The ABCs of Special Registration

Special Registration is a system that will allow the U.S. government to keep track of specific nonimmigrants that come to the United States every year or are already in the United States. The U.S. government has implemented this program because it has determined that certain nonimmigrants require closer monitoring when national security or law enforcement interests are raised.

This article will provide general information about the new Special Registration system that has been implemented and enforced by the Immigration & Naturalization Service (INS)¹ within the past several months. Because of the importance of this information, we encourage companies and foreign national employees to continually check the Immigration Service's website for more updated information on Special Registration as the INS continues to implement new procedures, as well as to add additional countries. The author would like to acknowledge the Immigration Service's website and the American Immigration Lawyers Association and its website as sources for the information used in this article. A complete list of source material used in this article is attached at the end.

Background and History of Special Registration

U.S. law has long required foreign nationals who stay in the U.S. for more than 30 days to be registered and fingerprinted. However, such requirements have been suspended for decades, with respect to most foreign nationals. Under current law, the Attorney General can require the registration and fingerprinting of any class of foreign nationals, other than those admitted for permanent residence. For many years, the immigration regulations have waived the fingerprinting requirements. However, the Attorney General has the authority to require registration as long as the countries subject to registration are outlined through the publication of a Federal Register Notice.

European Countries Already Have Registration Systems

Most European countries already have registration systems for foreign nationals in place. For example, in France, foreign nationals who stay for an extended period, must register with the local prefecture of the national police within one week of arrival, every 12 months, and whenever there is a change of address. Additionally, in Germany, a foreign national must register when residence is established and when there is a change in address.

What is NSEERS?

According to the Attorney General, this rule is part of the country's New National Security Entry-Exit Registration System (NSEERS), which will expand America's scrutiny of foreign visitors entering the country who may pose a national security concern. Congress has mandated that by 2005 the Department of Justice build an entry-exit system that tracks virtually all 35 million foreign visitors who come to the United States annually. The goal is that through fingerprinting and photographing at the border, and now at local INS offices, and then running the fingerprints against a database of thousands of known terrorists, immigration officials will be able to stop terrorists from entering or remaining in the country. The registration requirement is a way for the United States to make sure that foreign nationals do not try to disappear into society, and that they stick to their stated plans while in the country. Finally, NSEERS is establishing a system of exit controls, so that the U.S. government will know who leaves on time and who does not. Individuals who try to evade registration requirements or who attempt to stay in the country beyond their permitted time will be arrested, prosecuted, and likely deported.

Foreign Nationals Subject to Special Registration

As of February 13, 2003, the INS has announced that four separate groups of nationalities already in the United States are subject to Special Registration. The INS refers to these groups as Call-in Group 1, Call-In Group 2, Call-In Group 3, and Call-In Group 4. Additionally, foreign nationals from these countries who are entering the United States are also subject to Special Registration upon their admittance into the United States. In addition to the specific countries outlined in these Call-in Groups, foreign nationals from other countries who may meet certain criteria are also being subjected to Special Registration upon their admittance into the United States.

Call-In Group 1

On November 6, 2002, the INS announced that citizens or nationals of Iran, Iraq, Libya, Sudan and Syria were required to appear at a designated INS office between November 15, 2002 and December 16, 2002. As outlined by the INS, this rule was to be applied to: (1) males born on or before November 15, 1986; (2) those individuals admitted to the United States as a nonimmigrant on or before September 10, 2002; (3) those individuals that had not applied for asylum on or before November 6, 2002; and (4) those individuals who were going to be in the United States until at least December 16, 2002.

Call-In Group 2

On November 22, 2002, the INS announced that citizens or nationals of Afghanistan, Algeria, Bahrain, Eritrea, Lebanon, Morocco, North Korea, Oman, Qatar, Somalia, Tunisia, United Arab Emirates and Yemen were required to appear at a designated INS office between December 2, 2002 and January 10, 2003. As outlined by the INS, this rule was to be applied to: (1) males born on or before December 2, 1986; (2) those individuals inspected by the INS and last admitted to the United States as a nonimmigrant on or before September 30, 2002; (3) those individuals that had not applied for asylum on or before November 22, 2002; and (4) those individuals who were going to be in the United States until at least January 10, 2003.

Call-In Group 3

On December 18, 2002, the INS announced that citizens or nationals of Pakistan and Saudi Arabia were required to appear at a designated INS office between January 13, 2003 and February 21, 2003. However, through a Federal Register Notice published on February 19, 2003, the Department of Justice announced an extension until March 21, 2003 for Call-In Group 3. As outlined by the INS, this rule was to be applied to: (1) males born on or before January 13, 1987; (2) those individuals inspected by the INS and last admitted to the United States as a nonimmigrant on or before September 30, 2002; (3) those individuals that did not have an application for asylum pending on or before December 18, 2002; and (4) those individuals who were going to be in the United States until at least February 21, 2003.

Call-In Group 4

On January 16, 2003, the INS announced that citizens or nationals of Bangladesh, Egypt, Indonesia, Jordan and Kuwait were required to appear at a designated INS office between February 24, 2003 and March 28, 2003. However, through a Federal Register Notice published on February 19, 2003, the Department of Justice announced an extension until April 25, 2003 for Call-In Group 4. As outlined by the INS, this rule was to be applied to: (1) males born on or before February 24, 1987; (2) those individuals inspected by the INS and last admitted to the United States as a nonimmigrant on or before September 30, 2002; (3) those individuals that did not have an application for asylum pending on or before January 16, 2003; and (4) those individuals who were going to be in the United States until at least March 28, 2003.

Individuals Registered Upon Admission to the United States

On September 11, 2002, a rule went into effect that required registration and fingerprinting of certain nonimmigrants. This rule requires certain foreign nationals to be fingerprinted and photographed by the INS upon their admission into the United States, as well as ongoing registration with the INS if they remain in the United States for more than 30 days. All citizens and nationals of the countries in the four call-in groups are subject to this requirement upon admission, as well as foreign nationals of other countries that meet certain criteria.

"Secret" INS Memorandum

In a confidential memorandum dated September 5, 2002, the INS outlined an expanded special registration process. This "secret" INS memorandum was obtained by a news organization and its information was released to the public. Included in this memorandum were procedures for registering citizens and nationals of Pakistan, Saudi Arabia and Yemen; nonimmigrants identified by the Interagency Border Inspection System (IBIS); and foreign nationals of any nationality who satisfied "pre-existing" criteria.

"Pre-existing" Criteria

1. The nonimmigrant foreign national has made unexplained trips to Iran, Iraq, Libya, Sudan, Syria, North Korea, Cuba, Saudi Arabia, Afghanistan, Yemen, Egypt, Somalia, Pakistan, Indonesia, or Malaysia, or the alien's explanation of such trips lack credibility.
2. The nonimmigrant foreign national has engaged in other travel, not well explained by the foreign national's job or other legitimate circumstances.
3. The nonimmigrant foreign national has previously overstayed in the United States on a nonimmigrant visa, and monitoring is now appropriate in the interests of national security.
4. The nonimmigrant foreign national meets characteristics established by current intelligence reports and advisories.
5. The nonimmigrant foreign national is identified by local, state or federal law enforcement as requiring monitoring in the interest of national security.
6. The nonimmigrant foreign national's behavior, demeanor or answers indicate that the foreign national should be monitored in the interest of national security.
7. The nonimmigrant foreign national provides information that causes the immigration officer to reasonably determine that the individual requires monitoring in the interest of national security.

Permanent Residents, Asylees, and Others Not Subject to Special Registration

At this time, Special Registration does not apply to U.S. citizens, lawful permanent residents, refugees, asylees, certain asylum applicants, and foreign nationals who entered the United States without inspection. It is important to note that for Call-In Groups 1 and 2, the INS exempted individuals who had filed an asylum application as of a particular date. For Call-In Groups 3 and 4, the INS exempted only those whose applications were pending as of a certain date. The INS-Bloomington office has indicated that for all Call-In Groups, INS interpretation is to exempt only those individuals whose applications for asylum were pending as of the referenced date. Foreign nationals who are diplomats in A status and official government representatives to international organizations in G status are also exempt from Special Registration.

INS has also indicated that parolees, including applicants for permanent residence who were last admitted into the United States pursuant to INS-issued advance parole documents, are not currently subject to Special Registration. Applicants for permanent residence who meet the requirements listed above and who were not last admitted in advance parole status are subject to Special Registration. Recent reports indicate that there will likely be issues with individuals who were subject to Special Registration and who later become lawful permanent residents. According to some INS offices, if a Special Registrant becomes a permanent resident prior to the registration anniversary date, the Special Registrant should send Form AR-11SR updating the INS with this information, including the adjustment date. It appears that at this time there is no other mechanism for the NSEERS system to become notified of a Special Registrant's permanent residence status.

At this time, Call-In Registration does not apply to females who are citizens or nationals of the countries listed above. However, some females have been subjected to Special Registration pursuant to the procedures upon admission into the United States.

Dual Citizens/Nationals from Canada and other Countries

The applicability of Special Registration requirements to persons of dual citizenship or nationality is, unfortunately, a fairly gray area. At this time, it is NOT clear whether Canadian citizens (and citizens of other countries not currently subject to Special Registration) who were born in countries subject to Special Registration are or are not subject to registration. Guidance from the INS and other government agencies has muddied the waters with regard to this important issue.

Upon concerns from the Canadian government that Canadian citizens who were born in one of the listed countries were being subject to Special Registration upon admission into the U.S., the Department of Justice issued a statement on November 20, 2002 that "place of birth, by itself, will not automatically trigger registration." However, in a Federal Register Notice published on November 6, 2002, the notice was made applicable to any alien who is a citizen or national of a designated country, notwithstanding dual nationality or citizenship with another country. An informational sheet from the INS also indicates that those who claim citizenship from countries included in the Call-In Groups are required to register even if they are also citizens of another country. Field Guidance issued to INS district offices handling call-in registration specifically states that call-in registration is applicable notwithstanding dual nationality or citizenship. If the foreign national holds a passport or other document that identifies him as a citizen or national of a designated country, or has personal knowledge of such citizenship or nationality, this Guidance indicates that they are subject to special registration. Finally, the Canadian government website states that Canadian citizens born in one of the listed countries are to be exempt from Special Registration when entering the United States – but are subject to "call-in" registration like other dual citizens/nationals.

In addition to the confusion caused by these various documents, INS offices and U.S./Canadian ports of entry are applying these rules in different ways. Some offices and ports are not subjecting Canadian (and other) citizens who were born in one of the listed countries to Special Registration, but others are. The American Immigration Lawyers Association (AILA) has been trying to work on this issue with the INS. INS has indicated to AILA that it will look to the laws of the country of birth to determine if dual citizenship exists, and thus special registration applies. However, INS has not yet clearly outlined these rules or procedures for AILA or others.

Because of the complexity of these issues and the importance of complying with registration requirements, cases that involve dual citizens/nationals must be carefully examined on a case-by-case basis.

Other Countries or Nationalities

As has been demonstrated by the INS through the addition of several countries over the past few months, it is likely that the Department of Justice will continue to add countries to the list of Special Registration and that Special Registration will apply to all nationalities by 2005. However, a local INS official recently indicated that Call-In Group 4 is likely to be the last group. Because of this uncertainty concerning the addition of more countries, employers and foreign nationals should continue to be alert and check the INS website, or with an immigration attorney, regarding these requirements. The Immigration Service's website has a special section devoted to issues and information about Special Registration.

Special Registration Procedures

Foreign nationals subject to Call-in Special Registration are required to appear and register at an INS field office. A list of INS field offices conducting special registration can be found on the Immigration Service's website at: www.immigration.gov in the Special Registration section. Foreign nationals who are subject to this rule and who are entering the United States are required to register their presence in the United States and be photographed and fingerprinted at the port of entry when applying for admission to the United States.

Call-In Procedures

In addition to answering questions under oath before an immigration officer, foreign nationals subject to Call-in Special Registration will be required to present to the immigration officer: (1) their travel documents, including passport, Form I-94 card issued upon admission into the United States, and any other forms of government-issued identification (e.g. driver's license, state ID card, etc); (2) proof of residence, such as a lease or rental agreement; (3) proof of enrollment at educational institution (for student-visa holders); (4) proof of employment; and (5) any other information requested by the immigration officer. These foreign nationals will also be fingerprinted and photographed and will be required to visit the INS every 12 months thereafter until the foreign national departs from the United States. These foreign nationals will also be required to be examined by an inspecting officer at the time of departure from the United States in order to have their departure confirmed and recorded by the inspecting officer. In addition to the above, these foreign nationals will also be required to provide any change of address to the INS within 10 days, as well as any employment, educational institution or other material change. Foreign nationals should notify the INS of these changes by using Form AR-11 SR (Alien's Change of Address Card – Special Registration). A copy of this form can be obtained from the Immigration Service's website.

Admission at Port of Entry

Upon entry for admission to the United States, foreign nationals subject to Special Registration will be photographed, fingerprinted, and questioned by the INS official at the airport or land port of entry. Those foreign nationals that are subject to Special Registration and who remain in the United States for 30 days or more, will be required to appear at an INS field office and re-register between 30 and 40 days after initial admission into the United States. They will be required at that time to provide: (1) proof of tenancy at stated U.S. address (e.g., rental contract, mortgage); (2) proof of enrollment at educational institution (for student-visa holders); and (3) proof of employment (for work visa holders). These foreign nationals will then be required to visit the INS every 12 months thereafter until the foreign national departs from the United States. These individuals will also be required to be examined by an inspecting officer at the time of departure from the United States in order to have their departure confirmed and recorded by the inspecting officer.

Departure Notification

Upon departure from the United States, a nonimmigrant foreign national who is subject to Special Registration is required to report to an INS departure control officer at a specified port of entry. This includes visits to Mexico, Canada or adjacent islands. This list is available from the National Customer Service Center (1-800-375-5283). It is important to note that on February 19, 2003, the INS updated this list of designated ports of entry for departure by Special Registrants. If a foreign national is subject to Special Registration, they must review this list prior to any departure from the United States as many airports and land ports of entry are not included and the INS has indicated that newly designated ports may be added by a Federal Register notice at any time. If a Special Registrant fails to depart as instructed, the foreign national will be deemed to be inadmissible as an alien whom the Attorney General has grounds to believe seeks to enter the United States to engage in unlawful activity.

INS Field Guidance on Special Registration

The INS has recently issued field guidance to local offices regarding implementation of Special Registration. Although barred from releasing this memorandum to the public, the INS has told AILA that the memo covers the following areas: (1) what checks are to be completed on each registrant; (2) how to determine the appropriate action, such as referral to Investigations or issuance of a Notice to Appear for removal proceedings; and (3) factors in determining whether someone should be taken into custody. This memo also states that if a registrant has an application pending, and approval would result in lawful status (temporary or permanent), the foreign national should be registered and not referred to Investigations.

Previous field guidance on Special Registration advised INS officials that when information is encountered during the call-in registration process that could subject the foreign national to removal proceedings, the foreign national should be referred to the Investigations section for appropriate action.

Notation on Form I-94 Card

Upon completion of registration, the foreign national's Form I-94 card must be annotated with the fingerprint identification number above the family name. For call-in registrants, the words "Special Registrant – Call-In" will be annotated or stamped on the reverse side of the Form I-94 card.

Practical Advice regarding Call-In Registration Procedures

In addition to bringing the documentation that is specifically outlined and referenced by the INS (see above), we would recommend that foreign nationals who are subject to Special Registration bring in all immigration documentation that shows that they are currently in and are maintaining their nonimmigrant status. For example, an H-1B visa holder should bring the original, unexpired INS-issued H-1B Approval Notice. If an applicant for permanent residence is subject to special registration and is working pursuant to an INS-issued Employment Authorization Document (EAD), that foreign national should have the original I-485 Receipt Notice and original INS-issued EAD card.

During Call-In Registration, INS officials have been requesting to review and document everything in a Special Registrant's wallet or purse, including credit cards, video rental cards, etc. In order to avoid such intrusion, it is recommended that the foreign national does not enter the INS office with a wallet or purse. Instead, the foreign national should just carry the required documentation (i.e. driver's license, passport, Form I-94 card, immigration documentation, company badge).

Local INS Bloomington Procedures

There is no appointment system for Special Registration. Those required to appear for Special Registration must go to the local INS office in Bloomington prior to the specified deadline for their specific country. There are now two lines at INS Bloomington – one for the general public and a second one for individuals with appointments. The appointment line is the line that should be used for special registrants. The INS office in Bloomington has a special biographic information sheet and questionnaire for Special Registration. Foreign nationals appearing for call-in registration at INS Bloomington should familiarize themselves with these documents and the information that is requested. This will help them prepare for the Special Registration interview and questions they will be asked by the interviewing officer.

Late Registration

On January 16, 2003, the INS announced that citizens or nationals of Afghanistan, Algeria, Bahrain, Eritrea, Iran, Iraq, Lebanon, Libya, Morocco, North Korea, Oman, Qatar, Somalia, Sudan, Syria, Tunisia, United Arab Emirates or Yemen who were required to register by December 16, 2002 and January 10, 2003, but did not do so, should register pursuant to the prior Notices issued by the INS. These foreign nationals may appear before and register with the INS pursuant to the Special Registration procedures between January 27, 2003 and February 7, 2003. In this announcement, the INS specifically stated that this is "an act of grace" and that in its discretion, "the Attorney General has decided to permit those individuals who were required to register under the Groups I and II Notices but who did not do so, an additional opportunity to register and provide information in a timely fashion." This announcement also specifically stated that it only applied to Call-In Groups 1 and 2 and that "aliens who are covered by other notices are not being, and should not expect to be, afforded an additional opportunity to comply with the requirements of the relevant notice." However, on February 19, 2003, the INS announced an extension in the time periods to register for Call-In Groups 3 and 4. The time period for Call-In Registration was extended until March 21, 2003 for Call-In Group 3 and until April 25, 2003 for Call-In Group 4.

Prior to this announcement by the INS allowing late registration for Call-In Groups 1 and 2, different INS offices and examiners around the country were taking different approaches with late registration of foreign nationals in Call-In Groups 1 and 2. Some offices were allowing foreign nationals to register late without any consequences. Other offices were detaining and placing foreign nationals into removal proceedings, even if those foreign nationals had no other immigration or criminal problems and were otherwise in lawful status.

Field Guidance from the INS indicates that the INS official must determine whether the failure to register timely was excusable and/or not willful. This Guidance also suggests that the interviewing officer should obtain supervisory concurrence before determining that the failure was excusable and/or not willful and then the foreign national should be registered. If the failure was willful or not reasonable excusable, the foreign national should be referred for possible enforcement action.

Change of Address, School or Employer Requirements for Special Registrants

Within 10 days of a change of address, school or employer, the INS must be notified by mail of the change. A foreign national who is subject to Special Registration must use a special form – Form AR-11 SR (Alien's Change of Address Card – Special Registration). This form can be can be obtained and printed from the Immigration Service's website www.immigration.gov. Special Registrants should send their change of address form to the following address:

Regular Mail
BCIS
Change of Address – Special Registration
P.O. Box 7134
London, KY 40242-7134

Overnight Mail Services
BCIS
Change of Address – Special Registration
1084-1 South Laurel Road
London, KY 40744

The INS suggests that it is advisable to use certified, registered or receipt mail so that the foreign national has documentation that the form was mailed to the INS. When a Special Registrant is completing this particular form, the INS also indicates that the Special Registrant must copy the Fingerprint Identification Number (FIN) that was written on the Special Registrant's I-94 form or passport when the foreign national was registered and fingerprinted by the INS. Additional information about Special Registration and change of address procedures for these foreign nationals can be obtained from the Special Registration section on the Immigration Service's website.

Waivers

Waivers for certain Special Registration requirements can be requested in limited circumstances. Waivers are only applicable to a specific INS District. For example, if the INS District Director in Minnesota were to grant a waiver, that waiver would only be recognized as valid with airports and ports of entry in this particular district (i.e., land ports of entry along the Canadian border with North Dakota and Minnesota; INS Pre-flight Inspection in Winnipeg; and the Minneapolis-St. Paul airport). Additionally, any waiver that was granted would only be valid for a one-year period.

To obtain a waiver, an individual must be subject to Special Registration and in the Special Registration system. A waiver can only be applied for and obtained after a foreign national has been through the registration process. This could be through call-in registration or registration by the INS upon admittance to the U.S. Any waiver request will be subject to very strict scrutiny and is only applicable to foreign nationals that have the "cleanest" immigration history and background. Moreover, waivers will only be granted in situations where the special registrant has extensive and frequent international business travel. Although the waiver procedures outlined by the INS indicate that a waiver can be obtained for "all or part" of the requirements, it is likely that, if granted, the INS will only grant a waiver for some of the requirements, such as the admission/interview requirements.

Penalties for Failure to Register

Failure to register will result in the foreign national's name being turned over to law enforcement, fines, incarceration, and possible removal from the country. Failing to register could also impact any future immigration benefit from the United States. A nonimmigrant who willfully fails to comply with the registration rules and to provide information requested truthfully is deportable for failing to maintain nonimmigrant status. Extra sanctions can be imposed on those registered at entry or who are later subject to registration if they fail to register upon departure.

Where to Find Additional Information about Special Registration?

The Immigration Service's website has a special section devoted to issues and information about Special Registration. This website includes questionnaires and documents being used by local offices. Because of the importance of this information, we encourage companies and foreign national employees to continually check this website at www.immigration.gov for more updated information on Special Registration as new procedures continue to be implemented and new countries are added to the list. The American Immigration Lawyers Association (AILA) also has certain information on special registration available to the general public on its website at www.aila.org, including an Office-by-Office Summary of How INS is Handling Call-In Special Registration.

Conclusion

The INS has already fingerprinted and processed thousands of foreign nationals pursuant to Special Registration and the NSEERS program. During testimony before the Senate Committee on Finance Regarding Combating Terrorism: Protecting the United States on January 30, 2003, the INS announced the following statistics about the NSEERS program: (1) 7 suspected terrorists were identified and apprehended; (2) 341 foreign nationals have been denied admission to the United States because of law enforcement concerns or prior criminal or immigration violations; (3) 26,334 foreign nationals have been registered through Call-In Registration; (4) 2,776 of the 26,334 have been charged with immigration status violations with 84 who remain in custody and 21 who have serious criminal backgrounds. Moreover, despite constitutional protests from many groups, including several members of Congress, it is clear that the INS or the new Department of Homeland Security will continue to implement and likely expand upon these procedures as part of the Bush Administration's war on terrorism. Therefore, because these procedures continue to be changed and added to, it is extremely important that companies and their foreign national employees continue to update themselves on the latest INS procedures with respect to Special Registration.

Sources:

Articles

1. "Field Guidance on Special Registration (Updated 1/13/02)." Posted on AILA InfoNet at Doc. No. 03011040 (Jan. 13, 2003).
2. "Office by Office Summary of How INS is Handling Call-In Special Registration (Updated 1/30/03)." Posted on AILA InfoNet at Doc. No. 02121642 (Jan. 16, 2003).
3. "AILA's Statement in Opposition to the Special Registration Program." Posted on AILA InfoNet at Doc. No. 02121644 (Dec. 16, 2002).
4. "Members of Congress Protest Special Registration." Posted on AILA InfoNet at Doc. No. 02122640 (Dec. 26, 2002).
5. "Practice Note on Call-In Special Registration for Citizens of Third Countries." Posted on AILA InfoNet at Doc. No. 02122645 (Dec. 26, 2002).
6. "DOJ Seeks to Assuage Canadian Concerns Over Special Registration." Posted on AILA InfoNet at Doc. No. 02110540 (Nov. 5, 2002).
7. "History of Special Registration." Posted on AILA InfoNet at Doc. No. 02120943 (Dec. 9. 2002).
8. "The New Rule on Special Registration," Stanley Mailman and Stephen Yale-Loehr, Bender's Immigration Bulletin, Vol. 7, No. 22 (November 15, 2002), p. 1399.
9. "AILA Q&A About "Call-In" Special Registration (Updated 12/26/2002). Posted on AILA InfoNet at Doc. No. 02121741 (Dec. 17, 2002).
10. "INS Publishes Proposed Rule on Registration and Fingerprinting of Designated Nonimmigrants,"Immigration Business News & Comment, Vol. 4, No. 12, (July 15, 2002).
11. "INS Testimony on Combating Terrorism," Posted on AILA InfoNet at Doc. No. 03020544 (Feb. 5, 2003).

Government Materials

1. INS Memorandum from Johnny Williams, Executive Associate Commissioner, Office of Field Operations, dated November 27, 2002 regarding Special Registration of Certain Nonimmigrant Aliens Already Admitted to the United States.
2. Department of Justice Memorandum dated June 5, 2002 regarding National Security Entry-Exit Registration System.
3. Attorney General Prepared Remarks on the National Security Entry-Exit Registration System dated June 6, 2002.
4. INS Memorandum from Johnny Williams, Executive Associate Commissioner, Office of Field Operations, dated September 5, 2002 regarding Identification of Nonimmigrant Aliens Subject to Special Registration, or the National Security Entry Exit Registration System.
5. Special Call-In Procedures for Certain Nonimmigrants (for all Call-In Groups) Questions and Answers, Immigration & Naturalization Service
6. Federal Register, Vol. 68, No. 11, January 16, 2003, p. 2363.
7. Federal Register, Vol. 67, No. 241, December 16, 2002, p. 77135.
8. Federal Register, Vol. 67, No. 215, November 6, 2002, p. 67766.
9. Federal Register, Vol. 67, No. 226, November 22, 2002, p. 70526.
10. Federal Register, Vol. 67, No. 155, August 12, 2002, p. 52584.
11. Federal Register, Vol. 67, No. 114, June 13, 2002, p. 40581.

Web Resources

1. Bureau of Citizenship and Immigration website (formerly Immigration and Naturalization Service).
2. American Immigration Lawyers Association (www.aila.org).

   Footnotes

   ¹ On March 1, 2003, the Immigration and Naturalization Service became part of the new Department of Homeland Security. The Bureau of Citizenship and Immigration Services (BCIS) now handles all immigration services and benefits. As this article was prepared prior to the transition, references to the INS can be read as a reference to the BCIS.