Canada's Auditor-General reports that gaps in the nation's citizenship program are leading to fraud, according to
The Globe and Mail. An audit of 700 citizenship cases between July 2014 and October 2015 found that the Immigration Department lacked a method to identify and document fraud risks when dealing with suspicious immigration documents. Moreover, citizenship officers lacked information needed to identify problem addresses when they made decisions to grant citizenship. The report also cites poor information sharing between the Immigration Department and law enforcement and border control agencies. Canada's immigration minister announced the government will implement all of the Auditor-General's recommendations.
Immigration policy and whether a country has effective controls in place to prevent immigration fraud are hot topics these days. This story, although it involves an external audit, offers insights into what internal auditors working in immigration agencies also can do to help prevent and detect immigration fraud. Here is a summary of the most important observations and recommendations contained in the Auditor-General's recent audit of Canada's immigration system, to which I've added a few of my own. The full report can be found
Doing a thorough job of identifying and analyzing immigration risk must include a focus on fraud risk. It's not sufficient to merely identify broad categories of fraud risks, such as residency and document fraud. The information collected during citizenship application processes needs analysis to better understand the types of fraud detected or the extent to which it occurs. Then, departments must apply appropriate mitigation to determine whether a situation improves. Examples include:
- Analysis of key information, such as revoked, abandoned, or withdrawn citizenship applications, to identify patterns and improve understanding of program risks.
- Review of applications refused for residency reasons to assess the extent of residency fraud. The audit found examples where the same addresses were used by many different applicants over several years, which none of the citizenship officers who processed their applications noticed. One address was used by at least 50 different applicants during overlapping time periods between 2008 and 2015. Among these applicants, seven became Canadian citizens.
Furthermore, immigration organizations need to develop a systematic, evidence-based approach to identifying fraud risks, including establishing a baseline and monitoring trends. The Auditor-General's report examined whether risk indicators for residency fraud were based on sound evidence and analysis, and found that overall the Immigration Department documented the risk indicators it considered to be associated with residency fraud. However, it did not have sufficient data or analysis to explain how or why it selected some of those indicators.
Even if immigration fraud risks are identified appropriately and mitigation is put in place, consistent application of methods is essential to identify and prevent fraud during the citizenship application process. This includes the need to ensure clear authority to seize problem documents, provide officers with more detailed guidance and training, and ensure that officers implement this guidance. The auditor's report found that due to such inconsistent application, people were granted citizenship based on incomplete information or without all of the necessary checks being completed. Particular areas of concern included:
Checking for problem addresses. Immigration officers did not consistently have information about problem addresses to support their decisions to grant citizenship due to database factors, such as data entry errors and inconsistent updating. In turn, these officers may not have detected potentially fraudulent residency claims.
Identifying fraudulent and altered documents. Altering passports and other documents to falsely establish residency in Canada, and counterfeit documents, are growing risks. Inconsistent guidance and practices for dealing with suspicious documents, such as one region not seizing documents for years versus another doing so regularly, are examples of inconsistency.
Reliable interagency cooperation and sharing of information is a key part of a robust control system in preventing immigration fraud. The report found that Canadian partners the Royal Canadian Mounted Police (RCMP) and the Canada Border Services Agency (CBSA) did not consistently share, or did not do so timely, important information on criminal charges and potential residency fraud that citizenship officers need to make informed decisions about granting citizenship.
The report found the RCMP does not systematically track people's citizenship status, so it is difficult to link citizenship applicants with those charged with crimes. However, using criminal occurrences that included the keywords "permanent resident" and "foreign national," auditors came up with a list of 2,576 cases since 2010. Examining a sample of 38 of these cases (these individuals had been charged by the RCMP with a crime, some serious enough to make an individual ineligible for citizenship, such as drug trafficking and assault), auditors found that the RCMP shared this information with citizenship officers timely in only two cases.
In the case of the CBSA, if adverse information that might affect a permanent resident's eligibility for citizenship is found, it has a responsibility to advise citizenship officers. In turn, citizenship officers are required to check for these alerts and may decide to carry out additional procedures to make sure the applicant's residency requirements have been met before granting citizenship. Based on a random sample of 38 names out of 4,001 that were associated with seven recent CBSA fraud investigations, auditors found that the CBSA did not consistently provide information to immigration officials when permanent residents were linked to major fraud investigations.
Readers in the U.K., U.S., and other countries may recognize these immigration fraud issues and may find some of the recommendations helpful.