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ICE Encounter

Overview

The surveillance apparatus depends on data access from federal agencies, state databases, and private-sector brokers. These pipelines frequently bypass state privacy laws and sanctuary ordinances.


IRS-ICE Memorandum of Understanding

Agreement Details

On April 7, 2025, the IRS and ICE signed an unprecedented MOU establishing formal taxpayer data sharing.

Data Shared

  • Names
  • Last-known home addresses
  • Tax data

No Court Order Required

Data transfers occur without judicial oversight.

Legal Basis

The MOU relies on 26 U.S.C. § 6103(i)(2), permitting disclosure to agencies preparing for criminal proceedings.

Target Population

ICE requests data for individuals:

  • Facing final removal orders
  • Under investigation for 8 U.S.C. § 1253(a)(1) (willful failure to depart)

Historical Departure

The MOU marks a radical departure from decades of IRS precedent protecting:

  • Undocumented immigrants filing taxes
  • Individual Taxpayer Identification Number (ITIN) users

Implementation

August 2025 Request

ICE requested records for 1.28 million taxpayers.

IRS successfully provided addresses for approximately 47,000 individuals.

Litigation

Center for Taxpayer Rights v. IRS

Civil rights organizations and labor unions sued.

Court Rulings (Nov 2025, Feb 2026)

Federal judge in D.C. blocked further sharing:

  • IRS violated Internal Revenue Code ~42,695 times
  • Failed to verify ICE data accuracy before disclosure
  • Automated TIN Matching process improper

State DMV Access via Nlets

Nlets System

The National Law Enforcement Telecommunications System (Nlets) enables multi-state database queries.

ICE Capabilities

Through Nlets, ICE agents query state DMVs using:

  • Name and date of birth
  • Receive consolidated multi-state returns

Data Retrieved

  • Current addresses
  • Physical descriptions
  • Social Security numbers
  • Vehicle registration data

State Privacy Laws

States like New York (Green Light Law) technically block ICE's Originating Agency Identification (ORI) codes from Nlets queries.

Facial Recognition Bypass

Despite legal restrictions, ICE continues accessing DMV photos through:

  • Direct requests to state DMVs
  • Facial recognition searches against license photo databases
  • States include: Utah, Vermont, Washington

No Warrants Required

These biometric searches:

  • Are largely unregulated
  • Occur without warrants
  • Subject all state residents to surveillance

Perverse Outcome

Undocumented individuals who complied with state driving laws have their legal protections weaponized against them.


Private Sector Data Brokers

Purpose

To circumvent sanctuary laws prohibiting local police from sharing data, ICE purchases equivalent data from commercial brokers.

LexisNexis Risk Solutions

Contract Value

$22.1 million with ICE

Accurint Database

Aggregates billions of records:

  • Credit histories
  • Bankruptcy filings
  • Phone data
  • Real estate ownership

VINE Network

LexisNexis subsidiary Appriss Insights manages Victim Information and Notification Everyday (VINE).

How It Works
  1. Local jails feed incarceration/release data into VINE
  2. LexisNexis sells real-time alert data to ICE
  3. ICE agents arrest individuals upon release
Jurisdictions Affected
  • Cook County, Illinois
  • Colorado (statewide)
  • Others nationwide
Impact

ICE bypasses local non-cooperation ordinances.

Query Volume

Over a seven-month period in 2021:

ICE agents ran over 1.2 million queries through LexisNexis.

Thomson Reuters CLEAR

Contract Value

Multi-million dollars with ICE

Capabilities

CLEAR provides a "360-degree view" aggregating:

  • Utility bills
  • Financial records
  • Healthcare provider content
  • Employment data
  • Coverage: all 50 states

Why It Matters

Because immigrants must establish utilities and housing to survive, these databases provide:

  • Highly accurate location data
  • Continuously updated
  • Avoids legal scrutiny of traditional law enforcement databases

Federal Database Access

Databases ICE Can Query

Database Contents
NCIC National Crime Information Center
TECS Treasury Enforcement Communications
IDENT/HART DHS biometrics
SEVIS Student visa records
CLAIMS Immigration benefits applications
NGI FBI biometrics/criminal history

Interagency MOUs

Memoranda of Understanding govern ICE access to:

  • FBI databases
  • DEA records
  • State Department visa data
  • IRS taxpayer information

Sanctuary Law Circumvention

The Problem

State and local sanctuary laws prohibit:

  • Local police from honoring ICE detainers
  • Sharing of local jail data with ICE
  • Use of local resources for immigration enforcement

The Workaround

ICE purchases equivalent data commercially:

Prohibited Source Commercial Alternative
Local jail records LexisNexis VINE
DMV records Facial recognition requests
Utility records Thomson Reuters CLEAR
Location data Venntel/Babel Street

Effectiveness

Commercial data access renders sanctuary protections largely ineffective at the enforcement level, though they still provide important community trust benefits.


Data Security Concerns

Retention Periods

  • Commercial broker data may be retained indefinitely
  • No standardized disposal requirements
  • Multiple copies across agencies

Access Controls

  • Over 9,000 ICE agents access Vigilant ALPR
  • 1.2+ million LexisNexis queries in 7 months
  • Limited audit trails

Breach Risks

  • Massive aggregated databases attractive targets
  • Immigration-sensitive data exposure risks
  • Limited notification requirements

Implications

For Individuals

Understanding data access helps:

  1. Recognize exposure from everyday activities (utilities, taxes)
  2. Understand that sanctuary policies have commercial workarounds
  3. Assess risks of various data footprints
  4. Make informed decisions about data sharing

For Advocates

Documentation supports:

  1. Policy advocacy for commercial data restrictions
  2. FOIA requests for specific data contracts
  3. Litigation challenging data acquisition
  4. Supporting Fourth Amendment Is Not For Sale Act

For Local Officials

Understanding ICE data workarounds helps:

  1. Design more effective sanctuary policies
  2. Restrict local contributions to commercial databases
  3. Assess true scope of federal enforcement access

Related Resources