In response to a FOIA request submitted to Immigration and Customs Enforcement (ICE) by the End SIJS Backlog Coalition, a project of the National Immigration Project, ICE produced two documents, available below. The Coalition submitted the FOIA request after a news report about an apparent ICE memo targeting “unaccompanied alien children” (UCs). In the spring of 2025, practitioners across the United States reported that UC clients were being subjected to fear-inducing “wellness checks” by ICE enforcement agents. Here is a National Immigration Project resource on Legal Defense Plans for Unaccompanied Child Clients with Removal Orders.
The first document, a memo titled “Unaccompanied Alien Child Joint Initiative Field Implementation,” directs several agencies within DHS to launch a “joint initiative” to locate UCs who have been released to sponsors, in order to “mak[e] sure UAC’s immigration obligations are met,” and to “conduct[] investigative activities to ensure to ensure UAC are not subjected to human trafficking or other exploitation.” While the memo claims to be concerned with child safety, it in fact seems aimed at targeting UCs for immigration enforcement and investigating whether any criminal charges can be brought against them or their sponsors. It describes categories of UCs who are to be targeted, including those with final removal orders, those released to a non-blood relative sponsor, those with “arrests or egregious criminal backgrounds,” and those with “gang or terrorist ties/activities.” It concludes with a list of possible federal criminal charges to consider bringing against UC sponsors, leading with providing false or misleading information to gain sponsorship of the UC. (Perhaps as part of this initiative, on April 18, 2025, the Department of Justice issued a press release announcing the indictment of a Guatemalan man for allegedly making false statements in his application to sponsor a UC from ORR custody.)
The second document, an email dated February 10, 2025 with subject line “Unaccompanied Alien Children (UAC) Increased Coordination - Field Office Designees” appears to distribute the above policy to ICE Field Office Directors across the country, requiring each ICE Field Office to provide 1-2 officers to “participate and contribute to the effort.”