After decades of helping place children overseas with adoptive families in the United States, Catholic Charities of Baltimore has ended its international adoption program.

Ellen Warnock, adoption program coordinator at Catholic Charities of Baltimore, told CNA this month that multiple factors have contributed to the decision to end the program.

“It’s the capacity of the countries [to provide required documentation] on the one hand, and the willingness of our country on the other hand to believe the documentation from the sending country about the child’s orphan status,” she said.

Catholic Charities of Baltimore has facilitated adoptions for 75 years, including international adoptions for more than 40 years. During that time, it has helped nearly 3,500 children from other countries be united with families in the United States.

But international adoptions have plummeted in recent years. In the mid-2000s, about 24,000 foreign-born children were adopted each year into families in the United States. By last year, that number had dropped to below 3,000.

In some cases, this is because of internal decisions within foreign countries. Russian President Vladamir Putin signed a law in 2012 banning U.S. citizens from adopting children from Russia. Ethiopia, which once accounted for 20% of foreign adoptions by U.S. families, banned international adoptions in 2018.

But increased scrutiny from U.S. authorities has also played a role, Warnock said. She cited a shift in recent years in how the government views international adoption, although she said that the changes have not been partisan in nature.

Warnock said especially that a concern that adoption will be used for human trafficking has changed the process and requirements of international adoptions.

“The Department of State does not trust the documentation that is coming from certain countries. So they are making it very difficult to adopt from those countries,” she said.

Many children in overseas orphanages were abandoned in public places, such as train stations. Police officers take such children to orphanages, but usually without birth certificates or identifying documentation, Warnock said. The United States will not allow children to be adopted without evidence of birth that includes a birth mother’s name.

“There are countries that simply don’t have a sophisticated child welfare infrastructure,” she said. “There might be millions of children within that country who need homes, but the resources within that country to provide the appropriate documentation that our country needs before a child can immigrate, those resources are very limited.”

Many adoption advocates point to the 2014 appointment of Trish Maskew as the head of the Adoption Division in the State Department’s Office of Children’s Issues as a key turning point in the government’s stance on international adoption.

Maskew had testified before Congress that she believed insufficient regulations in the field of international adoptions had led to a climate where illegal and unethical activity was far too common.

She cited the situation in Cambodia in 2001, when officials said they had found evidence of child trafficking, with corrupt middlemen profiting from the adoption of children whose parents had not consented to them being adopted. In some cases, the birth parents had left the children at an orphanage temporarily with plans to recover them when their financial situation improved, while the adoptive families were unaware that the children were not actually orphans.

Advocates of reform say the Cambodia crisis shows a need for greater regulation of the international adoption process, while many adoption advocates say there is no evidence that trafficking is widespread, and existing international standards are sufficient to prevent potential abuse. They also warn that children living in orphanages face significant risks of trafficking and abuse in their own countries.

Under Maskew’s leadership, the State Department proposed new regulations, including a new “country-specific authorization,” increased training requirements for adoptive parents, and additional oversight of adoption agencies and the service providers they work with during the adoption process.

In late 2017, the Council on Accreditation announced that it was withdrawing from its role as the sole U.S. international adoption accrediting entity. The council cited new requirements at the State Department which it saw as being “inconsistent with [its] philosophy and mission.”

A new accrediting organization was created – the Intercountry Adoption Accreditation and Maintenance Entity (IAAME) – which began implementing new regulations and fees.

IAAME maintains that ensuring compliance with federal regulations is necessary to ensure that adoptions are conducted ethically.

“There have been instances of trafficking of children within intercountry adoptions,” IAAME Executive Director Kim Loughe told CNA.

“With the safety of children, adoptive families, and biological parents as our top priority, IAAME works with adoption service providers to ensure intercountry adoptions take place in the best interest of children,” she said.

“In doing so we work to prevent the abduction, exploitation, sale, or trafficking of children.”

However, critics argue that the regulations are so strict that they impose unrealistic burdens on other countries, and fail to accommodate for their lack of resources to meet these requirements.

In some countries, such as Nigeria, birth certificates are not created until they are needed for legal purposes. A Nigerian birth certificate, not registered at the time of birth, is disallowed by U.S. regulations, despite the explanation given for discrepancy, Warnock said.

“They’re imposing U.S. standards on countries that don’t have those kinds of practices in place. How can families meet that requirement? They can’t. And then they’re stuck,” she said.

Warnock acknowledged that there could be better educational outreach for some facilities that do not have a good record-keeping system.

“We would hope that record-keeping would be better [in some of the international orphanages], but there is still no evidence that, despite certain gaps in the record-keeping, that children are being trafficked,” she said.

“I also know that these orphanages are just struggling to make ends meet,” she said. “And for them to hire the administrative or social work staff to meet the enormous amount of bureaucratic requirements, it would be impossible.”

A State Department official told CNA that intercountry adoption is a high priority for the department, but preventing harm and corruption is an essential part of working to support adoption.

The official noted that the department’s Office of Children’s Issues created a bilateral engagement division earlier this year to focus on relationships with foreign partner nations and expanding intercountry adoption opportunities. In July, the department announced that it had begun discussions with Vietnam on a plan to expand adoptions by U.S. families, which are currently only permitted for children with special needs, children over age 5, and sibling groups.

For Warnock, the bottom line is that children’s needs are going unmet.

“The real struggle for Catholic Charities and for the agencies that are left is that the children we are placing are really children who desperately need with significant issues, children who are coming from really challenging backgrounds, and more and more agencies are being closed.”

Catholic Charities of Baltimore nearly ended its program several years ago, after years of watching international adoptions drop, Warnock said.

But then Nigerian-American families began to contact them and ask for help adopting. The families – U.S. citizens who had immigrated from Nigeria – were hoping to adopt from their home country.

“We stepped up to that challenge,” Warnock said. Catholic Charities hosted conferences in Nigeria, and met with government ministries, American embassy personnel, judges and orphanage directors. It became one of the few agencies that worked with Nigerian-American families in the United States. Over the course of four years, it helped place hundreds of children with adoptive families.

As the agency’s Nigerian adoption program got underway, an uptick in visa approvals attracted the attention of IAAME and the State Department, which determined they could not rely on the accuracy of documents from Nigeria, Warnock said. Families started getting denied at the embassy level, after having completed the adoption process and receiving U.S. immigration approval. Then in April the State Department and IAAME contacted Catholic Charities of Baltimore and instructed the agency to cease its work in Nigeria.

“That has had a domino effect on our other programs,” Warnock said. “Because even though we didn’t get any complaints about any of our other programs, those other programs were so small – the Philippines and Colombia – that they could not sustain our work. There’s a certain level of work that you have to do to be financially sustainable and the work that we’re doing in Colombia and the Philippines now is a victim of the action the IAAME took against us about Nigeria.”

For families whose adoptions were already well underway, the news that their adopted children cannot enter the United States is crushing, Warnock said.

About 30 families working with Catholic Charities of Baltimore have already finalized the adoption process and were waiting on the immigration paperwork to be approved by the embassy so their children could enter the United States.

In many cases, the children had already left the orphanages where they were staying and were expected to join their families in the United states. To be denied by the embassy in the very final stages of the long and exhausting process is devastating, Warnock said. Some families are now hiring lawyers or contacting their lawmakers as they desperately attempt to be united with their children.

“Those families are a wreck,” she said. “The parents are hysterical - this is their daughter, this is their son.”

As Catholic Charities of Baltimore ends its international adoption program – the domestic adoption program was shut down several years ago due to decreasing numbers of adoptions –  Warnock will now oversee a small amount of post-adoptive work for the agency.

This includes help connecting adoptees – both foreign-born and domestic – with their birth parents, and referrals for counseling or other services, sometimes decades after an adoption takes place.

Warnock said she is grateful that Catholic Charities will be continuing to offer these limited services, despite the fact that they do not bring money into the agency. She said the post-adoptive work is a way for the agency to show that it is still committed to the work that it began 75 years ago.

“We can’t walk away from that legacy,” she said.