The Do's and Don'ts of Handling Immigration Law Enforcement Tips

By David North on January 17, 2020

[Editor's note, 2/5/2020: This posting has been revised to reflect a helpful note from an attorney for the university in question, Ronald L. Holt, and to describe more precisely the institution's accreditation issues. A somewhat similar revision can be found in an earlier posting published by CIS on January 20 entitled "Department of Education Agrees with CIS on Two Marginal Colleges". The full text of Mr. Holt's letter can be seen here.]

We at the Center often receive — and pass along to the appropriate authorities — tips on violations of the immigration law.

There are folks who are now in, or have been, in jail as a result, and there were questionable institutions that are no longer in business. There also has been a certain amount of lost time and effort.

Two events earlier this week reminded me that it might be useful to review the do's and don'ts of handling immigration enforcement tips, which can be summarized as follows for the tipsters:

  • Be precise;
  • Be brief;
  • Try to be literate;
  • Send your tips to the right place;
  • Be prepared to answer specific, follow-on suggestions;
  • Don't simply dump scores of pages of undigested raw material on us; and
  • Don't make a nuisance of yourself with constant repetitions of a single fact.

And, on the part of the authorities:

  • Respond to tips as quickly and as thoroughly as you can; and
  • Let tipsters know — even if it's years later — the results of the tip, such as the guys in jail.

If these rules are followed, enforcement can be enhanced; if not, time will be wasted and useful information will be ignored.

As to the events in question, in a space of no more than two hours earlier this week, and as the result of emailed tips I had passed on to state agencies in California and Virginia regarding the misbehavior of for-profit colleges in the foreign-student business, this happened:

  • A Virginia regulator to whom I had once been very briefly introduced sent me an instant email reply saying: "Thanks. I am glad you are documenting these issues. As you know, this area of activity is little known and even less understood by the public at large."
  • I got a phone call from a California regulator totally unknown to me who said he was impressed by the information I had given to his agency — " you found one line in a long website and did so from 3,000 miles away."

Needless to say I was chuffed and, of course, indirectly encouraged to work more closely with both agencies.

The Virginia regulator was reacting to his receipt of this posting on Virginia University of Science and Technology, a would-be teacher of foreign students.

The man in California saw a note I had sent to his boss regarding a school in the foreign-student business, the San Diego University of Integrative Studies. An on-campus affiliate of the university, USA English language Center, had noted in its part of the university's website that it was accredited by the Accrediting Council for Continuing Education and Training, when in fact, it had been rejected by that organization. [In our earlier report we said that the university itself — not the affiliate — had made that claim, when in fact the university does not claim accreditation.] The state employee said he would talk to SDUIS about the claim, and it was soon off the website.

I took advantage of his call to tell him about Northwestern Polytechnic University in Fremont, Calif., a marginal school for foreign students that somehow — despite nominal non-profit status — has accumulated a surplus of a quarter of a billion (with a "b") dollars, as we reported earlier.

And, moving back in the sequence, a tipster had told me earlier about SDUIS in unflattering terms. (I have since told that person the results of his or her tip to me; and have let ACCET know about this development.)

Back to the North Rules on Enforcement Tips. The general idea is that the easier the tip is to the handle, the greater the likelihood of its being useful. And while my comment about the need for literacy may sound a bit elitist, it is part of the bigger picture. An enforcement tip should be regarded as a sales package — the tipster not only wants to convey information, he or she wants to stimulate someone else to do something. And the better the presentation, the more likely there will be a positive result. So, among other things, use the spell-check mechanism on your computer.

Further, over-tipping, if you will, can be counterproductive. I have an informant who will, from time to time, send me masses of information about specific problems in the EB-5 (immigrant investor) program without pointing out the specific, actionable elements. I guess he assumes that I know as much about the program as he does, which, sadly, is not the case.

Another informant repeatedly — I think using different names — sends again and again the same information about another flaw in the immigration system, the fact that some countries, largely in Asia, do not allow us to deport their citizens back to the homeland. I get the point, but the repetition is irking.

So drafting a successful law-enforcement tip is a bit of an art form, and some do it better than others.