Report to the Senate and House 

Committees on Appropriations 

United States Government Accountability Office

GAO

January 2005 DRUG CONTROL

High Intensity Drug 

Trafficking Areas’ 

Efforts to Link 

Investigations to 

International Drug 

Traffickers 

GAO-05-122 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-122.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Laurie 

Ekstrand, (202) 512-2758 or 

ekstrandl@gao.gov. 

Highlights of GAO-05-122, a report to the 

Senate and House Committees on 

Appropriations 

January 2005

DRUG CONTROL

High Intensity Drug Trafficking Areas' 

Efforts to Link Investigations to 

International Drug Traffickers 

The mission of the HIDTA program is to enhance and coordinate U.S. drug 

control efforts among federal, state, and local law enforcement agencies to 

eliminate or reduce drug trafficking and its harmful consequences in 

HIDTAs. CPOT investigations were not inconsistent with this mission 

because HIDTAs’ targeting of local drug traffickers linked with international 

organizations on the CPOT list was one possible strategy for achieving the 

program’s goal of eliminating or reducing significant sources of drug 

trafficking in their regions. GAO found that in fiscal years 2002 through 2004, 

ONDCP distributed discretionary funds to 17 of the 28 HIDTAs for CPOT 

investigations. Some HIDTA officials said they did not receive CPOT funding 

for several reasons including unclear guidance, insufficient application 

information to the HIDTAs for funding, and local priorities not linking with 

CPOT investigations. Reduced discretionary funding in fiscal year 2004 for 

CPOT investigations affected the number of HIDTAs that received this 

funding. 

ONDCP and the Department of Justice (Justice) agreed with the facts in this 

report. Regarding application information provided to HIDTAs, ONDCP did 

not agree with some HIDTA officials’ view that it was insufficient. Justice 

acknowledged that some HIDTAs faced difficulty obtaining the CPOT list but 

were confident the problem has been overcome. Regarding local priorities 

not linking with CPOT investigations, ONDCP stated HIDTAs should be 

focusing on investigations of local activities that reach beyond the 

boundaries of the HIDTA, given their designation as centers of illegal 

trafficking that affect other parts of the country. 

High Intensity Drug Trafficking Areas That Received CPOT Funding for Fiscal Years 2002 

through 2004 

Source: GAO.

IDTA headquarters that received CPOT funding

Five locations along the southern border constitute the Southwest Border HIDTA, which received CPOT funding

New England

New York/New Jersey

Washington, D.C./

Baltimore

South Florida

Houston

Ohio

Southwest

Border

Hawaii

Los Angeles

Central

Valley

Northern

California

Oregon

Northwest

Midwest

Chicago

North Texas

West Texas

New Mexico

Gulf Coast

South Texas

Arizona region

California border

In fiscal year 2002, the Attorney 

General called upon law 

enforcement to target the “most 

wanted” international drug 

traffickers responsible for 

supplying illegal drugs to America. 

In September 2002, law 

enforcement, working through the 

multi-agency Organized Crime 

Drug Enforcement Task Force 

(OCDETF) Program, developed a 

list of these drug traffickers, known 

as the Consolidated Priority 

Organization Target List (CPOT), to 

aid federal law enforcement 

agencies in targeting their drug 

investigations. Also, the White 

House’s Office of National Drug 

Control Policy (ONDCP) 

collaborated with law enforcement 

to encourage existing High 

Intensity Drug Trafficking Areas 

(HIDTA) to conduct CPOT 

investigations. According to 

ONDCP, the 28 HIDTAs across the 

nation are located in centers of 

illegal drug production, 

manufacturing, importation, or 

distribution. ONDCP distributed 

discretionary funds to supplement 

some HIDTAs’ existing budgets 

beginning in fiscal year 2002 to 

investigate CPOT organizations. 

Out of concern that a CPOT 

emphasis on international drug 

investigations would detract from 

the HIDTA program’s regional 

emphasis, the Senate Committee 

on Appropriations directed GAO to 

examine whether investigations of 

CPOT organizations are consistent 

with the HIDTA program’s mission 

and how ONDCP distributes its 

discretionary funds to HIDTAs for 

CPOT investigations. 
Page i GAO-05-122 Drug Control 

Letter 1

Results in Brief 3 

Scope and Methodology 4 

Background 5 

CPOT Investigations Were Not Inconsistent with the Mission of the 

HIDTA Program 7 

ONDCP Distributed Discretionary Funds to Many HIDTAs to Help 

Support CPOT Investigations 9 

Agency Comments and Our Evaluation 16 

Appendix I CPOT Funding Awarded to HIDTAs, Fiscal Years 

2002, 2003, and 2004 18 

Appendix II Federal Law Enforcement Organizations Engaged in 

CPOT Investigations 19 

Appendix III Comments from the White House Office of National 

Drug Control Policy 22 

Appendix IV Comments from the Department of Justice 25 

Appendix V GAO Contacts and Staff Acknowledgments 27 

GAO Contacts 27 

Staff Acknowledgments 27 

Figures 

Figure 1: CPOT Funding by Fiscal Years 13 

Figure 2: Seventeen of 28 High Intensity Drug Trafficking Areas 

That Received CPOT Funding for Fiscal Years 2002 

through 2004 15 

Figure 3: Federal Law Enforcement Organizations Conducted 744 

CPOT Investigations in Fiscal Year 2003 19 

Contents 
Page ii GAO-05-122 Drug Control 

Figure 4: Federal Agencies That Conduct CPOT Investigations 21 

Abbreviations

CPOT Consolidated Priority Organization Target 

DEA Drug Enforcement Administration 

FBI Federal Bureau of Investigation 

HIDTA High Intensity Drug Trafficking Areas 

OCDETF Organized Crime Drug Enforcement Task Force 

ONDCP Office of National Drug Control Policy 

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Page 1 GAO-05-122 Drug Control 

January 28, 2005 

The Honorable Thad Cochran 

Chairman 

The Honorable Robert C. Byrd 

Ranking Minority Member 

Committee on Appropriations 

United States Senate 

The Honorable Jerry Lewis 

Chairman 

The Honorable David Obey 

Ranking Minority Member 

Committee on Appropriations 

House of Representatives 

The war against illegal drugs is fought both internationally and 

domestically, as many of the “most wanted” international drug traffickers 

are the primary suppliers of illegal drugs in the United States. In 

September 2002, the U.S. Attorney General called on the law enforcement 

community to target the most wanted international drug traffickers for 

special law enforcement emphasis by developing a list known as the 

Consolidated Priority Organization Target (CPOT) list. The White House’s 

Office of National Drug Control Policy (ONDCP) collaborated with the 

Department of Justice (Justice) in an effort to encourage High Intensity 

Drug Trafficking Areas (HIDTA)1

 to conduct CPOT investigations. ONDCP, 

through its federally funded HIDTA program, coordinates much of 

America’s drug control efforts among federal, state, and local agencies to 

reduce drug trafficking in critical regions of the United States. ONDCP 

responded to Justice’s emphasis on the CPOT list by designating a portion 

of its discretionary funds to supplement HIDTAs’ ongoing investigations of 

drug traffickers that link with international drug organizations on the 

CPOT list. 

 1

The HIDTA program is a federally funded program that brings together federal, state, and 

local law enforcement agencies into task forces that conduct investigations of drug 

trafficking organizations engaged in illegal drug production, manufacturing, importation, or 

distribution. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-122 Drug Control 

Out of concern that a CPOT emphasis on international drug investigations 

would detract from the HIDTA program’s regional emphasis, the Senate 

Committee on Appropriations, in its Committee Report 108-146, directed 

us to, among other things, conduct a study concerning whether 

investigations of international drug trafficking organizations on the CPOT 

list are consistent with the HIDTA mission. For this report, we examined 

(1) whether CPOT investigations2

 undertaken by HIDTAs were consistent 

with the mission of the HIDTA program as authorized in the Office of 

National Drug Control Policy Reauthorization Act of 19983

 (the 

Reauthorization Act) and (2) how ONDCP distributed discretionary funds 

to HIDTAs for CPOT investigations and why some HIDTAs did not receive 

funding. We are also providing information in appendix II about federal 

law enforcement organizations that are engaged in CPOT investigations 

and how many investigations they conducted in fiscal year 2003 and the 

first 7 months of fiscal year 2004.4

To address these objectives, we reviewed applicable legislation, ONDCP 

strategic plans and policies, and all HIDTA applications (38) for CPOT 

funding in fiscal years 2002 and 2003 to determine whether CPOT 

investigations, as discussed in the applications, were consistent with the 

HIDTA mission. We reviewed documents and correspondence that 

described the basis for ONDCP’s decisions for distributing CPOT funds to 

HIDTAs and interviewed officials at 8 of the 13 HIDTAs that did not 

receive CPOT funds in fiscal years 2002 and 2003. We also interviewed 

officials at federal law enforcement agencies engaged in CPOT 

investigations. We conducted our work between March and December 

2004 in accordance with generally accepted government auditing 

standards. 

 2

We are using the term CPOT investigations in this report to describe domestic drug 

investigations conducted by HIDTAs that link to leaders of international drug organizations 

on the CPOT list. 

3

Pub. L. No. 105-277, div. C, tit. VII, §§ 701-715, 112 Stat 2681, 2681-670-93. 

4

We were unable to determine the dollar amounts that federal agencies designated for 

CPOT investigations because they do not record resources for CPOT investigations 

separately from resource expenditures for other investigations they conduct. 
Page 3 GAO-05-122 Drug Control 

CPOT investigations were not inconsistent with the HIDTA mission 

because HIDTAs’ targeting of local drug traffickers5

 linked with 

international organizations on the CPOT list was one possible strategy for 

achieving the program’s goal of eliminating or reducing significant sources 

of drug trafficking in their regions. On the basis of the Reauthorization 

Act, ONDCP interpreted the HIDTA mission as enhancing and 

coordinating U.S. drug control efforts among federal, state, and local law 

enforcement agencies to eliminate or reduce drug trafficking and its 

harmful consequences in HIDTAs. Drug traffickers operating in a HIDTA 

that are affiliated with illegal international drug organizations would 

contribute to the HIDTA’s status as a center of illegal drug importation as 

well as have a harmful impact in other regions. These two factors—

importation and distribution across regions—are among several statutory 

factors that the director of ONDCP must consider when designating a 

region as a HIDTA. 

ONDCP distributed discretionary funds to HIDTAs to help support their 

investigations of drug traffickers linked with international organizations 

on the CPOT list by reviewing and approving applications for funding from 

the HIDTAs. During fiscal years 2002, 2003, and 2004, 17 of 28 HIDTAs 

received CPOT funds. ONDCP encourages applications for CPOT funding 

where additional funds are likely to benefit an initiative and move the 

investigation forward. However, we identified several reasons why certain 

HIDTAs did not receive funding, including unclear guidance in fiscal year 

2002, insufficient information for applying for funding, and local priorities 

not linking with CPOT investigations. ONDCP addressed the unclear 

guidance by meeting with HIDTAs to explain how to link their 

investigations with the CPOT list. ONDCP was unable to provide the full 

CPOT list to the HIDTAs, which would help them determine if they qualify 

for funding. Justice and several other federal law enforcement agencies 

controlled and tracked the distribution of the CPOT list and designated it 

as “law enforcement sensitive.” They determined that sharing the full 

CPOT list with HIDTAs, state or local police, and non-law enforcement 

organizations such as the White House’s ONDCP was to be done on a 

“need-to-know” basis at their discretion. Justice said it was not its intent to 

withhold access to the CPOT list from HIDTA personnel. Although we 

have no indications of such intent, we found some HIDTAs had more 

 5

We are using the term local drug traffickers to refer to HIDTA region-wide drug trafficking 

organizations that have been identified by HIDTAs in their ONDCP-approved threat 

assessments developed in consultation with the local, state, and federal law enforcement 

agencies within their respective geographic region. 

Results in Brief 
Page 4 GAO-05-122 Drug Control 

difficulty than others in obtaining the full CPOT list from these agencies. 

Although ONDCP believes the information it provided to HIDTAs was 

sufficient, some HIDTAs disagree. In 2004, ONDCP advised all HIDTAs 

that because of reduced discretionary funding for CPOT investigations, 

they should focus their applications on three specific CPOT organizations 

that provided a baseline of opportunity for all HIDTAs to apply for CPOT 

funding. ONDCP recognized that reduced discretionary funding for CPOT 

investigations in fiscal year 2004 affected the number of HIDTAs that 

received this funding. With respect to local priorities, some HIDTAs did 

not request or receive funding because they could not show a link between 

CPOT organizations and their investigations of domestic drug producers 

and distributors. However, ONDCP stressed that HIDTAs should be 

focusing on investigations of local activities that reach beyond the 

boundaries of the HIDTA, given their designation as centers of illegal 

trafficking that affect other parts of the country. 

We provided a draft of this report to the Director of ONDCP and the 

Department of Justice’s Attorney General for their review and comment, 

and both generally concurred with the facts of this report but added some 

clarifying language, which we incorporated in the report where 

appropriate. A copy of the comments from both agencies is in appendixes 

III and IV, respectively. 

To obtain information on whether CPOT investigations were consistent 

with the mission of the HIDTA program, we reviewed the Office of 

National Drug Control Policy Reauthorization Act of 1998, ONDCP’s 

appropriations statutes and accompanying committee reports, ONDCP’s 

strategic plans and policies, and ONDCP’s Web site.6

 We also reviewed all 

HIDTA applications (38) to ONDCP from HIDTAs that received 

discretionary funds for various investigation activities linked to the CPOT 

list in fiscal years 2002 and 2003, and compared them with the mission of 

the HIDTA program.7

 At 11 selected HIDTA sites—Appalachia; Atlanta; 

Central Florida; Lake County, Indiana; Los Angeles; Milwaukee; Nevada; 

North Texas; Oregon; Rocky Mountain; and Washington-Baltimore—we 

interviewed HIDTA management officials and task force leaders to discuss 

 6

ONDCP’s Internet Web page: 

http://www.whitehousedrugpolicy.gov/hidta/frames_overview.html/. 

7

We did not include applications awarded CPOT funding for fiscal year 2004 in our 

application review because ONDCP had not concluded the award process at that time. 

Scope and 

Methodology 
Page 5 GAO-05-122 Drug Control 

whether their investigative activities were consistent with the HIDTA 

mission. We selected these 11 HIDTAs to ensure geographic spread (east 

coast, central, west coast) across the country. 

To obtain information about ONDCP’s distribution of CPOT funding, we 

interviewed ONDCP officials and obtained statistics they provided on 

HIDTAs that received CPOT funding in fiscal years 2002, 2003, and 2004 

(app.I). We also reviewed ONDCP documents and correspondence that 

described the basis for ONDCP’s decision for awarding HIDTAs CPOT 

funding. In addition, we discussed with officials at three HIDTAs— 

Washington-Baltimore, North Texas, and Los Angeles—how CPOT funding 

was being used. We selected these three HIDTAs because they had 

received funds for both fiscal years 2002 and 2003 and were geographically 

dispersed. We also interviewed officials from 8 of the 13 HIDTAs 

(Appalachia, Atlanta, Central Florida, Lake County, Milwaukee, Nevada, 

Oregon, and Rocky Mountain) that did not apply for or applied for but did 

not receive CPOT funding in fiscal years 2002 and 2003. We selected these 

HIDTAs to reflect broad geographic segments of the country. 

We determined that the data presented in appendixes I and II from 

ONDCP, the Organized Crime Drug Enforcement Task Force (OCDETF), 

the Drug Enforcement Administration (DEA), and the Federal Bureau of 

Investigation (FBI) are sufficiently reliable, for the purposes of this review, 

based on interviews with agency officials and a review of their information 

systems documentation. 

In 1988, Congress established the White House’s Office of National Drug 

Control Policy to, among other things, coordinate the efforts of federal 

drug control agencies and programs and establish the HIDTA program. By 

fiscal year 2004, ONDCP had designated 28 drug trafficking areas 

(HIDTAs) as centers of illegal drug production, manufacturing, 

importation, or distribution within the United States with a federally 

funded HIDTA program budget of about $225 million.8

 Each HIDTA is to 

develop and implement an annual strategy to address the regional drug 

threat. The initiatives involve the active participation of federal, state, and 

 8

Congressional funding for the HIDTA program, which was between $221 and $225 over the 

last 3 fiscal years up through 2004, consisted of a base level of about $206 million for 

HIDTA operations (allocated to each HIDTA at a level not less than what they received the 

previous year), and discretionary funds of between $15 and $19 million for special projects, 

such as CPOT funding. 

Background 
Page 6 GAO-05-122 Drug Control 

local law enforcement agencies to enhance and assist the coordination of 

drug trafficking control efforts in the region. To encourage HIDTAs to 

conduct CPOT investigations, ONDCP utilized discretionary funding. In 

fiscal year 2004, ONDCP allocated about $8 million in discretionary 

funding to HIDTAs to support their drug initiatives that link with 

international drug trafficking organizations on the CPOT list. This funding 

is not meant to supplant or replace existing agency/program budgets 

intended for similar purposes, according to ONDCP guidance to the 

HIDTAs. 

OCDETF is a nationwide law enforcement task force program 

administered within Justice that targets major narcotic trafficking and 

money laundering organizations using the combined resources and 

expertise of its federal member agencies together with state and local 

investigators.9

 Its mission is to identify, investigate, and prosecute 

members of high-level drug trafficking enterprises and to dismantle or 

disrupt the operations of those organizations. To help carry out this 

mission and to focus investigative resources on major sources of supply, 

OCDETF member agencies developed the CPOT list of major international 

drug trafficking organizations. 

In September 2002, at the request of the U.S. Attorney General, OCDETF 

issued the first CPOT list, naming international drug trafficking 

organizations most responsible for supplying illegal drugs to the United 

States. OCDETF member agencies developed criteria for determining 

whether an international drug organization was to be placed on the CPOT 

list. Criteria include whether the international organization 

• operates nationwide in multiple regions of the United States and 

• deals in substantial quantities of illegal drugs or illicit chemicals on a 

regular basis that have a demonstrable impact on the nation’s drug 

supply. 

 9

OCDETF’s member federal agencies are the Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF); the Drug Enforcement Administration; the Federal Bureau of 

Investigation; the Internal Revenue Service (IRS); the United States Coast Guard (USCG); 

the Bureau of Immigration and Customs Enforcement (ICE); and the United States 

Marshals Service (USMS). 
Page 7 GAO-05-122 Drug Control 

OCDETF compiles and issues the CPOT list at the beginning of each fiscal 

year,10 with the intent that federal law enforcement agencies will target 

their investigations on CPOT organizations. OCDETF member agencies 

control the CPOT list and its distribution. OCDETF also collaborates with 

ONDCP on reviews of CPOT funding applications by HIDTAs that link 

their initiatives with the CPOT list. 

CPOT investigations were not inconsistent with the mission of the HIDTA 

program because HIDTAs’ targeting of local drug traffickers linked with 

international organizations on the CPOT list was one possible strategy for 

achieving the program’s goal of eliminating or reducing significant sources 

of drug trafficking in their regions. The mission of the HIDTA program is 

not expressly stated in current law. However, ONDCP has developed a 

mission statement that reflects the legislative authority for the HIDTA 

program, specifically, to enhance and coordinate U.S. drug control efforts 

among federal, state, and local law enforcement agencies to eliminate or 

reduce drug trafficking and its harmful consequences in critical regions of 

the United States. 

The primary legislative authority for the HIDTA program is the 

Reauthorization Act,11 which provides guidance on the mission of the 

program by setting out factors for the Director of ONDCP to consider in 

determining which regions to designate as HIDTAs. The factors contained 

in the act are the extent to which 

1. the area is a center of illegal drug production, manufacturing, 

importation, or distribution; 

2. state and local law enforcement have shown a determination to 

respond aggressively to drug trafficking in the area by committing 

resources to respond to it; 

3. drug-related activities in the area are having a harmful impact in other 

areas of the country; and 

 10OCDETF reviews the CPOT list at the midpoint of the fiscal year and adds drug trafficking 

organizations, if warranted. 

11The Office was originally established by the Anti-Drug Abuse Act of 1988, Pub. L. No. 100-

690, 102 Stat. 4181, 4181, with almost identical language authorizing the HIDTA Program, 

id. §1005(c), 102 Stat. at 4186. 

CPOT Investigations 

Were Not Inconsistent 

with the Mission of 

the HIDTA Program 
Page 8 GAO-05-122 Drug Control 

4. a significant increase in federal resources is necessary to respond 

adequately to drug-related activities in the area.12

In addition, House and Senate Appropriations Committee reports on 

ONDCP’s appropriations have stated that the program was established to 

provide assistance to federal, state, and local law enforcement entities 

operating in those areas most adversely affected by drug trafficking.13

The use of a portion of the HIDTA program’s discretionary funds to focus 

on CPOT investigations is not inconsistent with ONDCP’s mission 

statement for the program and the legislative authority on which it is 

based, particularly the first and third factors in the Reauthorization Act. 

Drug traffickers operating in a HIDTA may be linked with the CPOT list 

because of their role in major international drug trafficking activities, 

including illegal distribution in multiple regions of the United States. Given 

such activities, they would contribute to the HIDTA’s status as a center of 

illegal drug importation and distribution and have a harmful impact in 

other regions. Similarly, in keeping with appropriations committee 

statements on the purpose of the program, HIDTA involvement in CPOT 

investigations is one way of assisting federal, state, and local operations in 

areas where the significant adverse effects of drug trafficking activities are 

due in part to links to international criminal organizations. Thus, for 

HIDTAs to investigate and disrupt or dismantle regional drug traffickers 

that are linked with CPOT organizations is not inconsistent with the 

HIDTA program’s stated mission and its legislative authority. 

 12Office of National Drug Control Policy Reauthorization Act of 1998, §707(c) (codified at 

21 U.S.C. §1706(c) (2000)). These same factors were listed in §1005(c)(2) of the Anti-Drug 

Abuse Act of 1988 when the HIDTA program was first authorized. 

13See, e.g., S. Rep. No. 108-146, at 139 (2003); H.R. Rep. No. 107-575, at 68 (2002); S. Rep. No. 

107-212, at 59 (2002). 
Page 9 GAO-05-122 Drug Control 

ONDCP distributed discretionary funds to HIDTAs to help support their 

investigations of drug traffickers linked with international organizations 

on the CPOT list by reviewing and approving HIDTA applications for 

funding. In fiscal years 2002, 2003, and 2004, ONDCP distributed CPOT 

funds to a total of 17 of the 28 HIDTAs.14 A Justice official who participates 

in the evaluation of HIDTA applications for CPOT funding said that 

ONDCP encourages applications for CPOT funding where additional funds 

are likely to benefit an initiative and move the investigation forward. Some 

HIDTAs chose not to apply because they face a domestic drug threat that 

does not have a link to any international CPOT organization activity. Other 

HIDTAs that have applied for funds did not receive CPOT funding because 

they did not have sufficient investigative resources to uncover the link to a 

CPOT organization. In commenting on a draft of this report, Justice said 

that while this may be true in some circumstances, it was also often the 

case that HIDTAs may have had sufficient resources but simply had not 

yet taken the investigation far enough to justify the award of discretionary 

funds. During fiscal years 2002 and 2003, 6 HIDTAs did not apply and 7 

applied but were not approved for CPOT funding. In fiscal year 2004, 17 of 

the 28 HIDTAs did not receive CPOT funding—10 did not apply and 7 

applied but were not approved for funding. 

ONDCP and HIDTA officials mentioned several reasons why some HIDTAs 

may not receive funding. 15 First, some HIDTAs were denied funding if the 

investigative activities in their funding applications were not consistent 

with the HIDTA mission and linked to a CPOT organization. Second, 

ONDCP did not provide clear guidance or sufficient information for 

HIDTAs to develop their applications for CPOT funds, although it took 

steps to clarify its guidance and create opportunity for all HIDTAs to 

participate. Third, reducing the amount of discretionary funds available for 

CPOT funding in fiscal year 2004 affected the number of HIDTAs that 

received this funding. Fourth, HIDTAs’ local priorities may not link to any 

CPOT organization activity. 

 14In fiscal year 2002, 8 HIDTAs received CPOT funding; in fiscal year 2003, 14 HIDTAs 

received CPOT funding; in fiscal year 2004 11 HIDTAs received CPOT funding. Collectively, 

in all 3 years 17 HIDTAs received CPOT funding (see app.1). 

15Our review of applications for CPOT funding did not include those for which no funds 

were awarded by ONDCP. 

ONDCP Distributed 

Discretionary Funds 

to Many HIDTAs to 

Help Support CPOT 

Investigations 
Page 10 GAO-05-122 Drug Control 

ONDCP granted CPOT funding for HIDTA investigative activities that it 

determined demonstrated a link to the CPOT list and were consistent with 

the mission of the HIDTA program.16 As an example, one of the 

applications we reviewed requested CPOT funding for overtime pay, video 

cameras, portable computers, and wiretaps for surveillance activities to 

target a complex criminal organization involved in the distribution of 

significant quantities of heroin and cocaine as well as related homicides, 

abductions, arson, assaults, fraud, and witness tampering. Surveillance of 

the organization indicated that it was being supplied with drugs through an 

affiliate of a Latin American/Caribbean-based CPOT organization. 

Therefore, these drug activities were linked to an organization on the 

CPOT list, and the investigations also were consistent with the HIDTA 

program’s mission, in that these activities contributed to eliminating or 

reducing significant sources of drug trafficking within the HIDTA region. 

Drug investigation activities that were not consistent with the HIDTA 

program’s mission were not to receive CPOT funds from ONDCP, even if 

they showed a CPOT link. Specifically, it is inconsistent with the HIDTA 

program’s mission to supplant funds from other sources. Rather CPOT 

funds are meant to supplement funding for investigations that support the 

HIDTA mission. For example, in one HIDTA application, a request was 

made for $686,000 for the HIDTA to provide software to a cellular 

telephone company located in a Caribbean country to monitor the cellular 

telephone calls of a CPOT organization. The application also asked for 

travel expenses of $7,500 to send a prosecutor and two HIDTA 

investigators to that country to review the cellular telephone records. 

ONDCP officials told us that they denied funding for these activities 

because ONDCP guidance to the HIDTAs regarding CPOT funding states 

that the funds cannot be used to “supplant,” or replace, existing 

agency/program budgets intended for similar purposes because to do so 

would be inconsistent with the HIDTA mission. In commenting on a draft 

of this report, ONDCP made the clarifying statement that CPOT funding is 

provided for investigations of major drug trafficking organizations 

affiliated with CPOTs. However, HIDTAs do not participate in 

international investigations, and CPOT funding cannot be used to conduct 

or supplement investigations in places like Colombia or Afghanistan. In 

another application, a request was made for $120,000 to pay for street 

 16HIDTA applications for CPOT funding may contain multiple drug investigation activities 

in one initiative. Also, some applications may receive funding for some activities and not 

for others. 

Drug Investigative 

Activities Must Be 

Consistent with the HIDTA 

Mission and Linked to the 

CPOT List to Receive 

CPOT Funds 
Page 11 GAO-05-122 Drug Control 

lighting in a drug-infested crime area of a major U.S. city to aid the HIDTA 

surveillance task force in pursuing drug enforcement operations. ONDCP 

officials told us that they determined the activity was not consistent with 

the HIDTA mission because CPOT funding cannot be used to supplant a 

city’s budget for street maintenance and improvements. 

In some cases, ONDCP’s lack of clear guidance or sufficient information 

limited some HIDTAs’ ability to apply for CPOT funding. For example, 

some HIDTA officials told us that in fiscal year 2002, ONDCP did not 

provide clear directions in its guidance about how HIDTAs were to 

document the link between their investigations and the CPOT list. 

However, in fiscal year 2003, ONDCP’s officials recognized the problem 

and, at quarterly meetings, discussed with HIDTAs how to document links 

between their investigations and the CPOT list, thus resolving the problem. 

In addition, ONDCP was only able to provide a partial CPOT list to 

officials in all HIDTAs in each of the 3 fiscal years it provided CPOT 

funding, even though applications were to include a link between their 

investigations and the CPOT list. The partial list contained some of the 

largest organizations in operation and ones that were most frequently 

targeted by law enforcement. ONDCP, in its guidance, advised HIDTAs 

that they could obtain the entire list from their Justice contacts.17 Some 

HIDTA officials said not having a full list available to them from ONDCP 

limited their ability to apply for CPOT funding. In fiscal year 2004, ONDCP 

created an opportunity for all HIDTAs to participate. 

According to OCDETF officials, access to the full CPOT list is restricted to 

federal law enforcement officials. Commenting on a draft of this report, 

Justice said these restrictions are driven by the fact that the member 

agencies have designated the list as “law enforcement sensitive,” because 

disclosure of certain investigative information contained on the list might 

jeopardize ongoing investigations of targeted organizations. As a result, 

access to the full CPOT list is restricted to OCDETF-member federal law 

enforcement agencies. Nonparticipating federal agencies, HIDTA 

directors, state and local police officials, and non-law enforcement federal 

agencies such as ONDCP could obtain the list from U.S. Attorneys or 

Special Agents-in-Charge of the OCDETF member agencies on a need-to-

 17Commenting on a draft of this report, Justice said the CPOT list was available from U.S. 

Attorney’s offices and the Special Agents-in-Charge of any OCDETF-member agency; see 

appendix II for member agencies. 

ONDCP Did Not Provide 

Sufficient Information for 

Some HIDTAs to Fully 

Develop Their 

Applications for CPOT 

Funding but Took Steps to 

Address These Issues 
Page 12 GAO-05-122 Drug Control 

know basis. To facilitate the distribution of discretionary CPOT funding, 

however, OCDETF provided a partial list, which contained information on 

some of the largest organizations and those commonly known to, and 

targeted by, the law enforcement community, to ONDCP. Since HIDTA 

officials have said that they need to know who is on the CPOT list to 

determine which of their investigations qualify for CPOT funds, ONDCP, in 

its guidance, advised HIDTAs to obtain the full CPOT list through their 

Justice contacts. However, officials from 2 HIDTAs we spoke to said that 

they had some difficulty in obtaining the full CPOT list. 

We spoke with officials from 8 of the 13 HIDTAs that either did not apply 

or applied for and did not receive CPOT funds in either of the first 2 years 

(fiscal years 2002 and 2003) ONDCP awarded CPOT funds. Officials from 2 

of the HIDTAs said that obtaining the full list was a problem because for 

one HIDTA, they did not have the full CPOT list within the time needed to 

complete the application, and the other HIDTA said there was not a formal 

procedure for obtaining the full CPOT list. Officials from 6 of the 8 HIDTAs 

said it was not a problem, however, because they were able to obtain the 

full CPOT list from their Justice contacts. Although these examples may 

not typify all HIDTAs, they nevertheless indicate that not every HIDTA was 

able to readily access the full CPOT list and that it would be difficult to 

show how their investigations qualify for CPOT funds without having the 

full list. Although ONDCP believed the CPOT information it provided was 

sufficient for all HIDTAs to fairly compete for discretionary CPOT funding, 

an ONDCP official responsible for CPOT funding acknowledged that not 

receiving a full CPOT list most likely reduced opportunities for some 

HIDTAs to receive CPOT funding or discouraged others from applying for 

funds. 

All HIDTAs are eligible to apply to receive CPOT funding, according to 

ONDCP officials, even though 13 of the 28 HIDTAs did not apply for or 

applied for but did not receive CPOT funding in fiscal years 2002 and 2003. 

In fiscal year 2004, ONDCP’s guidance identified three international 

organizations that trafficked in illegal drugs in all HIDTAs. ONDCP 

officials said that this additional guidance would allow all HIDTAs to focus 

their limited funding on these three organizations and would allow a 

baseline of opportunity for all HIDTAs to apply for CPOT funding. ONDCP 

stated it would give preference to funding applications that had links to 

these three CPOT organizations. Ten of the 11 HIDTAs that received CPOT 

funds in fiscal year 2004 linked their applications to the three CPOTs 

referenced in ONDCP’s guidance. Providing HIDTAs with the names of 

three CPOT organizations that operated in all the HIDTA regions 

established a baseline of opportunity for the HIDTAs to apply for funding 
Page 13 GAO-05-122 Drug Control 

despite receiving a limited number of CPOT organizational targets from 

ONDCP. 

Commenting on a draft of this report, Justice acknowledged that the 

HIDTAs did face some difficulty regarding the distribution of the CPOT 

list. However, through participation with ONDCP in evaluating 

applications for CPOT funding, Justice officials noticed that—for those 

HIDTAs that applied—problems associated with the limited distribution of 

the list appeared to be confined to fiscal year 2002, when the list was first 

developed. In subsequent years, law enforcement agencies, including 

those in the HIDTAs, were more familiar with the CPOT list and how to 

gain access to it. 

The CPOT funding amount almost tripled from fiscal year 2002 to fiscal 

year 2003 but was cut in half in fiscal year 2004. Given the reduction in 

discretionary funding allocated to CPOT funding, ONDCP officials said 

that even if HIDTAs link their investigations to the CPOT list, and do not 

supplant other funding sources, they are not guaranteed CPOT funding. 

They recognized that reduced funding affected HIDTA participation. As 

shown in figure 1, fiscal year 2004 funding was reduced from $16.5 million 

to $7.99 million. 

Figure 1: CPOT Funding by Fiscal Years 

In the first year, 8 HIDTAs received funding. In the second year, 14 

HIDTAs received funding, and in the third year, when funding was 

reduced, 11 HIDTAs received funding. Despite more than a 50 percent 

drop in funding in fiscal year 2004, 2 of 11 HIDTAs received CPOT funding 

for the first time. While there could be multiple causes, we also noted that 

ONDCP’s Reduction of 

CPOT Funding in Fiscal 

Year 2004 Affected HIDTA 

Participation 

5.75

16.50

7.99

ONDCP funding for CPOT (dollars in millions)

2002 2003 2004

Fiscal year

Source: GAO analysis of ONDCP data.

0

5

10

15

$20
Page 14 GAO-05-122 Drug Control 

the number of HIDTAs that did not apply in fiscal year 2004 compared 

with prior years increased from 6 to 10. ONDCP officials said that the 

limited CPOT funds must be directed at those HIDTAs where, in the 

judgment of those officials who reviewed the CPOT applications, the 

supply of drugs from CPOT organizations had the best chance of being 

interrupted. 

Commenting on a draft of this report, ONDCP agreed that the reduction of 

CPOT funding in fiscal year 2004 affected HIDTA participation but added 

that this observation, while accurate, should be stated within the context 

of all discretionary funding activities. ONDCP consulted with Congress 

prior to allocating the discretionary funding, as required by the report 

language accompanying the ONDCP’s appropriations. As a result of those 

consultations, ONDCP decided to reduce the amount available for funding 

CPOT-related investigations in order to fund other activities. Thus, while 

the reduction in fiscal year 2004 for CPOT-related funding resulted in 

fewer HIDTAs receiving CPOT funding, that should not have caused a 

decline in applications for other discretionary funding activities. For more 

detailed information on the amounts funded to each HIDTA, see appendix 

I. Figure 2 shows the 17 HIDTAs that received CPOT funding at least once 

during fiscal years 2002 through 2004 and the 11 that have not received 

funding. 
Page 15 GAO-05-122 Drug Control 

Figure 2: Seventeen of 28 High Intensity Drug Trafficking Areas That Received CPOT Funding for Fiscal Years 2002 through 

2004 

Within certain HIDTAs, law enforcement tended to focus more on 

domestic drug enforcement than on developing links with CPOT 

organizations. Officials at three HIDTAs we spoke to told us that in fiscal 

years 2002 and 2003, they did not apply for CPOT funding because their 

biggest drug problems were domestic drug producers and distributors, 

such as those organizations involved in methamphetamine and marijuana. 

As a result, their strategy was to focus on these local drug traffickers that 

Local Priorities May Not 

Link with CPOT 

Organizations 

Michigan New England

New York/

New Jersey

Philadelphia/

Camden

Washington, D.C./

Baltimore

North Florida

Central Florida

Puerto Rico/

U.S. Virgin Islands

South Florida

Gulf Coast

Houston

Atlanta

Appalachia

Ohio

Lake County

Southwest Border

Hawaii

South Texas

West Texas

New Mexico

Milwaukee

Los Angeles

Central Valley

Nevada

Northern

California

Oregon

Northwest

Rocky Mountain

Midwest

Chicago

North Texas

Source: GAO.

HIDTA headquarters that did not receive funding

HIDTA headquarters that received CPOT funding

Five locations along the southern border constitute the Southwest Border HIDTA, which received CPOT funding

Arizona region

California border
Page 16 GAO-05-122 Drug Control 

they were required by law to investigate,18 and those investigations did not 

necessarily link with CPOT organizations. In addition, according to some 

HIDTA law enforcement officials, local law enforcement officers in their 

HIDTA focused on local investigations rather than those potentially linked 

with CPOT organizations because they saw a direct benefit to their city or 

countyprosecution of local targets accompanied by drug and asset 

seizures. Also, HIDTA officials said that while their law enforcement 

officers initiated numerous investigations, they do not always have enough 

funds to proceed to a level that may link the HIDTA investigation to the 

CPOT list. 

Commenting on a draft of this report, ONDCP did not disagree with the 

facts above but emphasized that HIDTAs should be focusing on 

investigations of local activities that reach beyond the boundaries of the 

HIDTA, consistent with their designation as centers of illegal drug 

trafficking activities that affect other parts of the country. 

On December 27, 2004, we provided a draft of this report for review and 

comment to ONDCP and Justice. ONDCP commented on our analysis that 

the use of some discretionary funding for the HIDTA program to support 

CPOT-related drug trafficking investigations was not inconsistent with the 

HIDTA mission because it was one possible strategy to eliminate or reduce 

significant sources of drug trafficking in their regions. Justice generally 

agreed with the substance of the report and provided clarifications that we 

also incorporated in this report where appropriate. Both agencies focused 

their comments and clarifications on the second objective: how ONDCP 

distributed discretionary funds to HIDTAs for CPOT investigations and 

why some HIDTAs did not receive funding. ONDCP stressed their belief 

that the information they provided to HIDTAs was sufficient for all 

HIDTAs to fairly compete for limited CPOT funding, and that although 

CPOT funding was reduced in fiscal year 2004, HIDTAs could still 

participate in other discretionary funding activities. Finally, ONDCP 

believes that while some HIDTAs’ investigations may not link to CPOTs, 

HIDTAs should focus on finding that link, given their designation as 

centers of illegal trafficking that affect other parts of the country. 

 18Each of HIDTAs’ investigations supported with federal funds must be consistent with its 

approved strategy under the HIDTA program. See, e.g. Consolidated Appropriations 

Resolution, 2003, Pub. L. No. 108-7, 117 Stat. 11, 447 (2003) (appropriating funds for “drug 

control activities consistent with the approved strategy for each of the designated High 

Intensity Drug Trafficking Areas”). 

Agency Comments 

and Our Evaluation 
Page 17 GAO-05-122 Drug Control 

Justice emphasized that their restrictions on the distribution of the CPOT 

list were soundly based, allowed for HIDTAs to gain access to the full list, 

and were not intended to withhold access to the CPOT list from HIDTA 

personnel. They acknowledged that HIDTAs did face some difficulty but 

were confident the problem has been overcome. We incorporated their 

perspectives as appropriate. 

The full text of the ONDCP Deputy Director for State and Local Affairs’ 

letter, and the Department of Justice’s Associate Deputy Attorney 

General’s memo are presented in appendix III and IV, respectively. 

We will provide copies of this report to appropriate departments and other 

interested congressional committees. In addition, we will send copies to 

the Attorney General of the United States and the Director of the Office of 

National Drug Control Policy. We will also make copies available to others 

upon request. In addition, the report will be available at no charge on 

GAO’s Web site at http://www.gao.gov. Major contributors to this report 

are listed in appendix V. If you or your staffs have any questions 

concerning this report, contact me on 

(202) 512-8777. 

Laurie Ekstrand 

Director, Homeland Security 

 and Justice Issues 
Appendix I: CPOT Funding Awarded to 

HIDTAs, Fiscal Years 2002, 2003, and 2004 

Page 18 GAO-05-122 Drug Control 

Fiscal year 2002 Fiscal year 2003 Fiscal year 2004 

HIDTA 

Received 

CPOT 

funding 

CPOT 

funding 

amount

Received 

CPOT 

funding 

CPOT 

funding 

amount 

Received 

CPOT 

funding 

CPOT 

funding 

amount

Central Valley California 0 yes $500,000 0

Chicago 0 yes 2,600,000 yes $1,278,048

Gulf Coast 0 yes 110,000 0

Hawaii 0 yes 1,000,000 0

Houston yes $690,900 yes 1,251,600 yes 925,000

Los Angeles yes 965,700 yes 1,220,000 yes 1,091,000

Midwest 0 yes 395,000 yes 290,000

New England 0 yes 1,120,000 yes 445,000

New York/New Jersey yes 2,100,000 0 yes 550,000

North Texas yes 150,000 yes 465,000 0

Northern California yes 107,400 yes 200,000 0

Northwest 0 yes 290,000 yes 245,000

Ohio 0 0 yes 315,000

Oregon 0 0 yes 250,000

South Florida yes 700,000 yes 841,115 yes 255,000

Southwest Border yes 796,000 yes 5,000,000 yes 2,350,217

Washington/Baltimore yes 240,000 yes 1,500,000 0

Total 8 $5,750,000 14 $16,492,715 11 $7,994,265

Source: ONDCP. 

Note: CPOT refers to Consolidated Priority Organization Target. HIDTA refers to High Intensity Drug 

Trafficking Area 

Appendix I: CPOT Funding Awarded to 

HIDTAs, Fiscal Years 2002, 2003, and 2004 
Appendix II: Federal Law Enforcement 

Organizations Engaged in CPOT 

Investigations 

Page 19 GAO-05-122 Drug Control 

During fiscal year 2003, a total of 744 CPOT investigations were conducted 

by OCDETF member law enforcement agencies. The majority of those 

investigations (497, or 67 percent) were multi-agency OCDETF 

investigations, involving participation from DEA, FBI, ICE, IRS and other 

member agencies, while the remaining were conducted individually by 

DEA (191, or 26 percent) or FBI (56, or 8 percent). 

Figure 3: Federal Law Enforcement Organizations Conducted 744 CPOT Investigations in Fiscal Year 2003 

Notes: In March 2003, the federal government merged the investigation components of Immigration 

and Naturalization Service (INS) and U.S. Customs Service (USCS ) into one agencyImmigration 

and Customs Enforcement—under the Department of Homeland Security. 

Totals do not add to 100% because of rounding. 

Given that these member agencies conduct investigations jointly, totaling the number of CPOT 

investigations in this figure by each agency does not add up to 497. 

For fiscal year 2004, the majority of CPOT investigations continued to be 

multi-agency OCDETF investigations. For the first 7 months of fiscal year 

2004, 72 percent (548 of 761) of CPOT investigations conducted by 

member law enforcement agencies were designated as OCDETF 

investigations. OCDETF officials attributed fiscal year 2004 increases in 

CPOT investigations over fiscal year 2003 to OCDETF’s emphasis on 

identifying links between targeted domestic organizations and the CPOT 

list. 

Appendix II: Federal Law Enforcement 

Organizations Engaged in CPOT 

Investigations 

Source: GAO analysis of OCDETF, DEA and FBI data.

56

191

497

26%

DEA

 8%

FBI

67% 

OCDETF

0

50

100

150

200

250

300

350

400

450

OCDETF member agencies

79

ATF DEA FBI INS IRS USCG USCS USMS

402

320

212

270

14

276

96

Investigations Conducted by Federal Law 

Enforcement Organizations - FY2003a Number of investigationsb
Appendix II: Federal Law Enforcement 

Organizations Engaged in CPOT 

Investigations 

Page 20 GAO-05-122 Drug Control 

As previously mentioned, OCDETF is composed of member agencies that 

worked together on the 497 CPOT investigations in fiscal year 2003. 

Member agencies either led investigations or supported other OCDETF 

member agencies in these investigations. The bar chart in figure 3 shows 

the number of drug investigations in which each OCDETF member agency 

participated. For example, DEA participated in 402 CPOT investigations, 

the highest level of participation by any member agency. FBI participated 

in 320 investigations, many of which it conducted jointly with DEA along 

with other member agencies. 

DEA and FBI are the only OCDETF member agencies that conducted 

separate CPOT investigations. Generally, these investigations were 

handled outside of OCDETF because they did not yet satisfy the criteria 

for OCDETF designation—that is, they were investigations conducted 

exclusively by foreign offices or investigations that had not yet developed 

to a sufficient level to be designated as OCDETF cases. For the first 7 

months of fiscal year 2004, data showed that DEA separately conducted 23 

percent (172 of 761) and FBI separately conducted 5 percent (41 of 761) of 

investigations linked to CPOTs in addition to their participation in 

OCDETF investigations. These two agencies conducted their CPOT 

investigations out of their own agency’s direct appropriations. 

These CPOT investigations can subsequently become eligible for OCDETF 

funding when OCDETF’s criteria are met. For example, besides being 

linked to the CPOT list, DEA and FBI investigations are to involve multiple 

law enforcement agencies, among other things, in order to qualify as 

OCDETF-designated CPOT investigations. Figure 4 shows the relationship 

among OCDETF, DEA, and FBI in their handling of CPOT investigations 

and shows that DEA and the FBI conduct CPOT investigations both 

separately and collectively with other OCDETF member agencies. Figure 4 

also shows the collaborative relationship between ONDCP and Justice. 
Appendix II: Federal Law Enforcement 

Organizations Engaged in CPOT 

Investigations 

Page 21 GAO-05-122 Drug Control 

Figure 4: Federal Agencies That Conduct CPOT Investigations 

Consolidated Priority Organizational Targets (CPOT) Investigations

Organized Crime Drug Enforcement 

Task Force (OCDETF)

Member agencies

28

High Intensity 

Drug Trafficking

Areas (HIDTA)

Program Drug Enforcement

Administration (DEA)

Drug Enforcement

Administration

Federal Bureau

of Investigation

United States

Marshals Service (USMS)

Alcohol, Tobacco, Explosives,

and Firearms (ATF)

United States

Coast Guard (USCG)

Internal Revenue

Service (IRS) Immigration and Customs

Enforcement (ICE)

Source: GAO.

Department of

Justice (DOJ)

Office of National 

Drug Control Policy

(ONDCP) 

White House

Collaborate with each other

Federal Bureau

of Investigation (FBI)
Appendix III: Comments from the White 

House Office of National Drug Control Policy 

Page 22 GAO-05-122 Drug Control 

Appendix III: Comments from the White 

House Office of National Drug Control Policy
Appendix III: Comments from the White 

House Office of National Drug Control Policy 

Page 23 GAO-05-122 Drug Control 
Appendix III: Comments from the White 

House Office of National Drug Control Policy 

Page 24 GAO-05-122 Drug Control 
Appendix IV: Comments from the Department 

of Justice 

Page 25 GAO-05-122 Drug Control 

Appendix IV: Comments from the 

Department of Justice 
Appendix IV: Comments from the Department 

of Justice 

Page 26 GAO-05-122 Drug Control 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 27 GAO-05-122 Drug Control 

Laurie E. Ekstrand, (202) 512-8777 

In addition to those named above, the following individuals contributed to 

this report: Frances Cook, Grace Coleman, David Dornisch, Michael H. 

Harmond, Weldon McPhail, and Ron Salo. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(440292) 
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