Services operational support needed
Branch to facilitate the achievement
of the FDNS mission.
U.S. Citizenship
and Immigration
Services
Branch Functions
Develop fraud detection policies and procedures
Develop CIS fraud priorities
Identify areas of vulnerability and propose solutions
Perform proactive fraud detection and document significant findings in reports
Identify fraud indicators for proactive and reactive data mining
Use pattern recognition and data mining software in anti-fraud activities
Provide oversight and direction to fraud detection and background check staff
Review applications/petitions for fraud and identify fraud trends
Write intelligence reports and assist the Fraud Branch with proactive analysis
Assist LEAs/lntelligence agencies with operational requirements for CIS documents
and subject information
Liaise with DHS components/LEAs on issues impacting background checks
Support ICE in prosecuting cases
Resolve background checks that are national security and public safety related
Develop background check policies and procedures
Coordinate background check process with other internal and external organizations
(e.g., CIA, ICE, FBI)
Conduct background check activities
Perform background check-related data analysis
Provide system requirements for the Background Check System
Perform human and capital resource related functions for FDNS including budget
development and facilities/inventory management
Develop functional requirements and training
Oversee contract management, technology resources and communications
8
1/28/2004 v9