The Biden-Harris DHS earlier this month paused its “parole” program for nationals of Cuba, Haiti, Venezuela, and Nicaragua amidst findings of fraud. The Washington Times now reports that the administration is restarting “CHNV Parole”, and in an interesting twist, the department is soliciting volunteers to “confirm” (read: “process”) those applications — volunteers who don’t need any prior experience. What’s the worst that could happen? Trafficking, exploitation, forced marriage, peonage, and national-security threats, for starters.

CHNV Parole

The number of illegal migrants from the four CHNV countries (Cuba, Haiti, Nicaragua, and Haiti) who were apprehended by Border Patrol at the Southwest border rose from just over 17,500 in FY 2020 to more than 600,000 in FY 2022.

To put that latter figure differently, more than one in four (27.2 percent) of all illegal entrants nabbed at the U.S.-Mexico line in FY 2022 came from those four non-contiguous countries, while “just” 23.6 percent (520,602) were from the “root causes” Northern Triangle countries of El Salvador, Guatemala, and Honduras.

In lieu of deterring CHNV aliens from coming illegally by detaining them or expanding Vice President Kamala Harris’ root causes portfolio in response to that migration shift, the administration decided to bribe would-be illegal migrants from the four CHNV countries not to come illegally through the back door by opening the front door (U.S. international airports) to them, using CHNV parole. (For more on this “humanitarian flights” program, see reporting by my colleague Todd Bensman, including here and here.)

CHNV began with a much more limited parole program for Venezuelan nationals, which the White House initiated in October 2022.

A DHS press release for that program explained that, in exchange for that parole, Mexico had agreed to accept Venezuelan migrants who entered the United States illegally. Thus, if would-be illegal entrants from that country wanted to come to the United States, parole was the better option.

That Venezuelan parole program was capped at 24,000 slots total, and it had some brief impacts: Border apprehensions of migrants from the country dropped from nearly 25,000 in December 2022 to just over 3,000 in January 2023.

Thinking it had discovered some “secret border sauce”, in January 2023 the White House announced it would be expanding Venezuelan parole into CHNV. “Expand” is the key word there.

That’s because unlike the 24,000-parolee cap under the Venezuelan program, CHNV offers parole to up to 30,000 nationals of those four countries combined each month (360,000 per annum). Those paroles were the carrots in this scheme.

The stick, the White House explained, was that Mexico had now agreed to accept the return of 30,000 nationals combined of those four countries who entered illegally and faced expulsion under Title 42 each month.

The Problems

That may sound great, but there are a number of problems with the program.

First, Title 42 ended on May 11, 2023, and it’s not entirely clear that the Mexican government continues to keep its end of the border bargain by accepting expelled CHNV migrants.

Second, a recent House Judiciary Committee report suggests that Cubans, Haitians, Nicaraguans, and Venezuelans who were expelled to Mexico weren’t expected to stay there or go home.

Rather, it appears that they are sent back to either apply for CHNV parole or to preschedule their illegal entries at a Southwest border port using the CBP One app — a separate Biden-Harris innovation I’ve dubbed the “CBP One app interview scheme” — which has its own fraud issues.

Third, although it’s packaged as a “parole” program, CHNV doesn’t meet most parole requirements.

Under section 212(d)(5)(A) of the Immigration and Nationality Act (INA), although DHS has the authority to parole inadmissible aliens into the United States without formally “admitting” them, it may do so: “only on a case-by-case basis for urgent humanitarian reasons or significant public benefit”.

“Urgent humanitarian reasons” have usually been defined as emergency medical-related issues, and “significant public benefit” as a need for the alien to appear for some law-enforcement purpose, like to be a witness or defendant in a U.S. criminal proceeding.

Moreover, that parole statute requires DHS to take parolees back into custody “when the purposes of such parole shall … have been served”. But there are no clearly defined purposes for CHNV parole, aside from funneling would-be illegal migrants into the country, and no plan to take them into custody, either.

Fifth, and relatedly, while the administration claims it only provides CHNV beneficiaries with two-year periods of parole, it has no expectation that any of them will leave after they get here.

Want proof? The “Frequently Asked Questions” web page for the program includes the following:

If I am paroled into the United States through these processes, what happens when my 2-year period of parole ends?

There are a full range of existing lawful immigration pathways, including an extension of parole, immigrant and nonimmigrant visas, asylum, and Temporary Protected Status (TPS), that certain parolees may be eligible for in accordance with U.S. laws.

Notably absent from that answer is “you get taken into custody and are sent home”, which is what section 212(d)(5)(A) of the INA mandates.

Exploitation, Trafficking, and Forced Marriage . . .

Sixth, the structure of CHNV is ripe for human exploitation.

An “alert” appears at the top of USCIS’s CHNV parole page, which states: “DHS has temporarily paused the issuance of Advance Travel Authorizations (ATA) for new CHNV beneficiaries while it undertakes a review of the supporter application process.”

ATAs are the documents the agency issues to CHNV beneficiaries allowing them to board the planes to fly here and to be processed at U.S. arrival airports — i.e., a kind of imitation visa. Curiously, however, that page never mentions why that “supporter application process” merits review. To explain, first some background.

CHNV is a six-step process, which begins when a “supporter” in the United States files an I-134A, “Online Request to be a Supporter and Declaration of Financial Support”, through a USCIS portal. In that form, the supporter ostensibly agrees to financially provide for a given CHNV national.

Once USCIS “confirms” those supporters (it won’t admit it’s adjudicating anything), the agency sends beneficiaries e-mails directing them to set up an online account attesting to eligibility (i.e., they are nationals of one of those countries or the spouse, common-law partner, or minor child of a beneficiary) and averring they’re not inadmissible on medical grounds.

After that’s done, beneficiaries then go to the CBP One app to upload photos and enter biographic information. At that point, beneficiaries are notified through the online account whether CBP will give them permission to fly to the United States to seek parole at a port of entry.

Step five is airport inspection, and step six is when beneficiaries are released into the country to then “apply for work authorization”.

That step-one supporter requirement prompted the pause on the program.

Notably, supporters of CHNV applicants don’t need to have any preexisting relationship to those aliens. What’s more, supporters don’t have to be “people” at all — “organizations, businesses, [and] other entities” all qualify. If unscrupulous and/or unsavory employers seek cheap and exploitable workers, all they have to do is find a CHNV applicant, file papers, and wait for their soon-to-be victim to arrive.

In fact, being a “supporter” can be a lucrative and easily exploitable endeavor, a fact that was apparent from the outset of CHNV parole, which is why the USCIS warns would-be beneficiaries to:

Look out for individuals who attempt to contact you online or through your social media accounts to offer to be your supporter or connect you to a supporter in exchange for a fee or other form of compensation. … Beneficiaries are not obligated to repay, reimburse, work for, serve, marry, or otherwise compensate their supporter in exchange for the potential supporter submitting Form I-134A … on their behalf or for providing financial support while they are in the United States. [Emphasis added.]

The degree to which this CHNV supporter requirement has facilitated extortion, peonage, trafficking, and forced marriage is unknown (perhaps the DHS inspector general will look into it at some point), but keep in mind such warnings appear on government websites for a reason.

. . . And Fraud

Which leads me to the sponsorship fraud that prompted the administration to pause the program.

On August 2, Fox News reported that DHS paused CHNV after the Fraud Detection and National Security (FDNS) directorate at USCIS discovered that “100,948 forms were filled out by 3,218 serial sponsors — those whose [Social Security] number appears on 20 or more forms”.

Worse, “24 of the 1,000 most used numbers belonged to a dead person” and “100 physical addresses were used between 124 and 739 times on over 19,000” sponsorship forms.

Plainly, real people filled out all of those I-134A sponsorship applications, and plainly they didn’t want to be identified after the fact, hence the fraud.

Put the degree to which CHNV beneficiaries could be exploited by their potential sponsors together with all that sponsorship fraud and — assuming you’re the least bit cogent and not naïve — you’ll realize that if the administration isn’t quite running a trafficking scheme, it’s put in place all the parts for one.

‘DHS Seeking Quick Restart’, ‘Calls for Volunteers’

Notwithstanding those patent concerns, the Washington Times reports, in an August 25 article headlined “DHS seeking quick restart of fraud-filled ‘parole’ program for migrants, calls for volunteers”, that the White House is anxious to recommence CHNV — and cutting corners to do so.

According to the Times, Donna Campagnolo, the chief human capital officer at USCIS, has sent out an e-mail seeking volunteers from across the agency, which explains: “This will be a full-time, remote detail for 180 days. No prior experience is necessary.”

The Times report references former USCIS Director Emilio Gonzalez, who warned that the new recruits are “low-level staffers who lack the expertise to detect fraud” and explained: “This administration is intent on driving this program through regardless of the consequences. That’s what’s bothersome from a national security perspective.”

Gonzalez’s concerns were echoed by former acting USCIS Director Joe Edlow, who told the Times:

This eliminates their chances of catching fraud … . To have staffers who have no connection to the immigration work of the agency reviewing forms in the hopes they’re either going to catch fraud or make a determination or a review, in this case, that someone is or is not eligible is laughable.

To recap: The Biden-Harris administration is so keen to restart CHNV parole — a program that doesn’t comply with key congressional requirements, is a breeding ground for abuse and exploitation, and has already been riddled with fraud — that it’s recruiting volunteers with no experience to administer it. The problems with this program, I fear, are only beginning.