In February 2019, the FBI announced that it will shutter its International Human Rights Unit, which played a role in denaturalizations brought against war criminals.270 The move casts doubt that the administration views the statutes as a tool to seek accountability for grave crimes. Overall, the history of OSI prosecutions sheds light on the possibilities and limits of denaturalization as a tool to enforce criminal accountability for heinous crimes. Because there are no more Nazis to prosecute, OSI’s mission is no longer contingent on the absence of a statute of limitations in the civil denaturalization statute. Instead, the lack of a statute of limitations is currently being exploited to denaturalize individuals who committed no such crimes and naturalized decades ago. Decades of practice under the denaturalization statutes focused on war criminals and other high profile defendants lowered the procedural protections afforded to today’s defendants. The fact that war criminal proceedings may still be possible under the statutes augurs for their retention, according to certain advocacy groups. But the costs of maintaining such an imperfect tool just in case it may be needed have never been seriously examined. A New Bureaucracy of Denaturalization: The Department of Homeland Security and Department of Justice Office of Immigration Litigation – District Court Section This section surveys a number of developments in the 1990s and 2000s that have led to an expanded bureaucracy for the investigation and litigation of denaturalization cases. OSI’s mandate expanded to cover modern war crimes cases under the Intelligence Reform and Terrorism Prevention Act of 2004, but OSI did not retain exclusive jurisdiction over denaturalization cases.271 A separate, more fluid, and steadily expanding agency structure emerged during this period, without as focused a mandate as OSI’s. Citizenship USA sparks a new denaturalization operation. The first relevant development began with the inauguration of the “Citizenship USA” or CUSA program. On August 31, 1995, the U.S. Immigration and Naturalization Service (INS) announced this effort, which was designed to address the mounting backlog of naturalization applications pending adjudication.272 The surge in applications at the time was not unexpected: 2.7 million beneficiaries of the 1986 Immigration Reform and Control Act amnesty would become eligible to apply for naturalization during this time.273 CUSA was an ambitious program unfolding as the U.S. government was modernizing many aspects of its bureaucracy to make use of emerging new technology. In 1996, under the CUSA program, 1.1 million new Americans were naturalized. The program received criticism, including allegations that it was a partisan effort to shift electoral demographics. Ultimately, government oversight mechanisms, including congressional hearings and a lengthy OIG investigation, noted weaknesses of the program, in particular with respect to criminal background check procedures used to vet potential candidates for naturalization.274 II. Denaturalization: A Radical Measure in the Hands of Zealots 65