Secret ‘Keyhole’ program emerges as ICE surveillance of protestors widens

U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI) placed Operation Puppet Master, its undercover surveillance and investigation of groups resisting the Trump administration’s Minnesota immigration crackdown, under something identified in agency records as “CUC Op Keyhole,” according to HSI documents filed August 13 in federal court.

Puppet Master was part of a broader surveillance effort in which agents used Clearview AI facial recognition, license plate and identity lookups, covert recordings, undercover identities and other investigative tools to identify people and map relationships around the anti-ICE movement.

The court records do not explain what Keyhole was, but separate ICE and HSI policy documents show that “CUC” is agency terminology for “Certified Undercover Operation,” a formal structure capable of supporting undercover identities, covert communications, surveillance vehicles, recordings and other technical and operational resources.

The documents establish that Puppet Master was “accepted [for inclusion] under” HSI’s Keyhole CUC as a formally administered framework through which individual investigations can be authorized, funded, equipped and managed.

An ICE Undercover Operations Handbook dated April 14, 2008, says each CUC receives a program code in TECS, the agency’s law enforcement information system, and describes that code as embodying the operation’s certification and authorization.

The handbook lays out the structure and authorities of Certified Undercover Operations. The document’s continuing relevance is supported by official ICE records that include a 2017 HSI directive and a 2023 ICE financial policy that continued to require compliance with the agency’s Undercover Operations Handbook.

The Government Accountability Office (GAO) reported in September 2015 that ICE began revising the handbook years ago, but as of June 2025 had not provided GAO with a more recent update on the revisions or an estimated completion date.

The newly disclosed designation helps explain the structure behind ICE’s activities in Minnesota and Michigan that used undercover agents, covert recordings and other surveillance techniques to investigate alleged assaults, obstruction and organized resistance to federal immigration enforcement.

HSI’s undercover policy shows that individual investigations can be placed within a CUC and operate under its authorization and resources. Puppet Master therefore appears to have been accepted into a broader certified undercover framework called Keyhole, whose scope remains undisclosed.

The documents disclosed in the prosecution of Isaac Sant and 14 other defendants describe Operation Puppet Master and Project Whipple Shield.

Undercover agents entered meetings, recorded conversations, monitored activist communications and gathered information about political organizations and their finances.

Sant’s attorney, Kevin Riach, specifically asked the government to produce additional records concerning Keyhole after finding the reference in the HSI case opening report. What those records have not revealed is what Keyhole authorized.

The 2008 ICE Undercover Operations Handbook provides unusually detailed insight into how the agency structured Certified Undercover Operations.

Although the handbook is nearly two decades old and cannot be assumed to reflect every current HSI rule, later HSI directives continue to use the CUC terminology and ICE’s Office of Professional Responsibility said as recently as May that it conducts biennial financial audits of the agency’s Certified Undercover Operations.

The older handbook makes clear that a CUC is not simply another word for a specific case.

Once a Certified Undercover Operation is approved, ICE creates a special CUC program code in TECS, its law enforcement information and case management platform.

The handbook says the code “embodies the certification and authorization of the operation” and indicates that a particular investigation has been certified and authorized within that CUC.

Individual investigative cases could therefore be placed beneath a larger certified operation. Reports generated by one CUC could even document assistance from another CUC, including transportation, undercover meetings and other law enforcement support.

Read against that policy, the otherwise cryptic statement that Puppet Master had been “accepted under CUC Op Keyhole” takes on a different meaning. It appears to indicate that Puppet Master was an investigation placed within a formally certified undercover operation called Keyhole.

That interpretation remains an inference from HSI’s own terminology, as the Department of Homeland Security (DHS) has not publicly confirmed Keyhole’s organizational relationship to Puppet Master or Whipple Shield, and no public document located in a search of ICE and HSI records explains Keyhole’s mission.

But the distinction matters because the certified operation could be larger than the particular investigation that exposed its existence.

The ICE handbook required managers to ensure that cases placed beneath a CUC involved undercover activity or had a direct nexus to it. Reports of Investigation are used to track how cases advance the objectives of the larger operation.

Sant’s defense is now seeking records that could answer the obvious questions of when was Keyhole authorized, what its purpose was, what investigations were accepted under it and what reports its undercover agents generated.

Those questions have become more significant as the geographic reach of the Minnesota surveillance has emerged. HSI personnel followed activity related to the Minnesota crackdown beyond the Twin Cities, including an undercover operation at a church event in Ann Arbor, Michigan.

Nothing disclosed so far establishes that Keyhole was a national political surveillance operation. But the existence of undercover activity across state lines makes the still undisclosed boundaries of the CUC increasingly relevant.

ICE’s undercover handbook also helps explain why discovering the CUC behind Puppet Master matters operationally. Certified operations could maintain equipment, leased vehicles, undercover identities, bank accounts and other property specifically dedicated to their work.

The handbook cited an undercover cellular phone as an example of a legitimate operational expense and a leased sedan as reasonable when needed for “general surveillance and undercover security.”

Vehicles could be leased covertly when ordinary government procurement would compromise operational cover.

CUCs could also support covert online identities.

The handbook instructed agents to use computers stripped of registration information that might expose them as government systems. Software could be registered to an undercover identity.

Email and Internet service accounts were to be “backstopped” so that account information would not reveal the government behind them.

For certified undercover Internet activity, agents could operate covertly online, develop websites and post messages under false identities.

Biometric Update first reported last month how ICE has built a covert browsing capability that allows investigators to monitor social media, online communities and dark web forums without revealing a government presence.

Current HSI infrastructure continues to support such work. ICE says its Cyber and Technical Operations Center provides technical assistance and guidance to HSI undercover operations, while HSI’s publicly released Technical Operations Handbook governs specialized electronic surveillance support.

None of that establishes that Keyhole possessed or used every capability available to a CUC.

It establishes what kind of operational structure Keyhole apparently was.

That distinction becomes especially relevant in Minnesota because undercover HSI agents secretly recorded political meetings and conversations.

ICE’s 2008 policy specifically contemplated consensual monitoring and electronic audio surveillance of undercover conversations or activities.

An undercover operative could record a conversation in which the operative participated and, under specified circumstances, conversations overheard from a place where the operative had a legitimate right to be.

Such monitoring required additional approvals and remained subject to technical surveillance policy.

That closely resembles a number of the HSI activities exposed in the Minnesota records.

Undercover agents entered meetings at churches, libraries and other gathering places while posing as participants. At University Baptist Church in Minneapolis, an agent secretly recorded a martial arts training before the concealed recorder fell onto the gym floor.

In another operation, HSI sent an undercover agent into Zion Lutheran Church in Ann Arbor to record a presentation about resistance to Minnesota immigration enforcement.

Again, the available records do not establish that those particular recordings were conducted under Keyhole’s authority. But Puppet Master’s placement beneath CUC Op Keyhole raises the question of whether the larger certified operation supplied the authorization, resources and management framework for at least some of the undercover activity now coming to light.

The ICE handbook becomes still more relevant because the Minnesota records show undercover personnel doing more than listening.

At a Sunrise Movement gathering described in an HSI report as focused on peaceful protest, an undercover agent told a participant that he worked in construction and could build items that might assist groups conducting more direct-action protests.

The agent also said going to jail did not bother him.

Another undercover agent volunteered for an action team that could become involved in mass noncooperation.

The defense argues that such conduct shows agents attempting to shape the political activity they were supposedly observing.

HSI records show undercover monitoring began before Puppet Master was formally opened on January 28.

At a publicly advertised ICEWatch training on December 3, an undercover agent reported that participants were being taught to document ICE activity, notify others of agents’ presence and lawfully observe enforcement operations.

The report said there did not appear to be violations of the federal assault statute or threats to public safety and initially recommended no further action absent additional information.

The agent nevertheless remained inside the movement’s communications network. After joining Monarca’s Rapid Response Network, HSI again recorded that its notifications did not encourage criminal activity but continued receiving them for law enforcement situational awareness.

Ten days after the ICEWatch training, the agent entered a Sunrise Movement gathering at First Universalist Church. From there, undercover access expanded into announcement channels and Signal groups, and an agent later volunteered for an “action” team involved in planning protest activity.

In other words, the undercover presence did not begin with Puppet Master. It preceded the formal investigation, continued after agents themselves documented apparently lawful activity and then moved progressively deeper into the organizations and communications being monitored.

ICE’s historical undercover rules are important here because they specifically address that boundary.

The handbook states that undercover personnel generally may not induce someone to commit a crime. But it also provides a procedure allowing inducements in specified circumstances when approved by the Special Agent in Charge and coordinated with federal prosecutors.

It separately allows approved participation in certain conduct that would otherwise be illegal if committed by a private person when necessary to obtain evidence, maintain an undercover identity or protect life and safety.

The policy does not show that the Minnesota agents received any such authorization, nor does it establish that their conduct amounted to legal inducement.

It does, however, identify another category of Keyhole records that could prove important: what conduct was authorized when the operation was certified and what later expansions, waivers or approvals were granted.

For particularly intrusive investigative conduct, the handbook imposed additional limits. Illegal wiretapping, breaking and entering, illegal mail openings and trespass were prohibited unless approved by the local U.S. Attorney’s Office.

The question is not whether a CUC gave agents a blank check. It did not. It is what Keyhole’s certification permitted. Certified Undercover Operations were designed to leave an administrative trail.

The handbook describes formal applications, certification and reauthorization procedures, management reviews, expenditure plans, property inventories, Reports of Investigation and TECS coding intended to connect individual cases to the operation under which they were authorized.

More sensitive circumstances could trigger review by an Undercover Review Committee and higher-level approval.

And CUCs remain subject to oversight today. ICE’s Office of Professional Responsibility says it conducts financial audits of Certified Undercover Operations every two years. That means Keyhole should not merely be an ephemeral codename.

If the current system retains the essential structure described in ICE’s earlier policies, there should be records showing what the operation was created to do, what authorities it received, which investigations belonged to it and how its undercover activity was supervised.

Those are precisely the records the Minnesota defendants say they have not received from ICE.

The government has separately withheld at least five Project Whipple Shield Reports of Investigation prosecutors say concern an unrelated, ongoing investigation. The defense contends that additional undisclosed undercover activity may exist.

Whether any of those materials are connected to Keyhole remains unknown. But the wording of HSI’s own Puppet Master case opening report now provides a reason to look beyond the two operations whose names have dominated the Minnesota surveillance story.

Puppet Master may have been the investigation, and Whipple Shield may have expanded it.

But Keyhole appears to have been the certified undercover framework behind at least part of it.

What HSI has not yet disclosed is how much else was operating through that keyhole.

Article Topics

facial recognition  |  ICE - U.S. Immigration and Customs Enforcement  |  law enforcement  |  surveillance