The New York Times recently reported that the Department of Justice (DOJ) soon plans on assigning “civil litigators in 39 regional offices ... to file denaturalization cases against” 384 naturalized citizens. It’s high time DOJ — and DHS for that matter — took the issue of fraud and deliberate omissions during the naturalization application process seriously, if for no other reasons than U.S. citizenship deserves to be vigorously guarded and to send a message to any alien thinking about defrauding our immigration system.
The Naturalization Process in Brief
As USCIS explains: “Naturalization is the process by which U.S. citizenship is granted to a lawful permanent resident after meeting the requirements established by Congress in the Immigration and Nationality Act (INA).”
It is the culmination of a process by which a foreign national legally immigrates to the United States and receives lawful permanent resident (LPR) — that is, “green card” — status.
Aliens who are at least 18, have LPR status, have resided here for three years after receiving a green card, and are “living in marital union with their U.S. citizen spouses can apply to naturalize, provided they can “read, write and speak English” and understand “the fundamentals of the history, and of the principles and form of government, of the United States”.
Green card holders who have “served honorably at any time in the U.S. armed forces for a period or periods totaling at least 1 year” and are at least 18 can apply for naturalization provided they meet the language and civics requirements and, if they have left the armed forces, “were separated under honorable conditions”.
Other green card holders — the majority — must rack up five years of residence in the United States and meet the English and civics requirements before applying for citizenship, except for the minor children of U.S. citizens, who automatically receive citizenship provided they are “in the legal and physical custody of the U.S. citizen parent”.
One older immigration judge of my acquaintance referred to the last process as “the magic immigration fairy sprinkling naturalization dust on the kid’s head”, and it’s stuck with me ever since.
The Bars to Naturalization
The description above left out some critical factors.
Persons applying for naturalization must show they are persons of “good moral character” (GMC) and have been persons of GMC for the statutory period (and likely for a good bit prior, as well), and like most 19th century concepts that continue to haunt the INA, it’s a difficult thing to explain simply.
Logically, murderers, aggravated felons, persecutors, torturers, Nazi genocidaires, and those who have engaged in “particularly severe violations of religious freedom” can’t ever show GMC.
And then there are the “conditional bars” to GMC for a laundry list of offenses committed in the recent past, which include “crimes involving moral turpitude”; certain drug, prostitution, gambling, and smuggling convictions; false testimony under oath; polygamy; adultery; and habitual drunkenness and serial DUIs.
If you have been convicted of “two or more offenses with combined sentence of 5 years or more (other than a political offense)”, or have served more than 180 days in jail, you should likely let the GMC clock run for a bit before applying, as well.
By the way, USCIS won’t take your word on your English-language competency, but the test isn’t overly strenuous (as shown by voting ballots written in a variety of languages), and the civics portion of the application process involves an examination as well.
You won’t be deported if you fail either test, but you may have to apply for naturalization again.
Denaturalization
While USCIS can handle naturalization administratively, an order of “revocation of naturalization” — better known as “denaturalization” or simply “denatz” — can only be issued by a federal judge.
As the agency explains:
A person’s naturalization can be revoked either by civil proceeding or pursuant to a criminal conviction. For civil revocation of naturalization, the United States Attorney’s Office must file the revocation of naturalization actions in Federal District Court. For criminal revocation of naturalization, the U.S. Attorney’s Office files criminal charges in Federal District Court.
The government holds a high burden of proof when attempting to revoke a person’s naturalization. For civil revocation of naturalization, the burden of proof is clear, convincing, and unequivocal evidence which does not leave the issue in doubt. For criminal revocation of naturalization the burden of proof is the same as for every other criminal case, proof beyond a reasonable doubt.
There are generally only three situations in which a naturalized citizen loses U.S. citizen status: the individual illegally procured naturalization; the individual concealed a material fact or made a willful misrepresentation at some point during the immigration and/or naturalization application process; or the newly minted citizen received naturalization through military service and received an “other than honorable” discharge before serving at least five years in uniform honorably.
Note that “procurement of citizenship unlawfully” is also a federal crime under 18 U.S.C. § 1425, carrying a minimum penalty of up to 10 years’ incarceration and a fine, which jumps to 25 years “if the offense was committed to facilitate an act of international terrorism”, or 20 years if it’s just to facilitate drug trafficking.
Marriage Fraud
Any number of aliens received green cards through fraudulent marriages of the sort discussed by the Board of Immigration Appeals (BIA) in its recent opinion in Matter of Fortjoe, a case involving a Ghanian who received LPR status through his marriage to his U.S. citizen wife, “Emma”, in 2002.
When Fortjoe appeared before USCIS in 2007 in connection with the visa petition Emma had filed on his behalf, he oddly failed to tell the adjudicator about the two children he had fathered (in 2004 and 2007) with another Ghanian national, Christy.
Sadly, not all marriages last, and the now-LPR thereafter divorced Emma and “did the right thing by” Christy, though the paternity of their two children didn’t come up until he applied for naturalization — which USCIS denied.
This is far from an isolated case.
In April 2025, federal officers arrested 14 individuals for immigration fraud in connection with “Operation Bargain Brides”, described by ICE as a “significant investigation into a marriage fraud scheme” that reaped approximately $4 million.
According to local reporting in Baltimore on the case:
The ringleaders are accused of charging up to $40,000 for each bogus bride and groom matched up. ... More than 120 people paid that price tag, including 10 Maryland residents who showed up for scheduled immigration appointments and were arrested.
Then, there’s the “Benitez Agency Case”, in which four individuals were sentenced in federal court in Boston in March 2024 for their participation in what’s described as “a large-scale marriage fraud agency that arranged hundreds of sham marriages for the primary purpose of circumventing immigration laws”.
As ICE Homeland Security Investigations (HSI) Special Agent in Charge Chad Plantz explained after those convictions were handed down: “The defendants in this case knowingly and willing abused our current immigration system to obtain fraudulent green cards. ... These fraudsters and nefarious actors are responsible for over 600 illegal applications filed with the courts.”
Then, there’s the 11 individuals who were charged in Jacksonville, Fla., in February for alleged conspiracy related to marriage fraud and bribery. As the DOJ press release explains:
According to the indictment, the ... individuals allegedly engaged in a conspiracy to recruit United States citizens, preferably members of the armed forces, to enter into sham marriages to Chinese nationals for the purpose of evading immigration laws and illicitly obtaining lawful permanent resident status for the Chinese nationals.
There’s no information on how many individuals allegedly entered unholy wedlock under this purported scheme, but local reporting from Jacksonville claims that the defendants were charged with conspiring “to recruit U.S. citizens to enter fraudulent marriages with citizens of the People’s Republic of China”, as well as with “a bribery conspiracy to obtain Defense Department common access cards, known as CACs” to gain access to U.S. military bases.
It’s curious that this case hasn’t received broader attention, and I could go on, but you get the point.
That Was Then, This Is Now
Traditionally, when DHS busted a large-scale scheme to obtain immigration benefits through marriage, asylum, business-visa, or green-card fraud, it only targeted the ringleaders and left the equally culpable beneficiaries alone.
That has plainly changed now that Joe Edlow has taken the helm as director of USCIS. On April 20, he tweeted:
Fraud permeates our entire immigration system.
Our new @USCIS special agents will ensure there are consequences for this type of fraud.
No one is entitled to immigration benefits & naturalization. Immigration to the U.S. is an honor & we will make sure it’s done correctly. pic.twitter.com/45JNDtQsMu— USCIS Director Joseph B. Edlow (@USCISJoe) April 20, 2026
The agency reportedly plans on hiring 200 special agents who will focus solely on immigration fraud, and Edlow will be opening a tip-line where individuals can report on scammers and directing his agency to re-vet cases approved during the last administration.
Interestingly, Edlow’s fraud proposals have been extensively covered by Indian outlets, including the Times of India and Financial Express.
Make of that interest what you will, but don’t be surprised when aliens found to have benefitted from fraud start diming out others, including more than a few who have naturalized.
“Justice Dept. Targets Hundreds of Citizens in New Push for Denaturalization”
Which brings me back to the Times article, which, while not mentioning Edlow, suggests his efforts will soon be supported by denatz units at U.S. Attorney’s Offices around the country.
Interestingly, the article states that, “The move will likely scare many naturalized immigrants as the Trump administration has sought to curtail immigration across the board and spoken disdainfully about migrants from certain countries.”
The last part is a petty non-sequitur, particularly given that the Times never mentions the nationalities of those who are being targeted and apparently is unaware of their identities.
The intro, however, is spot-on, though it implicitly suggests aliens who naturalized illegally have a right to live without fear of the consequences of their actions, a contention I believe most would disagree with.
“Naturalized Citizens Don’t Have the Same Rights and Stability”
In that vein, the outlet quotes a University of Virginia law professor, who complains: “The message it sends is that naturalized citizens don’t have the same rights and stability as native-born citizens.”
Respectfully, by definition “naturalized citizens don’t have the same rights and stability as native-born citizens” because the latter cannot be denaturalized or deported, while the former should be if they obtained their citizenship illegally.
Perhaps the professor thinks Edin Dzeko, a national of the former Yugoslavia who was denatz’ed and deported for failing to disclose his affiliation with “an elite unit of the Army of the Republic of Bosnia and Herzegovina” during the “Trusina massacre” should be allowed to sleep soundly in his U.S bed, but I doubt it.
Nor should Melchor Munoz, one-time Mexican national who was denaturalized in March after it came to light that he failed to mention his role in a drug-trafficking conspiracy when he applied for U.S. citizenship in 2009 (he tried unsuccessfully to claim at trial that he only got into the game after he was naturalized).
Nor should Italian native Michael Pizzuti, who was denaturalized early this month.
Pizzuti appeared at his naturalization interview in May 2002 — “less than five months after his first indictment and arrest” for dealing in counterfeit cash, trafficking contraband cigarettes, and conspiring to steal a truck and commit mail fraud — but never mentioned that arrest to the adjudicator (it should have been fresh on his mind), which led to his naturalization two months later.
Nor should Baljinder Singh, and countless others.
Hard to Do, but Worth It
Fraud by its nature is difficult to uncover after the fact, so it’s essential to deter fraudsters before they act. One reason our immigration system is rife with fraud is that prior administrations rarely punished it, even after it was revealed.
Uncovering immigration fraud is hard, and the “clear, convincing, and unequivocal evidence” standard for denaturalization is onerous, but all should agree U.S. citizenship deserves to be jealously guarded and that anyone who attempts to steal it should be prosecuted and denied “stability”. Well, maybe only some of us would agree with that last point.