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 of world and could have negative impacts on economic cooperation between the United States and other countries. 238 Furthermore, visa sanctions are not the only tool available to the United States government to encourage cooperation. 239 Examples of such alternative measures include the issuance of a demarche (i.e., a formal diplomatic request); holding a joint meeting with the country’s ambassador to the United States, DOS, and ICE; providing notice of the United States government’s intent to exercise visa sanctions to gain compliance; and calling for inter-agency meetings to pursue withholding of aid other funding. 240 2) Order of supervision If a stateless individual is unable to obtain legal status in the United States, they cannot be lawfully deported from the United States. 241 In these cases, an immigration judge has the discretion to release a stateless individual under order of supervision. 242 Orders of supervision are authorized under INA §241 and the regulatory authority is provided in 8 C.F.R 241.5. 243 Under this program, if a detained noncitizen cannot be removed within a reasonable time after receiving an order of removal, the noncitizen must be released from detention. 244 Many stateless individuals are released under an order of supervision. 245 To comply with orders of supervision, they must check in regularly with immigration officials, obtain advanced approval to travel beyond specified times and distances, provide notices of change of address, and continue to try to obtain travel documents, which most likely ends up 238. Recalcitrant Countries: Denying Visas to Countries that Refuse to Take Back Their Deported Nationals Before the Comm. on Oversight and Government Reform, supra note 229. 239. Recalcitrant, supra note 220. 240. Recalcitrant Countries: Denying Visas to Countries that Refuse to Take Back Their Deported Nationals Before the Comm. on Oversight and Gov’t Reform, supra note 229. 241. See Citizens of Nowhere, supra note 3, at 20. 242. Corgan, supra note 18. 243. See RUTGERS SCHOOL OF LAW-NEWARK IMMIGRANT RIGHTS CLINIC, FREED BUT NOT FREE: A REPORT EXAMINING THE CURRENT USE OF ALTERNATIVES TO IMMIGRATION DETENTION 5 (2012) [hereinafter FREED BUT NOT FREE]; Immigration and Nationality Act §241; 8 U.S.C §1231 (2018); 8 C.F.R 241.5. 244. See Immigration and Nationality Act §241; 8 U.S.C §1231(a)(3) (2018). 245. FREED BUT NOT FREE, supra note 243, at 19. 383