A look at the US government's growing use of facial recognition, including contracts at agencies like the FBI and ICE with Clearview AI, Trust Stamp, and others
Context & Ripple Effects
This report lands after a year of audits trying to map the same terrain: in mid-2021 the GAO counted facial recognition in use across most surveyed agencies — 20 of 42 federal agencies in June, then 19 of 24 by August — while leaked Clearview AI data showed five agencies, including the IRS and TSA, that the GAO had missed. What those snapshots lacked was the contracting layer; this piece names it.
The significance is that informal or untracked use is hardening into paid relationships: the FBI holds contracts with Clearview AI and ICE with Trust Stamp, converting what leaked data showed as scattered adoption — 1,803 taxpayer-funded organizations using Clearview AI, often without leadership knowing — into budgeted, documented procurement.
First-order effects
- Clearview AI and Trust Stamp now have recurring federal revenue through the FBI and ICE respectively, insulating both vendors from the reputational pressure and local bans that have hit their law-enforcement customer base elsewhere.
- Agency leaders gain a paper trail they previously lacked: contracted use is auditable in a way the unauthorized officer-level usage documented in the Clearview leak was not.
Second-order effects
- Other biometric vendors get a procurement template — Trust Stamp's ICE contract shows smaller firms, not just Clearview, can win federal identity work — intensifying competition for agency budgets.
- Oversight bodies face a moving target: each audit cycle has undercounted actual use, so Congress and inspectors general must shift from surveying who uses the tech to auditing contract portfolios.
Third-order effects
- If contracting keeps outrunning audits, facial recognition becomes embedded in federal procurement before any governing framework exists — the stall in US and EU restriction efforts noted back in early 2020 leaves contracts as the de facto policy.
- Structurally, identity verification consolidates around a small set of commercial vendors holding multi-agency contracts, giving private companies durable leverage over how government surveillance capabilities expand.
The trend: Federal agencies are converting ad-hoc, often untracked facial recognition use into formal vendor contracts faster than auditors and legislators can map or regulate it.