The Department of Homeland Security’s internal watchdog says the Global Entry system is vulnerable to exploitation by those seeking to enter the United States illegally.
U.S. Customs and Border Protection (CBP) created the Global Entry Program to allow expedited entry for pre-approved, low-risk travelers arriving in the U.S. But a report by the Office of the Inspector General (OIG) has found CBP’s controls over the Global Entry Program do not always prevent ineligible and potentially high-risk Global Entry members from obtaining expedited entry into the U.S.
Specifically, during vetting, CBP approved four applicants in a random sample for FYs 2016-2017 who did not meet the eligibility requirements and should not have been considered low risk. This occurred because CBP officers did not always comply with policies when reviewing Global Entry applications. Further, OIG says CBP’s policies do not sufficiently help officers determine an applicant’s level of risk. OIG infers that there could be a number of potentially high-risk members in CBP’s Global Entry Program.
The OIG review found that during the airport arrival process, CBP officers granted some Global Entry members expedited entry without verifying the authenticity of their kiosk receipts. CBP officers also did not properly respond to a breach of the Daily Security Code. These weaknesses were due to officers not following policy, as well as CBP’s insufficient verification procedures. Unless CBP officers authenticate kiosk receipts, someone could use a fake receipt to enter the United States. Officers said they were less inclined to verify the receipts because the process is “cumbersome, ineffective and inadequate”.
OIG also criticized CBP for failing to effectively monitor Global Entry to ensure members continue to meet program requirements. In particular, the review found CBP did not conduct the required number of internal audits and did not use its Self-Inspection Program effectively.
OIG made six recommendations, with which CBP has concurred:
- Develop a method, including but not limited to enhanced training and oversight to ensure CBP officers at the vetting, enrollment centers, and ports of entry follow Federal regulations and Global Entry Program policies and procedures.
CBP will create a nationwide training team to implement best practices in support of national, standardized training. Additionally, CBP will develop job aids for the management of Global Enrollment System data, interpretation of Risk Assessment Worksheet data, and interview Enrollment Center scenarios. CBP estimates this work will complete by February 29, 2020.
- Properly document results of analysis conducted for potential query matches for all members to ensure they meet Global Entry low-risk requirements. After CBP completes its analysis, it should re-evaluate whether members meet the low-risk criteria and determine each member’s Global Entry eligibility.
CBP will update the Trusted Traveler Programs Handbook to include a series of questions to address where there is doubt as to whether an applicant meets the strict standards of the program. It estimates the work will be completed by February 29, 2020.
- Update the policies and procedures in CBP’s Consolidated Trusted Traveler Programs Handbook (April 2016) to include descriptions, explanations, and examples of how CBP officers should use record match-type classifications.
CBP will update the Trusted Traveler Programs Handbook to include policy, operational, procedural, and technological changes and advancements focused on strengthening identified program security vulnerabilities. Additionally, CBP will update its SharePoint website to include updated policy documents, memos, musters, and reference guides. CBP aims to complete these updates by February 29, 2020.
- Develop and evaluate improved methods to ensure CBP officers authenticate Global Entry membership prior to travelers exiting the Federal Inspection Service area.
CBP management will engage Field Offices immediately to reinforce policy and will re-publish field memoranda regarding Global Entry receipt security features. Additionally, CBP management has mandated a Training Cohort to travel to ports of entry to reiterate basic Global Entry security training.
- Update the policies and procedures in the CBP Vetting Center Policy-Internal Audits of Trusted Traveler Program Application Vetting SOP to include performance of compliance reviews; communication of results to the Global Entry Program Office for concurrence and appropriate action; and identification of risk areas, and a method to track, analyze, and address trends.
CBP will revise policy to include regular performance of compliance reviews conducted by supervisors, sharing of compliance reviews with Trusted Traveler Program Office management, and a method of identifying risk areas and tracking, analyzing, and addressing trends. Much of this work has already been undertaken and OIG is currently awaiting documentation.
- Add operational Global Entry Program procedures to the Self-Inspection Worksheet to effectively measure Global Entry Program compliance.
By February 29, 2020, CBP will update the Global Entry Self-Inspection Program worksheet to include the critical elements of policy and procedure, inclusive of training, oversight, and quality control.