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American Samoa: Performing a Risk Assessment Would Better Inform U.S. Agencies of the Risks Related to Acceptance of Certificates of Identity

GAO-10-638 Published: Jun 11, 2010. Publicly Released: Jul 12, 2010.
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Highlights

American Samoa is a U.S. insular area that operates its customs and immigration programs according to its own laws and independent of the United States. As such, U.S. agencies, such as U.S. Customs and Border Protection, have no roles in operating the customs or immigration programs in American Samoa. U.S. officials have raised questions about how American Samoa operates its customs and immigration programs, and if this introduces any risks to the security of American Samoa or the rest of the United States. GAO was asked to review American Samoa's customs and immigration programs and this report discusses (1) the operations of American Samoa's customs and immigration programs, and (2) the extent to which U.S. and American Samoa agencies have identified potential risks in American Samoa's customs and immigration programs. GAO reviewed available statutes, regulations, policies, and procedures governing American Samoa and U.S. customs and immigration programs. GAO also visited American Samoa and interviewed U.S. and American Samoan officials to obtain insights.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Homeland Security To better understand the extent and significance of the possible risks associated with aliens in American Samoa fraudulently obtaining documents to travel to the rest of the United States and potentially pursue U.S. citizenship, the Secretary of DHS, should, in consultation with the Secretary of the Departments of State and the Interior, perform a risk assessment to (1) determine the extent of the threats, vulnerabilities, and consequences associated with aliens fraudulently obtaining CIs and using them to travel to the rest of the United States from American Samoa: and (2) make a determination as to whether CIs should continue to be an acceptable identification document that establishes nationality for U.S. nationals wishing to travel to the rest of the United States from American Samoa.
Closed – Implemented
In 2010, we found that American Samoa's immigration operations may pose risks to American Samoa and the rest of the United States because of vulnerabilities we found with the process used by the Government of American Samoa to issue Certificates of Identity (CI) for travel to the United States in lieu of passports. As a result, we recommended a risk assessment to determine the extent and significance of possible risks associated with aliens inappropriately obtaining CIs to travel to the United States from American Samoa. As of the end of October 2013, the Department of Homeland Security sent GAO correspondence stating, in effect, that it has no plans to conduct the risk assessment and so we amended the recommendation to show it as being "closed-not implemented." Then, on October 23, 2019, the Office of the Attorney General for American Samoa issued GAO a letter to document that it had recently implemented new procedures for processing applications for CIs that include enhanced security procedures that address vulnerabilities GAO identified in 2010. The new, enhanced security procedures include: development of a new Border Management System (BMS) that issues each CI a unique number that it can track and provide real time information on regarding any arrivals or departures or any over-stayers; and new CIs that are issued on security paper to deter forgery, include an embossed stamp over the Attorney General's seal, and use a laser-engraved photograph of the traveler rather than a glued-on photograph as was previously used. With these new, enhanced security procedures and capabilities, we believe that the Government of American Samoa has addressed the vulnerabilities we identified in 2010 and so consider this recommendation to be "Closed-Implemented."

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Immigration statusCustoms administrationDocumentationExcise taxesFederal agenciesFederal lawFederal regulationsIdentification cardsImmigrationImmigration and naturalization lawInspectionInternal controlsPassengersRisk assessmentTravelPolicies and procedures