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FOLLOW-UP AUDIT OF THE 

TERRORIST SCREENING CENTER

U.S. Department of Justice 

Office of the Inspector General 

Audit Division 

Audit Report 07-41 

September 2007 
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FOLLOW-UP AUDIT OF THE 

TERRORIST SCREENING CENTER* 

EXECUTIVE SUMMARY 

The Terrorist Screening Center (TSC) is a multi-agency organization 

administered by the Federal Bureau of Investigation (FBI) that consolidates 

terrorist watchlist information and provides 24-hour, 7-day a week 

operational support for federal, state, local, and foreign governments.1 The 

TSC was created by the September 16, 2003, Homeland Security 

Presidential Directive-6 (HSPD-6), which directed the TSC to integrate all 

existing U.S. government terrorist watchlists and assist in the screening of 

individuals who, for example, apply for a visa, attempt to enter the 

United States through a port-of-entry, attempt to travel internationally on a 

commercial airline, or are stopped by a local law enforcement officer for a 

traffic violation. Prior to the establishment of the TSC, the federal 

government relied on at least a dozen separate terrorist watchlists 

maintained by different federal agencies. 

In June 2005, the Department of Justice Office of the Inspector 

General (OIG) issued an audit of the TSC’s operations from the time of its 

inception in 2003.2 The OIG reported that although the TSC had made 

significant strides in becoming the government’s single point-of-contact for 

law enforcement authorities requesting assistance in identifying individuals 

with possible ties to terrorism and had developed a consolidated terrorist 

watchlist database, the TSC had not done enough to ensure that the 

information in that database was complete and accurate. For example, we 

reported instances where the consolidated database did not contain names 

that should have been included on the watchlist. Additionally, we found 

inaccurate or inconsistent information related to persons included in the 

database. In this prior review, we also found problems with the TSC’s 

management of its information technology, a crucial facet of the terrorist 

screening process. Our June 2005 report included 40 recommendations to 

 

* The full version of this report includes information that the FBI considered to be 

law enforcement sensitive and therefore could not be publicly released. To create this 

public version of the report, the OIG redacted (deleted) the portions of the full report that 

were considered sensitive by the FBI, and we indicated where those redactions were made. 

1

 The participating agencies include the FBI, Central Intelligence Agency (CIA), and 

the Departments of Homeland Security (DHS) and State (State Department). 

2

 Department of Justice, Office of the Inspector General, Review of the Terrorist 

Screening Center, Audit Report 05-27, June 2005. 

 

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the TSC addressing areas, such as database improvements, data accuracy 

and completeness, and staffing. 

The objectives of this follow-up audit were to: (1) determine if 

accurate and complete records are disseminated to and from the watchlist 

database in a timely fashion; (2) review the TSC’s efforts to ensure the 

quality of the information in the watchlist database; and (3) assess the 

TSC’s efforts to address complaints raised by individuals who believe they 

have been incorrectly identified as watchlist subjects. 

To accomplish these objectives, we interviewed more than 45 officials 

and reviewed TSC documents and databases. To evaluate the accuracy and 

completeness of the consolidated watchlist, we analyzed the consolidated 

database as a whole, including a review of the number of records in the 

database, any duplication that existed within those records, and the 

associated watchlist processes. We also tested individual records within the 

database for accuracy and completeness, as well as the timeliness of any 

related quality assurance activities. Finally, we assessed the TSC’s activities 

related to individuals who raised complaints following their involvement in a 

screening encounter. This included examining the TSC’s coordination with 

other participating agencies and reviewing a sample of such cases to 

determine if the actions taken were timely and conformed to TSC policy.3 

Results in Brief 

Overall, this follow-up audit found that the TSC has enhanced its efforts 

to ensure the quality of watchlist data, has increased staff assigned to data 

quality management, and has developed a process and a separate office to 

address complaints filed by persons seeking relief from adverse effects 

related to terrorist watchlist screening. However, we also determined that 

the TSC’s management of the watchlist continues to have weaknesses. For 

example, the TSC is relying on two interconnected versions of the watchlist 

database. As a result of this and other conditions, we identified several 

known or suspected terrorists who were not watchlisted appropriately. 

Specifically, we identified 20 watchlist records on suspected or known 

terrorists that were not made available to the frontline screening agents 

(such as a border patrol officer, visa application reviewer, or local police 

officer) for use during watchlist screening encounters (such as at a border 

crossing, through the visa application process, or during a routine traffic 

stop). We also found that the number of duplicate records in the database 

has significantly increased since our last review. 

 3

 Detailed information regarding the audit objectives, scope, and methodology is 

contained in Appendix I. 

 

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In addition, because of internal FBI watchlisting processes, we found 

that the FBI bypasses the normal international terrorist watchlist nomination 

process and enters these nominations directly into a downstream screening 

system. This process is cumbersome for the TSC and, as a result, the TSC is 

unable to ensure that consistent, accurate, and complete terrorist information 

is disseminated to frontline screening agents in a timely manner. 

We also concluded that the TSC needs to further improve its efforts for 

ensuring the accuracy of the watchlist records. We found that, in general, 

the TSC’s actions to review records as part of a targeted special project 

successfully ensured the quality of the data. In contrast, our examination of 

the routine quality assurance reviews revealed continued problems. We 

examined 105 records subject to the routine quality assurance review and 

found that 38 percent of the records we tested continued to contain errors or 

inconsistencies that were not identified through the TSC’s quality assurance 

efforts. Although the TSC had clearly increased its quality assurance efforts 

since our last review, it continues to lack important safeguards for ensuring 

data integrity, including a comprehensive protocol outlining the agency’s 

quality assurance procedures and a method for regularly reviewing the work 

of its staff. Additionally, the TSC needs to work with partner agencies to 

develop clearly defined areas of responsibility and timeframes for quality 

assurance matters. 

A single omission of a terrorist identity or an inaccuracy in the 

identifying information contained in a watchlist record can have enormous 

consequences. Deficiencies in the accuracy of watchlist data increase the 

possibility that reliable information will not be available to frontline screening 

agents, which could prevent them from successfully identifying a known or 

suspected terrorist during an encounter or place their safety at greater risk 

by providing inappropriate handling instructions for a suspected terrorist. 

Furthermore, inaccurate, incomplete, and obsolete watchlist information 

increases the chances of innocent persons being stopped or detained during 

an encounter because of being misidentified as a watchlist identity.

We are also concerned that the TSC’s ongoing review of the watchlist 

will take longer than projected. At the time of our audit field work in 

April 2007, the TSC was continuing its efforts to conduct a record-by-record 

review of the consolidated watchlist and anticipated that all watchlist records 

would be reviewed by the end of 2007. However, the watchlist database 

continues to increase by an average of over 20,000 records per month and 

contained over 700,000 records as of April 2007. Given this growth and the 

TSC’s weak quality assurance process, we believe the TSC is 

 

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underestimating the time required to sufficiently review all watchlist records 

for accuracy. 

Our audit further determined that the TSC was following its procedures 

and reaching appropriate resolutions in its review of complaints filed by 

individuals seeking redress from further adverse experiences that they 

believed were the result of terrorist watchlist screening. However, we found 

that the redress reviews were not always completed in a timely manner, and 

we recommend that the TSC and partner agencies develop timeliness 

measures for each phase in the redress process. 

Additionally, the TSC’s redress reviews have identified that the 

database contains records for individuals that should not be watchlisted and 

that some watchlist records are inaccurate or incomplete. We believe that 

these results provide a further indicator that watchlist data needs continuous 

monitoring and attention. We also believe that the TSC should use 

information related to terrorist watchlist identities that are frequently the 

subject of watchlist encounters to proactively initiate redress reviews before 

complaints are filed.

Our report contains detailed information on the full results of our 

follow-up review of the TSC and contains recommendations to help the TSC 

carry out its important role in the terrorist watchlisting process. 

Summary of Watchlist Nomination, Screening, and Redress Processes 

Agencies that conduct counterintelligence, counterterrorism, and law 

enforcement activities provide information to the FBI and the National 

Counterterrorism Center (NCTC) on suspected or known terrorists who are 

nominated for inclusion on the consolidated terrorist watchlist maintained by 

the TSC.4 The FBI is responsible for submitting to the TSC all domestic 

terrorist identity nominations, and NCTC is responsible for submitting 

international terrorist identity nominations.5 These two agencies employ 

analysts who review the information on the known or suspected terrorist 

identity and forward an unclassified subset of information to TSC analysts, 

who then review the information to ensure that all required criteria are met 

 4

 NCTC was established on May 1, 2003, to develop comprehensive threat 

assessments through the integration and analysis of terrorist information collected 

domestically and abroad by the U.S. government. NCTC is a component of the Office of the 

Director of National Intelligence and was formerly known as the Terrorist Threat Integration 

Center. 

5

 The FBI is a source agency for domestic and international terrorist information; it 

forwards relevant information to NCTC on suspected or known international terrorists. 

 

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to incorporate the identity record in the TSC’s consolidated terrorist 

screening database (TSDB). As additional information is obtained that either 

enhances the identifying information or indicates that the individual has no 

nexus to terrorism, source agencies must also submit this information 

through the nominating process to effect watchlist record modifications and 

deletions, as appropriate. 

The review performed by analysts at NCTC, the FBI, and the TSC 

includes an analysis of information supporting the watchlist nomination, as 

well as an examination of the quality, accuracy, and sufficiency of the 

identity information.6 Thus, all identity records undergo a two-stage review 

before inclusion in the TSDB: (1) at NCTC and then at the TSC for 

international terrorist identities, or (2) at the FBI and then at the TSC for 

domestic terrorist identities. 

The TSC shares the terrorist information contained in the TSDB by 

sending it “downstream” to other government screening systems where 

frontline screening agents can use the information to identify individuals 

against TSDB records.7 The following are examples of three databases that 

contain information from the TSC’s consolidated watchlist: (1) an employee 

of the U.S. Customs and Border Protection (CBP) agency at a U.S. port-ofentry searches the DHS’s Interagency Border Inspection System (IBIS) to 

determine if a person should be granted access to the United States, (2) a 

state police officer stops a vehicle for a traffic violation and queries the 

driver’s name in the FBI’s National Crime Information Center (NCIC) system, 

and (3) a State Department consular affairs official searches the Consular 

Lookout and Support System to determine if a foreign national should be 

granted a visa to visit the United States. The TSC reported that 

approximately 270 million individuals are screened by frontline screening 

agents and law enforcement officers each month.8 

When a name appears to be a match against the terrorist watchlist, 

frontline screening and law enforcement personnel contact the TSC’s 

 6

 The TSC’s general criterion for including a record in the consolidated watchlist 

database is that the nominating agency must have provided evidence of a nexus to 

terrorism. From a data perspective, the minimum criteria for inclusion of a terrorist identity 

into the TSDB are that the record contains at least a partial name (e.g., given name, 

surname, or both) and at least one additional piece of identifying information (e.g., date of 

birth). 

7

 A description of each of the downstream screening systems is contained in 

Appendix II. 

8

 The TSC provided data on screening agency encounters from February through 

April 2007. We reported the average of these 3 months. 

 

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24-hour call center for assistance in confirming the subject’s identity. In 

responding to such a call, the TSC Call Center staff searches the TSDB and 

other databases to determine if a terrorist watchlist identity match exists. 

Between the TSC’s inception in December 2003 and May 2007, the TSC has 

documented more than 99,000 encounters for which its call center was 

contacted. TSC data shows that 53.4 percent of these calls were determined 

to be a positive match to a terrorist watchlist identity in the TSDB. In those 

cases, the TSC contacted the FBI, which is responsible for initiating any 

necessary law enforcement action. In 43.4 percent of these calls, it was 

determined that the encountered individual did not match the watchlisted 

identity, and the TSC Call Center staff instructed the frontline screening 

agent of this resolution. In the remaining 3.2 percent of the encounters, the 

TSC Call Center staff could not definitively determine if the match was 

positive or negative and therefore forwarded these calls to the FBI. 

The nature of the U.S. government’s actions to screen individuals 

against the consolidated terrorist watchlist can result in individuals being 

delayed or detained during security screenings. This can range from an 

individual being subjected to enhanced security screening and slight delays 

to missing a flight or being detained for a long period of time. Persons 

stopped may be actual watchlist subjects, individuals misidentified to a 

terrorist identity, or someone mistakenly included on the watchlist. 

In 2005, the TSC created a process for resolving complaints from 

individuals who were adversely affected by terrorist watchlist-related 

screenings and who were seeking relief or “redress.” Since the creation of a 

unit dedicated to processing such complaints in 2005, the TSC Redress 

Office has received 438 terrorist watchlist-related redress complaints. 

Known or Suspected Terrorists Missing from Watchlist 

Our review revealed continued instances where known or suspected 

terrorists were not appropriately watchlisted on screening databases that 

frontline screening agents use to identify terrorists and obtain instruction on 

how to appropriately handle the subjects. Even a single omission of a 

suspected or known terrorist from the watchlist is a serious matter. We 

found at least 20 watchlist records that were not appropriately watchlisted to 

downstream screening databases. These watchlisting errors are discussed in 

detail below. 

Due to technological differences and capabilities of the various systems 

used in the watchlist process, the TSC maintains two interconnected versions 

of the TSDB to allow for the electronic import and export of data. Although 

the TSC is developing an upgraded TSDB to eliminate the need for the two 

 

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systems, in the meantime TSC officials informed us that these two databases 

should be identical in content and therefore should contain the same number 

of records. However, we discovered during our review that these two 

systems had differing record counts. Specifically, on one day that we tested 

the databases the difference was 18 records, and on a subsequent day the 

difference was 38 records. 

On March 26, 2007, the TSC informed us that the differing record 

counts were due, in part, to five watchlist records that were missing from 

the TSC database responsible for exporting watchlist records to most 

downstream screening databases. Therefore, the associated terrorist 

identities were not included in downstream databases used to screen 

individuals against the terrorist watchlist. Further, our testing of a sample of 

105 watchlist records revealed 7 additional watchlist identities that were not 

being exported to all appropriate screening databases. As a result of the 

TSC’s failure to export all terrorist watchlist records to screening databases, 

these 12 watchlisted individuals could be inappropriately handled during an 

encounter. For instance, a suspected or known terrorist could be 

erroneously issued a U.S. visa or unknowingly allowed to enter the United 

States through a port-of-entry. We discussed these records with TSC 

officials who agreed with our findings and began correcting these omissions. 

During the course of our review, we were also informed by TSC 

officials that in September 2006 they had identified 2,682 records in the 

TSDB that were not being exported to any screening database. Working 

with NCTC, the TSC determined that 2,118 of these records should not have 

been watchlisted in any system and needed to be removed from the TSDB.9 

TSC officials conducted a manual review of the remaining 564 records and 

determined that 8 had not been appropriately watchlisted and needed to be 

renominated to the TSDB. 

However, despite being responsible for removing outdated or obsolete 

data from the TSDB, the TSC did not have a process for regularly reviewing 

the contents of the TSDB to ensure that only appropriate records were 

included on the watchlist. TSC officials told us that they intend to begin 

performing a monthly review of the database to identify any records that are 

being stored in the TSDB that are not being exported to any downstream 

systems. We believe it is essential that the TSC regularly review the TSDB 

to ensure that all outdated information is removed, as well as to affirm that 

all records are appropriately watchlisted. 

 9

 On April 27, 2007, the TSC implemented an information technology solution to 

delete these records. 

 

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Inconsistent FBI Procedure for Processing Watchlist Data 

The FBI’s Terrorist Review and Examination Unit (TREX) receives 

requests from FBI agents to include an individual with known or suspected 

ties to terrorism on the terrorist watchlist. These requests are provided on 

nomination forms, which are also used to modify previous submissions or 

remove records from the watchlist. Analysts at TREX review the nomination 

information for accuracy and completeness. Once verified, nomination forms 

for known or suspected domestic terrorists are electronically forwarded to 

the TSC where a TSC analyst manually enters the information into the TSDB. 

This information is electronically distributed to the downstream screening 

agency data systems, including the FBI’s Violent Gang and Terrorist 

Organization File (VGTOF), which is part of the NCIC system. 

By contrast, once the TREX analyst verifies an FBI-generated 

international terrorist nomination, the analyst enters the information into 

VGTOF directly and then submits the nomination form to NCTC. Following 

its review and vetting, the NCTC analyst manually enters the information 

into its database – the Terrorist Identities Datamart Environment (TIDE) – 

that in turn feeds the information to the TSDB. Because TREX has already 

entered the record into VGTOF, it is not necessary for the TSC to export the 

record it receives from TIDE to VGTOF. Therefore, these records are not 

exported from the TSDB to VGTOF.10 Because these VGTOF records will not 

receive electronic modifications or deletions from the TSDB, the TSC and 

TREX have agreed that TREX will be responsible for ensuring FBI-originated 

international watchlist records in VGTOF are accurate, complete, and 

current. 

The FBI’s direct entry of international terrorist watchlist nomination 

data into a downstream screening database bypasses NCTC and the TSC and 

makes it difficult for the NCTC and the TSC to carry out their responsibilities 

related to watchlist nominations and records. In our opinion, this process 

does not comport with the nomination and data flow procedures agreed to 

by the partner agencies, which requires agencies to provide to NCTC, rather 

than directly into a downstream database, information related to known or 

suspected international terrorists. Additionally, we believe the FBI’s practice 

is cumbersome for the TSC and creates unnecessary data errors, anomalies, 

and inconsistencies as described below. 

 10 To alert the TSC of this non-standard entry of records into the TSDB, the TSC 

implemented a special flag, referred to as “FBI sole source,” for FBI-originated international 

records. This designation precludes all future electronic transactions, including related 

modifications and deletions, from being exported from the TSDB to VGTOF. 

 

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To test for data accuracy and consistency, we reviewed a judgmental 

sample of 50 FBI-originated additions or modifications to the watchlist.11 

We found that while the records for the domestic terrorist nominations we

generally accurate, the international terrorist nominations were not. We 

identified 16 records with 28 instances in which the identifying information 

related to international terrorists was inconsistent between the nomination 

form, VGTOF, TIDE, TSDB, or other screening systems. According to 

TSC officials, TREX analysts frequently augment the data on the nomination 

forms with information they glean from FBI case files and enter this 

additional information into the VGTOF system. However, this supplemental 

case information is not forwarded to NCTC and as a result the information is 

not included in TIDE, not sent to the TSDB, and not made available, if 

appropriate, to downstream screening systems. Further, because TREX 

enters the record into VGTOF before the addition of any other existing 

information from other government databases to which NCTC has access, 

this additional information is often not included in VGTOF. As a result, vital 

information on watchlist subjects is not being shared with all appropriate 

screening agencies. 

re 

 

In addition, we found that the FBI’s procedures for processing 

international terrorist watchlist nominations are cumbersome for the TSC 

and can inadvertently create an incomplete watchlist. The difference in 

procedures between the FBI’s and other agencies’ watchlist nominations 

requires TSC analysts to review every incoming international terrorist 

nomination and indicate within the record whether it is an FBI source record. 

If a terrorist watchlist record is improperly designated as an FBI source 

record, the subset of terrorist watchlist records in VGTOF will be incomplete 

because that record will not be exported to or modified within VGTOF. TSC 

staff told us that they were concerned about this because, when reviewing 

nominations from NCTC, it is often difficult to distinguish between FBI source 

records and nominations received from other agencies. In fact, TSC staff 

stated that there was a period of time (possibly as long as a year) in which 

many records had been improperly designated as FBI-originated records and 

vice versa. In March 2007, the TSC and NCTC addressed this problem by 

developing a method to permit TSC analysts to more easily identify FBI 

source records. 

FBI officials responded to our concerns by stating that they had 

implemented their nomination procedures to ensure that FBI international 

terrorist information was entered into VGTOF in a more efficient manner. 

Yet, our review of 70 FBI record transactions (50 nominations previously 

11 The total sample of 50 records consisted of 25 each for domestic and 

internationally known or suspected terrorists. These 50 records were part of our 

156 watchlist record sample that we selected for testing. 

 

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mentioned and 20 deletions) revealed that although the transactions were 

entered into VGTOF in a timely manner, the transactions were not 

incorporated into the TSDB in a timely fashion.12 Specifically, 18 of the 

70 transactions took more than 5 days for TREX to process, with one 

transaction taking 35 days. In addition, we identified 2 instances in which 

TREX erroneously delivered nomination forms for domestic terrorists to 

NCTC that resulted in delays of 6 and 16 days, respectively. 

Delays in including terrorist information in the consolidated database 

present a significant vulnerability to the integrity of the consolidated 

watchlist. Further, the FBI’s current practice of bypassing NCTC and the TSC 

and entering international terrorist-related data directly into VGTOF 

increases the likelihood that watchlist information within the TSDB, TIDE, 

VGTOF, and other downstream databases is inaccurate and incomplete. As a 

result, we recommend that the FBI, NCTC, and TSC work together to design 

a more consistent and reliable process by which FBI-originated international 

terrorist information is provided to NCTC for inclusion in TIDE and 

disseminated to the TSDB and downstream screening systems, including 

VGTOF. 

Duplicate Terrorist Watchlist Records 

Multiple records containing the same unique combination of basic 

identifying information can needlessly increase the number of records that a 

call screener must review when researching a specific individual. In 

addition, when multiple records for a single identity exist, it is essential that 

the identifying information and handling instructions for contact with the 

individual be consistent in each record. Otherwise, the screener may 

mistakenly rely on one record while a second, more complete record may be 

ignored. This can result in important information being missed. Further, 

inconsistent handling instructions contained in duplicate records may pose a 

significant safety risk for law enforcement officers or screeners. 

In reviewing the TSDB for duplicate records, we defined duplicate 

records as those records that contain the same identifying information for 

five primary identifying fields – [SENSITIVE INFORMATION REDACTED].13 

In our June 2005 TSC report, we identified 31 such instances of duplicat

records in the TSDB and recommended that the TSC implement corrective 

e 

 12 Officials from NCTC, the TSC, and TREX stated that each agency attempts to 

process nominations to the watchlist within 1 day. 

13 For each terrorist watchlist record in the consolidated database, only these five 

fields are exported to downstream systems for use in identifying suspected or known 

terrorists during the watchlist screening phase. 

 

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action. For our current audit, we again determined that duplicate records 

existed within the TSDB and that the occurrence of duplicates had increased 

significantly. In March 2007, we found that the TSDB contained 

2,533 repeated combinations in the 5 core fields involving 6,262 watchlist 

records. For example, one unique combination of the 5 core fields had 

19 associated records. Further, our analysis of the 6,262 duplicate TSDB 

records indicated that at least 20 percent had some discrepancy in handling 

instruction, identifying information, or watchlist export designation. For 

example, we identified one individual with duplicate identity records in the 

consolidated watchlist. Because both records pertained to the same 

individual, the instructions for handling the subject should be consistent. 

However, we identified significant differences between the records regarding 

handling instructions and additional warnings related to the individual. 

Specifically, one record noted that the individual was “armed and dangerous 

with violent tendencies” and also had a valid arrest warrant. The other 

record did not contain this important information. These types of 

inconsistencies place screeners and law enforcement officers at undue risk 

and could potentially result in the admittance of a dangerous individual into 

the United States. 

According to the TSC Chief Information Officer (CIO), the TSC does not 

have an ongoing process to review the TSDB for duplicate records. Based on 

our findings, however, the TSC CIO stated that the TSC plans to implement 

a procedure to conduct weekly reviews of the TSDB for duplicate records and 

forward any issues to the TSC’s internal quality assurance unit for review. 

The TSC’s Watchlist Quality Efforts 

 Our June 2005 audit report identified weaknesses in the completeness 

and accuracy of the consolidated watchlist. At that time, TSC management 

acknowledged that it needed to focus more attention on ensuring the quality 

of the watchlist. We recommended that the TSC regularly review and test 

the information contained in the consolidated watchlist database to ensure 

the data is complete, accurate, and non-duplicative. We also recommended 

that the TSC coordinate with participating agencies and establish procedures 

to identify and resolve missing and conflicting record information. 

In response to our recommendations, the TSC increased its quality 

assurance efforts and implemented a data quality improvement plan. 

Additionally, in November 2006, the TSC’s consolidated terrorist watchlist 

database was upgraded to incorporate a tracking feature for quality 

assurance activities. As a result of this upgrade, individual watchlist records 

in the database now contain a record (referred to as a QA ticket) in which 

 

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TSC staff can record all quality assurance work that has been performed on 

that record.

 The Nominations and Data Integrity Unit (NDIU) is responsible for 

performing the TSC’s activities related to ensuring the quality and accuracy 

of the watchlist. The NDIU’s activities for ensuring the quality of watchlist 

information can be categorized into three areas: (1) reviewing incoming 

watchlist data (referred to as the single review queue); (2) performing 

reviews of historical records following an encounter where the TSC identifies 

a potential discrepancy in watchlist records; and (3) conducting special 

quality assurance projects, such as performing a targeted review of the 

Transportation Security Administration (TSA) No Fly list.14 As of March 2007, 

the TSC had assigned 34 staff to this unit. In comparison, as of September 

2004 the TSC had 12 staff assigned responsibility for nominations and data 

integrity tasks, including 1 staff member that was dedicated solely to quality 

assurance matters. 

To examine the TSC’s efforts to ensure the quality of the information 

in the TSDB, we examined 156 TSDB records that had been subjected to the 

TSC’s quality assurance procedures. Of these 156 records, 36 involved 

record deletions and we found that each had been handled appropriately. 

Using the remaining sample of 120 records, we performed tests to 

determine if the watchlist records were accurate. We found that, in general, 

the TSC’s actions to review records as part of a targeted special project 

successfully ensured the quality of the data, and we identified virtually no 

errors in the 15 records we tested in connection with special project reviews. 

In contrast, our examination of 105 records subjected to the single review 

queue or post-encounter quality assurance reviews revealed that 38 percent 

of these tested records continued to contain errors or inconsistencies that 

were not identified through the TSC’s quality assurance efforts. 

In general, we believe the actions the TSC has taken to improve 

quality assurance since our last audit are positive steps. We also recognize 

that it is impossible to completely eliminate the potential for errors. 

However, the inaccuracies that we identified in TSDB records that had 

undergone the TSC’s quality assurance processes underscore the need for 

additional actions to ensure that the TSDB is a reliable source of information 

about known or suspected terrorists. The results of our testing and analysis 

of the TSC’s quality assurance efforts are summarized below. 

 14 [SENSITIVE INFORMATION REDACTED] 

 

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The TSC’s Review of the No Fly List 

 

In July 2006, the Homeland Security Council Deputies Committee issued 

guidance on how to correctly apply its criteria for including individuals on the 

No Fly list. Subsequently, the TSC submitted all TSDB records associated with 

individuals who were on the No Fly list to a comprehensive quality assurance 

review using this guidance. When the TSC began its review in July 2006, the 

No Fly list contained 71,872 records. The TSC completed its special review of 

the No Fly list on January 31, 2007, determining that the No Fly list should be 

reduced to 34,230 records.15 The TSC recommended 22,412 records for 

removal from the No Fly list and placement on the TSA’s Selectee list.16 For 

another 5,086 records, the TSC determined that the individual did not require 

inclusion on either the No Fly or Selectee list. 

 We selected and reviewed 15 records that were part of the TSC’s review 

of the No Fly list. We did not find any data inaccuracies or inconsistencies in 

these records. Each record’s basic identifiers [SENSITIVE INFORMATION 

REDACTED] were shown consistently in all of the affected databases and each 

record remained the same or was downgraded from the No Fly list in 

accordance with the final recommendation of the TSC. 

Data Inaccuracies and Inconsistencies Exist After Quality Assurance Review 

Unlike our review of the No Fly list special project, however, our 

examination of records passed through the TSC’s single review queue or 

encounter-driven quality assurance processes revealed that records were 

still likely to contain errors or inconsistencies. We examined 105 records to 

determine if basic information [SENSITIVE INFORMATION REDACTED] was 

shown consistently in all of the affected databases. We also verified that 

correct handling codes were included on watchlist records. In short, our 

testing revealed that records the TSC reviewed through its routine quality 

assurance processes frequently continued to contain errors, which indicates 

weaknesses in the TSC’s practices for verifying the integrity of the original 

watchlist data. 

As previously reported, we found that 7 of the 105 records we tested 

were not exported to appropriate downstream databases. In addition, our 

 15 During its review of the No Fly list, the TSC continued to receive routine No Fly list 

additions, modifications, and deletions through the watchlist nomination process. As a 

result, it is not possible to subtract the special project-driven No Fly list changes from the 

starting point of 71,872 records and obtain the correct number of No Fly records as of 

January 31, 2007. 

16 [SENSITIVE INFORMATION REDACTED] 

 

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review of the 105 watchlist records that had been subjected to the TSC’s 

single review queue or encounter-driven quality assurance processes 

revealed that 35 records had inconsistent identifying information when 

comparing one or more fields in the TSC’s consolidated watchlist records 

with the source or screening agencies’ database records. Identifying 

information related to terrorist watchlist identities must be accurate and 

consistent across all systems involved in the watchlisting process, namely 

the TSDB, the downstream systems, and the nominating agencies’ systems. 

Inconsistent data can confuse or delay TSC Call Center operators in their 

efforts to determine whether an encountered individual is a positive match 

to a known or suspected terrorist. Further, inconsistent information among 

databases involved in terrorism screening indicates that at least one record 

may be incorrect. Incorrect records can also misinform frontline screening 

agents and contribute to the misidentification of a person not on the 

watchlist or the inappropriate release or admittance of a dangerous 

individual. Finally, our testing of the 105 sample watchlist records also 

revealed that 5 records contained incorrect handling instructions. 

During our review, it became apparent that both the TSC’s quality 

assurance efforts and our reviews of watchlist records identified errors and 

inconsistencies in incoming records from the source agencies – NCTC and 

the FBI. We discussed the watchlist nomination process with NCTC and FBI 

officials, and both agency representatives stated that records are reviewed 

for accuracy, completeness, and consistency before the records are 

forwarded to the TSC. However, these efforts are failing to identify a 

significant number of deficiencies in the nominated records. The TSC’s 

quality assurance efforts, therefore, are hampered by the inaccurate and 

incomplete source material. 

Untimely Resolution of Quality Assurance Issues 

Delays in the closure of quality assurance matters directly affects the 

accuracy of the consolidated watchlist database because records can contain 

inaccurate and incomplete information for extended periods of time while the 

matter is being resolved. We examined a sample of 51 quality assurance 

matters opened between February 2006 and February 2007. We found that 

these matters were open from 0 days (matter was closed the same day as it 

was opened) to 329 days. On average, the quality assurance matters 

examined in our sample were open for 80 days. 

 The TSC has not established a performance measure identifying what 

it believes to be an acceptable duration for its analysts to complete a quality 

assurance review. According to TSC personnel, NDIU analysts were 

supposed to follow up on all quality assurance matters every 30 days. 

 

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However, the TSC does not have a mechanism such as a standardized report 

or digital dashboard that catalogs all outstanding quality assurance 

matters.17 In concert with the development of timeframes for resolving 

quality assurance matters, we believe the TSC should develop a system, 

including an aging schedule, to track its quality assurance work.

Weaknesses in TSC Quality Assurance Policy and Oversight 

 We also found that the TSC has implemented necessary enhancements 

in its quality assurance resources and processes since our last audit. Our 

examination of records submitted to the TSC’s No Fly list special project 

showed that the TSC’s review was generally successful in ensuring the 

quality of watchlist records. However, the inaccuracies we found in our 

review of watchlist records that were subjected to the TSC’s single review 

queue and post-encounter quality assurance reviews – examinations that are 

less comprehensive than the No Fly list review – indicate a need for further 

enhancements to these quality assurance processes. 

 During our audit, we performed a physical observation of TSC analysts 

conducting quality assurance reviews of watchlist records. We noted that 

the analysts’ method of performing their reviews was not always consistent. 

For example, some analysts inspected all of the documents supporting a 

TSDB record while other analysts relied solely upon summary information. 

We also found that the analysts were not consistently documenting their 

quality assurance work. 

We believe that this situation was caused by inadequate standard 

operating procedures (SOP) detailing the TSC’s quality assurance processes 

and by insufficient training. The TSC has an SOP for its quality assurance 

efforts, but the document was last revised on August 16, 2005. Moreover, 

the document provides incomplete guidance to analysts on the processing of 

quality assurance matters and did not mention the existence of special 

quality assurance projects and encounter-based quality assurance reviews. 

Further, while the SOP informs the analysts performing standard quality 

assurance reviews how to examine watchlist records, it fails to detail what 

fields, supporting information, and other aspects of the records the analysts 

should be verifying and comparing. In addition, these procedures do not 

instruct the analysts on the necessary actions to take when inaccurate or 

incomplete information is identified. 

 17 A digital dashboard is a business management tool that visually displays the 

status of a business project. The dashboard can provide warnings, next steps, action 

notices, and summaries of a project. 

 

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Additionally, the TSC provides its quality assurance analysts only a few 

days of training before allowing them to work independently, and no 

supplemental training is required. Moreover, the TSC does not have a 

mechanism for regularly evaluating the work of its quality assurance 

analysts to help ensure that the analysts are performing appropriate reviews 

and keeping abreast of any process changes. We believe that the TSC 

should develop a more detailed and comprehensive quality assurance SOP to 

better guide NDIU analysts through their work. In addition, the TSC should 

develop a mechanism to routinely review its analysts’ work to identify 

processing deficiencies and areas requiring additional training. 

Insufficient Process to Comprehensively Review Watchlist Data Quality 

 In response to our previous TSC audit that identified errors and 

inconsistencies in the watchlist records, the TSC stated that it intended to 

conduct a record-by-record review of the approximately 400,000 records in 

the TSDB. The TSC later estimated that this review would not be complete 

until 2012. In February 2007, TSC officials stated that the review was being 

performed through its three-pronged quality assurance strategy – the single 

review queue, encounter-driven quality assurance reviews, and special 

projects. TSC officials told us that they plan to examine the TSDB following 

the completion of the ongoing special projects and determine how many 

TSDB records have not yet been reviewed. The TSC then plans to review 

any previously unexamined TSDB records. 

 In February 2007, TSC officials told us that since the inception of the 

single review queue in March 2006 over 670,000 TSDB records had been 

reviewed and the agency had revised its estimated completion date. TSC 

officials now project that the record-by-record review will be complete by the 

end of 2007. However, we believe that the TSC may have overstated the 

number of records reviewed and is underestimating the amount of time and 

effort that it will take to complete its review of the entire TSDB. We base 

these conclusions on the following factors: 

• As previously discussed, the TSC’s single review queue and 

encounter-driven quality assurance processes do not sufficiently 

ensure the quality of the watchlist records. Therefore, the TSC 

should reconsider records examined in these processes in its 

count of records reviewed. 

• The number of records reviewed is not limited to the review of 

unique records. Rather, the TSC’s quality assurance process 

allows for one record to be reviewed multiple times: through the 

single review queue, following each request to modify or delete 

 

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the record, in accordance with one or more special projects, and 

subsequent to each encounter. Therefore, we believe that the 

TSC’s cumulative tally of records reviewed can include records 

counted multiple times. 

• Between September 2006 and April 2007, the TSDB grew at an 

average rate of over 20,000 records per month. This growth 

adds to the analysts’ workload. Since April 2004, the TSDB has 

more than quadrupled in size, growing from 150,000 to 

724,442 records in April 2007. 

• As of February 2007, there were about 3,000 open quality 

assurance matters that required follow-up. 

As part of this review, we obtained TSC data for the number of quality 

assurance matters identified and resolved between November 2006 and 

March 2007.18 These data show that the TSC is identifying incomplete or 

inaccurate information in TSDB records faster than the matters are being 

resolved by source agencies. As the following graph shows, cumulative 

differences between identified quality assurance matters and addressed 

quality assurance matters increased from 177 in November 2006 to 2,514 in 

March 2007. This differential also shows that the TSC is regularly identifying 

errors or concerns with known or suspected terrorist records. 

Cumulative Growth in Quality Assurance Matters

2,253 3,116

5,287

11,270

18,143

2,430

3,436

5,862

12,433

20,657

0

5,000

10,000

15,000

20,000

25,000

November 2006 December 2006 January 2007 February 2007 March 2007

QA Matters

Resolved Identified

Source: OIG analysis of Terrorist Screening Center data 

 18 The TSC only could provide historical data on quality assurance matters since 

November 2006 when the latest version of the TSDB was deployed. 

 

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We believe that if the number of watchlist records and the associated 

quality assurance matters in the TSDB continue to grow, the TSC will not 

complete the record-by-record review of the TSDB by the end of 2007 as 

anticipated. The TSC needs to accurately determine the magnitude of the 

unexamined portion of the TSDB so that the TSC can implement a sound 

plan for examining those records and develop a realistic completion date for 

the project. Further, the TSC should establish benchmarks against which it 

can measure its progress. 

Watchlist Redress 

We found that the TSC’s efforts to resolve terrorist watchlist redress 

matters since our previous audit have improved. For example, in 2005 the 

TSC created a dedicated unit for redress matters. The TSC also helped to 

spearhead the creation of a multi-agency Memorandum of Understanding 

(MOU) focusing on watchlist redress (Redress MOU) and developed a 

comprehensive Redress SOP to ensure watchlist information for redress 

complainants is accurate, complete, and current. 

 

The frontline screening agencies, such as DHS and the State 

Department, receive complaints from persons seeking relief, or “redress,” 

related to the terrorist watchlist screening process. Matters believed to be 

related to a terrorist watchlist identity or an encounter involving the 

watchlist are forwarded to and reviewed by the TSC.19 The TSC Redress 

Office conducts an examination of the watchlist records, reviews other 

screening and intelligence databases, and coordinates with partner agencies 

for additional information and clarification. The TSC determines if any 

watchlist records need to be modified or even removed from the watchlist, 

ensures these identified changes are made, and notifies the referring 

frontline screening agency of its resolution. The frontline screening agency 

is then responsible for responding to the complainant. TSC policy requires 

that responses to complainants neither confirm nor deny the existence of 

watchlist records relating to the complainant. According to TSC officials, this 

nondisclosure policy protects U.S. counterterrorism operations and 

intelligence objectives and safeguards the personnel involved in these 

sensitive activities. 

We judgmentally selected 20 redress complaints received by the TSC 

between January 2006 and February 2007 and reviewed the corresponding 

files to determine if the TSC followed its Redress SOP for resolving 

 19 On occasion, the TSC receives a redress complaint referral from a screening 

agency and determines that the complaint does not relate to a terrorist watchlist identity or 

an encounter involving the watchlist. The TSC returns such complaints to the referring 

agency for resolution. 

 

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complaints. We found that in each of the sampled cases the TSC complied 

with its Redress SOP, including reviewing the applicable screening and 

intelligence databases, coordinating with partner agencies, and reaching 

appropriate resolutions. However, the TSC’s redress activities identified a 

high rate of error in watchlist records. In addition, we believe the TSC needs 

to address the timeliness of redress complaint resolutions. 

Significant Watchlist Record Changes Following TSC Redress Review 

As part of our review, we analyzed TSC data on the resolution of 

terrorist watchlist redress complaints. Between January 2005 and 

February 2007, the TSC closed 388 of the 438 redress complaints it 

received. Through its comprehensive redress review process, the TSC 

concluded that 45 percent of the watchlist records related to redress 

complaints required modification or deletion from the watchlist. In some 

instances, the TSC stated that redress resolution may have been 

simultaneous to current watchlist record updates. We also found instances 

where the TSC Redress Office found inaccuracies in the watchlist record or 

discovered additional, relevant information that had not been passed to the 

TSC. 

The Privacy Officer acknowledged that the high percentage of records 

requiring modification or removal may point to deficiencies in the terrorist 

watchlist nomination process and with nominating agencies not providing the 

TSC additional information important for appropriately updating terrorist 

records. We believe that the results of the TSC’s redress reviews are a 

further indicator that watchlist data needs continuous monitoring and 

attention. 

Untimely Resolution of Redress Complaints 

The TSC is responsible for adjudicating watchlist-related complaints 

through its review process and working with nominating and screening 

agencies to resolve the matters in a timely fashion. The Redress MOU states 

that one of the goals of the redress process is to provide a timely review, 

which ensures any required changes to the watchlist are implemented 

efficiently so that watchlist records do not continue to be inaccurate. 

We reviewed TSC files and statistics for closed redress matters to 

determine the efficiency of redress reviews. This data revealed that it took 

the TSC, on average, 67 days to close its review of a redress inquiry. For 

redress matters referred to the TSC during the last semiannual period in our 

review (July through December 2006), it took the TSC an average of 

57 days to finalize its review. In addition to these closed matters, we also 

 

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analyzed the 50 open redress complaints as of February 27, 2007, and 

determined that these matters had been open an average of 61 days. Of 

these complaints, 38 percent were open over 60 days, including 2 inquiries 

that were pending over 180 days. 

Open TSC Redress Matters 

(as of February 27, 2007) 

Number of Days Open Number of 

Open Redress Matters

Percentage of Total 

Open Redress Matters

180 days or more 2 4% 

90-179 days 12 24% 

60-89 days 5 10% 

30-59 days 11 22% 

less than 30 days 20 40% 

Total 50 100% 

Source: The Terrorist Screening Center Redress Office 

Our review of redress files indicated that delays were primarily caused 

by three factors: (1) the TSC took a long time to finalize its determination 

before coordinating with other agencies for additional information or 

comment, (2) nominating agencies (the FBI and NCTC) did not provide 

timely feedback to the TSC or did not process watchlist paperwork in a 

timely manner, and (3) certain screening agencies were slow to update their 

databases with accurate and current information. For example, our file 

review found that the State Department and the DHS’s Customs and Border 

Protection did not revise encounter records in a screening database in a 

timely fashion to reflect modified or removed terrorist identities. 

TSC officials acknowledged that it has not developed response 

timeframes for redress matters with its partner agencies. While the Redress 

MOU states that one of the goals of the redress process is to provide a 

timely review, the MOU does not define what constitutes a reasonable 

timeframe. We believe that timeliness measures could be used as standards 

to evaluate the U.S. government’s efficiency in resolving terrorist watchlist 

redress inquiries and responding to complainants. Because the TSC is 

central to resolving any complaint regarding the content of the consolidated 

terrorist watchlist, we encourage the TSC to organize the U.S. government’s 

effort to develop timeliness measures for the entire watchlist redress 

process. 

 

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More Proactive Efforts Needed to Mitigate Incidence and 

Effect of Watchlist Misidentifications 

The TSC does not have any policy or procedures to proactively use 

information from encounters to reduce the incidence and impact of terrorist 

watchlist misidentifications. For example, the TSC could program its 

encounter tracking system to automatically generate a quality assurance 

lead for the TSC to perform a comprehensive review of watchlist records that 

have been the subject of a certain number of encounters. Moreover, the 

TSC’s strategic plan does not include goals or actions associated with 

reducing the incidence of misidentifications or the impact on misidentified 

persons other than that covered by a formal redress process. Considering 

that nearly half of all encounters referred to the TSC Call Center are 

negative for a watchlist match, we believe the TSC should consider 

misidentifications a priority and develop strategic goals and policy specific to 

mitigating the adverse impact of the terrorist screening process on nonwatchlist subjects, particularly for individuals who are repeatedly 

misidentified as watchlist identities. 

Conclusion and Recommendations 

We found that since our June 2005 report the TSC has enhanced its 

staffing and implemented practices to handle redress matters and help 

ensure the quality of terrorist watchlist information. Our review also found 

that the TSC’s processes for examining watchlist records as part of its 

special project (the No Fly list examination) and redress complaint reviews 

were comprehensive and improved watchlist data quality. 

However, we found continued weaknesses in other watchlist processes 

and significant deficiencies in watchlist data. We determined that the FBI’s 

fragmented international terrorism nomination process caused many 

terrorist identity records to be inaccurate, incomplete, and inconsistent 

across watchlist systems. Additionally, the TSC’s single review queue and 

encounter-driven quality assurance processes were not successful in 

ensuring the quality of watchlist records. We also found that TSC quality 

assurance analysts employed disparate procedures in their reviews, and the 

TSC did not have a mechanism for conducting oversight of its quality 

assurance efforts. 

We believe the TSC should consider incorporating elements from its 

more comprehensive reviews in its other quality assurance processes to help 

better ensure the quality of watchlist data. Further, the TSC should develop 

detailed, comprehensive standard operating procedures and an oversight 

function for quality assurance matters. 

 

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In addition to these process deficiencies, we found suspected or known 

terrorists still missing from the watchlist or downstream screening systems, 

incorrect terrorist handling codes on watchlist records, and duplicate identity 

records within the TSDB. Moreover, our testing of specific watchlist records 

revealed that records submitted to a TSC quality assurance review contained 

significant errors –38 percent of the records tested contained data that was 

inaccurate, incomplete, inconsistent, or not current. Further, our 

examination of TSC redress data for positive-match encounters showed that 

the TSC determined that 45 percent of the watchlist records referred for 

review required modification or removal. In addition, watchlist agencies, 

including the TSC and nominating and screening agencies sometimes caused 

unnecessary delays in closing redress inquiry reviews. 

The results of our testing of watchlist records, as well as the TSC 

finding that many records involved in its redress reviews required 

modification or removal, indicate a deficiency in the integrity of watchlist 

information. We recommend that the TSC resolve current process 

weaknesses – within the TSC and at nominating agencies – that are 

contributing to the weaknesses we identified in the watchlist data. The TSC 

also needs to develop and implement a plan to complete a sufficient analysis 

of all watchlist records in a timely fashion. 

This report contains 18 recommendations to help the TSC improve its 

operations and the quality of watchlist data. These recommendations 

include two recommendations to the FBI directly for matters pertaining to its 

operations outside the TSC.

 

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FOLLOW-UP AUDIT OF THE 

TERRORIST SCREENING CENTER 

TABLE OF CONTENTS 

INTRODUCTION .................................................................................. 1 

PURPOSE OF THE CONSOLIDATED WATCHLIST................................................. 2 

OVERVIEW OF WATCHLIST NOMINATION AND SCREENING PROCESSES..................... 3 

TSC ENCOUNTER MANAGEMENT ................................................................ 6 

NUMBER OF TERRORIST WATCHLIST RECORDS................................................ 7 

HANDLING INSTRUCTIONS ....................................................................... 8 

OIG’S AUDIT APPROACH ...................................................................... 10 

FINDINGS AND RECOMMENDATIONS................................................ 12 

I. DATA ACCURACY AND TIMELINESS .............................................. 12 

STRUCTURE OF THE TSDB..................................................................... 12 

RECORDS NOT DESIGNATED FOR ANY WATCHLISTING ..................................... 17 

FBI PROCEDURE FOR PROCESSING WATCHLIST DATA...................................... 18 

DUPLICATE RECORDS........................................................................... 20 

INCLUSION OF KNOWN TERRORISTS IN THE TSDB ......................................... 24 

CONCLUSION .................................................................................... 24 

RECOMMENDATIONS ............................................................................ 25 

II. QUALITY ASSURANCE ................................................................. 27 

OVERVIEW OF THE TSC’S QUALITY ASSURANCE PROCESS................................. 27 

OIG ANALYSIS OF TSC QUALITY ASSURANCE EFFORTS ................................... 31 

QUALITY ASSURANCE MANAGEMENT AND OVERSIGHT ...................................... 35 

TSC EFFORTS TO ENHANCE TERRORIST WATCHLISTING ................................... 41 

CONCLUSION .................................................................................... 42 

RECOMMENDATIONS ............................................................................ 43 

III. TERRORIST WATCHLIST REDRESS ............................................ 45 

OVERVIEW OF THE TSC’S REDRESS EFFORTS ............................................... 45 

MULTI-AGENCY REDRESS AGREEMENT ....................................................... 47 

OVERVIEW OF THE TERRORIST WATCHLIST REDRESS PROCESS ........................... 47 

DISPOSITION OF REDRESS COMPLAINTS ..................................................... 51 

TIMELINESS OF PROCESSING REDRESS COMPLAINTS ....................................... 53 

RESPONSE TO REDRESS COMPLAINANTS ..................................................... 56 

APPEAL OF REDRESS DISPOSITION ........................................................... 57 

PROACTIVE REDRESS........................................................................... 57 

CONCLUSION .................................................................................... 59 

RECOMMENDATIONS ............................................................................ 60 

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STATEMENT ON INTERNAL CONTROLS.............................................. 61 

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS........ 62 

APPENDIX I: OBJECTIVES, SCOPE, AND METHODOLOGY.................. 63 

APPENDIX II: SYSTEMS USED IN THE TERRORIST 

WATCHLIST PROCESS.............................................. 67 

APPENDIX III: DIAGRAM OF TERRORIST WATCHLIST DATAFLOW... 69 

APPENDIX IV: ACRONYMS ............................................................... 70 

APPENDIX V: TERRORIST SCREENING CENTER RESPONSE .............. 71 

APPENDIX VI: OFFICE OF THE INSPECTOR GENERAL 

ANALYSIS AND SUMMARY OF ACTIONS 

NECESSARY TO CLOSE THE REPORT......................... 77 

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INTRODUCTION 

Prior to the establishment of the Terrorist Screening Center (TSC), the 

federal government relied on at least a dozen separate terrorist watchlists 

maintained by different federal agencies. The TSC was created by Homeland 

Security Presidential Directive-6 (HSPD-6), signed on September 16, 2003. 

In that directive, the TSC was required to integrate the existing U.S. 

government terrorist watchlists and provide 24-hour, 7-day a week 

responses for agencies that use the watchlisting process to screen 

individuals who, for example, apply for a visa, attempt to enter the United 

States through a port-of-entry, attempt to travel internationally on a 

commercial airline, or are stopped by a local law enforcement officer for a 

traffic violation. HSPD-6 mandated that the TSC achieve initial operating 

capability by December 1, 2003. 

The TSC is a multi-agency organization administered by the Federal 

Bureau of Investigation (FBI). Following the issuance of HSPD-6, the 

Attorney General, the Director of Central Intelligence, and the Secretaries of 

the Department of Homeland Security (DHS) and the Department of State 

(State Department) entered into a Memorandum of Understanding (MOU) 

describing the new organization and the level of necessary cooperation, 

including the sharing of staff and information from the four participating 

agencies. The MOU stipulated that the Director of the TSC would report to 

the Attorney General through the FBI and required that the Principal Deputy 

of the TSC be an employee of DHS. Since fiscal year (FY) 2004, the 

participating agencies have shared responsibility for funding and staffing the 

TSC, and for FY 2007 the TSC has a budget of approximately $83 million and 

408 positions.20 

In June 2005, the Department of Justice (DOJ) Office of the 

Inspector General (OIG) issued an audit report that examined the TSC’s 

operations from the time of its inception.21 The OIG reported that 

although the TSC had made significant strides in becoming the 

government’s single point-of-contact for law enforcement authorities 

requesting assistance in identifying individuals with possible ties to 

terrorism and had developed a consolidated terrorist watchlist database, 

the TSC had not ensured that the information in that database was 

complete and accurate. For example, we found instances where the 

consolidated database did not contain names that should have been 

- 1 – 

 20 As of June 2007, the TSC had 323 personnel on board. 

21 Department of Justice, Office of the Inspector General, Review of the Terrorist 

Screening Center, Audit Report 05-27, June 2005. 

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included on the watchlist. In addition, we found inaccurate or inconsistent 

information related to persons included in the database. In that review, 

we also found problems with the TSC’s management of its information 

technology (IT), an integral part of the terrorist screening process. 

TSC officials attributed some of these deficiencies to the immediate 

need during the earliest days of the TSC to develop a comprehensive 

database of potentially high-risk suspects. TSC officials explained that 

blending different types of data in various formats from multiple sources 

with varying technological infrastructures had resulted in data 

inconsistencies and inaccuracies. In addition, technology challenges and 

frequent record additions, deletions, and modifications affected the TSC’s 

ability to ensure the quality of the watchlist data. Our report included 

40 recommendations to the TSC addressing areas such as database 

improvements, data accuracy and completeness, and staffing. 

The purpose of our current follow-up review of the TSC was to 

determine if accurate and complete records are disseminated to and from 

the watchlist database in a timely fashion, as well as to assess the TSC’s 

current processes for ensuring the quality of the known or suspected 

terrorist information. Further, we examined the TSC’s efforts to minimize 

the impact on individuals misidentified as watchlist subjects. 

Purpose of the Consolidated Watchlist 

One goal of the nation’s counterterrorism efforts is to identify 

suspected terrorists and keep them out of the United States and from 

harming U.S. citizens both at home and abroad. An essential element of 

these efforts is the maintenance of a consolidated watchlist containing the 

names of known and suspected terrorists. This consolidated watchlist should 

include the most current and complete information and not contain 

inaccurate, inconsistent, or inappropriate information. Further, similar 

names and limited information in the watchlist can impair a frontline 

screening agent (such as a border patrol officer, visa application reviewer, or 

local police officer) from distinguishing between a suspected terrorist and a 

mistakenly identified individual. Deficiencies in the terrorist watchlist 

information also increase the opportunity for a terrorist to go unnoticed or 

not be properly handled when encountered. Additionally, inadequate 

information increases the possibility of individuals being misidentified as 

terrorist watchlist subjects and thereby being detained for more rigorous 

screening procedures. 

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Overview of Watchlist Nomination and Screening Processes 

When a law enforcement or intelligence agency has identified an 

individual as a potential terrorist threat to the United States and wants that 

individual watchlisted, the source agency must nominate that person for 

inclusion in the consolidated watchlist maintained by the TSC. Similarly, as 

additional information is obtained that either enhances the identifying 

information or indicates that the individual has no nexus to terrorism, the 

record should be either updated or deleted. 

All nominations from source agencies to the consolidated watchlist are 

vetted through the FBI or the National Counterterrorism Center (NCTC).22 

Analysts at NCTC or the FBI review the nomination information and decide 

whether or not the person is an appropriate candidate for inclusion on the 

consolidated watchlist. This review includes an evaluation of the information 

supporting the nomination, an examination of the quality and accuracy of 

the identifying information, and an examination of whether sufficient 

identifying information is available.23 The FBI and NCTC are responsible for 

providing the TSC an unclassified subset of identifying information for 

individuals known or suspected to be or have been involved in activities 

related to terrorism.24 

 22 As stated in the TSC MOU, source agencies responsible for U.S. 

counterintelligence, counterterrorism, and law enforcement provide information to the FBI 

and NCTC on suspected or known terrorists who are nominated for inclusion on the 

consolidated terrorist watchlist maintained by the TSC. The FBI is responsible for 

submitting to the TSC all domestic terrorist identity nominations, and NCTC is responsible 

for international terrorist identity nominations. While the FBI is a source agency for 

domestic and international terrorist information; it forwards relevant information to NCTC on 

suspected or known international terrorists. Domestic terrorist information is defined as 

information about U.S. persons that has been determined to be purely domestic terrorism 

information with no link to foreign intelligence, counterintelligence, or international 

terrorism. 

23 The TSC’s general criterion for including a record on the consolidated watchlist is 

that the nominating agency must have provided evidence of a nexus to terrorism. From a 

data perspective, the minimum criteria for inclusion of a terrorist identity into the TSDB are 

that the record contains at least a partial name (e.g., given name, surname, or both) and at 

least one additional piece of identifying information (e.g., date of birth). 

24 The TSC also has an emergency nomination process, which is used when there is 

an imminent threat and a watchlist record needs to be highlighted or created quickly. 

Under the emergency process, a requesting agency informs the TSC directly and the TSC 

adds the individual to the consolidated watchlist. The TSC then forwards all the information 

gathered on the subject to NCTC for subsequent additional vetting and creation of a record 

at NCTC. 

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The TSC shares the terrorist information contained in its Terrorist 

Screening Database (TSDB) by exporting or sending data “downstream” to 

other screening systems, such as the State Department’s Consular Lookout 

and Support System (CLASS), DHS’s Interagency Border Inspection System 

(IBIS), the Transportation Security Administration’s (TSA) No Fly list, the 

FBI’s Violent Gang and Terrorist Organization File (VGTOF) within its 

National Crime Information Center (NCIC) system, and others.25 Watchlist 

information is then available for use by U.S. law enforcement and 

intelligence officials across the country and around the world. 

Personnel working for these organizations routinely encounter 

individuals as part of their regular duties during various government 

processes. For example: (1) DHS agents of the U.S. Customs and Border 

Protection (CBP) agency examine individuals at various U.S. ports-of-entry 

and search IBIS to determine if a person can be granted access to the 

United States, (2) State Department officials process visa applications from 

non-U.S. citizens wishing to visit the United States and search CLASS to 

determine if the individual should be granted a U.S. visa, and (3) state and 

local law enforcement officers review the identifying information of 

individuals encountered through the criminal justice system and query the 

FBI’s NCIC system. In turn, these databases contain terrorist watchlist 

records so that the federal, state, and local law enforcement screening 

agents can identify persons that the U.S. government has determined are 

known or suspected terrorists. 

An overview of the flow of watchlist information from nominating 

agencies to the TSC and ultimate distribution to downstream screening 

databases is displayed in Exhibit 1-1. 

 25 NCIC is a nationwide information system maintained by the FBI that provides the 

criminal justice community with immediate access to information on various law 

enforcement data, such as criminal history records and missing persons. The FBI’s Criminal 

Justice Information Services Division is responsible for managing the NCIC database. A 

description of each of the downstream screening systems is contained in Appendix II. 

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EXHIBIT 1-1 

Terrorist Watchlist Dataflow Diagram26

Source/

Nominating

Agencies

Downstream

Screening

Databases

International Terrorist

Information

Domestic Terrorist

Information

Consolidated

Terrorist Watchlist

NCTC

FBI

TSC

Source: The National Counterterrorism Center 

Screening Activities and Hits Against the Terrorist Watchlist 

 When a name appears to be a match against the terrorist watchlist, 

requestors receive a return message through their database informing 

them of the preliminary match and directing them to call the TSC. When a 

call is received, TSC staff in the 24-hour call center assist in confirming the 

subject’s identity. 

To do this, the TSC Call Center staff search the TSDB and supporting 

databases to locate any additional information that may assist in making a 

conclusive identification. The caller is immediately informed of any 

negative search result – such as the subject of the inquiry does not match 

the identity of an individual on the watchlist. 

In general, if the subject is positively identified as a watchlist hit or 

the match attempt is inconclusive, the TSC call screener forwards the call 

to the FBI’s Terrorist Screening Operations Unit (TSOU), the FBI’s 24-hour 

global command center for terrorism prevention operations. The TSOU is 

then responsible for making further attempts to confirm the subject’s 

identity and, if necessary, coordinating the law enforcement response to 

the encounter, including deploying agents to take appropriate action. 

 26 A diagram providing a more detailed look at the flow of data in the 

U.S. government’s terrorist watchlisting process is located in Appendix III. 

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Not all encounters are face-to-face. According to State Department 

officials at the TSC, when a person located overseas submits an application 

for a visa, State Department officials search the CLASS database, which 

receives watchlist information from the TSC. If the search reveals a possible 

identity match with an individual recorded in the TSDB, the official sends the 

TSC a cable (a secure, electronic communication). A State Department 

representative at the TSC reviews the cable along with information from 

supporting agency databases to determine if the person requesting a visa is 

an individual with ties to terrorism. This information is then used by U.S. 

government officials overseas to either process or deny the application. 

TSC Encounter Management 

To manage information related to “hits” or possible matches against 

the watchlist, called “encounters,” the TSC uses a software application, 

called the Encounter Management Application (EMA). This system was 

implemented in July 2004 and includes a record of all encounters since the 

inception of the TSC. EMA contains the details of all incoming calls, 

including information about the inquiring law enforcement agency, the 

databases the TSC staff searched and the information obtained from these 

systems, the status of the TSC’s efforts to confirm an identity match against 

a watchlist record (i.e., positive, negative, or inconclusive), whether the 

caller was forwarded to TSOU for further action, and the final disposition of 

the call. For every inquiry that TSC call screeners refer to the TSOU, the 

TSC screeners are responsible for obtaining feedback on the disposition of 

the encounter, such as whether the subject was arrested, questioned, or 

denied entry into the United States. 

EMA provides the TSC with the ability to generate detailed statistics 

and prepare reports for analysis. Daily status reports are generated from 

EMA identifying the specific call information, which is reviewed by the TSC’s 

Tactical Analytical Team to identify patterns or threatening circumstances. 

If any such patterns are identified, the TSC forwards this information to the 

appropriate intelligence and law enforcement agencies for further review. 

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As of April 2007, the 

TSC Call Center had 

recorded nearly 

97,000 watchlist encounters 

referred by screening 

agencies since its creation in 

December 2003. More than 

50 percent of this total 

resulted in a positive 

identity match. As shown in 

Exhibit 1-2, 60 percent of 

the total calls received by 

the TSC Call Center originated from the U.S. Customs and Border Protection 

agency. 

EXHIBIT 1-2 

Watchlist Encounters Referred to 

the TSC Call Center by Organization 

(December 1, 2003, through April 30, 2007)

Referring Agency Number of 

Referrals 

Percent of 

Referrals 

DHS – CBP 58,266 60 

Other Federal 19,965 21 

State and Local 17,967 19 

Foreign Government 513 <1 

Total 96,711 100% 

Source: The Terrorist Screening Center 

Number of Terrorist Watchlist Records 

 Since the creation of the TSC in December 2003, the number of records 

in the consolidated U.S. government watchlist of known or suspected terrorists 

has significantly increased. We compiled a summary of available database 

size information, which illustrates the continued growth of the watchlist. 

According to TSC officials, there were approximately 150,000 records in 

the TSDB in April 2004.27 TSC data indicate that by July 2004 the number of 

records had increased to about 225,000 records, representing approximately 

170,000 unique terrorist identities. Eighteen months later, in February 2006, 

the TSC reported that the database contained approximately 400,000 records. 

Most recently, information we obtained from the TSC indicates that the TSDB 

contained a total of 724,442 records as of April 30, 2007. The vast majority of 

these records are international terrorist records – less than 1 percent of 

records related to the identities of suspected domestic terrorists. As shown in 

Exhibit 1-3, the number of watchlist records contained in the TSDB has more 

than quadrupled since its inception in 2004. 

 27 The reported figure represents the number of records in the system. This does 

not equate to the number of known or suspected terrorists in the system as a single person 

may have multiple records to account for the use of aliases, alternate identities, and 

multiple identifying documents. As such, the number of records generally will be larger 

than the number of suspected or known terrorists on the watchlist. 

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EXHIBIT 1-3 

Number of Terrorist Watchlist Records 

0 200,000 400,000 600,000 800,000

 April 2007

 February 2006 

 July 2004

 April 2004

DATE

RECORDS

Source: OIG analysis of Terrorist Screening Center data 

Handling Instructions 

Each record within the consolidated watchlist database is designed to 

contain information about the law enforcement action to be taken when 

encountering an individual on the watchlist. This information is conveyed 

through two separate “handling codes” or instructions – one handling code 

for the FBI and one for the DHS. 

FBI Handling Codes - each individual nominated for inclusion in the 

FBI’s screening database, National Crime Information Center’s (NCIC) 

Violent Gang and Terrorist Organization File (VGTOF), is assigned a code 

used to provide instruction for handling the individual. These codes are 

assigned based on whether there is an active arrest warrant, a basis to 

detain the individual, or an interest in obtaining additional intelligence 

information regarding the individual.28 Following are the definitions for each 

code. 

• Handling Code 1 - [SENSITIVE INFORMATION REDACTED] 

• Handling Code 2 - [SENSITIVE INFORMATION REDACTED] 

 28 Practices and procedures regarding one handling code are classified Secret, and 

are not, therefore, discussed here. 

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• Handling Code 3 - [SENSITIVE INFORMATION REDACTED]. 

All records in the consolidated watchlist database that are eligible for 

export to VGTOF should have a handling code assigned. Based on our 

review, we determined that all eligible records contained in the TSDB 

contained a VGTOF handling code. As depicted in Exhibit 1-4, the majority 

of the records in the TSDB are designated as Handling Code 3. 

EXHIBIT 1-4 

Distribution of VGTOF Handling Codes 

(as of March 6, 2007)29

Other

2,555, 0.6%

Handling Code 3 

404,647, 96.8%

Handling Code 2 

2,270, 0.5%

Handling Code 1 

 8,701, 2.1%

Source: The Terrorist Screening Center 

 

DHS Handling Instructions – each individual nominated for inclusion in 

the DHS’s screening database is assigned one of three codes that provide 

instructions to law enforcement officials at ports-of-entry. According to TSC 

officials, each instruction requires the individual to receive additional 

screening. However, one code provides a less intrusive method for handling 

known or suspected terrorists because the law enforcement officer is 

directed to not meet the individual at the arriving plane and not alert the 

subject of his or her possible watchlist status. Based on our review, we 

determined that all eligible records in the TSDB contained an IBIS handling 

instruction. As shown in Exhibit 1-5, approximately 5 percent of the records 

in the TSDB that are eligible for export to IBIS are designated with this 

special handling instruction. 

 29 The other category relates to the handling code practices and procedures that are 

classified at the Secret level. 

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EXHIBIT 1-5 

Distribution of IBIS Handling Instructions 

(as of April 30, 2007) 

Special

34,623 

5%

Lost or Stolen 

Passport

 2,836 

0%

Standard

 676,533 

95%

Source: The Terrorist Screening Center 

OIG’s Audit Approach 

The objectives of this OIG audit were to: (1) determine if accurate 

and complete records are disseminated to and from the watchlist database 

in a timely fashion; (2) review the TSC’s efforts to ensure the quality of the 

information in the watchlist database; and (3) assess the TSC’s efforts to 

address complaints raised by individuals who believe they have been 

incorrectly identified as watchlist subjects. 

To accomplish these objectives, we interviewed more than 45 TSC 

officials, including the Director, the former Acting Director and Deputy 

Directors, as well as officials at NCTC, the FBI, and DHS. In addition, we 

interviewed participating agency representatives and toured facilities to 

ensure that we obtained a detailed understanding of the working 

relationships utilized, assistance provided, and communication flow during 

the terrorist screening process. 

To evaluate the accuracy and completeness of the consolidated 

watchlist, we divided our review into two separate tracks. First, we analyzed 

the consolidated database as a whole, including a review of the number of 

records in the database, any duplication that existed within those records, 

and the associated watchlist processes. Second, we tested individual 

records within the database for accuracy and completeness. This included 

reviewing a sample of FBI and other government agency nominated 

domestic and international terrorist records and tracing these records to the 

TSDB to determine if the individuals were included in the database and that 

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the information was accurate, complete, and consistent. In addition, we also 

checked whether known terrorist names were in the database. 

To assess the TSC’s efforts to ensure the quality of the information in 

the watchlist database, we examined the TSC’s quality assurance activities 

and reviewed records subjected to these processes. We also examined the 

timeliness of the TSC’s efforts to resolve matters arising from its review of 

the accuracy and completeness of the data. This included an evaluation of 

the TSC’s progress to conduct a system-wide, record-by-record review and 

to improve its quality control processes as a result of recommendations in 

our previous audit. 

To fulfill our third objective, we examined the TSC’s policies and 

procedures for handling inquiries related to individuals who raised 

complaints following their involvement in a screening encounter. This 

process is referred to as redress. We evaluated the TSC’s efforts to 

coordinate redress response efforts with other participating agencies, 

reviewed a sample of redress inquiries, and assessed the timeliness of the 

TSC’s responses to redress inquiries. 

Detailed information regarding our audit objectives, scope, and 

methodology is contained in Appendix I. 

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FINDINGS AND RECOMMENDATIONS 

I. DATA ACCURACY AND TIMELINESS 

Our prior audit in June 2005 found that the TSC was operating 

two vastly different versions of the TSDB and the TSC lacked 

sufficient internal controls to ensure the integrity of the 

databases, resulting in names excluded from the watchlist and 

inaccurate and incomplete records. In our current review, we 

found that the TSC was operating two versions of the TSDB in 

tandem and the TSC had not taken adequate steps to ensure 

that the content of the two databases was identical. Further, we 

found significant numbers of duplicate records. In addition, 

because of internal FBI watchlisting processes, we found that the 

FBI bypasses NCTC and the TSC and enters a nomination into a 

downstream screening system prior to submitting the 

nomination to NCTC. As a result, the TSC is unable to ensure 

that consistent, accurate, and complete terrorist information is 

disseminated to frontline screening agents in a timely manner. 

Moreover, the TSC had determined that the TSDB contained over 

2,000 watchlist records that did not belong in the database. This 

TSC review also identified at least eight records that were 

missing from the downstream databases and were therefore not 

available to frontline screening agents. While we recognize that 

no process will be perfect, omissions of a terrorist identity, as 

well as the existence of inaccurate, incomplete, or outdated 

watchlist records can have significant ramifications. Our findings 

indicate that the TSC needs to further improve its controls over 

the TSDB to help ensure the integrity and effectiveness of the 

watchlist. 

Structure of the TSDB 

In concert with NCTC’s implementation of its Terrorist Identities 

Datamart Environment (TIDE) database, the TSC developed a web-based 

version of the TSDB called the Nomination Tracking Processor (TSDB NTP) in 

March 2005. As shown in Exhibit 2-1, the TSDB NTP facilitates the receipt of 

data from NCTC, provides direct connectivity to the NCIC VGTOF data 

system, and enables the initiation and monitoring of data quality assurance 

efforts of the TSC.30 However, the TSDB NTP system is unable to export 

watchlist data to most screening agencies or process expedited and domestic 

 30 Direct connectivity to the NCIC VGTOF system and quality assurance functionality 

were established in May 2005 and March 2006, respectively. 

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terrorist nominations into the TSDB. As a result, the TSC has retained a 

legacy version of the TSDB to accommodate these processes.31 These two 

versions of the TSDB are interconnected to help ensure that nominations are 

properly exported to downstream watchlist agencies. 

EXHIBIT 2-1 

TSDB Operating Environment 

NCTC

IT Input

Customers TSC

TIDE

XML

Nomination

File

CLASS-VISA

VGTOF

CLASS-PPT

Redacted

Redacted

IBIS

TSA

TSDB - NTP

Web based

Receives data from NCTC and

gives feedback to NCTC

Contains Single Review Queue

Contains Reports

Exports to VGTOF

Sends data to TSDB (Legacy)

TSDB (Legacy)

Receives data from TSDB

(NTP)

Exports to several customers

Enables records to be entered

manually into TSDB

TSDB

(Legacy)

TSDB

(WEB)

FBI / TSC

DT Input

Expedited

 Nominations

Source: The Terrorist Screening Center 

TSC officials stated that while this operating environment is not 

optimal, they needed to maintain the legacy version of the TSDB because 

the TSDB NTP is unable to process expedited nominations or connect 

electronically with all of the related downstream screening databases. With 

two versions of the TSDB, however, it is critical that the TSC maintain strong 

controls to ensure that each name nominated for inclusion in the TSDB NTP 

is appropriately included in the legacy version and accurately marked for 

export to the relevant downstream supporting systems in a timely manner. 

However, we determined that the TSC did not implement the 

necessary controls to ensure that both databases contained a complete and 

accurate version of the terrorist watchlist. Specifically, the NTP and legacy 

databases were not synchronized, which caused inconsistent record counts 

between the two systems. As a result, names were omitted from the 

downstream screening databases. In addition, we noted that records had 

 31 In June 2004, the TSC upgraded its original watchlist, which facilitated the 

electronic exchange of data with participating agencies’ systems. 

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been inappropriately maintained in the TSDB without any watchlist 

designation. These findings are discussed in detail below. 

Inconsistent Record Counts 

At the beginning of this audit, we were informed by the TSC Chief 

Information Officer (CIO) that the NTP and legacy versions of the TSDB were 

interconnected to help ensure that the watchlist was properly exported to 

frontline screening agencies. Therefore, the two databases should be 

identical in content and should contain the same number of records. 

However, on March 16, 2007, we found that the TSDB legacy database had 

689,631 records while the NTP had 689,613 records – a difference of 

18 records. Although the difference is a small portion of the universe of 

records, omitted records can result in a missed opportunity to identify a 

known or suspected terrorist. 

We brought the record discrepancy to the attention of the TSC CIO, 

who said he was surprised to learn that the systems were not in balance. 

Upon further review, the CIO learned and reported to us that the IT staff at 

the TSC was aware that the record counts sometimes varied. Despite the 

increased risk created by continual transactions between the two databases 

as well as recent system modifications, the TSC IT staff did not appear to 

have examined the differences, researched a valid explanation for the 

discrepancies, or sought a correction for whatever condition was causing the 

record counts to be out of balance. 

Through subsequent analysis, on March 26, 2007, the TSC determined 

that the record difference between the two databases had increased to 

38 records – 5 records were missing from the TSDB legacy system while at 

the same time it contained an additional 33 records that were not in the 

TSDB NTP system. These omissions and inaccuracies resulted from 

problems in a number of different areas. 

Records Missing from the TSDB Legacy Database

Because the TSDB legacy database facilitates the export of data to 

downstream screening databases, any information that is missing from the 

system is not made available to all appropriate law enforcement and 

intelligence officials for screening of persons against the watchlist. As a 

result of our review, the TSC identified five records that were missing from 

the TSDB legacy system, which caused the exported watchlist to be 

incomplete. 

• One record, nominated on December 22, 2006, was never 

transmitted from the TSDB NTP system. As a result, this known 

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or suspected terrorist record was not watchlisted for over 

3 months. TSC officials were unable to determine why the 

record was not sent. However, as a result of our review, the 

TSC subsequently added this record to the watchlist. 

• Three records nominated on March 5, 2007, were transmitted by 

the TSDB NTP system but were never imported into the TSDB 

legacy system. According to TSC officials, the import process for 

the file containing these records was interrupted. The individual 

processing the file should have received a notification that the 

process failed. However, because multiple files are processed 

each day, TSC officials could not readily identify who processed 

the file nor provide an explanation as to why corrective action 

had not been taken. The TSC CIO stated that as a result of our 

review, the TSC has taken corrective action by modifying the 

software so that if the transfer process is interrupted again and 

the user restarts the program, the application returns to the last 

successfully imported identity and restarts the process to ensure 

that no records are lost by the interruption. 

• On December 20, 2006, the NTP system appropriately processed 

a request for the deletion of one record. However, the record 

was not deleted from the TSDB legacy system at the same time. 

As a result, this name continued to be inappropriately exported 

to downstream screening databases for nearly 2 months. On 

February 6, 2007, the individual was re-nominated by NCTC 

through the TSDB NTP, resulting in the two systems being 

synchronized for this record. On February 21, 2007, the original 

request for deletion was inappropriately processed in the TSDB 

legacy system resulting in the name not being watchlisted for 

approximately 1 month until we brought it to the TSC’s attention 

in early March 2007. 

TSC officials explained that earlier versions of the TSDB legacy 

database could not process multiple actions for a single record, 

such as both a modification and a deletion, within one daily 

import file. TSC officials also theorized that for this record it 

appears that the December 20, 2006, file contained both a 

modification and a deletion. Because the TSDB legacy system 

processed the modification first, the deletion did not process, 

remained within the queue, and was processed 2 months after it 

was submitted. TSC officials stated that they have modified the 

processing order of the queue to prevent this anomaly from 

occurring again. 

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Additional Records in the TSDB Legacy Database

 As a result of our review, the TSC identified 33 additional records 

contained within the TSDB legacy system that were omitted from the TSDB 

NTP system. According to TSC officials, the errors associated with each of 

the 33 records resulted from deficient historical data and technological 

complications.32 TSC officials agreed that none of the records should have 

been included in either database. TSC officials stated that they have now 

ensured that these records have been submitted to the internal quality 

assurance unit for corrective action. 

Inaccurate Display of Watchlist Designation 

 The State Department’s Consular Lookout and Support System 

(CLASS) is one of the downstream screening systems that receives watchlist 

information from the TSDB. CLASS consists of two modules – CLASS/Visa 

and CLASS/Passport, which are used for processing visa and passport 

applications. According to State Department policies, individuals who are 

designated as a U.S. citizen or a U.S. person are ineligible for inclusion in 

the CLASS/Visa module.33 Non-U.S. persons are eligible for inclusion in both 

CLASS/Visa and CLASS/Passport. Therefore, an individual’s TSDB record 

can be exported to CLASS/Visa, CLASS/Passport, or both data systems 

based upon their status as a non-U.S. person. The TSC has included these 

criteria in the TSDB legacy software to ensure that watchlist records are 

correctly nominated and exported to the appropriate CLASS module during 

the data transfer process. 

 TSC users viewing the TSDB NTP system see check boxes that clearly 

identify the downstream screening systems to which each record is 

disseminated. However, the series of check boxes includes only one CLASS 

box that does not delineate between CLASS/Visa and CLASS/Passport and 

has the generic label “CLASS.” 

The TSC plans to correct the CLASS designation in the TSDB NTP 

system to appropriately reflect that U.S. persons are not eligible for export 

to CLASS/Visa. In addition, as part of its planned system upgrades, the TSC 

 32 Many of these deficiencies are attributable to data inconsistencies and 

inaccuracies that resulted from the TSC’s immediate need during its earliest days to develop 

a comprehensive database of known or suspected terrorists. 

33 According to TSC standard operating procedures, a U.S. person is defined as 

either: (1) a citizen of the United States; (2) an alien lawfully admitted for permanent 

residence; (3) an unincorporated association with a substantial number of members who 

are U.S. citizens or are aliens lawfully admitted for permanent residence; or (4) a 

corporation that is incorporated in the United States. 

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intends to modify the TSDB NTP to accommodate designations for both 

CLASS/Visa and CLASS/Passport. This will help ensure that once the TSC 

begins to use the NTP system to export watchlist records to the downstream 

databases, the appropriate records are sent to each of the CLASS modules 

and individuals are watchlisted in the correct systems. 

Future of the TSDB 

 We were told by TSC officials that they intend to streamline the TSDB 

by incorporating the functionality of the legacy system into the TSDB NTP 

and eliminating the legacy version. To minimize the impact on operations, 

the TSC plans to implement the changes in an incremental and phased 

approach. TSC officials anticipate that the project will be completed by the 

end of calendar year 2007. 

It is essential that the TSC maintain and distribute to frontline 

screening agents a complete subset of known or suspected terrorist identity 

information. Therefore, the TSC should work aggressively to implement its 

plan to consolidate the TSDB NTP and legacy systems. Further, we believe 

that for as long as the TSC must maintain its current operating environment, 

the TSC must closely monitor the content of each to ensure that the record 

counts agree and that all watchlist records are accounted for and 

disseminated as appropriate. As a result of our audit, the TSC CIO stated 

that he had implemented a policy whereby the contents of the two systems 

are reconciled manually on a daily basis. 

Records Not Designated for Any Watchlisting 

According to its governing MOU, the TSC is responsible for regularly 

reviewing the contents of the TSDB and promptly adjusting or deleting 

outdated information. During the course of our review, we were informed by 

TSC officials that in September 2006 they had identified 2,682 records that 

were not being exported to any downstream screening database. Working 

with NCTC, the TSC confirmed that 2,118 of these records did not belong in 

the TSDB and needed to be removed from the consolidated watchlist.34 TSC 

officials conducted a manual review of the remaining 564 records and 

determined that 8 had not been appropriately watchlisted and needed to be 

renominated to the TSDB.35 

 34 On April 27, 2007, the TSC implemented an information technology solution to 

delete these records. 

35 The TSC determined that the 564 records represented 443 unique identities. As 

of June 15, 2007, the TSC had resolved 413 of the 443 records. 

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Despite being responsible for removing outdated or obsolete data from 

the TSDB, however, the TSC did not have a process for regularly reviewing 

the contents of the TSDB to ensure that the database does not include 

records that do not belong on the watchlist. TSC officials told us that they 

intend to begin performing a periodic review of the database to identify any 

records that are being stored in the TSDB that are not being exported to any 

downstream systems. We believe it is essential that the TSC regularly 

review the TSDB to ensure that all outdated information is removed, as well 

as to affirm that all records are appropriately watchlisted. 

FBI Procedure for Processing Watchlist Data 

The FBI’s Terrorist Review and Examination Unit (TREX) receives 

requests from FBI agents to include individuals with known or suspected ties 

to terrorism on the terrorist watchlist. These requests are provided on 

nomination forms, which are also used to modify previous submissions or 

remove records from the watchlist. Analysts at TREX review the nomination 

information for accuracy and completeness. Once verified, nomination forms 

for known or suspected domestic terrorists are electronically forwarded to 

the TSC where a TSC analyst manually enters the information into the TSDB. 

This information is electronically distributed to the downstream screening 

agency data systems, including the FBI VGTOF, part of the NCIC system. 

By contrast, once the TREX analyst verifies an FBI-generated 

international terrorist nomination, the analyst enters the information into 

VGTOF directly and then submits the nomination form to NCTC. Following 

its review and vetting, the NCTC analyst manually enters the information 

into its database – TIDE – that in turn feeds the information to the TSDB. 

Because TREX has already entered the record into VGTOF, it is not 

necessary for the TSC to export the record it receives from TIDE to VGTOF. 

Therefore, these records are not exported from the TSDB to VGTOF.36 

Because these VGTOF records will not receive electronic modifications or 

deletions from the TSDB, the TSC and TREX have agreed that TREX will be 

responsible for ensuring FBI-originated international watchlist records in 

VGTOF are accurate, complete, and current. 

The FBI’s direct entry of international terrorist watchlist nomination 

data into a downstream screening database bypasses NCTC and the TSC 

and makes it difficult for these agencies to carry out their responsibilities 

related to watchlist nominations and records. In our opinion, this process 

 36 To alert the TSC of this non-standard entry of records into the TSDB, the TSC 

implemented a special flag, referred to as “FBI sole source,” for FBI-originated international 

records. This designation precludes all future electronic transactions, including related 

modifications and deletions, from being exported from the TSDB to VGTOF. 

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does not comport with the nomination and data flow procedures outlined in 

the MOU and agreed to by the partner agencies, which requires agencies to 

provide directly to NCTC, rather than directly into a downstream database, 

information related to known or suspected international terrorists. 

Additionally, we believe the FBI’s practice is cumbersome for the TSC and 

creates unnecessary data errors, anomalies, and inconsistencies as 

described below. 

To test for data accuracy and consistency, we reviewed a judgmental 

sample of 50 FBI-originated additions or modifications to the watchlist.37 

We found that while the records for the domestic terrorist nominations were 

generally accurate, the international terrorist nominations were not. We 

identified 16 records with 28 instances in which the identifying information 

related to international terrorists was inconsistent between the nomination 

form, VGTOF, TIDE, TSDB, or other screening systems. According to 

TSC personnel, TREX analysts frequently augment the data on the 

nomination forms with information they glean from FBI case files and enter 

this additional information into the VGTOF system. However, this 

supplemental case information is not forwarded to NCTC and as a result the 

information is not included in TIDE, not sent to the TSDB, and not made 

available, if appropriate, to downstream screening systems. Further, 

because TREX enters the record into VGTOF before the addition of any other 

existing information from other government databases to which NCTC has 

access, this additional information is often not included in VGTOF. As a 

result, vital information on watchlist subjects is not being shared with all 

appropriate screening agencies. 

In addition, we found that the FBI’s procedures for processing 

international terrorist watchlist nominations are cumbersome for the TSC 

and can inadvertently create an incomplete watchlist. The difference in 

procedures between the FBI’s and other agencies’ watchlist nominations 

requires TSC analysts to review every incoming international terrorist 

nomination and indicate within the record whether it is an FBI source 

record. If a terrorist watchlist record is improperly designated as an FBI 

source record, the subset of terrorist watchlist records in VGTOF will be 

incomplete because that record will not be exported to or modified within 

VGTOF. TSC staff told us that they were also concerned about this because, 

when reviewing nominations from NCTC, it is often difficult to distinguish 

between FBI source records and nominations received from other agencies. 

TSC staff stated that there was a period of time (possibly as long as a year) 

in which many records had been improperly designated as an FBI-originated 

 37 The total sample of 50 records consisted of 25 each for domestic and 

internationally known or suspected terrorists. 

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record or not. In March 2007, the TSC and NCTC addressed this problem by 

developing a method to permit TSC analysts to more easily identify FBI 

source records. 

In response to these concerns, FBI officials informed us that they had 

implemented nomination procedures to ensure that FBI international 

terrorist information was entered into VGTOF in the most efficient manner. 

Yet, our review of 70 FBI record transactions (50 nominations previously 

mentioned and 20 deletions) revealed that although the transactions were 

entered into VGTOF in a timely manner, the transactions were not 

incorporated in the TSDB in a timely fashion.38 Specifically, 18 of the 

70 transactions took more than 5 days for TREX to process, with 

1 transaction taking 35 days. In addition, we identified 2 instances in which 

TREX erroneously delivered nomination forms for domestic terrorists to 

NCTC that resulted in delays of 6 and 16 days, respectively. 

Delays in including terrorist information in the consolidated database 

present a significant vulnerability to the integrity of the consolidated 

watchlist. Further, the FBI’s current practice of bypassing NCTC and the 

TSC and entering international terrorist-related data directly into VGTOF 

increases the likelihood that watchlist information within the TSDB, TIDE, 

VGTOF, and other downstream databases is inaccurate and incomplete. As 

a result, we recommend that the FBI, NCTC, and TSC work together to 

design a more consistent and reliable process by which FBI-originated 

international terrorist information is provided to NCTC for inclusion in TIDE 

and disseminated to the TSDB and downstream screening systems, 

including VGTOF. 

Duplicate Records 

As shown in Exhibit 2-2, the TIDE and TSDB systems store all 

information known about an individual in a single “identity” record using 

five core identifying fields, including [SENSITIVE INFORMATION 

REDACTED]. However, the downstream screening agency data systems do 

not store information at the identity level. Rather, the identity information 

is split into separate watchlist records to reflect unique combinations of the 

five core fields. 

 38 Officials from NCTC, the TSC, and TREX stated that each agency attempts to 

process nominations to the watchlist within 1 day. 

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EXHIBIT 2-2 

Record Overview 

[SENSITIVE INFORMATION REDACTED] 

Source: The Terrorist Screening Center 

Multiple records containing the same unique combination of 

identifying information can increase the number of records that a call 

screener must review when researching a specific individual. In addition, 

when multiple records for a single identity exist, it is essential that 

identifying information and handling instructions be consistent. Otherwise, 

the screener may mistakenly rely on one record while a second, more 

complete or accurate record may be ignored. This can result in important 

information being missed. Further, inconsistent handling instructions may 

pose a safety risk for law enforcement officers. 

In our June 2005 report, we identified 31 instances in which 5 core 

identifying fields were the same and recommended that the TSC implement 

corrective action to address the duplicate records and develop an ongoing 

process to review the TSDB for duplicate records. 

In our current audit, we identified a significant increase in duplicated 

records – 2,533 repeated combinations in these 5 fields involving over 

6,262 watchlist records. For example, one unique combination of the 5 core 

fields had 19 associated records. 

In response to the apparent duplicates we identified, TSC officials 

explained that the duplicates were the result of multiple TIDE identity 

records for a single individual, system-generated duplicate records, and 

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improperly processed expedited nominations. TSC officials stated that, while 

they did not have an ongoing process by which they reviewed the TSDB for 

duplicate records, as a result of our finding the TSC will review the TSDB on 

a weekly basis for duplicate records. The results will be forwarded to the 

TSC’s internal quality assurance unit for further review and action. 

Multiple Identity Records for the Same Individual 

Of the 2,533 instances in which the core identifying fields were the 

same, TSC stated that most were not necessarily duplicate records. Rather, 

because the records have different TIDE record numbers, the TSC was 

unable to independently determine whether these records were duplicates. 

TSC officials explained that NCTC has indicated to them that many of these 

occurrences are inherent to old data. For example, prior to the 

implementation of HSPD-6 in 2003, both the FBI and the State Department 

may have maintained information regarding a single terrorist identity. 

During the blending of all sources of international terrorist information, both 

records may have been included in the TIDE data system resulting in 

duplicated data. In addition, TSC officials explained that some terrorist 

information remained classified and, as a result, could not be linked to 

unclassified data.39 To ensure that the most complete subset of unclassified 

information was disseminated, NCTC created multiple identity records for 

some individually known or suspected terrorists. As a result, rather than the 

optimal one identity record with multiple watchlist records, some individuals 

have multiple identity records that contain multiple identical watchlist 

records. 

Through additional data analysis of the duplicate records we identified, 

the TSC identified at least one instance in which both the FBI and another 

government agency nominated the same individual. Because both records 

pertain to the same individual, the identifying information and instructions 

for handling the subject should be consistent. However, we identified 

significant differences in the handling instructions and warnings for the 

individual. Specifically, one record indicated that the individual was “armed 

and dangerous with violent tendencies” and also had a valid federal arrest 

warrant. The other record did not contain this information. Moreover, our 

analysis of the instances in which the five identifying fields were the same 

indicates that at least 20 percent have some discrepancy in handling 

instruction, identifying information, or watchlist export designation. These 

 39 By August 2004, the Attorney General, the Director of Central Intelligence, and 

the Secretaries of Homeland Security, State, Treasury, and Defense signed Addendum A to 

the original governing MOU. Addendum A contained provisions for the declassification and 

sharing of terrorist information, including [SENSITIVE INFORMATION REDACTED]. 

However, the provisions only covered information obtained after August 2004. 

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descriptions and instructions are used by frontline law enforcement 

personnel to assess and determine the level of threat posed by the individual 

encountered and help to protect themselves and others. Therefore, it is 

essential that this information be accurate and consistently applied to all 

records related to one individual. 

Because these multiple records occur in TIDE, the TSC believes the 

review of the 2,533 possible duplicates more appropriately falls to NCTC. In 

June 2006, NCTC implemented an Identity and Person Merge project. 

Through this project, NCTC intends to resolve the duplication of identity data 

across multiple TIDE identity record numbers. However, until the identity 

information is consolidated, NCTC analysts should apply new information for 

an existing individual to each TIDE identity record for the individual. 

Through this process, NCTC intends to ensure that users of TIDE do not miss 

information about an individual that is potentially relevant to their work 

because they viewed the “wrong” TIDE identity when conducting their 

analysis. NCTC and the TSC anticipate that NCTC initiatives will help to 

alleviate many of these multiple identity records. However, until corrected 

we believe that these multiple records can affect a screening agent’s ability 

to protect against terrorism and can also pose significant risks to the safety 

of frontline law enforcement officers. 

System-Generated Duplicates 

According to TSC officials, the TSDB should not contain multiple 

watchlist records for a single identity from TIDE with identical information in 

the five core identifying fields. We determined that the TSDB contained one 

TIDE identity with two associated watchlist records with duplicated 

identifying information. The TSC determined that these two records resulted 

from a nomination from NCTC in February 2005 in which the two records 

were either improperly included in the daily import file or an error occurred 

during the import process on that day. Based on our review, the TSC 

submitted this record to its internal quality assurance unit, and the duplicate 

record was deleted. 

Expedited Nominations 

When the TSC is informed about an individual who poses an imminent 

threat, it creates an “expedited” watchlist record directly into the TSDB. The 

TSC then forwards all of the information gathered on the subject to NCTC or 

the FBI for subsequent creation of a record through the standard nomination 

process. Once the record is submitted through the standard processes, the 

original expedited record should be deleted. However, our review of the 

duplicate record issue identified three expedited records that had been 

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improperly processed and not deleted from the TSDB after the record was 

submitted through the standard nomination process. 

According to TSC officials, these duplicated records (the expedited and 

subsequent routine nomination) should contain identical information. Our 

analysis revealed two instances in which either an additional date of birth or 

passport number was missing. According to the TSC CIO, these three 

expedited nominations have been submitted to the TSC’s internal quality 

assurance unit for further review, and the duplicated records have been 

deleted. 

Inclusion of Known Terrorists in the TSDB 

We also performed limited testing on the TSDB to examine the 

completeness of the watchlist by determining if known terrorists were 

included in the consolidated database. We selected for our review a total of 

49 names: 10 from NCTC, 4 from news media accounts, 17 from the FBI’s 

Most Wanted list, 16 from the State Department’s List of Terrorists under 

Executive Order 13224, and 2 from the Rewards for Justice website.40 We 

searched the TSDB for these 49 names, and found that each was recorded in 

the TSDB. TSC officials also said they regularly checked their database 

against names reported in the news, broadcast on television, or included on 

lists such as the FBI’s Most Wanted. 

However, our review of the 49 known terrorist names also revealed 

that the handling instructions for individuals from the FBI’s Most Wanted list 

had significant discrepancies. Specifically, two VGTOF records indicated that 

the watchlist subjects were armed and dangerous, but the TSDB records did 

not reflect this handling instruction. In addition, we identified four records 

containing discrepancies in identifying information between TIDE and TSDB. 

As previously discussed, it is essential that the TSC ensure that individuals 

are properly and consistently recorded in the TSDB and downstream 

screening systems, so that appropriate actions are taken if the individual is 

encountered by a frontline screening agent. 

Conclusion 

It is critical that the TSC ensure that the TSDB contains comprehensive 

information and that each watchlist record is appropriately disseminated to 

downstream screening systems in a timely manner. While we recognize that 

 40 The State Department maintains a list of the most wanted terrorist organizations 

and individuals as specified by Executive Order 13224. The Rewards for Justice website is 

an organization operated by the FBI, CIA, DOJ, and the State Department. 

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no process will be perfect, the potential effect of omissions of a terrorist 

identity, or the existence of an inaccurate, incomplete, or obsolete watchlist 

record, requires the TSC and its partner agencies to take all available actions 

to minimize such errors. 

Despite our identification in our June 2005 audit of deficiencies related 

to the TSC’s information technology management and overall database 

reliability, our current audit determined that the TSC has not yet 

implemented routine processes to ensure that the TSDB contained all proper 

watchlist nominations and did not contain duplicate data resulting from 

improperly processed records, system malfunctions, and historical data 

deficiencies. Moreover, despite being responsible for removing outdated or 

obsolete data from the TSDB, the TSC did not have a process for regularly 

reviewing and verifying the contents of the TSDB. We believe that it is 

essential that the TSC regularly review the TSDB to ensure that all obsolete 

and out-of-date information is removed. Finally, because of internal FBI 

watchlisting processes, the TSC cannot ensure that accurate and complete 

terrorist information has been disseminated to downstream screening 

systems in a timely manner. 

Recommendations 

We recommend that the TSC: 

1. Implement its plan to consolidate the TSDB NTP and legacy 

databases in a timely manner. In the interim while the two systems 

coexist, the TSC should establish a formal procedure to regularly 

review the TSDB NTP and legacy databases to ensure that the 

information in these systems remains synchronized. 

2. Develop procedures to regularly review and test the information 

contained in the TSDB to ensure the data is complete, accurate, and 

non-duplicative. 

3. Modify the TSDB NTP to accommodate designations for both 

CLASS/Visa and CLASS/Passport. In addition, the TSC should review 

and correct the records identified in the TSDB NTP to appropriately 

reflect that U.S. persons are not eligible for export to CLASS/Visa. 

4. Review and correct the records identified in the TSDB NTP to ensure 

that the IBIS handling instructions are appropriately applied. 

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5. Develop procedures to regularly review the information in the TSDB 

to ensure that outdated or obsolete data is removed in a timely 

manner. 

We recommend that the FBI: 

6. Working with the TSC, revise the watchlist nomination process to 

provide international terrorist nominations directly to NCTC for 

inclusion in TIDE, submission to the TSC, and dissemination to all 

downstream databases, including VGTOF. 

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II. QUALITY ASSURANCE 

Our review indicated that the TSC had the foundations of a 

sound quality assurance plan that will improve the accuracy of 

the TSDB. The TSC is also continuing its efforts to perform a 

record-by-record review of the TSDB. However, we are 

concerned the TSC has not instituted adequate internal controls 

to ensure that its quality control initiatives are properly 

implemented. In addition, the TSC’s quality assurance efforts 

have been hampered by the growth in workload as the size of 

the watchlist increases. 

To test the quality assurance plan, we reviewed 120 TSDB 

records that had been through the TSC’s quality assurance 

process in FYs 2006 and 2007 and identified several instances in 

which the individual was not appropriately watchlisted, as well as 

inconsistencies between the TSDB record and other available 

information. These inconsistencies make it more difficult for 

screening agents to determine if encountered individuals are on 

the watchlist. 

Overview of the TSC’s Quality Assurance Process 

 In our June 2005 audit report, we identified weaknesses in the 

completeness and accuracy of the TSDB. During the TSC’s earliest days, it 

had 12 staff assigned responsibility for nominations and data integrity tasks, 

including one staff member that was dedicated solely to quality assurance 

matters. During our initial audit, TSC management acknowledged that the 

organization needed to focus more attention on ensuring the quality of the 

watchlist. We recommended that the TSC regularly review and test the 

information contained in the TSDB to ensure data is complete, accurate, and 

non-duplicative. We also recommended that the TSC coordinate with 

participating agencies and establish procedures to identify and resolve 

missing and conflicting record information. 

 In response to our recommendations, the TSC increased its quality 

assurance efforts and implemented a data quality improvement plan that 

detailed the TSC’s intent to conduct a record-by-record review of the TSDB. 

As of March 2007, the TSC had 34 staff on-board in its Nominations and 

Data Integrity Unit (NDIU), which is responsible for performing or overseeing 

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all of the TSC’s activities related to ensuring the quality and accuracy of the 

watchlist, including:41 

• Reviewing incoming watchlist data (referred to as the single review 

queue). 

• Performing reviews of historical records following an encounter where 

the TSC identifies a potential discrepancy in watchlist records. 

• Conducting special quality assurance projects, such as performing a 

targeted review of the No Fly list or individuals with particular handling 

codes. 

Single Review Queue 

 Implemented in March 2006, the single review queue is a feature of 

the TSDB that segregates the incoming data feed from NCTC so that quality 

assurance analysts can test each record before releasing that record for 

inclusion in the TSDB. Prior to the implementation of the single review 

queue, each watchlist addition or modification the TSC received underwent 

numerous, separate reviews by individual subject matter experts (persons 

who were knowledgeable about the requirements of the specific databases 

used by various screening agencies). In implementing the single review 

queue, the TSC sought to make the nomination acceptance and review 

process more efficient. The single review queue was designed to have 

individual analysts in the NDIU be responsible for guiding individual records 

through the process of loading the information into the TSDB. The single 

review queue begins with the use of a computer program that analyzes 

incoming records against more than 45 business rules.42 A business rule is 

an automated information technology function in which the record is 

analyzed for specific deficiencies and compliance with criteria. 

 Once the business rules have been applied to all of the records 

received, the records are routed to the NDIU for manual review. Although 

the TSC has drafted a standard operating procedure (SOP) describing the 

single review queue process, it does not detail how NDIU analysts should 

conduct this manual record review. We observed NDIU analysts reviewing 

records in the single review queue and found that, in general, the review 

 41 The NDIU’s 34 staff included 7 individuals whose primary duty was to function as 

a subject matter expert. The remaining 27 staff members were assigned to specific quality 

assurance tasks and assisted with other quality assurance efforts as necessary. 

42 The TSC also uses 55 business rules to ensure watchlist criteria are met in 

exporting records to downstream databases. 

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included: (1) determining whether the person met the criteria for inclusion 

in the TSDB (i.e., nexus to terrorism and quantity of identifying 

information); (2) confirming the supporting downstream screening systems 

to which the record should be exported; (3) resolving any issues identified 

during the execution of the business rules; and (4) comparing information 

contained in watchlist nominations, such as [SENSITIVE INFORMATION 

REDACTED], to source documents and source databases. The NDIU has 

seven individuals serving as subject matter experts who are consulted when 

NDIU analysts are unable to resolve all issues related to watchlist 

nominations prior to these nominations being sent to downstream screening 

databases. Generally, each record is reviewed by fewer persons than before 

the implementation of the single review queue. As of March 2007, 10 of the 

34 staff members in the NDIU were dedicated to the single review queue. 

Encounter-Driven Quality Assurance Reviews 

In addition to data integrity work that is performed when new or 

modified data is processed through the single review queue, the NDIU 

receives referrals from the TSC Call Center for data checks on specific TSDB 

records. If a call center operator identifies a potential discrepancy in a 

watchlist record or obtains additional data relevant to a watchlist subject, 

the operator alerts the NDIU to perform a quality assurance review of the 

record. Generally, this occurs following a frontline screening agency’s 

encounter with a watchlist subject. 

In April 2005, TSC management began requiring call center operators 

to perform limited data quality tests while handling encounters. Because the 

operators have access to all of the databases that interact with the TSDB, 

they were in a position to point out inconsistencies in the information 

contained in the records on specific individuals in the various databases. 

This process was modified slightly in November 2006 when the TSDB was 

upgraded to incorporate quality assurance activities. As a result of the 

upgrade, individual watchlist records in the TSDB now contain a record 

(referred to as a QA ticket) in which TSC staff can record all quality 

assurance work that has been performed on that record.43 With the 

upgrade, call center screeners were instructed to create a QA ticket in the 

 43 Prior to the November 2006 TSDB upgrade, NDIU analysts first used an electronic 

spreadsheet and then a database commonly referred to as the “quality assurance tracker” 

to monitor quality assurance matters. NDIU analysts continued to use the quality assurance 

tracker for matters requiring classified correspondence because classified information 

cannot be placed into the QA ticket, which is housed within the TSDB – an unclassified 

system. In April 2007, the quality assurance tracker program was discontinued due to a 

number of concerns; the concerns and the TSC’s interim solution for recording classified 

quality assurance matters are discussed on page 39. 

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TSDB for each positive screening encounter for which they identified any 

erroneous or inconsistent information in the database records.44 In addition, 

the call screeners were told to create a QA ticket if they obtained new 

information that should be added to the watchlist records.45

When a call center operator prepares a QA ticket, the TSDB 

electronically routes the QA ticket to the NDIU for further action. An 

encounter-driven QA ticket indicates that the encounter revealed that 

information needs to be added or modified, or it will indicate that a call 

screener identified a discrepancy with the completeness and accuracy of the 

records. Upon receipt of QA tickets, dedicated NDIU staff review the 

information from the call center screener and perform a full quality 

assurance review of all affected records. The QA ticket is closed when all 

necessary changes have been communicated to the source agencies and fed 

back into the TSDB, which then updates the downstream screening 

databases. As of March 2007, the NDIU had 9 individuals dedicated to 

responding to QA tickets.46

Special Quality Assurance Projects 

The TSC also examines historical TSDB records for accuracy and 

completeness through targeted reviews of specific subsets of the watchlist 

records. Examples of special projects that the TSC has conducted include a 

review of TSDB records for individuals on the No Fly list and individuals with 

particular handling codes. As of March 2007, the TSC assigned 8 of the 

34 NDIU staff to these kinds of special projects. 

 44 Each encounter is positive, negative, or inconclusive. A negative encounter 

occurs when a screening agency contacts the TSC because during a screening event an 

individual is a potential match to a TSDB record, and the TSC (or other law enforcement 

responder) determines that the individual is not a match to the name on the watchlist. 

Conversely, a positive encounter is where the individual encountered is a match to the 

watchlist. An inconclusive encounter occurs when the TSC is unable to determine if the 

individual encountered is a match to an individual on the watchlist. 

45 Encounters offer law enforcement agents an opportunity to obtain additional 

information about watchlist subjects. For example, if a watchlist subject is positively 

identified during an attempted border crossing, the federal agent may obtain previously 

unknown information, such as a new passport number, eye color, or current address. 

46 These NDIU staff members also address QA tickets generated from TSC quality 

assurance efforts other than encounter-driven reviews, such as through the single review 

queue and during ad hoc record quality reviews. 

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OIG Analysis of TSC Quality Assurance Efforts 

 To examine the TSC’s efforts to ensure the quality of the information 

in the TSDB, we examined the TSC’s review of records in the single review 

queue and its review of encounters and special projects. In total, we 

examined 156 TSDB records. Of these 156 records, 36 involved a request 

for deletion. We determined that each of these records had been 

appropriately deleted from the consolidated watchlist. Using the remaining 

sample of 120 records, we performed tests to determine if the watchlist 

records were accurate. We found that, in general, the TSC’s actions to 

review records as part of a targeted special project successfully ensured the 

quality of the data, and we identified virtually no errors in the 15 records we 

tested in connection with special project reviews. In contrast, our 

examination of 105 records subjected to the single review queue or postencounter quality assurance reviews revealed that 38 percent of these 

tested records continued to contain errors or inconsistencies that were not 

identified through the TSC’s quality assurance efforts. Our results are 

discussed in detail below. 

Review of TSC No Fly List Special Project 

The first major subset of TSDB records that the TSC began reviewing 

as a special project was the Transportation Security Administration (TSA) 

No Fly watchlist records. The No Fly list includes individuals who, in general, 

are considered a threat to civil aviation and should be prevented from 

boarding commercial aircraft.47

To assist the TSC in its review of the No Fly list, the DHS temporarily 

assigned 10 federal air marshals to the TSC. The process included a review 

of the available information for each individual listed on the No Fly list and a 

determination of whether the individual should remain on the No Fly list. In 

addition to reviewing each entry on the No Fly list, the TSC performed a 

concomitant quality assurance review of all information contained in the 

TSDB’s records for individuals on the No Fly list. As a result, all of the 

TSDB’s records associated with individuals who were on the No Fly list 

underwent a comprehensive quality assurance review. 

When the TSC began its review in July 2006, the No Fly list contained 

71,872 records. As a result of the review, the TSC identified 22,412 records 

for removal from the No Fly list and placement on the TSA’s Selectee list.48 

 47 [SENSITIVE INFORMATION REDACTED] 

48 [SENSITIVE INFORMATION REDACTED] 

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For another 5,086 records, the TSC determined that the individual did not 

require inclusion on either the No Fly or Selectee list. The resulting No Fly 

list changes the TSC identified are displayed in Exhibit 3-1. As of 

January 31, 2007, the TSC had determined that the No Fly list should 

contain 34,230 records.49 

EXHIBIT 3-1 

Results of TSC Review of No Fly List 

56% 8%

36%

Records whose status did not change

Records downgraded to Selectee status

Records removed from both lists

Source: The Terrorist Screening Center Nominations and Data Integrity Unit 

We reviewed a sample of 15 TSDB records that had undergone a 

quality assurance review as part of the TSC’s review of the No Fly list. We 

did not find any data inaccuracies or inconsistencies in the records we 

reviewed. Each record’s basic information [SENSITIVE INFORMATION 

REDACTED] were shown consistently in all of the affected databases, and 

each record remained the same or was downgraded from the No Fly list in 

accordance with the final recommendation from the NDIU. 

 We did, however, identify an issue with the implementation of the 

status changes that the TSC identified during its review of the No Fly list. 

TSC officials told us that although the No Fly records were reviewed at the 

TSC, the status changes for known or suspected international terrorists 

could not be reflected in the TSDB until the changes were processed in TIDE 

 49 During its review of the No Fly list, the TSC continued to receive routine No Fly list 

additions, modifications, and deletions through the watchlist nomination process. As a 

result, it is not possible to subtract the special project-driven No Fly list changes from the 

starting point of 71,872 records and obtain the correct number of No Fly records as of 

January 31, 2007. 

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at NCTC. The correct watchlisting status could then be uploaded from TIDE 

to the TSDB during the normal daily data feed. In turn, the TSC would 

export the No Fly and Selectee lists to the TSA for dissemination to the 

airlines on a daily basis. 

According to TSC officials, NCTC and the airlines told the TSC that they 

could not effectuate all of the 27,498 changes (22,412 downgrades from the 

No Fly to the Selectee list plus 5,086 removals from the No Fly list) at once 

due to resource limitations. TSC management had previously decided not to 

send any record changes to NCTC until this special project was nearing 

completion. TSC management explained that TSC analysts needed the time 

to complete their quality assurance checks for each individual, particularly 

those with multiple TSDB records. The first changes were sent to NCTC on 

January 19, 2007. We were told that NCTC and the airlines could only 

process between 500 and 1,000 record changes a day. As a result, the TSC 

agreed to limit the number of changes it provided to NCTC and the airlines 

each day. 

This piecemeal approach to implementing the changes in all of the 

databases meant that the status of many individuals was incorrectly shown 

on the TSA’s No Fly and Selectee lists for a period of time.50 According to 

TSC officials, all of the changes had been passed back to NCTC as of 

March 21, 2007. However, as of May 31, 2007, the TSC and NCTC were in 

disagreement about the proper No Fly-list status of 108 records. 

Review of Routine Quality Assurance Matters 

 Unlike our review of the No Fly list special project, our examination of 

records passed through other TSC quality assurance processes revealed that 

the reviewed records were still likely to contain errors or inconsistencies. 

We selected a judgmental sample of 105 new and historical TSDB records 

that had undergone the single review queue or encounter-driven quality 

assurance processes.51 We examined the records to ensure that each record 

was exported to the appropriate screening databases. Additionally, we 

reviewed the records to determine if basic information [SENSITIVE 

 50 The period of time for which a record would have been inappropriately watchlisted 

to the No Fly list could range from a minimum of 1 day to a maximum of about 9 months. 

51 We have consolidated our single review queue and encounter-driven quality 

assurance sample selection and testing results here for ease of presentation. Although we 

selected records from different subsets of the TSDB, each had been subjected to the same 

quality assurance steps in the NDIU, making this consolidation possible. Details of our 

sample selection and the populations from which we selected them are provided in 

Appendix I. 

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INFORMATION REDACTED] was shown consistently in all of the affected 

databases. 

Watchlist Designation and Handling Code Errors

 Our review revealed that 7 of the 105 TSDB records examined were 

not being exported to all appropriate downstream watchlists. Specifically, 

three records were not exported to CLASS Visa. Moreover, these three 

records and an additional three records were not exported to [SENSITIVE 

INFORMATION REDACTED].52 Additionally, one record was not properly 

exported to the Interagency Border Inspection System (IBIS). 

We discussed these records with NDIU officials who agreed with our 

findings. As a result of the TSC’s failure to export the four records to IBIS or 

CLASS Visa, which are used by U.S. screening agencies, the watchlisted 

individuals could be issued a U.S. visa erroneously or inappropriately allowed 

to enter the United States. The TSC’s failure to export the six records to 

[SENSITIVE INFORMATION REDACTED] can prevent U.S. allies from 

identifying known or suspected terrorists and sharing additional intelligence. 

 Our review also revealed that in two instances the TSDB records did 

not correctly indicate how the record would be seen within the IBIS system. 

When records are exported from the TSDB to the IBIS system, watchlist 

records can be identified with a special, less-intrusive handling code, as 

described earlier. We identified two TSDB records that were exported to 

IBIS with the special handling designation but should not be because the 

subjects were considered armed and dangerous or were not deemed a 

U.S. person. In addition to incorrect IBIS handling designations, an 

additional three records contained improper VGTOF handling codes. As 

discussed earlier, VGTOF handling codes instruct law enforcement officers 

how to properly handle an encounter with a watchlist subject. Incorrect 

watchlist designations and handling codes can place frontline screeners at 

increased risk. 

Inconsistent or Incomplete Watchlist Records

Our review of the 105 TSDB records submitted to the TSC’s single 

review queue or encounter-driven quality assurance examinations also 

revealed that 35 TSDB records and the source or downstream records 

contained inconsistent identifying information in one or more data fields. In 

total, we identified 54 instances of inconsistent information. Our results are 

displayed in Exhibit 3-2: 

 

52 [SENSITIVE INFORMATION REDACTED] 

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EXHIBIT 3-2 

TSDB Record Inconsistencies 

TSDB Record Field Inconsistencies53

[SENSITIVE INFORMATION REDACTED] 

TOTAL 54 

Source: OIG analysis of TSDB, TIDE, and VGTOF watchlist records 

During our review, it became apparent that both the TSC’s quality 

assurance efforts and our reviews of watchlist records identified errors and 

inconsistencies in incoming records from the source agencies – NCTC and 

the FBI. We discussed the watchlist nomination process with NCTC and FBI 

officials, and both agency representatives stated that records are reviewed 

for accuracy, completeness, and consistency before the records are 

forwarded to the TSC. However, these efforts are failing to identify a 

significant number of deficiencies in the nominated records. The TSC’s 

quality assurance efforts, therefore, are hampered by the inaccurate and 

incomplete source material. 

However, inconsistent records can confuse or delay TSC Call Center 

operators in their efforts to determine if encountered individuals are a 

positive match for watchlisted known or suspected terrorists. Further, 

inconsistent information among databases involved in terrorism screening 

indicates that at least one record may be incorrect. Incorrect records can 

also misinform frontline screening agents and contribute to the 

misidentification and delay of an innocent person or the inappropriate 

release or admittance of a dangerous individual. 

Quality Assurance Management and Oversight 

 In general, we believe the actions the TSC has taken to improve 

quality assurance since our last audit are positive steps. We also recognize 

 53 Each entry in this column represents a TSDB record for which we determined that 

the identified TSDB record field was not in agreement with TIDE and VGTOF. (We limited 

our review to those databases.) It is possible for one record to have more than one error, 

and the overall total is the number of field errors. 

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that it is impossible to completely eliminate the potential for errors. 

However, we identified inaccuracies in the TSDB that persisted even after 

undergoing the quality assurance process. This underscores the need for 

additional actions to ensure that the TSDB is a reliable source of information 

about known or suspected terrorists. Specifically, as described below, we 

believe that the TSC should: (1) work with the participating agencies to 

improve coordination related to quality assurance work, including 

establishing areas of responsibility and timeframes for following up on 

quality assurance matters; (2) develop a comprehensive standard operating 

procedure for quality assurance matters; (3) regularly review the NDIU’s 

quality assurance work; (4) develop a reliable and secure method for 

tracking quality assurance matters that involve classified correspondence; 

and (5) develop quality assurance benchmarks to monitor the TSC’s 

progress in conducting a record-by-record review of the TSDB. 

Coordinating with Participating Agencies 

According to TSC personnel, NDIU analysts should follow up on all 

quality assurance matters every 30 days. However, the TSC does not have 

a mechanism such as a standardized report or digital dashboard that 

catalogs all outstanding quality assurance matters.54 As a result, NDIU 

analysts are not prompted to follow up on long-outstanding quality 

assurance matters for which the TSC is waiting for a response from another 

agency, such as NCTC. Rather, it is up to each individual analyst to take 

follow-up action. 

We examined a sample of 51 quality assurance matters opened 

between February 2006 and February 2007 and found that the matters were 

open from 0 days (the matter was closed the same day as it was opened) to 

329 days. On average, quality assurance matters in our sample were open 

for 80 days. We also obtained TSC data related to the number of quality 

assurance matters identified and resolved between November 2006 and 

March 2007.55 This data shows that the TSC is identifying incomplete or 

inaccurate information in TSDB records faster than the matters are being 

resolved. 

 54 A digital dashboard is a business management tool to visually display the status 

of a business project. The dashboard can provide warnings, next steps, action notices, and 

summaries of a project. 

55 The TSC could provide historical data on quality assurance matters only since 

November 2006 when the latest version of the TSDB was deployed. 

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EXHIBIT 3-3 

Cumulative Growth in Quality Assurance Matters 

2,253 3,116

5,287

11,270

18,143

2,430

3,436

5,862

12,433

20,657

0

5,000

10,000

15,000

20,000

25,000

November 2006 December 2006 January 2007 February 2007 March 2007

QA Matters

Resolved Identified

Source: The Terrorist Screening Center 

Exhibit 3-3 shows that the cumulative difference between quality 

assurance matters identified and addressed has increased from 177 in 

November 2006 to 2,514 in March 2007. A significant portion of the 

increase in quality assurance matters processed by the TSC resulted from its 

implementation of its No Fly special project in January 2007. However, the 

TSC is regularly identifying errors or concerns with known or suspected 

terrorist records. To resolve inaccuracies and inconsistencies in watchlist 

records, the TSC usually must involve the source agencies – NCTC and the 

FBI. TSC officials acknowledged that the TSC and the participating agencies 

have not established timeframes for the resolution of quality assurance 

matters. 

We believe that the TSC needs to work more closely with watchlisting 

agencies to better coordinate quality assurance efforts. This includes setting 

a standard for the timeliness of response to quality assurance matters, as 

well as delineating the roles and responsibilities of the various agencies 

involved. To improve the overall quality of the watchlist, the TSC needs the 

source agencies to provide records that are accurate, complete, and 

consistent, and to respond to quality assurance matters within a reasonable 

time. Without such an agreement, the TSC must expend additional effort to 

resolve errors that should have been identified earlier in the nomination 

process and continue to remind watchlist agencies about individual quality 

assurance matters. 

Further, the delayed closure of quality assurance matters directly 

affects the accuracy of the consolidated watchlist database because records 

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can contain inaccurate and incomplete information for extended periods of 

time while the matter is being resolved. Therefore, in concert with the 

development of established timeframes for resolving quality assurance 

matters, we recommend that the TSC develop a tickler system or aging 

schedule for its quality assurance work. 

Standard Quality Assurance Procedures 

During our audit, we personally observed NDIU analysts conducting 

quality assurance reviews of watchlist records. We noted that the analysts’ 

method of performing their reviews was not always consistent. For example, 

some analysts inspected all of the documents supporting a TSDB record, 

while other analysts relied solely upon summary information. We also found 

that the analysts were not documenting their quality assurance work 

consistently. The TSC has an SOP for its quality assurance efforts which was 

last revised on August 16, 2005. The document did not provide complete 

guidance to the analysts on the processing of quality assurance matters. 

Further, this SOP informs the analysts to review the record, but does not 

detail what fields, supporting information, and other aspects of the record 

the analysts should be verifying and comparing. In addition, these 

procedures do not instruct the analysts on the necessary actions to take 

when inaccurate or incomplete information is identified. Moreover, this 

protocol does not mention the existence of special projects within the TSC’s 

quality assurance efforts. We believe that the TSC should develop a 

detailed, comprehensive quality assurance SOP to better guide the NDIU 

analysts through all aspects of their work. 

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NDIU Analyst Oversight 

The TSC provides only a few days of training to its quality assurance 

analysts in the NDIU. Following the completion of that training, the analysts 

begin working independently and no additional routine training or refresher 

courses are required. However, staff meetings are held on an ad-hoc basis 

to discuss specific issues that have been encountered. The TSC does not 

have a mechanism for regularly spot-checking the work of its quality 

assurance analysts to help ensure that the analysts are performing 

appropriate reviews and keeping abreast of any process changes. We 

believe that the TSC should develop a system for performing regular spotchecks of NDIU analysts’ work to identify any weaknesses and needs for 

additional training. This process should be included within the 

comprehensive quality assurance SOP. 

Handling Classified Quality Assurance Matters 

Prior to April 2007, the TSC was using an in-house system called 

quality assurance tracker to catalog all classified correspondence related to 

quality assurance matters.56 However, TSC officials determined that the 

database: (1) had reached its storage capacity, (2) temporarily lost an 

estimated 2,000 records in January 2007, (3) did not have a reliable process 

for backing up the data, (4) did not create any standard management 

reports, (5) had no method for audit tracking, (6) had not been examined 

and tested thoroughly by the FBI, and (7) was used by very few staff. 

Therefore, the TSC shut down the database in April 2007 to prevent any 

more problems with its use. 

The TSC researched several possible long-term methods for tracking 

classified quality assurance correspondence. As of April 2007, the TSC’s 

temporary method was to use electronic folders on a classified server. We 

believe that this method will not be an effective method for tracking 

classified correspondence. In addition, a quality assurance analyst in the 

NDIU told us that the electronic folder method will be more time-consuming 

and less useful than tracking their individual correspondence within e-mail 

accounts and, as a result, some analysts do not plan to use the temporary 

system. We believe the TSC needs to develop a more effective and userfriendly means for temporary tracking of classified quality assurance 

correspondence. 

 56 The TSC cannot place classified information into its QA tickets because this 

information is stored within the TSDB, which is an unclassified system. 

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Progress on the TSC’s Record-by-Record Review of the TSDB 

 In responding to our earlier audit, TSC officials reported that they 

planned to conduct a record-by-record review of all records within the TSDB. 

In February 2006, TSC officials estimated that this review would not be 

complete until 2012. At the time of our current audit, the record-by-record 

review was ongoing through the three-pronged strategy of the NDIU – the 

single review queue, encounter-driven quality assurance reviews, and 

special projects. TSC officials told us that they plan to examine the TSDB 

following the completion of the on-going special projects and determine how 

many TSDB records have not yet been reviewed. The TSC then plans to 

review any previously unexamined records in an effort to examine the entire 

TSDB. 

 In February 2007, TSC officials told us that since the inception of the 

single review queue in March 2006 over 670,000 TSDB records had been 

reviewed and the agency had revised its estimated completion date. TSC 

officials now project that the record-by-record review will be complete by the 

end of 2007. 

 Yet, we believe that the TSC may have overstated the number of 

records reviewed and is underestimating the amount of time and effort that 

it will take to complete its review of the entire TSDB. We base these 

conclusions on the following factors: 

• As previously discussed, the TSC’s single review queue and 

encounter-driven quality assurance processes do not sufficiently 

ensure the quality of the watchlist records. Therefore, the TSC 

should reconsider records examined in these processes in its 

count of records reviewed. 

• The number of records reviewed is not limited to the review of 

unique records. Rather, the TSC’s quality assurance process 

allows for one record to be reviewed multiple times: through the 

single review queue, following each request to modify or delete 

the record, in accordance with one or more special projects, and 

subsequent to each encounter. Therefore, we believe that the 

TSC’s cumulative tally of records reviewed can include records 

counted multiple times. 

• Between September 2006 and April 2007, the TSDB grew at an 

average rate of over 20,000 records per month, or 

approximately 174,000 additional records during this 8-month 

period. This growth adds to the analysts’ workload. Since 

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April 2004, the TSDB has more than quadrupled in size, growing 

from 150,000 to 724,442 records in April 2007. 

• In February 2007, there were about 3,000 open quality 

assurance matters that required follow-up. 

We believe that, if the number of records in the TSDB continues to 

grow at the current rate and the number of quality assurance matters 

similarly increases, the NDIU will not complete the record-by-record review 

of the TSDB by the end of 2007 as anticipated. We recommend that the TSC 

accurately determine the magnitude of the unexamined portion of the TSDB 

so that agency officials can implement a sound plan for examining those 

records and develop a realistic completion date for the endeavor. Further, 

the TSC should establish benchmarks against which it can measure its 

progress. 

TSC Efforts to Enhance Terrorist Watchlisting 

Although we identified several actions that the TSC should take to help 

improve the accuracy and completeness of watchlist records, our audit also 

revealed a recent TSC initiative that we believe is a noteworthy practice for 

enhancing watchlist records. Specifically, we noted that the TSC runs a 

report each week of NCIC hits in VGTOF and compares these hits to positive 

encounters in its Encounter Management Application (EMA) database to 

determine if each hit was called into the TSC Call Center. Performing this 

review offers the TSC an opportunity to educate local law enforcement 

officers about the importance of the TSC mission and determine if there 

have been additional known or suspected terrorist encounters of which the 

TSC was previously unaware. If the encountered individual was a positive 

identity match to a terrorist watchlist record, then any new information 

obtained during the encounter should be added into the TSDB record to 

enrich the record and provide added value to the intelligence community. 

TSC officials stated that currently they are identifying an average of 40 to 

70 encounters each week that are not being called into the TSC. When the 

TSC identifies a hit that was not called into the call center, this information is 

relayed to the FBI. In turn, the local FBI field office is asked to follow up 

with the local law enforcement agency that ran the NCIC check. The FBI 

field office sends an agent to the local, state, or tribal law enforcement 

agency to obtain any information about the encounter and to remind the law 

enforcement agency that they should call all NCIC hits for known or 

suspected terrorists into the TSC Call Center. 

We believe this practice can provide useful information for enriching 

the watchlist records. However, we noted that although the NCIC hit report 

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is run on a weekly basis, it is taking an additional 2 weeks to notify the FBI 

of these encounters. Our concern with the 2-week time lag is that some 

local, state, and tribal law enforcement personnel will not remember clearly 

the encounter by the time they are contacted by the FBI, which can result in 

a missed opportunity to obtain new information. TSC officials told us that 

they are working with the FBI to expedite this process. 

We were also told that other law enforcement agencies do not always 

follow up with the TSC to inform them about any newly obtained encounter 

information. Considering that approximately 60 percent of the encounters 

are identified by the CBP, the TSC should explore methods for performing 

similar enrichment exercises related to other screening agency encounters. 

Conclusion 

The TSC has made significant strides in its quality assurance efforts 

since our last review, including the creation of the NDIU and the 

development of new quality assurance processes. In addition, the TSC’s 

goal to perform quality assurance testing of all new and historical records in 

the TSDB is a positive step. However, we believe that more needs to be 

done to ensure the accuracy of the watchlist records. 

The number of quality assurance matters identified by the TSC 

increased from about 2,500 in November 2006 to over 20,000 in 

March 2007, with the number of unresolved matters increasing from 177 to 

2,514 during this period. Additionally, the overall size of the consolidated 

terrorist watchlist has quadrupled in size since the TSC’s inception, 

increasing from about 150,000 records in April 2004 to over 700,000 as of 

April 2007. This growth further adds to the amount of work for the TSC 

quality assurance staff to ensure the quality of the records in the 

consolidated watchlist database. 

Our review found that the TSC has not developed a detailed plan of 

action and benchmarks or milestones to accomplish its goal of reviewing 

every record in the watchlist database. Additionally, we found errors in 

records that had undergone routine TSC quality assurance reviews, but a 

higher quality for watchlist records examined in TSC special project 

reviews. 

We also found that the TSC’s SOP for quality assurance matters did 

not provide sufficient guidance for analysts to use in performing their 

examinations of watchlist records. Further, the TSC’s oversight and internal 

controls over the quality assurance process did not detect the continued 

existence of significant record errors and omissions. Finally, we believe the 

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TSC is hampered by the lack of agreements with the nominating and 

screening agencies. Such agreements could improve the timeliness for 

resolving quality assurance matters and help ensure that additional 

information is obtained during encounters with known or suspected 

terrorists. 

Without a standardized process, adequate internal controls, and 

agreements with source and watchlist agencies, watchlist records may 

remain inaccurate and incomplete for an unnecessary amount of time. 

Before the records are corrected or updated, law enforcement agencies may 

encounter watchlisted individuals. Additionally, inaccurate records can cause 

screeners to unnecessarily delay or detain individuals misidentified as a 

known or suspected terrorist. 

Recommendations 

We recommend that the TSC: 

7. Correct the records identified by the OIG containing incorrect 

watchlist designations, handling code errors, and inaccurate and 

inconsistent information. 

8. Coordinate with NCTC and the FBI to implement an agreement that 

establishes the areas of responsibility and the timeframes for data 

quality assurance matters. 

9. Develop a comprehensive standard operating procedure that 

describes the TSC’s three-pronged quality assurance strategy and 

details the methodology to be used in performing quality assurance 

reviews. 

10. Develop a process to perform regular spot-checks of NDIU analysts’ 

work to identify any weaknesses and need for additional training. 

11. Develop an improved and user-friendly process for tracking classified 

correspondence related to quality assurance matters. 

12. Develop a tickler system or digital dashboard for all pending quality 

assurance matters. 

13. Develop a comprehensive plan, including benchmarks or milestones, 

to complete the record-by-record review of the TSDB. 

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14. Coordinate with other partner agencies to establish a formal process 

for relevant encounter information to be captured by frontline 

screening agents and returned to the TSC to update watchlist records. 

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III. TERRORIST WATCHLIST REDRESS 

The TSC has developed comprehensive procedures, has 

dedicated staff, and coordinates with partner agencies to help 

ensure that it effectively and efficiently processes complaints 

from individuals experiencing delays or difficulties due to 

terrorist watchlist screening. Our review found that the TSC was 

following its procedures and reaching appropriate resolutions in 

such redress reviews. TSC redress disposition data indicated 

that nearly half of the total closed redress reviews resulted in a 

modification to or removal of a terrorist watchlist record. We 

believe that the TSC’s redress review results provide a further 

indicator that watchlist data needs continuous monitoring and 

attention. 

We also found that there are excessive delays in closing redress 

matters. Additionally, we believe that the TSC should use 

information related to terrorist watchlist identities that are 

frequently the subject of watchlist encounters to proactively 

initiate redress reviews before complaints are filed.

Overview of the TSC’s Redress Efforts 

Persons stopped as a result of watchlist matches may be actual 

watchlist subjects, individuals misidentified to a terrorist identity, or 

someone mistakenly included on the watchlist. As a result of the terrorist 

watchlist screening process, individuals may complain that they were 

adversely affected and seek relief. Individual government agencies involved 

in terrorist watchlist screening should have a redress process to effectively 

resolve the complaint and respond to the complainant. Similarly, the TSC 

should have reasonable procedures to provide redress for individuals from 

faulty watchlist identifications. 

 

When we initiated our first TSC audit in 2004, the TSC did not have an 

established process for handling inquiries related to private individuals who 

sought watchlist information following their involvement in a screening 

encounter. In January 2005 the TSC assigned staff to address terrorist 

watchlist screening complaints and began to develop a strategy for redress 

matters. In our previous audit report, we recommended that the TSC 

develop formal procedures for handling redress inquiries. In response, the 

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TSC formalized its process by implementing an official Redress SOP in 

July 2005 and a revised version in May 2007.57

In brief, individuals who believe they were unnecessarily and adversely 

affected by watchlist-related screening procedures may file a redress 

complaint with the agency involved in the event. For example, if an 

individual is prohibited from boarding a commercial airline flight, the person 

would contact the TSA to file a redress complaint. If the TSA determines 

that the event was related to terrorist watchlist screening, the complaint is 

forwarded to the TSC for review. Once the TSC has completed its 

examination, it makes any necessary changes to associated watchlist 

records and forwards its results back to the TSA, which provides feedback to 

the complainant. 

In November 2005, the TSC created a separate Redress Office to 

process redress matters. As of April 2007, the TSC Redress Office was 

managed by the Redress Officer and supported by four analysts and one 

management assistant. TSC officials said they plan to expand the Redress 

Office to seven analysts.58 The analysts in this office are responsible for 

reviewing redress inquiries, corresponding with partner agencies for 

clarification or additional information, and recommending to the Redress 

Officer how to dispose of an inquiry. The Redress Officer is responsible for 

supervising the analysts, reviewing each redress evaluation, facilitating 

coordination with other agencies, and finalizing the disposition of the redress 

inquiry. 

We believe the TSC has taken a number of other positive steps to 

address redress matters since our prior audit. For example, the TSC helped 

to spearhead the creation of a multi-agency agreement addressing watchlist 

redress. In addition, the TSC has enhanced its own procedures for handling 

redress matters. 

However, in this audit we identified areas in need of continued 

improvement and further development, such as the timeliness of redress 

 57 The TSC’s revised May 2007 Redress SOP includes more detailed guidance and 

reflects changes within the TSC, such as technology improvements, organization structure, 

and staffing. The revised Redress SOP also expanded TSC redress disposition categories 

and provided more detailed instructions on its redress processing as well as the 

incorporation of new technology and terminology. 

58 As of April 2007, the TSC allocated six analyst positions to its Redress Office, of 

which four positions were filled. The TSC reported that it expected to add an additional 

analyst position for a total of seven. 

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matter resolution and utilizing encounter information to provide redress 

without a complaint being submitted. These issues are discussed below. 

Multi-agency Redress Agreement 

 In December 2006, a multi-agency agreement entitled Memorandum 

of Understanding on Terrorist Watchlist Redress Procedures (Redress MOU) 

was developed by a working group of representatives from the various 

agencies involved in terrorist watchlisting and screening. Representatives 

from the Privacy and Civil Liberties Oversight Board of the Executive Office 

of the President were also included in the development of the MOU.59 As of 

April 2007, the Redress MOU was being circulated for signature by the heads 

of the TSC, DOJ, DHS, State Department, the Office of the Director of 

National Intelligence (ODNI), the FBI, the Central Intelligence Agency (CIA), 

NCTC, the Department of Defense (DOD), and the Department of the 

Treasury.60 

The Redress MOU formalizes the responsibilities of each agency in 

adjudicating redress inquiries. The agreement requires each agency to 

assign redress responsibilities to a senior official and commit necessary 

resources to ensure the efficiency of the redress process and compliance 

with the Redress MOU. The Redress MOU notes that the TSC has ultimate 

authority on redress decisions related to the terrorist watchlist.61 

Overview of the Terrorist Watchlist Redress Process 

On February 20, 2007, DHS and the State Department implemented 

the Traveler Redress Inquiry Program (TRIP). This program established a 

centralized portal for persons to file complaints regarding difficulties 

experienced at screening points during travel, such as airports, train 

stations, and border crossings. DHS headquarters officials informed us that 

TRIP will also help coordinate the resolution of complaints, monitor trends in 

complaints, and measure redress process efficiencies. 

Exhibit 4-1 shows a basic illustration of the U.S. government’s process 

for addressing redress inquiries related to the terrorist watchlist. 

 59 The Privacy and Civil Liberties Oversight Board advises the President and other 

senior executive branch officials on matters with respect to privacy and civil liberties. 

60 The TSC reported that as of April 18, 2007, all agencies had signed the 

agreement except the DOD, the CIA, and the State Department. 

61 The TSA makes final decisions on No Fly list redress appeal matters. 

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EXHIBIT 4-1 

Flowchart of Terrorist Watchlist Redress Process 

Frontline screening

agency receives complaint

TRIP

(DHS and State Department)

FBI

Screening agency

determines if

complaint is related

to a terrorist

watchlist encounter

Resolve at

screening

agency

Related to

watchlist

Not related

to watchlist

TSC

receives

redress

referral

TSC Redress Office

determines factors

related to

terrorist watchlist

Positive match

to terrorist

watchlist identity

Not related

to the terrorist

watchlist

Misidentification

to terrorist

watchlist identity

TSC Redress Office

reviews related

watchlist record(s)

& resolves complaint

Screening agency

responds to

complainant

TSC revises

watchlist

record(s) as

necessary

TSC REDRESS PROCESS

Source: The Terrorist Screening Center 

Receipt of Redress Complaints 

Complainants file redress inquiries with the frontline screening 

agencies involved in the encounters, such as to the FBI or through TRIP for 

DHS and the State Department.62 As shown in Exhibit 4-1, the screening 

agency reviews the complaint and determines if the inquiry relates to a 

possible terrorist watchlist match. 

 62 The FBI is typically not the agency encountering the individual, but its NCIC system is 

used in the screening process. Therefore, the FBI is considered the screening agency in such 

instances. 

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Individuals can also be affected by screening protocols unrelated to 

the terrorist watchlist, such as through random search procedures or other 

security screening practices. Despite someone’s actual presence or nonpresence on the terrorist watchlist, individuals may assume they have been 

mistakenly included on the watchlist or misidentified to a terrorist watchlist 

identity and submit a complaint requesting relief. If the screening agency 

determines that the complaint is not related to the terrorist watchlist, it 

should resolve the matter internally and respond to the complainant. For 

example, an airline may deny a person from boarding an airplane because of 

drunkenness or disorderly behavior. Complaints related to these types of 

matters and others unrelated to the terrorist watchlist should not be referred 

to the TSC. 

However, the screening agency should refer to the TSC all redress 

inquiries determined to pertain to a possible watchlist match. From 

January 2005 through February 2007, the TSC received 438 such redress 

referrals. As illustrated in Exhibit 4-2, 96 percent of the redress inquiries 

referred to the TSC were forwarded by DHS components (CBP, TSA, 

Immigration and Customs Enforcement (ICE), and other DHS entities). The 

TSA referred nearly one-half of all redress inquiries received by the TSC. 

Non-DHS agencies referred a total of 19 redress matters, including the FBI 

(9 referrals), the State Department (3 referrals), state and local law 

enforcement agencies (6 referrals), and the Executive Office of the President 

(1 referral). 

EXHIBIT 4-2 

TSC Redress Referrals by Referring Agency 

(January 2005 through February 2007)

Other 

agencies

19 referrals

4%

DHS other

33 referrals

8%

ICE

85 referrals

19%

CBP

91 referrals

21%

TSA

210 referrals

48%

Source: The Terrorist Screening Center Redress Office 

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TSC Redress Process 

 When the TSC receives a redress complaint, the TSC Redress Office 

analyst assigned responsibility for resolving the complaint determines the 

relationship of the complainant to the terrorist watchlist and places the 

individual in one of the following three categories: (1) non-related, 

(2) positive match, and (3) misidentified. 

Non-related – The analyst may determine that the complainant does 

not match a terrorist watchlist identity and was not the subject of an 

encounter involving a potential match. Essentially, the inquiry should not 

have been referred to the TSC in the first place. In these cases, the TSC 

returns this matter to the appropriate screening agency for resolution. 

Positive Match – A complainant who matches an identity on the 

terrorist watchlist and was the subject of at least one watchlist-related 

encounter is considered a positive terrorist watchlist match. For positive 

match redress referrals, a Redress Office analyst conducts a complete review 

of the watchlist records to ensure information on the individual meets the 

criteria for watchlisting and is accurate, complete, and current. This review 

will also include contacting the nominating agency to obtain any new 

information on the individual not yet available to the TSC. 

After reviewing this information, the analyst recommends that a 

record: (1) remain unchanged, (2) be modified, or (3) be removed from the 

watchlist. If it is determined that the watchlist record is accurate, complete, 

and current, the analyst then recommends that no changes be made to the 

record or the watchlist status of the individual. 

For some redress inquiries, the analyst recommends a modification to 

the record. This could entail updating the record with new information or 

correcting errors in the record. Another recommended revision may include 

changing the watchlist status of an individual, such as removing a person 

from the Selectee list or escalating a person’s watchlist status from the 

Selectee list to the No Fly list. 

The last disposition scenario for a positive match record involves 

removing the identity record from the terrorist watchlist altogether. Based 

on a review of relevant and current information, the analyst may determine 

that an identity does not meet the criteria for inclusion on the terrorist 

watchlist. 

Misidentification – An individual who is the subject of a terroristrelated screening but whose identity is not on the terrorist watchlist is 

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considered to have been misidentified. Redress referrals for misidentified 

complainants are processed by the TSC similarly to positive match referrals. 

The Redress Office analyst assigned the inquiry reviews the terrorist 

watchlist record involved in the misidentification and ensures that the record 

is accurate, complete, and current. The analyst then recommends any 

necessary changes to the record or watchlist status. 

If, as a result of a redress review, the TSC recommends a change to 

the watchlist record or status (for either a positive match or misidentification 

referral), the Redress MOU and the TSC Redress SOP both require that the 

TSC discuss its findings with the nominating agencies. While the nominating 

agencies may provide input, the TSC has the ultimate authority to resolve all 

terrorist watchlist redress matters. Finally, the TSC Redress Office ensures 

that the necessary changes are made to watchlist records before closing its 

review and alerting the frontline screening agency of its resolution. The TSC 

does not respond to the complainant. Rather, the TSC coordinates with the 

frontline screening agency, which should submit a formal reply to the 

complainant. 

The TSC’s revised May 2007 Redress SOP includes an expansion of the 

redress disposition categories. The non-related category was expanded to 

capture two additional situations: (1) instances in which the TSC 

administratively closes its review because screening agencies do not comply 

with TSC redress requirements, and (2) occasions that a redress complaint 

was considered moot because the terrorist identity to which the redress 

inquiry refers was already removed from the watchlist through normal 

watchlist modification or quality assurance procedures. In addition, the TSC 

renamed its misidentification category to “near match.” Lastly, the TSC 

added one disposition category to use when the TSC Call Center incorrectly 

identified an individual as a positive watchlist match. The TSC believes its 

expansion of disposition categories will allow it the ability to better track its 

redress resolutions and to identify areas in the watchlist process that could 

be improved. For instance, the Redress Office could find that the TSC Call 

Center’s percentage of incorrect identifications has increased significantly 

and recommend that a thorough review be conducted. 

Disposition of Redress Complaints 

The TSC tracks its processing and disposition of redress inquiries in a 

TSC database. At the time of our review, the database included only those 

disposition categories used by the TSC prior to the revision of the TSC’s 

Redress SOP. The disposition for the 388 redress inquiries closed by the 

TSC between January 2005 and February 2007 is shown in Exhibit 4-3. 

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EXHIBIT 4-3 

TSC Redress Complaint Disposition 

(January 2005 through February 2007) 

Disposition Number of 

Complaints 

Percentage of 

Complaints 

Misidentification 52 13% 

Positive Match (no change) 136 35% 

Positive Match (remove record) 76 20% 

Positive Match (modify record) 97 25% 

Non-related 27 7% 

Total 388 100% 

Source: The Terrorist Screening Center Redress Office 

Misidentified Complainants 

TSC redress complaint disposition data show that 13 percent of the 

388 closed redress inquiries were for complainants who were misidentified to 

a terrorist identity and were not an actual watchlist subject.

According to the TSC, the most common cause of a misidentification is 

name similarity. As previously discussed, the watchlist is identity-based and 

relies on name searches in order to vet persons against the watchlist. This 

can result in a person with an identical or similar name being identified as a 

terrorist watchlist identity. In many instances the screening agency can use 

additional identifying information, such as a date of birth or a passport 

number, to eliminate the individual as a terrorist watchlist match.63

Positive Watchlist-Match Complainants 

Of the 388 redress complaints reviewed by the TSC between 

January 2005 and February 2007, 80 percent involved complainants who 

were on the terrorist watchlist. Through its redress review process, the TSC 

determined that watchlist records for 35 percent of the closed positive 

 63 Screening agencies have also developed programs to assist persons repeatedly 

misidentified to terrorist watchlist identities. For instance, an individual can voluntarily 

submit personal-identifying information to the TSA and request to be placed on the TSA 

Cleared List. If approved for placement on the Cleared List, the individual’s name and 

personal-identifying information can be used to more quickly determine that the individual 

is not on the No Fly or Selectee lists. Similarly, the CBP and the State Department have 

implemented procedures to annotate records of misidentified persons in their databases to 

help avoid future port-of-entry screening and visa application delays. These actions are 

particularly helpful for a non-watchlist individual with an exact or a very similar name match 

to a known or suspected terrorist. 

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watchlist-match redress complaints required no change, 25 percent required 

some modification to the watchlist records, and 20 percent necessitated 

removing the complainant’s identity from the watchlist. 

Therefore, the TSC determined through its review that 45 percent of 

the watchlist records related to redress complaints were inaccurate, 

incomplete, not current, or incorrectly included.64 TSC officials stated that, 

in some instances, at the same time that a nominating agency was going 

through the process of having an individual removed from the watchlist, that 

individual filed a redress complaint. In other instances, the TSC Redress 

Office found inaccuracies in the watchlist record or discovered additional, 

relevant information that had not been passed to the TSC. 

Specifically, in 76 redress reviews, the TSC determined that the 

individual should not be watchlisted. In an additional 97 instances, the TSC 

found that the watchlist record was inaccurate or incomplete. The TSC’s 

redress review results indicate that the watchlist includes individuals that 

should not be watchlisted and that other records contain deficiencies. These 

results are further evidence that watchlist data needs continuous monitoring 

and attention. 

At the time of our review, the TSC did not track whether a change to 

the watchlist record was the result of a TSC redress review or whether the 

change was coincidental to a concurrent nominating agency submission of 

information to update the watchlist record. The TSC believes its expanded 

disposition categories will better account for these scenarios and provide a 

more accurate picture of redress resolution. The TSC Privacy Officer 

acknowledged that the high percentage of records requiring modification or 

removal may point to deficiencies in the terrorist watchlist nomination 

process and with nominating agencies not providing the TSC additional 

information important to appropriately update terrorist records. 

Timeliness of Processing Redress Complaints 

 For each redress complaint it receives, the TSC develops a file folder 

and inputs information into a redress tracking database. The redress file 

contains information obtained, verified, and developed by the Redress Office. 

The file contains the Redress Office’s review of relevant databases, 

correspondence with partner agencies, rationale for the resolution of the 

complaint, and management review. 

 64 This 45 percent does not include the terrorist records that were modified or 

removed as part of a redress inquiry by a misidentified individual because the TSC did not 

specifically track those types of dispositions. 

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We judgmentally selected 20 redress inquiries the TSC received 

between January 2006 and February 2007 and reviewed the corresponding 

redress files to determine if the TSC followed its Redress SOP for resolving a 

redress complaint. We found the TSC complied with its Redress SOP in all 

20 cases, including reviewing the applicable screening and intelligence 

databases, coordinating with partner agencies, and reaching appropriate 

resolutions. 

We also reviewed TSC redress files and statistics to determine the 

efficiency of redress reviews. Our analysis of TSC data reveals that it took 

the TSC, on average, 67 days to close its review of a redress inquiry.65 For 

redress matters referred to the TSC during the last semiannual period in our 

review (July through December 2006), it took the TSC an average of 

57 days to finalize its review. 

In addition to closed matters, we also analyzed the number of days 

that pending TSC redress matters had been open. The TSC had a total of 

50 open redress inquiries as of February 27, 2007 and the average number 

of days these matters were open was 61. Of these inquiries, 38 percent 

were open over 60 days, including 2 inquiries that were pending over 

180 days. Exhibit 4-4 details the number of days the 50 redress matters 

were open as of February 27, 2007. 

EXHIBIT 4-4 

Open TSC Redress Matters 

(as of February 27, 2007) 

Number of Days Open Number of 

Open Redress Matters

Percentage of Total 

Open Redress Matters

180 days or more 2 4% 

90-179 days 12 24% 

60-89 days 5 10% 

30-59 days 11 22% 

less than 30 days 20 40% 

Total 50 100% 

Source: The Terrorist Screening Center Redress Office 

Our analysis of closed and open redress matters indicates that it takes, 

on average, about 2 months for the TSC to finalize its review of a redress 

inquiry. TSC redress files included copies of e-mails and records of 

discussion between the TSC Redress Office and nominating agency 

personnel, as well as an accounting of other significant actions taken by TSC 

 65 Redress matters pending as of February 27, 2007, were not included in our 

analysis of closed redress matters. 

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analysts to resolve the inquiry. TSC officials stated that each redress review 

is unique and that more complex cases require a longer review period. 

Our review of TSC redress files revealed that long review periods were 

caused by a variety of factors. In some instances, the TSC took a significant 

amount of time to finalize its determination before coordinating with other 

agencies for additional information or comment. A TSC official involved in 

redress also stated that the Redress Office staffing level sometimes affected 

the TSC’s ability to reach timely determinations. At times, the Redress 

Office used staff from other TSC units on a collateral, part-time basis. These 

persons would process redress matters when not performing their primary 

responsibilities and as time permitted. However, the TSC determined that 

this collateral assignment method did not provide the most efficient or 

effective means of resolving redress matters and, as a result, stopped this 

practice as of April 2007. 

Other lengthy redress reviews were affected by nominating agencies 

not providing timely feedback to the TSC or not efficiently processing 

watchlist paperwork. The coordination TSC conducts with nominating 

agencies on redress matters includes corresponding with subject matter 

experts and case agents for clarification or updated information, requesting 

necessary watchlist processing documents (such as the FBI’s terrorist 

watchlist nomination and modification form), and resolving differences of 

opinion between the TSC and nominating agency. For two redress matters, 

we found that the TSC repeatedly requested the FBI to file necessary 

paperwork in order to modify the watchlist records, and that it was finally 

able to close the matters over 140 days after its original requests. Further, 

we reviewed another redress file showing the FBI closed a preliminary 

investigation on an individual in November 2005. However, it did not notify 

the TSC that it determined the individual had no nexus to terrorism and 

should be removed from the watchlist. The TSC’s redress review finally 

effected the overdue removal of this individual from the watchlist in 

January 2006. 

Additionally, our file review found that certain screening agencies were 

slow to update their databases with accurate and current information. For 

instance, the State Department and the CBP did not revise encounter 

records in the IBIS database in a timely fashion to reflect modified or 

removed terrorist identities. For example, in one case the CBP did not make 

a TSC-requested change for more than 130 days. 

TSC officials noted that no response timeframes have been established 

with partner agencies for redress matters. The Redress MOU states that one 

of the goals of the redress process is to provide for a timely review, but 

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explicit timeframes are not defined. We believe that timeliness measures 

should be established for resolving terrorist watchlist redress complaints and 

responding to complainants. The TSC Privacy Officer stated a next step in 

improving terrorist watchlist-related redress coordination among 

government agencies is to negotiate timeframes for redress processing. 

Given the TSC’s responsibility for the content of the consolidated terrorist 

watchlist and its role in developing the Redress MOU, we recommend that 

the TSC attempt to coordinate timeliness measures for the entire watchlist 

redress process. 

Response to Redress Complainants 

The TSC does not respond to complainants filing redress inquiries. 

Instead, the TSC notifies the frontline screening agency of its disposition 

decision as it relates to the terrorist watchlist. The frontline screening 

agency involved in the watchlist-related encounter prompting the complaint 

is responsible for responding to the complainant. TSC policy dictates that 

responses to complainants neither confirm nor deny the existence of 

watchlist records relating to the complainant. This nondisclosure policy 

exists to protect U.S. counterterrorism operations and intelligence objectives 

and to safeguard the personnel involved in these sensitive activities. The 

TSC works with screening agencies such as the TSA in developing 

appropriate language for responding to complainants. 

While the FBI is not the user of the NCIC database during a terrorist 

watchlist-related encounter involving a state or local law enforcement 

officer, it is the de facto screening agency in instances involving its NCIC 

database, and therefore responsible for responding to redress complaints 

concerning its database.66 In May 2007, the FBI implemented a watchlist 

redress policy, identifying its Terrorist Review and Examination Unit (TREX) 

as responsible for processing the FBI’s review of redress matters and for 

responding to complainants for NCIC-related complaints.67 However, before 

it developed this policy, the FBI had not decided how it would respond to 

complainants, and we found that as of June 2007 it had not responded to a 

 66 A typical NCIC-related encounter involves a state or local law enforcement officer 

conducting a routine traffic stop. The officer searches the subject’s identification 

information (full name and date of birth) through the NCIC system to check for any 

outstanding warrants on the person. In the event the person is a possible terrorist watchlist 

identity match, the NCIC system will instruct the officer to contact the TSC to confirm the 

identity of the individual as an actual watchlist subject and to be instructed on the proper 

handling procedures for this individual. 

67 As stated earlier, only 4 percent of the redress referrals provided to the TSC from 

January 2005 through February 2007 were from non-DHS components such as the FBI. 

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redress complainant on a matter the TSC had closed on February 13, 2007, 

and had forwarded to the FBI for action. 

Appeal of Redress Disposition 

If a complainant is not satisfied with the disposition of an initial 

redress inquiry, the complainant may file an administrative appeal where 

available by the screening agency. The Redress MOU outlines the 

responsibilities for each agency in processing an administrative appeal of an 

original redress inquiry determination. Additionally, the TSC adopted a 

separate Redress Appeals SOP in November 2006 to expressly describe its 

administration of an appealed redress decision. The TSA is the only frontline 

screening agency that has developed its own process for redress appeals. 

The TSC Redress Appeals SOP stipulates that a complete analysis of 

the appeal be performed by the TSC Legal Department, a unit separate from 

the Redress Office. The TSC prohibits the TSC Redress Office and any 

personnel involved in the original redress review from direct involvement in 

the redress appeal process. According to the SOP, the TSC will alert NCTC 

and the nominating agency that an appeal has been submitted, and it will 

facilitate necessary communication between the nominating and screening 

agencies. The final recommendation or decision is determined by the TSC 

Redress Appeals Board, comprised of TSC Deputy Directors. For an appeal 

involving a No Fly watchlist status, the TSC recommends a disposition and 

the TSA has the final decision authority. 

As of May 1, 2007, the TSC had received four redress appeals. It 

resolved two appeals, and these resulted in downgrading the watchlist status 

of the individuals. The remaining two appeals had been pending resolution 

for 83 and 167 days, according to the TSC. The TSC stated that staffing 

constraints hindered its ability to more quickly resolve these redress 

appeals. The TSC informed us that in April 2007 it was able to assign 

redress appeal duties to a permanent staff position and the TSC believes 

that this action will improve the TSC’s timeliness in resolving redress 

appeals. 

Proactive Redress 

It is possible for the TSC and other watchlist agencies to use available 

information to provide unsolicited relief to non-watchlist persons identified 

by the terrorist watchlist process. Besides its standard redress reviews, the 

TSC Redress Office also conducted ancillary evaluations of persons reported 

to have been identified by terrorist watchlist screening who had not filed a 

formal complaint. Additionally, the U.S. government, including the TSC and 

screening agencies, has information on persons misidentified as a terrorist 

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watchlist subject in the various screening databases. However, the 

U.S. government, including the TSC, is not currently coordinating the use of 

this data in attempts to proactively reduce the incidence and impact of 

misidentifying persons as watchlist subjects. 

TSC Informal Redress Reviews 

Typically, the TSC undertakes a redress review only when an individual 

submits a formal redress request. Occasionally, however, the TSC Redress 

Office reviews records outside this formal process. The TSC may be asked 

by a government official to look into a matter or it may acquire from a news 

media publication the name of a person possibly stopped due to the terrorist 

watchlist. For instance, a newspaper may publish an article explaining that 

a foreigner was not allowed to board a flight destined for the United States 

and the TSC Redress Office believes that the TSC should research the 

events. In such a case, the TSC Redress Office performs an evaluation 

similar to its formal redress review for such matters. First, it determines if 

the person was the subject of a terrorist watchlist-related encounter. If so, 

it reviews the related watchlist record for accuracy and completeness, 

making changes and updates as necessary. 

The TSC Redress Office maintains a log that records the intake and 

resolution of these proactive reviews. Our review of this log shows that 

since this initiative began in December 2005, the TSC had resolved 76 cases 

through March 1, 2007, tracking them according to its redress disposition 

categories. Exhibit 4-5 shows that over 80 percent of these reviews 

involved an individual who experienced a watchlist-related encounter 

(misidentification and positive-match categories). Of the 32 positive 

matches, terrorist records were modified or removed from the watchlist for 

16 of the reviews. 

EXHIBIT 4-5 

TSC Informal Redress Reviews 

(December 2005 through March 1, 2007) 

Disposition Category Number Percent 

Misidentification 32 42% 

Positive Match 32 42% 

Non-related 10 13% 

Further Investigation68 2 3% 

Total 76 100% 

Source: The Terrorist Screening Center Redress Office 

 68 Two of the TSC Redress Office’s informal reviews required further investigation in 

order to determine the relationship of the individual to a watchlist identity. 

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Use of Watchlist Encounter Information for Misidentified Individuals 

The TSC has a record of all potential terrorist watchlist encounters 

referred to its call center, including information on positive, negative, and 

inconclusive encounters.69 Therefore, the TSC has knowledge of the 

watchlist records involved in the negative encounters referred to its call 

center, as well as information on the individual that was misidentified as a 

potential terrorist for a period of time. 

The TSC does not have any policy or procedures to proactively use 

information from negative encounters to reduce the incidence and impact of 

terrorist watchlist misidentifications. Moreover, the TSC’s strategic plan 

does not include goals or actions associated with reducing the incidence of 

misidentifications or the impact on misidentified persons, other than that 

covered by the formal redress process. Considering that 43 percent of all 

encounters referred to the TSC Call Center are negative for a watchlist 

match, we believe the TSC should develop strategic goals and policy specific 

to mitigating the adverse impact of the terrorist screening process on nonwatchlist subjects, particularly for individuals who are repeatedly 

misidentified as potential watchlist subjects. 

Additionally, we believe the TSC should consider developing the ability 

within its encounter tracking system or consolidated watchlist database to 

alert the TSC to take proactive action on watchlist records that have been 

the subject of a certain number of encounters. For example, the system 

could be programmed to automatically generate a quality assurance lead for 

the TSC to perform a comprehensive review of the terrorist record. Such a 

function would help certify that a watchlist record frequently the subject of 

encounters, whether the encounters are positive, negative, or inconclusive, 

is accurate, complete, and current. This is important for both appropriately 

handling suspected or known terrorists and for reducing the adverse effects 

on persons misidentified as watchlist subjects. 

Conclusion 

Screening agencies across the federal government are in the process 

of instituting an interagency agreement that will formalize the 

U.S. government’s review of redress inquiries from individuals who complain 

they were adversely affected during watchlist screening. Additionally, the 

 

69 Not all potential watchlist matches are referred to the TSC. If possible, screening 

agencies resolve negative encounters without contacting the TSC by comparing information 

on the encountered individual to the potential terrorist watchlist identity match. Screening 

agencies contact the TSC Call Center on all encounters where it cannot definitively make this 

determination. 

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TSC has developed its own SOP for processing redress complaints. We 

found that the TSC generally followed these procedures, the procedures are 

comprehensive, and TSC staff resolved redress matters logically and 

accurately. 

However, our examination of TSC redress files also revealed that the 

TSC’s comprehensive redress reviews often resulted in watchlist record 

changes and removals. We believe that the high percentage of redress 

reviews resulting in changes to or removals of watchlist records provides 

further evidence that watchlist data needs continuous monitoring and 

attention. 

Our review also revealed that watchlist agencies, including the TSC 

and nominating and screening agencies, sometimes caused unnecessary 

delays in closing redress inquiry reviews. We recommend that the TSC 

coordinate efforts for the watchlist agencies to develop timeliness measures 

for each stage in the redress process. 

Recommendations 

We recommend that the TSC: 

15. Organize a working group comprised of representatives from agencies 

involved in the terrorist watchlist redress process to develop 

timeliness measures for each phase in the redress process. 

16. Develop goals and measures for its strategic plan to reduce the 

incidence and impact of misidentifications. 

17. Develop procedures to proactively review terrorist watchlist identities 

that are frequently the subject of watchlist encounters, no matter if 

the encounter was positive, negative, or inconclusive. 

We recommend that the FBI: 

18. Develop and implement timeliness measures to ensure that the FBI 

responds in a timely manner to redress inquiries from complainants 

subject to terrorist watchlist-related encounters involving the NCIC 

database, including the complainant identified by the OIG whose 

complaint has been pending since February 2007. 

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STATEMENT ON INTERNAL CONTROLS 

 

 In planning and performing our audit of the TSC, we considered its 

control structure for the purpose of determining our audit procedures. This 

evaluation was not made for the purpose of providing assurance on the TSC 

management control structure as a whole. However, we noted certain 

matters involving management controls that we considered to be reportable 

conditions under the Government Auditing Standards. 

 Reportable conditions involve matters coming to our attention relating 

to significant deficiencies in the design or operations of the management 

control structure that, in our judgment, could adversely affect the TSC’s 

ability to maintain and disseminate accurate and complete information on 

known or suspected terrorists used during watchlist screening. We identified 

weaknesses in the TSC’s internal control structure that resulted in inaccurate 

and incomplete watchlist records and terrorist identities not being correctly 

exported to downstream watchlist databases. These issues are discussed in 

Findings I, II, and III of the report. 

 Because we are not expressing an opinion on the TSC’s management 

control structure as a whole, this statement is intended solely for the 

information and use of the TSC management. This restriction is not 

intended to limit the distribution of the report. 

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STATEMENT ON COMPLIANCE WITH LAWS AND 

REGULATIONS 

In connection with this audit of the TSC, as required by generally 

accepted government auditing standards, we reviewed management 

processes and records to obtain reasonable assurance about the 

organization’s compliance with laws and regulations that, if not complied 

with, in our judgment, could have a material effect on TSC operations. 

Compliance with laws and regulations applicable to the management of the 

TSC is the responsibility of the TSC’s management. 

 Our audit included examining, on a test basis, evidence about laws and 

regulations related to the maintenance and sharing of information on 

suspected or known terrorists. The specific laws and regulations we 

reviewed included the relevant portions of: 

• Intelligence Authorization Act, Public Law 108-177; 

• Homeland Security Presidential Directive 6; and 

• Homeland Security Presidential Directive 11. 

Our tests of the consolidated terrorist watchlist identified weaknesses 

related to the accuracy and completeness of the data which is discussed fully 

in Findings I, II, and III. The requirements for an accurate and complete 

watchlist are contained in HSPD 6. 

With respect to areas that were not tested, nothing came to our 

attention that caused us to believe that the TSC management was not in 

compliance with the laws and regulations cited above. 

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APPENDIX I 

APPENDIX I: OBJECTIVES, SCOPE, AND METHODOLOGY 

Audit Objectives

The objectives of the audit were to: (1) determine whether accurate 

and complete records are disseminated to and from the Terrorist Screening 

Center’s (TSC) watchlist database in a timely fashion; (2) review the TSC’s 

efforts to ensure the quality of the information in the watchlist database; 

and (3) assess the TSC’s efforts to address complaints raised by individuals 

who believe they have been incorrectly identified as watchlist subjects. 

Scope and Methodology

We performed our audit in accordance with Government Auditing 

Standards issued by the Comptroller General of the United States, and 

accordingly, included such tests of the records and procedures that we 

considered necessary. Our audit covered but was not limited to the period 

of June 2005 through April 2007. 

To accomplish our objectives, we conducted work primarily at the TSC, 

located in the Washington, D.C., metropolitan area. Additionally, we 

interviewed personnel at other federal agencies and offices whose work 

relates to TSC operations, such as NCTC, the FBI, DHS, and the White House 

Privacy and Civil Liberties Oversight Board. 

 

 To obtain an overall understanding of the TSC’s role and 

responsibilities, we reviewed legislative materials related to the TSC’s 

creation and watchlisting requirements, prior audit reports, and various 

other documents as needed, including financial documents, strategic plans, 

and staffing reports. 

Accuracy and Completeness of Database Records 

 To obtain an understanding of the TSC’s processes and procedures for 

ensuring the quality of data ingested into and exported from the Terrorist 

Screening Database (TSDB), we reviewed the TSC’s procedures for 

processing database nominations and encounters. In addition, we 

interviewed: 

• Contractors and representatives from the various participating 

Departments working within the TSC’s Administration Branch, 

Operations Branch, Information Technology Branch, Call Center, 

Nominations and Data Integrity Unit, and other support areas. 

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APPENDIX I 

• Program managers at NCTC. 

• Supervisors from the FBI’s Terrorist Threat Center, Terrorist 

Review and Examination Unit, and Terrorist Screening Operations 

Unit. 

• The Executive Assistant Director of the FBI’s National Security 

Branch and the Assistant Director and Deputy Assistant Director of 

its Counterterrorism Division. 

Testing of Watchlist Database Records 

As of March 16, 2007, there were 689,613 records in the web-based 

version of the TSDB. We performed various tests of a limited number of 

these records, and reviewed related records from the pertinent automated 

data systems used to store terrorist-related information maintained by the 

NCTC and FBI, to determine whether the records were accurate and 

complete, and any record changes were made in a timely fashion. The 

automated data systems were the TSDB, TSC’s Encounter Management 

Application (EMA), NCTC’s Terrorist Identities Datamart Environment (TIDE), 

and the FBI’s Violent Gang and Terrorist Organization File (VGTOF). 

In addition to querying the TSDB to identify duplicate records and 

determining whether records related to 20 FBI requests for removal had 

been deleted from the TSDB in a timely manner, our tests of judgmentally 

selected records included: 

• Review of 50 TSDB records related to 25 FBI international terrorist 

and 25 FBI domestic terrorist nominations to determine whether 

basic identifying information [SENSITIVE INFORMATION 

REDACTED] listed on the FD-930 (the form used by the FBI for 

watchlisting nominations) were accurately entered into the 

databases. In addition, we analyzed key dates shown on the 

FD-930s to determine whether the names and other information 

were entered into the TSDB in a timely fashion. 

• Review of a sample of 49 known terrorist names to determine 

whether the basic identifying information as well as citizenship and 

physical characteristics were accurately entered into the databases. 

Of these names, 10 were non-FBI originated international terrorist 

identities in the TIDE database, 17 were selected from the FBI’s 

Most Wanted Terrorists list, 2 were selected from the Rewards For 

Justice website, 16 came from the State Department’s Office of 

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APPENDIX I 

Counter Terrorism, and 4 were obtained from various newspaper 

articles. 

• Review of 51 TSDB records for which TSC staff had identified as 

having quality assurance issues, such as missing, outdated, or 

inaccurate information.70 This review included identifying the 

quality assurance issue that was raised, determining whether the 

appropriate changes had been made to the TSDB, TIDE, and VGTOF 

records. In addition, we evaluated the timeliness of the revision 

and any additional follow-up performed by TSC staff to ensure that 

the necessary changes were made. Finally, we reviewed these 

records to determine whether the basic identifying information was 

accurately entered into the databases. 

• Review of 20 TSDB records related to positive encounters with 

watchlist subjects, as recorded in EMA, to determine whether the 

basic identifying information was accurately entered into the 

databases and information obtained by law enforcement agencies 

as a result of the encounters was added to appropriate database 

records. 

• Review of 15 TSDB records that TSC staff identified as having 

undergone a thorough quality assurance review as part of a special 

project to evaluate the adequacy of the TSC’s review and to 

determine whether the basic identifying information was accurately 

entered into the databases. 

Finally, we compared information in the TSDB records to watchlisting 

criteria to determine whether the individuals were nominated for the 

appropriate watchlists and were assigned an appropriate handling 

instruction.71 

Watchlist Redress

To obtain an understanding of the TSC’s role in the terrorist watchlist 

redress process and its efforts to reduce watchlist misidentifications, we 

reviewed the TSC’s redress procedures and the U.S. government’s 

 70 25 of the 51 records were selected from the TSC’s Quality Assurance Tracker, the 

TSC’s original system for monitoring TSDB records with quality assurance issues. The 

remaining 26 records were selected from quality assurance tickets, the TSC’s current 

monitoring system. 

71 The criteria used by the agencies hosting TSDB records are identified in 

Appendix II. 

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APPENDIX I 

interagency agreement on terrorist watchlist redress. We judgmentally 

selected and examined 20 redress complaints reviewed by the TSC Redress 

Office to evaluate whether the TSC followed its Redress SOP for resolving a 

redress complaint. 

We also conducted interviews with the TSC’s Privacy and Redress 

Officers, and we reviewed the TSC’s strategic plan to identify any goals 

related to redress or reducing the incidence and effect of watchlist 

misidentification. Additionally, to obtain an understanding of the partner 

agencies’ roles in the redress process and how they coordinate with the TSC, 

we interviewed representatives from the White House Privacy and Civil 

Liberties Oversight Board, the DHS’s Screening Coordination Office, TSA, 

and CBP. 

From January 2005 through February 2007, 438 redress complaints 

were referred to the TSC. During this same period, the TSC closed 

388 complaints. We performed various analyses of TSC’s redress referral 

data, including calculating: 

• the percent of cases referred to the TSC according to referring 

agency;

 

• the average amount of time cases were open, and evaluating the 

reasons affecting delays in closing the matters; and 

• the TSC’s disposition for its closed redress matters. 

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APPENDIX II 

APPENDIX II: SYSTEMS USED IN THE TERRORIST WATCHLIST 

PROCESS 

The Terrorist Screening Database (TSDB) is the U.S. Government's 

consolidated terrorist watchlist. The TSDB contains basic biographical 

information on known or appropriately suspected domestic and international 

terrorists. In this regard, the underlying derogatory information on individuals 

nominated for inclusion in the TSDB must demonstrate a reasonable suspicion of 

ties to terrorism. 

Currently, TSDB records are exported to various U.S. and international 

government entities tasked with conducting terrorism screening. Each agency 

receiving TSDB records has established criteria that dictate what records it 

receives from the TSC. The TSC provided us with the following descriptions of 

the databases receiving watchlist records and the minimum criteria for exporting 

records to them: 

CLASS 

The Consular Lookout and Support System (CLASS) is maintained by the 

Department of State (State Department). CLASS, divided into CLASS/Visa and 

CLASS/Passport, is used by State Department representatives when processing 

visa and passport applications, respectively. 

[SENSITIVE INFORMATION REDACTED] 

IBIS 

The Interagency Border Inspection System (IBIS) is maintained by DHS’s 

U.S. Customs and Border Protection agency. IBIS is generally queried by federal 

law enforcement agents at ports of entry. 

[SENSITIVE INFORMATION REDACTED] 

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No Fly and Selectee Lists 

The No Fly and Selectee Lists are maintained by the Transportation 

Security Administration. These lists are used by public carriers, both airline and 

other modal, to screen their passengers. The No Fly list includes individuals who 

are prohibited from boarding an aircraft. The Selectee list includes individuals 

who must undergo additional security screening checks before being permitted to 

board an aircraft. 

[SENSITIVE INFORMATION REDACTED] 

• In addition, a minimum threshold of derogatory information for inclusion 

on the No Fly or Selectee lists was established on October 21, 2004, by the 

Homeland Security Council. 

[SENSITIVE INFORMATION REDACTED] 

VGTOF 

Terrorist records contained in the Violent Gang and Terrorist Organization 

File (VGTOF) is one segment of the FBI’s National Crime Information Center 

(NCIC) system. The NCIC is a database queried by federal, tribal, state, and 

local law enforcement agencies in performance of their duties. 

Minimum Criteria: 

In order for a known or suspected terrorist to be included in VGTOF, the 

following minimum biographical information is required: 

• first name 

• last name 

• approximate year of birth 
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APPENDIX III: DIAGRAM OF TERRORIST WATCHLIST DATAF

[SENSITIVE INFORMATION REDACTED] 
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APPENDIX IV 

APPENDIX IV: ACRONYMS 

CBP Customs and Border Protection 

CIA Central Intelligence Agency 

CIO Chief Information Officer 

CLASS Consular Lookout and Support System 

DHS Department of Homeland Security 

DOJ Department of Justice 

EMA Encounter Management Application 

FBI Federal Bureau of Investigation 

FY Fiscal Year 

HSPD-6 Homeland Security Presidential Directive-6 

IBIS Interagency Border Inspection System 

ICE Immigration and Customs Enforcement 

IT Information Technology 

MOU Memorandum of Understanding 

NCIC National Crime Information Center 

NCTC National Counterterrorism Center 

NDIU Nominations and Data Integrity Unit 

NTP Nomination Tracking Processor 

ODNI Office of the Director of National Intelligence 

OIG Office of the Inspector General 

TIDE Terrorist Identities Datamart Environment 

TREX Terrorist Review and Examination Unit 

TSA Transportation Security Administration 

TSC Terrorist Screening Center 

TSDB Terrorist Screening Database 

TSOU Terrorist Screening Operations Unit 

SOP Standard Operating Procedure 

VGTOF Violent Gang and Terrorist Organization File

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APPENDIX V

APPENDIX V: TERRORIST SCREENING CENTER RESPONSE 

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APPENDIX V

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APPENDIX V

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APPENDIX VI

APPENDIX VI: OFFICE OF THE INSPECTOR GENERAL 

ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO 

CLOSE THE REPORT 

 In its response to our draft audit report, the TSC concurred with each of 

our 18 recommendations and discussed the actions it has already taken and 

others it will implement in response to our findings. This appendix contains 

our analysis of the TSC’s responses to our recommendations and the actions 

necessary to close each recommendation. 

Status of Recommendations

1. Resolved. The TSC concurred with our recommendation that it 

implement its plan to consolidate the TSDB NTP and legacy databases 

in a timely manner, and the TSC stated that it developed a project 

plan to guide the future consolidation of the system. In the interim 

period while it is still necessary to operate both databases, the TSC 

stated that it implemented a daily reconciliation process between the 

TSDB NTP and legacy databases for routine monitoring of the data. 

This recommendation can be closed when we receive evidence that the 

TSC has fully implemented its plan to consolidate the TSDB NTP and 

legacy databases. In the meantime, please provide evidence that the 

TSC has implemented a daily reconciliation process that identifies and 

addresses differences in database content. 

2. Resolved. In its response to our draft report, the TSC concurred with 

our recommendation to develop procedures to regularly review and 

test the information contained in the TSDB to ensure the data is 

complete, accurate, and non-duplicative. The TSC noted that it has 

used informal procedures to review and test the information in the 

TSDB, and it now has implemented procedures to formalize this 

process. 

This recommendation can be closed when we receive documentation or 

other evidence to support that the TSC has developed and fully 

implemented procedures to regularly review and test information in 

the TSDB to ensure the data is complete, accurate, and nonduplicative. 

3. Resolved. The TSC concurred with our recommendation and stated 

that it will implement our recommended changes as part of its 

planned, phased improvements for the TSDB NTP, including the 

incorporation of the export capability of the legacy system. 

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This recommendation can be closed when we receive evidence that the 

TSC has mofidied the TSDB NTP to accommodate designations for both 

CLASS/Visa and CLASS/Passport, and that it has reviewed and 

corrected the records identified in the TSDB NTP to appropriately 

reflect that U.S. persons are not eligible for export to CLASS/Visa. 

4. Resolved. The TSC concurred with this recommendation and stated 

that it had completed its review of watchlist records and made 

corrections to records in the TSDB NTP with incorrect IBIS handling 

instructions. 

This recommendation can be closed when we receive evidence that the 

TSC identified and corrected the watchlist records with inappropriate 

IBIS handling instructions. 

5. Resolved. In its response to our draft report the TSC concurred with 

this recommendation and stated that while it had used previously 

undocumented procedures, it will now formalize this process to ensure 

that outdated or obsolete data is removed in a timely manner. 

This recommendation can be closed when we receive evidence that the 

TSC has developed and implemented formal procedures to regularly 

review the information in the TSDB to ensure that outdated or 

obsolete data is removed in a timely manner. 

6. Resolved. The FBI concurred with our recommendation and stated 

that it will continue to work to revise the current nomination process. 

However, the FBI stated that it had implemented its current 

nomination process initially to address its concern that watchlist 

nominations were not being processed in a timely manner due to the 

operations schedule of the NCTC. 

While we recognize that the FBI conducts its watchlisting operations 

on a continuous basis, we believe that the NCTC is operational during 

the time period in which the majority of watchlist nominations are 

submitted. Further, an additional emergency nomination process is 

available to the FBI for those instances in which the FBI determines a 

nomination is exigent and the NCTC may not be available. Given our 

identification of significant data errors and inconsistencies resulting 

from the FBI’s non-standard nomination process for international 

terrorists, we believe that the FBI, NCTC, and TSC should work 

together to design a more consistent and reliable process by which 

FBI-originated international terrorist information is provided to the 

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APPENDIX VI

NCTC for inclusion in TIDE and disseminated to the TSDB and 

downstream screening systems, including VGTOF. To close this 

recommendation, please provide us with information on specific steps 

taken to revise the FBI’s watchlist nomination process for known or 

suspected international terrorists. 

7. Resolved. The TSC concurred with this recommendation and stated 

that it has taken steps to correct the watchlist records under its 

purview. This recommendation can be closed when we receive 

evidence that the records we identified during our review that 

contained incorrect watchlist designations, handling code errors, and 

inaccurate and inconsistent information have been corrected. 

8. Resolved. The TSC concurred with our recommendation to coordinate 

with NCTC and FBI to implement an agreement that establishes the 

areas of responsibility and the timeframes for data quality assurance 

matters. 

This recommendation can be closed when we receive evidence 

supporting the implementation of a signed agreement between the 

NCTC and FBI that outlines areas of responsibility and the timeframes 

for data quality assurance matters.

9. Resolved. The TSC concurred with our recommendation to develop a 

comprehensive standard operating procedure that describes the TSC’s 

quality assurance strategy and details the methodology to be used in 

performing quality assurance reviews. 

This recommendation can be closed when we receive evidence that the 

TSC has finalized its quality assurance strategy and methodology and 

has trained its staff on using the standard operating procedure in 

performing quality assurance reviews. 

10. Resolved. The TSC concurred with our recommendation to develop a 

process to perform regular spot-checks of NDIU analysts’ work. This 

recommendation can be closed when we receive evidence that the TSC 

has developed, documented, and implemented a process to perform 

regular spot-checks of NDIU analysts’ work to identify weaknesses and 

needs for additional training. 

11. Resolved. In its response, the TSC concurred with this 

recommendation and stated that it had implemented a solution to 

remedy our finding. Specifically, the TSC stated that it will utilize the 

FBI’s Automated Case Support (ACS) system to track all quality 

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APPENDIX VI

assurance classified correspondence, including e-mails and electronic 

communications. 

This recommendation can be closed when we receive evidence that the 

TSC has formally documented this process and communicated the 

policy to its staff. 

12. Resolved. The TSC concurred with this recommendation and stated 

that it has begun developing a tickler system or electronic dashboard 

for pending quality assurance matters. This recommendation can be 

closed when we receive evidence that the TSC has implemented such a 

system. 

13. Resolved. The TSC concurred with this recommendation and stated 

that it will develop a comprehensive plan to ensure that each record in 

the TSDB has undergone a quality assurance review. 

This recommendation can be closed when we receive evidence that the 

TSC has developed a plan that: (1) includes specific milestones for 

the successful completion of this comprehensive review, (2) tracks its 

progress against these milestones, and (3) identifies actions to take if 

the milestones are not met. 

14. Resolved. The TSC concurred with this recommendation and stated 

that since its inception the TSC has used an undocumented process to 

coordinate with other partner agencies to obtain relevant information 

captured by frontline screening agents during encounters with known 

or suspected terrorists. We recognize that the TSC has endeavored to 

update watchlist records by incorporating encounter information 

captured by frontline screening agents. However, without a formal 

process with which frontline screening agencies agree, the TSC is 

unable to ensure that it is receiving complete, accurate, and timely 

encounter information. This recommendation can be closed when the 

TSC provides documentation to support that a formal process has been 

developed and implemented between partner agencies to ensure that 

encounter data is appropriately returned to the TSC for updating 

watchlist records. 

15. Resolved. The TSC concurred with this recommendation and stated 

that implementation to address this recommendation was underway 

and pending signatures by all parties. This recommendation can be 

closed when we receive the finalized agreement containing timeliness 

measures for processing watchlist redress matters agreed to and 

signed by the appropriate agencies. 

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APPENDIX VI

16. Resolved. The TSC concurred with this recommendation and stated it 

is developing goals and performance measures relative to 

misidentifications for its strategic plan. This recommendation can be 

closed when the TSC provides its updated strategic plan that includes 

goals and performance measures to address reducing the incidence 

and impact of misidentifications. 

17. Resolved. The TSC concurred with this recommendation, stating in 

its response that it is developing the framework for a program that will 

proactively review watchlist records related to frequently encountered 

individuals. This recommendation can be closed when the TSC 

provides documentation formalizing this new proactive redress 

program, as well as evidence that this program has been 

implemented. 

18. Resolved. The FBI concurred with our recommendation and stated 

that it has instituted a new policy and process for resolving redress 

matters involving the NCIC database. Additionally, the FBI noted that 

the February 2007 redress matter that was pending at the time of our 

review has been resolved. 

To close this recommendation, please provide us the FBI policy 

containing timeliness measures for processing NCIC-related redress 

matters. Additionally, please provide documentation to confirm that 

the February 2007 redress matter that was pending at the time of our 

review has been appropriately resolved. 

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