The petitioners, Luis Ernesto Bonilla (Bonilla) and Judith Mercado Bonilla (Mercado), are Colombian nationals. They seek judicial review of a final order of the Board of Immigration Appeals (BIA) denying their application for asylum, withholding of removal and relief under the Convention Against Torture (CAT). Mercado’s application is derivative and thus, its success depends on the success of Bon-illa’s application.
See Ang v. Gonzales,
I.
Bonilla and Mercado entered the United States on or about October 24, 2002 as non-immigrant visitors with authorization to remain in the United States up to six months. After six months, instead of returning to Colombia, Bonilla filed an application for asylum, withholding of removal and CAT relief. The Department of Homeland Security (DHS) subsequently served Bonilla with a Notice to Appear in May 2004, charging him with being removable under 8 U.S.C. § 1227(a)(1)(B). Bon-illa conceded removability.
At his hearing before an immigration judge (IJ), Bonilla testified about the events in Colombia that formed the basis for his claims. Prior to entering the United States, Bonilla was a businessman in the city of Barranquilla, Colombia. He owned a food store and lived in an apartment above the store. Bonilla was involved in politics in Colombia, supporting the Liberal Party and hosting meetings in support of Liberal candidates in his store. In 2002, Bonilla supported the Liberal Party’s candidate for president, Alvaro Ur-ibe Vélez. It was during the run-up to the May 2002 presidential election that Bonilla began receiving anonymous threats. In January 2002, Bonilla received a threatening phone call at his store. The caller told him that he and his family would be killed for his support of Uribe. Bonilla received similar phone calls over the next few months. At times he would receive one or two calls a day, at other times two or three calls a week. At the end of March, Merca *75 do answered the phone and was told that the family would be killed for their political support of Uribe. Following this incident, Bonilla told the rest of his family about the threats and changed his phone number. In July 2002, he rented out his store to another businessman but continued to live above the store.
Bonilla succeeded in putting a stop to the threatening phone calls by changing his number, but in September 2002 he found a threatening letter outside his apartment. Although the people responsible for the phone calls had not identified themselves, the letter was from the gueril-la group the Revolutionary Armed Forces of Colombia (FARC). In the letter, FARC stated that it had been unable to contact Bonilla by phone after he changed his number and so it had “decided to change the rules of the game.” Because he had ignored the telephone warnings and had supported Uribe, FARC declared Bonilla to be a military target. That same month, Bonilla traveled to Venezuela. He had received a Venezuelan resident stamp in his passport in 1997 and subsequently had traveled to Venezuela a number of times on business, since he owned a cattle ranch in that country. On this trip, Bonilla sold his cattle ranch and deposited the proceeds of the sale in a bank in Venezuela.
On October 4, 2002, after returning to Colombia, Bonilla filed a complaint with the district attorney to report the threats against his family. Bonilla and his wife left Colombia for the United States on October 24th. In March 2003, graffiti with the FARC logo was sprayed outside the entrance of Bonilla’s former store.
On May 3, 2006, the IJ denied Bonilla’s application for asylum, withholding of removal and CAT relief. The IJ concluded that Bonilla had been “firmly resettled” in Venezuela prior to entering the United States and had chosen to sever his connections with that country in order to come to the United States. Because firm resettlement is a mandatory bar to asylum, the IJ denied Bonilla’s asylum claim. The IJ also explained that even if Bonilla were eligible for asylum, he had not established a well-founded fear of persecution should he return to Colombia.
With respect to Bonilla’s claim for withholding of removal, the IJ considered whether Bonilla had shown that it was more likely than not he would face persecution if he returned to Colombia. The IJ reasoned that the evidence of past threats did not establish a likelihood that FARC would carry out its threats against Bonilla, citing the fact that one of Bonilla’s sons continues to live in his former apartment as evidence that it was unlikely that FARC would carry out its threats should Bonilla return to Colombia. Finally, the IJ denied Bonilla’s application for CAT relief, reasoning that Bonilla had not shown that he would be subjected to torture should he return to Colombia or that the Colombian government would inflict or acquiesce in his torture.
Bonilla appealed the IJ’s decision, asserting that the evidence in the record showed that he had endured past persecution, that the IJ erred in finding that the Venezuelan resident stamp triggered the firm resettlement bar to asylum and that he had a valid fear of future persecution in Colombia. On April 30, 2007, the BIA affirmed the IJ’s decision. The BIA supported the IJ’s conclusion that Bonilla had been firmly resettled in Venezuela and upheld the IJ’s finding that Bonilla was ineligible for withholding of removal. Bonilla appeals this decision. 1
*76 II.
We deferentially review the agency’s findings of fact under the “substantial evidence” standard.
Sunoto v. Gonzales,
A. Withholding of Removal
In order to establish eligibility for withholding of removal, an applicant must establish that if he is removed, “he is
more likely than not
to face persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.”
Salazar v. Ashcroft,
The BIA affirmed the IJ’s denial of withholding of removal, concluding that Bonilla had not established that it was more likely than not that he would be harmed if he returned to Colombia. The BIA only expressly mentioned past persecution in its discussion of Bonilla’s asylum claim, stating that “[s]ince a finding of firm resettlement is a bar to asylum, we need not address whether the respondent established that he experienced past persecution in Colombia.” Bonilla contends that the agency erred in failing to determine whether the evidence established past persecution. An agency must make findings “on all grounds necessary for decision.”
Un v. Gonzales,
It is true that the BIA stated that its conclusion about firm resettlement made consideration of Bonilla’s past persecution claim unnecessary. However, in affirming the IJ’s denial of withholding of removal, the BIA stated that it found “no error on the part of the Immigration Judge in finding the respondent ineligible for withholding of removal,” and cited portions of the IJ’s opinion. In those portions of the IJ’s opinion, the IJ had observed *77 that the threats against Bonilla were not “escalating,” and that Bonilla had stopped receiving threatening phone calls after he changed his phone number. The IJ also stated that “[n]obody ever came to his store looking for him. Nobody ever came to his home looking for him. And approximately September of 2002[sic] he did receive a letter, but no other action was ever taken against him or any other member of his family.” Summing up the evidence that Bonilla had presented, the IJ concluded that Bonilla had failed to show it was more likely than not that FARC would carry out its threats against him because no harm befell him “other than receiving phone calls, one letter, and a graffiti on the security gate to his store,” and “[h]is freedom in Colombia other than not hanging out in front of his store and not operating the store itself does not appear to have otherwise been curtailed by his fears of harm.”
These statements do not represent an express finding that Bonilla did not endure past persecution, but an express finding is not required where it is evident from the IJ’s opinion that she considered the evidence presented and concluded that the petitioner’s experiences do not amount to persecution.
See Waweru v. Gonzales,
Bonilla also urges us to find that the agency erred in concluding that he did not suffer past persecution. Our review of the agency’s finding is quite deferential, and we will reverse only if “the evidence he presented was so compelling that no reasonable factfinder” could conclude that he did not suffer past persecution.
Fesseha v. Ashcroft,
B. Asylum,
To be eligible for a discretionary grant of asylum, an applicant must prove that she is a “refugee” within the meaning of the Immigration and Nationality Act. 8 U.S.C. § 1158(b)(1). The Act defines a “refugee” as one who is “unable or unwilling to return to ... [his] country because of persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.” 8 U.S.C. § 1101(a)(42)(A). An asylum applicant can meet her burden of proof either by showing that she suffered past persecution on account of a protected ground, or by proving that she has a genuine and objectively reasonable fear of future persecution.
Journal v. Keisler,
[10] Asylum is not available to an alien who was firmly resettled in another country before entering the United States. 8 U.S.C. § 1158(b)(2)(A)(vi); 8 C.F.R. § 208.15. “The firm-resettlement bar to asylum ensures that ‘asylum is not granted to aliens who have found a haven from persecution’ elsewhere.”
Sultani v. Gonzales,
(a) That his or her entry into that country was a necessary consequence of his or her flight from persecution, that he or she remained in that country only as long as was necessary to arrange onward travel, and that he or she did not establish significant ties in that country; or
(b) That the conditions of his or her residence in that country were so substantially and consciously restricted by the authority of the country of refuge that he or she was not in fact resettled. In making his or her determination, the asylum officer or immigration judge shall consider the conditions under which other residents of the country live; the type of housing, whether permanent or temporary, made available to the refugee; the types and extent of employment available to the refugee; and the extent to which the refugee received permission to hold property and to enjoy other rights and privileges, such as travel documentation that includes a right of entry or reentry, education, public relief, or naturalization, ordinarily available to others resident in the country.
[11] The government bears the initial burden of showing firm resettlement.
Salazar,
*79 The agency based its firm resettlement determination in part on Bonilla’s testimony that when he entered Venezuela in September 2002, he would have been allowed to live there because he had “the resident visa.” 2 The agency focused on the following exchange between a government attorney and Bonilla:
Q: Sir, were you allowed to live in Venezuela?
A: Yes, because I entered there as a businessman.
Q: And when you went in 2002 in September could you have remained there and lived there at that time?
A: No, because the borderline is a very long wide line, 1200 kilometers and the people are switching from one side to the other side.
Q: Legally, would you have been allowed to live there?
A: Yes, because I got the resident visa. Q: And why didn’t you stay in Venezuela?
A: Because these people cross the border through the mountain side and they come wherever you — they can find you.
Although the agency cited this exchange as evidence that Bonilla had an offer of permanent residence from Venezuela, we do not think it clearly establishes this point. Bonilla stated that he could have lived in Venezuela at the time he entered that country, i.e., in September 2002, prior to the expiration of his resident stamp. His answers do not show that he had an offer to remain in that country indefinitely.
The resident stamp in Bonilla’s passport, which Venezuela honored several times when Bonilla traveled to Venezuela between 1997 and 2002, constitutes stronger evidence of an offer of permanent residence. In
Salazar,
we upheld a finding of firm resettlement where the petitioner, a native and citizen of Peru, had a Venezuelan passport with a resident stamp and had been readmitted to Venezuela as a resident on two occasions.
As an initial matter, there is no evidence in the record that Bonilla ever lived in Venezuela and it seems somewhat unusual to conclude that someone has been “firmly resettled” in a country when there is no evidence that he ever resided there. Indeed, in the present case there is every indication that Bonilla maintained his principal place of residence in Colombia until his departure in October 2002. Many cases involving the firm resettlement bar to asylum have involved petitioners who have resided for a substantial period of time in a third country without receiving an official offer of permanent residence, and courts have struggled to determine whether the circumstances suggest that the petitioner had an implicit offer of permanent refuge.
See, e.g., Sall v. Gonzales,
The present case represents the converse of these cases: we are presented with a document that may represent a formal offer of permanent residence, but there is no evidence in the record that Bonilla ever lived in Venezuela. Of course, the regulation does not require that the alien have lived in a country in order to be firmly resettled. The regulation requires only that the alien have been offered permanent refuge by a third country prior to entering the United States in order for the mandatory bar to apply. This makes sense when we consider the purpose of the firm resettlement bar, which is to prevent “country shopping” and to preserve asylum only for those applicants who do not have safe refuge elsewhere.
See Sail,
Bonilla argues that because his Venezuelan resident permit expired on September 20, 2002- — approximately one month before he entered the United States — the agency erred when it found that he had been firmly resettled prior to his arrival in the United States. But the language of the regulation requires only that “prior to arrival in the United States” an alien “enter[ ] into another country with, or while in that country receive! ], an offer of permanent resident status, citizenship, or some other type of permanent resettlement.” 8 C.F.R. § 208.15 (emphasis added). It does not require that the alien have an offer of permanent residence at the time he enters the United States. Bonilla entered Venezuela in September 2002 — prior to his entry into the United States — with a resident stamp. If that stamp represented an offer of permanent residence, he falls squarely within the scope of the regulation.
On its face, the regulation clearly focuses on whether an asylum applicant has received an offer of
permanent
resettlement.
See Maharaj v. Gonzales,
However, in the present case, we are confronted with the question whether the resident stamp is sufficient to represent an offer of permanent residence. We simply do not have evidence of the significance of a five-year resident stamp from Venezuela. It may be that renewing the resident stamp is an administrative requirement as routine as renewing one’s passport, and that Bonilla was entitled to maintain his resident status permanently as long as he renewed it. If this is the case, then the firm resettlement bar should apply.
See, e.g., Elzour v. Ashcroft,
Other courts confronted with ambiguous immigration documents from third countries have remanded the case for further development of the record.
See Maharaj,
The course followed by these courts seems a prudent one in light of the severe consequences of a finding that Bon-illa had firmly resettled. We note that in the present case, the IJ stated that even if Bonilla were not barred by a finding of firm resettlement, she did not believe that Bonilla had established a well-founded fear of persecution, “that is, at least a 10 percent chance that harm would actually be inflicted on him.” Although Bonilla has not contested this alternative basis for denying his asylum claim before this court, the BIA did not address the IJ’s alternative ground for denying asylum. When the BIA does not consider an IJ’s alternative ground for denying relief, that ground
*82
is not before us.
INS v. Ventura,
Bonilla did not explicitly challenge the IJ’s alternative finding before the BIA. In his notice of appeal, he presented a brief challenge to the IJ’s decision, which included an assertion that he and his wife “have a valid fear of future persecution” should they return to Colombia. But the BIA decision suggests that the Board discerned the scope of Bonilla’s appeal. The BIA acknowledged that in his appeal, Bon-illa contended that he had a well-founded fear of persecution and that the IJ erred in denying him relief. But the BIA did not make a finding as to the reasonableness of the IJ’s alternative reason for denying Bonilla asylum, focusing its discussion on the IJ’s conclusion that Bonilla was firmly resettled in Venezuela prior to coming to the United States. Its statement that it did not need to consider Bonilla’s past persecution argument suggests that the Board did not feel compelled to consider the merits of Bonilla’s asylum claim once it had determined that he satisfied the firmly resettled bar to asylum. Even though the BIA concluded that Bonilla did not satisfy the standard for withholding of removal, the standard for establishing eligibility for asylum is a less stringent one.
Tota v. Gonzales,
Although Bonilla’s appeal to the BIA was, to put it mildly, short on analysis, we have treated asylum applicants’ arguments before the BIA generously.
Sunoto,
We thus remand for further proceedings consistent with this opinion. On remand, Bonilla and DHS should be afforded the opportunity to supplement the record with evidence bearing on whether the five-year resident stamp represents an offer of permanent resettlement. We note that the government bears the initial burden of showing that Venezuelan law supports application of the firm resettlement bar.
See Abdille,
*83 III.
We conclude that the agency’s determination that Bonilla had an offer of permanent residence in Venezuela lacks support. We grant the petition and remand for investigation into the significance of Bonilla’s five-year resident stamp under Venezuelan law.
PETITION GRANTED.
Notes
. Bonilla’s CAT claim is not before us. He failed to exhaust his administrative remedies with respect to CAT relief by failing to identify any error in the IJ’s denial of CAT relief in his
*76
Notice of Appeal filed with the Board.
See Un v. Gonzales,
. By resident visa, Bonilla was apparently referring to the resident stamp in his passport.
. In
Salazar,
we noted that some courts have held that the government may make its initial showing by " 'non-offer-based elements,' such as the alien’s establishment of significant familial or business ties or the prolonged duration of the alien's residence in the resettlement country without any government efforts to deport him.”