naturalizations in the late 1990s and early 2000s is the closest predecessor to Operation Janus in terms of its scale and methods. Yet in the CUSA investigation, no known targeting based on national origin occurred. Between 2008 and June 2014, little is known about the efforts of OTGIS, except that an inter-agency working group was formed. While it is not known how or when, during this time ICE identified a pool of approximately 315,000 records in its database (IDENT) of aliens with a final deportation order or record of a criminal conviction or fugitive status, for which there was no digital fingerprint data. In July 2014, a list of 1,029 names derived from that pool of roughly 315,000 was given to the Department of Homeland Security’s (DHS) Office of the Inspector General (OIG). The list named individuals “identified as coming from special interest countries or neighboring countries with high rates of immigration fraud, had final deportation orders under another identity, and had become naturalized U.S. citizens.” Of those, 858 did not have digital fingerprint records when USCIS was reviewing their citizenship applications.285 By March 2015, of the 1,029 individuals whose names were given to DHS, ICE had closed 90 investigations and had 32 open investigations. The Offices of the United States Attorneys (USAO) had accepted two cases for criminal prosecution, which could lead to denaturalization.286 Also in 2015, DOJ and DHS agreed to widen the scope of denaturalization cases to include naturalized citizens who had gained “security clearances or positions of public trust or who had a criminal history,” which led to a sharp increase in referrals in 2016 beyond the special interest or neighboring countries.287 According to a September 2016 OIG report, Operation Janus ran out of funds and was formally eliminated in 2016, although it was subsequently rebranded as Operation Second Look, accompanied by a hiring increase.288 At the time Operation Janus was disbanded, 148,000 records from the original pool of 315,000 had not been reviewed. The OIG report recommended that in addition to digitizing the remaining 148,000 fingerprints of immigrants “with final deportation orders or criminal histories or who are fugitives,” DHS should “establish a plan for evaluating the eligibility of each naturalized citizen whose fingerprint records reveal deportation orders under a different identity. The plan should include a review of the facts of each case and, if the individual is determined to be ineligible, a recommendation whether to seek denaturalization through criminal or civil proceedings.”289 Thus, the groundwork for the rise in denaturalizations under the Trump administration evolved under the Obama administration, although it is important to note a key limiting factor in the Operation Janus approach: there were prioritization criteria in effect that limited targeting in an arguably objective manner, to focus energy and resources on potential threats to national security. The operation was not, in other words, a generalized immigration enforcement effort designed to root out all naturalized citizens whose records threw up 68 UNMAKING AMERICANS

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