Russell.lundberg 

Office of Inspector General 

DEPARTMENT OF HOMELAND SECURITY 

A Review of CBP and ICE Responses to Recent 

Incidents of Chinese Human Smuggling in 

Maritime Cargo Containers 

(Redacted) 

The Department of Homeland Security, Office of Inspector General, has redacted this report for public release. 

A review under the Freedom of Information Act will be conducted upon request.

OIG-07-40 OIG-07-40 May 2007 April 2007
Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528

April 23, 2007 

Preface 

The Department of Homeland Security Office of Inspector General was established by the 

Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector General Act 

of 1978. This is one of a series of audit, inspection, and special reports prepared as part of our 

oversight responsibilities to promote economy, effectiveness, and efficiency within the department. 

This review examined how Customs and Border Patrol (CBP) and Immigration and Customs 

Enforcement (ICE) responded to three incidents of Chinese human smuggling in maritime cargo 

containers that occurred in January and April 2005, and April 2006. We reviewed the lessons that 

CBP and ICE learned from the incidents, as well as any modifications they made to their programs 

and operations as a result. 

The recommendations herein have been developed to the best knowledge available to our office, and 

have been discussed in draft with those responsible for implementation. It is our hope that this 

report will result in more effective, efficient, and economical operations. We express our 

appreciation to all of those who contributed to the preparation of this report. 

 

Richard L. Skinner 

Inspector General 
Table of Contents 

A Review of CBP and ICE Responses to Recent Incidents of Chinese 

Human Smuggling in Maritime Cargo Containers

 Executive Summary.........................................................................................................................1 

 Background......................................................................................................................................2 

 Results of Review ............................................................................................................................9 

 CBP Strengthened the Customs-Trade Partnership Against Terrorism 

 Program as a Result of Incidents ............................................................................................9

 Incidents Highlighted Container Security Initiative Program’s 

 Inherent Limitations..............................................................................................................12 

CBP Modified Targeting Activities......................................................................................17 

CBP Modified Enforcement Activities.................................................................................21 

CBP Ports of Los Angeles/Long Beach and Seattle/Tacoma 

Prepared for New Smuggling Season ...................................................................................24 

ICE Improved Coordination of Investigations With the Chinese 

Government, but Coordination With CBP Needs Improvement ..........................................25 

Management Comments and OIG Analysis..............................................................................30 

 

Appendices 

 Appendix A: Purpose, Scope, and Methodology .......................................................................34 

 Appendix B: Management Response to Draft Report ...............................................................35 

 Appendix C: Congressional Request Letter...............................................................................40 

 Appendix D: CBP and ICE Modifications Made in Response to Incidents ..............................44 

 Appendix E: Major Contributors to This Report.......................................................................46 

 Appendix F: Report Distribution...............................................................................................47
Table of Contents 

A Review of CBP and ICE Responses to Recent Incidents of Chinese 

Human Smuggling in Maritime Cargo Containers

 

Acronyms 

 CBP Customs and Border Protection 

 CSI Container Security Initiative 

 C-TPAT Customs-Trade Partnership Against Terrorism 

 DHS Department of Homeland Security 

 ICE Immigration and Customs Enforcement 

 MOU Memorandum of Agreement 

 OIG Office of Inspector General, DHS 

 USCG United States Coast Guard 

 
 

OIG

Department of Homeland Security 

Office of Inspector General

A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 1

Executive Summary 

This review was conducted in response to a request from members of the U.S. 

Senate’s Committee on Homeland Security and Governmental Affairs and the 

House of Representatives’ Committee on Homeland Security and Committee 

on Energy and Commerce. They requested that we review three incidents of 

Chinese human smuggling in maritime cargo containers to determine what 

lessons Customs and Border Protection (CBP) and Immigration and Customs 

Enforcement (ICE) learned from the incidents and what changes, if any, they 

made as a result of them. In particular, we examined the effects of the 

incidents upon CBP’s Customs-Trade Partnership Against Terrorism (CTPAT), Container Security Initiative (CSI), and U.S. targeting and 

enforcement procedures, as well as the ICE investigations of the incidents. 

After the three incidents, CBP and ICE modified their operations to improve 

the deterrence and detection of Chinese stowaways in maritime cargo 

containers. CBP broadened C-TPAT minimum-security criteria compliance 

to its members’ non-C-TPAT partners and is negotiating expansion of CSI to 

ports at which the containers were laded. Domestic port targeting and 

enforcement measures improved, as well. ICE modified its methods for 

exchanging information with the Chinese government to facilitate information 

exchange. However, during our fieldwork ICE and CBP did not reveal to us 

any formal procedures for coordinating response to incidents of human 

smuggling at the ports, which may have had a negative effect on the 

investigation of one of the incidents. 

We made three recommendations, directing two to CBP and one to CBP and 

ICE. CBP and ICE concurred with our recommendations, and their actions 

taken enabled us to close the second and third recommendations. The first 

recommendation remains open. 
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Smuggling in Maritime Cargo Containers

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Background

While human smuggling in maritime containers accounts for only a small 

portion of illegal entries into the United States, it presents risks to the life and 

health of the stowaways and illustrates national security vulnerabilities in 

maritime commerce. Since April 1998, there have been 23 known incidents 

of Chinese nationals being smuggled into the United States via maritime cargo 

containers. Six additional smuggling attempts were intercepted at foreign 

locations before they arrived in the United States. Of the 23 incidents, 15 

were discovered at Los Angeles/Long Beach ports and 8 at Seattle/Tacoma 

ports. Through the year 2000, containers used in the incidents were laded 

onto the vessel in Hong Kong, but containers in later incidents were laded at 

ports on the Chinese mainland or in Busan, Korea. The three most recent 

incidents were discovered between January 15, 2005, and April 5, 2006. 

On January 15, 2005, Customs and Border Protection (CBP) and the U.S. 

Coast Guard (USCG) apprehended 32 Chinese nationals after they attempted 

to enter the United States via two cargo containers arriving in the port of Los 

Angeles, California. The containers were laden in Shekou, China, and had 

been modified to support life and to assist the eventual escape of the 

stowaways. Routine targeting revealed discrepancies on the manifests, and 

CBP ordered the containers held for examination, but the stowaways were 

discovered before the containers were discharged from the vessel. CBP and 

the USCG responded initially, detaining all known stowaways. ICE took 

custody of the stowaways while their asylum status was determined and began 

to investigate the incident. 

On April 3 and 4, 2005, port security and CBP apprehended 29 Chinese 

nationals after they attempted to illegally enter the United States via two cargo 

containers discharged in the Port of Los Angeles. As with the January 2005 

incident, the containers were laden in Shekou, China, and were modified to 

support life and to assist the eventual escape of the stowaways. Targeters 

(CBP officers who target containers for inspection) placed a hold for 

examination on one of the containers due to discrepancies on the manifest. 

After the vessel discharged the containers, but before CBP examined the 

questionable container, the stowaways exited the containers and dispersed into 

the terminal yard. Port security spotted the stowaways and contacted CBP 

and ICE to respond. CBP and ICE detained 29 Chinese nationals, but 2 

additional stowaways breached the perimeter and escaped. ICE took custody 

of the stowaways while their asylum status was determined and began to 

investigate the incident. 
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On April 5, 2006, CBP apprehended 22 Chinese nationals after they attempted 

to illegally enter the United States in a cargo container discharged at the Port 

of Seattle. This container was laden in Shanghai, China, and was minimally 

modified. CBP targeters at the Port of Seattle placed a hold on the container 

for examination. On the morning of arrival, but before CBP examined the 

container, the stowaways exited the container and were discovered by 

terminal security in the terminal yard. CBP coordinated the response with 

ICE, USCG, and other law enforcement authorities. ICE took custody of the 

stowaways while their asylum status was determined and began to investigate 

the incident. 
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Ports of Los Angeles/Long Beach and Seattle 

Together, the ports of Los Angeles and Long Beach comprise the largest port 

in the Nation. The ports cover 35 miles of waterfront and receive 42% of all 

seaborne containers that arrive in the United States. CBP administers both 

ports together under a single CBP office and port director. Los Angeles/Long 

Beach CBP targeters screen 12,000 containers a day and 31,000 crewmembers 

and passengers a week. 

The Port of Seattle is the eighth most active port in the Nation, with three 

international container terminals. Due to their proximity, CBP administers the 

ports of Seattle, Tacoma, and several smaller ports in Washington under a 

single office and area port director. The ports are 20 miles apart and require 

separate enforcement teams. 

The port authorities at Los Angeles/Long Beach and Seattle lease their 

terminals to private entities. The lessees, known as terminal operators, are 

responsible for terminal security, in accordance with federal and international 

standards. Terminal operators schedule the arrival and departure of vessels, as 

well as the discharge and release of cargo. Cargo discharge is the unloading 

of cargo from the vessels onto the terminals. CBP allows cargo to be moved 
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from the terminal only after it has been subjected to all enforcement activities 

CBP requires, such as examination and radiation detection. 

CBP Layers of Security 

CBP maintains several layers of security to protect the United States against 

in-bound cargo and people that may present threats of terrorism or breaches of 

customs and immigration laws, such as the import of illegal drugs, banned 

agricultural products, and products violating intellectual and property rights. 

In the case of Chinese stowaways, preventing the stowaways from loading 

into containers or intercepting the containers offshore is especially important 

because Chinese stowaways are coached to give fictitious reasons for asylum, 

which provides them legal status in the United States. There is no practical 

way to investigate or question their claims. Therefore, intercepting the 

containers before they reach U.S. soil and the stowaways obtain asylum rights 

would prevent the award of legal status to those who use duplicitous means to 

get it. 

Two CBP layers of security, the Customs-Trade Partnership Against 

Terrorism (C-TPAT) and the Container Security Initiative (CSI), extend 

border protection beyond U.S. boundaries. C-TPAT is a partnership with 

members of the shipping industry that works to improve security and prevent 

the transmission of illegal goods into the United States. CSI is a partnership 

with foreign governments that allows CBP’s targeters in host countries to 

target all containers and refer containers suspected of national security threats 

to host governments for inspection. 

In addition, CBP targeters at domestic ports can prevent containers suspected 

of posing a high risk to national security from entering the United States. 

They begin targeting containers before the containers are loaded onto vessels 

bound for the United States. When the targeters determine that a container 

poses a national security risk, they may issue a Do Not Load order on the 

container, which prevents the container from being laded at a foreign port, or 

from being discharged in the United States. However, the threshold for 

issuing this order is so high that it is rarely done. Accordingly, C-TPAT and 

CSI are the primary means by which containers carrying stowaways will be 

prevented from entering the United States. 

When CBP domestic targeting indicates that a container is suspicious, but the 

evidence is not strong enough to issue a Do Not Load order, the domestic 

targeters will order an examination of the container once it reaches the 

domestic port. CBP enforcement teams work with terminal operators to 
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examine containers before they are released from the terminal into the United 

States. 

Customs-Trade Partnership Against Terrorism 

The C-TPAT program comprises the outermost layer of security by imbedding 

security practices in the international supply chain overseas. C-TPAT is a 

voluntary partnership between CBP and private businesses to secure the 

foreign supply chain of goods that are imported into the United States while 

facilitating legitimate trade. Under the program, C-TPAT members agree to 

meet minimum-security criteria. In return, CBP reduces targeting scores for 

importers, decreasing the probability that their containers will be examined 

and thus delayed. All other members such as carriers and brokers receive 

increased market credibility and access. CBP officials said that many large 

importers require carriers and brokers to be C-TPAT certified. 

C-TPAT includes 3,231 importers, 1,655 carriers, 38 terminals, 637 brokers, 

and 400 foreign manufacturers and consignees. “Consolidators,” or 

nonvessel-operating common carriers, are responsible for shipping goods, but 

do not use their own vessels. Instead, they arrange to have goods shipped on 

other companies’ vessels. 

To gain C-TPAT membership, a business must submit, among other 

documents, an action plan to CBP that describes security enhancements that it 

will take to bring it into compliance with C-TPAT’s minimum-security 

criteria. (See C-TPAT Criteria for Sea Carriers, March 1, 2006, available at 

http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/s

ecurity_criteria/sea_carrier_criteria/sea_carrier_criteria.ctt/sea_carrier_criteria

.doc, viewed on January 25, 2007.) CBP reviews the action plan and the 

company’s history. If there is no evidence of prior violations, and if the 

company’s action plan is satisfactory, CBP certifies the applicant. Certified 

members are then validated after CBP conducts site visits to ensure the action 

plan is executed to expectation. C-TPAT has 6,502 certified members, of 

which 3,926 are validated. 

The Container Security Initiative

CBP’s other layer of security outside the U.S. borders is CSI, which targets 

U.S.-bound cargo for terrorist threats at the foreign ports of lading. CSI has 

three objectives: 
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• Identify high-risk containers; 

• Prescreen containers before they are shipped to reduce disruptions to 

trade; and, 

• Minimize physical examinations through technological means. 

To achieve these objectives, the United States enters into bilateral agreements 

with foreign governments to host CBP and ICE officials so they may conduct 

targeting operations in the foreign ports. These CSI teams work in partnership 

with their host counterparts and with the National Targeting Center to identify 

containers destined for the United States that pose a risk of terrorism. Once 

CSI identifies a high-risk container, it presents reasons for examining the 

container to the host government. If the host government determines the 

reasons are convincing, it will examine the container. However, the host 

government maintains the right to refuse requests for examination. CSI now 

operates in 50 ports and targets nearly 82% of the containerized shipments 

bound for the United States. 

 

Targeting and Enforcement Procedures

 

CBP’s third layer of security occurs at U.S. ports. CBP and the USCG share 

federal jurisdiction over port security; CBP is the lead agency for cargo, while 

the USCG is the lead agency for vessel, port, crew, and passenger security. 

Specifically, CBP works with the USCG, ICE, local and port authorities, and 

terminal operators to prevent the entry of illegal containers or individuals by 

(1) targeting all cargo and people entering at the port; and (2) conducting 

various enforcement activities, such as examining containers that CBP’s 

targeters identify as suspicious. 

At the ports, CBP officers in the Advanced Targeting Units target all U.S.-

bound containers and people to determine their level of risk. Officers use the 

Automated Targeting System to assess the risks presented by each shipment 

or person entering the United States. The Automated Targeting System 

analyzes information in cargo manifests, which carriers submit 24 hours 

before the cargo is loaded on the vessel. These manifests may subsequently 

be updated until a day after the cargo arrives. Targeters use a separate 

Automated Targeting System rule-set or filter to target each area of risk, such 

as terrorism, narcotics violations, agricultural threats, and goods violating 

intellectual or property right laws. Applying a rule-set against a container’s 

manifest results in a numerical score indicating the degree of likelihood for 

the threat being assessed. Targeters must review all manifests with the 

terrorism rule-set. Containers with scores exceeding ---- on the terrorism 

rule-set must be examined before leaving the port terminal. Containers with 
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scores between -------------- are subject to further review. At their discretion, 

targeters may use other rule-sets, past experience, intelligence, or other 

research to assess threats and target containers. 

Using the Automatic Targeting System score and the results of any additional 

research, targeters notify the CBP enforcement officers and the terminal 

operator when to examine a container. The CBP enforcement officers work 

with the terminal operators to schedule a convenient time to examine the 

containers. An operator may not release a container from the terminal once it 

has been identified for examination. The CBP enforcement officers usually 

employ a nonintrusive inspection device that captures an image of the 

container’s contents with gamma or x-rays. If the image reveals a suspicious 

object, CBP enforcement officers will open the container and examine it. 

CBP also randomly selects containers for examination. 

CBP officers also conduct other law enforcement activities. They board 

vessels to look for stowaways or contraband, patrol the terminals for 

suspicious activity, and verify that manifests match the containers discharged 

from vessels. 

ICE Investigations 

CBP refers violations of immigration and customs laws, including incidents of 

human smuggling, to ICE for investigation. ICE investigators gather evidence 

to support the prosecution of smuggling ring members by pursuing leads 

generated from interviews, observations, and physical evidence. In addition 

to investigations, ICE is responsible for the custody of detained immigrants 

pending their immigration hearings. ICE’s Office of Detention and Removal 

Operations transports and houses detained immigrants.

The transnational nature of human smuggling crimes often requires 

investigators to seek assistance from foreign law enforcement counterparts. 

Investigators rely on ICE attachés to facilitate cooperation with foreign 

agencies, including those in mainland China and Hong Kong. Given 

sovereignty concerns, ICE attachés do not conduct investigative work in 

China, and serve only as liaisons to facilitate the exchange of information 

between Chinese officials and ICE investigators. 
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Results of Review 

 

CBP Strengthened the Customs-Trade Partnership Against Terrorism 

Program as a Result of Incidents 

CBP gathered lessons learned from the three incidents and used those lessons 

to make modifications that enhanced the C-TPAT program. After the April 

2005 incident, CBP established requirements that C-TPAT members involved 

in a human smuggling incident must satisfy to maintain their membership, 

including: 

• Pay a fine; 

• Conduct an assessment of security gaps; and, 

• Submit to CBP an action plan for correcting security lapses. 

CBP will revoke the membership of companies that fail to comply. 

Additionally, CBP updated the C-TPAT minimum-security criteria, which in 

turn required C-TPAT members to ensure that their business partners met the 

C-TPAT minimum-security requirements. 

C-TPAT Program Standardized Response to Maritime Human Smuggling 

Incidents

The January 2005 incident was the first incident to involve a C-TPAT carrier, 

Nippon Yusen Kaisha Shipping Lines, and C-TPAT nonvessel-operating 

common carriers, WiceMarine and P&O Nedlloyd. CBP responded to the 

incident by meeting with representatives from the carrier and nonvesseloperating common carriers to discuss the incident and course of action to be 

taken. CBP and Nippon Yusen Kaisha representatives said that the meeting 

resulted in a misunderstanding of the follow-up actions that CBP expected the 

carrier to take. C-TPAT officials said that they requested the carrier to 

produce additional action plans to identify the security gaps and outline any 

corrective actions it planned to take. The carrier’s officials said that they did 

not believe CBP made such requests. As a result, the carrier did not produce 

the action plan that C-TPAT officials expected to receive. However, C-TPAT 

took no action against the carrier for its perceived failure to comply with a CTPAT request until after the April 2005 incident. 

Immediately after the April 2005 incident, in which Nippon Yusen Kaisha 

was also the carrier, Nippon Yusen Kaisha contacted CBP. C-TPAT officials 

determined that they did not communicate requirements clearly to the carrier 
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after the January 2005 incident. They determined that the program needed 

standard procedures for responding to members implicated in human 

smuggling incidents. On April 6, 2005, CBP suspended the carrier from the 

program due to the carrier’s failure to submit an action plan following the first 

smuggling incident. The carrier’s representatives said that losing C-TPAT 

membership would have had a devastating effect on its business had they not 

acted quickly. Soon after learning of the suspension, Nippon Yusen Kaisha 

officials contacted CBP and C-TPAT program managers to schedule a 

meeting. On April 13, 2005, CBP met with the carrier’s chief operating 

officer to discuss the incidents, the carrier’s response, and the suspension. 

CBP agreed to reinstate the carrier if it immediately paid $2000 per alien 

stowaway not detained (as per 8 USC § 1253, 1231) and addressed its supply 

chain vulnerabilities. Specifically, CBP instructed the carrier to: 

• Inspect their business operations in China for security gaps; 

• Submit a satisfactory, comprehensive action plan to close gaps in 

security; and, 

• Schedule quarterly follow-up meetings with CBP to report its progress 

in implementing the action plan. 

Nippon Yusen Kaisha complied with the conditions and improved its security, 

as well as the security of its partners. Carrier officials visited its terminal 

operations at the port of Shekou and 22 other ports where the carrier conducts 

business to determine security gaps. The carrier found security breaches at its 

terminal in Shekou and identified problems at its terminals in other ports. The 

carrier submitted an action plan to CBP summarizing the security gaps and 

how it would resolve them. Although we did not verify their claims, the 

carrier’s officials said that it made the following corrections to improve 

security at its Shekou terminal: 

• Terminated all of its staff; 

• Trained its new staff in security measures including detection of 

anomalies such as trap doors and holes in container floors; 

• Refined its detection systems, including improving its process for 

weighing containers; and, 

• Installed carbon dioxide detection devices that indicate a likelihood of 

stowaways in containers. 

According to Nippon Yusen Kaisha officials, its Shekou terminal now has 

seven layers of security and all of its personnel are conducting surveillance of 

the containers that are laded there. Every 2 weeks, carrier officials visit the 

ports to ensure adherence to security practices. The carrier is implementing 
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similar security enhancements at all of its terminals. Nippon Yusen Kaisha 

also worked with the Chinese government and business partners to deter 

future smuggling incidents. Carrier officials distributed press releases in 

China to discourage smuggling attempts on carrier vessels, and they met with 

Chinese police and customs officials to discuss smuggling issues and 

prevention. The carrier facilitated meetings with shippers and other trade 

partners to discuss security concerns and ways to overcome them. For 

example, the carrier’s officials suggested that its partners hire truck drivers 

that have been vetted for security concerns. 

Following the April 2006 incident, C-TPAT officials followed the same 

process with China Shipping Container Lines that it used with Nippon Yusen 

Kaisha in the April 2005 incident. China Shipping Container Lines contacted 

CBP immediately after the incident, initiated an internal review of the 

incident, and provided CBP with information related to the shipment. On 

April 7, 2006, CBP’s Assistant Commissioner for Field Operations met with 

the carrier’s president to discuss the facts of the incident and the actions that 

the shipping line would have to take in order to maintain its C-TPAT 

membership. 

Fine proceedings were initiated for failure to detain stowaways. CBP required 

the carrier to pay the stowaway penalty. The carrier was also required to visit 

its terminals in China to determine security vulnerabilities and submit an 

action plan to address any security gaps. Because the carrier responded 

quickly to CBP’s requests, and because the container harboring stowaways in 

April 2006 incident had no trap doors or other visible indicia of stowaways, 

CBP did not suspend the carrier’s membership in the C-TPAT program. 

On April 17, 2006, China Shipping Container Lines submitted an action plan 

but said it was unable to conduct the security reviews at its terminals at that 

time. CBP acknowledged the carrier’s reasons for delaying the site visits, yet 

urged its officials to conduct them as soon as possible. A few months later, 

the carrier conducted a site visit of Shanghai to assess security controls, 

including assurance that each container being laded on its vessels are visually 

inspected for signs of modifications. 

The January 2005 incident led C-TPAT program managers to standardize their 

response to members involved in maritime human smuggling incidents. CBP 

acted decisively and consistently in response to the April 2005 and the April 

2006 incidents. As a result, both carriers’ terminals at Chinese ports are more 

secure. Also, Nippon Yusen Kaisha’s communications with its business 
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partners and the Chinese government may have generated more interest in 

implementing maritime security measures. 

C-TPAT Program Leveraged C-TPAT Membership to Improve Security

Partly as a result of the January 2005 incident, CBP issued updated minimumsecurity criteria for C-TPAT members with a new requirement that leveraged 

C-TPAT sea carriers’ membership to improve the security of nonmember 

business partners and customers. CBP required C-TPAT sea carriers to screen 

their business partners who provide transportation services. Similarly, CTPAT sea carriers must screen new customers to determine whether they are a 

legitimate business or otherwise pose a security risk. Sea carriers must also 

ensure that nonvessel-operating common carriers commit to the C-TPAT 

security recommendations. CBP gives C-TPAT members 90 days to comply. 

The minimum-security criteria provide broad security goals, but do not 

prescribe the methods by which C-TPAT members may satisfy the goals. To 

fulfill the new requirement, Nippon Yusen Kaisha created standard language 

for its contracts with business partners requiring the partner to uphold certain 

security standards. To achieve the same goal, China Shipping Container 

Lines required the agents that book space on its vessels to ask a list of 

security-related questions to each entity seeking reservations on the carrier. 

Should an answer reveal a security lapse, the booking agent notifies the 

carrier’s security officer, who decides whether the customers’ security 

measures meet the minimum-security criteria. 

Nippon Yusen Kaisha and China Shipping Container Lines are large 

companies in the container shipping community, and each has specific needs 

that are unique to its operational and management structure. CBP recognized 

that mandating rigid methods for compliance with the criteria would not allow 

C-TPAT members enough flexibility to support their differing business 

models. Accordingly, while the C-TPAT 2006 minimum-security criteria 

require C-TPAT members to ensure the security of their business partners and 

customers, the criteria allow each C-TPAT member to devise its own methods 

for achieving that goal. This approach allowed Nippon Yusen Kaisha and 

China Shipping Container Lines to comply with the requirement in ways that 

were compatible with their own business models. 

Incidents Highlighted CSI Program’s Inherent Limitations 

Although the CSI program performed as designed, the incidents highlighted 

the program’s inherent limitations. First, CSI is unable to recommend for 
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examination containers that are laded at non-CSI ports. In the January and 

April 2005 incidents, the containers passed thru Hong Kong, a CSI port, but 

were laded elsewhere. Second, it is difficult for program officials to convince 

the Chinese government to examine containers with intermediate Automated 

Targeting System terrorism rule-set scores and no additional specific indicia 

of threat. The April 2006 incident illustrated that even when containers 

harboring stowaways are laded at CSI ports, the targeting does not always 

provide a threat specific enough to persuade the Chinese government to 

examine the container. 

CSI is working to remedy these problems. When the January incident 

occurred, CSI was negotiating to establish CSI operations at ports in China, 

and is continuing to negotiate expansion to Shekou, the port in Shenzhen 

where the containers in the incidents were laded. However, given that the 

Chinese smuggling rings have changed tactics in the past, it is likely that the 

smugglers will use other ports where CSI does not have a presence for lading 

human cargo. Nonetheless, CBP is currently negotiating with the shipping 

industry to include more information in the 24-hour rule submissions to 

improve its targeting. Some of the additional information might improve the 

ability of CSI to provide specific information to support its recommendations 

for examination. 

CSI Program Is Limited Due to Restricted Number of Ports Served

CBP never intended for CSI to cover all 704 ports that ship to the United 

States. Instead, CBP prioritized ports based on the volume of exports to the 

United States and the risk presented across multiple dimensions including 

terrorism, drug smuggling, human smuggling and other threats. However, the 

lack of a CSI presence in Shekou and other ports exemplifies the program’s 

limitations as part of the layered maritime security strategy. 

In the 2005 incidents, the containers holding the Chinese nationals were 

loaded onto a vessel in Shekou, China, a non-CSI port. The vessel then sailed 

to the CSI port of Hong Kong where the containers harboring the stowaways 

remained on board. CSI does not target containers that are laded at non-CSI 

ports and then pass through a CSI port without being discharged from the 

vessel. The program only targets containers that are laded in the foreign ports 

at which CSI has a presence. According to CSI officials, removing and 

examining containers laded at non-CSI ports would place a much higher 

burden on carriers and ports than inspecting containers as they are being 

laded. Foreign governments would be less receptive to hosting the CSI 

program if it required containers laded at non-CSI ports be removed and 
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examined. Therefore, the CSI program acted according to its protocols and 

was not directly implicated in the 2005 incidents. 

Before the 2005 incidents, CSI was negotiating with China to expand the CSI 

program to ports in mainland China. The ports of Shanghai and Yantian 

export 1.5 million containers to the United States annually. The other Chinese 

ports, which do not host CSI, export approximately 500,000 containers to the 

United States annually. CSI has been expanding since its inception in January 

2002. As of January 2005, CSI targeted approximately 50% of in-bound 

containers. In 2003, the United States and China signed a Declaration of 

Principles, agreeing to pursue a CSI presence in Chinese ports. However, 

China proceeded slowly in negotiations, requiring precise delineation of CBP 

and ICE roles in the program to alleviate security concerns and sovereignty 

issues. Despite its efforts, CSI still had not established its program at the new 

ports when the 2005 incidents occurred. 

The United States and China finally approved CSI implementation guidelines 

for mainland China on March 28, 2005. CSI established pilot ports in 

Shanghai and in Shenzhen’s port of Yantian in April and June 2005, 

respectively. The efforts to implement these two CSI ports in mainland China 

are not a reaction to the two Chinese human smuggling incidents in 2005, but 

are part of the initial phase of CSI expansion. However, the containers in the 

January and April 2005 incidents were laded in Shekou, where there was no 

CSI presence planned. CSI officials wanted to expand the program to Shekou 

and similar ports in China to reduce the human smuggling and other 

vulnerabilities, but were concerned that aggressively seeking to expand CSI 

would elicit resistance from already cautious Chinese negotiators. 

In December 2005 and January 2006, CSI officials identified a creative 

opportunity for expanding CSI in China. The operational agreement with 

China listed Shenzhen as one of the two new port areas to become a CSI 

program. Shenzhen has customs authority for three physically distinct 

container ports, including Shekou. China and the United States initially 

agreed that the CSI program would target the shipments for only one of the 

Shenzhen ports, the port of Yantian. CSI officials decided to propose a slight 

change to the initial agreement with China. In January 2006, CSI officials 

requested China to expand the CSI team’s effective presence without 

expanding its actual presence. The CSI team would continue operating out of 

Shenzhen, but would target containers laded at all ports within the customs 

authority of Shenzhen. China agreed to the proposal. To accommodate the 

expanded examinations, China improved infrastructure and officer training in 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 15

the ports of Shekou and Chiwan. The expansion of CSI in Shenzhen 

continues to develop. 

CSI continues to expand, both generally and in response to obvious 

vulnerabilities identified in the 2005 incidents. Expanding CSI’s presence 

might decrease the number of containers with human stowaways laded in 

those ports. While the ports of Shanghai and Yantian export 1.5 million 

containers to the United States annually, approximately 500,000 containers 

arrive from Chinese ports without a CSI presence. To some extent, these 

containers come from lower-risk ports, as CSI officials established the 

program in the ports with higher levels of risk. However, the recent history of 

Chinese human smuggling suggests that smugglers are adaptive and change 

ports of lading for stowaways in containers. Ports lacking a CSI presence 

remain vulnerable. 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 16

CSI officials reacted appropriately to the 2005 incidents. They identified the 

obvious threat of the port of Shekou and developed a creative solution without 

disrupting their phased expansion. CSI’s expansion to high-risk ports will 

decrease the number of ports vulnerable to human smuggling and other 

immigration and customs violations. 

 

Targeting Limits CSI

The April 2006 incident highlighted another vulnerability in the CSI 

program—container targeting is limited in its ability to ascribe specific risk 

factors to suspect containers, which reduces the likelihood that a host 

government will examine a container. The container that harbored Chinese 

stowaways in the April 2006 incident was laded at Shanghai, a CSI port. The 

CSI targeting team had identified the container as an intermediate risk using 

the Automatic Targeting System terrorism rule-set, but additional review did 

not find any specific information indicating a risk of terrorism. Without more 

specific information of risk, CSI’s targeters could not justify requesting China 

to examine the container. The Chinese government requires more specific 

information relating to terrorism threats other than intermediate scores on the 

Automatic Targeting System terrorism rule-set. To justify a request to 

examine a container, CSI needs targeting information that specifically 

identifies containers that are a high risk to national security. 

CBP officials said that targeting with the Automatic Targeting System 

terrorism rule-set is rarely able to determine the specific nature of the threat, 

just that there is one. The Automatic Targeting System terrorism rule-set 

identifies factors that could be indicative of a national security threat, but the 

number and nature of the data elements it reviews limit the Automatic 

Targeting System. Although many containers fall within the terrorism ruleset’s range for further review, it is unlikely that targeters will detect specific 

information identifying the nature of the threat through subsequent research. 

If no specific information is available to link specific risk factors to a 

container, the targeting information alone may not be sufficient to support a 

request for inspection. While CSI officials said that Chinese officials would 

review containers presenting a risk for stowaways, China is also more likely 

to reject inspections if the evidence suggesting a threat is not specific, as 

evidenced by their denial of 19% of all examinations requested by CSI, while 

all other ports denied less than 1% of requests. The container in this incident 

could not be tied to sufficient evidence to indicate any specific threat. 

Lacking adequate specificity, CSI’s targeters referred the container to 

domestic targeters for additional review and possible inspection. 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 17

Following the April 2006 incident, CSI program officials reviewed CSI 

actions and determined that all CSI procedures were followed appropriately. 

We agree with their assessment. Due to the limited data elements available 

for targeting and the voluntary nature of the program, it is unclear what 

additional steps CSI could have taken to influence Chinese officials to 

examine the container. However, we are concerned that future containers 

with stowaways will not be examined. 

CBP is aware of its targeting system’s limitations and is pursuing 

improvements. For example, CBP is negotiating with the shipping industry to 

require additional data elements in the 24-hour rule submissions in an 

initiative called “Ten Plus Two.” Some of the data sought includes -----------

------- -- - ------------------------------- --------------- ---- ---------------------- ---

------------------------------- . CBP determined that ------- ---------------------------

------------------------------------------------- ------------------------------------ -----

-----------------------------. In addition, historical analyses showed that 

containers with stowaways --------------------------------------------------, 

-------- --------------------------------------------------------- -------- These 

additional data elements might improve CBP’s capability to identify risk in 

containers more accurately and to articulate those risk factors to host 

governments. The SAFE Port Act (Public Law No. 109-347) requires CBP to 

seek additional data elements to improve targeting. CBP should continue to 

advocate for these data elements in its ongoing negotiations with the shipping 

industry. 

CBP Modified Targeting Activities 

Using the lessons learned from the incidents, CBP ports revised targeting 

procedures to improve the likelihood of identifying containers harboring 

Chinese stowaways. In addition, CBP headquarters took actions to change 

targeting procedures at the ports. CBP did not alter targeting practices after 

the January 2005 incident, but altered its targeting procedures, both nationally 

and at the ports, after the April 2005 and April 2006 incidents. National 

changes included the creation of automated targeting system filters for 

detecting Chinese human smuggling in maritime cargo containers. CBP 

Seattle/Tacoma targeters decreased the automated targeting system mandatory 

examination score to increase the number of containers it examined, and CBP 

Los Angeles/Long Beach increased its targeting staffing in order to provide 

the resources necessary to conduct a more thorough analysis of each 

container. In addition, the CBP port staff there developed a new targeting 

approach that focused on the entire vessel and not just the individual 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 18

containers that are discharged. The vessel targeting is used to develop a more 

comprehensive enforcement plan for each day’s activities. 

CBP’s Response to the January 2005 Incident

Although CBP documented lessons learned from the January 2005 incident, it 

appears that CBP Los Angeles/Long Beach did not change its targeting 

practices after the January 2005 incident. CBP does not have documentation, 

and the officials we interviewed do not recall whether the targeting changes 

were made in response to the January 15, 2005, incident. Some CBP Los 

Angeles/Long Beach officers recalled that after one of the incidents, the 

targeters “scrubbed” the container manifests, reviewing them more often with 

particular attention to indications of human smuggling. However, we cannot 

confirm whether this change was made subsequent to the January 2005 

incident. 

CBP’s Response to the April 2005 Incident

In response to the April 2005 incident, CBP Los Angeles/Long Beach’s 

targeters developed an automated targeting system filter to identify containers 

that held a high risk of harboring Chinese stowaways. The filter relied on 

commonalities that CBP identified and documented from the January and 

April 2005 incidents. In addition to the rule-sets, targeting officers may 

develop queries or filters to identify containers that match certain port-specific 

indicators. Officers can implement them quickly because they do not have to 

undergo CBP’s formal approval process. The filter created by CBP Los 

Angeles/Long Beach’s targeters identified containers that were laded or 

received in the ports in and near Shekou, China, the port at which the 

containers harboring stowaways in both incidents were laded. 

CBP Los Angeles/Long Beach also implemented recommendations by a team 

assigned by CBP headquarters to review its operations after the April 2005 

incident. The review team recommended changes to the Automated Targeting 

Unit, including increasing the unit’s staff to accomplish the additional 

research necessary on importers, consignees, and other aspects of container 

shipments. Among other changes, the review team also recommended that the 

port provide supervisory staff on all shifts. CBP Los Angeles/Long Beach 

increased the size of its targeting staff. CBP’s staff said that there are 

supervisors working on every shift. 

In addition, CBP Los Angeles/Long Beach port personnel instituted a new 

targeting approach. The impetus for this change was an April 28, 2005, CBP 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 19

headquarters memorandum instructing the ports to increase security measures 

due in part to the 2005 incidents. In addition to targeting maritime containers, 

crew, and passengers, the Los Angeles/Long Beach targeters created the 

Integrated Threat Analysis Group, which began targeting entire vessels by 

determining the risk presented in five areas: vessel type and history; ports of 

call; cargo; crew; and passengers. Each of the five areas is assessed for risks 

related to terrorism, narcotics smuggling, stowaways, deserters and 

absconders, agricultural or bio-terrorism, trade fraud, and illegal exports. Two 

other CBP ports, Baltimore and Philadelphia, subsequently instituted this 

approach. 

CBP Seattle/Tacoma responded to the April 2005 CBP memorandum to 

increase port security by reducing the Automated Targeting System’s 

terrorism threshold score for mandatory examinations from ------------ . As a 

result, the container harboring Chinese stowaways in April 2006 was held for 

a mandatory examination due to its score -------- Had Seattle maintained the 

original threshold score ------- , it is possible that the container would not have 

been subjected to additional review and held for examination. CBP 

Seattle/Tacoma’s targeters have maintained the ---- score as the threshold for 

mandatory examinations. 

In addition, CBP conducted a special operation, No. 2005-03, from May 5, 

2005, through May 27, 2005, in its West Coast field offices. The operation 

required ports to target containers with traits similar to the containers in the 

January and April 2005 incidents. Containers with the following 

characteristics were targeted: 

• ------------------------------

• ------------------------------------------------------------------------

• -------------------------- ---------------

The operation required that CBP examine all containers meeting these criteria. 

The operation ended because CBP analyzed incidents of Chinese stowaways 

in maritime cargo containers and determined that ----------------------------------

--------------------------------------- ----------- ----------------------------------------

---------------- ------- ---- --------

CBP’s Response to the April 2006 Incident

In response to the April 2006 incident, CBP Seattle/Tacoma port staff created 

new Automated Targeting System filters for detecting Chinese stowaways in 

maritime cargo containers. CBP Seattle port personnel developed a filter 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 20

similar to that created by Los Angeles/Long Beach that relied on 

commonalities between the three incidents. Within a few days of Seattle’s 

creation of a filter, CBP headquarters required all ports to use two new 

Chinese human smuggling filters that headquarters had developed in 

conjunction with CBP Los Angeles/Long Beach targeting staff. The filters 

added to the criteria the port of Shanghai as the port of lading and receipt. 

Shanghai was the port of lading for the stowaways in the Seattle incident. 

CBP headquarters issued standard operating procedures requiring targeters to 

conduct additional research on containers identified by the filters. The factors 

to be researched were commonalities that CBP had identified through its 

analysis of the incidents of Chinese stowaways in maritime cargo containers. 

When the filters identified a container, targeters were to research certain 

factors not captured by the Automated Targeting System. 

• ---------------------------------

• -------------- ------------ ------------------------------------------------

------------- ----- ---

• -----------------------------------------------

• ------- ----------------------------

• --------------------------------- ------------------------------

• ---------------------------------------------------------- ---- -------- --------

The standard operating procedures required CBP’s targeters to place a hold 

for examination on the containers that matched the factors or otherwise had 

indicia of human smuggling. 

CBP’s Current Efforts to Improve Targeting to Detect Chinese Stowaways

CBP is undertaking other improvements to detect Chinese stowaways in 

maritime cargo containers. At the conclusion of our fieldwork, CBP officials 

were negotiating with the shipping industry to expand the data provided in the 

24-hour rule submission. Among the additional data elements that CBP seeks 

are --------------------------- --------------------------------------------------------

---------------------------------------------- ----------------------------------. Having 

this information 24 hours prior to shipment would give CBP’s targeters more 

time to determine ----------------------- -------------------------- Knowing where 

containers were loaded would allow CBP to determine whether the loading 

point was near to those used in the past to load Chinese stowaways. However, 

historical analysis indicates that the smugglers change location. For years 

they loaded containers in Hong Kong, then in Busan, then in Shenzhen, and in 

April 2006, in Shanghai. The point of loading may be useful, but the 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 21

smugglers could begin to use new points of loading more frequently, which 

might make the information less useful. 

CBP is also negotiating to obtain ------------------------------------ ------------

-------- ----------------------------------------------------------------------------------

-------------------------- -------------------------------------------- ----------------------

------------------------------------------- ------------- ------------------------------------

----------------------------------------------- --------------- ------------------------ -

-------------------------------------------- ------------------------

Although CBP did not appear to have altered its targeting practices in 

response to the January 2005 incident, CBP ports made significant 

improvements to their targeting efforts in response to the April 2005 and April 

2006 incidents. Increasing the number of targeters and supervision at Los 

Angeles/Long Beach allows targeters more time to research important data 

points for targeting purposes. Moreover, although the new Integrated Threat 

Analysis Group reports are not directed solely to targeting for Chinese 

stowaways, they provide CBP with a more comprehensive view of an 

incoming vessel to plan appropriate enforcement action. CBP 

Seattle/Tacoma’s decision to decrease the mandatory examination threshold 

score will improve the likelihood of apprehending stowaways and other 

threats to national security. 

Likewise, CBP headquarters helped improve targeting capability, and it 

continues to enhance targeting by expanding the data required by the 24-hour 

rule. CBP’s development of a human smuggling filter for the Automated 

Targeting System represents an advance in targeting for Chinese stowaways in 

maritime cargo containers. The filters, in conjunction with the required 

research of commonalities, capture many of the factors shared by the 2005 

and 2006 incidents. 

CBP Modified Its Enforcement Activities 

Using the lessons it learned from the incidents, CBP also modified its 

enforcement efforts. CBP Los Angeles/Long Beach instituted a permanent 

change, using the Integrated Threat Analysis Group’s vessel targeting reports 

to direct and align enforcement activities between CBP enforcement teams 

and the USCG. CBP also increased patrols and vessel boardings and 

implemented more rapid examinations of containers targeted by the new 

Automated Targeting System filters for Chinese stowaways. CBP 

headquarters mandated these changes during brief special operations. CBP 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 22

ports have re-instated some of the enforcement activities for the current 

season of Chinese human smuggling. 

CBP’s Response to the January and April 2005 Incidents

As with the targeting procedures, it appears that CBP did not make changes to 

its enforcement efforts after the January 2005 incident. However, it did do so 

after the April 2005 incident. On April 28, 2005, CBP headquarters issued a 

memorandum requiring local enforcement teams to increase enforcement 

activities. In addition, the May 5, 2005, special operation affected targeting 

and special enforcement actions by CBP officers some of the large Pacific 

coast ports. 

The most significant change CBP made in response to the memorandum and 

the May special operation was to examine more quickly those containers 

identified by the Automated Targeting System terrorism rule-set. In one of its 

incident reports, CBP noted the following as a potential improvement to 

enforcement team practices: 

Prior to the May 2005 special operation, CBP did not specify when ports 

should examine containers, and ports scheduled examinations at times that 

were convenient to them and their terminal operators. The May special 

operation required CBP enforcement teams to board vessels and examine all 

containers that met the operation’s targeting criteria. When the targeted 

containers could not be examined on board the vessel, CBP required that 

enforcement teams examine containers immediately upon discharge. In 

addition, after the special operation concluded, CBP Los Angeles/Long Beach 

created, trained, and equipped a special enforcement stowaway team to 

examine containers targeted by its Automated Targeting System filters for 

Chinese stowaways within 6 hours of discharge. That team was operational 

during the following Chinese stowaway season in October 2005 through May 

2006, and did not discover any stowaways. 

CBP Los Angeles/Long Beach also instituted daily review of Integrated 

Threat Analysis Group reports by its chiefs and members of the USCG. The 

Ports should examine more expeditiously containers that are held 

for examination due to their scores on the terrorism rule-set. The 

shorter the delay between discharge and examination, the smaller 

the opportunity for the stowaways to escape. 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 23

meeting participants reviewed the threat level assessment for each vessel to 

determine how to focus and coordinate enforcement activities to address each 

potential threat. For vessels with a high risk of Chinese stowaways, the interagency vessel boarding team might decide to question the vessel’s crew about 

unusual noises or smells emanating from containers. The vessel boarding 

team might attempt to observe containers targeted for Chinese stowaways 

before the containers are discharged from the vessel, look for trap doors or 

out-of-place trash, sniff for unusual smells, or listen for noises. Other 

enforcement measures might be implemented, as well, depending on the level 

of the threat. Reviewing the Integrated Threat Analysis Group reports 

increases the likelihood of detecting Chinese stowaways and the effectiveness 

and efficiency of CBP enforcement activities. 

CBP port officials said that they were able to respond to the 2005 incidents 

quickly only because CBP officers happened to be working late on the nights 

the incidents occurred. To ensure a rapid response to future incidents of 

Chinese human smuggling or other threats, those CBP staff said the port 

should have a continuous watch command. However, at the time of our 

fieldwork, CBP management at the port did not have the resources to operate 

a continuous watch command. 

CBP’s Response to the April 2006 Incident

CBP headquarters issued a special operation directive to all ports on April 7, 

2006, in response to the April incident. CBP required that for all China 

Shipping Container Lines vessels, CBP enforcement teams had to board the 

vessels immediately, search the vessel for any signs of stowaway activity, 

monitor the vessel from the time of arrival to departure, and ensure that the 

containers discharged matched their manifest information. Teams were to 

examine targeted containers as soon as they were discharged from China 

Shipping Container Lines vessels, to the extent possible. For containers on 

other vessels arriving from certain Chinese ports and targeted by CBP 

headquarters’ new Automated Targeting System filters, CBP enforcement 

teams were expected to conduct the examination as soon as possible after the 

containers were discharged. In addition, enforcement teams were asked to 

maintain increased security patrols. CBP Seattle/Tacoma port staff arranged 

rapid examinations of targeted containers with the terminal operators. CBP 

Los Angeles/Long Beach continued the special stowaway enforcement team 

that it assembled after the April 2005 incident. 

Using the lessons learned from the three incidents, CBP enhanced its 

enforcement operations to identify and apprehend Chinese stowaways in 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 24

maritime cargo containers. Some of the modifications also improved CBP’s 

ability to identify and apprehend other violators. CBP should continue to 

examine, as quickly as possible, all containers held for examination due to 

Automated Targeting System terrorism rule-set scores. Quick responses to 

those containers might prevent or mitigate a serious incident. Likewise, the 

daily Integrated Threat Analysis Group report is a good tool for coordinating a 

comprehensive response to all threats. Officials in CBP headquarters are 

assessing the feasibility of expanding the Integrated Threat Analysis Group 

program to all CBP seaports. Finally, increasing patrols also improves not 

only the ability to apprehend stowaways, but also other violators. 

CBP Ports of Los Angeles/Long Beach and Seattle/Tacoma Prepared for 

New Smuggling Season 

CBP’s historical analyses indicated: (1) that the ports of Los Angeles/Long 

Beach and Seattle are the ports prone to Chinese stowaways in maritime 

containers; and (2) the incidents ----- ----------- -- --------------------

presumably ---------------------------- ----- -------------------- --------- ----------

------------- Since 1999, all of the containers harboring Chinese stowaways 

were destined for one of the two ports ------------------------ . Relying on 

CBP’s historical analyses, the CBP ports of Los Angeles/Long Beach and 

Seattle/Tacoma increased targeting and enforcement efforts ---------------------

------ ----------------------------- . 

CBP Los Angeles/Long Beach’s targeters are using the automated targeting 

system stowaway filters and Integrated Threat Analysis Group reports to 

identify vessels with a higher probability of harboring containers with Chinese 

stowaways. The enforcement teams are conducting patrols and surveillance 

activities to apprehend stowaways and other miscreants, -------------------------

---------------------- ------- Because earlier incidents at Los Angeles/Long 

Beach ----- ------- -------------------------- --------------------------------------- -

---------------- ----------- - ------ - -- ---------------- ------------------ --

------ --- ------------

CBP Seattle/Tacoma’s targeters are using the human smuggling filters and 

research procedures to detect containers with a high risk of harboring Chinese 

stowaways. The boarding teams now operate 24 hours a day, 7 days a week. 

They have begun boarding high-risk vessels with the intent to detect Chinese 

stowaways. As funds become available, CBP Seattle/Tacoma enforcement 

units will conduct other activities. 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 25

The CBP Los Angeles/Long Beach and Seattle/Tacoma increase in targeting 

and enforcement activities are appropriate and reflect the lessons learned from 

the three incidents. However, given that Chinese smuggling tactics have 

changed in the past, it is likely they will change again in the future. CBP 

Pacific coast ports need to alert their staff and industry partners to the 

heightened risk of Chinese human smuggling ----- --------------------------- and 

train staff to be vigilant for potential stowaways. 

We recommend that the CBP Commissioner: 

Recommendation #1: Distribute summaries of the commonalities shared by 

past incidents of Chinese human smuggling in containers to Pacific coast port 

personnel with an instruction to be alert to the possibility of incidents 

occurring in their ports. While increased targeting and enforcement activities 

are not yet called for at these ports, CBP personnel should be vigilant for 

Chinese stowaways in containers. 

Recommendation #2: Direct Pacific coast port personnel to inform its 

partners, such as terminal operators and local law enforcement, of the 

potential for Chinese human smuggling in cargo containers and indicia of 

such smuggling. Encourage local partners to contact CBP if they encounter 

suspicious parties at the ports. 

ICE Improved Coordination of Investigations With the Chinese 

Government, but Coordination With CBP Should Be Improved 

ICE’s investigations demonstrated the need to coordinate better with Chinese 

and CBP counterparts to conduct a successful investigation. Exchanging 

information with the Chinese government benefits both countries’ respective 

investigations. However, achieving an open and equitable exchange has been 

difficult and has required ICE officials to continue to develop their negotiating 

skills as they conduct their investigations. ICE officials were concerned that 

not being present at the initial stages of an apprehension of stowaways might 

hinder their investigations as well. While ICE has initiated some measures to 

improve response coordination with CBP, both components can do more to 

ensure that ICE has appropriate opportunities to advance its investigations. 

ICE Faces Significant Issues When Dealing With Chinese Investigative 

Counterparts

ICE learned from its investigations of the 2005 smuggling incidents that 

obtaining assistance from Chinese government officials is difficult. ICE 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 26

submitted all of its information to its Chinese counterparts, but received little 

in return. ----------------------------------------------------------------------------

------------------------------- In 2006, ICE revised its strategy for obtaining 

assistance from China. It meted out information, providing the Chinese 

officials one piece of information and insisting on receiving information in 

return before sharing another piece of information. That strategy was more 

successful; ICE obtained useful information from the Chinese government 

officials to advance its investigation, which is ongoing. 

----------------------------------------------------------------------------------

---------------------------------------------------------------------------------------------

--------------------------------------------------------------------------------------- ---

---------------------------------------------------------- ---- ----------------------

---------------------- ----- ----------------------------------------- -- ----------

-------- ------------------------------------------------------------------------------------

------------------------------- --------------------------------------------------------------

------------------------------------------- -------------------------------------- ---------

----------- ----------------- ----- ------ --------------------------------------------- --

-------- ------------------- ----------- -------- -------- ------------- --------

-------------------------------- ---------------------------------- ---- -------------------

---------------------- -------

ICE has no investigative authority in China and must seek assistance from its 

Chinese counterparts. ICE investigators communicate their investigative 

needs to the ICE attaché in Beijing, China, who coordinates with Chinese 

government officials. China has allowed ICE investigators access to officials 

in its Entry and Exit office, which oversees customs issues. However, ICE 

believes that the Entry and Exit office is not the appropriate counterpart, as it 

lacks true investigative capabilities. Given that China has made officials from 

this office available, ICE has continued to cooperate with them. According to 

ICE officials and staff, Chinese government officials do not distinguish ICE 

investigators from FBI, CIA, and other agencies. This has become a 

hindrance to obtaining investigative information from China because the 

Chinese government does not cooperate willingly with the other U.S. law 

enforcement and intelligence agencies. Moreover, ICE officials and 

investigators said that the Chinese government does not appreciate the U.S. 

asylum process and is less likely to cooperate with U.S. investigative requests 

when the smuggled Chinese nationals are granted asylum in the United States. 

The investigations concluded that the smuggling operations for each of the 

three incidents were located in mainland China. While investigating the 

January and April 2005 incidents, ICE investigators forwarded information 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 27

requests through the ICE attachés to the Chinese government. The Chinese 

government did not respond. In June 2005, ICE investigators organized a 

meeting with a Chinese delegation representing the Entry and Exit office to 

exchange information related to the 2005 smuggling cases. The investigators 

described the meetings as difficult and unproductive. ------------------- ------

---------------------------------------------------------------------------------------

-------------------------------------- ------------------------- -------------------

-------- ------ - ---- ---------------------- -----------------------------------------------

---------------------------------------

-------------------------------------------------------------------------------------------

-------------------------------------------- ----------------- ---------------------------

------------------------------------------ ---------------------------------------------------

------------------------------------------------- --------------------------------------------

------------------------------------------- ----------------------------------------------

----------------------------- -------------------------------------------------

------------------------------------ ------------------- ----------- -----------------------

----------------------------- -------------- -------------------------- --------

---------------------------------- -------------------------------------- -------------------

------------------------ -----------------------------------

With photographs of the suspected smugglers and knowledge of the staging 

areas, ICE was able to question the smuggled Chinese nationals more 

effectively and obtain new and useful information. Some of the smuggled 

Chinese nationals confirmed that the photographs were of the smugglers and 

of the loading areas. The investigation is still open and has made more 

progress than the 2005 investigation due to China’s willingness to share 

information. 

To formalize the information exchange process, ICE successfully negotiated a 

Memorandum of Understanding (MOU) with the China’s Ministry of Public 

Security and International Cooperation Department. The MOU was signed in 

July 2006. It is too early to be certain, but the MOU should provide some 

clarity to the collaborative process. 

The Lack of Formal Coordination Between ICE and CBP Might Have 

Hindered ICE’s Investigation

CBP and ICE do not have formal protocols for notifying each other when a 

smuggling incident occurs. Specifically, neither CBP Los Angeles/Long 

Beach’s nor CBP Seattle/Tacoma’s standard operating procedures for 

stowaways discuss ICE’s role or requirements for investigating incidents. The 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 28

Seattle/Tacoma document requires the port director to ensure that enforcement 

actions are coordinated with ICE, USCG, and other law enforcement entities, 

but it does not provide any details about how CBP should coordinate with 

ICE. As a result, all appropriate parties may not be present when a container 

suspected of human smuggling is opened, and the crime scene could be 

compromised. In the January 2005 incident, this procedural void resulted in 

delayed notification to ICE. While there is no way to know whether ICE 

would have gained substantiating evidence from being present at the opening, 

the failure to include ICE denied it that opportunity, which could have 

resulted in a stronger investigative case. 

It is critical that federal and local law enforcement agencies coordinate their 

immediate responses to incidents of Chinese stowaways in maritime 

containers because valuable information is very difficult to obtain during an 

investigation. ICE agents have emphasized the importance of timely 

notification, citing a successful smuggling investigation that resulted in a 

conviction in 2004. The success of that investigation was directly related to 

investigators being present when the container harboring Chinese stowaways 

was opened. 

In the January 2005 incident, CBP did not notify ICE until approximately 2 

hours after it notified USCG and others of the incident. Investigators from 

ICE’s port security and the human trafficking groups responded immediately. 

Upon arriving at the scene, they discovered that CBP officers and USCG sea 

marshals had already opened the second container, found stowaways inside, 

detained them, conducted cursory examinations of the container, and moved 

the containers. CBP officers were already interviewing the stowaways. CBP 

provided ICE with information from the interviews and a cellular telephone 

retrieved from one of the containers. 

----------------------------------------------------------------------------------------

-------------------- -----------------------------------------------------------------------

----------------------- -------------------------- --------------------------------------------

------------------------------------------- ------------------------------------ ---------

-------------------------------------------- ------------------------------------------

--------------------------------------------------------------------------------------

------------------------------------------------ ------------------------------- ------------

------------------------------- -------------------------------------------------------------- 

------------------------------------------- -----------------------------------------

-------------------------------------------------------------------------------
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 29

ICE agents said that shortly after the January incident, they met with CBP, 

USCG, and other law enforcement entities to discuss lessons learned and 

proper crime scene handling to preserve evidentiary integrity. The discussion 

and any agreements that resulted from the meeting were not documented. 

ICE made another attempt to formalize the response to incidents in June 2006, 

a few days before our interview with ICE’s Los Angeles/Long Beach 

investigators. The group supervisor for the January and April 2005 

investigations sent a letter to CBP and USCG to communicate the importance 

of an organized response and to seek resolution of the competing priorities. 

We later asked a Los Angeles/Long Beach CBP official about ICE’s request. 

The official acknowledged that there were discussions about preserving the 

crime scene, but CBP was not aware of any discussions about notifying and 

waiting for ICE before opening a container. The June 2006 letter did not 

resolve the problems that arose in the January 2005 incident. 

ICE employees expressed to us their interest in seeing USCG, CBP, and ICE 

create a human smuggling task force to respond to maritime human smuggling 

events. ICE envisioned task force members would coordinate their activities 

for the advantage of each of their agencies. At a minimum, the agencies 

would determine each other’s priorities and response requirements, and 

establish procedures by which each agency would be alerted to and afforded a 

full opportunity to respond effectively to human smuggling incidents. Those 

procedures would be clearly delineated in an interagency agreement. With 

clear procedures in place, ICE would be afforded the investigative 

opportunities it needs to successfully investigate human smuggling incidents. 

The components have not created this task force. 

We recommend that the Assistant Secretary for ICE and the Commissioner for 

CBP: 

Recommendation #3: Establish formal protocols to guide the department’s 

response to maritime human smuggling incidents. Determine organizational 

roles and responsibilities, especially with regard to: 

• Parties who must respond to human smuggling incidents and be 

present when opening containers suspected of holding human 

stowaways; 

• A notification system and timeline for contacting those parties; and 

• Actions to be taken to preserve the crime scene and other interests. 
A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

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Management Comments and OIG Analysis 

CBP and ICE provided a combined response to our report, which contained 

both technical and formal comments. We evaluated their response and made 

changes to the report where we deemed appropriate. We modified the report 

to incorporate updated data and phrasing regarding the CSI and C-TPAT 

programs that CBP suggested in its portion of the technical comments to the 

draft. We did not modify the wording of one paragraph as ICE requested 

because the draft’s language is sufficiently clear. 

The components identified both “Law Enforcement Sensitive” and “For 

Official Use Only” information that would be inappropriate to publish to the 

public. Many of the items identified directly answer the Congressional 

request to report what CBP and ICE had learned from the incidents and what 

changes they had made to improve operations as a result. Accordingly, we are 

providing the report in full to Congress, but are issuing a redacted version for 

public distribution. 

Below is a summary of the components’ response to each recommendation 

and our analysis. Appendix B contains a complete copy of the components’ 

combined response. 

Recommendation #1 (Directed to CBP): Distribute summaries of the 

commonalities shared by past incidents of Chinese human smuggling in 

containers to Pacific coast port personnel with an instruction to be alert to the 

possibility of incidents occurring in their ports. While increased targeting and 

enforcement activities are not yet called for at these ports, CBP personnel 

should be vigilant for Chinese stowaways in containers. 

CBP Response 

CBP concurs with the recommendation and suggests that activities it has 

undertaken have already satisfied the recommendation. CBP has: 

1. Created a centralized office to coordinate responses to containers 

suspected of harboring stowaways; 

2. Conducted a comprehensive analysis of the incidents and referred the 

commonalities to the affected ports; 

3. Appointed a CBP headquarters representative to ensure that potential 

human smuggling incidents are identified, targeted, and communicated 

appropriately; 
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4. Developed a reporting system for suspected human smuggling cases to 

capture key information; 

5. Established regular calls to the West Coast ports to discuss strategy, latest 

intelligence, and use of the human smuggling filters and rule sets in ATS; 

6. Issued a memorandum to remind the ports of the commonalities found 

between incidents of human stowaways in maritime cargo containers. 

OIG Analysis 

Of the activities listed, two may be responsive to our recommendation. Item 5 

may have served as a reminder of the commonalities and the need to be 

vigilant. However, CBP did not provide sufficient detail to confirm that the 

telephone calls relayed the required information. CBP provided us with a 

copy of the memorandum mentioned in item 6. The memorandum did not 

mention the commonalities that we requested for dissemination. 

Items 1, 2, 3, and 4 are not pertinent to the recommendation, although the 

actions they describe may be useful for coordinating CBP activities with 

regard to human smuggling incidents. The information CBP provided did not 

explain how the actions described in items 1, 3, and 4, address our first 

recommendation. With regard to item 2, the commonalities uncovered by the 

comprehensive analysis were distributed approximately a year ago. The goal 

of our recommendation is to provide a reminder to the Pacific port personnel 

of the commonalities and of the need for continued vigilance. 

Accordingly, this recommendation is resolved, but open. To close the 

recommendation, CBP should provide us with documentation of the actions 

taken to remind the Pacific port personnel of the commonalities noted from 

CBP’s earlier comprehensive review. 

Recommendation #2 (Directed to CBP): Direct Pacific coast port 

personnel to inform its partners, such as terminal operators and local law 

enforcement, of the potential for Chinese human smuggling in cargo 

containers and indicia of such smuggling. Encourage local partners to contact 

CBP if they encounter suspicious parties at the ports. 

CBP Response 

 

CBP concurred with the recommendation and reported it has taken actions to 

close it. CBP instructed its Directors of Field Operations to remind interested 

parties, including terminal operators, of the indicia of maritime human 
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Smuggling in Maritime Cargo Containers

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smuggling and of their responsibility to contact CBP when stowaways or 

indicia of stowaways are found onboard a vessel or in a container. 

OIG Analysis

 

We agree that CBP has fulfilled this recommendation, and consider the 

recommendation closed. 

Recommendation #3 (Directed to CBP and ICE): Establish formal 

protocols to guide the department’s response to maritime human smuggling 

incidents. Determine organizational roles and responsibilities, especially with 

regard to: 

• Parties who must respond to human smuggling incidents and be 

present when opening containers suspected of holding human 

stowaways; 

• A notification system and timeline for contacting those parties; and 

• Actions to be taken to preserve the crime scene and other interests. 

CBP and ICE Response

 

CBP and ICE responded to this recommendation, which was addressed to both 

components. The two components concur with the recommendation and 

report that their actions have fulfilled it. Their response referred to a 

December 8, 2005 MOU between them, which defines the roles of CBP and 

ICE at the ports of entry. The MOU provides that CBP will refer all complex 

criminal violations to ICE, such as those that involve foreign leads and coconspirators. Maritime container stowaway incidents fall within the definition 

of complex criminal investigations. Accordingly, the MOU established that 

ICE will be asked to respond to maritime container stowaway cases, such as 

those examined in this report. 

CBP and ICE determined that ICE was not required to be present at the 

opening of a container suspected of harboring stowaways. Both agreed that 

opening a container immediately to preserve the health and safety of 

stowaways was more important than delaying to allow ICE time to respond to 

the scene. 

Additionally, both components’ responded that the existing system to notify 

ICE of potential complex criminal investigations, the National Law 

Enforcement Communications Center, satisfies the notification and crime 

scene preservation aspects of the recommendation. CBP officers must use the 
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Smuggling in Maritime Cargo Containers

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system to notify ICE immediately when they uncover a potentially complex 

criminal case, such as those involving stowaways in maritime containers. 

Moreover, the response concludes that immediate notification to ICE will be 

adequate for crime scene preservation. 

Finally, CBP and ICE refer to a working group to coordinate their activities 

and the Maritime Operations Threat Response protocols, which are designed 

to “ensure a seamless coordination effort to address maritime threats.” 

OIG Analysis

 

We agree that CBP and ICE have satisfied the recommendation, and consider 

the recommendation closed. We did not receive, but should have been 

provided, the December 8, 2005 MOU during fieldwork in response to our 

request for: “Any SOPs, procedures, policies, or other documents defining the 

roles of CBP, ICE, and USCG in responding to aliens smuggled into U.S. 

ports.” When asked, no CBP or ICE personnel at the ports named the MOU 

or the communication system as guidance for responding to incidents of 

stowaways in cargo containers. Nonetheless, CBP and ICE have provided 

documentation subsequently that defines their roles in responding to cases of 

maritime container stowaways and have established expectations that CBP 

will immediately notify ICE through an existing 24-hour system as soon as 

such cases are discovered so that the crime scene may be preserved. We 

remain concerned that port personnel may not be aware of the MOU and the 

procedures CBP described in its response, as the 2006 incident was not 

handled in accordance with the procedures set forth in the MOA. We 

encourage CBP to remind its personnel of these procedures.
Appendix A 

Purpose, Scope and Methodology 

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Smuggling in Maritime Cargo Containers

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We conducted this review at the request of the Senate Committee on 

Homeland Security and Governmental Affairs, the House Committee on 

Energy and Commerce, and the House Permanent Subcommittee on 

Investigations to answer the following questions: 

• Are the current layers of container security effective in mitigating the 

smuggling threat? 

• Is DHS learning from and adjusting its operations? 

• Is DHS incorporating the lessons learned to improve its targeting 

systems and operations? 

We conducted our fieldwork from May 16, 2006, through August 24, 2006. 

During this period, we interviewed 62 people in CBP, ICE, DHS HQ, and 

members of the maritime shipping community, and we attended a CSI 

conference. We traveled to Seattle, Washington, and Long Beach, California, 

to interview CBP and ICE personnel and tour CBP port facilities, terminals, 

container ships, and examination facilities. We also traveled to Secaucus, 

New Jersey, to interview executives from Nippon Yusen Kaisha and China 

Shipping Container Lines. 

We examined many documents related to CBP and ICE special operations, 

operational statistics, correspondence, port musters, post-event analyses, 

procedural manuals, and program requirements. We reviewed reports issued 

by the General Accountability Office, the Congressional Research Service, the 

Congressional Budget Office, and the Senate Permanent Subcommittee on 

Investigations. 

This review was conducted under the authority of the Inspector General Act of 

1978, as amended, and according to the Quality Standards for Inspections 

issued by the Presidents Council on Integrity and Efficiency. 
Appendix B 

Management Response to Draft 

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Smuggling in Maritime Cargo Containers

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Appendix B 

Management Response to Draft 

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Smuggling in Maritime Cargo Containers

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Appendix B 

Management Response to Draft 

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Smuggling in Maritime Cargo Containers

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Appendix B 

Management Response to Draft 

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Smuggling in Maritime Cargo Containers

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Appendix B 

Management Response to Draft 

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Smuggling in Maritime Cargo Containers

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Appendix C 

Congressional Request Letter 

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Smuggling in Maritime Cargo Containers

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Appendix C 

Congressional Request Letter 

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Smuggling in Maritime Cargo Containers

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Appendix C 

Congressional Request Letter 

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Smuggling in Maritime Cargo Containers

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Appendix C 

Congressional Request Letter 

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Smuggling in Maritime Cargo Containers

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Appendix D 

CBP and ICE Modifications Made in Response to Incidents 

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Smuggling in Maritime Cargo Containers

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CBP Modifications Made in Response to Incidents 

C-TPAT 

• Established procedures for handling members involved in human 

smuggling incidents, including mandatory assessment and correction of 

security vulnerabilities at foreign ports. 

• Updated minimum-security criteria to require sea carriers to screen new 

customers for security risks and ensure that their nonvessel-operator 

common carriers commit to C-TPAT security recommendations.

CSI 

• Continues negotiations in expanding to ports in the Chinese region of 

Shenzhen, including Shekou, the port where the containers were laden.

• Negotiating for the submission of additional data elements to improve 

targeting in general and targeting for Chinese stowaways in particular. 

Domestic Port Targeting 

• Developed Automated Targeting System human smuggling filters and 

research procedures. 

• Increased targeting staff in CBP Los Angeles/Long Beach. 

• Developed the Integrated Threat Analysis Group vessel targeting 

methodology in Los Angeles/Long Beach. 

• Lowered automated targeting system threshold scores for mandatory 

examinations in Seattle/Tacoma. 

Domestic Port Enforcement 

• Negotiated with terminal operators to obtain containers targeted for human 

smuggling more quickly. 

• Conducted examinations of suspicious containers immediately or soon 

after discharge. 

• Implemented daily coordination with USCG using Integrated Threat 

Analysis Group reports at Los Angeles/Long Beach.

• Boarded vessels to observe containers for smells, sounds, trash, and to 

question crewmembers.

• Maintained surveillance on suspicious vessels or containers. 

• Increased patrols. 
Appendix D 

CBP and ICE Modifications Made in Response to Incidents 

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Smuggling in Maritime Cargo Containers

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ICE Modifications Made in Response to Incidents 

• Improved methods for obtaining information from the Chinese 

government.
Appendix E 

Major Contributors to the Report 

A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 46

William McCarron, Chief Inspector, Department of Homeland Security, 

Office of Inspections 

Elizabeth Kingma, Senior Inspector, Department of Homeland Security, 

Office of Inspections 

Russell Lundberg, Inspector, Department of Homeland Security, Office of 

Inspections 

Lawrence Anderson, Inspector, Department of Homeland Security, Office of 

Inspections
Appendix F 

Report Distribution 

A Review of CBP and ICE Responses to Recent Incidents of Chinese Human 

Smuggling in Maritime Cargo Containers

Page 47

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Assistant Secretary for Public Affairs 

Assistant Secretary for Policy 

Assistant Secretary, Legislative and Intergovernmental Affairs 

Chief Security Officer 

Assistant Secretary for Immigration and Customs Enforcement 

Commissioner for Customs and Border Protection 

DHS OIG Liaison 

CBP Audit Liaison 

ICE Audit Liaison 

Chief Privacy Officer 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS Program Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at 

(202) 254-4100, fax your request to (202) 254-4285, or visit the OIG web site at 

www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or 

noncriminal misconduct relative to department programs or operations, call the OIG 

Hotline at 1-800-323-8603; write to DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 245 Murray Drive, SW, Building 410, 

Washington, DC 20528, fax the complaint to (202) 254-4292; or email 

DHSOIGHOTLINE@dhs.gov. The OIG seeks to protect the identity of each writer and 

caller.