How the United States Is Using Third Countries to Expand Immigration Control

When the U.S. government removed Elvis Rodriguez Venturas to Liberia in August 2026, it was the first he had ever heard of the country.1 The Honduran national had lived in the United States without authorization for years and left behind four children, two of them U.S. citizens.2 Although U.S. authorities had ordered his removal, an immigration court had determined that he faced a risk of torture if returned to Honduras. Instead, the United States transferred him and 14 others to the West African country.

His case is not an isolated one. Since the Trump administration returned to office in January 2025, third-country deportations are less of an outlier than they used to be. The federal government has rapidly expanded the signing of third-country removal agreements, removing more than 25,000 noncitizens to at least 30 countries other than those of their nationality or habitual residence as of mid-October,3 about 80 percent of whom were deported to Mexico.4 The U.S. Supreme Court has agreed to hear a case on the policy after a lower court temporarily blocked the removals in September.5

Third-country removals in and of themselves are not a new feature of U.S. immigration policy, but the scale, geographic reach, and diversity of diplomatic tools used for these repatriations during the second Trump term are unprecedented.

To facilitate the removals, the administration has struck arrangements with at least 35 governments worldwide; several have yet to receive deportees (see Figure 1). This does not include countries that have been used as layovers for U.S. removals to an individual’s place of origin, such as Egypt, Kuwait, Poland, and Qatar. The third-country deportation agreements that are publicly available make reference to upholding international law such as the Convention Against Torture and the principle of nonrefoulement, according to research by the authors, but texts for six of these deals—including those with Mexico, Moldova, and Uzbekistan—have not been disclosed, leaving those commitments unclear.

The arrangements range from formal international instruments to considerably less formal ones, such as written diplomatic notes. Receiving countries also impose varying conditions on whom and how many people they will accept. Some limit transfers by nationality or other criteria, while others establish numerical caps or retain discretion to reject individuals, for example based on having a criminal record. While the U.S. government had reportedly promised more than $410 million as part of 31 of the agreements,6 the financial arrangements vary, with some including direct payments or other U.S. support and others lacking publicly identifiable transfers. The consequences for deportees are similarly varied and unclear. Depending on the receiving country and the terms of the arrangement, individuals may face detention or other restrictions on their freedom of movement. Some may remain in the third country temporarily before being transferred onward to their country of origin, be permitted to stay in the receiving country, or in some cases seek asylum or another form of international protection.

"Third-country deportations are thus both a way to remove individuals who might otherwise not be removable and part of a broader strategy to create a climate of fear."

The Trump administration’s arrangements are part of a broader effort to strengthen immigration control and deter unauthorized immigration. It has repeatedly presented the ability to carry out removals as essential to restoring control over immigration, while its public messaging has starkly emphasized that people unlawfully present in the United States face arrest, deportation, and financial penalties. However, some individuals cannot be deported to their country of origin: They have been determined to be at risk of serious harm in that country and so cannot legally be removed there, or in other cases, the origin country refuses or is unable to accept them.

Third-country deportations are thus both a way to remove individuals who might otherwise not be removable and part of a broader strategy to create a climate of fear to urge unauthorized immigrants to leave the country voluntarily and dissuade new irregular arrivals. In the words of one unnamed administration official, “The point is to scare people.”7

Legal Obligations

Yet while U.S. authorities seek to control migration, execute removal orders, and manage demands on the removal and asylum systems, they also remain subject to domestic and international legal obligations that constrain where and under what circumstances deportations can be carried out. Some deportees and their lawyers allege that authorities have not lived up to these obligations; some individuals have reportedly been forced back to countries where they face risks of persecution or torture, and others claim to have been subjected to beatings and indefinite detention in the host country.

The rapid expansion of these arrangements raises a fundamental question: Can the United States use third countries to enforce removal orders without exposing deportees to the very harms its legal obligations are meant to prevent? To address this question, this article traces the evolving use of third countries in U.S. immigration policy and examines the level of safeguards and oversight accompanying deportation arrangements negotiated during the second Trump term.

The Evolving Use of Third Countries, from Asylum to Deportations

The Trump administration’s use of third-country deportations did not emerge from nowhere; they are the culmination of a broader evolution in U.S. policy in which responsibility for migration control and humanitarian protection has increasingly been shared with, shifted to, or exercised by foreign states.

Earlier measures largely operated as or before individuals arrived at the border, using transit countries to deter irregular arrivals, contain migrants outside U.S. territory, or offload responsibility for asylum and other forms of protection. The emerging third-country removal system instead reaches the broader population of noncitizens already in the United States who are subject to removal. Third countries are thus no longer used solely to regulate access to U.S. territory and protection, but increasingly as destinations for removal.

Third-Country Policies and Practices

In 2002, the United States entered its first bilateral third-country deal: the U.S.-Canada Safe Third Country Agreement (STCA). The agreement allows both countries to return asylum seekers of other nationalities so their claim can be assessed by whichever country they entered first. So, a non-Canadian asylum seeker who crossed into the United States from Canada can be returned to Canada unless they qualify for exceptional treatment as an unaccompanied minor or for family reunification.8

The use of third countries for asylum evolved during the first Trump term, with the signing of Asylum Cooperative Agreements (ACA) with El Salvador, Guatemala, and Honduras.9 Under the ACA agreements, the U.S. government sought to transfer certain asylum seekers to these countries, where their claims for protection would be considered. In exchange for receiving asylum seekers, the United States agreed to strengthen these countries’ institutional capacities. Although the agreements did not specify how this strengthening was to occur, the State Department in April 2020 announced $258 million in foreign assistance for the three countries.10 Part of the funding was to be used to “complement existing security plans for each government that will assist them as they continue to build stronger asylum systems.”11

Only the Guatemala ACA was implemented, in part because the outbreak of the COVID-19 pandemic chilled global movement and introduced new variables. Guatemala received more than 930 asylum seekers12—all from El Salvador and Honduras—before transfers were suspended in 2020, during the pandemic.13 The Biden administration terminated all three agreements when it entered office in 2021.14

Beyond the ACAs, first-term Trump administration policies including the Migrant Protection Protocols (also known as the “Remain in Mexico” program) similarly relied on another country to play a role in asylum processing, although in a different manner. This policy required certain asylum applicants to stay in Mexico while awaiting the conclusion of their immigration court case, allowing temporary entry only for the duration of their court hearings in the United States.

Under the pandemic-era Title 42, the U.S. public health policy used to expel unauthorized border arrivals, Mexico accepted Guatemalans, Hondurans, and Salvadorans who had been caught crossing into the United States irregularly. In 2022, Mexico also agreed to receive Venezuelans expelled under Title 42, while the Biden administration established a humanitarian parole process for Venezuelans, allowing those arriving via air to enter and, if they chose, later apply for asylum. The arrangement linked Mexico’s cooperation on migration enforcement to expanded lawful migration opportunities, including additional H-2B temporary nonagricultural worker visas.15 This model expanded in January 2023: As the Biden administration broadened the parole program to include nationals from Cuba, Haiti, and Nicaragua (collectively known as the CHNV process), Mexico agreed to accept up to 30,000 of these countries’ nationals per month being expelled under Title 42.16

After the lifting of Title 42 in May 2023, the Circumvention of Lawful Pathways rule implemented by the Biden administration restricted access to asylum for individuals who arrived between official border crossings and had not applied for protection in a transit country. While Mexico continued accepting some third-country deportees, this effectively used a federal regulation—not a bilateral agreement—to externalize asylum. The restriction did not apply to people who had made appointments at a port of entry with the CBP One app, CHNV beneficiaries, Mexican nationals, unaccompanied minors, and individuals in “exceptionally compelling circumstances.”17 The rule was challenged in court and, in May 2026, struck down by a federal district court in California.18

Upon returning to office, the Trump administration terminated the CHNV program and use of the CBP One app, but Mexico continued accepting third-country nationals. This continuity masked a broader change: Whereas previous policies enlisted third countries to contain migration or host migrants while they sought protection (either in the United States or the third country), the Trump administration’s expanded third-country arrangements use countries as destinations for executing U.S. removal orders, including of individuals who had not sought asylum. In February 2025, U.S. authorities started deporting third-country nationals to Costa Rica, although terms for the agreement were not formalized until weeks later.19 Dozens of similar arrangements followed.

Raising Fear

The impact of third-country deportations extends well beyond the number of people actually transferred. The Trump administration has made deterrence and self-departure—or “self-deportation”—central to its broader immigration policy. Deportations to third countries reinforce that strategy, signaling to deportable immigrants that remaining in the United States could lead to them being sent to a faraway country with which they have no previous connection, and where their life will be difficult. The administration has publicly presented the destinations as part of its deterrence message. In September 2025, a DHS spokesperson warned that people who entered the United States illegally “could end up in Eswatini, Uganda, South Sudan, or CECOT,” referring to El Salvador’s Terrorism Confinement Center, explicitly invoking third-country destinations as a consequence for unauthorized immigration.20

For individuals facing removal, the uncertainty is multidimensional: They may not know whether they will be detained, can reunite with their families, or will eventually be sent to another country. The threat of such transfers may therefore serve as a deterrent in its own right, encouraging noncitizens already in the United States to leave voluntarily while discouraging prospective migrants from attempting to enter without authorization.21

Rights Concerns

The fear of being sent to an unfamiliar country where one’s safety and rights may be at risk is not merely hypothetical. As the experiences of some deportees illustrate, third-country removals can expose individuals to detention, mistreatment, and other serious harms. These risks raise important questions about the procedural safeguards accompanying removals, particularly given the United States’ obligations under domestic and international law.

March 2025 guidance from the Department of Homeland Security (DHS) on third-country removals, which applies to individuals with final removal orders not in ongoing proceedings where they can raise claims for withholding of removal or protection under the Convention Against Torture, establishes two different procedures, depending on whether the proposed receiving country has provided diplomatic assurances that deportees will not face persecution or torture.22 The guidance itself does not identify the countries from which such assurances had been obtained. Where diplomatic assurances have been provided that the State Department considers credible, DHS may remove the individual “without the need for further procedures.” Otherwise, the individual receives notice of the destination but authorities are not to ask whether the person fears removal there; a screening is triggered if the individual affirmatively expresses such a fear.

In the case D.V.D. v. DHS, the U.S. Court of Appeals for the First Circuit in September 2026 determined the policy did not provide adequate safeguards and ordered new due-process protections, although the Supreme Court allowed the removals to continue while it considered the case.23 Lower courts have concluded the policy does not provide adequate protection against erroneous removals, including because individualized risks may be impossible to meaningfully assess without the deportee’s input. Supreme Court oral arguments in the case are scheduled for December. Separately, a team of UN human-rights experts have said the removals “are triggering a cascade of human-rights violations” and called for them to end.24

The administration has maintained that its arrangements protect against the risk of torture and other ill treatment. These protections vary across agreements. In some cases, receiving governments have provided diplomatic assurances concerning the treatment of deportees, including commitments related to persecution, torture, or onward removal. Other arrangements contain provisions referring more broadly to compliance with international human-rights obligations. Of the 35 third-country arrangements reviewed by the authors, 29 contain language concerning compliance with international legal obligations (see Table 1). The strength and specificity of these provisions vary: Some explicitly reference the 1951 Refugee Convention, its 1967 Protocol, or the 1985 Convention Against Torture; others provide assurances that transferred individuals will not face persecution or torture. Some go further to address the possibility of onward removal, affirming that individuals will not subsequently be sent to another country where they would face such risks.

Yet these formal safeguards coexist with significant concerns about conditions in receiving countries. Of the 29 arrangements with public text, 22 were with countries identified by the State Department as having credible reports of significant human-rights issues.25 This does not mean these countries are necessarily unsafe for every deportee or that the safeguards are meaningless; the State Department’s country reports document human-rights conditions generally, rather than make legal determinations about safety for removal, and a government may also credibly commit to particular treatment of deportees despite broader human-rights problems. But it raises questions about how the U.S. government determines an assurance is credible, particularly when its own assessments identify practices or conditions potentially relevant to the risks facing deportees.

Where third-country deportation agreements involve U.S. foreign assistance, financial reporting, oversight, and human-rights vetting requirements may provide additional avenues for scrutiny. Some publicly disclosed agreements also contain procedural safeguards and implementation requirements. For example, the U.S.-Liberia agreement that allowed the transfer of Elvis Rodriguez Ventura requires both countries to develop and sign operating procedures before transfers can begin,26 although such procedures have not been publicly disclosed so it remains unclear whether they have been adopted. While the agreement does not explicitly commit the United States to providing financial assistance, the State Department disbursed $5 million to Liberia in January 2026 for migration management and capacity-building activities.27 Separately, U.S. law requires that foreign governments identify security forces receiving assistance at least 30 days in advance so Washington can vet their human-rights records.

Lack of Monitoring and Susceptibility to Harms

Despite these contractual provisions and oversight requirements, their effectiveness in practice remains uncertain. Of the approximately $410 million allocated to implement third-country deportation arrangements during the first 20 months of the second Trump term, $81 million was designated for direct payments to 13 foreign governments, $178.6 million for the International Organization for Migration (IOM), and $123.8 million for the UN High Commissioner for Refugees (UNHCR).28

A February 2026 report from Senate Foreign Relations Committee Democrats alleged substantial deficiencies in monitoring how the governments of El Salvador, Eswatini, Equatorial Guinea, Palau, and Rwanda were using the more than $32 million sent for third-country deportation arrangements.29 Furthermore, as of January 2026, more than 80 percent of migrants sent to third countries under arrangements involving U.S. payments had subsequently returned to their countries of origin or were in the process of doing so, according to the report. In some cases, the United States first paid for removal to the third country and subsequently for onward transportation to the country of origin.

More consequentially, the Senate Democrats’ report found no evidence that the State Department was systematically monitoring receiving countries’ compliance with assurances and reported that U.S. officials had, in at least one case, been instructed not to follow up on deportees’ treatment.30 Many activists, analysts, and others were for instance worried about the fate of deportees sent to El Salvador’s notorious CECOT, given that the State Department had previously documented allegations of torture and other cruel or degrading treatment, physical abuse, inadequate medical care, and harsh and life-threatening conditions in Salvadoran detention facilities.31 Legal scholars and human-rights organizations have argued that transfers to such conditions may violate the Convention Against Torture, which prohibits transferring a person to a place where substantial grounds exist for believing they would face torture.32 Responding to the report, the White House defended the removals as lawful efforts to “carry out the largest mass deportation campaign of criminal illegal aliens in history,” but did not address the findings concerning monitoring or compliance with international legal obligations.

"Some deportees have allegedly been returned to countries where they may face serious harms. "

Another risk is so-called chain refoulement.33 Refoulement is the legal term for returning someone to a country where they might face persecution, torture, or other serious harms. Chain refoulement occurs when a person is transferred through one or more intermediary countries before ultimately being returned to a country where they face such risks. For example, the United States might deport an individual to country B, which subsequently removes them to country C, where they face persecution or torture. Some third-country deportation agreements explicitly include commitments to respect the principle of nonrefoulement. Under the terms of the U.S.-Liberia agreement,34 for instance, Liberian authorities committed not to return individuals transferred under the arrangement, including Rodriguez Ventura, to a country where they could face persecution or torture.35

Despite such assurances, some deportees have allegedly been returned to countries where they may face serious harms. Lawyers representing men deported to Ghana stated that their clients were subsequently removed to their countries of origin where they were at risk of persecution or torture.36 Although the Ghanaian government provided diplomatic assurances before transfer, U.S. officials have acknowledged they made no additional efforts to prevent deportees from being sent onward.37 Elsewhere, Venezuelans who had been transferred to El Salvador were subsequently returned to Venezuela.38

Balancing Deportations with Protection

The expansion of third-country deportations has aggravated the tension between the U.S. government’s interest in implementing removal orders and its obligations to protect individuals from persecution and torture. On their face, third-country removals promise to resolve this tension by allowing U.S. authorities to deport people who would either be unsafe in their origin countries or whose governments will not take them. The March 2025 DHS guidance attempts to thread this needle partly using diplomatic assurances about host countries’ treatment of third-country nationals. However, U.S. officials have acknowledged they do not systematically monitor compliance with these assurances and, according to the Senate Foreign Relations Committee minority report, in at least one unnamed receiving country had been instructed not to follow up on deportees’ treatment.39

Other governments have confronted similar questions about how to assess safety and monitor compliance when transferring migrants or asylum seekers to third countries, although these policies differ in important respects from the current U.S. system. The United Kingdom’s planned relocation arrangement with Rwanda, which faced significant legal challenges and was ultimately abandoned, would have established an independent committee with broad access to monitor compliance throughout the transfer process, including individuals’ treatment after relocation, and created a confidential complaints mechanism.40 The arrangement would have also prohibited onward removal from Rwanda, except back to the United Kingdom or where an individual voluntarily chose to leave.

EU asylum rules provide another model for assessing whether a third country is safe, requiring safety assessments that draw from multiple sources.41 The rules also incorporate protection against refoulement and provide for consideration of whether a third country is safe in an applicant’s individual circumstances.

These examples point to alternative models for third-country agreements, which go beyond relying primarily on human-rights language or diplomatic assurances. Additional layers could include assessing receiving countries against predetermined protection criteria using information from multiple independent sources; evaluating their capacity and record of providing protection in practice; allowing country-level assessments to be reconsidered where conditions change; conducting individualized assessments where a destination may be unsafe for a particular person; and establishing independent monitoring after transfer. Such mechanisms would make the selection of third-country partners separate from their willingness to accept deportees.

As U.S. third-country deportations have become more common, questions about the balance with protecting rights have grown increasingly consequential. The question is not whether officials can find another government willing to receive a deportee, but whether the individual’s safety can be guaranteed.

Research for this article was supported by the Andrew Carnegie Foundation (Securitization without Security: How Migration is Shaping the Global Order, Grant reference no. G-PS-24–61830).

Sources

Acquah, Edward, Wilson McMakin, and Rebecca Santana. 2025. Immigrants Deported from U.S. to Ghana Are Sent Home, Where Lawyers Say Some Could Face Torture. Associated Press, September 15, 2025.

Barr, Luke. 2026. Removal of Migrants to 3rd Countries Is an “Essential Public Safety Tool,” DHS Lawyer Says. ABC News, September 23, 2026.

BeMiller, David S. 2023. Safe Third Country Agreement with Canada and Additional Protocols Field Guidance. Memo from the Chief of Law Enforcement Operations Directorate for All Northern Border Chief Patrol Agents, U.S. Customs and Border Protection (CBP), March 24, 2023.

Blinken, Anthony J. 2011. Suspending and Terminating with the Governments El Salvador, Guatemala, and Honduras. U.S. State Department, February 6, 2021.

Center for Gender and Refugee Studies. N.d. East Bay Sanctuary Covenant v. Trump. Accessed September 25, 2026.

Cunningham, Kally. 2026. Legal Lipstick on Extraordinary Rendition: A Legal Analysis of U.S. Counterterrorism Tactics Recast as Third Country Deportation. Charles University in Prague Law Working Paper Series 5.

European Parliament and Council of the European Union. 2024. Regulation (EU) 2024/1348 of the European Parliament and of the Council of 14 May 2024 Establishing a Common Procedure for International Protection in the Union and Repealing Directive 2013/32/EU. Official Journal of the European Union, May 22, 2024.

European Union. 2024. Consolidated Text: Regulation (EU) 2024/1348 of the European Parliament and of the Council of 14 May 2024 Establishing a Common Procedure for International Protection in the Union and Repealing Directive 2013/32/EU. May 14, 2024.

Freier, Luisa Feline, Eleni Karageorgiou, and Kate Ogg. 2021. The Evolution of Safe Third Country Law and Practice. In The Oxford Handbook of International Refugee Law, eds. Cathryn Costello, Michelle Foster, and Jane McAdam. Oxford, UK: Oxford University Press.

Fuscoe, Grace et al. 2020. Dead Ends: No Path to Protection for Asylum Seekers Under the Guatemala Asylum Cooperative Agreement. Washington, DC: Georgetown Law Human Rights Institute.

Human Rights First. 2026. ICE Flight Monitor Interactive Dashboard. Updated August 31, 2026.

Ingber, Rebecca and Scott Roehm. 2025. The Trump Administration’s Recent Removals to El Salvador Violate the Prohibition on Transfer to Torture. Just Security, March 20, 2025.

James, Vanessa. 2026. Jamaica Signs MOU with U.S. to Transition Third Country Nationals. Jamaica Information Service, June 18, 2026.

Kandel, William A., Audrey Singer, and Hillel R. Smith. 2026. Immigration Removals to Third Countries. Washington, DC: Congressional Research Service.

Martín Gil, Ana. 2025. Managing Migration through Foreign Aid in Mexico and Central America: The Role of U.S. Conditionality on Mexico’s Migration Policies. Journal of Immigrant & Refugee Studies 23 (1): 147-62.

Martínez, Gustavo. 2025. Canciller Revela Que Acuerdo Con EE.UU. Para Recibir Migrantes No Fue Escrito. Diario Extra, March 19, 2025.

Montoya-Galvez, Camilo. 2026. Latin American Migrants Deported by ICE to West Africa Describe Being Stranded "On the Other Side of the World. CBS News, September 15, 2026.

---. 2026. Liberia Receives First Group of “Third Country” Deportees from U.S., Officials Say. CBS News, August 20, 2026.

---. 2026. Migrants on Being Sent to Place with No Ties. CBS News, September 29, 2026.

Montoya-Galvez, Camilo and Annabelle Hanflig. 2026. U.S. Deports Migrants from Afghanistan, Iran, Other Countries to Violence-Torn Central African Republic. CBS News, June 13, 2026.

Myers Jr., John. 2026. Jamaica Begins Receiving Third-Country Deportees Under Controversial U.S. Agreement. Associated Press, October 13, 2026.

Nakamura, David and Adam Taylor. 2026. How Trump Turned a Refugee Bureau into a $410 Million Deportation Operation. The Washington Post, September 21, 2026.

National Immigrant Justice Center. 2026. EBSC v. Trump: An Explainer for Advocates on Vacatur of the Circumvention of Lawful Pathways Rule. May 19, 2026.

National Immigration Law Center. 2025. Tracking the CECOT Disappearances. August 19, 2025.

Ngo, Madeleine, Hamed Aleaziz, and Zolan Kanno-Youngs. 2026. U.S. Agreed to Pay Liberia $5 Million in Connection with Deportees, Documents Say. The New York Times, August 21, 2026.

Noem, Kristi. 2025. Guidance Regarding Third Country Removals. Memo from the Secretary of Homeland Security to Kika Scott, Senior Official Performing the Duties of the Director, U.S. Citizenship and Immigration Services (USCIS); Pete R. Flores, Senior Official Performing the Duties of the Commissioner, U.S. Customs and Border Protection (CBP); and Todd Lyons, Acting Director, U.S. Immigration and Customs Enforcement (ICE). March 30, 2025.

Pompeo, Michael R. 2020. United States Continues U.S. Foreign Assistance for El Salvador, Guatemala, and Honduras. U.S. State Department, April 13, 2020.

Rajagopalan, Megha and Pranav Baskar. 2026. A Central African Hotel Has Become a Nightmare Prison for U.S. Deportees. The New York Times, September 18, 2026.

Ruiz Soto, Ariel G. 2026. U.S. Third-Country Deportation Agreements Are More About Fear than Numbers. Migration Policy Institute (MPI) commentary, March 2026.

Schacher, Yael, Rachel Schmidtke, and Ariana Sawyer. 2020. Deportation with a Layover: Failure of Protection under the U.S.-Guatemala Asylum Cooperative Agreement. Washington, DC and New York: Refugees International and Human Rights Watch.

Schmidtke, Rachel and Yael Schacher. 2026. Protection, Not Concession: Mexico’s Responsibility to Third Country Nationals Deported by the United States. Washington, DC: Refugees International.

Schwartz, Mattathias. 2026. Appeals Court Restricts Trump Administration Deportation Effort. The New York Times, September 18, 2026.

Singer, Audrey, Clare Ribando Seelke, and Jill H. Wilson. 2022. New Immigration Policies Related to Venezuelan Migrants. Washington, DC: Congressional Research Service.

St. Juste, Quinn. 2026. Saint Lucia Announces Non-Binding U.S. Deportee Agreement. St. Lucia Times, January 12, 2026.

Third Country Deportation Watch. 2026. Banished by Bargain: Third Country Deportation Watch. Updated September 2026.

UK Government. 2024. Monitoring Committee Terms of Reference. January 11, 2024.

UK Migration and Economic Development Partnership (MEDP). 2023. MEDP Monitoring Committee Monitoring Plan Proposal. London: UK Home Office.

UN Office of the High Commissioner for Human Rights (OHCHR). 2026. U.S. Migration Externalization Scheme Mires Over 35 Other States, Triggering Cascade of Human Rights Violations including Torture: Human Rights Experts. Press release, September 28, 2026.

U.S. Citizenship and Immigration Services (USCIS) and Executive Office for Immigration Review (EOIR). 2019. Implementing Bilateral and Multilateral Asylum Cooperative Agreements Under the Immigration and Nationality Act. Federal Register 84, no. 223 (November 19, 2019): 63994-4011.

U.S. Department of Homeland Security (DHS). 2019. Agreement between the Government of the United States of America and the Government of the Republic of Guatemala on Cooperation in the Examination of Protection Claims. Federal Register 84, no. 224 (November 20, 2019): 64095-99.

---. 2023. Fact Sheet: Circumvention of Lawful Pathways Final Rule. May 11, 2023.

---. 2025. ICE Lodges Detainer for Depraved Criminal Illegal Alien from Cuba Charged with Murder in Beheading of Victim with a Machete in Dallas. Press release, September 12, 2025.

U.S. Embassy San Salvador. 2023. DHS Continues to Prepare for End of Title 42. Press release, January 5, 2023.

U.S. Government Accountability Office (GAO). 2021. Northern Triangle of Central America: The 2019 Suspension and Reprogramming of U.S. Funding Adversely Affected Assistance Projects. Washington, DC: GAO.

U.S. Mission to the UN Agencies in Rome. 2020. U.S. to Provide $258 Million in Aid for Northern Central America. April 23, 2020.

U.S. Senate Committee on Foreign Relations. 2025. Nomination Hearing. December 11, 2025.

U.S. Senate Committee on Foreign Relations, Democratic Staff. 2021. Cruelty, Coercion, and Legal Contortions: The Trump Administration’s Unsafe Asylum Cooperative Agreements with Guatemala, Honduras, and El Salvador. Washington, DC: U.S. Senate Committee on Foreign Relations.

---. 2026. At What Cost? Inside the Trump Administration’s Secret Deportation Deals. Washington, DC: U.S. Senate Committee on Foreign Relations.

U.S. State Department. 2024. 2023 Country Reports on Human Rights Practices: El Salvador. Washington, DC: U.S. State Department.

---. 2025. 2024 Country Reports on Human Rights Practices. August 12, 2025.

---. 2025. Agreement Between the Government of the United States of America and the Government of the Republic of Liberia to Cooperate in the Examination of Protection Claims: Exchange of Notes at Monrovia September 10, 2025, Entered into Force September 10, 2025 Washington, DC: U.S. State Department.

---. 2026. Qualifying Non-Binding Instruments: Case Act Reporting. Updated September 9, 2026.

U.T. v Barr. 2020. Brief of Amicus Curiae National Citizenship and Immigration Services Council 119 in Support of Plaintiffs' Motion for Summary Judgment and Permanent Injunction. Case No. 1:20-cv-00116 (EGS), U.S. District Court of the District of Columbia. March 6, 2020.

Whitehurst, Lindsay. 2026. Supreme Court Lets Quick Deportations to Third Countries Resume for Now While It Weighs Trump Policy. Associated Press, September 29, 2026.

---. 2026. Trump Administration Turns to Supreme Court as Third-Country Deportations Are Thrown into Question. Associated Press, September 24, 2026.

Zengerle, Patricia. 2026. Democrats Say Trump’s Foreign Deportation Deals Cost Taxpayers Millions. Reuters, February 13, 2026.