INS sharing of tactical information with the airlines is limited. At the local level, most INS airport offices do not regularly share tactical information with the airlines. At the national level, there is no formal program for the timely exchange of tactical information with the airlines. Additionally, INS does not have an effective security policy for disseminating tactical information to airlines.

While JFK and Miami INS Offices Routinely Share Tactical Information with Airlines, Other INS Airport Offices Do Not

To improve the process for sharing tactical information, officials at JFK and Miami International airports established local INS carrier consultant programs.⁶ Under these programs, the same INS carrier consultants who share tactical information with the airline employees are typically the ones who have trained the airline employees. This dual carrier consultant role fosters familiarity, trust, and cooperation between the INS local airport officials and the airline employees who screen those passengers headed to the international airports in the United States.

During our visits to these two major air ports-of-entry, we noted numerous testimonial documents thanking local INS officials for tactical information that enabled the airline to identify and, thereby, deny boarding to improperly documented passengers. For example, on September 27, 1999, one foreign airline notified INS officials at JFK that information provided to them prevented an improperly documented passenger from boarding through a switch of passports between a French national and a Sri Lankan. That same month, a U.S. airline, acting on information from JFK, prevented the boarding of a national from the People's Republic of China who was attempting a passport switch with a U.S. citizen. During FY 1999, a foreign airline reported that it had prevented 360 fraudulently documented passengers from coming to the United States as a result of JFK's carrier consultant assistance. INS's program at Miami International Airport has reported similar results.

With the exception of the two programs at JFK and Miami international airports, however, there are no other formally established INS programs at U.S. international airports that regularly share timely tactical information with the airlines. Airline officials expressed a desire to increase tactical information sharing between INS and the airline industry. The timely sharing of tactical information improves the airlines ability to screen out many improperly documented passengers from boarding. Without having to process those passengers already screened out by the airlines, INS offices at U.S. international airports can devote their scarce resources to other important law enforcement work.

At the National Level, a Limited Amount of Tactical Information Is Shared with the Airlines

At the national level, the INS Office of Intelligence does not have a formal program for sharing information with the airlines. The Forensic Document Laboratory, however, produces fraudulent document alerts that can provide helpful information to the airlines for identifying passengers that are inadmissible to the United States.⁷ Depending on INS security considerations, the alerts are distributed to affected airlines. The CAO provides a monthly report, the Carrier Information Bulletin, to the airline industry that informs them of some trends and smuggling activities. However, since this report is produced monthly, airline officials advised that some of the information is often too out of date to be of value in identifying fraudulent documents, port-specific deceptive schemes, and illegal alien trafficking. Furthermore, the report does not always cover as much airport specific information as the local INS officials at U.S. international airports can provide.

INS local officials are in a position to immediately alert their airline counterparts at a foreign airport of a fraud so that the airline can take direct action to prevent the related boarding of improperly documented passengers. For example, both JFK and Miami INS officials immediately notify their overseas airline counterparts when they begin to encounter passengers with a particular type of fraudulent passport arriving from a foreign airport on a particular airline(s).

INS Policy Does Not Directly Address Dissemination of Tactical information to the Airlines

Based on our review of INS's District Intelligence Office Standard Operating Procedure (SOP) and our interviews with INS's Office of Intelligence, INS policy does not directly address the dissemination of tactical information to airlines. The SOP does have a few references to dissemination to entities outside INS, but even these references primarily refer to other government agencies. The SOP does not bar further distribution on a "need to know" basis. The Office of Intelligence believed that all tactical information should be reviewed prior to providing it to the airlines. Its concern was that the airlines did not have a "need to know" for certain types of information (e.g., the subject of an investigation), but could typically use other information to the benefit of INS and the airlines. According to the Office of Intelligence, the decision on what information can be shared is being left to the discretion of INS officers who may not always be knowledgeable on the security implications.

The Office of Intelligence expressed concern about instances where INS documents containing information enabling airlines to identify improperly documented passengers also contained the names and addresses of individuals who were the subject of investigations. Most INS field officials shared this concern at the airports that we visited. One Assistant Port Director described an incident in the Far East where the names of alien smugglers were being passed on even though the airlines did not have a "need to know." Another INS port manager was concerned with supplying too much technical information to some airline employees because he said that they might divulge sensitive information to unintended individuals. A third Assistant Port Director was concerned about giving tactical information to an airline that was owned by a country that had a significant number of illegal aliens attempting to enter the United States.

The sharing of information has been very beneficial to INS and the airlines in preventing improperly documented passengers from traveling to the United States. In view of this and the information shared with the airlines at JFK and Miami international airports, the issue of what can be shared is important to INS airport operations.

Recommendations on Tactical Information

4. INS's Office of Inspection should clarify to local INS officials the types of information that can be provided to the airlines and what information should be provided.

5. INS should require that a senior local INS port official be designated to approve all tactical information that is furnished to the airlines. The individual who provides this approval must be thoroughly knowledgeable of INS's policy including security considerations regarding what types of information can be disseminated to the airlines.

6. INS should promote the timely exchange of information that helps prevent improperly documented passengers from boarding inbound flights to the United States. To be timely, this exchange should primarily be initiated and coordinated at the local INS airport level with their airline counterparts preferably at the foreign points of embarkation.

7. INS should designate an employee at each major U.S. international airport to devote at least some time to actively work with the port's airlines to foster relationships that promote the exchange of tactical information on a regular basis.

6. The carrier consultant programs at JFK and Miami international airports are responsible for training and tactical information sharing with airlines. A carrier consultant program is in the initial stages of development at LAX airport and extensive tactical information sharing has not yet begun.

7. The Forensic Document Laboratory is a sub-unit of INS's Intelligence program. This laboratory, in part, provides expert identification of fraudulent documents, including new and emerging counterfeiting trends relating to these fraudulent documents.

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