DETAIN, AUDIT, THEN TALK
America First in the Marianas: Seven Chapters on Labor, Immigration, National Security, and the Price of Never Checking the Books
There is an old political trick in the Marianas that has become so familiar that it almost deserves its own line item in the territorial budget: whenever someone asks whether the government has properly enforced the rules, somebody changes the subject to the economy.
The conversation begins with immigration, moves quickly to labor shortages, makes a brief stop at tourism, takes a scenic detour through hotel occupancy, and eventually arrives at the same destination: “We need more foreign workers.”
If someone asks whether American workers were actually recruited, the answer is that there are not enough Americans.
If someone asks whether workers already admitted under existing programs have departed when their status expired, the answer becomes that the islands need more workers.
If someone asks whether the territorial government has adequately accounted for federal money, the answer becomes that the economy cannot survive without more tourism.
It is a remarkably versatile argument.
It can be used to justify almost anything.
The Commonwealth of the Northern Mariana Islands Growers Association's report, “Detain, Audit, Then Talk: A National-Security Case Against Philippine Visa-Free Travel to the Marianas,” begins from a different premise.
Before Washington is asked to widen the door, the government should determine whether the existing door is being properly managed.
Before another foreign-labor certification is approved, the recruitment record should be examined. Before another visa-waiver nationality is added, the territory's entry and exit systems should be tested. Before another promise of economic salvation is made, the books should be opened.
The report's central phrase is therefore intentionally blunt:
Detain. Audit. Then Talk.
The full report and its supporting documents are available with this article. Readers are encouraged to examine the underlying material rather than relying upon CNMIGA's characterization of it.
The report draws upon congressional debate, federal prosecutions and judgments, OCAHO proceedings, federal labor and immigration records, GAO and single-audit findings, DHS material, territorial records, and the CNMIGA investigative and policy file. Where the report relies upon an advocacy compilation or estimate rather than a primary government dataset, it identifies that distinction.
This is not an argument that every foreign worker is unlawful, every employer is fraudulent, or every Filipino visitor presents a security threat. It is an argument about whether a government should expand a system before demonstrating that it can administer the system it already has.
That distinction is important.
It is also the reason this article is divided into seven chapters.
CHAPTER ONE
THE PERIMETER IS NOT A LABOR DEPOT
The Commonwealth of the Northern Mariana Islands and Guam are not ordinary pieces of American geography. They sit on the Second Island Chain in the Western Pacific, near one of the most strategically important military and commercial environments on the planet. They host expanding Department of Defense infrastructure, operate American ports and airports, and function as American territory in a region where geography has consequences far beyond tourism brochures.
The CNMIGA report therefore begins with a question that is easy to overlook when the discussion is reduced to hotel rooms and airline seats: what does immigration policy look like when the jurisdiction administering it is itself part of the American strategic perimeter?
That question does not require treating immigrants as threats. It requires treating the perimeter as a perimeter.
The report argues that the CNMI's long history of foreign-labor dependence has created an unusual situation in which the same territory that is asking Washington for greater immigration access has not yet demonstrated complete control over the labor and immigration channels already operating there.
The report identifies a 2023 extract involving 4,857 CW-1 holders and approximately 1,700 potential overstays. It treats those 1,700 cases as a starting point for investigation rather than a final determination that every individual was unlawfully present.
That qualification matters. Numbers are useful only when people understand what they actually measure.
But even with the qualification, the underlying question remains difficult to avoid. A transitional worker program that exists in a jurisdiction of approximately 47,000 people cannot be treated like an administrative spreadsheet in a country of hundreds of millions. Scale changes the meaning of numbers. A percentage that might appear small on a national chart can represent a substantial institutional problem on an island.
This is where the report's argument becomes deliberately uncomfortable.
If the government cannot establish who entered, who departed, who remained, who changed employers, and which employment petitions remain valid, then the appropriate response is not necessarily to declare the entire system illegitimate.
The appropriate response is to audit it.
That is the boring answer.
And boring answers are often useful in government.
The report also challenges the idea that the CNMI should be treated as a labor depot whose economic problems automatically justify continued foreign-worker access.
The original CW-1 system was designed as a transition. Yet the transition has continued for years, while the political argument for keeping the system alive has become remarkably permanent.
A bridge is useful because it gets people from one side to the other.
If everyone has been living on the bridge for eighteen years, perhaps somebody should inspect the supports.
That is the first principle of the CNMIGA report.
The strategic location of the islands means immigration policy cannot be separated from enforcement capacity. A visitor program, a temporary-worker program, an airport, a maritime route and a military installation exist within the same physical environment. The policy may be written in different federal offices, but the geography does not recognize bureaucratic boundaries.
The report therefore argues that the perimeter should be treated as a security instrument before it is treated as an economic convenience.
That does not mean closing the islands to legitimate visitors. It means knowing who is arriving, why they are arriving, how long they are authorized to remain, and whether the government can verify that they actually leave.
In other words, the first question is not:
How many more people can we admit?
It is:
How many people can we reliably account for?
CHAPTER TWO
THE CLOSED SHOP AGAINST AMERICANS
The most persistent argument supporting foreign labor in the Marianas is familiar: there are simply not enough Americans willing or qualified to do the work.
That claim may sometimes be true.
But it is not self-proving.
An employer cannot establish the absence of American workers merely by announcing that American workers do not exist. The existence of a shortage must be demonstrated through recruitment, applications, interviews, qualifications, wages, working conditions and actual hiring decisions.
The CNMIGA report places several examples into that evidentiary question.
One CNMI contractor reportedly discarded 62 applications from qualified U.S. citizens for 50 positions. The report also identifies Core Tech Construction, a Guam-based federal and DPRI contractor, as a particularly important case because a U.S. citizen with documented construction experience applied for positions while the company continued using Filipino H-2B workers.
The report states that the applicant's qualifications included an OSHA 30-Hour Construction Safety Card and experience connected to federal and Commonwealth construction work.
The point is not that one disputed application establishes a universal pattern.
The point is that such a case should be investigated.
If an employer tells the federal government that no qualified American worker exists, and an American worker's résumé is sitting in the employer's file, the discrepancy deserves more than a shrug.
It deserves a file number.
It deserves an investigator.
It deserves a paper trail.
And, if the facts establish fraud, it deserves enforcement.
The report also identifies OCAHO proceedings involving several employers and manpower operations, including Costa World, EFG Pacific Holdings, Jin Joo, Manbin, Marianas Pharmacy and Kang.
The proceedings involve allegations concerning labor attestations, recruitment practices and the treatment of American applicants. The report expressly recognizes that allegations in administrative proceedings must be resolved by the appropriate forum.
That distinction should be repeated because public debate has a habit of destroying it.
A complaint is not a conviction.
An investigation is not a finding of guilt.
A referral is not a judgment.
But an allegation supported by documents is also not something that should disappear into a government filing cabinet simply because investigating it would be inconvenient.
The federal government already possesses the legal machinery necessary to examine these matters. The question is whether that machinery is actually being used consistently in the Marianas.
The CNMIGA report proposes that every CW-1 and H-2B attestation filed since 2019 be audited, with particular attention to cases in which an employer certified that no qualified U.S. worker was available while a qualified American applicant was documented.
It further argues that federally funded projects deserve additional scrutiny because false labor certifications can implicate federal funding and contracting obligations.
The underlying principle is simple: if American taxpayers are funding the project, American workers should not be erased from the recruitment record merely because a foreign-worker pipeline is more convenient.
The report's criticism is therefore not aimed at the foreign worker standing on the jobsite.
It is aimed at the certification sitting on the desk.
That distinction is fundamental.
CHAPTER THREE
WHAT THE DELEGATES TOLD WASHINGTON
The third chapter moves from the jobsite to Congress.
The report examines the arguments made by CNMI and Guam delegates in support of expanding immigration and visa access, including H.R. 10341, the Marianas Tourism Advancement Act, which would expand the Guam-CNMI Visa Waiver Program to additional nationalities, including the Philippines, India, Vietnam, Thailand, Indonesia and Mongolia.
The economic argument is understandable.
Tourism is important to the islands, and policymakers naturally look for ways to increase visitor arrivals, airline service, hotel occupancy and spending.
But the report argues that economic impact should not become a substitute for security analysis.
That distinction becomes especially important because H.R. 10341 itself contains mechanisms for suspension based on security findings and economic considerations.
The report questions whether a security mechanism becomes less useful if economic consequences effectively become the reason officials hesitate to use it.
There is a larger issue here.
When a territory repeatedly tells Washington that it needs additional foreign labor because Americans cannot be found, Washington should be entitled to ask for the recruitment evidence.
When a territory says it needs more tourists because the economy is weak, Washington should be entitled to ask whether the existing tourism infrastructure, transportation network and immigration-control system can safely handle the additional volume.
And when a territory with unresolved financial-audit problems asks for additional federal programs, Washington should be entitled to ask whether the underlying administrative machinery is capable of administering them.
That is not hostility toward the CNMI.
It is oversight.
The report also challenges the phrase “Team CNMI first” when it is used to frame federal oversight as an attack on territorial interests.
The report's position is that genuine territorial advocacy should include accountability because federal assistance ultimately depends upon the integrity of the institutions receiving it.
The Covenant created a political union.
It did not create a political exemption.
The islands have American citizenship, American federal law and American constitutional protections.
Those benefits carry responsibilities as well as privileges.
This is where the report's historical argument becomes important.
The CNMI's foreign-labor system did not appear out of nowhere. The garment era demonstrated how quickly an economy can become dependent upon imported labor when employers and government institutions have strong incentives to maintain that arrangement. Federalization was supposed to move the islands toward a different labor structure.
The question is whether that transition has actually occurred.
Or whether the transition simply changed the paperwork.
CHAPTER FOUR
SHELTER ON AMERICAN SHORES
The fourth chapter of the report turns toward a broader question: what happens when foreign labor, federal contracting, economic development and political influence begin operating inside the same small jurisdiction?
The report uses the historical garment industry and later casino-era development as part of that examination, including discussion of Tan Holdings and the Imperial Pacific footprint.
The Tan Holdings history is particularly significant because of the scale involved. According to the report, the company's garment-era operations once represented a substantial part of the CNMI economy.
Federal labor proceedings produced a $9 million award in 1992 involving systematic underpayment, and an EEOC consent decree later required $1.7 million and injunctive relief involving national-origin, pregnancy, age and retaliation claims against Tan-related entities.
Those are historical records, not rumors.
The report then makes a more controversial claim: that the political and economic architecture surrounding foreign labor did not disappear when the garment factories disappeared.
Instead, it argues that capital shifted into tourism, real estate and casino development while the underlying political economy continued to reward dependence on imported labor.
The report explicitly identifies those continuing-influence claims as advocacy allegations requiring audit rather than as established findings.
That is precisely where a serious investigation should go next.
Follow the money.
Follow the contracts.
Follow the recruitment agencies.
Follow the labor certifications.
Follow the federal grants.
Follow the political contributions.
Follow the ownership structures.
Follow the media relationships.
And then determine what the evidence actually shows.
This is especially important in a jurisdiction of approximately 47,000 people. In a large metropolitan area, a major employer can be influential without becoming the entire economic ecosystem.
On a small island, the same employer can become employer, contractor, landlord, advertiser, political stakeholder and community institution simultaneously.
That does not automatically make the organization corrupt.
It does mean that conflicts of interest deserve serious scrutiny.
The same principle applies to civic organizations.
The report discusses the United Filipino Organization–CNMI and describes its member associations, cultural activities, elections, consular relationships and public events.
It also acknowledges that none of those activities is inherently illicit.
The question posed by CNMIGA is narrower: when an organization represents a substantial foreign-worker constituency, does it also become a political force capable of influencing policy concerning that same worker system?
That is a legitimate question for any group, regardless of ethnicity.
The answer should be determined by records, not stereotypes.
And that is the important dividing line.
A Filipino cultural festival is a cultural festival.
A political campaign is a political campaign.
A labor organization is a labor organization.
The investigator's job is to determine where those activities overlap, if they do, and whether the overlap violates any law.
That is why CNMIGA argues for an audit rather than a collective accusation.
CHAPTER FIVE
NATIONAL SECURITY AND THE PHILIPPINE QUESTION
The Philippines occupies a complicated position in American national-security policy.
It is a U.S. treaty ally and an important partner in the Indo-Pacific.
At the same time, the country has experienced the longest-running communist insurgency in Asia, involving the Communist Party of the Philippines, the New People's Army and the National Democratic Front.
The CNMIGA report does not argue that the Philippine government is equivalent to the Chinese Communist Party.
In fact, it expressly states that the CCP-proxy discussion later in the report is a rhetorical diagnostic rather than an intelligence finding that Manila is Beijing.
That distinction should remain front and center.
The security question is whether Filipino tourists are secretly insurgents???
The question is whether immigration policy should take into account the characteristics of the source country, the existing labor pipeline, the territory's enforcement capacity and the possibility that organized criminal or political networks can exploit otherwise legitimate flows.
That is a conventional border-security question.
The report's argument is that national overstay statistics alone do not answer the territorial question.
The Philippines may show relatively low national tourist-overstay percentages in certain federal tables, while the CNMI simultaneously has an unresolved record involving CW-1 overstays, labor attestations and worksite enforcement.
The report argues that a 47,000-person territory cannot simply import a national average and declare the local problem solved.
This is particularly relevant because the same nationality already occupies a significant position in the CNMI foreign-worker system.
That means the proposed visa waiver would not necessarily create an entirely new population flow.
It could increase the volume of people arriving from a country already deeply connected to the territory's labor market/REPOPULATION.
The report therefore calls for advance electronic authorization, biometric entry-exit matching and real-time departure verification before additional nationalities are added to the territorial visa-waiver system.
Again, this is not an argument against Filipino people.
It is an argument for knowing who comes in and who goes out.
There is another reason the report raises the issue of birth tourism. The CNMI experienced a major increase in births associated with Chinese visitors during the period when special parole arrangements created opportunities for birth tourism.
The report cites a peak of approximately 581 foreign-visitor births in 2018 and cumulative estimates exceeding 3,300 Chinese children born in the CNMI since 2009. It also notes that those numbers subsequently declined sharply following enforcement and policy changes.
That historical episode is relevant because it demonstrates how an immigration channel designed for one purpose can be used for another.
The lesson is not that every future visitor will exploit the system.
The lesson is that policymakers should design the system so that exploitation is difficult.
That is what an audit is supposed to accomplish.
CHAPTER SIX
SANCTUARY PRACTICE, OUTSIDE CONTROL, AND THE INTERIOR INFLUX
The word “sanctuary” usually produces an image of a large American city refusing to cooperate with federal immigration authorities.
The CNMIGA report uses the term differently.
It argues that sanctuary can exist as a practice even when nobody puts the word on a government building.
If overstayers remain in the labor market, if recruitment complaints are not investigated, if false attestations are ignored, and if federal enforcement tools are applied inconsistently to the territories, the practical result can resemble sanctuary without the official declaration.
The report points to the approximately 3,700* potential CW-1 overstays, the alleged refusal of Guam DOL to investigate certain recruitment matters, disputed American-worker recruitment records and the 2023 Saipan-to-Guam maritime smuggling case as examples of what it describes as an enforcement gap.
The report also points to federal criminal judgments involving visa fraud.
Those cases are particularly important because they are not merely allegations.
The report identifies Alejandro Tumandao Nario, Mylene Basco Casupanan, Servillana Soriano, Arlene Hart, Angel Paras Cruz Jr. and Venerando Aquino Martin as individuals who received criminal sentences or convictions associated with fraudulent immigration petitions, supporting documents or employment authorization applications.
Again, these judgments do not establish that every employer, worker or immigration petition in the CNMI is fraudulent.
They establish something narrower and more important:
Fraud has occurred.
Therefore, the question is how much more exists that has not yet been detected.
That is an audit question.
The report also examines the Department of Homeland Security's September 2026 mass-influx finding and argues that Guam and the CNMI should not be administratively invisible when federal law-enforcement resources are being allocated elsewhere.
It points to the 2023 Saipan-to-Guam boat conspiracy as an example of an actual maritime immigration pathway between American jurisdictions.
The report then connects immigration oversight to fiscal oversight.
The CNMI's FY2023 single-audit record is cited as showing $96.9 million in questioned federal costs across fourteen programs, with cumulative questioned costs reaching approximately $349 million as of September 30, 2023.
The report identifies problems involving procurement, eligibility, allowable costs, subrecipient monitoring and missing documentation.
That is where the report's satire becomes particularly pointed.
A government that cannot easily prove where hundreds of millions of questioned federal dollars went is simultaneously asking Washington to trust it with a larger immigration and tourism pipeline.
Perhaps the answer should not be “no.”
Perhaps the answer should simply be:
“Show us the books first.”
The same issue appears in healthcare and utilities. The report discusses the Commonwealth Healthcare Corporation's unresolved liability exposure following Maratita v. CHCC, as well as the Commonwealth Utilities Corporation's financial problems following typhoon recovery efforts.
None of this means foreign workers are responsible for those institutional problems.
It means that immigration policy does not operate in a vacuum.
Workers require hospitals.
Families require housing.
Visitors require infrastructure.
Residents require utilities.
Governments require functioning financial controls.
If the underlying systems are already strained, policymakers should calculate the consequences of additional population and enforcement obligations rather than simply assuming that more arrivals automatically produce more prosperity.
CHAPTER SEVEN
DETAIN, AUDIT, THEN TALK
The final chapter is where the report stops diagnosing the problem and begins prescribing an institutional response.
Its first recommendation is a temporary moratorium on new CW-1, H-2B and related foreign-labor certifications and petitions in Guam and the CNMI while a joint federal audit is completed.
The report specifically distinguishes this proposed pause from cancellation of lawful existing status: workers already lawfully present would remain through their authorized periods, while employers would have to demonstrate genuine recruitment before receiving exceptions.
Second, the report calls for increased federal worksite and overstay enforcement.
Third, it calls for the existing visa-waiver system to be held at its current nationalities until territorial overstay, compliance and enforcement benchmarks are established. It proposes biometric entry-exit matching, advance electronic authorization and real-time departure verification as prerequisites to expansion.
Fourth, it calls for every employer that has filed CW-1 or H-2B attestations since 2019 to be audited, particularly where qualified American applicants can be documented.
Fifth, it proposes direct federal supervision of territorial labor departments during the audit period.
Sixth, it calls for multi-state recruitment and sister-state job-board requirements so that an employer cannot simply claim that no American worker exists without demonstrating a genuine national recruitment effort.
Seventh, it calls for continued closure of residual birth-tourism pathways.
Eighth, it calls for completion of deferred fiscal audits involving CHCC, CUC and the central government.
The report also proposes a coordinated investigative docket involving USCIS Fraud Detection and National Security, DHS's Office of Inspector General, the Department of Labor's Office of Foreign Labor Certification, and the federal Task Force to Eliminate Fraud.
It calls for matching labor attestations against job announcements, application logs and payroll records.
This is the heart of the proposal.
Not mass suspicion.
Not ethnic profiling.
Not a presumption that every visitor is dangerous.
Verification.
If the employer recruited Americans, the record should show it.
If the worker has lawful status, the record should show it.
If the worker departed, the record should show it.
If the petition was legitimate, the documents should show it.
If federal money was spent properly, the audit should show it.
And if the government is functioning properly, the government should be able to produce the evidence.
That is why the report's title is not simply “Detain.”
It is “Detain, Audit, Then Talk.”
The sequence matters.
The report's final position is not that the Marianas can never discuss additional tourism or labor access. It argues that after enforcement and auditing are completed, Washington can reconsider narrowly tailored, temporary and verifiable exceptions where the evidence demonstrates a genuine shortage or legitimate tourism need. It specifically contemplates future systems involving electronic authorization, biometric exit verification and documented recruitment from the American mainland.
That is a much different conversation from simply asking Washington to trust another promise.
THE RECORD IS NOW ON THE TABLE
CNMIGA understands that this report will be challenged.
It should be.
Public policy should survive scrutiny, not avoid it.
The appropriate response to a disputed number is to produce the better number.
The appropriate response to an allegation is to produce the evidence that disproves it. The appropriate response to an audit finding is to correct the deficiency. The appropriate response to a recruitment dispute is to produce the application, interview and payroll records.
That is why the full report and supporting documents are being made available with this article.
Readers can examine the underlying material themselves.
Journalists can examine it.
Federal agencies can examine it.
Congressional offices can examine it.
Employers can examine it.
Labor organizations can examine it.
Community organizations can examine it.
And government officials who disagree with the conclusions can identify the evidence that requires a different conclusion.
That is how serious public debate should work.
The CNMIGA report does not claim that every allegation is already proven.
It does not claim that every foreign worker is unlawful.
It does not claim that the Philippines is an enemy state.
Its own methodology explicitly distinguishes advocacy claims from primary records and labels its four-point Philippine/CCP discussion as a rhetorical diagnostic rather than an intelligence finding.
What it does claim is that the existing record contains enough documented problems to justify an audit before another expansion of the system.
That is the question readers should examine.
Not whether they like CNMIGA.
Not whether they like Congress.
Not whether they like the Philippines.
Not whether they like tourism.
Not whether they like foreign workers.
The question is whether the evidence justifies opening another door before the government has demonstrated that it can control the doors already open.
The Indigenous Americans of the Marianas have spent decades being told that the next program will finally solve the problems created by the last program.
The garment system was temporary.
The CW-1 system was transitional.
The casino was supposed to transform the economy.
The next tourism initiative will supposedly rescue the islands.
And now another visa channel is being offered as another piece of the solution.
At some point, someone has to ask whether the problem is the absence of another program—or the absence of accountability for the programs already in place.
That is the question this report puts before Washington.
Detain the people who are demonstrably out of status.
Audit the labor certifications that brought workers into the system.
Audit the employers.
Audit the recruitment agencies.
Audit the federal contractors.
Audit the books.
Verify the exits.
Examine the political and economic relationships.
Then talk about expansion.
Not because the Marianas should be isolated from the world.
Because the Marianas are part of America.
And American sovereignty is not merely a flag, a passport, a military installation or a congressional district.
It is a promise that the law will mean something when it arrives at the jobsite, the airport, the hospital, the utility, the courthouse and the government accounting office.
The Pacific does not need another slogan.
It needs the paperwork.
And this time, before Washington opens the door, perhaps it should first ask the question that has been avoided for far too long:
Who is already inside—and who has actually checked?
Read the full report.
Examine the supporting documents.
Follow the records.
Challenge the conclusions.
Then let the conversation begin.
About the Author
Zaji “Persona Non Grata” Zajradhara is a staunch advocate for American workers and indigenous rights in the CNMI.
Labeled a “persona non grata” by the CNMI government for his relentless pursuit of justice and his outspoken criticism of corruption and foreign influence, Zajradhara has become a symbol of resistance against the forces seeking to undermine American sovereignty in the islands.
As An Unemployed Afro-American resident and father, Zajradhara's firsthand experience with the CNMI’s dysfunctional labor market, its rigged political system, and the exploitation of vulnerable communities has fueled his activism. He has filed numerous legal claims against companies, including Tan Holdings, for violating labor laws and discriminating against American workers.
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