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8.15.1 Registration of Detainees. The detaining authority should register detaineespromptly. 111 Detainees should be registered within a reasonable time, taking into account otheressential tasks and resource limitations that may affect the detaining authority’s ability to registerdetainees. 112Registration of detainees assists in ensuring that all detainees can be accounted for andthat allegations of illegal detention can be addressed. 113 DoD practice has been to registerdetainees with the National Detainee Reporting Center that is also used to account for thedetention of POWs under the GPW and protected persons under the GC. 1148.15.2 Records of Detainee Property. DoD practice has been for property in thepossession of detainees to be inventoried, and for records of such property to be maintained inorder to maintain accountability of it (e.g., to prevent theft) and to ensure its lawfuldisposition. 115111 See Chairman’s Commentary to the Copenhagen Process: Principles and Guidelines 8 (“Persons detained areto be promptly registered by the detaining authority.”). For example, DOD DIRECTIVE 2310.01E, DoD DetaineeProgram, 3d (Aug. 19, 2014) (“Detainees will be registered, and property in their possession will be inventoried.Records of their detention and such property will be maintained according to applicable law, regulation, policy, andother issuances. (1) DoD Components will maintain full accountability for all detainees under DoD control.Detainees will be assigned an Internment Serial Number (ISN) normally within 14 days after their capture by, ortransfer to, the custody or control of DoD personnel, barring exceptional circumstances.”); DOD DIRECTIVE2310.01E, The Department of Defense Detainee Program, 4.4.1 (Sept. 5, 2006) (“Detainees shall be assigned anInternment Serial Number (ISN) as soon as possible after coming under DoD control, normally within 14 days ofcapture. DoD Components shall maintain full accountability for all detainees under DoD control.”).112 See also Chairman’s Commentary to the Copenhagen Process: Principles and Guidelines 8.3 (“It is difficult toprovide a precise time limit to indicate when a detainee should be registered. Operational necessities or resourceconstraints, such as force protection, or the limited availability of interpreters sometimes make it difficult to registera detainee at the precise moment of detention. The term ‘promptly’ is used to suggest that detainees should beregistered within a reasonable time, taking into account other essential tasks and resource limitations that may affectthe detaining authority’s ability to register detainees.”).113 See Chairman’s Commentary to the Copenhagen Process: Principles and Guidelines 8.1 (“Registration ofdetainees assists in ensuring that all detainees can be accounted for and that allegations of (illegal) detention can beaddressed.”).114 For example, Declaration of Vice Admiral Robert S. Harward, 8 (Dec. 17, 2010), attached to Hamidullah v.Gates, Response to Order to Show Cause and Motion to Dismiss, Civil Action No. 10-CV-758 (D.D.C. Dec. 17,2010) (“DoD has registered individuals held under its control at the DFIP with the National Detainee ReportingCenter (‘NDRC’) -- which accounts for persons who receive Internment Serial Numbers issued by DoD while inDoD’s custody -- and with the International Committee of the Red Cross (‘ICRC’).”). Compare § 9.31.4 (U.S.Practice in Reporting to the ICRC Central Tracing Agency); § 10.31.4 (U.S. Practice in Reporting to the ICRCCentral Tracing Agency).115 Compare § 9.7.4 (Money and Articles of Value); § 10.19.1 (Money and Valuables in the Internee’s Possession).507

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