Similar to withholding of removal under INA §241(b)(3), once a respondent establishes CAT, the IJ must grant withholding of removal under CAT unless she is subject to one of the mandatory bars to CAT withholding protection. These bars include participation in the persecution of others; conviction for a particularly serious crime; “serious reasons to believe he or she committed a serious nonpolitical crime outside of the United States;” or “reasonable grounds to believe [the respondent] is a danger to the security of the United States.”172 Importantly, as the prohibition on the return to torture is absolute, a respondent’s criminal convictions, no matter how serious, are not a complete bar to protection under the Convention against Torture.173 Instead, if a respondent is eligible for CAT protection, but crimes render her ineligible for Withholding, she must be granted deferral of removal.174 When an individual is granted Withholding under CAT, the scope of protection is the same as Withholding under INA §241(b)(3) (see section above). When the grant is instead for deferral of removal under CAT, she is given a removal order whose enforcement is deferred until such time as the deferral is terminated. However, under withholding of removal, either statutorily or under CAT, the respondent is also given a removal order whose enforcement is withheld. The IJ is required to inform the individual granted deferral of removal of the following: Deferral of removal 1. Does not confer upon the alien any lawful or permanent immigration status in the United States; 2. Will not necessarily result in the alien being released from the custody of the DHS if the alien is subject to such custody; 3. Is effective only until terminated; 4. Is subject to review and termination based on a DHS motion if the Immigration Judge determines that it is not likely that the alien would be tortured in the country to which removal has been deferred, or upon the alien’s request; and 5. Defers removal only to the country where it has been determined that the alien is likely to be tortured and does not preclude the DHS from removing the alien to another country where it is not likely the alien would be tortured.175 A grant of Withholding or deferral of removal under CAT provides some basic protections for a stateless person. However, as with a grant of Withholding under INA §241(b)(3), the absence of a permanent resolution of legal status under CAT protection may be particularly difficult for a stateless person. She will remain in legal limbo, with an underlying order of removal entered against her. A grant of CAT protection neither resolves the underlying issue of statelessness, nor provides permanent stability, the ability to petition for reunification with family members, or to travel internationally to visit them. 8 C.F.R. § 1208.16(d)(2); see also INA § 241(b)(3)(B). See 8 C.F.R. § 1208.17(a); Matter of G-A-, 23 I&N Dec. at 368. 174 8 C.F.R. §§ 1208.16(c)(4), 1208.17(a); 175 EOIR, IMMIGRATION JUDGE BENCHBOOK – ASYLUM, WITHHOLDING https://www.justice.gov/eoir/immigration-judge-benchbook-section-241b. 172 173 OF REMOVAL, CAT, available at 37