Denaturalization: Examining the Yemen Cases, 82 Fordham L. Rev. 2099, n.72-74 and accompanying text (2014). 521. 22 C.F.R. § 51.42. 522. Anthony D. Bianco, Michael A. Celone & Sherease Pratt, Defending Agency Immigration Fraud Adjudications, in 65 U.S. Attorneys’ Bulletin (July 2017), at 102, https:// www.justice.gov/usao/page/file/984701/download. 523. 22 C.F.R. § 51.45. 524. Anthony D. Bianco, Michael A. Celone & Sherease Pratt, Defending Agency Immigration Fraud Adjudications, in 65 U.S. Attorneys’ Bulletin (July 2017), at 103, https:// www.justice.gov/usao/page/file/984701/download, (“[C] ertificates of baptism are often based on baptism registries which are recorded at the time fo the ceremony, are official records of the church, maintained in a secure located [sic], and which are not easily tampered. While a person may fraudulently alter or create a certificate of baptism, he or she would be less likely to fraudulently alter a church’s registry to match the fraudulent certificate.”). 525. 22 C.F.R. § 51.42. 526. Id. 527. 22 C.F.R. § 51; Castelano et al. v. Clinton, 2d Amend. Compl., para. 36, U.S. Dist. Ct. S.D. Tex., 08-cv-57. 528. Ramzi Kassem, Passport Revocation as Proxy Denaturalization: Examining the Yemen Cases, 82 Fordham L. Rev. 2099, 2100 (2014). 529. DOS-OIG, Review of Allegations of Improper Passport Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 1 (October 2018). See also Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Submission by civil society organizations to the U.N. Committee on the Elimination of All Forms of Racism (July 11, 2014). The complaint to the OIG enclosed a more recent version of the CERD shadow report, Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Asian Americans Advancing Justice (the Asian Law Caucus) and the City University of New York (CUNY) Creating Law Enforcement Accountability & Responsibility Project (January 2016). Id. at 2 n.2. 530. Amel Ahmed, Yemeni Americans Cry Foul Over Passport Revocations, Jan. 21 (cited in Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Asian Americans Advancing Justice (the Asian Law Caucus) and the City University of New York (CUNY) Creating Law Enforcement Accountability & Responsibility Project (January 2016)). Endnotes 531. See, e.g., Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Submission by civil society organizations to the U.N. Committee on the Elimination of All Forms of Racism, 2 (July 11, 2014). 532. Department of State, Office of Inspector General (DOS-OIG), Review of Allegations of Improper Passport Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 2 (October 2018) (noting also that in some cases other documents including certificates of naturalization were confiscated). 533. Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Asian Americans Advancing Justice (the Asian Law Caucus) and the City University of New York (CUNY) Creating Law Enforcement Accountability & Responsibility Project (January 2016), at 5. 534. Department of State, Office of Inspector General (DOS-OIG), Review of Allegations of Improper Passport Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 2 (October 2018). 535. Stranded Abroad: Shadow Report on Coercive Interrogations and Due Process Violations in the Confiscation or Revocation of Passports of American Citizens of Yemeni Origin, Asian Americans Advancing Justice (the Asian Law Caucus) and the City University of New York (CUNY) Creating Law Enforcement Accountability & Responsibility Project (January 2016). 536. DOS-OIG, Review of Allegations of Improper Passport Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01, at 11-12 (October 2018). 537. See 8 U.S.C. § 1504(a) (revocation of a passport “shall affect only the document and not the citizenship status of the person in whose name the document was issued.”). 538. Ramzi Kassem, Passport Revocation as Proxy Denaturalization: Examining the Yemen Cases, 82 Fordham L. Rev. 2099, 2100 (2014). 539. 22 U.S.C. § 211a (Bureau of Consular Affairs (CA) has the authority “to issue, grant, and verify passports and to establish rules concerning the issuance of passports.”). See also 8 U.S.C. § 1504; 22 C.F.R. § 51.62(a)(2). 540. DOS-OIG, Review of Allegations of Improper Passport Seizures at Embassy in Sana’a, Yemen, OIG-ESP-19-01 (October 2018). 541. See, e.g., 22 C.F.R. § 51.62(i). 542. One of the OIG’s critiques is that the State Department has not adopted consistent policy as to the eligibility for limited validity passports. DOS-OIG, Review of Allegations of Improper Passport Seizures at Embassy in 185