U.S. Customs and Border Protection (CBP) has initiated a new program aimed at hiring private investigators to locate deported immigrants and other individuals who have departed the United States to collect outstanding government debts. According to internal documents and records reviewed by investigative outlets, the agency is seeking "commercial data verification and physical observation services" to track individuals across international borders, specifically targeting Mexico, Honduras, and Guatemala, with the potential for further expansion. This initiative, titled the Tracing and Payment Recovery Services program, marks a significant escalation in the federal government’s efforts to enforce civil monetary penalties against non-citizens after they have already left American soil.
The program is currently capped at $9 million over the next two years. It seeks to formalize a system where private contractors act as international skip-tracers, utilizing a variety of surveillance and investigative methods to confirm the residency and status of individuals who owe the U.S. government fines. These fines, which can reach into the millions of dollars per person, are often the result of failing to comply with departure orders. The move has sparked intense debate among legal experts, human rights advocates, and policymakers regarding the ethics of using private "bounty hunters" to pursue former residents in foreign jurisdictions.
The Tracing and Payment Recovery Services Program: Scope and Methods
Under the terms of the proposal, private investigators will be tasked with providing definitive proof of an individual’s location. The government has specified that acceptable evidence includes high-resolution photographs of the subject’s current residence, as well as copies of utility bills, employment records, or court documents. In cases where the individual has passed away, contractors are required to secure a death certificate to close the case file.
Beyond mere verification, the contractors are mandated to serve as couriers for the U.S. government. They must deliver a printed flyer, produced in both English and Spanish, which outlines the specific fines and fees the CBP claims are owed. These notices are intended to pressure individuals into utilizing Pay.gov, a federal payment portal, to settle their debts.
The payment structure for these contractors is designed to incentivize speed rather than the actual recovery of funds. Investigators will receive a set fee for each successfully documented notification, with tiered bonuses awarded for reporting back within seven, 14, or 28 days of receiving a lead from CBP. Notably, the contractors’ compensation is not contingent on whether the immigrant actually pays the fine, a detail that has led some critics to question the program’s ultimate fiscal utility.
Legislative Background and the Resurgence of Section 274D
The legal mechanism fueling these massive fines is found in an obscure provision of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA). Section 274D of the law allows the government to impose civil penalties on non-citizens who are subject to a final order of removal but fail to depart the United States. While the law has been on the books for nearly three decades, it remained largely unused until the first term of the Trump administration, when the Department of Homeland Security (DHS) began aggressively issuing fine notices as a tool of deterrence.
As of July 2026, DHS reports that it has issued more than $84 billion in civil fines. These penalties accumulate at a rate of $998 per day for up to five years for individuals who remain in the country past their departure date. For many, the total balance exceeds $1.8 million. Legal experts note that these fines are often issued without the traditional due process afforded in criminal proceedings, leading to situations where individuals are unaware of their mounting debt until they face severe financial consequences, such as the seizure of tax returns or the garnishment of wages.
Domestic Precedents and the "Bounty Hunter" Model
The expansion of skip-tracing into foreign countries follows a massive domestic investment in similar services. In late 2023, Immigration and Customs Enforcement (ICE) awarded open-ended contracts to 13 private companies, worth an estimated $1.2 billion over two years, to locate undocumented immigrants within the United States. These domestic contractors provide ICE with photos and documents confirming residences and workplaces, earning bonuses based on the volume of individuals located.
Privacy advocates, including former officials from the Privacy and Civil Liberties Oversight Board, have characterized these arrangements as transforming private firms into "ICE bounty hunters." The CBP’s new international program effectively exports this model. By hiring investigators to operate in Mexico and Central America, the government is attempting to close a perceived loophole where deportation formerly meant an end to U.S. financial jurisdiction over an individual.
Political and Legal Opposition
The program has faced sharp criticism from members of Congress. Senators Dick Durbin and Alex Padilla recently authored a letter to acting Attorney General Todd Blanche and Homeland Security Secretary Markwayne Mullin, demanding an immediate halt to the application of these fines against immigrants who are otherwise complying with the law. The senators raised concerns that the penalties are being arbitrarily applied to "Dreamers," survivors of domestic violence, and green card applicants who may have pending legal status.
Senator Durbin described the program as a "vindictive mass deportation campaign" and a waste of taxpayer dollars. "The Trump administration is burning taxpayer dollars to chase down immigrants who followed their directives to leave the country," Durbin stated, highlighting the irony of spending millions on investigators to pursue individuals who have already complied with removal orders.
Legal advocacy groups, such as the Legal Aid Society and the NYU School of Law’s Immigrant Rights Clinic, are also challenging the program. Hasan Shafiqullah, a supervising attorney at the Legal Aid Society, is currently suing the federal government over the fines. He argues that many of the targeted individuals are destitute and that the pursuit of these funds is a futile exercise in intimidation. "It makes no sense to go after people here if they don’t have the money," Shafiqullah noted. "Presumably they don’t have the money there, and they’re not subject to collections. What’s the point of this?"
Impact on Families and International Relations
One of the most significant concerns regarding the Tracing and Payment Recovery Services program is its impact on mixed-status families remaining in the United States. The NYU report, "Debt and the Deportation Agenda," found that CBP anticipates that payments may be made by "another party" on behalf of the deported individual. This suggests a strategy of leveraging the financial stability of family members still in the U.S. to pay off the debts of their deported relatives.
Furthermore, the program raises complex questions regarding international sovereignty and cooperation. As of late 2024, the foreign ministries of Mexico, Guatemala, and Honduras had not publicly confirmed whether they would cooperate with U.S.-hired private investigators operating within their borders. The use of private contractors to conduct "physical observation" and gather "commercial data" on foreign citizens could potentially violate local privacy laws or strain diplomatic relations if conducted without explicit bilateral agreements.
Financial Analysis and Potential Outcomes
While the government claims these fines are a necessary enforcement tool, the actual recovery rate remains low. The three debt collection agencies currently used by CBP reported that, as of July 2026, they had not successfully located a single person outside the United States using traditional methods like letters and phone calls. This failure is what prompted the shift toward "physical observation" and the hiring of private investigators.
The administrative costs of the program are also significant. In addition to the $9 million contract for investigators, some third-party collection agencies have been known to add up to $500,000 in administrative fees on top of the government’s original fines. Furthermore, even if an individual attempts to settle their debt through the CBP Home app—which DHS promises will result in a waiver of "failure-to-depart" fines—they may still be liable for a $5,130 fee created by Congress for those ordered removed in absentia. This fee is legally barred from being waived or reduced, meaning many who "self-deport" under the promise of a clean slate find themselves still hounded by federal debt.
Conclusion and Broader Implications
The implementation of the Tracing and Payment Recovery Services program signals a paradigm shift in U.S. immigration policy, moving toward a model of lifelong financial liability for non-citizens. By employing private investigators to track deportees internationally, the U.S. government is asserting that the end of physical presence in the country does not equate to the end of its enforcement reach.
As the bidding process for these contracts concludes, the focus will shift to how these private firms operate on the ground in Latin America. The methods they use to obtain foreign records and the level of "physical observation" they employ will likely remain under intense scrutiny from human rights observers and legal scholars. Whether the program succeeds in recovering any of the $84 billion in outstanding fines or simply serves as a multi-million dollar deterrent remains to be seen, but its existence underscores a hardening of the American border—one that now extends far beyond the geographical limits of the United States.
