When Immigration and Customs Enforcement agents are trying to track down undocumented immigrants, they seek out all the data they can find. In Arizona, they’ve found a special trove that’s ripe for abuse.

The Transaction Record Analysis Center, or TRAC, database offers a rare glimpse into the financial lives of millions of immigrants and U.S. citizens alike. The database contains details about more than 340 million wire transfers sent via Western Union and more than two dozen other companies that immigrants rely on to send money back home.

The database contains a record of every transfer of $500 or more sent using these services to or from Mexico, Arizona, California, New Mexico, and Texas. For each transaction, TRAC captures the name and home address for both the sender and the recipient, plus dozens of other sensitive data points.

“This database is a loaded weapon lying around for the taking.”

“This database is a loaded weapon lying around for the taking,” said Nathan Freed Wessler, deputy director of the American Civil Liberties Union’s Speech, Privacy, and Technology Project, which has called for TRAC to be shut down. “This is a data collection program that disproportionately sweeps in the records of poor people and immigrants, groups that the Trump administration is going out of its way to target.”

TRAC is unusual in many ways.

The data dragnet is powered by Arizona’s state attorney general using administrative subpoenas, which do not require a judge’s sign-off. But TRAC operates as a nonprofit and a clearinghouse for ICE and hundreds of other law enforcement agencies around the country to access the data. The current Arizona attorney general, Kris Mayes, a Democrat, is aggressively suing the Trump administration on numerous fronts — yet the database is an invaluable potential resource for its anti-immigrant campaign. And despite being a target of privacy advocates and lawsuits for years, TRAC has continued to suck up data.

ICE has played an outsized role in TRAC over the years, chipping in data of its own at times. ICE agents have also been top users of the database, served on TRAC’s board, and even funded its operations.

But Mayes’s office and TRAC downplayed concerns that ICE might use the data to target immigrants for deportation. The database does not contain details about immigration status, they noted, and it’s intended exclusively to investigate money laundering along the border, which was how TRAC first started more than a decade ago. Before searching the data, agents must promise not to abuse their access and declare the “underlying predicate offense” for a given query, under an agreement Mayes’s office signed with TRAC in 2023.

“TRAC offers officials a massive grab-bag of data to root around in.”

But privacy advocates told The Intercept that TRAC has insufficient safeguards and unacceptable risks, particularly under President Donald Trump. The Trump administration has been shifting agents at ICE and other agencies away from investigating money launderers, with orders to prioritize deportations and raids. Agents who are grabbing U.S. citizens, lawful permanent residents, and visa holders off the streets on pretext; shipping people to a mega-prison in El Salvador based on “administrative errors”; and filing questionable search warrant applications might simply lie to access data that makes the deportation machine run a bit more smoothly. On Monday, ICE inked an agreement with the IRS to obtain data about undocumented workers, including their home addresses.

“The Trump administration has already shown that it is acting recklessly at best with who it deports and why,” said Abigail Kunkler, a legal fellow at the Electronic Privacy Information Center. “TRAC offers officials a massive grab-bag of data to root around in for transactions it can label suspicious, and there isn’t currently any oversight.”

“Limitless” Investigative Power

TRAC’s origin story is a testament to that familiar bipartisan itch to expand surveillance powers. Despite an early loss in state court over the dragnet, Mayes and her predecessors — one fellow Democrat and two Republicans — used settlement agreements and administrative subpoenas to build the database into a go-to resource for cops and federal agents nationwide.

It started with one subpoena to a single company. In 2006, then-Arizona Attorney General Terry Goddard, a Democrat and former mayor of Phoenix, demanded data from Western Union about all wire transfers of $300 or more to any location in the Mexican border state of Sonora from any location worldwide over a three-year period. He did this under the state racketeering law, A.R.S. § 13-2315, which requires financial institutions to produce records in response to “reasonable” requests from the attorney general’s office.

Western Union initially proposed providing partially anonymized data to protect its customers’ privacy.

This wasn’t acceptable to Goddard and a task force of federal and state agencies, which wanted as much data as possible — including about innocent customers’ transactions — to establish “control groups.”

Western Union fought the subpoena, and in 2007 a state appellate court ruled Goddard had exceeded his authority under the racketeering law. The Arizona Court of Appeals was concerned at the subpoena’s sheer breadth, especially its geographic coverage far beyond Arizona state lines, and ruled it was not “reasonable” under the law.........

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