der of supervision as a prerequisite to release from detention, the only other advantage associated with an order of supervision is that it typically provides a basis for the individual to seek permission to work. An order of supervision will generally remain in effect unless and until that individual obtains a lawful immigration status in the United States. For stateless individuals, who have no means to gain lawful status based solely on their being stateless and frequently have no independent basis to obtain lawful status, an order of supervision will, in effect, continue for their entire lifetime. The regular reporting requirements pose hardships for stateless individuals. Many stateless individuals fear they may be taken into immigration custody each time they report to the immigration office for having inadvertently failed to comply with the terms of the order, for having run out of consulates or embassies to contact in order to request travel documents, or in some cases for no apparent reason at all.119 Between travel time and waiting to be called in to see an officer, reporting can take an entire day and can interfere with, and even jeopardize, a person’s employment. In addition, repeated need to request time off may lead to the need to explain their situation to supervisors and colleagues who may assume the person has been involved in criminal activity or something else to warrant close immigration supervision and may view the individual as a more risky employee. In fact, many stateless individuals express that these regular in-person reporting requirements make them feel that they are being treated like criminals. As mentioned above, the August 2012 ICE policy guidance on the use of discretion to set reporting requirements for individuals with final orders of removal should decrease the likelihood that stateless individuals are subject to unreasonable reporting requirements.120 This new policy represents a positive example of administrative action that, if applied appropriately and consistently, will alleviate a degree of the hardship facing stateless individuals in the United States. Again, the agency will need to issue specific guidance and develop train- 26 ing to ensure the memo is effectively implemented. There Are Not Enough Embassies in the World Agnes B.,121 a stateless woman born in the former Latvian Soviet Socialist Republic, first came to the United States as a child with her parents in 1995. After the family’s application for asylum was denied and final removal orders issued, Agnes was detained for the 90-day removal period. Upon her release from detention under an order of supervision, she was told that she would be detained again—and prosecuted—if she did not continually contact embassies to request permission to enter another country. Many embassies do not reply to such requests. She felt compelled to contact many embassies each month, but would share only one letter at a time with the officer she had to report to every month. She lived in constant fear of running out of countries to contact, being returned to immigration detention, and of being criminally prosecuted for lack of documentation of her efforts. Permission to Work Immigration regulations provide that non-U.S. citizens released under an order of supervision may be granted work authorization.122 It appears that most stateless individuals who have an order of supervision are granted work authorization; however, the authorization must be renewed annually and all required fees for this document must be paid.123 For stateless individuals, this means they will have to go through the filing process and pay the fees every year—potentially for the rest of their lives—even though their statelessness is typically no fault of their own. In addition, due to agency delays, there may be gaps in their authorization to work while the renewal request is being processed, which can lead to difficulty maintaining the same job year after year. Citizens of Nowhere: