[Also by Juan Mann: 03/20/02 - IT'S THE FRAUD, STUPID!]

Think the Mexican border in Arizona is insecure? Think again. The leaky southwest border is a drop in the bucket compared to the massive potential for immigration benefit fraud inside the Citizenship and Immigration Services [USCIS or CIS] division of the Department of Homeland Security [DHS].

No coherent system is in place for investigating and apprehending aliens who file fraudulent immigration applications (including asylum, immigrant petitions and adjustments of status from non-immigrant visas). The floodgates of benefit fraud are waiting to be opened wide should the Bush Administration's "willing worker—willing employer" amnesty program ever become law.

Considering the wholesale fraud of the 1986 amnesty disaster and the government's unwillingness to even measure the level of fraud in more recent amnesty give-away programs, the damage would be incalculable if America ever subjects itself to another immigration benefit free-for-all.

Moslem jihadists need only take a number along with the millions of potential "willing workers" out there.

But why such doom and gloom?

Don't blame me. Just ask the newly reinvented Government Accountability Office (GAO), formerly the General Accounting Office (also GAO).

In its two most recent reports dealing with immigration benefit fraud, the GAO found that the massive potential for fraud at USCIS was the same, or even worse, after the recent post-9/11 bureaucratic reshuffling.

As of January 2003, the alien-friendly district adjudications offices, asylum offices and regional service centers of the Immigration and Naturalization Service (INS) were consolidated into their very own agency (USCIS) within the Homeland Security department.

But in the two reports, from January 2002 and October 2004—i.e. before and after the DHS transition—the GAO found that as far as immigration benefit fraud goes, it was business as usual in the federal immigration bureaucracy.

Here's the proof. First from the GAO's January 2002 report—"Immigration Benefit Fraud: Focused Approach Is Needed to Address Problems," Report # AO-02-66 [PDF]:

• "Although the extent of the benefit fraud problem is unknown, internal and external reports and views of INS officials indicate that the problem is pervasive and significant." (Pg. 14)

• "INS's efforts to contain immigration benefit fraud are fragmented and unfocused." (Pg. 17)

• "INS is now only attempting to quantify the scope and extent of the immigration benefit fraud problem." (Pg. 16)

• "Further, INS has not established guidance for opening immigration benefit fraud investigations or for prioritizing investigative leads." (Pg. 17)

• "INS is hampered in establishing meaningful goals for benefit fraud in that it does not know the extent of the problem. . . . Institutionally, INS has not done much to combat this significant problem, which threatens the integrity of the legal immigration system because it results in INS's granting valuable benefits to ineligible aliens." (Pg. 33)

And in a clear case of deja vu, here's what the GAO reported again in October 2004—after the DHS bureaucracy was created—"Homeland Security: Management Challenges Remain in Transforming Immigration Programs," Report # GAO-05-81—[PDF]—[text]:

"At the time of our site visits, how ICE [Immigration and Customs Enforcement] and CIS should communicate and coordinate with each other in cases of suspected benefit fraud has not been formally defined by either CIS or ICE headquarters, and the field officials we contacted said that this has caused disagreement among CIS and ICE field officials."

"The difficulty between CIS and ICE investigations regarding benefit fraud is not new. We have noted in a past report that INS had numerous problems related to its enforcement of benefit fraud, including a lack of protocols for adjudicators and others in coordinating benefit fraud and a lack of criteria for investigators in prioritizing benefit fraud cases."

"Prior to the transition, INS had begun to place a priority on investigating benefit fraud perpetrated by large-scale organizations or persons of special interest, and this priority has continued under ICE. As a result, some CIS field officials told us that ICE would not pursue single cases of benefit fraud. ICE field officials who spoke on this issue cited a lack of investigative resources as to why they could not respond in the manner CIS wanted." (Pg. 17)

"One CIS manager and one ICE manager in the field indicated that while dismantling large-scale smuggling rings is important, single cases of benefit fraud can have national security implications. For example, a person who is allowed to remain in the country as a result of committing marriage fraud can become a naturalized citizen in 3 years and facilitate the entry of other persons into the United States who could possibly pose security risks." (Pg. 18)

Bravo, unnamed "CIS manager"! At least someone in government realizes that immigration benefit fraud and terrorism go together.

Does anyone out there remember Huffman Aviation International in Venice, Florida, and their two most notorious "willing students"?

Considering the deplorable state of immigration fraud detection at the INS—and now at CIS—it's painfully obvious that if garden-variety "good" illegal aliens on the street can file a phony immigration application, "bad" illegal aliens can file one too.

Let's hope DHS and Congress grasp this concept sometime soon . . . before it's too late.

Juan Mann [send him email] is a lawyer and the proprietor of DeportAliens.com.