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UNDER THE RADAR II: THE SECOND TRUMP ADMINISTRATION’S STEALTH ATTACK ON THE U.S. IMMIGRATION SYSTEM

In 2019, this office documented how the first Trump administration reshaped the U.S. immigration system through measures that often unfolded outside public view.

Rather than relying on headline executive orders or legislation, the Trump administration used internal memoranda, regulatory reinterpretations, adjudicatory slowdowns, and operational directives, among other tools, to constrict lawful pathways for immigrants and expand the federal government’s enforcement authority. The strategy was frequently shielded from sustained public debate, and therefore, “under the radar.”

This follow-up report examines immigration actions that the second Trump administration has taken in the same fashion since January 2025. The report finds a redoubled effort, drawing on the first Trump administration’s experience, which has destabilized lawful presence, expanded enforcement, and reengineered adjudication to accelerate and prioritize removal. During the first two years of the second Trump administration, Congress has not rewritten the Immigration and Nationality Act (INA), but through continued stealthy changes to immigration policies and practices, the administration has profoundly changed its practical application.