Case Western Reserve Journal of International Law 53 (2021) Ghosts in America: Working Towards Building a Legal Framework for Stateless Individuals in the United States approaches to statelessness has been geared towards declining to permanently host stateless individuals. 219 This section will discuss three main United States responses to statelessness: 1) “recalcitrant” country designations and visa sanctions; 2) orders of supervision; and 3) repatriation agreements. 220 Two of these policies, “recalcitrant” country designations and repatriation agreements, compel countries to accept stateless individuals removed from the United States. 221 Order of supervision is the method by which stateless individuals are able to remain in the United States but without legal status. 222 1) “Recalcitrant” countries and visa sanctions When Congress implemented the Immigration and Nationalization Act (INA) in 1952, it gave broad authority to the DHS and the Department of Justice (DOJ) to remove certain foreign nationals from the United States. 223 One provision in the INA that contributes to this broad authority is Section 243(d), which provides for the “discontinuance” of visa issuances as a penalty for countries that refuse to take back their “citizens, subjects, nationals, and residents” who have been ordered deported from the United States. 224 In other words, the United States can impose visa sanctions to try to compel cooperation with its removal decisions. 225 Since the INA’s implementation in 1952, the United States used Section 243(d) during the Cold War to restrict visa issuances to certain Soviet bloc nationals. 226 Between the Cold War and 2016, the provision was used only once, against Guyana in 2001 to remove 113 criminally convicted 219. See Baluarte, supra note 20, at 352–53. 220. See Immigration: “Recalcitrant” Countries and the Use of Visa Sanctions to Encourage Cooperation with Alien Removals, CONG. RSCH. SERV. (Jan. 23, 2020), https://fas.org/sgp/crs/homesec/IF11025.pdf [https://perma.cc/42RFQZU9 ] [hereinafter Recalcitrant] (defining “recalcitrant” as “countries that systematically refuse or delay the repatriation of their citizens”). 221. Id. 222. Corgan, supra note 18. 223. Recalcitrant, supra note 220. 224. Immigration and Nationality Act of 1952 §243(d), 8 U.S.C. § 1253(d); Discontinuance of Visa Issuance Under INA 243(d), NAFSA (Apr. 13, 2020), https://www.nafsa.org/professional-resources/browse-byinterest/discontinuance-visa-issuance-under-ina-243d [https://perma.cc/9SMG-AEGU]. 225. Recalcitrant, supra note 220. 226. Id. 381