AMO and Coast Guard 

Maritime Missions Are Not 

Duplicative, But Could 

Improve with Better 

Coordination 

October 14, 2016 

OIG-17-03 
 

 

DHS OIG HIGHLIGHTS
 

AMO and Coast Guard Maritime Missions 

Are Not Duplicative, But Could Improve with 

Better Coordination
 

October 14, 2016 

Why We Did 

This Audit 

Within the Department of 

Homeland Security, U.S. 

Customs and Border 

Protection’s (CBP) Air and 

Marine Operations (AMO) 

and the United States Coast 

Guard (Coast Guard) share 

responsibility for maritime 

security missions. At the 

request of Congress, we 

reviewed the maritime 

missions and 

responsibilities of AMO and 

the Coast Guard. 

What We 

Recommend 

We made two 

recommendations to 

improve oversight and 

coordination of maritime 

operations. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

We found that the two components’ maritime 

missions and responsibilities are not duplicative; 

their efforts bolster the overall effectiveness of DHS 

maritime border security and improve the ability to 

prevent the illegal flow of contraband and people 

into the country. Given the large area of 

responsibility, different activities, and limited 

resources, eliminating the maritime law 

enforcement responsibilities of either agency — or 

combining them — could be harmful to border 

security. However, AMO and the Coast Guard could 

improve coordination in some areas, which could 

potentially increase effectiveness of maritime 

border security, result in potential efficiencies, and 

enhance unity of effort. 

DHS Response 

DHS concurred with both recommendations and 

plans to improve operational coordination and 

update the 2011 Maritime Operations Coordination 

Plan. The Department is also pleased with the 

OIG’s positive recognition of AMO’s and the Coast 

Guard’s efforts to bolster maritime border security 

and remains committed to exploring ways to 

further the progress in strengthening unity of effort 

in maritime security. 

www.oig.dhs.gov OIG-17-03 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

October 14, 2016 

MEMORANDUM FOR: The Honorable Russell C. Deyo 

Under Secretary for Management 

Department of Homeland Security 

The Honorable R. Gil Kerlikowske 

Commissioner 

U.S. Customs and Border Protection 

The Honorable Admiral Paul F. Zukunft 

Commandant 

United States Coast Guard 

The Honorable Sarah R. Saldana 

Director 

U.S. Immigration and Customs Enforcement 

FROM: John Roth ~\.v....._~X'-- Inspector General 

SUBJECT: AMO and Coast Guard Maritime Missions Are Not 

Duplicative, But Could Improve with Better Coordination 

Attached for your action is our final report, AMO and Coast Guard Maritime 

Missions Are Not Duplicative, But Could Improve with Better Coordination. We 

incorporated the formal comments from the Department of Homeland Security in 

the final report. 

The report contains two recommendations aimed at improving Maritime Security 

Missions. DHS concurred with both recommendations. Based on information 

provided in your response to the draft report, we consider recommendations 1 

and 2 open and resolved. Once your office has fully implemented the 

recommendations, please submit a formal closeout letter to us within 30 days so 

that we may close the recommendations. The memorandum should be 

accompanied by evidence of completion of agreed-upon corrective actions and of 

the disposition of any monetary amounts. Please send your closure request to 

OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will provide 

copies of our report to congressional committees with oversight and appropriation 

responsibility over the Department of Homeland Security. We will post the report 

on our website for public dissemination. 

Please call me with any questions, or your staff may contact Don Bumgardner, 

Deputy Assistant Inspector General for Audits, at (202) 254-4100. 

Attachment 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 1 

Results of Audit .............................................................................................. 4 

Layered Security Strengthens Maritime Border Protection...................... 4 

AMO and the Coast Guard Need to Enhance Communication and 

Coordination.......................................................................................... 8 

DHS Implemented Asset Acquisition and Logistics Oversight ................. 9 

Use of Force Policies Differ without Affecting Mission Effectiveness ...... 10 

Conclusion.................................................................................................... 12 

Recommendations......................................................................................... 12 

Management Comments and OIG Analysis .................................................... 13 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 14 

Appendix B: DHS Comments to the Draft Report ................................. 17 

Appendix C: AMO and Coast Guard FY 2015 Seizure Statistics............ 21 

Appendix D: Office of Audits Major Contributors to This Report ........... 22 

Appendix E:Report Distribution .......................................................... 23 

Abbreviations 

AMO Air and Marine Operations 

CBP U.S. Customs and Border Protection 

Coast Guard United States Coast Guard 

GAO Government Accountability Office 

JIATF-South Joint Interagency Task Force - South 

OIG Office of Inspector General 

plan Maritime Operations Coordination Plan 

strategy National Strategy for Maritime Security 

www.oig.dhs.gov OIG-17-03 
 

Source: U.S. House of Representatives, Committee on Transportation and Infrastructure, 

June 2015 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background
 

The Department of Homeland Security is the lead Federal agency for combating 

maritime threats, including — but not limited to — drugs and people who are 

trying to enter the country illegally. Within DHS, U.S. Customs and Border 

Protection’s (CBP) Air and Marine Operations (AMO) and the United States 

Coast Guard (Coast Guard) share responsibility for maritime security missions. 

The U.S. House of Representatives, Committee on Homeland Security, 

Subcommittee on Border and Maritime Security requested this review of the 

maritime missions and responsibilities of AMO and the Coast Guard. 

Illegal drug trafficking continues to threaten the safety, security, and public 

health of the Nation and place significant strain on the health care and 

criminal justice systems, costing taxpayers hundreds of billions of dollars each 

year. The majority of drugs entering the United States pass from South 

America through a 6 million square-mile area called the Transit Zone. This 

area includes the Caribbean Sea, the Gulf of Mexico, and the Eastern Pacific 

Ocean. Although cartels use boats to move drugs into the United States, the 

vast majority of the drugs enter through the United States-Mexico land border. 

Figure 1 shows the primary paths for the flow of drugs into the United States. 

Figure 1: Primary Paths for the Flow of Drugs into the United States 

Typically, vessels carrying multi-ton loads of cocaine depart Colombian and 

Ecuadorian ports for delivery points along the Central American or Mexican 

coasts. Once the vessels arrive in Central America, the drugs are broken down 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

into smaller packages, and smugglers use small boats to transport them across 

the U.S. maritime borders. 

In the Caribbean, high-speed vessels haul as much as two metric tons of 

cocaine at a time. Smugglers also use submersible vessels to move large 

shipments of cocaine. 

In addition to drug smuggling, 

citizens from other countries use 

the sea as a way to enter the United 

States illegally. For example, in 

fiscal year 2015 the Coast Guard 

interdicted individuals trying to 

enter the country illegally from 

China, India, and the Czech 

Republic. People attempted to enter 

the United States from Mexico, 

Cuba, and the Bahamas. 

Within DHS, AMO and the Coast 

Guard are responsible for maritime 

operations to interdict drugs and Figure 2: A Coast Guard boat crew interdicts 

individuals trying to enter the 117 Dominicans near San Juan, Puerto Rico. 

country illegally before they reach An AMO aircraft detected this vessel. 

our shores. AMO and the Coast Source: AMO 

Guard share coastal security 

responsibilities in Florida, Puerto Rico, the Gulf of Mexico, Great Lakes, Pacific 

Northwest, and southern California. 

AMO 

Within CBP, AMO’s primary mission is law enforcement in the air, land, and 

sea. It is responsible for interdicting illegal drugs, smugglers, and aliens 

through four primary means: 

x Interdiction — efforts to intercept, apprehend, or disrupt threats as they 

move toward or across U.S. borders. 

x Investigations — using the expertise of agents in the air and at sea to 

defeat criminal networks. 

x	 Domain Awareness — the effective understanding of the environment 

and information associated with the various domains (air, land, and 

maritime) that could affect safety, security, the economy, or the 

environment. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Contingency Operations and National Tasking Missions — disaster relief, 

contingency of operations, humanitarian operations, enforcement 

relocation, search and rescue, and national special security events. 

Coast Guard 

The Coast Guard has 11 statutory missions that include drug and migrant 

interdiction. Its other responsibilities include non-law enforcement missions 

such as search and rescue, boating safety, and ice breaking operations. Table 1 

shows the Coast Guard’s programs and missions. 

Table 1: Coast Guard Operating Programs and Missions 

Coast Guard Operating Programs Homeland Security Act (2002) Missions 

1. Ports, Waterways, and Coastal Security 

Maritime Security Operations 2. Marine Safety 

Maritime Response and Prevention 3. Search and Rescue 

4. Marine Environmental Protection 

Defense Operations 5. Defense Readiness 

Marine Transportation Systems 6. Aids to Navigation 

Management 7. Ice Operations 

8. Living Marine Resources 

9. Other Law Enforcement Maritime Law Enforcement 10. Migrant Interdiction 

11. Drug Interdiction 

Source: The Coast Guard’s FY 2014 Performance Report 

The U.S. House of Representatives, Committee on Homeland Security, 

Subcommittee on Border and Maritime Security requested this audit to 

determine whether there is unnecessary duplication of the maritime missions 

and responsibilities of AMO and the Coast Guard. In addition, we assessed: 

x alignment of aircraft and vessel acquisition and logistics; 

x use of force policies and the degree that difference has on mission 

effectiveness, safety, and accountability; and 

x operational coordination and opportunities for co-location. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit
 

The maritime missions and responsibilities of AMO and the Coast Guard are 

not duplicative. Their efforts to interdict drugs and people bolster the overall 

effectiveness of DHS’ maritime border security. The agencies contribute to the 

national strategy of layered maritime security and conduct different activities, 

which leads to more interdictions. However, AMO and the Coast Guard could 

improve coordination and communication in some areas. 

Layered Security Strengthens Maritime Border Protection 

AMO and the Coast Guard contribute to the national strategy of layered 

maritime security. They have common goals of preventing the illegal flow of 

contraband and people in a shared area and complementary missions. Each 

conducts different activities and provides different capabilities to achieve those 

goals. As a result, the agencies do not duplicate drug and migrant interdiction 

efforts; they increase the overall effectiveness of DHS’ maritime border security. 

National Strategy for Maritime Security 

In 2005, the White House released the National Strategy for Maritime Security 

(strategy) outlining a comprehensive national effort to promote global economic 

stability, protect legitimate activities, mitigate the 

effects of natural disasters, and prevent hostile and 

illegal acts affecting the maritime environment. 

According to the strategy, responding to maritime 

threats requires teamwork and is dependent on the 

capabilities of governments and commercial 

interests throughout the world. The strategy 

emphasized maritime security is contingent upon a 

layered security system. 

DHS’ Layered Maritime Security 

DHS maritime security begins overseas where the 

Coast Guard visits international ports1 to assess 

security measures and determine whether U.S.-

bound vessels from those ports should be subject to 

additional screening. 

Diverse and 

complementary 

measures of the 

public and private 

sectors acting in 

concert can prevent 

terrorist attacks 

and criminal acts 

better than relying 

on a single layer of 

security. 

 

The National Strategy 

for Maritime Security 

1 CBP also conducts operations in foreign ports through its Container Security Initiative. 

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OFFICE OF INSPECTOR GENERAL 

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The next layer — in international waters — is offshore, including the Transit 

Zone, where Coast Guard deploys its major vessels (Cutters), patrol aircraft, 

and personnel.2 AMO also deploys surveillance aircraft in these waters. In the 

Transit Zone, both agencies contribute to the Joint Interagency Task Force - 

South (JIATF-South), which conducts detection and monitoring operations to 

interdict drug smuggling vessels. JIATF-South, led by the Department of 

Defense, coordinates activities in this area. According to officials at JIATF-S, 

interdiction resources (boats and aircraft) are limited in the Transit Zone, 

which affects interdiction efforts. Further, according to the 2015 National 

Security Strategy, the Department of Defense redirected some of its resources 

from the Transit Zone to Asia and the Pacific. This makes the next layer of 

maritime security — in “customs waters” — critical. 

Customs waters, the layer closest to the U.S. coastline, extend 12 nautical 

miles from shore. In these waters, AMO and the Coast Guard share 

responsibility to detect and intercept illegal drugs, smugglers, and individuals 

trying to enter the country illegally on the last leg of their transit to U.S. 

shores. There are 206 combined locations where AMO and the Coast Guard 

conduct operations in customs waters. Of the 206, there are 17 locations (8 

percent) where AMO and the Coast Guard have similar capabilities and an 

overlapping area of responsibility. According to AMO and the Coast Guard, 

many of these locations have a high concentration of drug and migrant flow. 

Figure 3 shows the overlapping locations. These layers of security in customs 

waters are necessary, and they bolster maritime border security. 

Figure 3: 17 Overlapping AMO and Coast Guard Locations 

Overlapping locations 

Source: DHS Office of Inspector General (OIG) 

2 The Coast Guard deploys law enforcement detachments, which are teams of law enforcement 

personnel that operate from U.S. Navy and allied naval ships transiting or operating in areas 

frequently used by illegal drug traffickers. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Activities, Capabilities, and Overall Effectiveness 

Having both agencies as layers of security increases the overall effectiveness of 

DHS’ border security because they each engage in different activities. In 

addition, each has capabilities that the other cannot provide. 

AMO’s primary mission is law enforcement. Its agents gather intelligence, 

conduct investigations, and assist other Federal agencies in their investigations 

to identify illegal activity. In FY 2015, at the 17 overlapping locations, all of 

AMO’s drug seizures occurred on land or in customs waters, where marine 

units primarily conduct operations. 

The Coast Guard is a multi-mission agency, including law enforcement that 

operates in both customs and international waters. In contrast to AMO, Coast 

Guard personnel assigned to drug and migrant interdiction do not conduct 

investigative or land operations. In FY 2015, 93 percent of Coast Guard drug 

seizures occurred in international waters (Transit Zone). AMO only deploys 

aircraft in this area; it does not have the vessels to operate in these waters.3 

In the overlapping locations, 84 percent of reported drug seizures were from 

AMO operations. These seizures occurred, in 

part, because of the different activities of each 

agency. For example, while some of AMO 

operations were intelligence based, the Coast 

Guard conducts routine patrols looking for illegal 

activity. Although Coast Guard patrols are not as 

effective as intelligence-based operations, they 

show a presence and can deter illegal activity. 

Table 2 shows the FY 2015 AMO and Coast 

Guard drug seizures4 from the 17 overlapping 

locations. 

Duplication occurs when 

two or more agencies or 

programs are engaged in 

the same activities or 

provide the same services 

to the same beneficiaries. 

Government 

Accountability Office 

(GAO) 15 -49SP 

3 AMO deploys aircraft in this area and reported it contributed to 198 events that resulted in 

interdiction of a total of 206,500 pounds of cocaine in FY 2015.

4 AMO and the Coast Guard each reported other seizures for that year. Appendix C shows all 

FY 2015 seizures for both agencies.
 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2: FY 2015 Drug Seizures from the 17 Overlapping Locations 

Agency Customs Waters 

(Drugs in Pounds) Percent 

AMO 28,707 84 

Coast Guard 5,602 16 

Total 34,309 100 

Source: OIG analysis of AMO and Coast Guard seizure data 

Limited Resources 

The resources AMO and the Coast Guard dedicate to maritime drug and 

migrant interdiction operations are small for each agency.5 In FY 2015, at the 

17 overlapping locations, AMO and the Coast Guard devoted less than 5 

percent of their budgets and less than 12 percent of the total personnel to 

maritime interdiction efforts. Table 3 shows the agencies’ budgets compared to 

the amount spent at the overlapping stations and table 4 shows the personnel 

information. 

Table 3: FY 2015 Comparison of AMO and Coast Guard Budgets to the 

Amount Spent at the 17 Overlapping Areas 

Component 

FY 2015 

Budget 

Amount Spent on Drug 

and Migrant Interdiction 

at the Overlapping 

Stations (millions) 

Percent of 

Component 

Budget 

AMO $750 million $36 4.8 

Coast Guard $8.38 billion $29 0.3 

Source: OIG analysis of AMO and Coast Guard budget data 

Table 4: AMO and Coast Guard Total Operational Personnel and Personnel 

Assigned to the 17 Overlapping Areas 

Component Personnel 

Personnel for 

Maritime Drug and 

Migrant Operations 

Percent of 

Personnel 

AMO 1,665 200 12 

Coast Guard 41,700 715 2 

Source: OIG analysis of AMO and Coast Guard personnel data 

5 AMO and the Coast Guard each have responsibilities in addition to maritime drug and 

migrant interdictions. For example, AMO is responsible for air operations on the Southwest 

and Northern borders, and the Coast Guard has nine other missions, such as search and 

rescue, ports, waterways, coastal security, and ice operations. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Limited Detection Capabilities 

AMO and the Coast Guard are limited in their ability to detect threats as they 

approach the U.S. shore lines. Detecting illicit activity is a key component of an 

active, layered maritime defense strategy called 

“Maritime Domain Awareness.” Figure 4 illustrates 

where AMO and the Coast Guard maintain maritime 

awareness. AMO and the Coast Guard gain awareness 

in the following ways: 

x Intelligence: Both agencies have separate 

intelligence centers that provide information 

related to illicit activity and increase awareness 

of events in the maritime domain. AMO also 

gathers intelligence through investigations. 

x Air Surveillance: Coast Guard and AMO both 

have aircraft with radar that provide 

surveillance. However, not all aircraft are capable of 

conducting maritime surveillance missions, and the Figure 4: The green 

availability of aircraft and personnel is limited. shaded area shows the 

area where AMO and the x Ground Radar: According to the Coast Guard and a Coast Guard maintain 

Sheriff’s office, fixed radar systems are more constant, awareness. 

but they are unavailable in most areas and were only Source: AMO 

used in parts of Florida and the Pacific Northwest. 

According to the National Strategy for Maritime Security, “Achieving awareness 

of the maritime domain is challenging. The vastness of the oceans, the great 

length of shorelines, and the size of port areas provide both concealment and 

numerous access points to land.” In addition, maritime awareness is heavily 

dependent on information sharing and requires cooperation between 

components. 

AMO and the Coast Guard Need to Enhance Communication 

and Coordination 

AMO and the Coast Guard took steps to coordinate maritime activities, but 

they could improve coordination at the 17 overlapping locations. In 2011, AMO 

and the Coast Guard issued the Maritime Operations Coordination Plan (plan)6 

to coordinate, share information, improve effectiveness, and prevent 

duplication of efforts. The plan also requires AMO and the Coast Guard to train 

together so that each understands the different rules of engagement. The plan 

created a framework for regional coordination of operations and joint training. 

6 DHS’ U.S. Immigration and Customs Enforcement also contributed to developing this plan. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to the plan, “Unity of effort is essential at the regional level in order 

to counter maritime threats (terrorism, national security, and criminal)....” 

Although AMO and the Coast Guard coordinate at the regional level, 

coordination and unity of effort do not always occur at the local level. 

We visited 11 of the 17 overlapping AMO and Coast Guard locations to 

determine the extent of the coordination of their operations. According to our 

analysis, AMO and the Coast Guard reported: 

x 5 of 11 (45 percent) locations did not coordinate operations or activities; 

and 

x 8 of 11 (73 percent) locations did not train together. 

The plan required DHS to monitor operational performance, coordination 

efforts, and information sharing. In response, DHS established a senior 

steering group and working group to oversee coordination efforts. According to 

DHS, the steering and working groups were discontinued in 2013 and 2014, 

respectively. 

The ideas in the plan are not new, and attempts to coordinate interdiction 

efforts began much earlier than 2011. For example, in 1988 the Coast Guard 

and the U.S. Customs Service7 agreed that coordination is necessary to: 

x use all assets in the most efficient and effective manner possible; 

x promote safety; and 

x enhance the “team” concept. 

In addition, in the 11 areas we visited, AMO and the Coast Guard were not colocated, but they shared dock space in 6 of those locations. In four locations 

AMO was already located with the U.S. Navy, CBP’s Office of Border Patrol, or 

U.S. Immigration and Customs Enforcement’s Homeland Security 

Investigations. However, in one area, AMO had its boats in a private dock space 

even though a nearby Coast Guard boat station had extra space. 

DHS Implemented Asset Acquisition and Logistics Oversight 

The similar missions of AMO and the Coast Guard resulted in each component 

acquiring aircraft and boats. The Department has taken steps to oversee 

aircraft and vessel acquisition and logistics, and it established three oversight 

mechanisms. The oversight mechanisms and their responsibilities are: 

7 The creation of DHS divided the responsibilities and assets of the U.S. Customs Service 

among CBP and U.S. Immigrations and Customs Enforcement. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x	 Joint Requirements Council — oversees DHS capability needs and 

prioritizes funding recommendations to mitigate redundant capabilities, 

fill capability gaps, drive unity of effort, and harmonize capabilities 

requirements across DHS. 

x	 Boat Forces Governance Board — coordinates leadership and oversight of 

DHS boats while addressing joint policy, business processes, strategy, 

standards, and other opportunities to align with a “One-DHS” vision for 

boat forces. 

x	 Aviation Governance Board — provides strategic guidance and oversight 

to ensure efficient and effective management of its aviation fleet. The 

Aviation Board plans, supports, and enables aviation opportunities 

without having command and control authority over operations. 

These groups align aircraft and vessel acquisition and logistics for DHS 

components. These groups are new to DHS and need time to achieve their 

goals. 

Use of Force Policies Differ without Affecting Mission 

Effectiveness 

There are differences between AMO and 

Coast Guard use of force policies, but those 

differences do not affect mission 

effectiveness, safety, and accountability. 

According to the DHS Office of General 

Counsel, there are three principle 

differences: 1) the area where each 

component is authorized to operate; 2) the 

approval authority for using force; and 

3) guidance on the use of force when 

migrants are involved. 

Areas of Operation 

The areas of operation in which the Coast Guard regularly operates are much 

broader than AMO’s areas of operation. The Coast Guard routinely conducts 

operations within customs waters, within internal waters, in international 

waters, and in other nations’ territorial seas with coastal state consent. AMO 

operates primarily within the customs waters, but it maintains the authority to 

pursue vessels fleeing the customs waters or hovering outside those waters as 

a means of avoiding AMO jurisdiction. According to the DHS Office of General 

Counsel, the Coast Guard is most likely to employ use of force in international 

waters, and AMO is most likely to employ use of force in the customs waters. 

Figure 5: Coast Guard marksman 

taking aim at boat engines. 

Source: Coast Guard 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Approval for Employing Use of Force 

Coast Guard crews must receive approval from the appropriate official in the 

chain of command, typically an Admiral, before using force to stop 

noncompliant vessels.8 According to the Coast Guard, the approval time can 

take from 10 minutes to several hours depending on the case. In contrast, 

AMO policy reflects a more traditional law enforcement approach and allows its 

agents to make use of force decisions. 

According to the Coast Guard, it needs a use of force policy to cover a vast 

range of mission sets across a legally and jurisdictionally complex operating 

environment. Although the approval process has some level of risk mitigation, 

the Coast Guard designed the process to relieve on-scene officers of the need to 

assess U.S. jurisdiction and legal authority to employ force against a 

noncompliant vessel, and allows those officers to focus on executing the tactics 

and procedures to safely and effectively employ that force. 

We participated in use of force demonstrations for noncompliant vessels with 

both components and experienced the delay in the Coast Guard’s approval 

process. Although there are potential safety concerns for Coast Guard boat 

crews during a pursuit, the Coast Guard stated that it updated its law 

enforcement manual to “refine and streamline the process in every way 

possible” to reduce the time lapse from when the Coast Guard vessel is “overt” 

(known by the suspected vessel to be following) to when the necessary actions 

(use of force) are completed. 

Guidance When Migrants Are Present 

Both components’ policies provide for additional considerations when migrants 

are present. According to the DHS Office of General Counsel, the Coast Guard’s 

policy permits vessel-to-vessel use of force in migrant cases, provided that the 

vessel is subject to U.S. jurisdiction, the vessel has exposed outdrives or an 

outboard engine, and there is probable cause to believe there is a violation of 

U.S. immigration law. In addition, according to the Coast Guard, it uses a 

“significant degree of restraint” in exercising force in migrant cases. 

AMO’s policy also permits vessel-to-vessel use of force when “objectively 

reasonable” and the level of force reflects the totality of circumstances 

including the severity of the crime and presence of imminent danger to the 

agent or others. The policy restricts the use of air-to-vessel force against 

noncompliant vessels where the sole violation appears to be illegal alien 

smuggling. The exception to this general prohibition in the AMO policy is where 

8 Coast Guard personnel can use force in self defense and other security missions without 

additional approval. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the vessel is suspected of a crime(s) in addition to the smuggling of aliens. In 

these cases, the AMO agents maintain the discretion to employ use of force. In 

other words, the mere presence of migrants on a vessel does not prevent AMO 

agents from using force if they suspect a separate crime and the potential 

benefit of employing force is not outweighed by the potential danger posed to 

personnel, other law enforcement personnel, or the public. 

Conclusion 

The maritime missions and responsibilities of AMO and the Coast Guard are 

not duplicative, and it is necessary for both to interdict drugs and people trying 

to enter the country illegally. Although they have common goals of preventing 

the illegal flow of contraband and people in a shared area, they contribute in 

different ways, and each provides capabilities that the other cannot. Having 

both agencies bolsters the overall effectiveness of maritime border security and 

meets the national goals for layered maritime security. Given the vast area of 

responsibility, different activities, and limited resources, eliminating the 

maritime law enforcement responsibilities of either agency — or combining 

them — could be harmful to border security. However, AMO and the Coast 

Guard could improve coordination in some areas. 

DHS and maritime border security could benefit from Department monitoring 

and improved coordination. Oversight and coordination could potentially lead 

to using resources more effectively, such as saving money through co-location 

of personnel. This could not only save money but also help with 

communication, coordination, and alignment with the “One-DHS” vision. 

Recommendations 

Recommendation #1: We recommend that the DHS Under Secretary for 

Management reestablish an oversight mechanism at the DHS level to ensure 

that AMO and the Coast Guard coordinate operations. 

Recommendation #2: We recommend that the Coast Guard Commandant, 

CBP Commissioner, and U.S. Immigration and Customs Enforcement Director 

revise the Maritime Operations Coordination Plan to include requirements for 

coordination and information sharing at all levels, especially the local level. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

DHS concurred with our recommendations and provided comments to the draft 

report. We have included a copy of the Department’s management comments in 

their entirety in appendix B. DHS also provided technical comments to our 

report, which we incorporated, as appropriate. 

Recommendation #1: DHS concurred. The Department recognizes that it can 

improve coordination of maritime operations and maritime security at the 

Department level. To address the recommendation, the Under Secretary for 

Management will charter and lead a Maritime Security Coordination Working 

Group that includes key leaders from applicable DHS Operational and 

Headquarters Components. The Working Group will ensure DHS implements 

oversight mechanisms to coordinate AMO, Coast Guard, and U.S. Immigration 

and Customs Enforcement operations on a sustained basis. Additionally, the 

Working Group will review how the principles and goals outlined in the 

Maritime Operations Coordination Plan, together with suitable means of 

oversight, can be incorporated into recently established coordination forums at 

both the Department and field levels. The estimated completion date is 

December 29, 2017. 

OIG Analysis: The Department’s planned actions are responsive to this 

recommendation. This recommendation is resolved but will remain open until 

DHS fully implements the corrective actions. 

Recommendation #2: DHS concurs. The Working Group will apply lessons 

learned from the implementation of the 2011 Maritime Operations 

Coordination Plan and revise the plan to address current operational 

structures and lines of effort. In accordance with DHS Under Secretary for 

Management tasking, the Working Group will review these new practices 

and submit recommendations to enhance joint training, situational 

awareness, intelligence sharing, and operational coordination at all levels. 

The estimated completion date is June 29, 2018. 

OIG Analysis: The Department’s corrective action is responsive to the 

recommendation. This recommendation is resolved, but it will remain open 

until DHS provides a copy of the revised plan and demonstrates how it 

implemented the new practices. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107−296) by 

amendment to the Inspector General Act of 1978. 

This review was a request from the U.S. House of Representatives, Committee 

on Homeland Security, Subcommittee on Border and Maritime Security. Our 

audit objective was to determine whether there is unnecessary duplication or 

fragmentation of the maritime missions and responsibilities of AMO and the 

Coast Guard to identify operational, mission, and cost efficiencies that DHS 

might realize. The U.S. House of Representatives, Committee on Homeland 

Security, Subcommittee on Border and Maritime Security requested this audit 

to determine whether there is unnecessary duplication of the maritime 

missions and responsibilities of AMO and the Coast Guard. In addition, we 

assessed: 

x alignment of aircraft and vessel acquisition and logistics; 

x use of force policies and the degree that differences had on mission 

effectiveness, safety, and accountability; and 

x operational coordination and opportunities for co-location. 

To answer our objective, we: 

x	 Consulted GAO and used its guidance to determine whether 

fragmentation, overlap, and duplication exist in AMO and Coast Guard 

maritime operations. To make the determination of whether there is 

unnecessary duplication, we identified and analyzed the activities, 

capabilities, and jurisdictions of AMO and the Coast Guard. We analyzed 

the: 

o	 intention of having layers of maritime security; 

o	 positive and negative impacts; 

o	 cost; 

o	 level of coordination; 

o	 size of areas of responsibility; 

o number of personnel; and 

o outcomes and results of AMO and Coast Guard efforts. 

x	 Analyzed the National Strategy for Maritime Security and its supporting 

plans and assessed how AMO and the Coast Guard provide layered 

maritime security. We also interviewed DHS officials to determine 

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whether the principles of the strategy expressed in 2005 remain part of 

the current National and Homeland Security plan. 

x	 Reviewed the 2011 Maritime Operations Coordination Plan and used its 

requirements to determine whether AMO and the Coast Guard have 

coordinated efforts. 

x	 Examined AMO and Coast Guard activities to determine the extent to 

which the components implemented the coordination plan, evidenced by 

the level of cooperation, coordination, and communication between the 

two agencies. During these site visits, we analyzed schedule sharing 

information, joint trainings, and coordination efforts to ensure that AMO 

and the Coast Guard coordinated and trained together. We also 

corroborated testimonial evidence in the areas where AMO and the Coast 

Guard were not coordinating or conducting joint training. We visited 

locations in: 

o	 San Diego, California; 

o	 Atlantic Beach, Fort Pierce, Jacksonville, Key Largo, Key West, 

Marathon Key, Miami, and West Palm Beach, Florida; 

o	 Grand Isle and Houma, Louisiana; 

o	 Detroit, Gibraltar, Mount Clemens, Port Huron, and Selfridge, 

Michigan; 

o	 Gulfport, Mississippi; 

o	 Cleveland, Clinton, and Marblehead, Ohio; 

o	 Erie, Pennsylvania; 

o	 Aguadilla and San Juan, Puerto Rico; 

o	 Corpus Christi, McAllen, Port Aransas, Port Isabel, and South 

Padre Island, Texas; and 

o	 Bellingham, Port Angeles, and Seattle, Washington. 

x	 Analyzed seizure data for AMO and the Coast Guard. We performed data 

reliability testing on drug seizure information and determined it was 

sufficiently reliable for the purposes of our audit. 

x	 Calculated FY 2015 operating costs for the overlapping AMO and Coast 

Guard locations to estimate operating costs. The operating costs included 

facility leases, boat dock leases, operations and maintenance, and salary 

expenses. We used this information to provide context, and it did not 

result in a finding or have an effect on the overall conclusion and 

recommendations. 

x	 Received a demonstration of a radar system in the Pacific Northwest and 

interviewed AMO to gain an understanding of the system. We also 

interviewed officials from the Palm Beach Sheriff’s Office, AMO, and the 

Coast Guard to determine where other radar systems are available and 

which maritime border security agencies have access to them. 

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x	 Reviewed use of force policies for the Coast Guard and AMO to determine 

the impact on safety and effectiveness. We also observed use of force 

demonstrations from AMO and the Coast Guard to understand how 

differences in policies affect the execution of use of force in San Diego, 

California; Miami and Key West, Florida; and San Juan, Puerto Rico. 

x	 Interviewed officials at AMO and the Coast Guard in Washington, DC, to 

gain an understanding of the maritime missions and obtain program 

statistics and cost information. 

x	 Interviewed officials from the Office of the Chief Readiness Officer to gain 

an understanding of the oversight roles of the Joint Requirements 

Council, Aviation Governance Board, and the Boat Forces Governing 

Board. 

x	 Toured CBP’s Air and Marine Operations Center and the Coast Guard’s 

Maritime Intelligence Fusion Center in California to gain an 

understanding of intelligence operations. 

x	 Observed AMO aerial surveillance training in San Diego, California, and 

Aguadilla, Puerto Rico, and a Coast Guard maritime law enforcement 

patrol in the Straits of Florida to understand the different activities and 

capabilities of AMO and the Coast Guard. 

x Compared authorities and mandates for AMO and the Coast Guard to 

determine jurisdictions, roles, and responsibilities. 

x Confirmed our findings with AMO, the Coast Guard, and other 

stakeholders. 

We conducted this performance audit between October 2015 and June 2016 

pursuant to the Inspector General Act of 1978, as amended, and according to 

generally accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based upon our 

audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objectives. 

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Appendix B 

DHS Comments to the Draft Report 

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Appendix C 

AMO and Coast Guard FY 2015 Total Seizure Statistics 

Totals ALL AMO ALL Coast 

Guard 

17 Overlapping 

AMO Units 

17 Overlapping 

Coast Guard 

Units 

Total Drugs (lbs.) 966,886 257,723 46,201* 5,602 

Cocaine 243,387 199,749 4,610 2,633 

Marijuana 719,180 57,855 41,481 2,914 

Ecstasy 477 0 74 0 

Heroin 627 0 11 0 

Methamphetamine 3,191 0 25 0 

Other Drugs** 24 119 0 55 

Currency (millions) $50.1 0 $5.5 0 

Weapons 1,427 0 71 0 

Aircraft 35 0 2 0 

Vehicles 788 0 67 0 

Vessels 113 146 62 4 

Source: AMO and Coast Guard FY 2015 Total Seizure Statistics 

* This figure differs from the number in the report because this includes all seizures from land
 

and maritime operations.
 

** The Coast Guard includes ecstasy, heroin, methamphetamine, and currency in the Other
 

Drugs category.
 

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Appendix D 

Office of Audits Major Contributors to This Report 

Donald Bumgardner, Director/Deputy Assistant Inspector for Audits 

Christine Haynes, Director 

Sean Pettersen, Audit Manager 

Lindsey Koch, Auditor-In-Charge 

Mike Brunelle, Program Analyst 

Priscilla Cast, Program Analyst 

Peter Christopher, Program Analyst 

James Diaz, Program Analyst 

Vashti Young, Program Analyst 

Andrew Herman, Auditor 

Toni Johnson, Auditor 

Elizabeth Argeris, Communication Analyst 

Kevin Dolloson, Communications Analyst 

Michael Staver, Independent Referencer 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Commandant, Coast Guard 

Commissioner, CBP 

Assistant Commissioner, AMO 

Director, ICE 

DHS Component Liaison 

CBP Liaison 

Coast Guard Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

Candice S. Miller, Chairman, Subcommittee on Border and Maritime Security 

Filemon Vela, Ranking Member, Subcommittee on Border and Maritime 

Security 

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