Page 1 GAO-25-107644 U.S. Immigration and Customs Enforcement
November 18, 2024
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
U.S. Immigration and Customs Enforcement: Update on Planning for Unit of Native
American Law Enforcement Personnel
Sixty-eight miles of the United States southwest border and 86 miles of the northern border are
within American Indian reservations. As with other border areas, these areas may be vulnerable
to illicit cross-border activity. Congress established the Shadow Wolves program, which began
operations in 1974, to address the illegal smuggling of controlled substances from Mexico to the
Tohono O’odham Nation reservation in Arizona and into the interior of the United States.
1
The
program’s employees—known as “Shadow Wolves”—must be certified to have at least one-
quarter American Indian ancestry from a federally recognized Tribe.
2
Within the Department of
Homeland Security (DHS), the unit is part of the U.S. Immigration and Customs Enforcement’s
(ICE) Homeland Security Investigations (HSI) office in Sells, Arizona—the capital of the Tohono
O’odham Nation.
The Tohono O’odham Nation has faced challenges due to an increase in migrant and
transnational criminal organization activity on the reservation in recent years, according to
Tohono O’odham Nation officials. As a result, the officials stated that in recent years the Tohono
O’odham Police Department has spent about 50 percent of its time on border-related issues.
The officials also cited negative effects of transnational criminal organizations on the
1
About 62 miles of the U.S. southwest border is located on the Tohono O’odham Nation reservation. According to
U.S. Immigration and Customs Enforcement (ICE), an act of Congress created the Shadow Wolves program in 1972,
and on April 14, 1974, the U.S. Customs Service swore in the first seven Shadow Wolves.
2
Excepted Service; Consolidated Listing of Schedules A, B, and C Exceptions, 89 Fed. Reg. 61177, 61180 (July 30,
2024) (Sch. A, 213.3111(e)); Excepted Service, 89 Fed. Reg. 45688 (May 23, 2024) (Sch. A, 213.3111(g)(2)). Dating
back to 1974, the program’s hiring authority has required that the program hire persons with one-fourth or more
“Indian blood.” For the purposes of this report, we refer to this language as requiring persons of American Indian
ancestry.