CBP’s controls over the Global Entry Program do not always prevent ineligible and potentially high-risk Global Entry members from obtaining expedited entry into the United States. This occurred because CBP officers did not always comply with policies when reviewing Global Entry applications nor do CBP’s policies sufficiently help officers
determine an applicant’s level of risk. Additionally, during the airport arrival process, CBP officers granted some Global Entry members expedited entry without verifying the authenticity of their kiosk receipts. CBP officers also did not properly respond to a breach of the Daily Security Code. These weaknesses were due to officers not following policy, as well as CBP’s insufficient verification procedures. Unless CBP officers authenticate kiosk receipts, someone could use a fake receipt to enter the United States. Finally, CBP does not effectively monitor Global Entry to ensure members continue to meet program requirements. In particular, CBP did not conduct the required number of internal audits and did not use its Self-Inspection Program effectively. CBP’s lack of adherence to its compliance program’s policies and procedures creates vulnerabilities in Global Entry by allowing potentially ineligible members to continue to participate.