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U.S. Department of Homeland Security
Office of Investigations
Benefit Fraud Unit - (Office)
Attention:
(Unit or Official who will receive BFR)
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Files(s):
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SEP - 5 2003
Effective September 12, 2003, a pilot project establishes ICE Benefit Fraud Units to support
the Bureau of Citizenship and Immigration Services' (BCIS) Service Centers in Vermont, Texas
and California. These units will be comprised of existing ICE resources currently assigned to the
Service Centers in addition to existing ICE investigative resources from the former Central, Eastern,
and Western Regional Offices of Investigations, to include the appropriate support staff. The
National Benefits Center (Missouri) and Nebraska Service Center will be addressed at a later time.
A list of affected positions is attached to this memorandum.
1. work in conjunction with the BCIS' Fraud Detection Units (FDU) at the Service Centers;
2. be the primary recipients of allegations, leads and fraud trends referred by FDU;
3. review, evaluate, and prioritize fraud leads for Investigation action; and
4. in coordination with the respective SAC offices, forward cases to the SAC, for
appropriate follow up or work the case under the supervision of the SAC and in
coordination with ICE Headquarters.
An ICE Benefit Fraud Coordinator will be established in Dallas, Texas. The ICE Benefit
Fraud Unit Supervisors will report to the Benefit Fraud Coordinator in Dallas, Texas. The
Coordinator will report to the Director of the Identity and Benefits Fraud Unit, Division 3 at ICE
Headquarters. The attachment shows the personnel who will become part of the ICE Benefit Fraud
Units and the field chain of command.
Attachment (2)
ICE Benefit Fraud Units (Service Centers) Field Structure
NeH Jacobs
National Benefit Fraud Coordnator
Dallas, TX
Staff Staff
Staff Special Agents (4) Special Agents (7)
California Service Center
Special Agents <7) Program Staff (5) Program Staff (4)
Laguna Miguel. CA
Program Staff (6) S«6 Attached See Attached
Jimmie Ward
See Attached
Supervisory Special Agent
Staff
Special Agents (2)
Eastern Region
Central Region
Western Region
Staffcrs/SrSAs/Detailees
Citizenship and Immigration Services (CIS) shall apply the following criteria when referring
cases to Immigration and Customs Enforcement (ICE) for investigation:1
> Level 2 - Limited Investigation: CIS has determined that articulable fraud
indicators are present and that the case requires ICE investigative intervention
before further administrative and/or prosecutorial action can occur. CIS will
request specific action, and explain the potential impact on the adjudication of
the related application and/or petition. CIS' primary objective is to validate or
invalidate fraud, and if fraud does exist, get sufficient information in which to
deny the application or petition. This category of mid-level investigation action
may include limited physical surveillance, interviewing witnesses and other
subjects (to possibly include sworn statements), obtaining information
pursuant to an administrative subpoena, etc. If ICE is unable to accept the case
or complete the investigative action within 60 days, they will return the case to
1 This caseload prioritization will enable ICE to engage its limited resources in a more efficient and effective
manner. Cases are referred to the applicable area ICE-Benefit Fraud Unit (BFU), via a CIS Fraud Detection Unit
(FDU).
REVISED CIS DRAFT- 10/1/03
their referring ICE-BFU, with a specific reason for an extension or declination.
After review, ICE-BFU will either forward the case to referring CIS-FDU with
their findings, or return it to the field ICE office for investigative purposes.
ICE-BFU will advise CIS-FDU of any and all extensions. At no time will an
extension exceed 90 days, unless the initial investigative action raised the level
of the referral to Level 3. Cases that are returned without the requested
investigative action may warrant a compliance and verification-related review
by CIS, in an effort to obtain the information needed to make a proper
adjudicative decision.