Based on recent information from the Afghanistan Affairs Unit (AAU), OIG reports from both DHS and State, a high-profile conviction of a fraudulent Afghan SIV holder, and the testimony of Foreign Service Officers who have adjudicated Afghan SIVs, the Ben Franklin Fellowship has serious concerns about the integrity of the Afghan SIV process. Specifically, these concerns are that approval criteria for SIV petitions are not aligned with administration priorities, that fraudulent applications are not being caught during visa interviews, that the State Department’s Overseas Criminal Investigator covering Afghanistan has other responsibilities, and that prior OIG investigations were focused more on the speed of processing Afghan SIV cases than safeguarding national security. As such, the Fellowship recommends that the State Department immediately pause both COM approval of Afghan SIV petitions and SIV visa issuance until such time as a thorough review of the program is completed.

The approval criteria for SIV petitions are deficient in several ways. The first issue is the “ongoing serious threat” requirement, which states that the Afghan citizen who performed credible service must be at risk as a result of their service. The FAM notes that COM has granted a blanket approval so that all Afghans meet this bar. However, the AAU’s 2024 Afghanistan Country Fraud Summary presents a different picture. It first notes that the United States is dependent upon Taliban cooperation to fly Afghan SIVs to Qatar for interviews. It then points out that many SIV recipients return to Afghanistan after becoming Legal Permanent Residents. This blanket approval appears to be inappropriate given the actual conditions. The second serious concern is the removal of the requirement for a U.S. citizen supervisor to sign letters of recommendation, which occurred in 2023. This allows non-citizens to vouch for each other, raising additional fraud concerns.

The State Department's org chart of the AAU, current as of May 2025, is also concerning. The org chart notes that three of the six consular officers are entry level, meaning that they may not have significant visa expertise. This fact, combined with a remarkably low visa refusal rate per the 2024 Country Fraud Summary, calls into question the AAU's ability to detect fraud. Even more remarkable is that the AAU still does not have a dedicated Overseas Criminal Investigator. While it is laudable that this position is now filled, the incumbent covers several other countries in addition to possessing the Afghanistan portfolio. This staffing model should be contrasted with Embassy Kabul, where every single SIV applicant had not only an interview with a Consular Adjudicator but also a separate fraud interview with trained Regional Security Officers and dedicated local staff.

Finally, a careful study of past OIG reports reveals that the primary goal of the investigations was to increase the speed at which the Department issued SIVs. Much effort went into documenting the AAU’s email backlog and the time that a petition took from submission to visa issuance. However, there are very few mentions of whether State’s efforts to fight fraud were sufficient. It seems clear, based on the case of Dilbar Gul Dilbar, who submitted a counterfeit Chief of Mission approval letter, a fraudulent employment letter, and a fake Letter of Recommendation to obtain a visa, that State lacks appropriate checks and balances in the visa adjudication process for SIVs. In fact, this example alone should be sufficient to trigger an immediate pause in SIV issuance and an overhaul of State’s processes.