Identifier
Created
Classification
Origin
09YEREVAN228
2009-03-30 14:02:00
UNCLASSIFIED//FOR OFFICIAL USE ONLY
Embassy Yerevan
Cable title:  

SEMI-ANNUAL FRAUD SUMMARY (SEPTEMBER 2008 - FEBRUARY 2009)-

Tags:  CVIS CPAS CMGT ASEC PHUM KFRD KCRM AM 
pdf how-to read a cable
VZCZCXRO3857
RR RUEHDBU RUEHLN RUEHSK RUEHVK RUEHYG
DE RUEHYE #0228/01 0891402
ZNR UUUUU ZZH
R 301402Z MAR 09
FM AMEMBASSY YEREVAN
TO RUEHC/SECSTATE WASHDC 8888
RUEHPNH/NVC PORTSMOUTH 0476
RUCNCIS/CIS COLLECTIVE
RUEHFT/AMCONSUL FRANKFURT 1900
UNCLAS SECTION 01 OF 07 YEREVAN 000228 

DEPT FOR CA/FPP - (RSBILLINGS),CA/VO/KCC AND CA/EX
CA/VO/KCC FOR FPM (JSCHOOLS)
NVC FOR FPM (BAUSTIN)
FRANKFURT FOR RCO (KBROUGHAM)
POSTS FOR CONS

SIPDIS

SENSITIVE

E.O. 12958: N/A
TAGS: CVIS CPAS CMGT ASEC PHUM KFRD KCRM AM
SUBJECT: SEMI-ANNUAL FRAUD SUMMARY (SEPTEMBER 2008 - FEBRUARY 2009)-
YEREVAN

REF: (A) 2008 YEREVAN 775 (B) 07 SECSTATE 171211

UNCLAS SECTION 01 OF 07 YEREVAN 000228

DEPT FOR CA/FPP - (RSBILLINGS),CA/VO/KCC AND CA/EX
CA/VO/KCC FOR FPM (JSCHOOLS)
NVC FOR FPM (BAUSTIN)
FRANKFURT FOR RCO (KBROUGHAM)
POSTS FOR CONS

SIPDIS

SENSITIVE

E.O. 12958: N/A
TAGS: CVIS CPAS CMGT ASEC PHUM KFRD KCRM AM
SUBJECT: SEMI-ANNUAL FRAUD SUMMARY (SEPTEMBER 2008 - FEBRUARY 2009)-
YEREVAN

REF: (A) 2008 YEREVAN 775 (B) 07 SECSTATE 171211


1. (SBU) SUMMARY: Armenia remains a high-fraud post. While
consular staff members periodically uncover fraud rings and other
organized plots, post's interviewing officers deal with small-scale
fraud every day. Due to widespread document fraud, including birth
and marriage certificates as well as passports and work documents,
consular officers at post cannot rely on documentation during visa
interviews. The Sixth Department of the National Police, which
combats organized crime, cooperates actively with Post in cases of
document fraud. The National Security Service (NSS),successor to
the Soviet-era KGB, until recently unresponsive when informed about
visa fraud, has become more cooperative as of late. Post has
requested an ARSO/I to strengthen anti-fraud capabilities. This
cable includes action requests (see paras 31-32): 1) that CA/EX
solicit reimbursement from DHS/ICE to for the costs of DHS-requested
investigations/translations, and 2) travel funding be provided to
support ICE-requested fraud manager briefing to ICE attorneys in
California. END SUMMARY

COUNTRY CONDITIONS
--------------


2. (U) The international financial crisis has affected Armenia.
Although Armenia's official unemployment rate is 7.5 percent,
according to household surveys conducted in line with International
Labor Organization methodology, actual unemployment is around 28
percent, and much higher in the provinces and among women. The
strong GDP growth of recent years, driven primarily by construction
in Yerevan, has evaporated and 2009 is likely to be a zero or
negative growth year. Economic projections for 2009 are growing
bleaker with each passing week; the World Bank resident
representative this week was saying informally his team is now
projecting negative eight percent growth this year. The percentage
of people living in poverty -- though much reduced from ten years
ago -- is still high and now growing. Many Armenians depend on

remittances from family members abroad, particularly in Russia,
followed by the United States. The global economic crisis, however,
has significantly reduced remittances--which in recent years have
accounted for approximately 15 percent of Armenia's GDP--and many
workers who used to make the annual trip to Russia to work in
construction (legally or illegally) for 6-8 months per year will not
be returning in 2009. Those remittances are down some 30 percent,
according to the IMF. An estimated 1.5 million Armenians have left
the country since 1990. About one-third of Armenians live in rural
areas, many of them as subsistence farmers. The average salary in
Armenia amounted to USD 270 per month in October 2008. Post's NIV
refusal rate was 53 percent in 2008 and 50 percent in the reporting
period.

NIV FRAUD
--------------


3. (U) Much of the document fraud seen in NIV interviews is
unsophisticated and easy to catch. Occasionally, we find more
serious cases where applicants obtain legitimately issued second
passports, sometimes with different names or dates of birth, an
alternate spelling of the last name, or a new name altogether to
support a mala fide persona. Applicants also can acquire either
genuine but fraudulently obtained or high-quality counterfeit
documents such as birth, marriage and divorce certificates. Post has
had success in referring such cases to the Sixth Department of the
National Police for prosecution. Genuine but fraudulently obtained
diplomas and other education documents are easily available for
those who need to prove credentials (e.g. for DV applicants).
Back-dated reentry stamps are easy to purchase from border guards.
With access to ADIS, post continues to detect ever more instances of
applicants hiding overstays through purchase of back-dated reentry
stamps, to date some dozen cases in the reporting period. Thus,
most primary and supporting documentation is suspect, and officers
cannot rely on them in making visa decisions.


4. (SBU) In the past, post observed the practice of widespread
sharing and/or selling not only of documents, but of phone numbers
and addresses of inviting parties, and other information that
applicants obtain to help facilitate their visas. This phenomenon
has decreased markedly. In immigrant visa and B1B2 visa cases
(especially for a subset of applicants consisting of Indian medical
students),applicants frequently provide commitments of support from
people whom they do not personally know, nor with whom they have any
cogent rationale for a relationship. In the immigrant visa cases,
virtually all cases of contrived contacts are the work of a

YEREVAN 00000228 002 OF 007


notorious visa form filler-slash-translator who fills out the DS-230
immigrant visa application forms. For the Indian medical students,
a tight-knit and small community, post believes issued applicants
share the names of relatives of friends, usually H1B visa holders,
to increase the chances of visa issuance for subsequent medical
students who intend to vacation in the U.S. during semester breaks.
Our Summer 2008 validation study into the travel patterns of Indian
medical students confirmed that virtually all stay much longer in
the U.S. than indicated during their visa application and return
late to school in Yerevan; there is also evidence that many of them
are working illegally during their semester break in the U.S. As a
consequence, post is refusing even more Indian medical students'
visa applications than in the past.


5. (SBU) Post uses its Accurint account several times a week and has
found it very helpful in vetting NIV petition visas, IV cases, and
sometimes ACS cases. Officers and the fraud investigator can follow
up on leads generated by the Lexis-Nexis reports and thus better
judge the accuracy of information submitted by petitioners and
applicants. This allows interviewing officers to render decisions
more quickly and confidently and to better support recommendations
for petition revocation.


6. (SBU) Post daily confirms NIV applicants' actual exit from the
U.S. using our two ADIS accounts provided by CA/FPP. ADIS has
become a powerful tool for discovering fraud, albeit the records
only appear to be accurate as of 2003.


7. (SBU) In the reporting period, post noticed B1B2 abuse by
Armenian performing artists. Triggered by feedback for one case,
post started to review Armenian music websites for information on
performances of Armenian recording and singing artists in the U.S.
We then checked the NIV software or the CCD to see if the artist had
the appropriate visa or was a U.S. citizen or green card holder. In
most cases, artists didn't have P or O visas. Case notes showed
that applicants were routinely and deliberately misrepresenting
their purpose of travel to consular officers in visa interviews.
Abuse has been particularly egregious among artist and performing
groups ostensibly attending a variety of awards shows in Los
Angeles. Post found that almost all recipients did perform at the
awards shows or at public concerts after the awards show. To date,
post has called in approximately a dozen performing artists upon
their return to Armenia to explain their performances on B1B2 visas.
In the vast majority of cases, post has cancelled B1B2 visas and
advised artists to have their tour organizers apply for P visas. In
at least one case so far, our remedy has worked. Post is severely
restricting the issuance of multiple-entry B1B2 visas as our
validation studies have shown overstays and inappropriate use of
B1B2 visas is much higher among holders of multiple-entry visas.

IV FRAUD
--------------


8. (SBU) Yerevan has been processing immigrant visas since 2006. We
find fraud in a significant percentage of family-based visa cases,
especially in K-1 fiancee visa cases. Most fraudulent cases involve
applicants with relatives in the United States who themselves either
overstayed B1B2 visas or lodged questionable asylum cases in the
U.S. These relatives have arranged sham marriages for IV
beneficiaries for the sole purpose of family reunification. In the
reporting period, post returned 26 petitions to NVC for revocation
out of 651 IV issuances and two cases to USCIS-Moscow, a
significantly smaller percentage of our IV/DV workload (excluding
Visas 92/93) than in the previous reporting period.


9. (SBU) Lexis-Nexis has been very helpful in providing leads for
investigation of fraud in instances of sham spouses, or their
follow-on step-children. We frequently find American citizen
petitioners continuing to live with their "ex"-spouses, or not
cohabitating with their new spouse.

DV FRAUD
--------------


10. (SBU) We occasionally discover fraudulent documents on DV
applications, usually intended to support the addition of
derivatives (birth or marriage documents),or - to a much lesser
degree - demonstrate adequate labor qualifications, i.e. vocational
school diplomas for those who didn't finish high school. Overall
fraud in our DV workload appears to be much less of a problem than
in the problematic CR1 and K-1 IV categories. In the reporting
period, only one DV case was refused for failure to qualify for the

YEREVAN 00000228 003 OF 007


DV lottery. There were no DV cases of mala fide pop-up spouses and
only two other cases with permanent ineligibilities. One was a case
where a principal applicant adopted the child of a J-1 Summer
Work/Travel overstayer to reunite the child with her parents in the
U.S. The other involved a DV couple who committed impostor fraud in
the past on a NIV application.


11. (SBU) Post continues to notice an unusually high number of
inexplicable data entry mistakes for biographic information in DV
winners' registration for the DV lottery. This is not just in cases
where a third party in the U.S., who doesn't really know the
beneficiaries, has registered their entry. Post suspects, but has
no proof, that these cases might represent instances where
beneficiaries deliberately register multiple times for the DV
lottery using slight derivations of their date of birth. These
cases may have somehow managed to bypass Facial Recognition checks.
In general, Armenians rely to an extraordinary degree on relatives
in the U.S. or third parties, usually unscrupulous form fillers
known to provide false or misleading advice, to register for the DV
lottery. This even though the DV instructions are posted in Armenian
on post's website and post outreach on DV issues focuses on the
importance of proper data entry.


12. (U) In the reporting period, several DV winners have informed
post that one particular form-filler who registered people for the
DV lottery and who entered the office address as the address for
delivery of notifications, is asking applicants for some USD 2,000
to hand over the envelopes with their immigrant visa appointment
information. In such cases, post has verified appointment dates
through the CCD and IVO software and asks DV winners to pick up
their appointment packets at the consular section.

ACS AND U.S. PASSPORT FRAUD
--------------

13. (U) There appears to be much less fraud in our ACS workload
compared to our IV and NIV workload. Nevertheless, we occasionally
have questionable CRBA applications centering on the U.S. citizen's
actual paternity and ability to transmit citizenship. To date, most
such dodgy CRBA cases have been resolved one way or another with DNA
testing.


13. (U) In the reporting period, Post had one case of a person
claiming to be an American Citizen who appeared in the ACS section
several times requesting a replacement passport for one he claimed
was stolen. There were no PIERS records or any other evidence to
support his claim to U.S. citizenship. On his last visit, the
applicant claimed that he had a copy of his old passport that he
would bring in the next day. A week later, Post received a call from
a woman, claiming that a person with the exact same name sold a visa
to her daughter for $6,000 but failed to deliver. The woman was
asking for the Embassy's help to recoup her money. Working with the
RSO, the National Security Service determined that the young man was
using his visits to the ACS section to convince the woman and her
daughter that he had influence at the Embassy and could get her the
visa. During his last visit to the ACS section, he came in with the
daughter so she could see him speaking with consular officials.
Since the daughter doesn't speak English, she didn't understand the
visa fixer's conversations with our ACS staff concerning his
citizenship claim. In hindsight, his odd citizenship claim had to be
seen in that context.

ADOPTION FRAUD
--------------


14. (U) To be eligible for adoption in Armenia, a child must be
legally abandoned by all living parents through a renunciation of
parental rights, or, in the case of missing parents, found to be an
orphan by the courts. Death certificates of both parents also may
serve as evidence of a child's orphaned status. Orphaned children
become the custody of orphanages, where they are placed on a list of
children available for adoption. For the first three months on this
list, a child may be adopted only by Armenians; after three months
have elapsed, a child may be adopted by Armenians or foreigners.


15. (SBU) Corruption on the part of Armenian government officials,
adoption agencies and orphanages is a concern, and due to pervasive
document fraud, local birth and identity documents are often not
reliable. In addition to field investigations, post combats
adoption fraud by running background checks on all adoption
facilitators. In the reporting period, post conducted three field
investigations of a problematic adoption case. American citizens
considering adopting an Armenian child are encouraged to check with

YEREVAN 00000228 004 OF 007


post to find out if a facilitator is considered reputable. We have
included this information in our Adoption Flyer.


16. (SBU) Adoptions from public orphanages seem to be mostly
above-board, but those from private orphanages are often suspect.
Recent changes in Armenian adoption law have resulted in the closure
of the few private orphanages and a waiver of the former requirement
for children to be placed in orphanages prior to adoption. They may
now be adopted directly from individuals. Any such case received by
post is likely to be verified through an unannounced field
investigation. Two of the three such cases we have seen in 2007
have not met the requirements of U.S. law.


17. (SBU) Armenia is officially a signatory to the Hague Convention
on Inter-Country Adoptions. Although the Ministry of Justice -
Civil Acts Registry is formally designated the Central Authority, in
practice, that office has not yet worked out procedures including
how, when and who will issue and accept Article 5 and 16
notification letters. Post meets periodically with the various
offices involved in adoption (Ministry of Justice, Adoption
Commission, Ministry of Labor and Social Affairs) to receive updates
on Armenia's Hague Convention preparations which are very much a
work in progress.

USE OF DNA TESTING
--------------


18. (U) DNA testing in Yerevan is done remotely with Embassy panel
physicians drawing samples and then sending the samples to
accredited labs in the U.S. for analysis. A Consular Officer
witnesses the sampling, and forwards it to the U.S. lab. Results
are sent directly the Embassy via DHL, generally within three to
four weeks. In the reporting period, post conducted no DNA tests.


19. (U) Post also encounters suspected relationship fraud in
Diversity Visa and family-based Immigrant Visa cases, usually in
marriage or fiance visa cases. To date, DNA testing has not been
used in such cases. In one typical case, the petitioner and
beneficiary volunteered to submit to DNA testing of their supposed
child in common to bolster their claims of being a bona fide couple.
Where DNA testing has been employed, post is generally satisfied
with its current operational procedures.

ASYLUM AND OTHER DHS BENEFIT FRAUD
--------------


20. (SBU) Post is exposed to asylum fraud in two ways. One, through
anecdotal evidence supplied by NIV applicants whose relatives went
to the United States on non-immigrant visas and claimed asylum. When
applicants volunteer information during visa interviews on their
family member's status in the U.S. as an asylee or refugee, they
have offered all kinds of reasons to justify their relatives'
applications for asylum, including, "She couldn't find a job here"
and the ever-popular, "He got sick."


21. (SBU) The second way in which post encounters asylum fraud is
through processing of Visas 92/93 following-to-join cases. Post
assumed this task in 2007. Interviews with derivative beneficiaries
of I-730 petitions indicate questionable underlying claims for
asylum in a significant proportion of cases. In the reporting
period, our caseload (some 200 cases at any one time and some 350 to
date) has revealed serious fraud such as false relationship claims
in two cases. In these cases, post returned the petitions to the
USCIS through NVC. In some twenty other cases, where post had
indications of a fraudulent or invalid asylum claim, we issued
transportation foils for the beneficiaries as they qualified in all
other respects, and subsequently sent cables to the Department and
the USCIS Asylum Branch as per 9FAM App. 0 1207.2-5(A). Feedback
from ICE agents at ConGen Frankfurt (with jurisdiction over Armenia)
and USCIS asylum fraud officers met during a July 2008 conference on
Visas 92/93, confirms that post's cables are being followed up.


22. (U) In the reporting period, post received no reports of lost or
stolen I-551. Post processed 9 transportation letters for I-551
holders whose documents had expired, but received 3 other
applications which were denied by USCIS-Mocow, the DHS office with
jurisdiction over Armenia, for various reasons.


23. (SBU) Post occasionally sees DHS travel documents (re-entry
permits) that appear to have been issued to aliens when they were
not in the United States, usually persons who received asylum or
refugee status including their derivative family members. The

YEREVAN 00000228 005 OF 007


applications for these documents usually have been filed by
relatives and initially sent to the relatives' addresses in the
U.S., whence they are forwarded to the alien in Armenia. Often these
cases involve questions by travel document holders on how to extend
reentry permits or applications for U.S. passports for children born
to Armenian asylees/refugees in the U.S. who have spent considerable
amounts of time in Armenia since receiving such status. We refer
all such cases to the DHS/USCIS office at Embassy Moscow. A typical
case was that of a young woman who entered the U.S. as an asylee
following-to-join single daughter of her father, the principal
applicant. Even though she would have signed an affidavit
acknowledging that she would forfeit this immigration benefit if she
married before entering the U.S., she did exactly that, i.e. marry
after receiving her transportation letter, but before entering the
U.S. Moreover, once in the U.S., she promptly filed an I-130
petition for her spouse which USCIS apparently approved, failing to
notice she didn't actually qualify for derivative asylee status.

ALIEN SMUGGLING, TRAFFICKING, ORGANIZED CRIME,
TERRORIST TRAVEL
-------------- -


24. (SBU) Due to its high unemployment and significant poverty,
Armenia is a source for illegal travel. In recent years, Yerevan's
fraud unit has uncovered two large alien smuggling efforts using
approved P-3 petitions. The fraud unit's investigations resulted in
permanent Class I ineligibilities entered against each group's local
organizer. At post, any group petition is suspected of having one
or two "ringers" and consular officers must vigilantly check the
qualifications of all group applicants. Organized crime is present
in Armenia and particularly active in monopoly sectors such as fuel
and energy. Armenian organized crime has strong linkages to
U.S.-based and Russia/CIS-based organized crime groups.

DS CRIMINAL FRAUD INVESTIGATIONS
--------------


25. (U) The Consular Section maintains good working relations with
the RSO. Post has requested an ARSO/I position to strengthen post's
anti-fraud program, leverage consular anti-fraud tools to combat
organized crime links to the U.S., and ensure that both criminal
figures and fraudulent claimants are denied improper access to the
United States. The Consular Section regularly informs the RSO of
cases referred to the Police's 6th Department for Organized Crime
Combat for further investigation and prosecution. The consular
section referred one case of alien smuggling of two children who
were impostors posing as U.S. citizens. The children were traveling
with a notorious visa fixer who himself received asylum in the U.S.
after fraudulently using the refugee travel document of another
person. (Note: Post is also in possession, but hasn't yet
processed, the Visas 92 cases of the alien smuggler's spouse and
children. End Note) In this case the alien smuggler bribed Russian
border guards to let him and the children clear passport control.
The case is being actively investigated by ICE as confirmed during a
recent visit by ICE agents from ConGen Frankfurt. (Note: By
bilateral agreement since the fall of the Soviet Union, Russian
Border Guards continue to oversee border security for Armenia's
Turkish and Iranian borders, and share responsibilities with
Armenian Border Guards for international airport immigration
controls. End Note)

HOST COUNTRY PASSPORT, IDENTITY DOCUMENTS,
AND CIVIL REGISTRY
--------------


26. (SBU) Post frequently encounters fraudulent or illegally
obtained original documents, ranging from municipally-issued civil
documents to passports. Yerevan's fraud unit has identified
fraudulent documents manufactured in both Armenia and the United
States according to applicant's own statements. Local forgers are
put in contact with potential clients via word-of-mouth and
"connections" (often in Moscow),while fraudulently obtained
original documents are available for small bribes from local
municipal authorities. Original Armenian passports with altered
information reportedly can be had for several thousand U.S. dollars
at one of Armenia's over 80 passport issuing offices. Used
passports for photo-substitution reportedly cost a similar amount.
The fact that there is no centralized database which civil
registries can use facilitates document fraud.


27. (U) Armenian authorities have issued machine-readable passports
since 1995. In 2000, Armenia began issuing a new machine readable

YEREVAN 00000228 006 OF 007


passport with improved photo security measures. The 1995 passports,
which are vulnerable to photo substitutions, remain valid and with
extensions may be in circulation through 2015. In remarks made
January 18 to the press, Armenia's President noted that his
government had budgeted USD 550,000 in FY2008 to develop a bio-chip
passport system, though he gave no target date for the system's
introduction. In fact, post has facilitated the Ministry of Foreign
Affairs' cooperation with ICAO and the Bureau of Consular Affairs
(CA/PPT) in starting a biometric passport program. Post's Export
Control and related Border Security (EXBS) program also funded
purchase of a new passport printer for the Armenian MFA in the
reporting period. Post's INL office has also invested significant
sums into Armenian Border Guards' port of entry Border Management
Information Systems (BMIS) infrastructure, completing several
significant installations during this reporting period. BMIS assists
in combating irregular migration, human trafficking, and unlawful
trade in drugs and weapons, while facilitating border-crossing data
exchange between law enforcement bodies. The system contains a
database of both genuine and fraudulent identification, travel, and
security documents issued by different countries.

COOPERATION WITH HOST GOVERNMENT AUTHORITIES
--------------


28. (SBU) We normally forward cases involving fraudulent government
documents to the Armenian National Police's 6th Department, the
division tasked with fighting organized crime, and have found them
quite receptive to conducting active investigations. Our most
recent case in June 2008 involved a Visas 92 beneficiary who
presented a false marriage certificate. We know that cases are
being prosecuted from the fact that one perpetrator (an IR-5 IV
applicant) returned to request her case be processed to conclusion
after paying a fine and being lightly sentenced. As the fraud
committed wasn't material to the case and she appears to benefit
from the sentencing clause, the woman is not likely to have a visa
ineligibility. Most recently, and to post's pleasant surprise,
the National Security Service (former KGB),has proven to be very
cooperative with post on visa fraud and alien smuggling cases (see
paragraph 25). In the recent past, the NSS had been very good at
taking, but not good about giving information.


29. (SBU) Under Armenian law, forgery is punishable by a fine, one
year's "correctional labor" or up to two years in prison. Using
false documents with the intent to cross a state border is subject
to up to three years in prison. Though we had referred several
cases of false documents to the National Security Service (NSS) in
the past, no one has been charged as a result of those cases. It is
our belief that some known forgers and document dealers have
protection within the Armenian government.

AREAS OF PARTICULAR CONCERN
--------------


30. (SBU) As requested in the current Mission Strategic Plan and
previous budgeting processes, Yerevan's Consular Section continues
to see a need and benefit in having an ARSO/I position within the
section. Given high fraud and the added complexities of a far-flung
Armenian diaspora community, as well as linkages to organized crime
groups operating both in Armenia and the United States, an ARSO/I
position would contribute significantly to the Department's "Secure
Borders, Open Doors" mandate. Through extensive fieldwork and
security service liaison, an ARSO/I would be expected to better
develop our contacts at ports of entry and government and police
agencies, as well in the private sector, including airlines,
orphanages and visa facilitators. An ARSO/I would also be ideally
placed to intensify our cooperation with U.S. law enforcement
agencies working to combat international crime activity tied to
Armenia.


31. (SBU) Post receives an unusually high number of requests from
ICE attorneys for document verification or translations of visa
applications for persons applying for immigration benefits in the
U.S. This is a labor-intensive task which occupies a significant
part of our fraud investigator's time. Until recently, document
verification requests were usually channeled through the USCIS
Attache's office at Embassy Moscow. Post now receives the majority
of such requests from DRL in the Department. Requests for visa
applications usually come directly from Assistant Chief Counsels in
Los Angeles and usually end up as a subsequent request for document
verification related to an asylum application. At any one time,
post has some 30 pending investigations with an average of two new
investigations requests and five visa application requests received

YEREVAN 00000228 007 OF 007


each week. The majority of these investigations confirm that the
submitted documentation is fraudulent. Post has developed a
Microsoft Access database to track these cases and, more
importantly, quantify the resources spent on these investigations.
We believe this information would be invaluable to CA/EX to request
partial DHS/ICE funding of our FSNI's position who spends some
40-50% of his time on DHS investigations.


32. (U) Post has developed a good working relationship with the ICE
office in Los Angeles which has invited the Fraud Prevention Manager
and Fraud Investigator to make a formal presentation on fraud trends
and patterns to ICE Assistant Chief Counsels working on Armenian
asylum cases in Los Angeles in October 2008. Post has so far been
unable to fund this travel. DRL, through which ICE/USCIS channels
most of our document verification requests per standard procedure,
supports post's plans to meet up with ICE in Los Angeles. DRL has
been invaluable in acting as a broker between post and ICE in Los
Angeles in managing the latter's expectations and regulating our
investigations workload to a manageable level.

STAFFING AND TRAINING
--------------


33. (U) Embassy Yerevan's FPU consists of Consular Section Chief
Robin Busse who serves also as Fraud Prevention Manager (FPM) and a
full-time FSN fraud analyst/investigator (Armen Alaverdian). The
fraud analyst also serves as an interpreter during IV and NIV
interviewing and screens applicants for likely imposters. The FPM
attended the fraud prevention course at FSI in 2002 and has
completed the online courses PC544 - Detecting Fraudulent Documents
and PC128 - Detecting Imposters. The fraud analyst attended FSI's
fraud course for FSNs in 2003, the 2006 Fraud Conference in
Istanbul, and completed the online courses PC 544 and PC 128 as well
(as have all consular staff). Two of post's three adjudicating
officers also have taken the fraud prevention course at FSI. We are
cross-training another FSN to assist as a part-time investigator,
and our Senior NIV Assistant has also attended the FSN Fraud
Prevention Workshop in the last five years. In addition, as noted
above as an area of particular concern, both the RSO and consular
section have formally requested an ARSO/I position to assist in
combating fraud (FY09 MSP).

PENNINGTON