CBP Memo Raises Alarms Over Trusted Traveler Program Revocations
Nicole Cleland was driving in Richfield, Minnesota, on January 10 when a Border Patrol agent approached her car, startling her by using her first name. The agent informed her they were employing facial recognition technology and warned her to cease "impeding" their work or face arrest. Three days later, Cleland received an email from U.S. Customs and Border Protection (CBP) notifying her that her Global Entry status had been revoked. Global Entry is part of the government's "Trusted Traveler" programs, designed to expedite arrivals into the United States.
"As soon as I got the email, I said to my husband, 'How much do you want to bet this has to do with Saturday?'" recalled Cleland, who had been volunteering as a legal observer to monitor immigration raids in her community. "There's just way too much coincidence there." Her suspicions are supported by a recent CBP memo reviewed by HuffPost, which instructs field offices to send "recommendations to revoke Trusted Traveler membership for U.S. citizens" to headquarters for review, accompanied by an incident report and an "articulated reason."
Expanded Use of Revocation Powers
The memo specifically addresses "encounters" with CBP officers supporting operations led by other law enforcement agencies. Over the past year, many CBP officers have been reassigned from their usual duties at U.S. ports of entry to assist Immigration and Customs Enforcement (ICE) in inland immigration operations, bringing them into direct contact with demonstrators in cities like Minneapolis and Los Angeles. This shift raises significant questions about whether revoking Trusted Traveler privileges could be used as a form of retribution against individuals protesting the administration's immigration policies.
While CBP personnel have long had the authority to recommend revocation, such cases typically stem from seizures of illegal drugs or prohibited items at entry points, not from interactions on city streets. The memo does not explicitly mention protests or outline specific grounds for revocation, stating only that final decisions rest with an executive director. However, a Department of Homeland Security employee indicated to HuffPost that the memo is perceived as an invitation to submit cases involving protesters. CBP, a component of DHS, declined to comment on the matter.
Personal Accounts of Revocation
Michelle Shara reported losing her Global Entry status in November after an encounter with federal agents in Charlotte, North Carolina. She and a friend had traveled from South Carolina to observe and document immigration raids. In a video provided to HuffPost, an agent in camouflage approached Shara's car, accused her of trespassing on federal property, and demanded her driver's license to record her information. Ten days later, she received an email revoking her Global Entry, with no explanation provided.
"It was very creepy," Shara said. "You always joke... 'I'll probably be on a list.' But then I was like, 'Oh shit.'" Although she rarely uses Global Entry, the incident left her anxious; she recently traveled to Australia and wiped her phone before returning, fearing detention. She passed through customs without issue, but the experience highlighted the psychological impact of such revocations.
Legal and Constitutional Concerns
Sara Robinson, a staff attorney with the ACLU's National Security Project, argued that revoking Global Entry as punishment for recording agents would be unconstitutional. "This is about more than convenience at the airport: It's about whether the government is punishing speech it dislikes and seeking to deter people from exercising their fundamental freedoms," Robinson stated. The memo's vague language leaves room for interpretation, potentially allowing revocations based on minor actions like following agents, blowing whistles to warn communities, or verbal heckling.
John M. Manley, an immigration attorney, noted that revocations often occur after customs violations, such as carrying undeclared cash or restricted agricultural products. However, he has also seen cases where people lose status after arrests without prosecution or due to name or address mix-ups. "There's really nothing to prevent them from revoking people," Manley explained. "It's a travel perk, basically. So you don't have any rights. That's why it's so subjective."
Broader Implications and Statistics
According to CBP, approximately 13 million people are enrolled in Global Entry, which includes TSA PreCheck. It is the most popular Trusted Traveler program, though others exist for commercial truck drivers and frequent travelers from Mexico and Canada. While revocations commonly result from criminal charges or customs violations, some occur without explanation, forcing individuals to seek reversal through a program ombudsman. An analysis by Bloomberg last year indicated a substantial increase in revocations since 2024.
The loss of Trusted Traveler status can be particularly severe for those who cross borders regularly for work or family reasons. Programs like NEXUS, SENTRI, and FAST, which facilitate quicker land border crossings, are also listed in the memo as subject to potential revocation. Cleland has filed a Freedom of Information Act request to uncover the reasons behind her revocation, expressing more concern about the perceived retaliation than the loss of convenience. "I struggle with it every day, because I feel like they've won," she said. "I'm almost ready to go back to some of this rapid-response work, but I don't know how far they'll go."
As protests against immigration policies continue, the memo underscores ongoing tensions between government enforcement actions and civil liberties, prompting calls for greater transparency and accountability in the Trusted Traveler program.
