VZCZCXRO8117
RR RUEHAST RUEHBI RUEHCI RUEHDBU RUEHLH RUEHNEH RUEHPW
DE RUEHKA #0950/01 2790954
ZNR UUUUU ZZH
R 060954Z OCT 09 ZDS
FM AMEMBASSY DHAKA
TO RUEHC/SECSTATE WASHDC 9515
INFO RUEHPNH/NVC PORTSMOUTH 2762
RUCNCLS/ALL SOUTH AND CENTRAL ASIA COLLECTIVE

UNCLAS SECTION 01 OF 06 DHAKA 000950 
 
C O R R E C T E D C O P Y (PARA 1 & 19) 
 
SIPDIS 
 
DEPT FOR CA/FPP 
DEPT PASS TO KCC WILLIAMSBURG KY 
POSTS FOR FRAUD PREVENTION MANAGERS 
 
E.O. 12958: N/A 
TAGS: KFRD CVIS CPAS CMGT ASEC BG
SUBJECT: FRAUD SUMMARY - DHAKA 
 
REF:  (A) 08 STATE 74840  (B) DHAKA 765  (C) DHAKA 799 
 
DHAKA 00000950  001.3 OF 006 
 
 
----------------------- 
¶A.  COUNTRY CONDITIONS: 
----------------------- 
 
¶1.  Dhaka is a high fraud post.  In FY 2009, Dhaka's FPU conducted 
FPU verifications (mostly site visits) for 488 cases, not/not 
counting cases referred for DNA analysis.  Many of these cases 
required several site visits to complete.  Infrastructure, 
especially road infrastructure, is poor outside of main cities and 
towns.  This circumstance, combined with wide-spread seasonal 
flooding and frequent natural disasters, makes scheduling and 
execution of fraud field verifications and site visits challenging. 
 
¶2.  Bangladesh is a developing country of more than 150 million 
people living in an area roughly the size of Wisconsin. The areas 
around the capital city, Dhaka, and around Comilla are the most 
densely populated.  More than a third of the population lives below 
the poverty line, and the current per capita income is about $621 
per year.  More than 50% of the population is involved in 
agriculture which accounts for about 22% of GDP. The annual GDP 
growth rate of about five percent for the past decade has not been 
sufficient to reduce the level of poverty for the majority of 
Bangladeshis. 
 
¶3.  The vast majority of Bangladeshis are culturally Bengali, 
although there are also non-Bengali ethnic groups among the tribal 
groups.  88.3 percent of the population is Muslim, 10.5 percent are 
Hindu, and the remaining 1.2 percent include Christians, Buddhists, 
and other religions. 
 
¶4.  Bangladesh is a parliamentary democracy. On December 29, 2008, 
the Awami league (AL), led by Sheikh Hasina Wazed, won 230 of 299 
parliamentary seats in elections considered by international and 
domestic observers to be both free, fair, and credible.  The 
elections and the peaceful transfer of power that followed ended two 
years of rule by a caretaker government under a state of emergency. 
 
-------------- 
¶B.  NIV FRAUD: 
-------------- 
 
¶5.  Although Dhaka is a high-fraud Post, window fraud on the NIV 
line is generally unsophisticated, obvious, and properly frustrated 
with a 214(b) refusal.  Given that almost all documents are 
considered unreliable, officers rely on effective lines of 
questioning during interviews rather than on documentation.  In 
order to cut down on cases referred to the Fraud Prevention Unit 
(FPU), line officers generally refer a case only when it contains 
traits of a possible new fraud trend or indication of visa fraud 
ring involvement. 
 
¶6.  We occasionally see walk-in individuals who want to verify that 
their visas are genuine.  These applicants have similar stories of 
being contacted by visa agents with stories of visas available for a 
steep price to travel to the U.S. for employment as "fisherman" or 
something similar.  Most of the walk-ins have produced what appears 
to be a computer manipulated color printout of a visa foil with 
mismatched data from a number of posts (i.e., foil number from 
Cairo/issuing post on foil is Cotonou).  The visa classification is 
either B1/2 or H1B.  Section L of this cable contains additional 
information regarding our coordination of efforts with local 
authorities on these cases.  One notable exception to this pattern 
was detected by Singapore Airlines.  A Bangladeshi passenger was 
offloaded in Singapore when airline authorities noticed 
irregularities with his visa.  This is the first known successful 
usage of one of these fake visas for travel.  The scam originated in 
Nigeria utilizing a Bangladeshi travel agency as the middle man. 
The passport was seized and local authorities interviewed the 
passenger.  Dhaka's ARSO-I has opened a DS investigation targeted 
against the alleged conspirators for producing a counterfeit visa. 
 
¶7.  Though Dhaka is a low-volume H1-B post, most of our serious NIV 
fraud is found in the H1-B category.  Frequently we find our 
applicants are qualified but the petitioning company is "benching" 
applicants.  However, we are seeing an increase in applicants who 
are not qualified.  The most sophisticated cases involve IT 
companies petitioning for Bangladeshi workers who are server 
administrators or database administrators but the position 
descriptions are for application developers.  Usually these 
positions require extensive code development knowledge, working with 
customers to identify application requirements, and defect tracking 
- skills which the applicants do not have.  We suspect the offending 
companies are attempting to bench lower level IT workers. 
 
¶8.  In the past, applicants in the R-1 category were chronically 
problematic due to nebulous qualifications and employment histories. 
 
DHAKA 00000950  002.3 OF 006 
 
 
The implementation of the petition requirement for R-1 applications 
has drastically reduced the total number of applicants under this 
category with no new cases referred to FPU for the second straight 
fraud summary reporting period. 
 
------------- 
¶C.  IV FRAUD: 
------------- 
 
¶9.  IV fraud consumes the majority of available FPU resources. 
Petitioners and applicants are well aware of our efforts to combat 
fraud, including our methods and limitations.  Consequently, we see 
many instances where a petitioner petitions for multiple family 
preference applicants but holds one or more of these cases at NVC by 
not paying fees.  This is done in order to enable fraudulent cases 
involving fake spouses or over-aged children to clear post first 
before legitimate cases are processed.  Our aggressive investigation 
policy involving all cross-reference cases usually pays dividends. 
We continue to uncover marital status fraud on current cases and 
those still pending at NVC (being held through non-payment of 
fees). 
 
¶10.  We see a significant amount of age fraud among applicants in 
age dependent visa categories (especially F2A applicants and F4 
derivatives).  With the almost complete lack of security of most 
Bangladeshi civil documents, it is very easy for applicants to 
obtain legitimate documents with false information to support their 
relationship claims.  FPU field verifications have uncovered many 
instances where responsible officials were aware that the documents 
they were issuing contained fraudulent information.  Since birth 
certificates are generally not reliable and most birth registrations 
occur only a few months before a petition is filed, we generally 
rely on secondary documents, such as school certificates, to 
corroborate the applicant's claimed date of birth.  The local school 
system is the most accurate record keeping entity in Bangladesh with 
respect to dates of birth.  The FPU is very successful on site 
visits initiated to uncover age fraud, either in the form of forged 
certificates or certificates with fraudulent information not 
supported by the school's records.  Often, a school administrator 
issues an official document with falsified data, either as a favor 
to the applicant, or as a result of heavy pressure from an outside 
entity, e.g. family in the U.S. 
 
¶11.  In IV cases, marital status fraud is common in F2A and F2B 
cases. Recent numbers indicate a fifty percent fraud rate where an 
applicant hid an existing spouse in order to remain eligible as the 
son/daughter of an LPR. FPU makes neighborhood site visits to verify 
marital status. Although both time and labor intensive, they are 
almost the only way to uncover or confirm fraud. 
 
¶12.   The tradition of arranged marriages also poses difficulties 
for adjudicators in CR1 and K visa cases.  Since it is not unusual 
for a new spouse to know almost nothing about their partner, we rely 
heavily on secondary evidence to establish the bona fides of the 
marriage.  We ask for photos, videos, invitations, cards, etc., to 
prove the relationship is valid.  The lack of secondary evidence can 
be a strong indicator that the applicants are perpetrating marriage 
fraud. 
 
¶13.  During this summary period, the Fraud Prevention Manager (FPM) 
and adjudicating officers jointly developed standardized criteria 
for referring CR1 and K visa cases to the FPU. This was a difficult 
task as the case facts and documentation of a marriage for 
immigration purposes and a legitimately arranged marriage are 
sometimes very similar.  The new criteria are based on supporting 
statistics from FPU verifications which showed a low fraud confirmed 
rate in such cases.  Highlights of our standardized criteria for 
referring CR1 and K visa cases include more targeted questioning and 
identifying a clear aspect of the case to investigate rather than a 
generically worded reason for referral. 
 
¶14.  Post receives a number of requests each year from the 
Department of Homeland Security (DHS) for document and field 
verifications, either from United States Citizenship and Immigration 
Services (USCIS) adjudicators or Fraud Detection and National 
Security (FDNS) investigators. In 2009, we completed 13 
investigations for DHS.  24 DHS cases are still pending. 
 
------------- 
¶D.  DV FRAUD: 
------------- 
 
¶15.  Bangladeshis are enthusiastic participants in the Diversity 
Visa (DV) program. For DV 2009, 4.3 million Bangladeshis submitted 
entries out of a worldwide total of 13.6 million, and Bangladesh 
perennially ranks in the top five for DV winners. Corrupt agents and 
cyber cafe operators (hereafter referred to as DV agents) are 
equally enthusiastic about the DV program.  Many Bangladeshis do not 
 
DHAKA 00000950  003.3 OF 006 
 
 
have access to the Internet or have limited English language skills, 
necessitating the use of cyber cafes and agents for online data 
entry.  DV agents manipulate the entries by substituting an address 
under their control and frequently change the applicant's marital 
status to single instead of married.  Once the address is changed, 
the applicant is effectively under the control of the DV agent. 
Once received, winning letters are held for ransom by the agent. 
The applicant is informed that he/she may receive the letter for a 
very large cash payment or, in lieu of payment, by adding a fake 
spouse to the application.  Every year, post conducts outreach to 
educate potential applicants of the pitfalls of DV agents and 
encourages the applicants to take control of their application 
process as much as possible.  DV 2009 experienced an increase in the 
number of applicants who were married but submitted an online 
application indicating they were unmarried.  Based on applicant 
interviews we know this is usually attributed to poor preparation on 
the part of the applicant at the time of data entry (usually at a 
cyber cafe) or DV agent involvement. 
 
¶16.  As previously discussed, the tradition of arranged marriages 
makes it extremely difficult to distinguish between legitimate 
arranged marriages and marriages solely for immigration purposes. 
Again, we rely on the usual array of secondary evidence.  If the 
submitted evidence fails to establish that a genuine marriage 
exists, we coQuct resource intensive field verifications.  DV 2009 
saw an unprecedented number of false addresses given by applicants 
in order to hide both sham marriages and their true marital status. 
 
¶17.  Occupational qualification fraud is the easiest DV fraud to 
detect.  Using the O-Net standards, adjudicators ask detailed 
questions about the applicant's usual work and can usually quickly 
separate those who qualify from those with inflated their 
qualifications. 
 
¶18.  Counterfeit, improvidently issued, and/or altered school 
certificates are also commonplace.  Post has extensive exemplar 
files of genuine and fake Secondary School Certificates (SSC) and 
Higher Secondary Certificates (HSC) from all the regional Boards of 
Education.  These are available in both hard copy and electronic 
soft copy to all members of the Consular staff. 
 
¶19.  In October 2005, the Ministry of Education established a 
website for on-line verification of educational certificates.  This 
website allows nationwide verification of certificates issued after 
the computerization of Board records, generally from the mid-1990s. 
This has proved to be an important anti-fraud resource for DV 
adjudicators.  During DV 2009, Dhaka saw a dramatic increase in the 
number of fraudulent Technical Board certificates.  Unlike HSC 
certificates, Technical Board certificates cannot be validated 
online.  Unqualified applicants and/or their corrupt agents sought 
to exploit this as a weak point in our ability to verify 
information.  Fortunately, Dhaka's FPU has an excellent relationship 
with the Technical Board Controller and we are able to hand deliver 
and verify on-site all questionable Technical Board documents. 
 
--------------------------- 
¶E.  ACS and PASSPORT FRAUD: 
--------------------------- 
 
¶20.  We have extremely low incidence of fraud in these areas.  Most 
suspect cases involve Consular Reports of Birth Abroad and are 
investigated through the use of DNA. 
 
¶21.  During a recent routine review of an A1 visa application for 
the spouse of a Bangladeshi diplomat in Washington, reported in 
reftel C, the interviewing officer noticed that she listed her son 
on her application but did not submit a visa application for him. 
Further questioning revealed that he had been born in the United-States 
in 2008 and had been issued a U.S. passport. 
 
The applicant was asked about the circumstances surrounding the 
issuance of her son's passport and she confirmed her signature on 
the Application for U.S. Passport.  According to passport records, 
the applicant presented a Maryland state identification card instead 
of her Bangladesh passport or diplomatic carnet, concealing her 
diplomatic status in the United States.  With Department 
concurrence, we revoked the passport.  The Chief of Mission has 
recommended the withdrawal of the Bangladeshi diplomat from the 
United States. 
 
------------------- 
¶F.  ADOPTION FRAUD: 
------------------- 
 
¶22.  Bangladesh civil law makes no provision for adoption. Islamic 
and Hindu practices either forbid or strictly limit almost all 
adoptions. The only legal adoption recourse is for Bangladeshi 
adults to apply for an order of guardianship under the 1890 Guards 
 
DHAKA 00000950  004.3 OF 006 
 
 
and Wards Act. Only Bangladeshi natives and citizens may become 
guardians in this manner.  In some cases, the guardianship can form 
the basis of an IR-4 petition.  Most of our fraud involves direct 
transfers between family members where a relative in the U.S. seeks 
to adopt a cousin or nephew/niece in order to give the child a 
better life in the US.  The family in Bangladesh generally tries to 
fraudulently conceal their standard of living in order to qualify 
the child as an eligible orphan.  Because of the prohibition of 
adoptions and lack of reputable orphanages, it is also common for 
prospective adoptive parents to rely on family and friends in 
Bangladesh to informally arrange adoptions directly with the 
biological parents.  These families also try to conceal the direct 
transfer in order to fraudulently qualify the child as an orphan. 
 
¶23.  There is also a tradition of "social adoptions" in Bangladesh, 
in which families take in orphans of relatives or foundlings and 
raise them as their own.  Social adoptions also include parents who 
have many children giving one of their children to a sibling who is 
childless and not able to conceive.  In both of these cases, the 
parents rarely regularize the child's status and the child may not 
be aware of his or her actual parentage.  This often comes to light 
when DNA testing reveals that one or another child may not be 
eligible to receive a visa in family preference cases. 
 
----------------------- 
¶G.  Use of DNA Testing: 
----------------------- 
 
¶24.  Post's adjudicating officers allow applicants ample opportunity 
to provide sufficient evidence of relationship (EOR) during an 
initial interview and subsequent return interviews.  However, many 
applicants are unable to provide adequate EOR required to establish 
a petitionable relationship and are requested to complete DNA 
testing.  Post provides a letter that explicitly states any AABB 
certified lab that the petitioner or applicants choose can conduct 
the testing.  The vast majority of genetic relationships are 
affirmed for those applicants that show up for testing. Not 
infrequently, a principal applicant advises us that one of the 
derivatives in the case has recently "died" - an indication that the 
derivative was most likely not an immediate family member.  Post 
views DNA testing as a valuable fraud deterrent. 
 
¶25.  Recent 9 FAM changes regarding DNA collection are being 
implemented in Dhaka.  Post procedures already incorporated many of 
the new procedures. 
 
--------------------------------------- 
¶H.  ASYLUM and other DHS BENEFIT FRAUD: 
--------------------------------------- 
 
¶26.  Dhaka handles both VISAS 92 follow-To-Join (FTJ) cases and 
requests for investigation in ongoing political asylum cases.  Since 
the arrival of the current FPM in August of 2008, there have been no 
VISAS 92 cases referred to FPU and only two requests from DRL for 
follow-up investigations of asylum cases.    Historically, post has 
had several file drawers dedicated to pending asylum and 
follow-to-join case investigations; however, this workload has 
recently abated.  Most likely this reduction is a direct result of 
FPU investigations proving a great number of these claims were 
bogus.  We are concerned about our ability to manage an 
investigation backlog if asylum cases reach prior year volumes. 
 
---------------------------------- 
¶I.   Alien Smuggling, Trafficking, 
Organized Crime, Terrorist Level: 
---------------------------------- 
 
¶27.  Reports from various sources in 2008 indicating Bangladeshi 
nationals may be probing for paths of lesser resistance into the 
U.S. via South America.  Sources include the Human Smuggling and 
Trafficking Center (HSTC) and our British counterparts.  It appears 
Bangladeshis are exploiting lax visa issuances and, in some cases, 
the lack of a visa requirement, to facilitate travel to South 
American countries with a probable final destination of the U.S. or 
Canada. 
 
¶28.  South American travel by our applicants is almost non-existent, 
but adjudicating officers are aware of the reports.  Any such travel 
could be an indication of a facilitator and our officers are 
instructed to alert the FPM or ARSO-I if an applicant's passport 
indicates travel in that region. 
 
------------------------------------- 
¶J.  DS Criminal Fraud Investigations: 
------------------------------------- 
 
¶29.  Dhaka's ARSO-I and FPM have a strong working relationship and 
are jointly defining strategies and areas of focus for combating 
 
DHAKA 00000950  005.3 OF 006 
 
 
visa fraud. As reported in reftel B, the A/RSO-I function is an 
element of Mission Dhaka's effort to combat pervasive high fraud. 
Lagging GOB law enforcement, slow judicial follow through and 
exigent post security requirements will continue to challenge 
A/RSO-I operations. 
 
--------------------------------------------- - 
¶K.  Host Country Passport, Identity Documents, 
and Civil Registry: 
--------------------------------------------- - 
 
¶30.  The lack of secure identity and relationship documentation in 
Bangladesh is one of the biggest contributors to the number of cases 
referred to FPU for investigation.  Neighborhood checks are usually 
the only way for FPU to establish whether or not information 
presented at the window is legitimate. Non-qualified individuals can 
obtain authentic (albeit improvidently issued) passports, birth 
certificates, driver's licenses, national IDs, marriage and divorce 
certificates, and any other issuable document from legitimate 
sources in Bangladesh. The current national passport is poorly made 
and easily manipulated.  There is very little control over 
biographic information contained in issued passports.  Genuine 
passports containing totally false identity data are easily 
obtained.  Bangladesh hopes to start producing machine readable 
passports in 2010. 
 
¶31.  Due to the inherent poor control of civil documentation, many 
applicants have difficulty providing credible ID.  Many applicants 
provide nothing more than a passport and an old school ID that 
consists of a piece of paper with a stapled photograph.  Many 
documents show signs of mold and severe weathering. 
 
¶32.  Muslim marriage and divorces are required by law to be 
registered at the local "Kazi" office.  The registration books are 
simple, ordinary registry books with hand-written pages.  The 
registry books are usually housed in locked wall lockers with no 
additional physical security.  Civil Government control over the 
Kazis is negligible.  It is not uncommon for FPU investigators to 
find books out of sequence, pages glued in, and marriages added to 
the end of the registration books for any given year.  These 
manipulations are reliable indicators of fraud. 
 
--------------------------------------------- --- 
¶L. COOPERATION WITH HOST GOVERNMENT AUTHORITIES: 
--------------------------------------------- --- 
 
¶33.  We receive cooperation from most local government offices 
regarding verification of school certificates, marriage and divorce 
certificates, and passports.  However, the court system and local 
police are usually uninterested in aggressively pursuing legal 
action against visa fraud perpetrators and corrupt visa agents. 
Witnesses generally fear extortion by local police and quickly lose 
interest in pursuing a complaint, especially when a case stagnates 
due to lack of police action.  In one case where the ARSO-I was 
successful in having witnesses make a formal complaint against visa 
brokers, police inaction led to the perpetrators going unpunished. 
 
--------------------- 
¶M.  AREAS OF CONCERN: 
--------------------- 
 
¶34.  Due to the steady increase in numbers of IV cases processed at 
post and the continued participation of Bangladesh in the DV 
program, we expect that the number of cases referred to FPU will 
continue at the same increasing rate.  In order to maintain the 
integrity of FPU operations and to protect our LES investigators 
from accusations of malfeasance, Dhaka sends an American FSO or EFM 
on all field investigations.  The FPM or the EFM Consular Assistant 
conduct most of the investigations with occasional assistance from 
other FSOs from the IV or NIV units.  Staffing levels are becoming a 
major area of concern.  We have requested additional positions, one 
officer, and one Locally Engaged Staff (LES), to bolster consular 
and FPU resources.  The current FPM has overhauled FPU operations to 
make them more efficient and to optimize use of available resources, 
but the number of cases pending investigation continues to outpace 
the number of cases completed despite the fact that our Consular 
Assistant or FPM are away from the office over 50 percent of the 
time completing field verifications and site visits. 
 
¶35.  The Dhaka Anti Fraud Group (AFG), a collection of mostly 
English-speaking foreign mission anti-fraud counterparts who met 
regularly to share and disseminate anti-fraud information, is in the 
early stages of being reconstituted.  For the previous year it had 
been defunct. Recently, Dhaka's FPM and British High Commission 
counterparts have reignited interest in this information sharing 
group and have scheduled its first meeting in over a year.  At least 
five diplomatic missions will be represented and we hope to grow the 
number during the next year. 
 
DHAKA 00000950  006.3 OF 006 
 
 
 
¶36.  Due to the high incidence of fraud in past year DV visa 
issuances; post is seeing a number of cases involving petitioners 
who may have received their immigration status through fraudulent 
circumstances.  The FPM will continue to aggressively research and 
return these cases to NVC and CA/VO/L/A for referral to DHS.  Dhaka 
firmly believes that the number of fraudulent IV cases will diminish 
if the Department and DHS pursue these types of cases. Loss of LPR 
or Citizenship status for past immigration fraud would go a long way 
to deter petitioner fraud as word will spread quickly that we mean 
business. 
 
--------------------------- 
¶N.  STAFFING AND TRAINING: 
--------------------------- 
 
¶37.  Miller, Glenn - FPM 
Fraud Prevention for Managers - FSI 
 
Vaagan, Nate - Consular Assistant 
 
Azahar, Mohammad - Senior FPU LES 
PC-542 FSN Fraud Prevention Workshop FSI 
PC-544 Detecting Fraudulent Documents Online 
PC-128 Detecting Imposters Online 
 
Khan, Jahan - FSN Investigator 
PC-542 FSN Fraud Prevention Workshop FSI 
PC-544 Detecting Fraudulent Documents Online 
PC-128 Detecting Imposters Online 
PC-545 Examining US Passports Online 
 
D' Costa, John - FSN Investigator 
PC-542 FSN Fraud Prevention Workshop FSI 
PC-544 Detecting Fraudulent Documents Online 
 
Akter, Sheuly - FSN Investigator 
PC-544 Detecting Fraudulent Documents Online 
PC-128 Detecting Imposters    Online 
 
Huda, Nazmul - FSN Investigator 
PC-544 Detecting Fraudulent Documents Online 
PC-128 Detecting Imposters Online 
PC-545 Examining US Passports Online 
 
DEAN