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prosecuting criminal and civil denaturalization cases, in combination with the

Department of Justice, for aliens who obtained citizenship through fraud or other

illicit means. Additionally, USCIS should create a criminal enforcement component within the agency to investigate immigration benefits fraud under Title 8

(perhaps requiring additional legislative and regulatory authorities for the officers themselves) and to prosecute cases through Special Assistant U.S. Attorneys

(SAUSAs) with substantive knowledge in the field. Particular attention should be

given to addressing increasing incidents of forced labor trafficking in temporary

work visa programs.

While the Biden regulatory agenda has focused on at least two major rules—the credible fear rule and the public charge rule—USCIS has utilized other policy and internal procedural mechanisms to extend employment authorization to large groups of people who are in the country without legal status. The agency has taken quiet steps to cut corners and lessen adjudicatory standards. During a transition period, a complete audit of agency policies, memoranda, and management directives issued during the Biden Administration should be completed, and rescission documents should be prepared for issuance within the first few days of the incoming Administration. Additionally, regulatory documents should be drafted to review or reverse all regulations promulgated during the Biden Administration.

New Policies

To advance the national interest, the three core immigration agencies— USCIS, ICE, and CBP—should remerge and have immigration elements outside of DHS (such as ORR of HHS) included. The fragmented immigration enforcement framework that developed in the wake of the Homeland Security Act has weakened each agency and should be remediated. Combining these critical agencies would strengthen their capabilities, ensure cooperation, and promote information-sharing. Agency responsibilities and the delineation of authorities, such as inconsistent use of deferred action and issuance of NTAs by each agency, have long been a point of contention that would be addressed much more easily if they were recombined into a single entity.

Alternatively, new policies for USCIS as it currently exists should focus on matters that can be addressed through administrative action.

• The workforce should be realigned and, as necessary, retrained on base eligibility and fraud detection rather than speed in processing.

• Training should be returned to Federal Law Enforcement Training Centers

(FLETC), which would underscore the enforcement role of USCIS asa vetting agency, and be rebranded accordingly.