DUBAI: Changes to
Procedures Since 9/11
Reviewed by: Type reviewer name here
Review Date: Type review date here
Record of Analysis
Analysis Title Dubai, UAE: Changes to Procedures Since 9/11
(Visocan, Aliu, Olson) Prior to 9/11, Dubai utilized a drop-box system for
all GCC nationals (including women and children) and any third country
nationals resident in the UAE who had been to the U.S. in the previous
five years. After 9/11, however, the drop-box system was eliminated, in
coordination with Abu Dhabi's consular section. Everyone must now
apply in person.
(Visocan, Aliu) The applicant pool here is different than that in Abu Dhabi
in that it is much more diverse. The Dubai consulate serves a very large
TCN population, seeing perhaps 50-60 different nationalities per month.
The largest TCN population consists of Indians and Pakistanis, followed
by Egyptians, Jordanians, Yemenis, Filipinos, and Sir Lankans. The
consulate also sees a significant number of Iranian applicants. Dubai is
the State Department's "window on Iran."
(Aliu) Each day in the late afternoon, Ms. Visocan reviews the day's
issuances and refusals.
Refusal Rates
(Documents, Visocan, Aliu) Dubai's refusal rate for all nationalities for
the period 1 January 2002 to 30 April 2002 is approximately 47%. The
refusal rate for the same period in 2001 was about 41%.
(Documents, Visocan, Aliu) From January to April 2001, there were 975
UAE nationals who applied for visas; they had a refusal rate of 1.5%. From
January to April 2002, there were only approximately 265 UAE nationals
who applied for visas; they showed a refusal rate of 24%.
Workload
(Visocan, Aliu) There are approximately 180 visa applicants who are
interviewed each day. Mr. Aliu stated that the most he himself would
interview in one day is 75 applicants. The number varies depending on
how sticky the case is or if there are lots of Condors. However, Ms.
Visocan noted that during the first two months of 2002, the Dubai consular
officers only had an average of 60-80 applicants coming in each day.
CLASS
(Visocan) Although the CLASS database is not perfect, it has improved
quite a bit as a result of the Department's efforts to clean up the
information it contains. Previously, there had been many FNU entries
(i.e., First Name Unknown) and many records had lacked date of birth
information. Although the system is now better, CLASS still has difficulty
running Arabic names, with the result that consular officers often try
running one name several different ways. However, consular officers here
in Dubai have not seen the same phenomenon of altered place of birth (in
the passports of naturalized UAE citizens) as they have in Abu Dhabi.1
(Olson) Mr. Olson reported that he has not gotten any feedback on the
9/11 hyacker whose visa was issued in Dubai (Marwan al-Shehhi), i.e.,
whether there was any derogatory information on him in CLASS. The
events of 9/11 highlighted CLASS as a line of defense and everyone has
been surprised at how little information is in the database.
(Aliu) Mr. Aliu said that CLASS must be updated with a wide range of
information; otherwise, the information is worthless. It is difficult for the
consular officer to assess the applicants' documentation, e.g., passport,
photos, travel history, without getting a bigger clue on the individual from
CLASS. Consular officers must also make sure that they are
knowledgeable about what information is in CLASS, as this will help them
assess the hits they get. On this note, Mr. Aliu was under the impression
that in order for a CLASS entry to be considered a "hit," it had to be an
exact match with the applicant.2
' The only problem resembling this that they have encountered in Dubai has to do with the Three
Islands Dispute between the UAE and Iran. If an applicant's birthplace was a particular disputed
location (Mogud) on one of these islands, Iranians list place of birth as Iran, while UAE nationals list it
as UAE.
2On the morning of 5/8/02, with GAO observing, Mr. Aliu ran a CLASS check on an applicant. One
record showed an entry with the same last name as the applicant, with the first names being
(Visocan, Aliu) CLASS is the first line of defense, but is only as good as
the information that is put into it. Consular officers do not start an
interview without conducting a CLASS namecheck. If the system happens
to be down, then they will not conduct any interviews or else they will
simply refuse applicants. Consular officers are no longer allowed to issue
visas using the CLASS back-up system. However, there are few problems
with CLASS being down.
(Ayervais) Ms. Ayervais primarily handles Lranian visa applicants. Her
complaint centered on the fact that much of the information in CLASS on
Iranians is outdated. In March 2000, the U.S. government relaxed
sanctions against Iran in four major areas (including caviar, fruits and
carpets). Within the past year, the U.S. government has also relaxed some
agricultural sanctions. Any person with a sanctions hit is entered in
CLASS as a PSA and many P3A records have not been updated since the
relaxing of sanctions. Ms. Ayervais felt that having to deal with such
outdated sanctions hits prevented her from focusing as well on serious
security threats. In addition, there were many Iranian in the early 1990's
who were in the U.S. as diplomats or students. These persons are still
flagged in the CLASS system. When Ms. Ayervais reviews the record by
contacting INS, she may find that the file is closed but nobody updated
CLASS. In Ms. Ayervais' opinion, having to examine the reasons for these
hits detracts from her ability to do her job properly.
(Ayervais, observation) Ms. Ayervais also noted that Iranians often
become very upset and emotional when they are denied visas. She said
that some Iranians will begin crying in front of her, while others will argue
V with her. During our observation of interviews, we noticed Ms. Ayervais
simply walking away from the interview window, after explaining the
denial, and ignoring the applicant. The applicant would eventually leave
and Ms. Ayervais could return to the window and call up the next
applicant for an interview
"DS-157
(Aliu) Mr. Abu noted that the DS-157 contains useful information for
filling out the Condor cable. He suggested, however, that the DS-157
include a question on where and when the applicant had been issued
previous U.S. visas and what their port of entry into the U.S. had been. He
himself uses the DS-157 for the applicant's previous travel history.
Condors & SAOs
(Visocan, Aliu, Olson) Although Dubai is rigorously following the post-
9/11 security procedures, consular officers do not feel that they can
comment on the utility of the new procedures for screening out terrorists.
This is simply because Dubai hardly ever hears back from Washington on
any of the Condors it sends in. Dubai has only received one response,
which came in recently. This was a "Visa 7," telling them to place a hold
on the visa application. Mr. Aliu said that, although the new procedures
Muhammed and Mohammed. No date of birth was given. Mr. Aliu felt that the applicant was not the
same person listed in CLASS because the biographical data was not exactly the same.
are an added burden (applying to those who would have been drop-box
cases prior to 9/11), he feels safer knowing that agencies in Washington
check to make sure that it's safe to issue these visas. Mr. Olson echoed
this, saying that although they hear many complaints about the new
security requirements, e.g., from U.S. businessmen or U.S. medical
facilities, the Dubai consulate believes that the procedures are workable
and worthwhile as long as Washington is following through at its end.
(Aliu) Mr. Aliu stated that for those applicants with a "00" hit, he would
not send in an SAO since he was probably just going to refuse them
anyway. Once he sees that the person has a "00" hit, Mr. Aliu said that he
screens that applicant harder. He would only send in an SAO on that
applicant if he knew that Washington wanted information on him/her.
(Olson, Visocan) Mr. Olson stated that more guidance from State would
be useful, especially in regard to Iranian applicants (who comprise 30% of
Dubai's workload). Dubai would like to get more guidance on categories
of people who we wouldn't want traveling at all. Ms. Visocan said that,
while the technology alert list is a guide for dealing with persons engaged
in sensitive issues, there are uncertainties over what should be considered
legitimate travel to the U.S. For example, should Iranian applicants
engaged in atomic energy or biotechnology matters be brought to the U.S.
to 'be on our side,' or should the Dubai consulate just refuse them on
214(b) grounds?
(Royden, Visocan, Pandya) For Iranian applicants, the Condor SAO has
superseded the Eagle SAO. Dubai now writes Condor, rather than Eagle,
on the SAOs it sends back to Washington. The only Eagles Dubai now
sends are for Iranian women.
(Pandya) Ms. Pandya types up and sends out, with the consular officers'
approval, the Condor cables and other SAOs. She noted that it generally
takes 6-8 weeks to get a response on a Donkey. Ms. Pandya will send
follow-ups as needed to Washington for Donkeys that have not received a
response. There have been only a few negative responses for Donkeys.
(Cables, guidance form) We collected two Visa Donkey cables, dated 12
November 2001 and 13 March 2002, which demonstrate that the Dubai
consulate is sending in SAOs on persons who do not necessarily require
one, "due to heightened security concerns after September 11." In
addition, we collected one form that contains guidance for overlapping
security procedures. Post wrote this up in an attempt to clarify the
overlapping pre- and post-9/11 security requirements.3
Visas Viper Committees
(Zupan) The RSO noted that it is easy for Dubai to hold Visas Viper
meetings because there are only 4 agencies that sit on it, namely, the RSO,
3Example of guidance written by post: "Applicants that fall under guidelines for Visas Donkey and
also Condor, a Donkey Condor cable has to be sent, e.g., for Visas Condor cases that have "00"
CLASS hits or Iranian government employees who are also Condor cases. Dept's response is required
prior to issuance for Donkey Condor cases."
' As an example, Ms. Royden said that she'd interviewed a young male Chinese applicant with a
chemical engineering degree. He generally met the visa criteria but she was uncertain about the case
and so denied him. In light of 9/11, she thinks this use of 214(b) is justified and understandable.
sAs an example, Ms. Visocan noted that her predecessor in the Consul position in Dubai had been
issuing visas to any applicant who claimed to be coming to the U.S. to take the CPA exam.
6As an example of this, Mr. Aliu said that he will refuse an applicant who cannot tell him how much
money he has in his bank account.
test If he returns, he can get a visa for longer validity the next time he
applies.