T5 B5 W Hempel's Files 2 Of 2 Fdr- Draft Materials Re Alien Absconder Initiative 185

3. The Absconder Apprehension Initiative (AAI) (U) Absconders are non-citizens who willfully fail to depart the United States after receiving a final order of deportation from an immigration judge. As such they are susceptible to federal felony prosecution.1 After September 11, INS Commissioner James Ziglar proposed the inclusion of the names of 314,000 absconders in the National Crime Information Center (NCIC) database accessible by State and local law enforcement." To meet NCIC standards, every absconder entry had to be supported by a set of fingerprints and a photograph so that the Law Enforcement Support Center (LESC) could electronically transmit them to the querying law enforcement official within ten minutes.111 If the absconder's identity was confirmed, then the INS could place a detainer or arrange for an INS agent to take the individual into custody and proceed with removal. Finding terrorists was not a focus of the program.lv Attorney General Ashcroft liked the idea and Commissioner Ziglar announced it on December 5, 2001.v Shortly thereafter, based on a recommendation from an aide to the Attorney General, the initiative was recast as a counterterrorism program. Deputy Attorney General Thompson on January 25, 2002 provided guidance for the newly named Absconder Apprehension Initiative (AAI). He explained that the object of the initiative was to deport 314,000 alien fugitives known as absconders in two phases. The first phase was to focus on several thousand priority absconders "who come from countries in which there has been al Qaeda terrorist presence or activity . . . because some of them have information that could assist our campaign against terrorism." The second phase of the initiative was to locate and deport the remaining absconders/1 (U) The INS National Security Unit (NSU) took charge of the project/11 There were approximately 5,200 priority absconder subjects when the project began.vm By the summer of 2002, the initiative had resulted in the apprehension of approximately 700 fugitives.1X By early 2003, 1,139 of the designated absconders had been apprehended; immigration authorities had removed from the country 803 of these, and 224 were in custody and awaiting removal. No absconders who were removed as part of the Phase I group were deported under a terrorism statute, prosecuted for terrorist related crimes, or linked in any way to terrorism. The Commission does not know how many of the 5,000 AAI cases were entered into NCIC, but we believe that not all of them were, and that only a minority may have been entered due to the poor quality of the INS' records. In addition, the Commission believes the remaining absconders who were not apprehended in the first phase of the program no longer receive special attention from INS/DHS enforcement personnel.

8 USC 1253 (failure to depart, imprisonment up to four years, 10 years if a criminal); 8 USC 1324d (failure to depart, civil fine of $500 a day); 8 USC 1326 (reentry after deportation, imprisonment from two to 20 years). " Ziglar MFR. ;ii NCIC 2000, Operating Manual, Section 5.6 iv Ziglar MFR. v Ziglar MFR.

Memorandum from the Deputy Attorney General to Commissioner, Immigration and Naturalization Service, Director Federal Bureau of Investigation, Director, U.S. Marshals Service, US Attorneys, Subject: Guidance for Absconder Apprehension Initiative, January 25, 2002. ™ Nardi MFR.; see also, Testimony of Joe Green, INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration, June 19, 2002. vm Nardi MFR; see also, Testimony of Joe Green, INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration, June 19, 2002; The Commission has learned that of the initial group of approximately 5,000 priority absconders: 24 were confirmed dead, 55 were determined to be female (and therefore outside the scope of the AAI), 390 had left the U.S. on their own while under a warrant of deportation, 14 had applied for or been granted political asylum. Testimony of Joe Green, INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration, June 19, 2002. vl

The Absconder Apprehension Initiative jJnder U.S. immigration law.^ abscgnders are npn-citizens who willfully fail to depart the_ _ _ , - \: United States after receiving a final order of deportation from an Immigration Judge. They jnay bejprgsecuted_for federal jelony,,1 After September^11th, INS_Cqrnmis_sio_ner „ _ - \: are amenable to James Ziglar proposed^^ the na^mes of 314,000 absconders be placed in the National ~ ~ •{ Deleted: prosecution Crime Information Center (NCIC) database Wanted Persons file accessible by State and ~ ~ ~ -[ Deleted: the inclusion of local law enforcement.2 To meet NCIC standards, every absconder entry had to be supported by a set of fingerprints and a photograph so that the INS Law Enforcement Support Center (LESC) could electronically transmit them to the querying law enforcement official within ten minutes.3 If the absconder's identity was confirmed, then the INS could place a federal detainer or arrange for an INS agent to take the individual into custody and proceed with removal. Finding terrorists was not a focus of the program.4 Attorney General Ashcroft liked the idea and Commissioner Ziglar announced it on December 5, 2001.5 Shortly thereafter, based on a recommendation from an aide to the Attorney General, the initiative was re-cast as a counterterrorism program.6 Deputy Attorney General Thompson on January 25, 2002 provided guidance for the newly named Absconder Apprehension Initiative (AAI). He explained that the object of the initiative was to deport 314,000 alien fugitives., known as absconders^ in two phases. The first phase was to focus on several thousand priority absconders "who come from countries in which there has been al Qaeda terrorist presence or activity . . . because some of them have information that could assist our campaign against terrorism." 7 These "special interest countries" were Afghanistan, Algeria, Bahrain, Bangladesh, Djibouti, Egypt, Eritrea, Indonesia, Iran, Iraq, Jordan, Kazakhstan, Kuwait, Lebanon, Libya, Malaysia, Morocco, Oman, Pakistan, Philippines, Qatar, Saudi Arabia, Somalia, Sudan, Syria, Tajikistan, Thailand, Tunisia, Turkey, Turkmenistan, United Arab Emirates, Uzbekistan, Yemen, Territories of Gaza and the West bank. DAG Thompson said that the first group to be investigated would be "a group of fewer than a thousand, many of whom appear to be convicted felons." The second phase of the initiative was to locate and deport the remaining absconders.8

8 USC 1253 (failure to depart, imprisonment up to four years, 10 years if a criminal); 8 USC 1324d (failure to depart, civil fine of $500 a day); 8 USC 1326 (reentry after deportation, imprisonment from two to 20 years). 2 Ziglar MFR 11/24/03 p.22 3 NCIC 2000, Operating Manual, Section 5.6 4 Ziglar MFR p.22 5 Ziglar MFR p. 23 6 Ziglar MFR p.23 7 NSU AAI final report 8 Memorandum from the Deputy Attorney General to Commissioner, Immigration and Naturalization Service, Director Federal Bureau of Investigation, Director, U.S. Marshals Service, US Attorneys, Subject: Guidance for Absconder Apprehension Initiative, January 25, 2002.

The Deputy Attorney General directed: •

the Foreign Terrorist Tracking Task Force (FTTTF) to remove any names that were subjects of active terrorist investigations;9 • the INS Law Enforcement Support Center (LESC) to review the paper files to exclude duplications, find current addresses, and confirm the validity of the deportation warrant and proper notice; to transmit an "absconder fugitive file" to the INS field office located in the INS district of the absconder's last known address; and to enter the data into NCIC; • the INS and FBI to create "apprehension teams" to locate, apprehend, and interview each absconder, soliciting extra staffing as needed from the local U.S. Attorney's Anti-terrorism Task Force (ATTF). • the INS to take absconders into custody pursuant to civil warrant arrest authority and the FBI to arrest them based on federal felony authority, to treat them as criminal suspects, and afforded all standard procedural rights and constitutional protections, and provided legal incentives (money and "S" Visas under the Responsible Cooperators Program) to cooperate; • the investigators to conduct interviews following a standard interview form to be provided and to provide written results to be entered into a Computerized Reporting System; • the FBI to make a timely request to the U.S. Attorney's office if further counterterrorism inquiries are needed, since once in INS custody, the absconder is subject to immediate removal; • the U.S. Attorney's office to consider prosecution if the non-citizen has engaged in criminal conduct. At the INS, the National Security Unit (NSU) was tasked with of the project. 10^The project was aimed at 5.923 Delected absconderj when die project began.^^ The AAI project was a massive undertaking for the NSU. a small unit that was the INS' primary counter terrorism unit. The NSU developed a special project staff of its own agents, INS intelligence analysts from the Office of Intelligence, and detailed agents from the INS field offices, as many as 10 at a time, to develop the project. These additional officers organized the leads, made copies of the documents in the file, created the work file, did data entry and kept track of the case assignment.12 For each absconder case where a last known address could be found, the NSU created a work file and sent it to a designated supervisory special agent POC in the INS field office located in that geographic area. T The administrative tasks associated with the AAI required the detailing of many officers

The Commission believes that the FTTTF did remove some subjects from the list; we have not yet learned how many and whether these subjects remained of interest to the FBI on terrorism grounds. Nardi MFRp, 10 Nardi MFR 4/1/04 p. 1; see also, Testimony of Joe Green, INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration, June 19, 2002. 11 Nardi MFR p. 1 ; see also, Testimony of Joe Green, INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration, June 19, 2002. 12 Ziglar MFR, p. 22

__ , - -(Deleted: There were _ _ _ - - \: absconder subjects

\:

Deleted: The AAI project was a massive undertaking for the NSU, a small unit that was the INS" primary counter terrorism unit.

to the NSU.Twhich left fewer special agents available to investigate the AAI cases in the field.13 To meet the terrorist-related reporting requirements imposed by the Department of Justice, the NSU developed special reporting requirements, to ensure that all encounters with designated absconders was treated as a "significant incident" and therefore reported within 24 hours of the incident.14 The directive from the Attorney General did not define what was meant by "from countries". Under the immigration laws there are two groups that could be included. Persons who were citizens of the country and persons who were born in one of these countries. By Citizenship 134 1 102 20 1 1 2 4 21 1 329 1 1 1 3 1 1 1 164 267 3 319 33 1 13 NardiMFR,

Country Afghanistan Albania Algeria Armenia Australia Austria Azerbaijan Bahrain Bangladesh Canada Denmark Egypt Eritrea Ethiopia France Germany Ghana Iceland India Indonesia Iran Israel Jordan Kazakhstan Kuwait

By Birth 135 101

1 2 3 1 333 4 1

1 166 293 11 293 29 21

p 1-2

In the usual course of immigration enforcement activity, significant incidents are those that involve death or injury of an officer, significant public and media interest, or an unusual event, such as the apprehension of large numbers of smuggled aliens. 14

__., ' \: something that

1 212 7 74 95 1 1 2,135 1 712 1 4 27 838 1 7 102 2 112 1 63 3 1 5 1 2 8 94

Laos Lebanon Libya Malaysia Mexico Morocco Netherlands Nicaragua New Zealand Pakistan Panama Philippines Qatar Russia Saudi Arabia Sierra Leone Somalia South Africa Spain Stateless Sudan Sweden Syria Tajikistan Thailand Turkmenistan Ukraine United Arab Emirates United Kingdom Unknown USSR Uzbekistan Vietnam Yemen

213 10 75 2 97 1 2,140 715 1 2 29 2 841 1 1 102 114 65 1 5 1 1 9 9 1 90 _ -'

Breakdown of the Cases Closed15

15 Closing report as of 7/10/03 when the AAI Project was transferred from Investigations National Security Unit to Detention and Removal Office.

Deleted: The Commission has learned that of the initial group of approximately 5,932 priority absconders, NSU was able to locate or determine the status of 2,261. This represents 38% of the total.lf 1i

Phase 1 of the AAI contained 5.932 cases. The breakdown above, of closed cases, lists a total of 4.074. The difference of 1.858 would be the remaining open cases still under investigation or cases for which there was no final report. Of the 4.074 closed cases. 1.807 could not be located or verified as having left the U.S. The total number of absconder cases that were actually closed as a result of verifying that the subject was no loneer an absconder was 2.267 or about 38% of the original number of 5.932.

AAI Phase 1 5,932 total initial cases 2,267 cases closed after investigation verified departure or immigration status 1,807 cases closed after investigation, unable to locate or verify immigration status 704 absconders located and removed from U.S. during Phase 1 1,858 cases remain open 14 cases referred to FBI for further investigation relating to possible terrorist links 0 cases prosecuted or removed on terrorism grounds

We also have learned that:

• • • • •

• • • •

by the summer of 2002. the initiative had resulted in the apprehension of approximately 700 fugitives.16 by early 2003.1.139 of the designated absconders had been apprehended. immigration authorities had removed from the country 704. and 224 were in custody and awaiting removal. U.S. Attorneys had criminally prosecuted 45 of the absconders. 41 were prosecuted for criminal immigration violations.17 No absconders who were removed as part of the Phase I group, were deported under a terrorism statute, prosecuted for terrorist related crimes, or linked in any way to terrorism. INS referred 14 cases to the FBI based on possible links to terrorism. Administrative closing Asylee/Refugee Board of Immigration Appeals Convention Against Torture

55 14 42 3

Testimony of Joe Green. INS Assistant Commissioner for Investigations, before the House Judiciary Subcommittee on Immigration. June 19. 2002. Testimony of Mike Dougherty. Director of Operations. Bureau of Immigration and Customs Enforcement (ICE). Department of Homeland Security, before the House Judiciary Subcommittee on Immigration. May 8. 2003. A total of 41 were charged with criminal immigration violations.

• Deceased • Duplicate • Identified as Females18 • In State or Federal Custody • In Legal Non-Immigrant Status • LIFE Act Applicant • Legal Permanent Resident • Motion to Reopen Deportation Hearing • No Final Deportation Order • Under Order of Supervision • Other19 • Pending Application for Immigration Benefits • Prior Removal • Refused Entry • Released on Bond • Removed from U.S. • Released on Order of Recognizance • Self-deported20 • Stay of Deportation or Removal2' • Temporary Protected Status (IPS)22 • Unable to Locate or Leads Exhausted • United States Citizen • Waiver Approved • Withholding Jotal

24 12 55 45 11 8 191 64 99 72 56 47 99 7 122 704 25 390 10 18 1807 80 5 9 4.074

Deleted:

r

1

We also have learned that: K

1

National Crime Information Computer (NCIC) NCIC criminal record checks were conducted on all AAI cases. A total of 863 had a criminal history. In many cases the disposition of the cases was not part of the NCIC record. Case agents determined what action was appropriate in each case.

If the alien was identified as female, the case was removed from the AAI project. Includes juveniles, informants, government sources, for file consolidation, post order custody review, reconsideration by District Director 20 Aliens under a final order of deportation who depart the United States voluntarily, legally deport themselves 21 Deportation is the legal term as expressed in the IN A. At some point INS decided to change the term "deportation" and use the term "removal" in response to legislative changes. 22 TPS applies to countries designated by the President as areas of war, disturbance, natural disaster, etc. TPS status can be extended by the President and may continue for years. Aliens must apply for TPS status and cannot usually be removed from the United States. Absconders in this category were from Lebanon, Sierra Leone, Somalia and Sudan. When they were located, a determination was made as to whether they were a threat. If it was determined that they were not, they were removed from the AAI project as they could not be removed. 18 19

<#>by the summer of 2002, the initiative had resulted in the apprehension of approximately 700 fugitives.23 H <#>by early 2003, 1,139 of the designated absconders had been apprehended.^ <#>immigration authorities had removed from the country 803, and 224 were in custody and awaiting removal.^ <#>U.S. Attorneys have criminally prosecuting 45 of the absconders.24 ^ <#>No absconders who were removed as part of the Phase I group, were deported under a terrorism statute, prosecuted for terrorist related crimes, or linked in any way to terrorism.1 <#>14 cases had sufficient terrorism links that they were referred to the local FBI officel]

NCIC hits resulted in 95 individuals being located25. This was the result of routine record checks conducted by law enforcement agencies. The LESC confirms all NCIC hits on immigration absconders in the NCIC Immigration Violators File. The LESC places a detainer on the alien and refers the case to the local ICE field office for follow-up. Three absconders were located as a result of the routine interaction between the FBI and the LESC involving aliens who have been arrested and fingerprinted for criminal activity.

How could aliens under final orders obtain legal permanent residence or be naturalized? A total of 191 absconders were found to be legal permanent residents when located. Another 80 had been naturalized and were United States citizens. This was a total of 271 cases or about 5%. INS record keeping has always been unreliable. The reasons are many. The INS "A" file is actually a paper file. The file is created from an alien's name and was not linked to a biometric identifier. Aliens may use a variety of name variations or they may use aliases to commit immigration fraud or to avoid deportation. Multiple files are not uncommon as the alien may apply for various immigration benefits at the same time.26 In some cases the reason can be explained by the fact that the final order of deportation had been issued years previously. The alien had departed and then legally returned to the United States. In other cases, it was because the United States had no system to record departures and therefore the warrant of deportation was issued after the alien had already departed. Some files were created when the alien applied for immigration benefits and the original "A" was no located or known. This resulted in the alien having two immigration tracks. One file was on the enforcement side of INS and the other was a temporary file on the service side of INS. With over a million aliens arrested each year and over a million aliens applying for benefits most years, the INS was overwhelmed. Not all 5,000 AAI cases were actually entered into NCIC. Immigration records do not always provide the documents required by NCIC to support entry into the system. The Commission believes the remaining absconders who were not apprehended in the first phase of the program, no longer receive special attention from INS/DHS enforcement personnel. The DHS is working to implement the proposed phase two of the project, and

Not all law enforcement agencies arrest immigration absconders even after they have received a "hit" from NCIC. Some agencies believe that they cannot legally arrest or detain an alien unless a crirninal arrest warrant has been issued. 26 Sheik Omar Abdel Rahman, the blind sheik, who was convicted of terrorism, had two immigration files at the same time. He did this by changing his name slightly and filing for immigration benefits at New York City and Newark, New Jersey. Immigration files. 25

incorporate in the same systematic fashion the remaining 314,000 absconders—or the current number-into the NCIC database after careful review. A continuing problem is the failure to have a compatible fingerprint system between the FBI and the INS/ICE. NCIC records contain a complete set of fingerprints which are readable by the IAFIS system. INS/ICE continues to use the two index finger prints that can be matched in the IDENT system. The joining of the two systems has been under development for many years but is behind schedule.

Lessons Learned •

Despite the commitment of extensive investigative resources, only 38% of the absconders could be located or their immigration status verified • The immigration records system is so poor that about 5% of the absconders were not deportable but had become legal residents or naturalized citizens • Many of the absconders were found to have left the United States but without a verifiable entry-exit system their cases remained open • A biographic identifier must be used to link an individual whenever there is interaction with the immigration system • Once someone enters the United States, either legally through a port of entry or illegally across an unguarded border, it is nearly impossible to locate them without extraordinary effort or pure luck,

PROTECT AND PREPARE 17. Integrate border security into national security^

Deleted:, while welcoming lawful visitors and immigrants through efficient border channels, and preventing entry outside them.

17a. Stopping the movement of terrorists must become a part of the international strategy against terrorists.TTerrqrists can be intercejyted with better border and transportation security. The higher the risk preelection,, the more difficult ij will be for terrorists enter and remain in the United States^

Deleted: Border and transportation security will prevent or hobble plots by intercepting terrorists. ( Deleted: detection

{ Deleted: is

17b. Terrorists use a variety of methods to travel, enter and stay in countries clandestinely. (Altered,and counterfeit passports and visas, specific travel methods and routes, and liaisons with corrupt foreign government officials, human smugglers, and travel agencies, are examples of common tactics.) Sophisticated programs specifically designed to detect these mernod^must be developed. This effort is the primary means by which the United States and its allies will be able to intercept traveling terrorists, and one way to uncover them if they succeed in entering.

Deleted: greater the likelihood that terrorists will cease trying.

~( Deleted: Manipulated Deleted: the concealment methods themselves

17c. Form a new partnership between the intelligence and border security communities to develop and use this "travel intelligence." — The intelligence community must perform classic, standard intelligence work. Border officials must collect and analyze information^atabases^interviews, inspections, surveillance and criminal investigations.

_ - j Deleted:fromtheir working and " - reference | Deleted: and

- Terrorist travel specialists should be trained and placed at consular posts, ports of entry, and immigratiori^qffices. Current findings and tools should be integrated _ _ , - \; services into the_Homeland Security'sUS^ISITprogram,Land all otherILS. border „- | Deleted: security programs. State and local officials also should be involved. 17d. Accelerate the construction of US^yiSIT, which links ail mdividuaFs digital _ , _ - \: photo and fingerprints to reference databases, like terrorist watchlists. Make this program the foundation for an integrated US border entry-exit screening system that begins with visa applications, covers entrances and exits from the country, and extends through naturalization. 17e. Establish the ability to monitor the Borders of the United States and respond _ „ _ - \: territorial to unauthorized^entries. Seek to further safeguard the United States by , - \: unknown developing joint approaches to North American border security with Canada and Mexico. ' Deleted: , to strengthen the United

17f. Take the lead^ with allies,, in developing an integrated approach to screening -•' {state's own and global border security individuals worldwide, ^nd support other nations[^efforts to increase use of /_. - -j Deleted: The United states should biometric identification; improve £crutiny and procedures at each point in the " ^ I drive and travel system; and use common_standardsLtha1^make it easier to share mjormatipn. _" % 1 Deleted: governments' x^x

~[ Deleted: the level of 1 Deleted: border and access process x ^

17g. Homeland Security should use the intelligence described above to develop proactive enforcement and regulatory programs to target terrorists and their travel facilitators overseas and in the U.S. It is appropriate to use all laws, including immigration laws, to stop and prevent attacks. New programs should be evaluated in light of the lessons learned from actions taken post 9/11v

, - -f Deleted: Hastily designed uses of immigration laws against American Arabs and Muslims that are not

17h.TThe entry, of students, scholars, businessmen, and tourists is important to our^ * demonsn-abiy effective in preventing economy and cultural"vitality,"anyejJianc^asVinfluencearound^e world] ~ ~_ ^ KS^Si^c^S," Lawful immigration also reflects national interests and ideals. Immigration policy * \ [ and the alienation of these communities. must find a balance between an open door and a moat. Illegal entry^nd a v^\ Deleted: The breakdown in the immigration benefits system in the United States, however, \ V (Deleted: of large numbers make more difficult the task of detecting and deterring terrorists. National \ formatted; indent- Left- o s" security provides a compelling reason to establish a safe, orderly, rational, and \ Deleted- to— humane immigration system. w ',. ') T

'

Deleted: When rules to provide security do not actually prevent terrorist entry, and instead exclude lawful visitors, they need to be revised

•1 Deleted: Deleted: across our borders Deleted: •!

1 1 1 1

LIMITED OFFICIAL USE / LAW ENFORCEMENT SENSITIVE Pursuant to the Alien Absconder Initiative (AAI) guidance memorandum from the Deputy Attorney General, dated January 25, 2002, the Foreign Terrorist Tracking Task Force (FTTTF) compiled a list of alien absconders per the criteria detailed in the response to question #1. The INS Headquarters National Security Unit (NSU) was responsible for managing Phase I of the project from January 25, 2002 through July 2003. After July 2003, the Detention and Removal Office (DRO) assumed management of the initiative. 1.

Who was targeted in the original list of 5,900 aliens? The total number of alien absconders who were targeted during Phase I of the Alien Absconder Initiative (AAI) was 5923. The alien absconders were all males from "countries in which the Intelligence Community indicated AlQaeda terrorist presence or activity." All subjects identified had received final orders of deportation/removal and had absconded. The Attorney General and the FTTTF developed the following criteria that was used to determine whether an individual was included on the list: 1) males; 2) between ages of 18 - 50; and 3) from "special interest countries."1

2.

What was the mechanism for determining who was to be included in the original list? Immigration database searches were conducted in the Deportable Alien Control System (DACS) for male alien absconders between the ages of 18-50 who were from countries referenced in the response to question #1.

3.

How many had identifiable terrorist indicators? During AAI Phase I, none of the subjects had been identified as possible terrorist threats. The individuals were included in Phase I based on the criteria as previously described in the response to question #1.

4.

How many were from countries identified as supporting terrorism? The subjects' Alien Registration Files (A-Files) were examined to determine the subjects' country of birth and country of citizenship based on the list of "special interest countries." As the term "from" used in the

The following list of countries from a compilation of State Department and other United States government lists are referenced as "special interest countries:" Afghanistan, Algeria, Bahrain, Bangladesh, Djibouti, Egypt, Eritrea, Indonesia, Iran, Iraq, Jordan, Kazakhstan, Kuwait, Lebanon, Libya, Malaysia, Morocco, Oman, Pakistan, Philippines, Qatar, Saudi Arabia, Somalia, Sudan, Syria, Tajikistan, Thailand, Tunisia, Turkey, Turkmenistan, United Arab Emirates, Uzbekistan, Yemen, Territories of Gaza & the West Bank

LIMITED OFFICIAL USE / LAW ENFORCEMENT SENSITIVE