and misdirected valuable resources. It has never been explained why the government needs to digitize and review hundreds of thousands of additional records under Operation Second Look. Moreover, the Trump administration has proposed to fund the operation through the account set up to administer naturalization fees, at a time when waiting times for the processing of naturalization applications exceed two years. Additionally, these policies instill a sense of fear, harming political and economic engagement by and with immigrants. Denaturalizations are particularly harmful, even in the abstract, for immigrant families, because of the possibility and unpredictable application of derivative citizenship-stripping. In July 2017, the Department of Justice published a bulletin to federal prosecutors encouraging increased immigration enforcement, with a significant portion of the publication focused on using denaturalization as a tool to target naturalized citizens. In it, then Attorney General Jeff Sessions described denaturalization of U.S. citizens as “a crucial link in the Department’s strategic enforcement framework.”300 Based on the Justice Initiative’s research, the Trump administration is systematically implementing this strategic framework as envisioned. This section details some of the observable wider impacts of the denaturalization program under the Trump administration—resource waste, chilling effects, and derivative denaturalization—prior to examining research focused on individual denaturalization cases. Resource Waste Denaturalization prosecutions are expensive and time-consuming to investigate. A former ICE prosecutor who litigated denaturalization cases interviewed for this report estimated that investigations can take several years just to develop.301 OSI’s efforts resulted in 108 successful prosecutions between 1978 and 2015, with many cases going on for years after they were filed.302 A recent examination of one of the early Operation Janus trials—of Parvez Manzoor Khan, who has been a citizen since 2006, but entered the U.S. on an altered passport in 1991—arrived at the same fundamental question: why sink so much into undoing the naturalization of one man, tearing his family apart, almost 30 years after he came here?303 DHS has proposed a budget reallocation that would shift money away from naturalization processing to immigration enforcement, including denaturalization and deportation. The money that is to be shifted derives from naturalization application fees, which are deposited into the Immigration Examinations Fee Account (IEFA) budget. This budget “is the primary funding source for USCIS” and is used to “fund the cost of processing immigration benefit applications and associated support benefits, as well as to cover the cost of processing similar benefit requests for applicants without charge, such as refugee and asylum applicants.”304 In its FY 2019 budget, DHS proposed to transfer $207.6 million from USCIS’s IEFA budget to ICE for denaturalizations and other immigration enforcement measures. Operation Janus’s budget II. Denaturalization: A Radical Measure in the Hands of Zealots 71