CBP Did Not Effectively
Conduct International Mail
Screening or Implement
the STOP Act(REDACTED)

September 25, 2023
OIG-23-56

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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Washington, DC 20528 / www.oig.dhs.gov

September 25, 2023
MEMORANDUM FOR:

Troy A. Miller
Senior Official Performing the Duties of theCommissioner
U.S. Customs and Border Protection

FROM:

Joseph V. Cuffari, Ph.D.
Inspector General

SUBJECT:CBP Did Not Effectively Conduct International Mail
Screening or Implement the STOP Act – Law
Enforcement Sensitive

signed by
JOSEPH V Digitally
JOSEPH V CUFFARI
2023.09.21
CUFFARI Date:
14:54:35 -04'00'

Attached for your action is our final report, CBP Did Not Effectively Conduct
International Mail Screening or Implement the STOP Act – Law Enforcement
Sensitive. We incorporated the formal comments provided by your office.
The report contains five recommendations aimed at improving U.S. Customs
and Border Protection’s (CBP) international mail screening and implementationof the Synthetics Trafficking and Overdose Prevention Act of 2018 (STOP Act).
Your office concurred with four recommendations. Based on the information
provided in your response to the draft report, we consider recommendation 3
open and unresolved. As prescribed by the Department of Homeland Security
Directive 077-01, Follow-Up and Resolutions for the Office of Inspector General
Report Recommendations, within 90 days of the date of this memorandum,
please provide our office with a written response that includes your(1) agreement or disagreement, (2) corrective action plan, and (3) target
completion date for the recommendation. Also, please include responsible
parties and any other supporting documentation necessary to inform us about
the current status of the recommendation. Until your response is received andevaluated, recommendation 3 will be considered open and unresolved.
Based on information provided in your response to the draft report, we consider
recommendations 1, 2, 4, and 5 open and resolved. Once your office has fully
implemented the recommendations, please submit a formal closeout letter to us
within 30 days so that we may close the recommendations. The memorandum
should be accompanied by evidence of completion of agreed-upon corrective
actions and of the disposition of any monetary amounts.

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Please send your response or closure request to
OIGAuditsFollowup@oig.dhs.gov.
Consistent with our responsibility under the Inspector General Act, we will
provide copies of our report to congressional committees with oversight andappropriation responsibility over the Department of Homeland Security. We
will post a redacted version of the report on our website.
Please contact me with any questions, or your staff may contact Kristen
Bernard, Acting Deputy Inspector General for Audits, at (202) 981-6000.
Attachment

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LAW ENFORCEMENT SENSITIVELAW ENFORCEMENT SENSITIVEDHS OIG HIGHLIGHTSCBP Did Not Effectively Conduct International
Mail Screening or Implement the STOP Act
September 25, 2023

Why We Did
This Audit

CBP plays a critical role ininterdicting illegal drugs
entering the United States
through international mail. In
2018, Congress passed the
STOP Act. This law requires
the U.S. Postal Service to send
CBP data about packages
coming from countries outside
the United States to help CBPidentify mail that may containopioids and other illicit goods.
Our audit objective was todetermine whether CBPeffectively manages IMF
operations and the extent towhich CBP targets andinterdicts inadmissible
international mail entering theUnited States through IMFs.

What We
Recommend

We made five recommendations
to improve CBP’s international
mail screening and STOP Act
implementation.

What We Found
U.S. Customs and Border Protection (CBP) did
not consistently target for additional inspection
or evaluate potentially inadmissible international
mail entering the United States through its nine
International Mail Facilities (IMFs). Although
IMFs faced challenges targeting mail andexamining packages identified as potential
threats, CBP did not evaluate whether its
screening was effective or refer problems to
stakeholders for resolution. Additionally, CBP
did not fully meet the requirements of theSynthetics Trafficking and Overdose Prevention
Act of 2018 (STOP Act) for exempting countries
from sending advance electronic data withwaivers and evaluating the imposition ofpenalties on the U.S. Postal Service for accepting
mail without required advance electronic data.
These issues occurred because CBP did not
assign responsibility for STOP Act
implementation and monitoring, provide updated
guidance or training on targeting, collect data toevaluate mail screening, or develop a process for
issuing and reporting waivers. Without effective
screening and performance monitoring, CBP may
increase the risk of the Department admitting
dangerous goods into the United States.

CBP Response

CBP concurred with four of the fiverecommendations.

For Further Information:

Contact our Office of Public Affairs at(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov.

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Table of Contents
Background .................................................................................................... 1
Results of Audit .............................................................................................. 3
CBP Did Not Evaluate Its Mail Screening Effectiveness and Address
Advance Electronic Data Quality Issues ................................................. 4
CBP Did Not Fully Implement the STOP Act as Designed or Required ... 10
Conclusion.................................................................................................... 14
Recommendations ......................................................................................... 14
Management Comments and OIG Analysis .................................................... 15

Appendixes
Appendix A: Objective, Scope, and Methodology ................................. 18
Appendix B: CBP Comments to the Draft Report .................................. 21
Appendix C: Report Distribution .......................................................... 26

Abbreviations
AED
ATS
CBP
CCS
C.F.R.
ECD
GAO
IMF
JFK
NTC
OFO

advance electronic data
Automated Targeting System
U.S. Customs and Border Protection
Cargo and Conveyance Security
Code of Federal Regulations
Estimated Completion Date
U.S. Government Accountability OfficeInternational Mail Facility
John F. Kennedy International Airport
National Targeting Center
Office of Field Operations

U.S.C.
USPS

United States Code
U.S. Postal Service

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Background
U.S. Customs and Border Protection (CBP) plays a critical role in the Nation’s
efforts to safeguard the American public by interdicting illegal drugs entering
the United States. All classes of international mail must be presented to CBP
at the first port of entry in the United States, which is generally an
International Mail Facility (IMF) where officers inspect the mail to identify
illegal drugs and other inadmissible items. From fiscal years 2018 through2022, CBP made a total of 184,792 drug seizures across its nine IMFs.
National security and law enforcement agencies at all levels — Federal, state,
local, tribal, and territorial — work to combat drug trafficking with the goal ofprotecting Americans from dangerous drugs, including opioids, that arecontributing to record numbers of fatal overdoses in the United States.
According to a 2019 report 1 by the Council of the Inspectors General on
Integrity and Efficiency, opioids are often produced by drug traffickers overseas
and illegally trafficked into the United States across its borders or through mailor parcel delivery services.
On October 24, 2018, Congress enacted the Synthetics Trafficking andOverdose Prevention Act of 2018 (STOP Act) 2 to respond to the influx ofsynthetic opioids entering the United States through international mailshipments. The law requires the U.S. Postal Service (USPS) to collect advance
electronic data (AED) for all mail packages coming from post offices outside theUnited States and send the data to CBP. AED contains information such as
the shipper or sender, recipient, and contents. USPS also collects and sends
data about when and where each package will arrive and must update CBP if
any AED changes. 3 The STOP Act also allows the CBP Commissioner, in
consultation with USPS, to exclude countries that cannot send AED as
required; CBP calls this action a waiver and extends waivers to countries for a
year.
CBP applies a multi-layered screening process to identify packages fromcountries outside the United States that may contain opioids and other illicit
goods it has traditionally identified through x-rays or physical inspections.
Before a package arrives, CBP begins screening by using advanced data
together with targeting procedures to identify potentially illicit goods. First,
1 Combatting the Opioid Crisis: Role of the Inspector General Community, Council of theInspectors General on Integrity and Efficiency, July 2019.
2 The STOP Act is Title VIII of the Substance Use-Disorder Prevention That Promotes Opioid
Recovery and Treatment for Patients and Communities Act (SUPPORT for Patients andCommunities Act), Public Law 115–271 (2018).
3 19 Code of Federal Regulations (C.F.R.) 145.74(c) and (d)(2).

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offices outside the United States improved CBP’s targeting process. CBP foundthat targeting AED increased seizures from about 9 percent to 16 percent 4
during its pilot at New York – John F. Kennedy International Airport (JFK).
Key CBP Office of Field Operations (OFO) offices that oversee implementation of
the STOP Act and manage international mail screening operations are:•••

IMFs, which report to field offices and gather mail from USPS to target
and screen mail for admissibility.
Cargo and Conveyance Security (CCS), which manages the mail program,including policies and operational guidance. CCS officials communicate
with USPS and the U.S. Department of State to implement STOP Act
provisions.
National Targeting Center (NTC), which oversees targeting policy andmonitors national effectiveness.

During our audit, CBP operated IMFs at eight locations across the UnitedStates and its territories: Chicago, Honolulu, Los Angeles, Miami, Newark, JFK,San Juan (Puerto Rico), and St. Thomas (U.S. Virgin Islands). Before our
audit, USPS announced that it would close a ninth IMF in San Francisco by
March 2022.
We conducted this audit to determine whether CBP effectively manages IMF
operations and the extent to which CBP targets and interdicts inadmissible
international mail entering the United States through IMFs. This reportaddresses the extent that CBP targets and interdicts inadmissible mail. We
addressed CBP’s management of IMF operations in a separate report. 5

Results of Audit
CBP did not consistently target for additional inspection or evaluate potentiallyinadmissible international mail entering the United States through its nine
IMFs. Although IMFs faced challenges targeting mail and examining packages
placed on hold, CBP did not evaluate whether its screening was effective orrefer problems to stakeholders for resolution. Additionally, CBP did not fully
meet STOP Act requirements for exempting countries from sending AED withwaivers and evaluating the imposition of penalties on USPS for accepting mailwithout required AED.
4 86 Federal Register 14245, Interim Final Rule, Mandatory Advance Electronic Information forInternational Mail Shipments, March 15, 2021.
5 CBP’s Management of International Mail Facilities Puts Officer Safety and Mission
Requirements at Risk, OIG-23-48, August 31, 2023.

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These issues occurred because CBP did not assign responsibility for STOP Act
implementation and monitoring, provide updated guidance or training on
targeting, collect data to evaluate mail screening, or develop a process for
issuing and reporting waivers. Without effective screening and performancemonitoring, CBP may increase the risk of the Department admitting dangerous
goods into the United States.

CBP Did Not Evaluate Its Mail Screening Effectiveness andAddress Advance Electronic Data Quality Issues
CBP did not effectively conduct mail targeting or evaluate how effective its AED
targeting and manual screening were in identifying inadmissible mail. Further,
CBP did not properly address AED quality issues with the U.S. Department ofState and USPS to ensure compliance with requirements to transmit AED.
These problems occurred because CBP did not assign responsibility forevaluating mail screening effectiveness and monitoring and resolving AED
quality issues. CBP also did not provide updated guidance or targeting trainingor have a system of record to capture manual screening data. As a result, CBP
limited its ability to identify and seize drugs at IMFs that did not target
packages, from countries sending poor quality data, and in packages without aport code.
CBP Did Not Effectively Conduct or Evaluate Mail Screening at Its
International Mail Facilities
IMF officers faced challenges consistently targeting mail, and CBP did not takeaction to monitor AED and address inaccuracies. Additionally, CBP did notmonitor whether its mail screening activities, including AED targeting
procedures and manual screening, were effective and was unaware some IMFs
faced challenges. CBP monitored some metrics at an aggregate level, like theoverall rate at which USPS presented packages with holds to CBP, but it did
not compare data among IMFs, identify common problems, or evaluate manual
screening. According to the U.S. Government Accountability Office’s (GAO)
Standards for Internal Control in the Federal Government, management should
monitor performance measures to achieve objectives and respond to risks. 6

6 GAO-14-704G, September 10, 2014, also known as the “Green Book.”

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Advance Electronic Data Targeting
We analyzed each IMF’s ATS data for FY 2019 through FY 2021 7 and foundthat two of the nine IMFs 8 operating in this period did not place any mail on
hold, one placed limited holds in FY 2021, and one consistently had lowerthan-average rates of examining holds. CBP officials at NTC and CCS were
unaware of these targeting limitations until we shared the information during
our audit.
•

CBP officers at the San Juan and St. Thomas IMFs did not place holds
on international mail. Officers in St. Thomas demonstrated that ATS
showed zero shipments to target using the St. Thomas port code, 9 andofficers in San Juan described a similar problem.

•

CBP officers at the Honolulu IMF placed holds on 2 of 15,167 packages
with AED (or .01 percent) in FY 2021. This was a sharp decrease fromthe 669 holds placed in FY 2019 and 975 holds placed in FY 2020 at
Honolulu. Officers we interviewed at the Honolulu IMF stated that, until
April 2022, they were unaware they could target mail.

•

From FY 2019 through FY 2021, Newark examined holds at a lowerthan-average rate. As shown in Figure 2, CBP officers at the other IMFs
that conducted targeting examined an average of 88 percent of holds, 10
whereas Newark officers examined an average of 56 percent of holds.
Newark IMF had difficulty obtaining its targeted packages from USPS; forexample, officials in Newark explained that they tracked their IMF’s
targeted packages from March through April 2021 and found that USPS
did not present 45 percent of the IMF’s targeted packages.

7 In August 2022, CBP provided ATS data from FY 2018 through FY 2022. We limited ouranalysis of targeting to FY 2019 through FY 2021 because the STOP Act was signed into law in
FY 2019 and the data CBP provided did not include the fourth quarter of FY 2022.
8 Although the San Francisco IMF was closed during our audit, we obtained data from when it
was operational from FY 2019 through FY 2021.
9 IMFs enter their port codes in ATS to identify mail arriving at their ports to target.
10 We calculated the average percentage of examined holds for all IMFs except Newark, San
Juan, and St. Thomas. We did not include packages that had placeholder text listed in theport code field .

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topics such as targeting expectations or benchmarks and escalating unresolved
problems after enactment of the STOP Act in 2018. During our audit, CCS
officials said they were rewriting the handbook in response to a
recommendation DHS OIG made in a 2018 report 13 but they had notcompleted the updates.
NTC also indicated that some targeting issues may have occurred because staff
may only be searching for their IMF’s port code in ATS, rather than using othertargeting methods,
Additionally, IMF staff did not have comprehensive training foradvanced targeting. During our audit, staff at multiple IMFs stated they were
not offered or could not attend formal targeting training. We determined that
only 35 out of 292 IMF staff members (12 percent) had taken one of thetargeting training courses that NTC identified as a basic targeting course.
Manual Screening
In addition to AED targeting, CBP uses various manual screening methods,
such as x-ray scans of mail from certain countries, canine inspections, orofficer knowledge, to identify mail that may pose a threat. 14 During our site
visits, we observed IMF officers examining non-targeted mail and seizing it,
referring it to Federal partner government agencies, or returning it to thesender. Officers did not formally record their actions in a system of record
unless they seized an item. 15 Two IMFs had some ability to track otherenforcement actions for mail they did not target. Specifically, the Chicago IMF
used barcode scanners to record actions, and Newark piloted a system to track
detained and referred packages. Other IMFs did not track the results of theirmanual screening.
CBP did not track the results of non-targeted manual screening at its IMFs orevaluate the effectiveness of manual screening because it did not have aofficials said CCS has always had these responsibilities and issued the guidance to document
its responsibilities for field staff.
13 OIG-18-83, CBP’s International Mail Inspection Processes Need Improvement at JFKInternational Airport, September 24, 2018. In its response to our 2018 report, CBP originallyestimated that it would finish updating its handbook by April 30, 2019. As of May 2023, CBP,
through CCS, had not completed or issued an updated handbook and the recommendation
remains open.
14 International Mail Operations and Enforcement Handbook, U.S. Customs Service, August
2001.
15 CBP requires officers to enter exam findings into ATS, including non-seizure actions taken.
However, at the time of our audit, officers could not enter exam findings for mail without AED
due to system limitations which CBP is working to address. DHS OIG previously reported that
CBP did not record non-seizure events in OIG-22-52, DHS and CBP Should Improve Intellectual
Property Rights Management and Enforcement (July 2022).
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component-wide formal process or system to track actions that did not resultin a seizure. NTC and CCS knew that IMFs could not comprehensively monitor
performance without quality enforcement data; in January 2021 they began
exploring ATS enhancements to record enforcement actions on non-targeted
mail. As of May 2023, they had not implemented the enhancements.
CBP Did Not Address Advance Electronic Data Quality Issues
We determined several countries and USPS sent noncompliant AED to CBP,
but CBP did not address these issues. According to 19 C.F.R. § 145.74,
Mandatory Advanced Electronic Data, when AED is required for international
shipments, CBP must receive it electronicallyFigure 3. Example offrom USPS. USPS obtains the AED from post
offices outside the United States, including
Incomplete AED frommandatory fields such as name and address ofGreat Britain
the sender, name and address of the recipient,and description of package contents. The
C.F.R. further requires that USPS submit data toidentify which IMF will receive incoming
shipments and provide updates if the datachanges. USPS provides a port code to identify
the IMF.
Inaccurate Data
We analyzed ATS data and identified countries
that sent inaccurate AED from FY 2019 throughFY 2021, one example of which was GreatBritain. 16 In 2019, CBP’s Office of Information
Technology created a monthly dashboard toassess AED quality and identify countries thatsent inaccurate data. CBP’s dashboard showed
Great Britain increasingly sent invalid data 17
from FY 2019 through FY 2021, reaching a peakof 83 percent invalid data in September 2021.
IMF officers said that they faced difficulties

Source: Example provided by CBP(top) and annotated in red font by
DHS OIG (bottom)

16 AED quality includes the completeness and accuracy of the AED data transmission. In thiscase, “accuracy” refers to the extent to which recorded data reflects the actual underlying
information (e.g., the shipper’s name and address). Progress Made in Using Electronic Data to
Detect Illegal Opioid Shipments, but Additional Steps Remain, GAO, GAO-20-229R (December2019).
17 CBP experts developed criteria for evaluating whether AED was considered valid. For
example, fields with (1) “UNK,” “Unknown,” or left blank; (2) fewer than two characters total; or(3) only numeric characters in the shipper name field would be identified as “invalid.”

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targeting mail from Great Britain because the AED for these packages was
inaccurate. The top photo in Figure 3 is a screenshot from ATS that a CBP
officer showed us as an example of data Great Britain sends; fields contain theword “Unknown.” We annotated the bottom photo to show which shipper
information should have been in those fields.
A CCS official stated they received the dashboard but did not find a need toshare it with USPS or the U.S. Department of State because they were notaware of any issues. The same CCS official stated they were unaware of the
upward trend in invalid data from Great Britain. In January 2023, CCS asked
three IMFs to add Great Britain to their list of requested countries for
additional screening. CCS did not refer the issue to USPS or the U.S.
Department of State. As a result, neither agency could inform its British
counterpart of the potential noncompliance with AED requirements and work
toward a resolution.
Missing Port Codes
Based on our analysis, USPS did not update the port code to show where a
package would arrive for 11 percent of all shipments with AED from FY 2019
through FY 2021. This equates to approximately 75 million of 671 million
shipments with AED. According to an NTC official, all mail packages initiallyhave placeholder text that reads
in theAED port code field in ATS until USPS enters a code for the IMF where thepackage will arrive. However,
was the fourth most frequent entry in the
AED port code field for FY 2019, fifth most frequent for FY 2020, and second
most frequent for FY 2021. This is problematic because CBP placed holds on
packages withas the port code 41 times less than the average rate itplaced holds on packages arriving with a known port code in FY 2021. 18
Even when CBP officers did place holds on packages listing
as the port
code, they examined them less frequently than those that had a port code. As
shown in Figure 4, IMFs examined an average of 34 percent of holds listing theport code from FY 2019 through FY 2021. By comparison, IMFs
examined an average of 84 percent of holds that had a real port code in the
AED. 19
18 We calculated the average percentage of AED holds placed for all IMFs and compared it to

the percent of AED holds for packages that had
listed as the port code. We did notinclude San Juan and St. Thomas because these IMFs did not place holds on any packages
from FY 2019 through FY 2021.
19
We calculated the average percent of examined holds for all IMFs and compared it to theaverage percent of examined holds for
We did not include San Juan and St. Thomas
because these IMFs did not place holds on AED from FY 2019 through FY 2021.
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a penalty on USPS for accepting packages without AED as required by the
STOP Act. These problems occurred because CBP did not formally assign
responsibility for implementing the STOP Act, and CCS did not establish aprocess to fully address STOP Act requirements, such as developing andreporting its AED waiver lists. Additionally, officials did not believe it waspossible or necessary to penalize USPS. As a result, CBP could not ensure it
fully met the STOP Act requirements.
CBP Did Not Document and Report Waivers or Require Alternate
Screening
The STOP Act allows the CBP Commissioner, under certain conditions, toexclude a country from the requirement to send AED. 20 We determined CCS
did not follow STOP Act requirements for issuing and reporting its waivers toCongress on an annual basis. CCS also did not define or require alternate
screening and did not transmit thewaiver lists to the IMFs.
The STOP Act allows the CBPCommissioner to grant a waiver if a
Issuance and Reporting of Waivers
country:
CCS did not obtain approval from the
1. does not have the capacity to collect
CBP Commissioner when it issued
and transmit AED;
waivers exempting 148 countries in
2. represents a low risk for mail2021 and 128 countries in 2022. A CCS
shipments that violate relevant U.S.
official said that OFO leadershiplaws and regulations; andinformally tasked them with drafting the
3. accounts for low volumes of mailinterim final rule that specified
regulatory requirements to implement
shipments that can be effectively
the STOP Act, but they were not formallyscreened for compliance withassigned responsibility for otherrelevant U.S. laws and regulations
implementation tasks. After writing thethrough an alternate means.
rule, CCS assumed the responsibility to
implement CBP’s part of the STOP ACT
Source: 19 U.S.C. § 1415(a)(3)(K)(vi)(II)but did not receive delegated authority
to issue waivers on behalf of the Commissioner. Instead, CCS used an
unsigned template of a blank waiver letter on USPS letterhead as its
documentation.
Additionally, CBP did not document its justifications for excluding a country
from AED requirements and did not report the justifications to congressional
committees. The STOP Act requires CBP to annually provide appropriate
20 19 United States Code (U.S.C.) § 1415(a)(3)(K)(vi)(II)-(IV).

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congressional committees 21 with a list of countries that received a waiver,along with information used to support the determination for each country. A
CCS official acknowledged that CBP did not assign responsibility andoverlooked the STOP Act requirement to record justifications and transmit
them to congressional committees annually.
Although the CBP Commissioner was responsible for issuing waivers, a CCS
official said they relied on USPS to maintain a comprehensive waiver list andinformation used to determine a country’s waiver eligibility. Additionally, CCS
reported collaborating with the U.S. Department of State to determine acountry’s capacity to collect AED and with USPS to determine its volume of
shipments but did not document the justifications for issuing waivers as partof this collaboration. CCS provided documentation showing that it transmitted
one list of waiver countries without justifications to the Senate Committee on
Homeland Security and Governmental Affairs in 2021 upon request for abriefing. CCS could not provide justifications for its lists from 2021 through2023, or documentation that it had transmitted the 2022 or 2023 lists to theappropriate congressional committees.
Risk Evaluation
CCS did not use internal CBP data, including seizure and ATS information, toassess each waiver country’s risk level more accurately. Instead, CCS chose toreference two Federal lists of countries (1) sponsoring terrorism or (2)producing or shipping narcotics. 22 Had CBP supplemented the Federal lists
with its own data, it would have learned that in 2021 it granted waivers to
three countries that fell within the top 15 countries for mail seizures during FY
2020. After we presented this information to CBP, CCS said it began using
seizure data when considering which countries would receive waivers in 2023.
CCS did not incorporate CBP data into its assessment because CBP did notestablish a process specifying that CBP data should be used to assess acountry’s risk eligibility when granting AED waivers.
Alternate Screening
CBP did not define or require an alternate means of screening mail fromwaivered countries or ensure that all IMFs conducted alternate screening of
21 The STOP Act defined appropriate congressional committees as follows: the Committee on
Finance and the Committee on Homeland Security and Governmental Affairs of the Senate;
and the Committee on Ways and Means, the Committee on Oversight and Government Reform,
and the Committee on Homeland Security of the House of Representatives.
22 CBP relied on the U.S. Department of State’s State Sponsors of Terrorism List and the Officeof National Drug Control Policy’s list of countries that ship or produce narcotics.

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mail from such countries. The STOP Act allows waivers if a country accounts
for a low volume of mail and if that mail can be effectively screened through analternate means. Even if CBP had defined alternate screening, IMFs would nothave been able to ensure countries granted waivers could be screened throughan alternate means because CCS did not send its 2021 waiver list to the IMFs
and sent the 2022 waiver list after our audit began in April 2022. This meansthat from January 2021 through April 2022, the IMFs did not know whichcountries had received waivers. As of January 2023, CBP had not transmitted
the 2023 waiver list to any IMFs.
This occurred because CBP did not assign responsibility for implementing
routine, alternate screening for mail from countries with AED waivers. CCS
also overlooked the STOP Act specification that CBP may issue waivers whenalternate screening can be implemented. CCS was not sure it had authority torequire alternate screening at IMFs. Once we raised this section of the STOP
Act with CCS, one CCS official we interviewed said alternate screening would
be unnecessary because IMFs already manually screen incoming packages.
This includes using canine inspections, local intelligence, and a country ofinterest list. Contrary to this statement, not all IMFs manually screen 100
percent of their inbound mail. 23 According to JFK and Chicago IMF officials,
their facilities manually screen only a selection of mail. Therefore, the IMFs’
current manual screening process does not negate the need for alternate
screening of mail from waivered countries.
CBP Did Not Evaluate Imposing STOP Act Penalties
Although USPS accepted packages without AED, CBP did not evaluate whether
to impose any penalties on USPS in accordance with the STOP Act. The STOP
Act requires USPS to be penalized if it does not refuse packages that are
missing AED. In its notice of proposed rulemaking, CBP stated it planned touse “flexible enforcement” and show restraint in enforcing AED requirements
against USPS for 12 months after the effective date of the rule, which was
March 15, 2021. 24 CBP could not provide evidence as to how it evaluatedapplying flexible enforcement. As of January 2023, it had not penalized USPS
for packages that were missing AED.
This occurred because CBP did not assign responsibility for CCS to enforce
penalties when USPS accepts mail without AED. CCS did not establish a
23 The mail handbook from U.S. Customs Service indicates that intensive examinations of mail,such as x-ray aids, should be determined based on intelligence or trends, but does not require
all mail to be manually x-rayed or intensively examined.
24 86 Federal Register 14245, Interim Final Rule, Mandatory Advance Electronic Information forInternational Mail Shipments, March 15, 2021.

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framework for evaluating and issuing penalties because officials did not believe
it was possible or necessary to penalize USPS. A CCS official said USPS was“100 percent compliant” with the STOP Act and cooperated with CCS on STOP
Act enforcement. Even though USPS cooperated with CBP, the STOP Act stillrequires CBP to penalize USPS for accepting mail without AED and further
grants authority for CBP to reduce or dismiss the penalty if USPS is
cooperating with CBP with respect to violations. 25 CBP did not evaluate
imposing, reducing, or dismissing penalties as per the STOP Act.

Conclusion
To increase seizures of illegal opioids and other inadmissible goods, CBP must
be able to consistently target and evaluate international mail entering theUnited States through IMFs. By not effectively conducting and evaluating its
screening operations, addressing AED quality issues, or fully implementing the
STOP Act, CBP limited its ability to identify new threats in the mailenvironment. Finally, by not using its internal data to evaluate the risk before
granting a waiver, CBP may inadvertently grant AED waivers to high-riskcountries.

Recommendations
Recommendation 1: We recommend that CBP’s Office of Field Operations
assign responsibility for ensuring STOP Act implementation, including:a. monitoring and resolving advance electronic data quality and quantity
issues;b. documenting justifications for advance electronic data waivers;c. providing lists of advance electronic data waivers to International Mail
Facilities and implementing routine, alternate screening for mail fromcountries with advance electronic data waivers; andd. enforcing penalties when the U.S. Postal Service accepts mail without
advance electronic data.
Recommendation 2: We recommend that CBP’s Office of Field Operations
implement a mechanism for all International Mail Facilities to record
enforcement actions other than seizures.

25 19 U.S.C. §1436(e)(2)(A).

The STOP Act allows CBP to reduce or dismiss a penalty if it
determines that USPS (1) has a low error rate in complying with the STOP Act at 19 U.S.C.
§ 1415(a)(3)(K), (2) is cooperating with CBP with respect to violations, or (3) has taken remedialaction to prevent future violations.

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Recommendation 3: We recommend that CBP’s Cargo and Conveyance
Security update the International Mail Operations and Enforcement Handbook,dated August 2001. At a minimum, updates should include:a. clearly defined roles and responsibilities for monitoring performanceacross International Mail Facilities; andb. key performance metrics and targeting goals to assess the effectivenessof mail operations.
Recommendation 4: We recommend that CBP’s National Targeting Center
provide Automated Targeting System training to officers assigned toInternational Mail Facilities, including on how to place targeted holds on mailand how to target mail without an identified port code.
Recommendation 5: We recommend that CBP’s Office of Field Operations
establish and implement a process for:a. developing advance electronic data waivers using CBP data to assess acountry’s risk eligibility;b. documenting justifications for waiver countries; andc. reporting advance electronic data waivers and justifications to Congress.

Management Comments and OIG Analysis
CBP management provided written comments on a draft of this report, which
are included in their entirety in Appendix B. CBP concurred with four of thefive recommendations, which we consider open and resolved. CBP did notconcur with recommendation 3, which we consider open and unresolved. A
summary of CBP’s response and our analysis follows. We also received
technical comments on the draft report and revised the report as appropriate.
In its response, CBP expressed a commitment to maintaining safe and efficient
mail screening facilities and improving its ability to detect and interdict illegal
opioids in international mail shipments. CBP disagreed with some statements
in our report. Specifically, CBP asserted that it does address AED quality
issues, collaborate with the U.S. Department of State and USPS, and evaluate
mail screening effectiveness. DHS OIG agrees that officials from CBP, the U.S.
Department of State, and USPS discussed meeting regularly regarding STOP
Act implementation. However, CBP could not provide documentation that itraised concerns about inaccurate data over a multi-year period or that it
evaluated mail targeting effectiveness.

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CBP also disputed that it did not always provide timely responses to requests
for information and denied our request for read-only access to ATS. DHS OIG
requested read-only access to ATS at the beginning of our audit. CBP did notgrant this request. We subsequently requested an extract of ATS data, and
CBP provided a large volume of records from ATS approximately 3 months after
our initial request.
CBP Comments to Recommendation 1: Concur. CCS will review existingprocesses and provide oversight to monitor AED quality and quantity issues
and ensure AED waiver justifications are documented and communicated.
CCS will continue collaborating with the U.S. Department of State and USPS toensure STOP Act requirements are met and to continue sharing data quality
issues identified by CBP with the U.S. Department of State and USPS for
resolution. Estimated Completion Date (ECD): March 29, 2024.
OIG Analysis: The actions CBP describes are generally responsive to therecommendation. Additionally, CBP should address its plans to assign
responsibility for enforcing penalties when USPS accepts mail without AED.
We consider this recommendation open and resolved until CBP provides
documentation it assigned responsibility for each of these actions.
CBP Comments to Recommendation 2: Concur. NTC deployed a new
functionality in ATS to allow IMFs to record enforcement actions other than
seizures in December 2022. NTC will provide DHS OIG with screenshotsshowing the capture of these non-seizure events, as well as a report showing
enforcement actions used by IMFs. ECD: November 30, 2023.
OIG Analysis: These actions are responsive to the recommendation, which we
consider open and resolved until CBP provides documented evidence
demonstrating it implemented the new functionality for all IMFs to record
enforcement actions other than seizures, specifically when a package arrives
with no AED record in the system.
CBP Comments to Recommendation 3: Non-concur. CCS is currently
updating the International Mail Operations and Enforcement Handbook to
include clearly defined roles and responsibilities for monitoring performanceacross the IMFs. However, CBP did not concur with including performance
metrics or targeting goals in its enforcement handbooks. CBP believes NTC’s
current approach to continuously evaluate, refine, and implement targeting
methodologies across all mission sets, including mail, is sufficient to address
the recommendation. ECD: December 29, 2023.

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OIG Analysis: CBP’s plan is not fully responsive to the recommendation.
Although CBP plans to define monitoring responsibilities, DHS OIG disagrees
that NTC’s current process is sufficient to address the second part of therecommendation, which requires establishing key performance metrics andtargeting goals. Our audit demonstrates that without clear expectations andperformance goals for the IMFs, not all IMFs consistently placed targeting holds
to respond to the influx of opioids entering the United States throughinternational mail. This recommendation will remain open and unresolved
until CBP provides an updated plan demonstrating how it will routinely
document key performance metrics and targeting goals to specifically assess
the effectiveness of mail operations.
CBP Comments to Recommendation 4: Concur. NTC will prioritize training
solicitations and class slots for personnel assigned to IMFs for the remainder of
the FY 2023 training cycle and implement this process as a standard practicestarting in FY 2024. ECD: November 30, 2023.
OIG Analysis: These actions are responsive to the recommendation, which we
consider open and resolved until CBP provides evidence that it provided ATS
training to officers assigned to IMFs, including training specific to placing holds
on mail and targeting mail without an identified port code.
CBP Comments to Recommendation 5: Concur. CCS will implement a
process for assessing a country’s risk eligibility based on CBP data. If waivers
are granted, CCS will document justifications for the waiver approval andcoordinate with CBP’s Office of Congressional Affairs to ensure waiver lists andjustifications are reported to Congress annually as required by the STOP Act.
ECD: May 31, 2024.
OIG Analysis: These actions are responsive to the recommendation, which we
consider open and resolved until CBP establishes a formal process for all of its
planned actions and provides documentation that it has implemented thatprocess.

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Appendix A
Objective, Scope, and Methodology
The Department of Homeland Security Office of Inspector General wasestablished by the Homeland Security Act of 2002 (Public Law 107−296) byamendment to the Inspector General Act of 1978.
The objective of this audit was to determine whether CBP effectively manages
IMF operations and the extent to which CBP targets and interdicts inadmissible
international mail entering the United States through IMFs. This reportspecifically addresses the extent that CBP targets and interdicts inadmissible
mail. 26 To answer this part of our objective, we reviewed Federal laws andregulations as well as DHS and CBP policies and guidance associated withinternational mail enforcement. For FY 2018 through FY 2022, we assessed
applicable criteria for STOP Act implementation and IMF operations, including:
•
•

•
•
•
•

Public Law 115-271, Sections 8001-8007, Synthetics Trafficking andOverdose Prevention Act of 2018 (STOP Act) (codified at
19 U.S.C. § 1415(a)(3)(K) and 19 U.S.C. 1436(e))
19 C.F.R. 145, Subpart G – Mandatory advance electronic data (AED)(issued at 86 Federal Register 14245, Interim Final Rule, Mandatory
Advance Electronic Information for International Mail Shipments, March
15, 2021)
CBP Directive 3290-022 – Advance Cargo Targeting Procedures andResponsibilities
U.S. Customs Service International Mail Operations and Enforcement
Handbook, August 2001
CBP and USPS Memorandum of Understanding, 2017
Standard operating procedures between local USPS and CBP officials at
each operating IMF

We reviewed DHS’ Risk Management Fundamentals Homeland Security Risk
Management Doctrine (dated April 2011) and evaluated GAO’s Standards forInternal Control in the Federal Government. We further identified control
weaknesses related to the control environment, risk assessment, control
activities, information and communication, and monitoring and maderecommendations in the report that address these gaps.

26 We issued our findings about IMF operations in a separate report: CBP’s Management ofInternational Mail Facilities Puts Officer Safety and Mission Requirements at Risk, OIG-23-48,
August 31, 2023.

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To observe targeting and screening measures, we conducted in-person site
visits at six IMFs (Chicago, Honolulu, Los Angeles, Miami, Newark, and JFK)
and virtual site visits at two IMFs (San Juan and St. Thomas). We interviewed
CBP officials at each IMF location, including officials formerly located at the
San Francisco IMF. We interviewed CBP officials from the Office of Information
Technology and the following OFO offices: CCS; NTC; and Planning, Program
Analysis, and Evaluation. We also interviewed U.S. Immigration and Customs
Enforcement Homeland Security Investigations officials who are located at the
IMFs. Finally, we interviewed an official with the U.S. Department of State,and headquarters and IMF officials from USPS.
As part of our audit, we evaluated an extract of mail targeting data from CBP’s
ATS, which contains and compares traveler, cargo, and conveyance information
with law enforcement, intelligence, and other enforcement data. We evaluatedmail targeting data from ATS for FYs 2018 through 2022. We determined thatthe data used was sufficiently reliable for this report. We leveraged the DHSOIG Office of Innovation to further extract and analyze subsets of data tocompare yearly trends between the IMFs, including:
•
•
•
•
•

AED received;
the number and rate of holds placed;
the number and rate of exams completed;the number and rate of outstanding holds (holds with no release dates);andthe number of AED entries with no updated port code.

Through direct access to the Seized Assets and Case Tracking System data
warehouse, we extracted and analyzed seizure data related to inbound postal
shipments from FY 2018 through FY 2022 by country of origin. We met with
CBP subject matter experts for the Seized Assets and Case Tracking Systemdata warehouse to confirm the correct parameters to create seizure reports for
inbound mail. We determined that the data used was sufficiently reliable forthis report.
We conducted this performance audit between April 2022 and April 2023
pursuant to the Inspector General Act of 1978, 5 U.S.C. §§ 401-424, and inaccordance with generally accepted government auditing standards. Thosestandards require that we plan and perform the audit to obtain sufficient,appropriate evidence to provide a reasonable basis for our findings andconclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.
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DHS OIG’s Access to DHS Information
During this audit, CBP did not always provide timely responses to DHS OIG’s
requests for information. Additionally, DHS denied our request for read-onlyaccess to CBP’s ATS. As noted above, we subsequently requested an extract ofdata from the system, and CBP eventually provided that information.

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Appendix B
CBP Comments to the Draft Reportwww.oig.dhs.gov

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Appendix C
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Under Secretary, Office of Strategy, Policy, and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Commissioner of Customs and Border Protection
CBP Component Liaison
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees

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ADDITIONAL INFORMATION AND COPIES
To view this and any of our other reports, please visit our website at:www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General
Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov.
Follow us on Twitter at: @dhsoig.

OIG HOTLINE
To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and clickon the red "Hotline". If you cannot access our website, call our hotline at(800) 323-8603, r write to us at:
Department of Homeland Security
Office of Inspector General, Mail Stop 0305
Attention: Hotline
245 Murray Drive, SW
Washington, DC 20528-0305

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