JOD uoae: 320087 DOC Number: Type document number hen

Consular Operations, Policies,

Procedures, and Management in
° & VVw
Ottawa and Montreal g ° 2.
Record of Analysis

Analysis Title A review of the consular operations, policies, procedures, and

management style at the U.S. embassy in Ottawa and the U.S. consulate in
Montreal.

Source Ottawa: Consul General Leslie Gerson; Vice Consuls Julie Stinehart and
Craig Bryant

Montreal: Consular Section Chief Bernadette Allen; NTV Chief/Vice Consul

Marko Velikonja; NIV officer/Vice Consul Jeanette Rebert; IV Chief/Consul
Mary Grandfield; IV officer/Vice consul Rebecca Varner

The GAO team visited Ottawa and Montreal to observe consular

Analysis/Summary operations and to discuss ways in which the visa process could be used to
screen out terrorists. At the embassy in Ottawa, our main point of contact
was Consul General Leslie Gerson. In addition to her duties as chief of
consular operations in Ottawa, Ms. Gerson had jurisdiction over the six
other U.S. consulates in Canada—Halifax, Quebec City, Montreal,
Toronto, Vancouver, and Calgary. During our visit to Montreal, our main
point of contact was Bernadette Allen, the Consular Section Chief.
Montreal is the only post in Canada that processes both immigrant visas
(IV) and nonimmigrant visas (NIV). Ottawa and the five other consulates
handle only NIVs and American citizen services (ASC),

The U.S. embassy and U.S. consulates in Canada do not process visas for
Canadians or landed immigrants1 from Commonwealth countries who are
planning to make a temporary visit to the United States. Canadian citizens
and landed immigrants in Canada who are either British subjects, citizens
of a Commonwealth country, or citizens of Ireland do not need to obtain a
visa to apply for admission to the United States. Commonwealth member
countries include many countries that are not U.S. visa waiver countries,
such as Pakistan, Bangladesh, and Nigeria (see workpaper for a
complete list of the 54 Commonwealth countries). Canadians and
Commonwealth landed immigrants seeking to work, study, or emigrate to
the U.S. would still need to seek the appropriate visa.

1 Landed immigrants in Canada are essentially green card holders. They are permanent residents in
Canada and can apply for citizenship after three years residency.

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Consular officers worldwide spend a large portion of their time

NIV Processing processing non-immigrant visas. Although posts vary in terms of workload
and local conditions, basic visa processing is fundamentally the same at
all posts:

1. Receive and Review Applications

2. Enter Data
3. Conduct Interviews
4. Make Adjudication Decisions
5. Prepare and pass back documents to applicant

[source: How to Improve Your NIV Processing and Briefing for SFRFC
Staffers]

The first step in NIV processing is the receipt and review of applications.
Receive and Review All applications must be submitted using form DS-156 (plus DS-157 for all
Applications male applicants). Applications must include a recent photograph of the
applicant and supporting documentation, such as job letters, bank
statements, and family records. The most popular visa worldwide is the
B1/B2 (visitor for business and pleasure), although there are more than 30
different types of non-immigrant visas. Some visa categories require
specific documentation, such as the 1-20 for the F-l student visa [source:
Briefing for SFRFC Staffers and the Self-Instructional Guide:
Nonimmigrant visa classification].

Applicants who apply in person at the consulate are usually "personal

appearance required" (PAR) applicants. Applicants using the post's drop
box or a third-party screener such as a travel agent or corporation are
considered to be "personal appearance waived" (PAW) applicants.

PAR applicants arrive at the consulate for a scheduled appointment or as

walk-in customers. They hand in their application and pay a $45 USD
application fee. PAW applicants submit their applications and fee through
the post's drop box or through a third-party screener.

A foreign service national (FSN) then pre-screens the applicant - ensuring

that all necessary documents are included and asking PAR applicants
some basic questions. Some PAR applicants are prescreened out of the
interview process at this stage if they are determined to be documentarily
qualified. For example, the visa interview is often waived for individuals
who have held previous visas and have used them properly.

Personal appearance waiver (PAW) programs

The Department of State considers PAW programs a best practice because

they free up limited consular resources, are more convenient for
applicants, and potentially enhance the post's public image. In order to
implement a PAW program, posts identify a segment of their applicant
pool for which visas are almost issued. These applicants can be referred
to a third party for screening, such as a travel agency or a corporation.

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The third party is responsible for preparing and presenting the application
and any supporting evidence to the post. Consular officers then review
and adjudicate these applications [source: How to Improve Your NTV
Processing].

The document review, whether it is done by a third party screener, an FSN

at post, or later by the FSO, may reveal grounds for ineligibility. For
example, a stamp on the last page of the applicant's passport that reads
"Application received, AmEmbassy London," indicates that the applicant
had previously been refused a visa in London, [source: Self-Instructional
Guide, Visa Ineligibility].

After receiving and reviewing applications, the FSN enters data from the
Enter Data application form. The data-entered applications are now ready to be
adjudicated by an FSO. In the case of PAW applications, the third party
screener sometimes performs the data entry function as well as preparing
the NTV application. In Saudi Arabia, for example, travel agents enter PAW
appli cations' names and data directly into a version of the consular
consolidated database, which is then saved on a diskette, and given to the
post [source: U.S. Visa Express Program Agent Manual].

Although the third party or an FSN at post can perform pre-screening and
data entry, a Foreign Service officer must do the interview and make the
adjudication decision.

The interview is considered to be the first step of the adjudicating

Conduct Interviews process, yet the importance of the interview varies depending on the post.
Some high-fraud, high refusal-rate posts interview a large percentage of
NIV applicants. [The GAO hardship team documented the need to
interview 70-80 percent of NTV applicants in Guangzhou, China]. Posts
with low-refusal and low-fraud rates historically interview a smaller
percentage of applicants. The length of the interview varies according to
workload pressures and the interview style of the consular officer.

The interview may reveal ineligibilities that were not apparent in the
document review. During the interview, consular officers seek
clarification of ambiguities on the DS-156 or other documents that the
applicant has provided. The officer attempts to verify the facts that are
stated on the application form and to confirm that the applicant's
documents are bona fide [source: Self-Instructional Guide, Visa
Ineligibility].

PAW applicants are not interviewed except when the consular officer
needs further clarification of the applicant's documents. In this case, the
applicant will be required to appear for an interview, after which the FSO
can make a decision. Although visas can be issued without a personal
appearance, they cannot be denied unless the applicant is given the
chance to appear in person.

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Consular officers are tasked with the difficult job of efficiently issuing
Make Adjudication visas to bona fide applicants while refusing visas to ineligible individuals.
Decisions Once the officer has reviewed the applicant's documents and, in some
cases, interviewed the applicant, he must make a decision whether to
grant or deny a visa.

214b Refusals

The most common basis for refusing a visa is "presumption of immigrant

status." In other words, all applicants are considered to be intending
immigrants until they prove otherwise. In section 214b of the Immigration
and Nationality Act of 1952 (INA), as amended, it states that each alien
"shall be presumed to be an immigrant until he establishes to the
satisfaction of the consular officer ... that he is entitled to a nonimmigrant
status under section 101(a)(15)." Under this section, the NIV is available
only to applicants who have a residence abroad which they do not intend
to abandon, and to those who can show evidence of strong family,
business, or social ties to a country other than the U.S. [source: Self-
instructional Guide, Visa Ineligibility].

Although the most common basis for refusal is a "2146," many other
sections of the INA outline ineligibilities based on health-related grounds,
criminal-related grounds, misrepresentation, and security related grounds.
Most of these ineligibilities can be determined through the document
review and interview, but the discovery of security-related ineligibilities is
determined by the officer's use of the Consular Lookout and Support
System (CLASS) automated database.

CLASS Namechecks

A CLASS namecheck must be performed before a visa can be authorized

and printed. CLASS contains names of individuals previously refused
visas, as well as those suspected to be ineligible, even if they have not
applied for a visa. In addition to visa refusal records, CLASS contains
lookout information from INS, DEA, Interpol, Federal Marshals, DOJ, and
the FBI.

CLASS entries are divided into two categories, Category One (for serious,
permanent ineligibilities such as security-related grounds, criminal
grounds, and permanent medical ineligibilities) and Category Two (for
less serious grounds based on a situation that may possibly change, such
as a 214B case).

When the consular officer runs a CLASS namecheck, the database returns
a list of names that are similar to the applicant's names. The officer must
read each of these names and determine if the name in the database and
the applicant's name are the same. The names in CLASS are color-coded.
Category One (Cat 1) hits are coded in red while Cat 2 hits are yellow. A
"00" by a name means that State headquarters entered the lookout for
terrorism-related grounds.

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Visa Lookout Accountability Procedures

In 1996, Congress instituted Visa Lookout Accountability (VLA)

procedures that require consular officers to certify iri writing that they
have checked the CLASS database for each visa applicant, both IV and
NIV. Officers are required by Section 14(c) of P.L. 103-236 (Foreign
Relations Authorization Act) to do so. The officer's failure to do so is
considered to be a matter of record and would be a serious negative factor
in the officer's annual performance review.
•
The machine-readable visa (MRV) system is designed so that consular
officers are forced to read through each screen of CLASS hits. In most
cases, the name and/date of birth of the applicant are different than the
name in CLASS. The officer can override the hits, but must explain why
each Cat 1 hit is being overridden. CLASS allows the officer to choose one
or more comments from a list of standardized comments to explain why
the visa is being issued despite the hit. The MRV system them retains a
record for the case, including all Cat I hits and the officer's comments for
each case [source: cable 1996 State 069153].

Special Clearances

Some visa applicants require a special clearance before a visa can be

issued. For example, consular officers must submit a request for a,
Security Advisory Opinion (SAO) to headquarters for all "00" CLASS hits
and for all nationals of countries that State has designated as state
sponsors of terrorism. If the consular officer is in any doubt about an
applicant, the officer is encouraged to request an SAO. [source: interviews
with S. Maloney, L. Gerson]

Once a request for an SAO has been submitted, the visa case cannot be
processed any further until a response is received from headquarters. The
applicant will be temporarily refused a visa for reasons of "administrative
processing" under Section 221(g) of the INA [source: Self-instructional
guide, Visa Ineligibilities].

If a visa applicant's name does not result in a CLASS hit and a special
clearance is not required, the consular officer can proceed with the
issuance of the visa Some applicants will have to pay an additional visa
fee at this stage, which is determined by a reciprocity schedule between
the U.S. and the applicant's country.

The tasks of preparing and passing back documents can be handled

Prepare and Pass entirely by the post's FSNs. Once the consular officer authorizes the visa,
Back Documents the FSN can print it, insert it into the passport, and file approved
applications. The post's consul general or senior consular officer will
review all refused applications.

Post-specific Procedures

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Given that consular policies and procedures are prescribed from

department headquarters, each post's operations vary to some degree
because of a multitude of factors. These factors are:

• Workload volume

• Whether the post is a low- or high-fraud post

• Management style of the Consul General of Consular Section

Chief

• Experience of officers on the visa line

• Number of FSNs available to help in visa processing

• The amount of space/layout of space in the consulate; room for

computers at visa window

• Types of visas being processed - e.g. Ottawa and Montreal do a

lot of Stateside cases for third country nationals (TCN)

• Drop box and third party screener programs

• Number of scheduled appointments vs. walk-ins

Specific Visa Processing Policies and Procedures in Ottawa

Ottawa
As with all posts, the policies and procedures of consular operations in
Ottawa reflect local conditions. The consular section at the embassy
handles a small volume of NIV applicants but does not process IVs. As
mentioned above, the chief of operations is Leslie Gerson, the Consul
General. She supervises two junior Foreign Service officers, Vice Consuls
Julie Stinehart and Craig Bryant. The officers are aided by four full-time
FSNs and one part-time FSN, who do visa pre-screening, anti-fraud work,
American citizen services, diplomatic visas, and extraditions.

We observed NIV processing in Ottawa on two mornings, Monday and

Tuesday, January 28-29. Ottawa holds visa interviews between the hours
of Sam and 11am on Mondays, Tuesdays, Thursdays, and Fridays. Ottawa
requires that most visa applicants schedule an appointment for their
interview, although it does allow some walk-in customers. The vast
majority of cases are from PAR applicants. In fiscal year 2001, 9,723 visa
applicants appeared in person while 157 mailed in their application
[source: Ottawa data report 11B].

The majority of the visa seekers in Ottawa are "Stateside" cases in which
aliens residing in the U.S. come to Canada to renew their visas. These
Stateside applicants are usually H1B visa holders. Another large group of

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applicants are landed immigrants in Canada who are not from a

Commonwealth country and therefore need a visa For example, while
observing operations we saw applicants from Bulgaria, Russia, and
Rwanda,

H1B Visas

A large percentage of Ottawa's visa processing is of H IB cases. Post data

show that nearly 13 percent of Ottawa's issuance? in fiscal year 2001 were
HIBs. The H1B visa is a temporary visa for aliens who are performing
\s in an occupation "requiring theoretical and practical application
of a body of highly specialized knowledge, licensure, completion of a
bachelor's or equivalent degree in the specialty, or experience equivalent
of such as degree." The "temporary period" can last up to six years. The
H1B is a petition-based nonimmigrant visa. Most petition-based visas are
for aliens seeking to work in the U.S. In order to protect the domestic
labor force, the INS has the responsibility to ensure that U.S. employers
abide by certain guidelines when they hire foreign employees. Employers
seeking to hire aliens must submit an 1-129 to INS for approval to hire the
alien. The H1B applicant, when applying for the visa, must bring the
approved 1-129 form with him or notification from INS or State that the
petition has been approved [source: Self-Instructional Guide on
Nonimmigrant Visa Classification]. What makes the H1B very different
from other nonimmigrant visas is that the alien does not have to prove
that he plans to return to his home country. The consular officer cannot
use 214B as grounds for ineligibility.

In practice, the H1B allows many foreign high-tech workers to stay in the
U.S. after completing a university degree and work for a U.S. firm. Since
many of these applicants do not want to return to their home countries to
apply for an H1B, they apply in Ottawa.

One of the vice consuls in Ottawa, Ms. Stinehart, was particularly

frustrated with H1B visa applicants. She thought that H1B was a
"backdoor" to immigration despite the fact that the applicants are
applying for nonimmigrant visa. She said that she feels pressure from
management to issue these visas regardless of whether the applicant's
employment documents are bona fide or not. She said that Ottawa rarely
checks to see if the applicant's verification of employment is real or not.
She thought it would be useful to do random checks on H1B applicants'
documents. She cited an example of a Chinese man who attempted to
renew his H1B in November 2001, despite being laid off in September. Ms.
Stinehart detected the fraud and denied him a visa as a "6C" case - lying
on a material fact.

Auto-revalidation

Aliens who entered the U.S. on a single-entry visa can make a short trip to
Canada and still be readmitted to the U.S. through a process known as
"auto-revalidation."

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Ms. Gerson explained the auto-revalidation process, "Basically this means

that someone entering Canada from the U.S. for a brief visit (29 days or
less) may be re-admitted to the U.S. even if their actual visa has expired if
they present current documentation indicating that they are still entitled
to that status. An example would be a student from a country with a very
limited reciprocity like Mali who is visiting Niagara Falls or his roommate
in Montreal. He has an updated 1-20 to show he is still in status but an old
three-month visa that got him to the U.S. the first time. He can just present
both to INS and be revalidated back in" [source: email from L. Gerson].
This does not work if the alien has been illegal or does not have updated
evidence of status.

State headquarters does not want Ottawa to tell people that they can auto-
revalidate but currently it is the practice for the post to suggest this to
people. Ms. Gerson said that State is currently discussing this issue with
INS (both the issue of auto-revalidation and Canada's landed immigrants
are under review by the Department of State).

Julie Stinehart '

Ms. Stinehart spent three years on the visa line in Santa Domingo before
coming to Ottawa. In Ottawa she said that she feels pressure from the
front office to "issue, issue, issue." As mentioned above, she does not like
the H1B visa, which she feels is a backdoor to immigration, but she said
that the consular officer has no recourse but to issue the H1B visas.

Ms. Stinehart thought that all visa applicants should be interviewed. She
said that in Ottawa, as compared to Santo Domingo, the luxury of having
more time to interview applicants helps her in detecting fraud. In Santo
Domingo she had about 90 seconds with each applicant, but in Ottawa we
observed Ms. Stinehart interviewing applicants from 5-7 minutes. She
emphasized the importance of making eye contact with the applicant. She
said that every applicant — both first time applicants and renewal cases —
should be interviewed; "a lot can change in ten years." We observed Ms.
Stinehart as she carefully interviewed applicants and we noted that she
took a considerable amount of time with each applicant.

Although she thought that longer interviews help consular officers pick up
on fraudulent cases, she did profess faith in the CLASS namecheck
system.

Ms. Stinehart pointed out other weaknesses in the visa system, such as the
practice of INS agents stamping "duration of status" on all student visa
holders' passports. She also said that religious visas (R visas) were very
difficult for consular officers to deny.

Craig Bryant

Mr. Bryant's posting in Ottawa is his second; his first tour was in
Cameroon, where he was an administrative officer. He is in the
administrative cone. In Ottawa he will do consular work for one year and

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the political work for one year. Although Mr. Bryant had filled in on the
visa line in Cameroon when needed, he had not had consular training
since before Cameroon.

Specific Visa Processing Policies and Procedures in Montreal

Montreal
We observed NIV processing during two mornings in Montreal, Thursday,
January 31 and Friday, February 1. We observed both pre-screening by
FSNs and adjudication interviews and CLASS checks by FSOs.

Ms. Allen said that approximately 50 percent of Montreal's NIV applicants

are interviewed. All NIV applicants must make an appointment for an
interview; Montreal has been on an appointment-only schedule since June
2001.

Like Ottawa, Montreal gets H1B cases. When we observed Marko

Velikonja, the NIV Unit Chief, process these applicants, he said that the
HIBs are all well-qualified, skilled workers. If the documents look good,
then the FSO does not really have a way to check up on them. He said that
it is possible that Montreal re-issues HIBs to people who are not working.

Drop Box in Montreal

Montreal accepts about 15 percent of its applications through a drop box.

Drop box applicants have been deemed a good risk—they have held
multiple prior visas, have proof of ties to Canada such as a professional
job, and they have a good record of travel. In drop box cases, an FSN does
pre-screening and determines that the applicant is "perfectly good," and
need not be interviewed. The applicant still has to come into the
consulate, however, to pay the application fee at the cashier's window. In
contrast, drop-box cases in Toronto do not have to come into the
consulate because they pay the fee at a local bank.

1-94

We observed many visa applicants who still had I-94s in their passports.
These should have been removed at the airport and returned to INS. In
Ottawa, the consular officers pulled the I-94s and returned them to INS. In
Montreal they did not do this. Mr. Velikonja said that this was because
they wanted to make sure that the alien could get back into the U.S.,
especially if that person was subject to a 20-day wait. [Auditor's note: this
defeats the purpose of the 20-day wait! It is surprising that the FSO said
this.]

Ottawa
Management Style
in Ottawa and In Ottawa, the tone of the post has been more permissive since Ms.
Montreal Gerson started as consul general. Ms. Gerson has a customer-friendly
outlook. She appeared to think that most NIV applicants were bona fide
cases. Post data show that refusal rates plummeted after Ms. Gerson

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arrived in July 2001J

I

Ms. Stinehart said that the management at post really drives the tone of
the post. Ms. Gerson's predecessor, Mike Bellows, was the opposite of Ms.
Gerson. She said that the problem with the current permissive style is that
if Ms. Gerson sees Deloitte and Touche or Microsoft on a HIBs
application, she immediately issues the visa. Ms. .Stinehart would like to
9/11 Personal Privacy see more checking up on job letters to verify whether these applicants are
really employed with these companies. Furthermore} as she is the post's
designated anti-fraud manager, she thinks it is a little embarrassing that
Ottawa had had nothing to report in its monthly visa viper reports.

In Ottawa, we also spoke with Aurelio Carreira, an FSN who helps screen
visa applicants and works on anti-fraud issues. He said that Ottawa,
before Ms. Gerson arrived, used to be known as a "tough" place to get a
visa and that now it is known as an "easy" post He said that Ms. Gerson
does not like to inconvenience an applicant and that she is more
permissive of applicants who do not have the proper documents or a
coherent story. SAOs are more rare now, too.|

Montreal

Ms. Allen concurred that the management style ofthe chief of the
consular section sets the tone for the entire staff. We observed that Ms.
Allen placed more emphasis on security concerns than Ms. Gerson. We
asked her if there had been more customer inconvenience since 9-11 and
she said that, for her, security has always taken priority over customer
convenience. She said that it has always been that way because consular
officers are held accountable for checking the CLASS system before they
authorize visas. She said that, since 1993, the State department has made
it clear that consulates have to balances customer service ant/security.

We asked the consular staff in Ottawa and Montreal about changes in visa
Procedure and processing since the terrorist attacks of September 11. They reported that
Policy Changes State headquarters has imposed some additional processing and
Since 9-11 procedural requirements:

1) As of September 12. 2001 all posts must retain all application

forms indefinitely. Previously, DS 156 forms for applicants who
were issued a visa were destroyed after one year and DS 156s for
applicants who were denied a visa who destroyed after two years.
Now all DS 156s (and DS 157s as of Jan. 02, 2002) will be retained
indefinitely.

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2) 20-day namecheck on male applicants aged 16-45 from 26

countries. As of November 14, 2001, all posts worldwide are
required to do special clearances on males of certain national
groups between the ages of 16 - 45. Consular officers must send a
request for a SAO for these applicants. The consular computer
system was modified so that it locks for 20 days before visas can
be printed for these individuals. The list of 26 countries is
classified. State has stated that this 20-day special clearance is an
inteririYmeasure; it has been authorized for 120 days since its
inception on November 14. [source: unclas cables State 196859 and
V State 198510].

3) On January 2. 2002 the Department of State announced the

introduction of a new form, the DS157. This additional form is
required of all male applicants aged 16-45, regardless of
nationality. The DS 157 asks applicants about prior travel, prior
military experience, and tribal affiliation. The Department cable
notes that "the use of the DS 157 is an interim measure that will
allow posts to elicit information which, in some cases, will lead to
a security advisory opinion." [source: unclas cable State 006020].
\S

4) On January 30. 2002 the Department of State notified posts of a

30^d(ay namecheck on male applicants aged 16-45 from certain
nationality groups who also fit a certain profile. This policy went
into effect will we were in Ottawa. The countries and the profile
information is classified. Officers must watt.30 days to issue visas
to these applicants and send a visa condor to headquarters about
the applicant.

Ms. Gerson and Ms. Allen reported that they had seen a decrease in visa
applications since 9-11. They said that people were concerned that if they
came to Canada for a visa they might not be able to get back into the U.S.

Both Ms. Gerson and Ms. Allen agreed that 9-11 attacks had helped all of
the Foreign Service see how important the consular section is, although
neither reported any major changes in visa processing except for the new
policies that were instituted by the Department. Ms. Gerson said that the
additional 20-day special clearances made Ottawa "terribly
uncomfortable" because the post could not perform its normal visa
function for certain individuals. Ms. Gerson said that if any males from
those countries have made appointments prior to the policy, they are
contacted to cancel their appointments. Ms. Gerson said that the 20-day
wait could be overridden for extenuating circumstances, and gave
examples such as an Algerian ambassador or a Tunisian who runs a
company and works with the post's political officer.

We observed the DS 157 forms being filled out by applicants and turned
into post, although Ms. Stinehart said that they didn't know what to do
with the form or why they had to be filled out. She also commented that
the DS 157 just brings back many of the questions that were on the OF-

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156, the general application form which preceded the DS 156. She noted
that it is unlikely that a terrorist would truthfully fill out a DS-156 or DS-
157.

Ms. Allen said that Montreal has done a lot of visa vipers since 9-11. As
mentioned above, Ms. Allen felt that consular officers have always had to
balance security and customer service. She said, however, that she did
think she always got the help she needed from law enforcement. Since 9-
11 she's seen an improvement in the amount and type of data that she's
been provided from law enforcement. '

Ways to Screen out We asked Ms. Gerson if there were ways to screen out terrorists other
than CLASS. She said that common sense was one tool, as well as
Terrorists in the mentioning the cable that post received on profiling (we picked up a copy
Visa Process of this classified cable at State headquarters. See cable 01 State 160600).

Consular officer Julie Stinehart said that she thought the interview could
be used to screen out terrorists. She said she would like more training on
how to detect terrorists during the interview.

Consular officer Craig Bryant was skeptical that screening for terrorists
during the visa process would be helpful. He thought that terrorists likely
to target the visa process are sophisticated; they would not answer an
FSOs questions truthfully and they would probably have fraudulent
documents.

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