ABSTRACT

On 3 December 1996, the U.S. Department of Justice announced that the United States would apply the Holtzman Amendment against Japanese war criminals. The Holtzman Amendment 1 provides that a person who has participated in, under the direction of the Nazi government or any other government that was an ally of the Nazi government, the persecution of any person because of race, religion, national origin, or political opinion is prohibited from entry into the United States. Additionally, the Holtzman Amendment 2 stipulates that any alien fitting the above description is deportable. 3