As published in the Federal Register today, the U.S. Customs and Border Protection (CBP) is requesting comments on the introduction of a newly developed biometric-based entry and exit program.

This program will be applied to non-exempt non-U.S. citizens entering and exiting the United States. According to the CBP, the purpose of this national security measure is to ensure non-U.S. citizens’ identity and to ascertain their admissibility in the United States. The system will capture biometrics including digital fingerprint scans, photographs, facial images and iris images, or other biometric identifiers. The notice does not refer to any of the technology details supporting the system. The existing biographic collection process used by CBP doesn’t capture facial and iris images.

The notice is open for written comments from federal agencies directly affected by the program and from the general public, which can be submitted to the CBP on or before October 19, 2015. The proposed biometric identity collection program will subsequently be submitted to the Office of Management and Budget for approval.

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Photo of Ian Macdonald Ian Macdonald

Ian R. Macdonald Co-Chairs the firm’s Labor & Employment Practice’s International Employment, Immigration & Workforce Strategies group. He focuses his practice on developing, assessing and managing global mobility programs for multinational companies on a range of challenges affecting the movement of people capital

Ian R. Macdonald Co-Chairs the firm’s Labor & Employment Practice’s International Employment, Immigration & Workforce Strategies group. He focuses his practice on developing, assessing and managing global mobility programs for multinational companies on a range of challenges affecting the movement of people capital domestically and internationally, including secondment agreements, benefits transferability, local host country employment concerns and immigration.

Ian and his team work closely with companies to manage and modify, where needed, corporate immigration programs to maximize efficiency, service and regulatory compliance levels. He is experienced with the full range of business immigration sponsorship categories (visas and permanent residence), anti-discrimination rules to reduce or eliminate risk of employment litigation, employer sanction cases, and I-9 and E-Verify compliance. Ian assists clients with establishing risk-based performance standards (RBPS) and Department of Homeland Security protocol, providing risk assessment assistance to corporations subject to Chemical Facility Anti-Terrorism Standards (CFATS) and assisting clients with ITAR/Export Control compliance within the immigration context.

Ian has developed strategic relationships abroad that he utilizes when working with clients to ensure compliance with foreign registration requirements. He is experienced with analyzing complex global mobility opportunities on country-specific matters to facilitate the transfer of personnel. Ian is also experienced in counseling employers on immigration strategy as well as immigration consequences of mergers and acquisitions, reduction in workforces, and furloughs.

Prior to joining the firm, Ian worked for the United Nations, various non-governmental think tanks and corporate law firms in London, Washington, D.C., New York and Atlanta.