SENSITIVE BUT UNCLASSIFIED

MEMORANDUM

TO: IG Mr. Clark Kent Ervin

THRU: OIG/ISP Robert Peterson

FROM: OIG/ISP/CE Charles A. Anderson

SUBJECT: Message Agreement on the Survey of Visa Operations

JOB CODE: 02ISP3069

DATE: October 1,2002

This memorandum is prepared for use as background information for our briefing session
with you tomorrow, Wednesday October 2,2002.

Purpose and Objectives

In response to a request from Congress, ISP/CE undertook a survey of visa issuance

policies at posts abroad. Specifically, we looked at travel agent referral programs
(TARPs) and procedures involving personal appearances waivers (PAWs). The survey
was expanded to include executive oversight, officer training and orientations, the Visas
Viper program and inter-agency cooperation in the visa function. To conduct this study
questionnaires were sent to all visa issuing posts. Based on the responses and other
statistical information, a number of posts were selected for on-site visits by inspection
teams. To date, on-site reviews have been conducted at 12 posts. Later this month 15
additional posts will be surveyed as follows:

1. Islamabad, Abu Dhabi and Doha: Joint OIG team headed by Chuck Anderson

2. Manila, Jakarta, Singapore, KL and Dhaka: Joint OIG team headed by Doug Ellice

3. Riyadh, Jeddah, Kuwait, and Paris: One inspector team: Bob Mustain

4. Ankara, Istanbul, and London: One inspector team: Bert Krieg

Division of these posts into four trips will make it possible to return 3 of the 4 inspectors
back to Washington by October 23rd. In this way, preparation of the final report can
begin early enough to allow completion by end of November, and editing, publication,
and delivery to the Hill before the end of December as requested by Senator Grassley.
While the on-site surveys are completed, Marlene Schwartz and her assistants will
complete the analysis of the 180+ responses to our unclassified cabled questionnaire.
There are about 40 posts that have TARPs in operation now. We will carry out a close
analysis of these 40 programs (with follow up cables requesting additional data if needed)
to determine just what types of control systems are applied, and whether apparent
vulnerabilities exist and how they might be eliminated by improved management and
control.
Principal Findings

At this half way point in the survey, we have reached several preliminary conclusions.
First, consular officers abroad are doing a good job of screening applicants given the
resource limitations under which they work. Second, there are significant lapses in
oversight of the process, creating vulnerabilities. The visa process is not in disarray, but
with the increased focus on security, changes must be made in how visas are issued and
additional resources must be found to achieve these changes. What follows is a list of the
findings to date.

Executive oversight and Junior Officers

Oversight of the visa function by post management is often weak, sometimes almost
nonexistent. In too many cases inexperienced junior consular officers are left alone to
determine visa policy and manage the visa function at small embassies. The consular
function is too often a part time responsibility and given too little weight. Consular
rotational positions are receiving much criticism in the field. Supervisors claim that one
year in a visa function is most often not enough to allow for job training. Post
management is found to be too anxious to use multi-hatted officers for non-consular
duties.

The current HR policy regarding the assignment of junior officers to do consular work at
critical threat posts should be reviewed. Currently, the primary factor determining the
grade level of consular positions is size of post and volume of workload. More weight
needs to be given to the complexity and (especially) the security threat of the visa
function at each post. In the wake of 9/11, the Department needs to consider upgrading
the level of consular positions to ensure that more experienced consular officers are
present to manage visa sections, even if they are the sole consular officer at post.
First tour officers should not be assigned to a one officer consular post—particularly
those where there is a critical terrorist threat.

Personal appearance waivers

Personal appearance waivers (PAWS) are generally well thought out and in many cases
very restrictive. PAWs are generally established to facilitate post operations and
maximize the use of resources to scrutinize those cases most likely to present problems
including security risks. Some posts, however, view these policies backwards, specifying
which cases to interview and not which to exempt. Posts with significant visa fraud and
security issues and corresponding high refusal rates have the most restrictive policies,
often interviewing all applicants.

Travel agent referral programs

TARPs are not, although some Hill staffers seem to think so, visa waiver programs.
There are many posts which report that they attempted to organize TARPs only to drop
the idea due to fraud problems. The 40 or so posts that do have TARPs claim that they
help to manage the workflow, decrease the number of applicants and in some cases,
when remote data entry is used, reduce the time spent by employees in basic data entry
functions. We have found the best TARPs are carefully organized and constantly
monitored. Making the continual monitoring of TARPs a control function to be included
in the COM's annual certification process must be enforced by OIG inspectors.
Dismantling of TARPs as has been advocated by some in Congress. The increased
resources needed to interview every applicant are huge and will be mentioned in the
report, based on estimates furnished by the 40 TARP posts. Although we found that
posts need to have flexibility in structuring the visa process, the Bureau of Consular
Affairs should carefully monitor the any changes made to previously agreed upon
procedures.

Visa interviews

The visa interview cannot be viewed as interrogation that will expose the potential
terrorists, but improvements are needed to make the most of the interview process. All
visa officers must be assured adequate training and guidance in identifying applicants
who are security threats. The flurry of instructions to the field in recent months have
caused confusion among some officers. Consular instructions governing the visa process
should be reviewed and reissued in a comprehensive and unclassified form so that they
are easily used and readily accessible.

Visas Viper

The teams found the Visa Viper program to be very useful in developing information to
be made available to consular officers in visa adjudications. But it's application is very
uneven. Not all posts have a well-managed, aggressive program. In many missions not
all agencies are well briefed on Visas Viper and do not participate fully, if at all.
Contributing to the weaknesses of the program is the lack of clear guidance and feedback
from Washington to all participating agencies. It is unclear how information is process in
Washington and posts do not always receive sufficient feedback or see the results of their
submissions in a timely manner.

The collection of overt data for submission to INR/TIPOFF for CLASS entries needs to
reviewed and upgraded. The increased use of FIBIS material should be reviewed and the
role of political/econ sections in this process must be reconsidered. The role of the RSO
in stepped up efforts at law enforcement liaison should also be revisited.
 Language skills

Many posts which process significant numbers of applicants who speak Arabic, Farsi and
other languages spoken in South Asia and the Middle East lack officers with the language
skills necessary to conduct interviews or read documents. Some posts lack even FSN
interpreters. This deficiency makes the adjudication process more difficult and raises the
possibility of missing vital information.

Officers assigned to consular positions at posts in the Middle East and South Asia should
receive appropriate language training. Posts outside the region that process significant
volumes of applicants from these regions (e.g., Germany, UK) should have language
designated positions in the consular section.