U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division

The Federal Bureau of Prisons’ 

Monitoring of Mail for 

High-Risk Inmates 

September 2006 

Report Number I-2006-009 
U.S. Department of Justice i

Office of the Inspector General 

Evaluation and Inspections Division 

EXECUTIVE SUMMARY 

INTRODUCTION 

The Office of the Inspector General (OIG) conducted this review to 

evaluate how effectively the Federal Bureau of Prisons (BOP) prevents 

terrorist and other high-risk inmates from using the mail to continue or 

encourage criminal behavior, threaten the public, or compromise national 

security. This issue received widespread public attention in March 2005 

when media reports disclosed that three convicted terrorists incarcerated at 

the BOP’s Administrative Maximum (ADX) penitentiary in Florence, 

Colorado, for the 1993 bombing of the World Trade Center wrote 

approximately 90 letters to Islamic extremists between 2002 and 2004.1 

These extremists included Mohamed Achraf, alleged leader of a plot to blow 

up the National Justice Building in Madrid and other inmates who were 

members of a Spanish terror cell with links to other terrorists suspected in 

the March 11, 2004, attacks on commuter trains in Madrid. 

 

The BOP monitors inmate mail to protect the public, BOP staff, and 

inmates from other inmates continuing their criminal activities from prison. 

Terrorist and other high-risk inmates are placed on mail monitoring lists, 

which require that all of their incoming and outgoing mail be read by BOP 

staff. The mail of inmates not on such monitoring lists is read on a random 

basis. When inmate mail is in a foreign language, the BOP may have it 

translated or reviewed by an individual fluent in that language. Because 

many of the BOP staff members who monitor mail also monitor inmates’ 

telephone calls, our review also examined the monitoring of inmates’ verbal 

communications over the telephone, as well as in visiting rooms and in the 

cellblock. To evaluate the BOP’s monitoring activities, the OIG visited 10 

BOP institutions and interviewed staff responsible for the institutions’ 

security and inmate communications monitoring operations. In total, we 

interviewed 163 BOP employees and managers and 16 other persons in the 

Department of Justice (Department). 

RESULTS IN BRIEF 

We found that the BOP has not effectively monitored the mail of 

terrorist and other high-risk inmates. Our review determined that the 

BOP’s monitoring of inmate mail is deficient in several respects: The BOP 

 1 Lisa Myers, “Imprisoned Terrorists Still Advocating Terror,” 

www.msnbc.msn.com/id/7046691, March 1, 2005, and Lisa Myers, “Jihad Letters From 

Prison Went Far, Wide,” www.msnbc.msn.com/id/7140883, March 9, 2005 (March 21, 

2005). 
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does not read all the mail for terrorist and other high-risk inmates on its 

mail monitoring lists, does not have enough proficient translators to 

translate inmate mail written in foreign languages, and does not have 

sufficient staff trained in intelligence techniques to evaluate whether 

terrorists’ communications contain suspicious content.2 Similarly, we 

found that the BOP is unable to effectively monitor high-risk inmates’ verbal 

communications, which include telephone calls, visits with family and 

friends, and cellblock conversations. In addition, the Department does not 

require a review of all international terrorist inmates to identify those who 

should be subjected to Special Administrative Measures (SAMs), the most 

restrictive conditions that can be placed on an inmate’s communications.3 

During interviews with the OIG, BOP managers acknowledged the 

BOP’s responsibility to vigilantly monitor inmate communications. They 

stated that after the ADX Florence incident, the BOP initiated several 

corrective actions and plans to initiate others to improve its monitoring of 

international terrorist communications. For example, the BOP hired fulltime staff to translate Arabic communications, started upgrading its 

intelligence analysis capabilities, and developed policies to limit high-risk 

inmates’ mail and telephone calls. 

However, the Director and BOP managers stated that the BOP cannot 

fully implement the planned initiatives because of budget constraints and 

an increasing inmate population. Consequently, the threat remains that 

terrorist and other high-risk inmates can use mail and verbal 

communications to conduct terrorist or criminal activities while 

incarcerated. 

We now provide a description of our main findings. 

BOP does not read a sufficient amount of inmate mail. 

At each of the 10 institutions we visited, staff members told us that 

their institution does not meet the BOP goal of reading all the mail of 

inmates on the institution’s mail monitoring list to detect terrorism or other 

criminal activity. Furthermore, the staff at those institutions reported wide 

2 Monitoring the mail consists of inspecting for drugs, weapons, explosives, and 

other contraband and reading mail for suspicious content. Our report focused on the 

BOP’s procedures for reading mail. 

3 SAMs are used when there is a substantial risk that communications can lead to 

death or bodily harm. The Attorney General must approve each use of SAMs. 
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Evaluation and Inspections Division 

variations in the amount of mail randomly read for inmates not on mail 

monitoring lists.4 

Mail Monitoring Lists 

Although the BOP has not stated it in written guidance, the BOP 

expects staff to read 100 percent of the mail for inmates on monitoring lists, 

according to the BOP Assistant Director for the Correctional Programs 

Division. However, according to Special Investigative Supervisor (SIS) staff 

at the 10 institutions that we visited, this goal has not been attained.5 In 

fact, at seven of the institutions we visited, SIS staff told us that their 

reading of mail for inmates on mail monitoring lists had decreased during 

the past year. The SIS staff attributed the decrease to the reallocation of 

positions assigned to the SIS office as part of BOP-wide streamlining 

initiatives. SIS staff members stated that with less staff, mail monitoring, 

when combined with other responsibilities such as monitoring inmate 

telephone calls and carrying out investigative duties, is overwhelming. They 

stated that their heavy workload leaves them less time to gather and analyze 

intelligence on inmate activities through reading mail. 

At three institutions we visited, the amount of mail SIS staff 

monitored also was affected by the BOP’s rotational assignment policy. At 

these institutions, some of the mail monitoring was done by telephone 

monitors who assisted permanent SIS staff in performing both telephone 

and mail monitoring. Because the telephone monitor position was a 3-

month rotational assignment, permanent SIS staff had to train a new 

telephone monitor each quarter, which they described as time-consuming.6 

Unlike permanent SIS staff, the rotational staff members were not familiar 

with inmates on the mail monitoring list or with what might be unusual 

content in the inmates’ mail, such as suspicious language, codes, or signs 

that a letter was from another inmate. The steep learning curve for 

rotational SIS officers reduced the amount of communications monitored. 

At the other seven institutions we visited, the BOP’s rotation policy was not 

an issue because the institutions either did not have telephone monitor 

 4 We relied on the statements of staff at the institutions to characterize the amount 

of reading that they perform because the BOP does not collect data on the volume of inmate 

mail sent or received at any institution, the amount of mail of inmates on mail monitoring 

lists that is read, or how much mail is randomly read. 

5 Each BOP institution has an SIS office, which is responsible for advising executive 

staff on security matters, conducting inmate and staff investigations, and gathering 

intelligence through monitoring of inmate communications. 

6 An institution’s Correctional Officers may bid for a rotational assignment. The 

selection for the assignment is based on seniority. 
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Evaluation and Inspections Division 

positions or the incumbents of the telephone monitor positions had 

sufficient seniority to retain the positions. 

At two of the institutions we visited, the temporary assignments of SIS 

staff to cover vacant security posts elsewhere in the institution further 

reduced the level of mail monitoring and intelligence gathering that the SIS 

offices could accomplish. SIS staff stated that as a result, when they were 

able to read the mail it was done in a rushed manner that risked missing 

valuable intelligence. 

 

Federal Bureau of Investigation (FBI) Special Agents assigned to the 

institutions we visited also expressed concern about the reduced level of 

monitoring and staffing in some SIS offices. Much of the agents’ knowledge 

about inmates and leads on potential terrorist and criminal activities came 

from the SIS offices’ monitoring of inmate mail and verbal communications. 

The FBI agents said vigorous monitoring on the part of the BOP is needed to 

obtain important intelligence information about subjects outside the prison 

as well as about inmates. 

Random Reading of Mail

Although the BOP does not track the amount of incoming and 

outgoing mail for inmates who are not on monitoring lists, we found wide 

variations in the amount of mail randomly read at the institutions we 

visited. Random reading of inmate mail, which is done by mailroom staff 

(incoming mail) and Housing Unit Officers (outgoing mail) rather than SIS 

staff, is important to gather intelligence on potential criminal and terrorist 

activity, as well as to identify unusual inmate behavior. Random reading 

also can detect inmates on the mail monitoring list who are attempting to 

circumvent SIS monitoring by using unmonitored inmates to send and 

receive mail for them. 

Despite the importance of random reading, the BOP’s policy for 

inmate correspondence and mail management does not require institutions 

to track the amount of incoming or outgoing mail, does not set targets for 

random reading by staff, and does not require each institution to measure 

the level of random reading achieved. When we asked the institutions we 

visited to track the volume of incoming mail and the amount randomly read 

for a short test period, the reported percentages of mail read varied from 0.3 

percent to 75 percent. 

At seven institutions, mailroom staff told us that the high volume of 

mail, short processing deadlines, and staff reductions have decreased the 

amount of random reading of inmate mail and the amount of suspicious 
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content mailroom staff can identify and refer to the SIS office for follow-up. 

In contrast, outgoing inmate mail is more likely to get read than incoming 

mail. At each of the institutions we visited, Housing Unit Officers on the 

12 a.m. – 8 a.m. shift, when inmate movement and activities are minimal, 

sort, search, and randomly read outgoing mail. These officers have less 

mail volume and more time than day-shift mailroom staff to review the mail 

for both contraband and content.

Capability to translate foreign language mail does not sufficiently 

support monitoring needs. 

Although the BOP is largely responsible for translating inmates’ 

foreign language communications to detect terrorism and other criminal 

activities, its system for translating mail is inadequate.7 The BOP primarily 

uses staff members who volunteer to translate foreign language mail as a 

collateral duty, and it does not have a comprehensive policy that 

(1) provides standard procedures or requirements for staff translations, 

(2) requires staff acting as translators to have a certain level of language 

proficiency and be tested for proficiency, and (3) establishes a procedure to 

randomly review the accuracy of translations. As a result, according to SIS 

staff, BOP volunteer staff translations are inconsistent, translators have 

varying levels of language proficiency, and some translations have been 

faulty. 

Moreover, the BOP does not have enough staff members fluent in 

foreign languages to provide all necessary translations, especially for inmate 

communications in Spanish, the most frequently spoken foreign language. 

The shortage of staff translators is aggravated by the BOP’s inconsistently 

applied and ineffective incentives to motivate staff with needed language 

skills to translate voluntarily, as well as by some supervisors’ lack of 

support for such collateral translation duties. In 2005, the BOP hired its 

first staff members dedicated to translating foreign language inmate 

communications – three full-time Arabic Language Specialists at ADX 

Florence. In late 2005, the BOP began providing intelligence training to 

these Language Specialists to enable them to provide analyses of what they 

translate. 

In an earlier effort to expand its capabilities, the BOP established the 

Language Translation Services Project in 2003 to have international terrorist 

inmates’ foreign language communications translated by General Services 

Administration-approved contract translators. Services under the centrally 

funded contracts are expensive and limited to terrorism inmates’ 

7 The BOP is responsible for translating inmate foreign language communications, 

except for the 34 inmates under SAMs who are the responsibility of the FBI. 
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communications in Middle Eastern and Asian languages. To translate other 

inmate communications, institutions must find and fund any non-BOP 

translation resources themselves. We found that the institutions do not 

always have the money to pay for external translation services, and federal 

agencies such as the FBI that do not require reimbursement for translations 

they provide often do not have enough translators to meet the institutions’ 

needs. 

Intelligence capability to analyze the content of terrorist inmates’ mail 

is not well developed.

We found that the BOP lacks sufficient intelligence capability to 

adequately analyze information from inmate mail to detect terrorist activity. 

Although historically SIS staff members have analyzed intelligence to detect 

and deter traditional criminal activity, they have yet to develop the 

specialized capabilities needed to analyze potential terrorism 

communications. SIS staff members have implemented investigative 

techniques and established relationships with other law enforcement 

agencies that assist them in gathering and analyzing information about 

criminal activity such as the introduction of drugs and gang violence inside 

the prisons. But the methods BOP staff use to analyze intelligence for 

traditional criminal activity are often not sufficient for detecting terrorist 

activity, which entails analyzing communications in uncommon foreign 

languages, understanding extremist ideology and radicalization, 

understanding world-wide terrorism networks, performing link analysis, and 

overseeing the enforcement of SAMs.8 

While the presence of international terrorist inmates in BOP 

institutions makes improving the SIS staff’s ability to detect terrorist activity 

essential, the BOP does not provide the intelligence training needed to 

adequately undertake that work. At the institutions we visited, BOP officials 

and staff told us that staff directly responsible for monitoring terrorist and 

high-risk inmates need additional intelligence training to adequately analyze 

inmate mail for terrorist inmates. We found that the BOP has provided only 

one 3-day course to SIS supervisors in September 2005, two classes that 

contained terrorism information during a mandatory 4-day introductory 

course on investigative practices for all newly appointed SIS Lieutenants, 

and 1 hour of training to all employees during their Annual Refresher 

Training. 

We also found that the BOP has not taken full advantage of the 

greater access to intelligence, information sharing, and resources it can 

8 Link analysis is the process of identifying what relationships exist between objects 

that are not apparent from isolated pieces of information. 
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obtain through federal law enforcement task forces, particularly the FBI’s 

Joint Terrorism Task Forces (JTTF). The BOP took a key step in that 

direction in 1999 when it established Intelligence Operations Officer (IO) 

positions at 12 of its Metropolitan Detention Centers (MDC) and 

Metropolitan Correctional Centers (MCC). The IOs were intended to act as 

the institutions’ link with all federal law enforcement task force operations, 

including the JTTFs. But we found that neither MCC New York nor MDC 

Brooklyn – which both house terrorist inmates – had their IOs serving on 

the local JTTF. The MDC Brooklyn IO was not currently serving as a 

member of the JTTF due to other workload demands and the MCC New York 

IO was only designated to be a liaison on the JTTF. Of five other BOP 

institutions we contacted, two had IOs who were full-time JTTF members; 

the IOs at the other three were part-time members or liaisons.9

Problems affecting the BOP’s monitoring of mail also affect monitoring 

of telephone calls and other verbal communications. 

Similar to the deficiencies we found in the BOP’s mail monitoring, we 

found that the BOP is unable to effectively monitor inmates’ verbal 

communications, including telephone calls, visits with family and friends, 

and cellblock conversations. Because of staffing reductions and the 

limitations of the BOP’s foreign language translation capability, none of the 

institutions we visited consistently met the BOP goal of monitoring 

100 percent of telephone calls for inmates on telephone monitoring lists.10 

Institutions also did not consistently meet Regional Directors’ goals of 

randomly monitoring 10 to 15 percent of other inmates’ calls. For the calls 

that are monitored, many staff members were not adequately trained to 

recognize suspicious content in terrorist inmates’ conversations. We also 

found that because of these same limitations, the BOP did not monitor the 

cellblock conversations of SAMs inmates or the visiting room conversations 

of international terrorist and other high-risk inmates who were not under 

SAMs. In addition, a lack of audio recording equipment was a further 

barrier to recording cellblock and visiting room conversations at most 

institutions. 

9 A member of the JTTF is supervised by and receives assignments from an FBI 

JTTF squad leader. A JTTF liaison is not a participating member of the JTTF, but rather 

only acts as a point of contact. 

10 Institutions can track the volume of inmate telephone calls and the number 

monitored through the electronic telephone system. 
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Evaluation and Inspections Division 

Telephone Monitoring Lists

According to BOP telephone records, 8 of the 10 BOP institutions we 

visited were not consistently meeting the BOP’s goal of monitoring 100 

percent of the conversations of inmates on telephone Alert lists.11 Even the 

country’s highest security federal prison, ADX Florence, which houses the 

most dangerous high-risk inmates, monitored less than 50 percent of the 

calls of inmates on the Alert list in fiscal year (FY) 2005. 

At seven of the institutions we visited, staff members told us that 

three factors reduced the amount of calls being monitored for inmates on 

the Alert and regular telephone monitoring lists along with the amount of 

intelligence gathering and analyses that could be conducted: the rotation of 

staff in the SIS telephone monitor position, the loss of those positions in 

some institutions, and the use of SIS staff to cover vacant security posts 

elsewhere in the institutions. Additionally, as with mail monitoring, 

telephone calls conducted in foreign languages were often not translated 

and therefore not monitored, including calls from inmates on the telephone 

Alert list. BOP staff who conducted telephone monitoring in 5 of the 10

institutions we visited stated that if the institution did not have a staff 

member readily available to translate a foreign language telephone call, it 

was unlikely to get translated, even though calls are recorded. As a result of 

the limited monitoring of Alert and foreign language telephone 

communications, important intelligence information can be missed. 

Random Telephone Monitoring

In addition, we found only three institutions met or surpassed the 

monthly goals set by Regional Directors for randomly monitoring 10 to 

15 percent of all other telephone calls placed by inmates. Random 

telephone monitoring can be conducted by any BOP staff member granted 

access to the telephone system, not just by SIS staff. Nonetheless, most of 

the institutions we visited did not consistently meet their monthly goals. 

Also, according to BOP staff who monitor inmate telephone calls, translation 

of foreign language calls remains a problem during random monitoring. 

Audio Recording of Cellblock Conversations and Visits 

Only one of the four institutions we visited that house SAMs inmates 

recorded those inmates’ cellblock conversations as authorized under federal 

regulations and SAMs procedures. SIS and other management staff at the 

 11 Alert lists are a subset of the telephone monitoring lists and include inmates that 

meet special criteria, including those convicted of terrorist activities. Alert calls trigger a 

signal on the telephone system so that SIS staff know they are to monitor the call “live.” 
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other three institutions stated that while they wanted to monitor such 

cellblock conversations, they were constrained by a lack of equipment, staff, 

and translators. ADX Florence was able to record SAMs inmates’ cellblock 

conversations because the prison already had recording equipment available 

as part of the cellblock construction. 

We also found that the BOP has no guidelines specifying when 

cellblock conversations of SAMs inmates are to be recorded. In addition, 

neither the FBI nor the U.S. Attorneys’ Offices (USAO) for the sites we 

visited had ever requested that the BOP record cellblock conversations of 

SAMs inmates. 

Inmates under SAMs are permitted to have only non-contact visits 

that are recorded and monitored live by the FBI.12 However, terrorist and 

high-risk inmates not under SAMs are permitted contact visits, and none of 

the 10 institutions we visited had the capability to make audio recordings of 

conversations in the institutions’ large contact visiting rooms.13 BOP staff 

stated that inmates realize that their telephone conversations and mail are 

monitored and consequently direct their family and friends to visit because 

they know that audio monitoring is not conducted in the visiting rooms. 

Therefore, BOP staff told us that they want the capability to listen to visiting 

room conversations of selected inmates not under SAMs to detect planned 

terrorist and criminal activities or other inappropriate behavior. 

However, the BOP does not have a policy addressing the recording of 

social visits for non-SAMs terrorist and high-risk inmates to guide 

institutions on when and how to carry out this type of monitoring. Further, 

recording visiting room conversations would be difficult because the rooms 

are often noisy and, without specialized equipment, specific conversations 

would be inaudible among the many other ongoing conversations. In 

addition, the institutions’ limited SIS, visiting room, and translator staff 

members would be further stretched by the additional responsibility of 

recording and listening to contact visit conversations. 

12 Non-contact visits do not allow any physical contact between inmates and their 

visitors. Non-contact visits are conducted in special booths separate from the “contact” 

visiting rooms, and the booths have physical barriers such as glass partitions. Only a 

small number of inmates are required to have non-contact visits: inmates under SAMs and 

inmates whose visitation privileges have been restricted as a result of disciplinary action. 

13 Contact visits allow inmates to meet with visitors without physical barriers 

between them. Limited physical touching is permitted, such as a quick kiss, embrace, or 

handshake at the beginning and end of the visit. Contact visits are conducted in a large, 

open visiting room with numerous inmates and visitors in the room at the same time. 
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Evaluation and Inspections Division 

The Department’s coordination and information sharing for 

international terrorist inmates are inadequate. 

The Department does not have a policy requiring that all inmates 

arrested for international terrorism-related crimes be reviewed to determine 

whether they should be placed under SAMs. Without a requirement for a 

SAMs review, there is no guarantee that international terrorist inmates will 

be considered for SAMs. Consequently, terrorist inmates who pose a risk of 

continuing their terrorist activities may not receive the heightened security 

and communications monitoring they require during pretrial and postconviction incarceration. 

We also found that the FBI’s intelligence gathering and information 

sharing on incarcerated terrorists vary widely among FBI field offices. At 

two of the five FBI offices at the sites we visited, FBI agents conducted little 

to no proactive intelligence gathering regarding the activities of the terrorist 

inmates or inmates described as terrorist associates. For example, the FBI 

agent assigned to ADX Florence did not closely monitor terrorist inmates 

housed at that facility until August 2004 – when Spanish authorities told 

the FBI that the three 1993 World Trade Center bombers housed at the ADX 

had been corresponding with Islamic extremists in Spanish prisons and 

elsewhere. The ADX Florence SIS staff told us that the FBI showed little to 

no interest in the international terrorist inmates prior to that time. We 

believe that better information gathering and intelligence sharing between 

the BOP and the FBI could have identified the need to place those three 

ADX inmates under SAMs. 

Officials at institutions housing SAMs inmates also told us in January 

2006 that they were experiencing backlogs of FBI mail and telephone 

translations for these inmates. SAMs provisions require the FBI to complete 

translations of inmate communications within 60 days. Staff members in at 

least three of the institutions we visited reported delays of 6 to 18 months in 

obtaining Arabic translations of SAMs inmate letters from the FBI. An FBI 

official said the FBI does not have enough Arabic translators to meet the 

demand for translations for all the FBI’s ongoing counterterrorism efforts. 

Consequently, the official said the FBI must prioritize the translation 

workload, which leads to delays in obtaining translations. These delays in 

translations for SAMs inmates pose a security risk because plans for 

terrorist and criminal activities could be communicated to or by inmates 

through the mail or telephone and implemented by outside contacts before 

translations are completed and the intelligence gleaned from them shared. 

Further, staff at MCC New York told us that law enforcement agencies 

and USAOs do not provide adequate information about newly incarcerated 
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Evaluation and Inspections Division 

terrorist inmates to allow the staff to determine the level of mail monitoring 

and other security measures required. The BOP depends on the arresting 

agency and the USAO to provide information on the inmates’ background, 

criminal history, and security threat. However, staff at MCC New York 

reported that they routinely receive pretrial terrorist inmates with little 

background information other than the charges under which the inmates 

are being held. The staff told us that the lack of information about inmates 

puts the security of staff and the institution at risk. 

BOP Initiatives 

 The BOP has several ongoing and proposed initiatives to improve the 

monitoring of communications for terrorist and other high-risk inmates. 

The initiatives include building stronger foreign language translation and 

intelligence analysis capabilities within the BOP, consolidating all terrorist 

inmates in a few institutions in order to concentrate the resources required 

to monitor them, limiting the volume of mail and other types of 

communication available to terrorists or other high-risk inmates, and 

eliminating unsolicited (junk) mail for all inmates. 

Arabic Translators - In 2005 the BOP hired three full-time Arabic 

Language Specialists at ADX Florence. These Language Specialists also are 

available to translate for other institutions. The Language Specialists are 

required to have Top Secret security clearances and be certified proficient in 

Arabic by the FBI. 

Language Translation Software - The BOP is exploring the use of 

language translation software. BOP officials said that although such 

language software is promising, it does not yet meet BOP standards for 

accuracy. Therefore, the BOP plans to use language translation software 

only to initially assess inmate communications in the absence of a qualified 

translator. 

Counterterrorism Unit - The BOP is developing a headquarters-level 

Counterterrorism Unit where four additional full-time Arabic Language 

Specialists will be co-located with BOP Intelligence Analysts. The BOP 

believes that co-locating the Language Specialists will improve the accuracy 

and timeliness of translations of inmate communications. The goals of the 

unit are to consolidate counterterrorism intelligence, produce intelligence 

products for BOP institutions, improve information sharing on terrorism 

matters with the FBI and other federal and state law enforcement agencies, 

and manage BOP translation services. 
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Evaluation and Inspections Division 

Counterterrorism Training - The BOP said it is collaborating with the 

FBI to develop training targeted to the BOP’s specific needs of managing 

high-risk inmates. BOP officials said they are assessing various 

counterterrorism and intelligence training to determine which topics would 

be most applicable to the correctional setting. 

Link Analysis Database - In June 2004, the Intelligence Section at 

BOP headquarters created a terrorist inmate database to conduct link 

analyses. The database includes information on inmate correspondence, 

telephone calls, and financial transactions. The BOP is seeking to enhance 

its link analysis capabilities to include all existing data systems that contain 

inmate information. 

Consolidation of International Terrorist Inmates - The BOP is planning 

to consolidate all international terrorist inmates in approximately six 

institutions for enhanced management and monitoring. The BOP believes 

that this consolidation will allow it to achieve better counterterrorism 

coverage with its limited intelligence, counterterrorism, and translation 

resources, while allowing the remaining institutions to concentrate on gangrelated activity and other prison-based issues. 

Limiting Mail and Verbal Communications - The BOP is developing a 

new policy that would permit it to limit the communications of inmates 

detained or charged with any terrorist-related activity upon request from the 

FBI or other law enforcement agency, or if BOP identifies a need to impose 

such restrictions. Under this policy, the BOP could limit an inmate to 

communicating only with immediate family members, courts, the inmate’s 

attorney, members of Congress, law enforcement agencies, and other 

specified entities. In addition, the BOP is considering other limits on such 

inmates’ communications. As of July 2006, the BOP was coordinating the 

final policy with the Department. 

 The BOP also is developing a policy to limit or eliminate unsolicited 

junk inmate mail. This limitation would reduce the overall volume of mail 

so that institutions could better focus their efforts on inspecting the mail for 

contraband and reading it for evidence of criminal activity. The BOP 

anticipated sending this proposed policy to the Department for review in 

August 2006. 
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Office of the Inspector General 

Evaluation and Inspections Division 

FBI Initiatives 

The FBI Assistant Director for Counterterrorism told us that during 

FY 2005 the FBI sought to identify more systematically where terrorists are 

incarcerated, as well as better monitor their activities and identify who they 

are communicating with. Toward that end, the FBI directed all field offices 

to open case files on all incarcerated international terrorist inmates within 

their jurisdictions. Before this change in policy, the FBI case agent who had 

arrested an inmate was responsible for monitoring that inmate, no matter 

where the inmate was eventually incarcerated. The FBI expected this policy 

change to increase communication between the FBI and the BOP because 

the jurisdiction and responsibility for monitoring international terrorist 

inmates now resides with the FBI office closest to where the prison is 

located. Additionally, the FBI has agreed to assist in training BOP staff in 

counterterrorism issues. 

CONCLUSION AND RECOMMENDATIONS 

Our review found that the BOP has not ensured that mail for terrorist 

and other high-risk inmates on its monitoring lists is consistently read and 

analyzed to detect terrorism, criminal activities, or other inappropriate 

behavior. Although the BOP expects 100-percent monitoring of inmate 

communications for inmates on monitoring lists, we found that BOP 

institutions do not read all the mail for these inmates. The BOP also does 

not have enough trained staff to translate foreign language mail or adequate 

staff trained in terrorism and intelligence techniques to analyze the content 

of mail to and from inmates convicted of terrorism-related offenses. 

The problems that we found with mail monitoring also have 

implications for the BOP’s monitoring of verbal communications. For 

example, BOP institutions do not always monitor the telephone calls of 

inmates on telephone monitoring lists, and as with mail monitoring, the 

foreign language translations and intelligence analyses of inmate telephone 

calls and other communications are not consistently performed. 

Our report contains 15 recommendations to help the BOP improve its 

monitoring capabilities for inmate mail and verbal communications, among 

them: 

• We recommend that the BOP ensures that all mail of inmates on 

its mail monitoring lists is read and that targets are set and 

measured for random reading of other inmate mail, including 

translation of foreign language mail. 
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Office of the Inspector General 

Evaluation and Inspections Division 

• For inmate communications requiring translation, we recommend 

that the BOP issue guidance that establishes procedures for 

conducting quality in-house translations and offer more language 

training, especially in Spanish, to staff who perform collateral 

translation duties. 

• We recommend that the BOP provide advanced and continuing 

counterterrorism intelligence training to its full-time Language 

Specialists, SIS staff, and intelligence staff, and strengthen its 

access to intelligence information through membership on the 

FBI’s Joint Terrorism Task Forces. 

• We recommend that the BOP ensure that all telephone calls of 

inmates on the telephone monitoring lists are monitored, including 

foreign language calls, and that random monitoring of other inmate 

telephone calls includes a target for monitoring a percentage of 

foreign language calls. 

• We recommend that the BOP consider implementing audio 

monitoring of cellblock conversations of all SAMs inmates. In 

addition, we recommend that the BOP issue guidance to its 

institutions that explains how recording cellblock conversations 

and visits will be used within the BOP for detecting, deterring, and 

investigating terrorist and criminal activities. 

• We recommend that the Criminal Division and the National 

Security Division, on behalf of the Department, develop a 

coordinated and mandatory review process for the FBI, USAOs, the 

Criminal Division, and the National Security Division to determine 

applicability of SAMs for all inmates incarcerated for terrorismrelated crimes, pretrial and post-conviction. 
TABLE OF CONTENTS 

LIST OF ACRONYMS

GLOSSARY 

BACKGROUND ......................................................................................1 

SCOPE AND METHODOLOGY OF OIG REVIEW..................................16 

RESULTS OF THE REVIEW.................................................................19 

 

The BOP does not read a sufficient amount of inmate mail....19

The BOP does not read all the mail of inmates on 

SIS mail monitoring lists....................................................19 

The BOP does not adequately manage the amount 

of mail for inmates that is randomly read...........................22 

The BOP does not track the amount of incoming or 

outgoing foreign language mail or maintain data on 

the foreign languages that inmates use..............................27 

Developments and future plans .........................................27 

Recommendations .............................................................28 

The BOP’s capability to translate foreign language 

mail does not sufficiently support monitoring needs..............29

The BOP does not have agency-wide standard 

procedures for conducting in-house translations ...............30 

The BOP volunteer staff who translate inmate 

communications are not subject to language proficiency 

requirements, and the BOP has no policy requiring 

translations be checked for accuracy .................................33 

The BOP does not have enough staff to translate inmate 

communications, especially for inmate communications 

in Spanish.........................................................................34 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
The BOP does not offer effective incentives to motivate 

staff with needed language skills to translate voluntarily 

and some supervisors do not support translating as a 

collateral duty ...................................................................35 

The BOP does not offer sufficient intelligence training 

to full-time Language Specialists .......................................37 

The Language Translation Services Project is a 

valuable but limited resource for institutions that house 

international terrorist inmates...........................................38 

Developments and future plans .........................................41

Recommendations .............................................................43 

 Intelligence capability to analyze the content of 

 terrorist inmates’ mail is not well developed ..........................44 

The BOP does not provide its SIS staff with the 

intelligence training needed to adequately monitor 

terrorist inmate mail..........................................................44 

The BOP does not take full advantage of existing access 

to information and intelligence through its Intelligence 

Operations Officers............................................................48 

Developments and future plans .........................................50 

Recommendations .............................................................51 

ADDITIONAL ISSUES ..........................................................................52 

The BOP does not monitor a sufficient amount of inmate 

telephone calls ..........................................................................52 

Alert telephone calls of terrorist and other high-risk 

inmates are not always monitored .....................................53 

Telephone calls of other inmates on telephone 

monitoring lists are not consistently monitored..................54 

The frequent rotation of telephone monitors and the 

reallocation of some positions in the SIS offices reduce 

intelligence gathering and analysis ....................................54 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
Translation of foreign language telephone calls is 

sporadic ............................................................................56 

Although some institutions meet or exceed their goals 

for random telephone monitoring, random monitoring 

is still inconsistent ............................................................57 

Developments and future plans .........................................58 

Recommendations .............................................................58 

Audio recording of cellblock conversations of SAMs 

inmates occurs at only one institution....................................58 

 

Recommendation...............................................................59 

The BOP has limited capability to monitor conversations 

of terrorist and other high-risk inmates during social 

visits..........................................................................................59 

Recommendation...............................................................60 

The Department does not have a mandatory review 

process to require that all international terrorist inmates 

are considered for SAMS upon initial incarceration and 

after conviction.........................................................................61 

The FBI’s intelligence gathering on terrorist inmates and 

information sharing with BOP institutions are inconsistent ..62 

MCC New York does not receive adequate information 

about newly incarcerated terrorist inmates to determine 

required monitoring..................................................................66 

Recommendations ....................................................................67 

CONCLUSION ......................................................................................68 

APPENDIX I: BOP PROGRAM STATEMENT 5265.11, POLICY 

FOR REJECTING INMATE CORRESPONDENCE.....70 

APPENDIX II: JOB DUTIES OF SIS POSITIONS ............................71 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
APPENDIX III: INMATE RESTRICTIONS AND FBI 

RESPONSIBILITIES RELATED TO SPECIAL 

ADMINISTRATIVE MEASURES...............................75

APPENDIX IV: THE FEDERAL BUREAU OF PRISONS’ 

 RESPONSE...............................................................77 

APPENDIX V: OIG’S ANALYSIS OF THE FEDERAL BUREAU 

 OF PRISONS’ RESPONSE ........................................86 

APPENDIX VI: THE CRIMINAL DIVISION’S RESPONSE.................94 

APPENDIX VII: OIG’S ANALYSIS OF THE CRIMINAL DIVISION’S 

 RESPONSE ..............................................................96 

APPENDIX VIII: THE FEDERAL BUREAU OF INVESTIGATION’S 

 RESPONSE ..............................................................99 

APPENDIX IX: OIG’S ANALYSIS OF THE FEDERAL BUREAU 

OF INVESTIGATION’S RESPONSE........................100 

 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
LIST OF ACRONYMS 

ADX Administrative Maximum Facility 

ATAC Anti-Terrorism Advisory Council 

BOP Federal Bureau of Prisons 

CTS Counterterrorism Section 

FBI Federal Bureau of Investigation 

FCI Federal Correctional Institution 

FDC Federal Detention Center 

FY Fiscal Year 

GSA General Services Administration 

INTRUDR Inmate Trust Fund Digital Recorder 

IO Intelligence Operations Officer 

ISM Inmate Systems Management 

ISO Inmate Systems Officer 

JTTF Joint Terrorism Task Force 

LSCI Low Security Correctional Institution 

MCC Metropolitan Correctional Center 

MDC Metropolitan Detention Center 

NCIC National Crime Information Center 

NJTTF National Joint Terrorism Task Force 

OEO Office of Enforcement Operations 

OIG Office of the Inspector General 

R&D Receiving and Discharge 

SAMs Special Administrative Measures 

SIS Special Investigative Supervisor 

USAO U.S. Attorney’s Office 

USP U.S. Penitentiary 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
GLOSSARY 

Bid Position – A bid position is a post in which a BOP Correctional Officer 

can make a request for assignment. Post assignments are generally based 

on seniority. 

BOP Administrative Facilities – Administrative facilities are institutions 

with special missions, such as the detention of pretrial offenders; inmates 

with serious medical problems; or the containment of extremely dangerous, 

violent, or escape-prone inmates. Administrative facilities include 

Metropolitan Correctional Centers, Metropolitan Detention Centers, Federal 

Detention Centers, and Federal Medical Centers, as well as the 

Administrative Maximum U.S. Penitentiary at Florence, Colorado. 

Administrative facilities are capable of holding inmates in all security 

categories. 

 

BOP Intelligence Operations Officer (IO) – The IO position exists at BOP 

institutions in select metropolitan areas such as the Metropolitan 

Correctional Centers and Metropolitan Detention Centers. This 

management-level position is supervised by the Intelligence Operations 

Officer (IO) located at the BOP Central Office in Washington, D.C. The IO 

works with law enforcement agencies and the courts to obtain information 

regarding inmates pending indictment or already in BOP custody. The 

information is to be used for determining the inmate’s security risk to the 

BOP and the public. 

BOP Unit Manager – The Unit Manager directs and manages an inmate 

housing unit and is responsible for the unit’s operation and security. The 

Unit Manager also is responsible for planning, developing, implementing, 

supervising, and coordinating individual programs for inmates, such as 

educational and vocational training, substance abuse treatment, 

counseling, and medical and health treatment. 

Joint Terrorism Task Force (JTTF) – JTTFs are squads within the FBI’s 

field and select resident agency offices that focus primarily on addressing 

terrorism threats and preventing terrorist incidents. JTTFs are operational 

units that respond to terrorism leads and conduct terrorism investigations. 

The JTTFs pool the resources and expertise of multiple law enforcement 

agencies, federal, state, and local, to collect and share counterterrorism 

intelligence. 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
JTTF Liaison – A JTTF liaison is not a participating member of the JTTF, 

but rather acts as a point-of-contact for an agency and may periodically 

attend JTTF meetings. 

JTTF Member – A member of the JTTF is supervised by and receives 

assignments from an FBI JTTF squad leader. These assignments could 

include assisting the JTTF in developing leads, conducting investigations, 

interviewing subjects, providing intelligence to the FBI on BOP inmates, and 

planning strategies for investigations to be conducted inside the BOP. 

Link Analysis – Link analysis is the process of identifying what 

relationships exist between objects that are not apparent from isolated 

pieces of information. 

Metropolitan Correctional Centers (MCC) and Metropolitan Detention 

Centers (MDC) – MCCs and MDCs are administrative facilities 

housing federal male and female inmates of all security levels who are 

primarily pretrial and holdover inmates (i.e., they have been convicted but 

are being held temporarily for a federal court appearance). 

National Crime Information Center (NCIC) – NCIC is a computerized index 

of criminal justice information (i.e., information on criminal histories, 

fugitives, stolen properties, missing persons, foreign fugitives, immigration 

violators, violent gangs, and terrorist organizations) maintained by the FBI. 

National Joint Terrorism Task Force (NJTTF) – The NJTTF is a multiagency task force run by the FBI with representatives from the intelligence, 

law enforcement, defense, diplomatic, public safety, and homeland security 

communities. The NJTTF provides administrative, logistical, policy, 

financial, and training support and guidance to the JTTFs. According to the 

FBI, the NJTTF serves as the “point of fusion” for terrorism intelligence for 

the JTTFs, member agencies, and others in the intelligence community. 

U.S. Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

 
U.S. Department of Justice 1

Office of the Inspector General 

Evaluation and Inspections Division 

BACKGROUND 

In March 2005, news media reports revealed that three convicted 

terrorists, Mohammed Salameh, Mahmud Abouhalima, and Nidal Ayyad, 

incarcerated at the Federal Bureau of Prisons’ (BOP) Administrative 

Maximum facility (ADX) in Florence, Colorado, for the 1993 bombing of the 

World Trade Center, wrote over 90 letters to Islamic extremists outside the 

prison between 2002 and 2004.14 These extremists included inmates who 

are members of a Spanish terror cell with links to other terrorists suspected 

in the March 11, 2004, terrorist attacks on Madrid commuter trains. One of 

the letters from Salameh was found in the possession of Mohamed Achraf, 

described as the leader of a radical Muslim cell, who was charged in October 

2004 in Spain for plotting to blow up the National Justice Building in 

Madrid, which is Spain’s “nerve center” for investigating Islamic terror.15 

Salameh also praised Osama bin Laden as a hero in a letter sent to Arabic 

newspapers. According to the March 2005 news reports, at least 14 letters 

were exchanged between the three terrorists in ADX Florence and the 

Spanish terror cell. In addition, 1 of the 17 people arrested in Spain for 

recruiting suicide operatives used these letters in his recruitment efforts. 

One of the news articles reported that a BOP employee who translated some 

high-profile terrorism communications warned in 2003 that many “Arabic 

letters and phone calls are unmonitored due to a lack of Arabic-speaking 

staff.”16

 

The Office of the Inspector General (OIG) conducted this review to 

evaluate how effectively the BOP prevents terrorist and other high-risk 

inmates from using the mail or the cover of a foreign language to continue 

or encourage criminal behavior, threaten the public, or compromise national 

security. Because many of the BOP staff members who monitor mail also 

monitor the inmates’ telephone calls, our review also examined the 

monitoring of inmates’ verbal communications. 

 14 Lisa Myers, “Imprisoned Terrorists Still Advocating Terror,” 

www.msnbc.msn.com/id/7046691, March 1, 2005, and Lisa Myers, “Jihad Letters From 

Prison Went Far, Wide,” www.msnbc.msn.com/id/7140883, March 9, 2005 (March 21, 

2005). 

15 Associated Press, “Spain Says Terrorist Plotted ‘Biggest Blow,’ ” October 20, 

2004, www.msnbc.msn.com/id/6282532 (March 6, 2006). 

16 We interviewed the employee and obtained a copy of the memorandum he sent to 

his Warden in 2003 stating that Arabic communications were unmonitored because of a 

lack of Arabic-speaking staff in the BOP. In this memorandum, he proposed that the BOP 

direct all inmate correspondence and telephone calls in Arabic to three Arabic-speaking 

BOP staff for translation. He never received a response to his proposal. 
U.S. Department of Justice 2

Office of the Inspector General 

Evaluation and Inspections Division 

 

The BOP’s Mission, Operations, and General Inmate Monitoring 

Procedures 

 

The stated mission of the BOP is to protect society by confining 

offenders in safe, humane, cost-efficient, and appropriately secure prisons 

and community-based facilities that provide self-improvement opportunities 

that assist them in becoming law-abiding citizens.17 As of July 2006, the 

BOP reported an inmate population of 191,224, an increase of 70 percent 

from 10 years ago when the population was at 112,289.18 The number of 

high-risk inmates who have been identified as needing heightened security 

monitoring, such as gang leaders, gang members, international and 

domestic terrorists, also has increased over the last 10 years by 

approximately 60 percent. As of July 2006, the BOP had identified 19,720 

such inmates. During this same 10-year time period, the number of BOP 

staff grew at a more modest rate of 14 percent, from 30,212 to 34,655.19 

The BOP has a sizable percentage of foreign-born inmates and 

inmates of Hispanic ethnicity. As of June 2006, 21.1 percent of inmates 

were foreign citizens of Spanish-speaking countries, 6.0 percent were listed 

as foreign citizens of other countries (non-Spanish-speaking) or unknown 

citizenship, and 31.5 percent of the inmate population was of Hispanic 

ethnicity (whether U.S. citizens or foreign citizens).20 

Based on security and program needs, an inmate is assigned to a 

particular BOP institution with an appropriate security level. An 

institution’s security level is based on such features as the presence of 

external patrols, towers, security barriers, or detection devices; the type of 

housing within the institution; internal security features; and the staff-toinmate ratio.21 As of June 2006, the breakdown of the BOP’s inmate 

population at each security level was: minimum, 18.7 percent; low, 

17 BOP, State of the Bureau 2005, p. 5. 

18 BOP, Weekly Population Report, July 27, 2006, 

www.bop.gov/locations/weekly_report.jsp (July 27, 2006), and BOP, State of the Bureau 

1997, www.bop.gov/news/PDFs/sob97.pdf (May 5, 2006). 

19 State of the Bureau 1997, BOP, www.bop.gov/news/PDFs/sob97.pdf (May 5, 

2006), and “Quick Facts About the Bureau of Prisons,” June 24, 2006, 

www.bop.gov/about/facts.jsp (July 14, 2006). 

20 BOP, “Quick Facts About the Bureau of Prisons,” June 24, 2006, 

www.bop.gov/about/facts.jsp#1 (July 14, 2006). 

 

21 BOP, “Prison Facilities, Prison Types, General Information,” 

www.bop.gov/locations/institutions/index.jsp (March 9, 2006). 
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Evaluation and Inspections Division 

39.6 percent; medium, 26.3 percent; high, 10.3 percent; and unclassified, 

4.9 percent.22

Inmate Communications

 While in BOP custody, inmates are granted certain communication 

privileges to maintain family and community ties. According to BOP policy, 

Contact with the public is a valuable tool in the overall 

correctional process. Toward this objective, the Bureau 

provides inmates with several means of achieving such 

communication. Primary among these is written 

correspondence, with telephone and visiting privileges 

serving as two supplemental methods.23 

 The BOP has established rules governing use of communication 

privileges, and various staff members in the BOP institutions are 

responsible for monitoring these communications to ensure that inmates 

adhere to the rules and do not use any communication method to carry out 

criminal behavior or behavior that would be considered a threat to the 

security of the institution or the public. To monitor inmate 

communications, institutions develop mail and telephone monitoring lists of 

high-risk inmates, terrorists, and other inmates who are suspected of 

criminal or suspicious activity. According to the BOP Assistant Director for 

the Correctional Programs Division, the BOP’s goal is to monitor 

100 percent of the mail and telephone communications for the inmates 

placed on these monitoring lists. 

Mail. The BOP encourages correspondence that is directed to socially 

useful goals. Inmates are therefore permitted to send and receive, with 

minimal restrictions, correspondence to and from family, friends, or anyone 

in the community.24 Inmates also can receive a variety of publications such 

as newspapers, magazines, and periodicals. The BOP’s limited restrictions 

on inmate mail are consistent with American Correctional Association 

standards, which state: 

 22 The BOP also has administrative facilities with special missions, such as the 

detention of pretrial offenders, inmates with serious medical problems, or inmates who are 

extremely dangerous, violent, or escape-prone. The administrative facilities are designed to 

securely house all security-level inmates. 

23 BOP, Telephone Regulations for Inmates, Program Statement 5264.07, 

January 31, 2002. 

24 BOP, Correspondence, Program Statement 5265.11, July 9, 1999. 
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Evaluation and Inspections Division 

 

When the inmate bears the mailing cost, there is no limit on the 

volume of letters the inmate can send or receive or on the 

length, language, content, or source of mail or publications 

except when there is reasonable belief that limitation is 

necessary to protect public safety or institutional order and 

security. 25 

Inmate correspondence, however, can be rejected by the BOP based 

on the content of the correspondence. Federal regulation 

28 C.F.R. § 540.14d (2002) and BOP policy authorize prison officials to 

review and reject inmates’ incoming and outgoing correspondence “if it is 

determined detrimental to the security, good order, or discipline of the 

institution, to the protection of the public, or if it might facilitate criminal 

activity.” See Appendix I for the BOP’s policy on rejecting inmate 

correspondence. 

To protect the security of its institutions, the BOP has the authority to 

inspect and read all inmate mail. Inspection of mail is intended to detect 

drugs and other contraband while reading inmate mail is intended to reveal, 

for example, plans to commit criminal acts.26 According to BOP policy, staff 

are required to open and inspect all incoming mail prior to distributing it to 

the inmates. Additionally, all incoming general correspondence is subject to 

random reading by staff.27 Inmates are notified in writing upon arrival at 

an institution that the BOP has the authority to open all mail addressed to 

inmates. If the inmate does not agree to this requirement, any mail 

subsequently received for that inmate is returned to the post office. In 

addition, a BOP Warden may place an inmate on restricted general 

correspondence based on a misconduct or security needs.28 

All outgoing mail in medium- and high-security and administrative 

institutions is subject to random reading by staff. Outgoing mail from 

inmates in minimum- or low-security institutions may be sealed by the 

inmate and not read by staff unless:

25 ACA Standard 4-4488, Standards for Adult Correctional Institutions, 4th edition, 

2003. American Correctional Association standards are considered the national 

benchmark for the effective operation of correctional systems throughout the United States. 

26 BOP, Mail Management Manual, Program Statement 5800.10, November 3, 1995. 

27 BOP, Mail Management Manual, Program Statement 5800.10. Legal and other 

specified special mail is opened and processed in the presence of the inmate. 

28 Restricted correspondence is general correspondence that is limited to a list of 

authorized correspondents, such as the inmate’s immediate family. 
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Office of the Inspector General 

Evaluation and Inspections Division 

 

• The correspondence would interfere with the orderly running of the 

institution, be threatening to the recipient, or facilitate criminal 

activity. 

• The inmate is on a restricted correspondence list. 

• The correspondence is between inmates. 

• The envelope has an incomplete return address.29

According to BOP policy, inmates are prohibited from corresponding 

with inmates in other correctional institutions, unless the proposed 

correspondent is a member of the inmate’s immediate family or is a party or 

witness in a legal action in which both inmates are involved. In each 

instance, the inmate’s Unit Manager must approve the correspondence, and 

the approval of the Wardens of both institutions is required if one of the 

inmates is housed at a non-federal institution.30 

Telephone. The BOP extends telephone privileges to inmates as part 

of its overall correctional management. The BOP considers telephone 

communications “a supplemental means of maintaining community and 

family ties that contribute to the inmate’s personal development.”31 

Inmates may submit up to 30 telephone numbers on their official Telephone 

Number Request Form.32 The numbers may be of immediate family 

members or anyone else they choose, with the understanding that these 

calls will be monitored. Inmates are issued an individual personal access 

number and are allowed up to 300 minutes of calls per month to the 

numbers listed on their forms, with each call generally limited to 15 

minutes. Inmates are responsible for the expense of telephone use. 

 

The BOP can impose limitations and conditions on an inmate’s 

telephone privileges to ensure the safety, security, and good order of the 

29 BOP, Correspondence, Program Statement 5265.11, July 9, 1999, pp. 9-10. 

30 A Unit Manager directs and manages an inmate housing unit and is responsible 

for the unit’s operation and security. The Unit Manager also is responsible for planning, 

developing, implementing, supervising, and coordinating individual programs for inmates. 

31 BOP, Telephone Regulations for Inmates, Program Statement 5264.07, 

January 31, 2002. 

32 An Associate Warden may authorize the placement of additional numbers on the 

list based on the inmate’s individual situation, such as the size of the inmate’s family. 
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Office of the Inspector General 

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institution or to protect the public.33 Unit management staff are 

responsible for reviewing the inmate’s telephone list and verifying that the 

numbers belong to the individuals listed. The Associate Warden may deny 

placement of a telephone number on the inmate’s list if the Associate 

Warden determines that there is a threat to institution security or public 

safety. All inmate calls are recorded and subject to monitoring. The BOP 

may restrict telephone privileges for any inmate who violates its telephone 

policy, such as by using the telephone to engage in criminal activity. 

Visits. Inmates are permitted visits by family, friends, and community 

groups. Inmates are required to submit a list of proposed visitors to their 

unit management staff. Although there are no limitations on the number of 

family members on the list, an inmate’s visiting list is generally limited to no 

more than 10 friends and associates.34 

BOP staff are required to obtain background information on potential 

visitors who are not immediate family members before placing them on the 

inmate’s approved visitor list in medium- and high-security and 

administrative institutions. If insufficient background information is 

available, visiting may be denied. The BOP conducts National Crime 

Information Center (NCIC) checks as part of the background investigations 

on proposed visitors.35 Visits may be restricted or suspended for violation of 

the visiting guidelines or if an inmate’s behavior indicates that the inmate 

would be a threat to the security of the visiting room. 

Foreign Language Translation Services

The BOP cannot identify how many of its inmates communicate in a 

foreign language. However, approximately 27 percent of the total BOP 

inmate population comprises non-U.S. citizens, and some portion of these 

inmates’ written and verbal communications requires translation for 

monitoring purposes. The BOP primarily uses three sources for translation 

services: volunteer staff members, three full-time staff Language Specialists, 

and outside contractors. 

 33 BOP, Telephone Regulations for Inmates, Program Statement 5264.07, 

January 31, 2002. 

34 BOP, Visiting Regulations, Program Statement 5267.07, April 14, 2003. 

35 NCIC is a computerized index of criminal justice information (criminal record 

history information, fugitives, stolen properties, missing persons, foreign fugitives, 

immigration violators, violent gang and terrorist organizations) maintained by the FBI. 

 
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Office of the Inspector General 

Evaluation and Inspections Division 

The BOP relies mainly on staff who volunteer to translate foreign 

language communications as a collateral duty.36 The names of these 

volunteers are listed in a BOP Directory of Translators, which is distributed 

to all institutions. The BOP also has three full-time Arabic Language 

Specialists at ADX Florence, hired in 2005, whose services are available to 

other BOP institutions as well. To procure translation services from outside 

contractors for what it deemed “exotic” languages, the BOP created the 

Language Translation Services Project in 2003.37 Intended to address the 

increase in the number of international terrorist inmates whose foreign 

language communications required translations, the project uses 

contractors approved by the General Services Administration (GSA). In 

addition, the BOP can use outside sources, such as universities or other law 

enforcement agencies, for translations. 

Special Investigative Supervisor Office Monitoring Responsibilities

Every BOP institution has a Special Investigative Supervisor (SIS) 

office, which is responsible for advising executive staff on security matters, 

setting security policy, conducting inmate and staff investigations, and 

gathering intelligence through monitoring of inmate communications. 

In each BOP institution, at least one lieutenant is assigned to carry 

out the SIS responsibilities. In most institutions the position is either a GS12 Special Investigative Agent or a GS-11 Lieutenant (SIS Lieutenant) who 

has successfully completed Advanced Lieutenant’s training, SIS training, 

and a minimum of 6 months as a shift supervisor at the assigned 

institution. The Special Investigative Agent position is non-rotational, but 

SIS Lieutenants ordinarily rotate at 18-month intervals. The Warden has 

the authority to assign additional staff to the SIS office.38 SIS Technicians, 

Intelligence Research Specialists, or Inmate Telephone Monitors are 

assigned to the SIS office according to an individual institution’s staffing 

level. The duties of each SIS position are described in Appendix II. 

 To monitor inmate communications, SIS offices develop mail and 

telephone monitoring lists. The names of high-risk, terrorist, and other 

 36 The FBI, not the BOP, translates foreign language mail and telephone calls for 

inmates under Attorney General Special Administrative Measures, which are discussed 

later in the report. 

37 The BOP defines “exotic” languages as Middle Eastern, Pacific Island, and South 

Asian languages. 

38 BOP, Role Authority and Scope of SIS Duties, Program Statement 1380.05, 

Chapter 1, August 1, 1995, p. 1. 
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inmates who are suspected of criminal or suspicious activity within the 

institution are placed on the lists, and according to SIS staff, all their mail 

and telephone communications are to be monitored. The BOP Central 

Office, through various memorandums, requires 100-percent mail and 

telephone monitoring for the inmates on these lists. In addition, the BOP 

Assistant Director for the Correctional Programs Division stated in our 

interview with him that the BOP expects 100 percent monitoring of mail and 

telephone communications for these inmates. 

Mail. The SIS office at each institution is responsible for reading all 

outgoing and incoming mail of inmates on the mail monitoring list, as well 

as reading mail identified as suspicious through random reading 

accomplished by mailroom staff and housing unit officers. 

Telephone. SIS staff monitor inmate telephone calls through the 

following three methods:

1. Telephone monitoring list – SIS staff at each institution develop a 

telephone monitoring list as a tool to monitor inmates under 

investigation, those suspected of engaging in criminal activity or 

violations of institutional rules, or based on prior behavior. The 

SIS office adds other inmates to the list based on information or 

intelligence it gathers from internal or external sources that 

indicates a need for monitoring. Many of the inmates who are on 

the telephone monitoring list also are on the mail monitoring list. 

The BOP Assistant Director for the Correctional Programs Division, 

and SIS staff told us that the goal is to monitor 100 percent of the 

inmates on the telephone monitoring list. 

2. Alert list – As a subset of the telephone monitoring list, some SIS 

offices maintain an Alert list for specific high-risk inmates.39 

When these inmates make a telephone call, a symbol appears on 

the Inmate Trust Fund Digital Recorder (INTRUDR) system to alert 

staff that this inmate is currently on the telephone.40 To the 

extent possible, Alert calls are to be listened to live; if staff are 

unable to listen live, they must listen to the recorded call later. 

The BOP goal is to monitor 100 percent of the calls of inmates on 

the Alert list. 

 39 Some institutions, such as MDC Brooklyn and MCC New York, have a single 

telephone monitoring list, which they refer to as their “Alert” list. 

40 INTRUDR records all inmate telephone calls, except calls to the inmates’ 

attorneys. During fiscal year (FY) 2005, INTRUDR recorded more than 39.3 million inmate 

calls. BOP staff randomly monitored about 5.5 million (14 percent) of these calls. 
U.S. Department of Justice 9

Office of the Inspector General 

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3. Random monitoring – Each of the BOP Regional Directors 

establishes a percentage of inmate phone calls to be randomly 

monitored by the institutions in their region. Generally, 

institutions are required to monitor between 10 and 15 percent of 

all inmate calls per month. INTRUDR tracks the number of calls 

monitored and the identity of the staff members performing the 

monitoring.41 SIS staff oversee random telephone monitoring. 

Inmate Systems Management and Housing Unit Officers Mail Monitoring 

Responsibilities

The Inmate Systems Management (ISM) department in an institution 

supervises mailroom operations to ensure the timely processing and 

handling of inmate and official mail. Mail service is provided to inmates 

Monday through Friday. ISM staff are responsible for ensuring that all 

incoming and outgoing letter mail is ordinarily processed within 24 hours, 

and incoming and outgoing packages processed within 48 hours, excluding 

weekends and holidays. Staff are not required to keep records on the 

volume of outgoing and incoming mail processed. ISM staff are required to 

open and inspect all incoming mail for contraband (unauthorized material) 

prior to distribution. They open all incoming packages in an outside 

storeroom or warehouse (except at minimum-security institutions). 

Inspection of mail may include the use of x-ray machines, metal detectors, 

and manual or visual inspection. By BOP policy, all incoming 

correspondence is subject to random reading by ISM staff. The ISM staff 

also is responsible for separating the incoming mail of inmates on the mail 

monitoring list and forwarding that mail to the SIS office for reading and 

analysis, along with any other mail randomly read that contains suspicious 

content. 

In addition to mailroom operations, the ISM department includes the 

inmate records management and the receiving and discharge (R&D) 

functions. The staff who work in the mailroom and R&D are called Inmate 

Systems Officers (ISO). The ISOs generally rotate between assignments in 

 41 The goals developed by the Regional Directors for random telephone monitoring 

are as follows: Northeast Region, 10 percent; Mid-Atlantic Region, 15 percent; Southeast 

Region, 15 percent; North Central Region, 10 percent; South Central Region, 15 percent; 

Western Region, 15 percent. In addition to SIS staff, at some institutions Counselors, Unit 

Managers, Associate Wardens, and other staff have access to INTRUDR from their desktop 

computers. At one type of institution, U.S. Penitentiaries, primarily tower officers listen to 

inmate telephone calls. There are no set procedures for randomly selecting inmate 

telephone calls to monitor. 
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the mailroom or R&D functions for fixed periods of time.42 On heavy mail 

volume days, such as Mondays or around holidays, or when the mailroom is 

short-staffed, the mailroom enlists staff from the other ISM functions to help 

process the mail and ensure timely delivery. 

Housing Unit Officers on the 12 a.m. to 8 a.m. “morning watch” shift 

inspect and randomly read outgoing inmate mail.43 They set aside and 

deliver letters from inmates on the mail monitoring list to the SIS staff for 

reading and analysis. If they find suspicious content while randomly 

reading other inmates’ letters, they deliver these letters to the SIS office as 

well. 

Figure 1 outlines the mail processing procedures for outgoing and 

incoming inmate mail. 

42 R&D duties include processing inmate admissions and releases, including 

identification (photography and fingerprints), data entry, and inmate property. 

43 The BOP has not established procedures for conducting “random reading.” 
Figure 1: BOP Institution Inmate Mail Processing Procedures 

Inmate Systems Officers 

(ISO) separate and 

process the previous 

day’s outgoing mail from 

inmates and staff. 

An ISO delivers the 

outgoing mail to 

the local U.S. Post 

Office each 

weekday. 

The ISO brings back to 

the institution incoming 

mail from the Post 

Office. 

ISO checks each 

package against the 

“approval list.” 

ISO sets aside mail 

for inmates who 

are on the SIS mail 

monitoring list. 

ISO randomly 

reads some 

incoming inmate 

mail, if time 

permits. 

ISO reseals envelope 

and delivers mail to the 

inmates the same day if 

no suspicious content is 

found. 

At the institution, staff 

conduct an x-ray 

inspection of all mail to 

screen for weapons 

and explosives. 

ISO matches each piece 

of mail individually 

against the inmate 

roster, reviews return 

addresses and checks 

for contraband. 

Mail for inmates on 

the mail monitoring 

list and any 

suspicious mail is 

forwarded to SIS. 

Unapproved 

packages are 

returned to the 

Post Office. 

Housing Unit 

Correctional Officer 

gathers inmate mail 

from mailboxes. 

The officer inspects 

each envelope for 

contraband. 

Outgoing Mail Incoming Mail

The officer separates 

mail from inmates on 

the SIS mail 

monitoring list and 

sets it aside. 

The officer 

randomly reads the 

general population 

mail. 

Mail from inmates on 

mail monitoring and any 

suspicious mail are 

forwarded to SIS. 

The officer seals 

the envelopes and 

delivers the mail to 

the mailroom. 

U.S. Department of Justice 11

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 12

Office of the Inspector General 

Evaluation and Inspections Division 

 

Monitoring Through Special Administrative Measures 

Special Administrative Measures (SAMs), approved by the Attorney 

General, may be applied to inmates whose communications require more 

restrictive conditions. SAMs, developed in May 1996 and overseen by the 

Department’s Office of Enforcement Operations (OEO) within the Criminal 

Division, serve two purposes: 

• Under 28 C.F.R. § 501.2 (1997), to prevent the unauthorized 

disclosure of national security information (classified information); 

and 

• Under 28 C.F.R. § 501.3 (1997), to prevent acts of violence and 

terrorism.44 

The Attorney General may authorize the BOP Director to implement 

SAMs upon written notification to the BOP, 

That there is a substantial risk that a prisoner’s 

communications or contacts with persons could result in death 

or serious bodily injury to persons, or substantial damage to 

property that would entail the risk of death or serious bodily 

injury to persons.45 

The C.F.R. further states: 

These SAMs ordinarily may include housing the inmate in 

administrative detention and/or limiting certain privileges, 

including but not limited to, correspondence, visiting, 

interviews with representatives of the news media, and use of 

the telephone, as is reasonably necessary to protect persons 

against the risk of acts of violence or terrorism.46

44 The OEO oversees the use of investigative tools, such as SAMs, all federal 

electronic surveillance requests, and requests to apply for court orders permitting the use 

of video surveillance. The OEO also reviews requests by federal agencies to use federal 

prisoners for investigative purposes and reviews the transfer of prisoners to and from 

foreign countries to serve the remainder of their prison sentences. 

45 28 C.F.R. § 501.3 (1997). 

46 28 C.F.R. § 501.3 (1997). 
Relationship of the FBI to the BOP 

Under 28 U.S.C. § 533, the FBI shares 

responsibility for investigating crimes on 

federal property, including federal prison 

facilities. (The OIG also has authority and 

responsibility to investigate allegations 

regarding BOP employees and contractors.) 

Each BOP institution has an FBI Special 

Agent assigned to investigate crimes that 

occur within the prison. Depending on the 

size of the FBI field or resident agency office, 

the prison, and the workload, the FBI may 

assign one agent to cover criminal issues and 

a second agent to handle terrorism issues. 

Criminal cases are investigated by local FBI 

Special Agents with oversight by the Criminal 

Investigative Division at FBI headquarters. 

BOP terrorism cases are investigated by the 

local Joint Terrorism Task Force, with 

oversight by the Counterterrorism Division at 

FBI headquarters. 

Because of the numbers of pretrial inmates at 

BOP Metropolitan Correction Centers and 

Metropolitan Detention Centers, numerous 

FBI agents interact with the BOP as case 

agents at these facilities. These case agents 

are responsible for communicating and 

coordinating with the BOP concerning these 

pretrial inmates. 

Inmates who are under SAMs are restricted to communications and 

visits with only immediate family members, and all such social 

communications are monitored by the FBI. The BOP forwards all mail to 

and from the SAMs inmates to the FBI for analysis and approval. The FBI is 

required to return the approved mail to the BOP for delivery to the inmate or 

addressee within 14 days. A period of 60 days is permitted if foreign 

language translation is required or if there is reasonable suspicion that a 

code was used and decoding is required. Telephone calls must be 

monitored contemporaneously by the FBI and recorded. All calls must be in 

English unless a fluent FBI translator is available to contemporaneously 

monitor the call. The FBI listens later to the recordings to analyze whether 

the communication includes 

messages that solicit or encourage 

acts of violence or other crimes or 

attempts to circumvent the SAMs. 

Except for visits with their 

lawyers, SAMs inmates are limited 

to visits with one adult immediate 

family member. The visits are 

non-contact only and monitored 

contemporaneously by the FBI. 

All communications during the 

visit must be in English unless a 

fluent FBI-approved translator is 

available. SAMs also can be 

invoked to allow for monitoring of 

conversations of inmates and their 

attorneys and to screen inmates’ 

correspondence with their 

lawyers.47 

SAMs may be recommended 

on a case-by-case basis by the FBI 

and prosecuting U.S. Attorney’s 

Office (USAO) independently or 

jointly through the OEO and are 

initiated during either the pretrial 

or post-trial period. The OEO 

reviews the initial SAMs requests, 

and after obtaining the necessary supporting documentation, prepares a 

memorandum to the Attorney General presenting the request and the 

 47 28 C.F.R. § 501.3 (1997). 

U.S. Department of Justice 13

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 14

Office of the Inspector General 

Evaluation and Inspections Division 

 

measures to be implemented. The Attorney General approves all original 

impositions of SAMs, and the Assistant Attorney General for the Criminal 

Division can approve SAMs extensions or modifications to existing SAMs. 

After the OEO drafts and submits an application for SAMs, it has no role in 

implementation or oversight, except during the renewal process. SAMs can 

be ordered for a year at a time and renewed at 1-year intervals indefinitely. 

The requesting agency must renew a SAMs application through the OEO, 

which reviews the request to determine the continued need for the special 

monitoring measures. Since March 2005, the BOP has worked with the FBI 

and OEO to standardize the conditions set forth in each SAMs to ensure 

consistency in application and monitoring of the SAMs inmates by the BOP 

and FBI. As of May 2006, there were 34 BOP inmates under SAMs. 

The FBI’s specific responsibilities related to monitoring pretrial and 

post-conviction inmates with SAMs are summarized in Appendix III. The 

FBI also is responsible for conferring with the USAO when SAMs are initially 

proposed. The USAO’s primary role in monitoring communications is to 

work with the FBI to identify inmates who are appropriate for SAMs. On 

occasion, a USAO is involved in the actual monitoring of inmate 

communications. In those instances, the USAO receives copies of 

communications from the FBI, and both components review the 

communications and any translations. 

Although the USAO ordinarily drafts SAMs requests to the OEO, on 

one occasion the Counterterrorism Section (CTS) in the Criminal Division 

has originated such requests.48 In March 2005, when the three World 

Trade Center bombers incarcerated at ADX Florence were discovered to be 

corresponding with other Islamic extremists in prisons abroad, the CTS 

drafted SAMs for these three inmates after requesting and receiving 

documentary justification from the FBI’s Counterterrorism Division. 

Although there is no requirement for the USAO, FBI, or OEO to coordinate 

SAMs requests for terrorism inmates with the CTS, they are encouraged by 

the CTS to do so.49

48 The CTS oversees “the design, implementation, and support of law enforcement 

efforts, legislative initiatives, policies and strategies relating to combating international and 

domestic terrorism.” In addition to investigating and prosecuting terrorism cases, CTS 

attorneys act as terrorism advisors or consultants to the USAOs and provide training on 

terrorism-related topics to Department personnel, law enforcement and intelligence agency 

personnel, the private sector, and the general public. 

49 Criminal Division, Guidance on Special Administrative Measures, March 2006. 
U.S. Department of Justice 15

Office of the Inspector General 

Evaluation and Inspections Division 

 

The BOP Cost Savings Plan 

In 2004, the BOP initiated a cost savings plan in response to budget 

cuts that has reduced institutions’ SIS and ISM staffing, including staff 

responsible for mail and telephone monitoring. During one phase of the 

plan, the BOP is centralizing key ISM functions – sentence computation and 

security classification – to a single facility in Grand Prairie, Texas, thereby 

eliminating 124 positions. In the nine institutions we visited with 

mailrooms, this centralization of ISM functions had decreased the number 

of ISM staff available to help sort, screen, and randomly monitor inmate 

mail when needed.50 

During another phase of the cost savings plan, the BOP implemented 

the Mission-Critical Roster on March 27, 2005. The Mission-Critical Roster 

developed a standardized staffing roster of Correctional Officer posts based 

on the size and mission of an institution. BOP staff from the SIS office and 

other departments can be required to cover critical Correctional Officer 

posts when vacant. The BOP developed the Mission Critical Roster with 

three key objectives: (1) establish posts that would be vacated only under 

rare circumstances, (2) reduce the reliance on other departments to cover 

Correctional Services posts, and (3) reduce overtime costs.51 In 7 of the 10 

institutions visited, the Mission-Critical Roster had resulted in a reduction 

of SIS positions that were used to monitor inmate mail and telephone calls. 

These SIS positions were reallocated to other security posts elsewhere in the 

institutions. 

 

50 The 10th institution we visited, the Beaumont Correctional Complex, which 

comprises three separate institutions, has a centralized mailroom. 

51 Harley G. Lappin, Director’s Message to All Staff, BOP, January 5, 2005. 
U.S. Department of Justice 16

Office of the Inspector General 

Evaluation and Inspections Division 

SCOPE AND METHODOLOGY OF OIG REVIEW 

This review focused on the BOP’s process for reading the mail of 

terrorist and other high-risk inmates, such as gang leaders, in medium- and 

high-security and administrative maximum institutions. The review also 

focused on the BOP’s foreign language translation services, which may be 

required for monitoring inmate mail, telephone calls, and visits. 

Our fieldwork, conducted from June to December 2005, included inperson and telephone interviews, document reviews, site visits to BOP 

institutions, data analysis, and direct observation of mail and telephone 

monitoring. 

Interviews 

We interviewed 179 officials and staff from the BOP, the FBI, the 

Criminal Division, and a USAO. Table 1 lists the sites visited or contacted 

and the officials we interviewed. 

Table 1: Officials Interviewed 

Department 

Component Site Official(s) Interviewed 

Director 

Assistant Director, Correctional Programs Division 

Deputy Assistant Director, Correctional Programs 

Division 

Chief, Intelligence Section 

Administrator, Correctional Services Branch 

Administrator, Inmate Systems Management 

Intelligence Officer, Intelligence Section 

Legal Staff Member, Office of General Counsel 

BOP Central Office 

National Joint Terrorism Task Force 

Representative (2) 

Regional Office(s) Regional Director (2) 

Warden (10) 

Associate Warden (17) 

Captain (13) 

Special Investigative Agent (10) 

SIS Lieutenant (8) 

SIS Technician (6) 

Intelligence Operations Officer (1) 

Phone Monitor (2) 

Inmate Systems Manager (7) 

BOP 

Institutions: 

LSCI, FCI, USP 

Allenwood 

FCI, USP 

Beaumont 

MDC Brooklyn 

ADX, USP Florence 

MCC New York 

FCI Sheridan 

FDC Houston Mailroom Staff (6) 
U.S. Department of Justice 17

Office of the Inspector General 

Evaluation and Inspections Division 

Department 

Component Site Official(s) Interviewed 

Unit Manager (14) 

Case Manager (1) 

Translator (13) 

Union President (8) 

Visiting Room Officer (20) 

Housing Unit Officer (8) 

Tower Officer (2) 

FDC Miami 

FDC Oakdale 

FDC Philadelphia 

FDC SeaTac 

MCC San Diego 

Finance Manager (5) 

Headquarters Assistant Director, Counterterrorism Division 

Beaumont, TX Supervisory Resident Agent 

FBI 

Allenwood, PA 

Beaumont, TX 

Brooklyn, NY 

Florence, CO 

New York, NY 

Sheridan, OR 

Special Agent (9) 

Department of Attorney, Office of Enforcement Operations (2) 

Justice 

Criminal Division 

Attorney, Counterterrorism Section 

USAO Southern District of Chief, Organized Crime and Counterterrorism 

New York Assistant U.S. Attorney 

Data Analysis and Document Reviews 

We reviewed data from a week’s mail volume from the BOP 

institutions we visited. We asked the 10 institutions to record the number 

of incoming and outgoing letters during the week of November 21-25, 2005. 

We also analyzed data on the monitoring of inmate telephone calls from the 

BOP’s INTRUDR system. 

We reviewed BOP Program Statements, budget documents, Post 

Orders, manuals, reports, memorandums, monthly intelligence reports, and 

SIS record keeping logs. We also reviewed the Department of Justice 

Strategic Plan for 2003-2008 and Department memorandums and guidance 

concerning SAMs. Additionally, we reviewed congressional testimony, news 

articles, and other reports that were related to the monitoring of inmate 

communications. 

Site Visits 

We completed 10 site visits to the following BOP institutions: 

• Allenwood, Pennsylvania – the Low Security Correctional 

Institution (LSCI), Federal Correctional Institution (FCI), and U.S. 

Penitentiary (USP); 
U.S. Department of Justice 18

Office of the Inspector General 

Evaluation and Inspections Division 

• Beaumont, Texas – the FCI and USP; 

• Brooklyn, New York – the Metropolitan Detention Center (MDC); 

• Florence, Colorado – the ADX and USP; 

• New York, New York – the Metropolitan Correctional Center (MCC); 

and 

• Sheridan, Oregon – the FCI. 

We selected the institutions based on a variety of factors, choosing 

institutions in different regions of the country and institutions of various 

security levels. 

Observations 

At the 10 institutions we visited, we observed the monitoring of 

inmate mail and telephone calls, as well as monitoring procedures in the 

visiting rooms and housing units. 
U.S. Department of Justice 19

Office of the Inspector General 

Evaluation and Inspections Division 

RESULTS OF THE REVIEW 

The BOP’s process for monitoring inmate mail is deficient 

in several respects: The BOP does not read all the mail for 

terrorist and other high-risk inmates on its mail monitoring 

lists, does not have enough proficient translators to 

translate inmate mail written in foreign languages, and 

does not have sufficient staff trained in intelligence 

techniques to evaluate whether inmate communications 

contain suspicious content. 

The BOP does not read a sufficient amount of inmate mail. 

We found that the BOP is unable to effectively monitor the mail of 

terrorist and other high-risk inmates in order to detect and prevent 

terrorism and criminal activities. Institutions did not read all the mail of 

inmates on mail monitoring lists as required, citing staffing shortages. 

Further, BOP staff said random reading of inmate mail is a lower priority 

than timely delivery of mail, and the amount of mail randomly monitored is 

not tracked. In addition, foreign language mail is less likely to get read 

because the BOP does not require translations of inmate mail for those on 

the mail monitoring lists or for randomly read mail and institutions do not 

always have ready access to proficient translators. 

The BOP does not read all the mail of high-risk inmates on SIS mail 

monitoring lists. 

Although the BOP Assistant Director for the Correctional Programs 

Division, told us that the BOP expects that 100 percent of the mail for 

terrorist and other high-risk inmates on the SIS mail monitoring lists will be 

read by the SIS office in each institution, our site visits showed that an 

unknown amount of mail was not being read. We sought information about 

the volume of incoming and outgoing mail for all inmates on the mail 

monitoring lists and the amount or percentage of mail that was read by BOP 

staff. However, the BOP does not require institutions to collect complete 

data on their mail monitoring and translation activities. In the absence of 

data, we relied on the statements of SIS staff responsible for mail 

monitoring at the institutions to characterize the level of reading that they 

perform. At each of the 10 institutions we visited, SIS staff stated the 100-

percent target, which includes translating and reading foreign language mail 
U.S. Department of Justice 20

Office of the Inspector General 

Evaluation and Inspections Division 

 

was not being consistently met. Therefore, letters from high-risk inmates 

sometimes went unmonitored.52

Moreover, at 7 of the 10 institutions we visited, the SIS staff told us 

that reading mail for inmates on mail monitoring lists had decreased since 

FY 2005 because some positions assigned to the SIS offices had been 

reallocated as part of the BOP-wide streamlining initiatives. SIS staff at 

these institutions could not quantify how much reading had decreased, but 

said that two additional factors contributed to it. Remaining SIS staff at 

some institutions who were responsible for mail and telephone monitoring 

had been regularly detailed to cover vacant security posts elsewhere in the 

institutions, while other SIS staff had been reassigned because of the BOP’s 

quarterly rotation policy for certain positions. The effects of the reallocation, 

rotation, or detail of SIS staff are discussed below. 

 

Reallocation. Because of the BOP’s cost savings plan (see Background 

Section) institutions have lost positions directly responsible for monitoring 

inmate mail and telephone calls. For example, SIS staff at one USP stated 

that they had approximately 175 names on the mail monitoring list and 

1,162 other high-risk inmates who also must be monitored for criminal 

activities and misconduct. Previously, the SIS office had four full-time staff 

members responsible for monitoring these inmates’ communications. 

However, in 2006, the four positions were reallocated to other functions 

outside of the SIS office, and all the monitoring work had been divided 

among the remaining three SIS staff. These staff members stated that 

keeping up with monitoring mail and other high-risk inmates, in addition to 

their regular SIS investigative duties, was overwhelming and that the heavy 

workload left them less time to gather and analyze intelligence on inmate 

activities through the mail. 

At 5 of the 10 institutions we visited, an SIS telephone monitor 

position that was also used to assist other SIS staff in monitoring mail had 

been reallocated elsewhere on the Correctional Officer roster. Overall, SIS 

staff in eight of the institutions identified reduced staffing as the greatest 

obstacle to effective inmate monitoring.53 Further, one Warden stated that 

he does not believe his institution has adequate resources to comply with 

BOP “mail and telephone monitoring goals.” At this institution, one of two 

telephone monitor positions as well as one intelligence officer position were 

reallocated from the SIS office. The Warden stated, “We still read the mail, 

but I can’t say it’s as thorough.” 

52 International terrorist inmates who are not under SAMs are always on the mail 

monitoring lists. 

53 The other two institutions did not have staff reallocated from their SIS office. 
U.S. Department of Justice 21

Office of the Inspector General 

Evaluation and Inspections Division 

 Rotation. The telephone monitor positions are 3-month rotational 

assignments, which affect the level of monitoring performed. Unlike 

rotational staff, permanent SIS staff are familiar with all of the inmates on 

the mail monitoring list and are more likely to recognize suspicious content 

and gather intelligence on terrorist and other criminal activities. 

Additionally, time spent training new monitors, coupled with the new 

monitors’ learning curve, reduces the amount of mail read by the SIS staff 

overall and the amount of intelligence that can be gathered. 

 

Two FBI Special Agents assigned to BOP institutions voiced concern 

about the reduced level of monitoring and staffing for SIS offices. One agent 

stated: 

[T]he FBI is missing a whole lot of stuff, also inmate informant 

recruitment will be affected. I’m so dependent on them . . . it’s 

nightmarish to rotate SIS every quarter [after] I have them 

trained. I count on them to have institutional memory. 

The other agent stated, “There has to be full-time intelligence staff. You 

need continuity and experience.” 

Details to Vacant Posts. Temporary assignments frequently reduce 

inmate monitoring by SIS offices. For example, the Special Investigative 

Agent for ADX Florence reported that on three consecutive days during the 

week prior to our July 2005 visit to ADX Florence, two or three of the SIS’s 

seven SIS technicians were pulled from their SIS duties to fill vacant officer 

positions on the housing units. Further, the SIS Technician responsible for 

monitoring all communications of all terrorist inmates at ADX Florence 

stated that in the week prior to our October 2005 interview with her, she 

was pulled from her SIS duties for 4 of her 5 work days to fill a vacant post 

elsewhere in the institution. The ADX’s Special Investigative Agent stated 

that the temporary assignments happened frequently and reduced the level 

of monitoring and intelligence gathering that the SIS office could 

accomplish. As a result, SIS staff members at the ADX Florence told us that 

they cannot achieve 100-percent monitoring as required and that when they 

are able to monitor communications, they “speed up reading the mail or 

monitoring the telephones and maybe miss something by rushing through 

it.” 

At ADX Florence, decreased reading of mail and intelligence gathering 

can have significant security consequences. The institution houses 

approximately 400 of the BOP’s most dangerous and violent inmates. SIS 

staff told us that one-half of the population comprises high-risk inmates 

and many of the inmates had either attempted to kill, or have killed, 
U.S. Department of Justice 22

Office of the Inspector General 

Evaluation and Inspections Division 

another inmate or a correctional officer. Additionally, the ADX houses the 

most terrorists – including the 1993 World Trade Center bombers – Ted 

Kaczynski (the Unabomber), convicted spy Robert Hanssen, and leaders of 

violent street gangs. Fifteen of these ADX Florence inmates are under 

SAMs, the largest number of SAMs inmates at any BOP facility. 

Approximately 70 percent of the ADX Florence inmate population is on the 

mail monitoring list as well. Therefore, the need to provide intensive 

monitoring of inmate mail is critical to ensure the safety and security of the 

institution and public. 

The assignment of SIS staff to other posts at ADX Florence is not an 

anomaly. At MCC New York, we were told that two of the three SIS staff had 

been detailed from their monitoring duties to work other institution posts 

three to four times per week for the past year. MCC New York houses many 

high-profile, unsentenced terrorists, organized crime figures, and gang 

leaders. Because the MCC is a pretrial facility, the BOP receives little 

background information on the inmates it admits other than the crime with 

which they are charged. Mail monitoring of these inmates is important to 

determine if an inmate is continuing criminal or terrorist activity and to 

plan for the appropriate level of security. 

The BOP does not adequately manage the amount of inmate mail that is 

randomly read. 

We found that the BOP has not met its goal of reading 100 percent of 

mail of inmates on mail monitoring lists, but it also does not know the 

amount of mail randomly read for other inmates. The BOP does not require 

institutions to track the volume of mail sent and received by all inmates, set 

targets for random reading, or measure the level of random reading 

achieved. Random reading of inmate mail is important to gather intelligence 

on potential criminal activity as well as to monitor unusual inmate behavior. 

Additionally, inmates on the mail monitoring list may use unmonitored 

inmates to send and receive mail. At seven institutions we visited, ISM staff 

members who manage the mailroom told us that while random reading is 

not measured, they believed random reading of incoming inmate mail and 

the amount of suspicious content they can identify and refer to the SIS 

office have decreased since early 2005. They attributed the decrease to one 

or more of the following factors: the high volume of mail, short processing 

deadlines, and staff reductions in the ISM departments. 
Outgoing Inmate Mail More Likely to Be 

Randomly Read 

While outgoing inmate mail also must be 

processed within 24 hours, it has a much 

higher likelihood of being randomly read 

than incoming inmate mail. Outgoing 

mail is sorted, inspected for contraband, 

and randomly read by the “morning 

watch” Correctional Officer (12 a.m. – 

8 a.m.) assigned to each housing unit. 

The morning watch officers are 

responsible for sorting and inspecting 

each piece of mail, as well as randomly 

reading some. 

We interviewed morning watch Housing 

Unit Officers at all 10 institutions we 

visited. Because the morning watch is the 

shift with the least amount of inmate 

movement and activities, each Housing 

Unit Officer has more time to review the 

letters for both contraband and content. 

Four Housing Unit Officers in different 

institutions reported reading 20 to 50 

letters per night. 

 

With few exceptions, the bulk of BOP inmates can correspond with 

anyone, and the amount of incoming and outgoing letters is unrestricted. 

We found that incoming inmate mail is less likely to have adequate 

monitoring through random reading 

than outgoing mail. The large 

volume of daily incoming mail 

causes the BOP to focus primarily 

on inspection for contraband and 

timely delivery of mail rather than 

on random reading for potential 

criminal activity. An ISM staff 

member we interviewed at a 

correctional complex stated that the 

challenge for staff is timeliness, 

saying that with the high volume of 

mail and reductions in staff, getting 

mail processed in a timely manner 

was the overriding concern. 

BOP policy states that 

“[d]elivery of letters may not be 

delayed and shall ordinarily be 

accomplished within 24 hours of 

receipt, excluding weekends and 

holidays.”54 One correctional 

complex’s local mail supplement 

stated, “It is imperative the 

scanning or spot-checking of both 

incoming and outgoing general correspondence not interfere with the 

prompt handling of all mail.” Consequently, because BOP staff are working 

to meet a strict mail delivery deadline, the amount of mail randomly read by 

ISM staff varies greatly by institution and overall may be less than what is 

advisable for security purposes. 

One obstacle in managing the random reading of inmate mail is the 

volume of mail institutions receive. The BOP Director compared monitoring 

inmate communications to searching for “a needle in a haystack.” He stated 

that because of the large volume of mail and telephone calls generated by 

inmates, the challenge is in “overseeing and managing the massive amount 

of information.” The BOP Assistant Director for the Correctional Programs 

Division stated that the BOP’s biggest challenge in monitoring inmate mail 

is the “volume of mail and the current regulations [that] allow virtually 

U.S. Department of Justice 23

54 BOP, Mail Management Manual, Program Statement 5800.10, Chapter 3, 

August 19, 1998, p. 4. 

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 24

Office of the Inspector General 

Evaluation and Inspections Division 

 

unlimited correspondence.” Similarly, one Warden stated, “Our problem lies 

in the area where inmates can communicate with anyone in the country.” 

Another Warden recommended that the BOP “limit the number of letters 

[inmates send and receive] each week.” 

Since the BOP does not track the volume of incoming mail and 

amount randomly read, we requested that the institutions we visited track 

their incoming mail and the number of pieces of mail they randomly read 

during a 1-week period. Although all incoming general correspondence and 

outgoing mail is subject to reading by staff, the BOP has no established 

target percentage of mail to be read.55 

We found that the lack of BOP-wide guidance for random reading had 

resulted in wide variances in the amount of reading accomplished by 

institutions with similar workloads and staffing. For example, the 

percentage of incoming mail randomly read during the test week at the 10 

institutions ranged from 0.3 percent (about 24 mail items) to 75 percent 

(about 3,000 mail items).56 Four of the institutions read less than 5 percent 

of the incoming inmate mail. Table 2 shows the volume of mail the 

institutions reported receiving and the amount of mail randomly read. 

55 BOP, Mail Management Manual, Program Statement 5800.10, Chapter 3, p. 3. 

56 The results of our request that institutions track their random reading for a week 

may not be representative in all instances of the reading that usually occurs because the 

institutions knew their 1-week efforts were being recorded. Moreover, the data provided to 

us show that although some institutions report higher levels of random reading, they have 

limited time to read. For example, USP Allenwood reported that its two staff members read 

75 percent of 4,218 pieces of mail during the 4-day (32-hour) work week. This equates to 

over 1,500 letters per staff member. Even with no other duties, this only would allow 

approximately 30 seconds to read each letter to identify possible criminal or terrorist 

activity. 
U.S. Department of Justice 25

Office of the Inspector General 

Evaluation and Inspections Division 

Table 2: Incoming Mail Processed and Randomly Read 

 by Mailroom Staff during November 21 – 25, 2005, 

as Reported by Institutions 

 

Pieces of Incoming Mail Processed 

Institution 

Number 

of 

Inmates 

Number 

of 

Mailroom 

Staff 

Monday 

Tuesday 

Wednesday 

Thursday 

Friday 

Weekly 

Total 

Percentage 

of Mail Read 

Randomly 

by Mailroom 

Staff 

LSCI 

Allenwood 1,385 2 2,070 1,249 1,024 Holiday 1,284 5,627 average of

 1.8%

FCI 

Allenwood 1,417 2 3,545 2,629 2,694 Holiday 3,538 12,406 33.0%

USP 

Allenwood 1,156 2 1,802 938 780 Holiday 698 4,218 75.0%

FCC 

Beaumont 3,905 5 4,422 2,236 2,186 Holiday 1,832 10,676 10.0%

ADX 

Florence 394 2 578 639 411 378 458 2,464 average of

 1.8%

USP 

Florence 1,079 4 1,678 926 678 Holiday 501 3,783 average of

 12.9%

MCC New 

York 900 2 2,035 1,740 1,070 Holiday 1,275 6,120 50.0%

MDC 

Brooklyn 

approx. 

3,000 4 2,320 1,425 1,425 1,425 1,425 8,020 average of

 0.3%

FCI 

Sheridan 1,128 2 1,808 1,007 1,119 Holiday 1,988 5,922 average of

 4.8%

Source: BOP institutions 

Notes: All mail volume counts include first-class mail, legal mail, newspapers, magazines, and staff mail. 

Because the three institutions at FCC Beaumont share a central mail processing center, the numbers 

include counts from the low- and medium-security and USP facilities. At the time of this mail volume 

report, the inmate population at the Beaumont complex was reduced by 1,668 inmates due to a 

temporary evacuation during Hurricane Rita. The normal population at that time would have been 5,570 

inmates and the amount of mail processed considerably higher. ADX Florence tracked mail volume the 

week of November 28 through December 2, 2005. MDC Brooklyn provided its mail volume data for the 

period September 19 through September 23, 2005, during our site visit. 

During our site visits, mailroom staff stressed that random reading is 

not a priority when compared with screening mail for contraband and timely 

delivery of mail. The staff also provided us with general estimates of the 

volume of incoming mail and how much random reading they believed they 

achieved. For example, at MDC Brooklyn where the mailroom staff told us 

they processed 1,400 pieces of mail per day, a mailroom supervisor stated 
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Evaluation and Inspections Division 

 

that on a slow day staff were instructed to read 5 pieces of first-class mail 

each. At LSCI Allenwood, the 2 mailroom staff members stated that they 

might read 25 of the approximately 1,400 to 1,500 daily incoming letters. 

The ISO also stated that on Mondays, when mail volume was the heaviest, 

they only skimmed through the mail.57 At the FCI Allenwood, the ISO 

stated that while he had a pile of 40 to 50 letters on his desk daily to read, 

he might read only 8 or 9. At other times, he said he just scanned or read a 

paragraph in each letter. At FCI Sheridan, the 2 mailroom staff members 

stated that they could process 1,400 incoming letters or publications daily 

and might read approximately 65 letters. The 5 staff members at the 

Beaumont Correctional Complex processed mail in a shared services 

mailroom for approximately 5,600 inmates housed in three institutions. 

The mailroom staff stated that because of the high volume, they primarily 

inspected mail for contraband. They stated that they might read 10 percent 

of the mail, but they did not have a specific target for random reading 

because there were no national guidelines. 

The elimination of certain ISM positions at BOP institutions and the 

attrition of some ISM staff have resulted in understaffed mailrooms and 

decreased random reading of incoming mail. Mailroom staff we interviewed 

generally said they had time only to inspect the mail for contraband rather 

than read the mail for suspicious or criminal activity. On high-volume days, 

mailroom staff at the institutions we visited stated that previously they had 

“borrowed” staff from other ISM functions such as inmate records and 

receiving and discharge (R&D). However, with the consolidation of key ISM 

functions, many of these staff positions had been eliminated, transferred to 

other departments or institutions, or transferred to a centralized facility in 

Grand Prairie, Texas, leaving fewer staff members available to assist in the 

mailroom. For example, Allenwood’s three institutions lost two ISMs and 

two Assistant ISMs, resulting in reduced random reading of mail. 

Beaumont’s ISM department lost four positions, which, according to the ISM 

manager, has affected the unit’s ability to effectively conduct mailroom 

operations. The manager told us, “The workload has been increasing, but 

the staff is decreasing.” Of the nine mailrooms we visited, six were 

processing the mail with two staff members, two USPs had four staff 

members, and a correctional complex processing mail for three institutions 

had five staff members. 

57 According to mailroom staff, mail volume on Mondays may be double that 

received on a typical Tuesday thought Friday. 
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Evaluation and Inspections Division 

The BOP does not track the amount of incoming or outgoing foreign 

language mail or maintain data on the foreign languages that inmates use. 

BOP institutions do not track the amount of foreign language mail for 

most inmates, but mailroom and SIS staff we interviewed said the amount is 

significant. BOP staff are required to translate and read all foreign language 

mail for inmates on mail monitoring lists, as well as translate and read 

foreign language mail randomly selected for reading.58 However, staff who 

monitor the mail at two institutions we visited told us that if they were 

reading outgoing mail and selected a letter in a foreign language, they would 

let the letter go out without having it translated because there was no 

requirement for translation. At six other institutions, staff said they 

forwarded randomly selected foreign language mail to the SIS office for it to 

translate and read. Yet, staff in the SIS offices said they were already 

having difficulty reading mail for inmates on mail monitoring lists, and 

random reading of other mail was unlikely. 

 

The BOP also does not maintain information on the types of foreign 

languages that inmates use to communicate in writing or verbally. The BOP 

also does not track the languages translated or the number of hours spent 

translating. Therefore, the BOP has no baseline to plan the translation 

resources it needs for its monitoring responsibilities. 

Developments and Future Plans

In a May 2006 interview, the BOP Director and the Assistant Director 

for the Correctional Programs Division both emphasized to us that mail 

monitoring was a priority for the BOP and that institutions should be 

reading 100 percent of the mail for inmates whose names are on the mail 

monitoring lists. They stated that they would review the standards for 

which inmates are placed on the mail monitoring lists to ensure that those 

listed are appropriate and that the resulting amount of inmate mail 

monitoring could be achieved. The Director and Assistant Director also said 

they planned to clarify their expectations for random reading of mail for 

inmates not on monitoring lists. 

The BOP Director also told us that a shift was occurring in the BOP’s 

approach to communications for terrorist inmates not on SAMs. He stated 

that in the past, the BOP encouraged inmates – even inmates convicted of 

terrorism-related offenses – to communicate and maintain links with 

 58 The FBI is responsible for translating communications of all inmates under 

SAMs, including international terrorists, and the BOP is responsible for translating 

communications of non-SAM international terrorist inmates. As of May 2006, the BOP 

classified 146 inmates as international terrorists, and held 25 of them under SAMs. 
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Office of the Inspector General 

Evaluation and Inspections Division 

families and friends with few limitations. However, the Director said that as 

a security measure the BOP was developing a policy that would reduce the 

communication privileges of international terrorist inmates not under SAMs. 

The new policy would limit the communications of inmates detained or 

charged with any terrorist-related activity upon request from the FBI or 

other law enforcement agency, or if BOP information indicated a strong need 

to impose such restrictions. Rather than allowing unlimited 

communications, under this proposal the BOP could limit the inmates to 

communicating only with immediate family members, U.S. Courts, the 

inmate’s attorney, members of Congress, law enforcement agencies, and 

other specified entities. In addition, communications with family members 

could be limited in frequency and volume as follows: 

• Correspondence could be limited to three pieces of paper, doublesided, once per week to a single recipient. 

• Telephone communications could be limited to a single completed 

telephone call up to 15 minutes in length per calendar month. 

• Visiting could be limited to 1 hour each calendar month. 

By limiting the frequency and volume of specific communications for 

terrorist inmates not on SAMs, the proposed policy would reduce the 

amount of communications requiring monitoring and allow the BOP to 

better scrutinize the communications it monitors. As of July 2006, the BOP 

was coordinating the final policy with the Department. 

The BOP also was developing a policy to limit or eliminate unsolicited 

(junk) mail. This policy would reduce the overall volume of mail for all 

inmates so that ISM staff could better focus their efforts on inspecting for 

contraband and randomly reading mail for evidence of terrorist or criminal 

activities. The BOP anticipated sending the proposed policy to the 

Department for review in August 2006. 

Recommendations 

1. The BOP should ensure that all mail of inmates on its mail monitoring 

lists is read, including translating and reading foreign language mail, and 

that the institutions’ monitoring of this mail is tracked. 

2. The BOP should set minimum target percentages of incoming and 

outgoing mail for random reading, including translating and reading 

foreign language mail, and track the institutions’ efforts to comply with 

these goals. 
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Evaluation and Inspections Division 

The BOP’s capability to translate foreign language mail does not 

sufficiently support monitoring needs. 

For translation of many inmate communications, the BOP primarily 

relies on staff who volunteer to translate as a collateral duty. The names of 

these volunteers are placed on a BOP Directory of Translators, which is 

distributed to all institutions. Because the BOP does not have enough 

volunteer staff for Arabic translations, particularly for its terrorist inmates, 

in 2005 the BOP hired three full-time Arabic Language Specialists at ADX 

Florence. These Language Specialists are the BOP’s first full-time staff 

translators. The Language Specialists translate mainly for ADX Florence, 

but other BOP institutions can request their assistance in translating 

Arabic. Additionally, in 2003 the BOP created the Language Translation 

Services Project to procure contractors to translate foreign language 

communications of international terrorist inmates. The BOP also can use 

outside sources such as universities or other law enforcement agencies for 

translations. 

Despite these resources, we found deficiencies in the BOP’s ability to 

translate inmate mail: 

• For volunteer staff translators: 

o The BOP did not have agency-wide standard procedures for 

conducting in-house translations. 

o The BOP staff used to translate inmate communications were 

not subject to language proficiency requirements, and the BOP 

had no policy requiring translations be checked for accuracy. 

o The BOP did not have enough staff to translate inmate 

communications, especially inmate communications in 

Spanish. 

o The BOP did not offer effective incentives to motivate staff with 

needed language skills to translate voluntarily. In addition, 

some supervisors did not support translating as a collateral 

duty for their staff. 

• For full-time staff Language Specialists, the BOP did not offer 

sufficient intelligence training. 
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Office of the Inspector General 

Evaluation and Inspections Division 

• For contract translation services, the BOP’s Language Translation 

Services Project was a valuable but limited resource for institutions 

that house international terrorist inmates. 

The sections below discuss these deficiencies more fully. 

Volunteer Staff Translators

The BOP does not have agency-wide standard procedures for conducting inhouse translations. 

The BOP has no written standard procedures or requirements for staff 

translating inmate mail or telephone calls. We found a wide range of 

translation practices at the 10 institutions we visited. Translations 

performed by staff were generally not word for word, but instead resulted in 

a brief summary of the contents or a handwritten note on a letter from the 

translator saying “OK” without any summary. According to the volunteer 

staff translators we interviewed, the SIS staff did not always provide 

adequate direction when requesting a translation. However, the SIS staff 

members said they did not receive adequate direction from BOP 

headquarters on translating foreign language inmate communications. 

While some translators we interviewed believed that effective monitoring of 

inmate communications required only simple “common sense,” others 

stated that they could provide better translations if they received better 

guidance. 

National guidance is not clear and complete. The only guidance that 

the BOP has issued for translation services was a March 15, 2005, 

memorandum from the Assistant Director for the Correctional Programs 

Division.59 Staff at most institutions we visited stated that this 

memorandum was not specific enough and did not provide adequate 

guidance. For example, this memorandum did not provide detailed 

guidance on the amount of mail to be translated; whether staff translators 

should be asked first to translate terrorist inmates’ communications prior to 

seeking translation services with outside contractors; what type of 

translation product is acceptable; or the time frame for completing a 

translation. The memorandum stated in part:

Due to the continued increase in the number of incarcerated 

inmates speaking various exotic Middle-Eastern, Pacific Island, 

and South Asian languages, and the agency’s need to maintain 

security of its institutions through mail and telephone 

 59 John H. Vanyur, Language Translation Services, BOP CT Translation Special 

Project Funding, Correctional Programs Division, BOP, March 15, 2005. 
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Evaluation and Inspections Division 

monitoring, it is necessary to procure translation services . . . . 

Translation services for inmates affiliated with 

international terrorist organizations or for any other 

inmate with special circumstances will be used for non-legal 

inmate mail and telephone calls . . . . Please note that every 

effort must be made to [ensure] BOP staff are utilized to 

translate common foreign languages, i.e., Spanish, Italian, etc. 

to promote cost containment.60 

However, staff told us that they were not certain if they are required to 

obtain translations for all international terrorist inmates and that if they do 

seek exotic language translations whether they should do so first through 

volunteer staff translators rather than through General Services 

Administration (GSA) contracts. The staff said the memorandum was 

confusing because it stated that staff translators should be utilized to 

translate “common” foreign languages, which excludes Arabic. BOP staff 

also were unsure whether translations were required to be word for word or 

whether a summary or just an “OK” was adequate. 

The March 2005 memorandum also failed to establish time frames for 

completion of requested translations. An SIS Lieutenant told us: 

We don’t get adequate guidance from BOP on translations. We 

fend for ourselves trying to get stuff translated. I don’t think 

there’s any direction as to what to do with the things that have 

to be translated. Unless BOP has a translation department 

where SIS can funnel their referrals, using BOP staff that are 

currently working [full time] is not working . . . . [T]hey [staff 

translators] had their own jobs and we never got [the 

translations] back. 

Further, because the March 2005 memorandum only addressed 

translations for international terrorist inmates, the BOP has no foreign 

language translation guidelines for any other group of inmates. As a result, 

the priority placed on obtaining translations for any inmates other than 

inmates convicted of terrorist-related offenses is left to the discretion of each 

institution’s staff, primarily the SIS staff. 

Translation practices are not standard at every institution. At 7 of 10 

institutions we visited, SIS staff and volunteer translators told us that SIS 

staff often gave inmate letters to the translators or asked them to listen to 

telephone calls without providing any background information on what they 

should be looking for or instructions on the type of translation to be 

 60 Language Translation Services, BOP CT Translation Special Project Funding. 
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Office of the Inspector General 

Evaluation and Inspections Division 

performed (i.e., word for word, summary, or just an “OK”). The SIS staff in 

the other three institutions provided context, instructions on what to look 

for, and whether word-for-word translations or just a summary was 

required. 

Because of the lack of guidance from SIS staff to translators, we found 

varied translation practices applied to the communications of terrorist and 

other high-risk inmates. These varied practices may not provide adequate 

translations for SIS staff to fully analyze the communications for suspicious 

content that was not recognized by translators. For example: 

• One volunteer staff Arabic translator told us he never received 

instructions from the SIS staff on how to perform translations and 

rarely communicated with SIS staff, even though translations took 

up 30 to 40 percent of his time. He said he did not read the 

letters, but rather scanned them. He never wrote summaries of 

translations, but wrote only “OK” on the communication. If 

something looked suspicious, he wrote a memorandum explaining 

why it was suspicious. When he recommended rejecting a letter, 

he said he cited the reason. 

• At one facility, the volunteer staff translator told us that she read 

10 to 15 Spanish letters per day, but was not required to provide a 

written translation or summary for any of the letters. She stated 

that she read all the letters but only notified SIS staff verbally if 

she detected anything suspicious. 

• At one pretrial facility, a Special Investigative Agent told us that he 

used a volunteer staff translator from another institution to screen 

inmate mail written in Arabic, but did not provide instructions to 

the translator as to the expected product. Consequently, the 

translator wrote only “OK – general conversation” on the letters 

with no translation if he found nothing suspicious. If he thought 

something was suspicious, he wrote a summary of that content. 

At other institutions, SIS staff provided some background information 

to translators and required complete or partial word-for-word translations: 

• At a medium-security institution, one staff member, a native 

Spanish speaker, translated mail and telephone calls from Spanish 

as a collateral duty. SIS staff usually told him what they were 

looking for in inmate letters. Normally, he wrote a summary of the 

letter, with a word-for-word translation of any suspicious sections. 
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Office of the Inspector General 

Evaluation and Inspections Division 

• At a low-security institution, a staff member who translated 

Spanish as a collateral duty for the SIS office told us that an SIS 

technician usually explained the context and what SIS was looking 

for in the correspondence. SIS required word-for-word 

translations, which she provided in handwritten form. 

The BOP volunteer staff who translate inmate communications are not subject 

to language proficiency requirements, and the BOP has no policy requiring 

translations be checked for accuracy. 

The BOP does not require staff who provide translations as a 

collateral duty to have a certain level of language proficiency, does not test 

staff for language proficiency, and does not have a procedure to randomly 

review the accuracy of communications that are translated. The lack of 

proficiency testing and quality controls could result in security 

vulnerabilities due to mistranslated or untranslated materials. 

BOP staff volunteer annually to be listed in the BOP Directory of 

Translators and self-report their proficiency levels. The BOP Central Office 

distributes this directory to all institutions, which are directed to use staff 

listed in it before seeking outside translation assistance. Since the BOP 

does not maintain minimum standards for collateral duty translators, the 

BOP staff who volunteered as translators at the institutions we visited had 

varying levels of proficiency. The examples below show some of the 

proficiency differences at these institutions: 

• At one medium-security institution, a staff member helped 

translate telephone calls and letters in French for the SIS staff. He 

considered himself to be at the “intermediate” level in reading and 

writing and at the “basic” level in speaking. He looked or listened 

for key words and phrases and provided summaries of the 

communications to the SIS office. 

• Another BOP employee who translated Japanese stated that while 

he was proficient in the language, it required considerable time 

and effort for him to translate, depending on the complexity of the 

writing, and he sometimes sought the assistance of his wife, a nonBOP employee. 

• At one institution, a staff member who is a native speaker of Arabic 

stated that he understood 90 percent of the Middle Eastern 

languages, but that he was not proficient in Pakistani and Afghan 

languages. He said these languages were totally distinct from 
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Office of the Inspector General 

Evaluation and Inspections Division 

 

Arabic and were best translated by native speakers rather than by 

him. 

Staff at the institutions we visited commented that mail and telephone 

translations were often done by BOP staff who were not native speakers and 

therefore were unfamiliar with some phrases in the foreign language. The 

large number of regional dialects and colloquialisms in many languages 

increases the risk of inaccurate or unreliable translations from untested 

staff. For example, an Arabic translator (native speaker) recounted the time 

an inmate stated that he was waiting for some “green olives.” The translator 

said that another person translating may have interpreted this expression 

literally, but in his country this expression meant money. 

In addition, the BOP does not have standard procedures for ensuring 

the accuracy of staff translations. SIS staff told us that they had little 

choice but to trust the volunteer staff who translated for them because they 

did not know the languages themselves. One SIS Lieutenant told us that he 

took a Spanish document that one staff member had translated to another 

Spanish-speaking staff member for verification and learned that the 

translation was inaccurate. 

The BOP does not have enough staff to translate inmate communications, 

especially for inmate communications in Spanish. 

In 5 of the 10 institutions we visited, Spanish language mail and 

telephone calls chosen for random monitoring are not always translated 

because of insufficient staff translators. Approximately 28 percent of the 

BOP’s inmates are from Spanish-speaking countries. However, we found 

that even institutions in parts of the country that have a large Hispanic 

population had a shortage of Spanish-speaking staff.61

We visited high- and medium-security facilities at two BOP complexes 

with substantial Hispanic inmate populations in different parts of the 

country: Beaumont, Texas, and Allenwood, Pennsylvania. Over a quarter 

(663 inmates) of Allenwood’s high- and medium-security population of 2,480 

inmates was Hispanic.62 However, between the two Allenwood institutions, 

only 12 Spanish-speaking staff covered three shifts a day and helped with 

translations. Staff at Allenwood reported that the shortage of Spanishspeaking correctional staff was a major challenge. Almost one-third of 

Beaumont’s inmate population (1,009 of 3,116 inmates) at its medium- and 

61 The Hispanic population for all BOP institutions constituted approximately 32 

percent of the inmates. Not all Hispanics communicate in Spanish. 

62 BOP, Inmate Characteristics Report, May 2005. 
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Office of the Inspector General 

Evaluation and Inspections Division 

 

high-security institutions was Hispanic, which matched the percentage of 

Hispanics in Texas as a whole.63 However, the BOP employed only 42 

Spanish-speaking staff at the Beaumont complex (3 institutions, 3 shifts a 

day), which an Associate Warden said was not enough to translate the 

amount of Spanish communications that must be monitored. 

The BOP periodically provided a Spanish language immersion course 

for BOP staff.64 However, the course was not offered to staff for over 2 

years, from July 2003 until November 2005, because of budget constraints. 

According to some Correctional Officers and other staff we interviewed, they 

have repeatedly requested the course, but have never been enrolled. Prior 

to 2003, the BOP offered the Spanish immersion course six times in 

FY 2002, and five times in FY 2001. The BOP offered the course only once 

in FY 2006 with a class of 25 participants, and stated it is uncertain about 

this course offering in FY 2007. 

 

The BOP has not regularly provided training for staff in languages 

other than Spanish. We interviewed one volunteer staff translator who 

maintained his proficiency in Arabic by speaking with inmates because 

there was no training available to him. 

The BOP does not offer effective incentives to motivate staff with needed 

language skills to translate voluntarily, and some supervisors do not support 

translating as a collateral duty. 

The BOP allows nominal monetary awards or written 

acknowledgements for staff who volunteer for collateral translation duties, 

but these incentives are applied inconsistently. Additionally, translating 

may affect the employee’s regular duties, and not all supervisors support 

this labor-intensive collateral duty. Because of these factors, employees 

often are discouraged from volunteering to translate inmate mail and other 

communications. 

Each Warden determines how much of a priority translation services 

will be in his or her institution and what kind of recognition staff will receive 

63 The Hispanic population in BOP institutions is made up of both U.S. citizens and 

foreigners. The BOP tracks inmates’ citizenship and ethnicity, but not the languages they 

speak. 

64 The Spanish immersion course is intended to give staff the ability to understand 

key words and to communicate with Spanish-speaking inmates. Staff who are more 

proficient in Spanish are then encouraged to participate as interpreters during disciplinary 

hearings, intake screening, and monitoring of phone calls to pick up words, phrases, or 

conversations that may be suspicious. 
U.S. Department of Justice 36

Office of the Inspector General 

Evaluation and Inspections Division 

 

for providing these additional services.65 Some staff translators we 

interviewed stated that supervisors promised that they would be considered 

for a bonus, but the translators never received it. However, according to 

staff translators we interviewed, monetary rewards are not the only 

successful incentives. One staff member proficient in Arabic cited lack of 

any recognition as the primary disincentive to taking on the added work of 

translating. Consequently, he said that he would only translate for fellow 

staff in his department, but not anyone else. At another institution, we 

found that the BOP was paying an outside vendor to translate inmate 

communications even though a full-time BOP employee fluent in the 

required language worked less than 30 minutes away at another BOP 

institution. This employee said he used to translate often, but told us that 

he stopped providing translation assistance because he received no 

recognition or other incentives. 

Some staff said that their supervisors were not supportive of their 

conducting translations during regular work hours. One staff member who 

translated Arabic told us he received so many requests for assistance from 

the SIS offices in both his institution and others that during some weeks he 

spent 8 or more hours translating. At one point, the staff member said he 

was admonished by his supervisor, who told him that the BOP “hired you as 

an accounting technician, not a translator.” From that point on, the staff 

member required all external requests for his translation services be sent to 

his Associate Warden, who was more supportive of his collateral translation 

activities. Another staff person we interviewed said that he had the support 

of the Warden and received compensatory time in one facility when he 

translated inmate communications in Arabic as a collateral duty. However, 

the situation changed when he transferred to another institution where his 

name was left out of the BOP-wide Directory of Translators, even though he 

submitted his name for inclusion and is a native Arabic speaker. He said he 

still received many requests for translations, which affected his ability to 

carry out his duties, so he translated largely on his own time. Hence, he 

received no compensatory time or overtime pay for his translation services. 

The staff members we interviewed who translated inmate 

communications as a collateral duty did not track the number of hours they 

devoted to translating because the BOP does not require or even recommend 

this. Without any type of tracking system to document the total number of 

65 According to a BOP Program Statement, a supervisor is responsible for 

submitting a nomination for an employee to receive a cash award for translations done as a 

collateral duty. Wardens may approve up to $1,500, Regional and Assistant Directors may 

approve up to $3,000, and the BOP Director may approve up to a $5,000 cash award. 

BOP, Bureau of Prisons’ Awards Program, Incentive Awards, Program Statement 3451.047, 

July 10, 2001. 
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Office of the Inspector General 

Evaluation and Inspections Division 

hours staff spend translating as a collateral duty and the type of language 

translations provided, the BOP cannot accurately allocate resources or plan 

for hiring an appropriate number of full-time Language Specialists. 

Institutions also cannot properly carry out the incentive and rewards 

program without knowing how many hours individual staff are devoting to 

this collateral responsibility. 

Full-time Arabic Language Specialists

The BOP does not offer sufficient intelligence training to full-time Language 

Specialists. 

In 2005, the BOP hired its first full-time staff translators – three 

Arabic Language Specialists assigned to ADX Florence – and officials said 

they planned to hire four more Arabic Language Specialists for the BOP’s 

new Counterterrorism Unit (described later in this report). However, the 

BOP did not provide counterterrorism intelligence training to the full-time 

Language Specialists at ADX Florence in their first year that would assist 

them in analyzing what they were reading. One of these translators had 

translated all communications for Arabic-speaking international terrorist 

inmates at ADX Florence since 2001 without any intelligence training, first 

as a collateral duty and then full-time beginning in June 2005.66 A former 

Special Investigative Agent at ADX Florence told us that he tried to get the 

Arabic translator intelligence training when he was a volunteer translator, 

but the BOP’s response was “unless you were in the SIS shop, do not even 

bother nominating someone.” 

The translators’ need for intelligence training was addressed in the 

BOP’s internal March 2005 After Action Report on Terrorist Issues. The 

report focused on the ADX Florence letter-writing incident and listed several 

recommendations related to terrorist inmate issues: 

• “[Foreign language communications] should be reviewed by 

suitably trained resources to identify potential intelligence from 

cultural contexts of communications. 

• “Institution linguistic staff should be given suitable training and 

security clearances to facilitate local review of [foreign language 

communications]. 

 66 Until 2005, the employee was assigned as an Education Specialist at the USP 

Florence. 
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Office of the Inspector General 

Evaluation and Inspections Division 

• “Telephone communications by non-SAMs [international terrorists] 

should be live monitored by suitably trained staff (linguistically 

and intelligence background) rather than just recorded. 

• “Consider requiring [international terrorist inmates’] visits be 

contemporaneously monitored by suitably trained staff 

(linguistically and intelligence background).” 

In November 2005, one of the three Language Specialists attended a 

1-week SIS training course, which focused on crime scene procedures and 

general investigative topics and contained only minimal counterterrorism 

information. In February 2006, the other two translators attended the same 

training. However, as described later in this report, this training did not 

adequately train the Language Specialists (or SIS staff) to perform 

intelligence analysis on communications for terrorist inmates not on SAMs. 

Language Translation Services Project

The BOP’s Language Translation Services Project is a valuable but limited 

resource for institutions that house international terrorist inmates. 

In 2003, the BOP created the Language Translation Services Project 

under which institutions can obtain translations from GSA-approved 

contractors for “exotic” languages.67 Through this project, institutions can 

obtain complete word-for-word translations of non-SAMs international 

terrorist inmates’ mail and telephone calls that enable the SIS offices to 

monitor and analyze the communications. We found the project was viewed 

favorably by staff at all the institutions we visited, not only because the 

institutions can have certain non-SAMs international terrorist inmates’ 

communications translated by professionals, but also because the costs are 

funded out of the Central Office budget rather than the institutions’ 

budgets. 

However, as we will discuss in more detail below, the project has some 

drawbacks. The services of contract translators are very expensive, the 

project does not cover non-terrorist inmates, and obtaining a contract 

translation involves a cumbersome approval process. Additionally, officials 

at one institution said they experienced several months’ delay in receiving 

translations from a GSA-approved vendor. Aside from the Language 

Translation Services Project contracts, however, BOP institutions have few 

options for obtaining external translation services. 

 67 As mentioned previously, the BOP defines exotic languages as Middle Eastern, 

Pacific Island, and South Asian languages. 
U.S. Department of Justice 39

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Evaluation and Inspections Division 

The high cost of the Language Translation Services Project has limited 

its availability. The BOP Central Office, in a July 2003 memorandum,

recognized the potential high costs associated with contracted translation 

services and stated that “every effort must be taken to ensure BOP staff 

translators are utilized to the greatest extent possible prior to utilizing the

National Language Translation Services Project.”68 The BOP Central Office 

issued a second memorandum in March 2005, after the ADX Florence 

letter-writing incident, reminding institutions of the project and encouraging 

close coordination with the Central Office on its use. The memorandum 

stated in part: 

In light of the recent events related to the monitoring of 

inmates that require special monitoring, I want to 

emphasize the availability and use of these services and 

encourage all BOP facilities to work closely with the 

Central Office Correctional Services section in making a 

determination when translation services need to be 

utilized. Note: When translator services are deemed necessary 

the cost will be funded via utilization of a Central Office 

National Fund Code.69

According to SIS staff, the wording of the 2003 memorandum led 

institutions to rely on BOP staff to translate Arabic and other languages for 

non-SAMs international terrorist inmates’ communications until the March 

2005 memorandum was issued. (The BOP staff who provided these 

translations at the institutions we visited informed us that most 

translations were just summaries or a note to the SIS staff stating “OK.”) 

We found that after the March 2005 memorandum was issued the 

institutions began to actively make use of the contract translation services 

for non-SAMs international terrorist inmates, although they continued to 

use staff translators as well. 

In FY 2005, 16 BOP institutions used outside translation contractors 

compared with 10 institutions in the previous year. The amount of money 

the BOP spent on contract translations increased from $47,289 in FY 2004, 

to $743,381 in FY 2005. For FY 2006, the BOP budgeted $2 million for 

contractor translation services. According to both the BOP Director and the 

Assistant Director for the Correctional Programs Division, the BOP planned 

to continue funding the project despite the cost because, in the absence of 

 68 Michael B. Cooksey, Language Translation Services for Inmates Affiliated with 

International Terrorism, Correctional Programs Division, BOP, July 25, 2003.

69 John H. Vanyur, Language Translation Services, BOP CT Translation Special 

Project Funding, Correctional Programs Division, BOP, March 15, 2005. 
U.S. Department of Justice 40

Office of the Inspector General 

Evaluation and Inspections Division 

other options, it provided a needed service for the institutions housing nonSAMs international terrorist inmates. 

The Language Translation Services Project is not available for all 

translation needs. The project can only be used to translate 

communications that took place after March 2005 in Middle Eastern, Pacific 

Islands, and South Asian languages for specific international terrorist 

inmates. At one institution, the SIS office had untranslated 

communications from an international terrorist inmate in Japanese but 

could not use Language Translation Services Project contracts because the 

letters were written before March 2005. The SIS office was relying on a BOP 

employee at another institution to translate the communications. A 

considerable backlog remained because of the collateral nature of the 

employee’s translation work and the lack of other Japanese-speaking staff. 

For translation needs that do not qualify for funding by the project, 

the BOP encourages institutions to use local resources whenever possible. 

Some institutions reported using AT&T’s translation service in the past, but 

could no longer do so because of budget cuts.70 Other institutions have 

approached universities in their regions, but the universities expected 

payment for their services. Some institutions have sought non-traditional 

resources, such as electronic dictionaries and web sites, to look up words in 

Arabic. Some institutions also have asked the FBI for translation 

assistance, but according to the SIS staff we interviewed the FBI does not 

have enough translators to meet the demand in a timely manner. 

The process for accessing the Language Translation Services Project is 

cumbersome. The request and approval process for using the Language 

Translation Services Project takes several weeks because the BOP Central 

Office requires institutions to submit paperwork for each separate request 

for translation. To avoid creating a purchase order for each letter or 

telephone call, institutions usually save several weeks’ worth of letters or 

compact discs of telephone call recordings and submit them as a single 

request. We found at the institutions we visited that the turnaround time 

from the initial request to sending the job to the translation contractor 

ranged from 15 to 60 days. This does not take into account the time needed 

to actually have a document or telephone call translated. Figure 2 

illustrates the procedures for using the Language Translation Services 

Project contracts. 

 70 AT&T Language Line Services offers live “over-the-phone” translation in over 140 

languages for a fee. 
Figure 2: Procedure for Accessing the 

Language Translation Services Project

s r q

SIS drafts a purchase 

order and sends it to the 

institution’s business 

office along with a copy 

of the approval from 

Central Office. 

After the translation is 

completed, the 

institution’s business 

office processes the 

transaction and charges 

the cost to the Language 

Translation Services 

Project accounting code. 

The SIS staff member 

sends copies of letters or 

CDs of telephone call 

recordings to the vendor 

for translation. 

n An SIS staff member 

estimates the required 

translation (counts the number 

of words in each inmate letter 

or number of minutes for each 

telephone call). This workload 

estimate gives the BOP Central 

Office an indication of the cost 

of the translation. 

The SIS staff member 

sends a memorandum to 

an official in the 

Intelligence Section at 

Central Office requesting 

funding through the 

contract. 

The Intelligence Section 

reviews the appropriateness 

of the request and notifies 

the institution of approval, 

usually via e-mail. 

o p

Developments and Future Plans 

Since the discovery in March 2005 that the three 1993 World Trade 

Center bombers incarcerated at ADX Florence were corresponding with 

Islamic extremists, the BOP Executive Staff has taken several steps toward 

addressing the increased security monitoring and translation needs posed 

by the international terrorist inmates. A summary of the steps related to 

the BOP translation capabilities follows. 

• Arabic Language Specialists. As discussed previously, three fulltime Arabic Language Specialists were hired at ADX Florence in 

2005, the BOP’s first full-time translators. The three employees 

translate communications primarily for ADX inmates and sometimes 

for other institutions. In addition, at the time of our review, the 

three Language Specialists were undergoing Top Secret security 

background clearances and obtaining language proficiency 

certification by the FBI. The three Language Specialists had passed 

some, but not all, segments of the proficiency test. 

• Language Translation Software. BOP officials said that language 

translation software was promising, but does not yet meet BOP 

U.S. Department of Justice 41

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U.S. Department of Justice 42

Office of the Inspector General 

Evaluation and Inspections Division 

standards for accuracy. A representative from the Interagency 

Language Roundtable told us that while technology to translate 

typed text is available, a program that can effectively translate oral 

communications will not be developed for many years. Therefore, 

the BOP plans to utilize language translation software to initially 

assess inmates’ foreign language communication in the absence of a 

qualified translator. 

• Counterterrorism Unit. The BOP is developing a headquarters-level 

Counterterrorism Unit at a field site where four new full-time Arabic 

Language Specialists will be co-located with BOP intelligence 

analysts. The BOP believes that co-locating the Language 

Specialists and intelligence analysts will produce “consistent and 

cost-effective” translation of inmate communications. Additionally, 

the BOP plans to have a centralized “traffic cop” at this unit to make 

decisions as to who (GSA translator, Language Specialist, or 

volunteer staff translator) should be translating particular terrorist 

inmates’ communications based on a risk assessment. The BOP will 

collect and disseminate counterterrorism information and 

intelligence at the Counterterrorism Unit to representatives from 

different agencies, such as the FBI. According to the BOP, the goals 

are to consolidate counterterrorism “intelligence, produce products 

for the field, enhance linkages to other agencies, and manage 

translation services.” As of June 2006, the BOP had half of the 

Counterterrorism Unit staff on-board and expected to have the unit 

fully staffed by October 2006. While we believe the unit is beneficial, 

the intelligence analysis capability of the SIS offices at institutions

where terrorists are housed also needs to be increased. The SIS 

staff at institutions work firsthand with terrorist inmates and need 

the ability to analyze the activities of these inmates so that they can 

recognize and pass on the appropriate intelligence to the BOP 

Central Office Counterterrorism Unit. 

• Counterterrorism Training. The BOP informed us that the FBI, Drug 

Enforcement Administration, and Bureau of Alcohol, Tobacco, 

Firearms and Explosives are working together to develop general and 

component-specific intelligence analyst training that will be available 

to all agencies in the Department. The training will address the 

needs of the BOP for managing high-risk inmates, and BOP staff will 

attend the training in phases. 

• National Virtual Translation Center. The BOP has used the center, 

an interagency entity established to provide translation of foreign 

language communication for Intelligence Community clients, to 
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Office of the Inspector General 

Evaluation and Inspections Division 

translate some terrorist inmate communications. The BOP entered 

into a memorandum of understanding with the center in May 2006 

and plans to use its services as a potentially less expensive option to 

the Language Translation Services Project. 

Additionally, during a May 2006 interview the BOP Director and the 

Assistant Director for the Correctional Programs Division told us that the 

BOP would provide further direction to the institutions concerning the use 

of contractors and volunteer staff to translate inmate communications. 

Recommendations 

3. The BOP should develop a policy for in-house translation services that 

includes: 

a. Guidelines for when and how translations are to be conducted, 

(e.g., when word-for-word translation or a summary is required), 

including translations of communications to and from 

international terrorist inmates. 

b. Guidelines for the random verification of the accuracy of staff 

translations; 

c. Guidelines on the minimum proficiency levels for volunteer BOP 

staff who translate communications for terrorist inmates, inmates 

on mail or phone monitoring lists, or other high-risk inmates; 

d. Guidelines requiring supervisors to support collateral translation 

duties, and when work conflicts exist, to seek resolution with the 

Associate Warden or Warden; 

e. Guidelines that require BOP staff who volunteer as translators to 

track the number of hours and the languages for which they 

perform translation services as a collateral duty to allow future 

resource needs to be determined; and 

f. Guidelines that ensure institutions use the existing incentive 

awards program, especially cash awards, to encourage and 

recognize BOP volunteer staff translators. The BOP also should 

consider developing additional incentives and awards to encourage 

BOP staff to volunteer for collateral translation duties. 

4. The BOP should offer Spanish and other language training to staff, as 

dictated by translation needs. 
U.S. Department of Justice 44

Office of the Inspector General 

Evaluation and Inspections Division 

The BOP’s intelligence capability to analyze the content of terrorist 

inmates’ mail is not well developed. 

We found that the BOP lacks a sufficient intelligence capability to 

adequately analyze inmate mail to detect terrorist activity. The SIS offices in 

BOP institutions we visited have more experience with intelligence gathering 

to detect and deter traditional criminal activity than terrorism. The SIS staff 

have implemented investigative techniques and established relationships 

with other law enforcement agencies that assist SIS staff in gathering and 

analyzing information about criminal activity in BOP institutions, such as 

drug introduction and gang violence. However, we found that the methods 

used by SIS staff to analyze intelligence for traditional criminal activity are 

not sufficient for detecting terrorism activity. 

The BOP incarcerates international terrorist inmates who require 

sophisticated monitoring and analysis of their mail, conversations, and 

activities. Adequate monitoring of these inmates requires SIS staff to 

develop specialized capabilities, such as the ability to analyze mail and 

telephone calls in uncommon foreign languages, understand extremist 

ideology and radicalization, understand world-wide terror networks, perform 

link analysis, and oversee the enforcement of SAMs. However, the BOP does 

not provide the SIS staff with the intelligence training needed to adequately 

undertake these tasks. Further, we found that the BOP does not always 

take advantage of available intelligence resources, such as its Intelligence 

Operations Officers (IO) and the FBI.71 

The BOP does not provide its SIS staff with the intelligence training needed 

to adequately monitor terrorist inmate mail. 

SIS staff told us they do not receive sufficient training in intelligence 

analysis and counterterrorism issues so that they can identify suspicious 

content in the mail of terrorist inmates. The BOP has developed limited 

training on intelligence and counterterrorism and has not made training 

widely available to the SIS staff. BOP SIS Lieutenants attend a mandatory 

4-day SIS course when first assigned to the SIS office, but this course is 

focused on crime scene procedures and general criminal investigative topics 

and contains only minimal counterterrorism information. No part of the 

 71 The IO position exists at certain institutions such as the BOP’s Metropolitan 

Correctional Centers and Metropolitan Detention Centers. This management-level position 

is supervised by the Intelligence Operations Officer located at BOP Central Office in 

Washington, D.C. The IO works with law enforcement agencies and the courts to obtain 

information regarding inmates pending indictment or already in BOP custody. The 

information is to be used for determining the inmate’s security risk to the BOP and the 

public. BOP, Position Description for Correctional Program Specialist, Intelligence 

Operations Officer, July 15, 2005. 
U.S. Department of Justice 45

Office of the Inspector General 

Evaluation and Inspections Division 

training specifically examines intelligence analysis. Similarly, other BOP 

staff involved in monitoring inmate communications, particularly 

Correctional Officers, do not receive training in intelligence analysis and 

receive little training in counterterrorism. 

In addition to classes on general criminal investigative issues, the 

BOP told us that the 4-day SIS training course contains six classes – a total 

of 8 hours of training – that cover issues and procedures related to 

counterterrorism and intelligence issues. When we requested the course 

content of these six classes, the BOP provided us with six slide 

presentations. We reviewed these presentations and found that only two 

(approximately 2 hours) of the six classes focused specifically on terrorism 

and provided little information that could be used to help assess the content 

of terrorist inmate communications. None of the presentations included 

information on how to conduct counterterrorism intelligence analysis for 

assessing inmate communications. 

One of the presentations, “Terrorism,” provided a broad introduction 

to both domestic and international terrorism, the history of terrorism, and 

information on various terrorist groups. The presentation also included 

information on terrorist threats to corrections, recommended management 

strategies, how the BOP monitors terrorists, how to recognize radicalization, 

and pictures of all international terrorist inmates at ADX Florence. The 

other presentation, “Terrorism Awareness,” included information on the 

BOP’s management and monitoring of terrorist inmates, as well as pictures 

of some terrorist inmates. 

Two of the other slide shows the BOP provided focused on use of two 

BOP automated database systems. Although the systems are used for 

intelligence management and investigations by the SIS offices, the 

presentations focused on familiarizing the staff with the systems’ features 

and the procedures for accessing the databases and did not specifically 

mention terrorism or how to use the systems’ data for monitoring inmates. 

The remaining two presentations provided information on interviewing 

inmates and legal issues. Neither presentation included information specific 

to terrorism, although the subject of SAMs was presented in reference to 

legal issues. We also reviewed a video, “7 Signs of Terrorism,” used in the 

SIS training and found that it presented information on how to identify 

terrorism activities in the local community that may indicate an attack is 

being planned. 

The BOP also held a 3-day counterterrorism training session for SIS 

supervisors in September 2005. This training session included the following 

topics: 
U.S. Department of Justice 46

Office of the Inspector General 

Evaluation and Inspections Division 

• Overview of radical Islamic groups, 

• Behavioral mindset of a terrorist, 

• Security designation and validation, 

• Management of terrorist inmates, 

• SAMs inmates, 

• Correctional Intelligence Initiative, 

• Protective custody investigation, 

• Ion spectrometry, 

• Religious issues, 

• Analytic partnerships, 

• Successful investigative strategies, and 

• Labor management relations and Office of Internal Affairs issues. 

A representative from the FBI presented the segment on building analytic 

partnerships and discussed FBI and BOP information sharing and what the 

FBI does with the information from the BOP. 

Even though this 3-day training course provided the attendees indepth information on international terrorist inmates, preventing prison 

radicalization, and accessing intelligence resources from the FBI, the 

training did not include information on how to conduct intelligence analysis 

on international terrorist communications. The BOP reported that 52 

Special Investigative Agents and SIS Lieutenants, as well as 13 BOP Central 

Office staff, attended the September 2005 session. The BOP Assistant 

Director for the Correctional Programs Division stated that the training 

would be offered to the remaining Special Investigative Agents and SIS 

Lieutenants in August 2006. However, the training was not available to 

other SIS staff responsible for monitoring terrorist inmates’ mail and 

telephone calls. 

In addition, the BOP has offered a 1-hour course called “Terrorism 

Management and Response” during the Annual Refresher Training attended 

by all BOP employees. The session covers the definition and history of 

terrorism, types of terrorism, terrorist inmates, management strategies for 

international terrorist inmates, and radicalization and recruitment. 

While the course lesson plan for the Annual Refresher Training 

includes a general background and history of terrorism, as well as some 

counterterrorism information related to the BOP or the institution 

conducting the training, it does not include specifics on intelligence analysis 

that would assist in assessing inmate communications for suspicious 

content related to terrorism. The course covers prevention and detection of 

radicalization and recruitment, but gives only general information on 

monitoring and gathering intelligence. For example, the lesson plan states 
U.S. Department of Justice 47

Office of the Inspector General 

Evaluation and Inspections Division 

that 100 percent of terrorist mail and telephone calls should be monitored 

and that staff responsible for monitoring should be alerted to look for 

specific words and phrases. No other information about specific words or 

phrases to look for was provided. Also, the lesson plan states, “Gather 

Intelligence – Gathering Intelligence has been shifted from a criminal activity 

to proactive focus on terrorism activity,” but the presentation does not give 

guidance on how to gather such intelligence other than the traditional 

approach of observing inmate actions and behavior. 

Many BOP staff members, including Regional Directors, Wardens, 

Associate Wardens, and SIS personnel, agreed that SIS staff need more 

counterterrorism and intelligence analysis training so they can recognize 

suspicious content in inmate mail and telephone calls. For example, we 

received the following comments from three officials: 

We need to distinguish what we do with the international 

terrorist inmates as opposed to general population inmates. 

From a linguistic approach, even cultural diversity, we need to 

have basic training. There’s a Spanish immersion course, 

there should be something like that [to help staff translate the 

communications of] international terrorists. 

The BOP tried to give us some training, but we need a lot 

more. For international terrorists, there’s so many groups . . . 

we need to know what is the up-to-date stuff in the last 6 

months . . . any updated training to keep you on top of the 

game. 

Counterterrorism is a new area for the BOP and it is learning 

how to deal with terrorism inmates as it goes along. 

 

Although BOP personnel have extensive experience in dealing with 

criminals and gangs, we found a lack of understanding and knowledge of 

international terrorism and how terrorists operate that would allow BOP 

staff to better analyze terrorist inmate mail. For example, one SIS 

Lieutenant stated that he felt unprepared and ill-equipped to deal with 

international terrorist inmates because he lacks knowledge about inmates’ 

language, culture, and history that would enable him to better collect 

intelligence from their mail and telephone calls. Another BOP IO who 

worked with the FBI’s Joint Terrorism Task Force (JTTF) described the need 

for more counterterrorism intelligence training: “I don’t think people really 

understand the seriousness and sophistication of [these inmates].” 
Collaborative Intelligence Work 

We found examples of SIS staff who made 

significant efforts to pursue terrorist 

intelligence relating to BOP inmates. For 

example, the SIS staff at the Allenwood 

Correctional Complex and FCI Sheridan 

have productive and collaborative working 

relationships with the FBI Special Agents 

assigned to terrorism matters in these 

institutions. These relationships have 

facilitated intelligence and information 

sharing. The FBI agent assigned to 

Allenwood stated that the SIS staff were 

“active and knowledgeable” about 

international terrorist inmates. For 

example, the SIS staff recently intercepted a 

letter to an extremist leader in Europe from 

an international terrorist inmate housed at 

Allenwood. The FBI agent assigned to FCI 

Sheridan stated that he regularly received 

intelligence and information from the SIS 

staff on terrorist inmates, and that he 

regularly monitors the communications of 

these inmates. We also found that the MDC 

Brooklyn IO had a solid understanding of 

terrorism issues because of his past 

membership on the FBI’s JTTF and could 

identify potential terrorism security risks 

and share this information with the FBI. 

We found that this lack of understanding of terrorist inmates’ beliefs, 

motivations, and actions affected the BOP’s information sharing with the 

FBI. The FBI relies on the BOP 

to inform it of any suspicious 

communication or activity that 

occurs within the prisons. 

However, because of a lack of 

training on terrorism issues, the 

BOP does not always know when 

a communication or activity is 

suspicious enough to report it to 

the FBI. For example, when the 

SIS staff at ADX Florence learned 

that terrorist inmates had been 

corresponding with Islamic 

extremist inmates in Spanish 

prisons, the SIS staff never 

notified the FBI because the staff 

did not understand the 

implications of the 

correspondence for furthering 

terrorist activity. Many BOP staff 

we interviewed told us that they 

do not believe they have the 

training to adequately analyze 

intelligence from terrorist 

inmates and therefore may not 

recognize such threats to 

security. 

The BOP does not take full advantage of existing access to information and 

intelligence through its Intelligence Operations Officers. 

Although both MCC New York and MDC Brooklyn have IOs, neither 

institution has taken advantage of the greater access to the intelligence, 

information sharing, and resources that JTTF membership could provide 

the BOP for better monitoring its terrorist inmates’ mail, telephone calls, 

and activities. The BOP developed the IO position in 1999 to serve as the 

BOP’s link with federal law enforcement task force operations “which are 

engaged in operations which could provide meaningful intelligence 

information regarding inmates already in BOP custody,” particularly the 

U.S. Department of Justice 48

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U.S. Department of Justice 49

Office of the Inspector General 

Evaluation and Inspections Division 

 

FBI’s JTTF.72 At BOP detention centers in metropolitan areas like New York 

City where there is a constant population of new inmates arrested on 

terrorism-related charges, we believe a consistent exchange of information 

between the IOs and the JTTFs is vital to help BOP institutions determine 

the appropriate level of monitoring for these inmates. 

For example, the MDC Brooklyn IO, a former member of the New York 

JTTF, said he found out that two inmates at the MDC were terrorism 

suspects by reading their arrest warrants at the FBI. The charge sheet the 

MDC had received stated only, “Lying to a Federal Officer.” Because of the 

information the IO gained from the JTTF, the MDC was able to plan for the 

appropriate level of security and communications monitoring for the 

inmates. However, the IO has not been permitted to participate on the JTTF 

since January 2004 because of staffing shortages at the MDC and his 

assignments covering vacant posts. At MCC New York, the IO is not a 

member on the JTTF and therefore has not received background 

information on incoming inmates, according to MCC New York management 

staff. 

We interviewed Special Investigative Agents and SIS Lieutenants at six 

other BOP detention centers (one MCC and five Federal Detention Centers 

[FDC]) concerning the IO position and benefits of JTTF membership to the 

BOP. Two of these IOs were full-time JTTF members, two were part-time 

members, one IO was a liaison, and one FDC did not have an IO position.73 

At four of the five institutions with IOs, the staff told us that the IO position 

had enhanced information sharing between the BOP and the FBI. For 

example, an IO who was a JTTF member had access to FBI databases and 

could access information about a subject prior to the subject’s arrest. The 

BOP was then able to plan the appropriate security measures, such as mail 

and telephone monitoring, prior to the inmate being placed in BOP custody. 

The IO also could provide information to the JTTF based on intelligence 

gathering in the prison and could assist the task force in planning 

operations and utilizing investigative methods inside the prison. In addition 

to information sharing, JTTF membership allows IOs to develop skills and 

expertise in intelligence analysis and terrorism issues and to take advantage 

of the terrorism and intelligence training that the FBI offers to its JTTF 

members. 

 

72 At the time of our site visit, 15 international terrorist inmates were incarcerated 

at MCC New York and MDC Brooklyn. 

73 A member of the JTTF is supervised by and receives taskings from an FBI JTTF 

squad leader. A JTTF liaison is not a participating member of the JTTF and acts only as a 

point of contact. 
U.S. Department of Justice 50

Office of the Inspector General 

Evaluation and Inspections Division 

Developments and Future Plans 

 In addition to the Counterterrorism Unit that will serve as a 

clearinghouse for terrorism intelligence in the BOP, the BOP is pursuing the 

following initiatives to improve its intelligence capability. 

• Link Analysis Database. In June 2004, an Intelligence 

Management Analyst at the BOP Central Office created a database 

(which the BOP refers to as a link database) that enables the 

Analyst to conduct link analysis on terrorist inmates’ mail, 

telephone calls, and financial transactions.74 In May 2005, the 

Analyst began sending monthly link analysis reports to all SIS 

offices, regional offices, and the National Joint Terrorism Task 

Force (NJTTF). He encouraged the SIS offices to share the report 

with their local JTTFs. The Analyst said that he had received 

positive feedback from BOP institutions and the FBI on his link 

analysis reports. As one example of the report’s value, he said that 

he detected a link between several BOP international terrorist 

inmates and a specific address and reported this to the FBI. 

According to the Analyst, the FBI initiated an investigation based 

on the information, which the Analyst believed eventually led to an 

arrest. 

To further expand its link analysis capability, the BOP is 

developing a web-based tool that will access the BOP’s existing 

inmate data systems. Staff will be able to conduct link analyses on 

all inmates, not just international terrorist inmates, without laborintensive data entry into a separate database. Additionally, all SIS 

staff will be able to access the web-based link analysis tool at their 

institutions. The BOP expects this link analysis tool to be available 

in fall 2006. 

• Consolidation of International Terrorist Inmates. The BOP is 

planning to consolidate all international terrorist inmates in 

approximately six institutions for enhanced management and 

monitoring. The approximately 146 international terrorist inmates 

will be re-classified under a new classification system as to their 

security designations and the resulting information will be used to 

determine where to house the inmates. In May 2006, BOP officials 

said the re-classifications were about half completed and should all 

 74 The BOP’s database does not create links but rather extracts and organizes the 

data in a manner that enables the analyst to identify relationships or links in phone 

numbers, addresses, names, financial transactions, etc. 
U.S. Department of Justice 51

Office of the Inspector General 

Evaluation and Inspections Division 

be completed by October. The BOP believes that this consolidation 

will allow it to achieve better counterterrorism coverage with its 

limited intelligence, counterterrorism, and translation resources, 

while allowing the remaining institutions to concentrate on gangrelated activity and other prison-based issues. 

Recommendations 

5. The BOP should provide advanced and continuing counterterrorism 

intelligence training to its full-time SIS staff, Language Specialists, and 

Intelligence Operations Officers (IOs), especially in those institutions that 

house terrorist inmates. 

6. The BOP should clarify the role of IOs regarding membership on the 

FBI’s JTTFs and ensure that the institutions support the IOs in carrying 

out their full-time task force coordination, intelligence gathering, and 

information sharing duties. 

 
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Office of the Inspector General 

Evaluation and Inspections Division 

ADDITIONAL ISSUES 

The problems we identified regarding the monitoring of 

inmates’ mail also affected the monitoring of international 

terrorist and other high-risk inmates’ telephone calls, 

cellblock conversations, and social visits. Because of 

staffing reductions and the limitations of BOP’s foreign 

language translation capability, the institutions we visited 

were not monitoring 100 percent of telephone calls of 

inmates on the telephone monitoring lists, including Alert 

calls. For calls that were monitored, staff were not 

adequately trained in intelligence analysis and 

counterterrorism to recognize suspicious content in the 

conversations. We also found that the recording of 

cellblock conversations of SAMs inmates, although 

authorized, was occurring at only one BOP institution. 

Additionally, social visits of non-SAMs terrorist and other 

high-risk inmates were not audio monitored. 

Many of the BOP staff responsible for monitoring inmates’ mail also 

are responsible for monitoring inmates’ verbal communications. Because of 

the close association of mail monitoring to other types of inmate monitoring 

(for example, an inmate on a mail monitoring list is usually on the telephone 

monitoring list as well), we also reviewed the BOP’s monitoring activities for 

verbal communications. 

The BOP does not monitor a sufficient amount of inmate telephone 

calls. 

We found that telephone calls from high-risk inmates are not always 

monitored. The institutions we visited were not consistently meeting their 

monthly goals of monitoring 100 percent of Alert telephone calls or 100 

percent of telephone calls of other inmates on the regular telephone 

monitoring lists.75

According to the SIS staff at 7 of the 10 institutions we visited, the 

frequent rotation of staff in the telephone monitor position, as well as the 

reallocation of other positions that monitor telephone calls, caused many 

 75 Alert calls are a sub-set of the SIS-created telephone monitoring list. Alert calls 

trigger a signal on the INTRUDR telephone system for staff to “live” monitor the calls. 

Inmates placed on Alert telephone monitoring status by SIS staff are those inmates 

identified as posing the greatest risk of being engaged in illegal or suspicious activity and 

include terrorist inmates. 
calls to remain unmonitored. Additionally, telephone calls conducted in 

foreign languages were often not translated and therefore not monitored, 

including calls placed by inmates on the Alert and regular telephone 

monitoring lists. SIS staff told us that, as a result, they believed important 

intelligence information was missed. Although some institutions met or 

exceeded their goals for random monitoring, institutions did not consistently 

meet the 10 to 15 percent random monitoring goals set by Regional 

Directors. 

Reduction of Telephone Monitoring at 

MCC New York

We found the most serious example of a reduction in 

telephone monitoring at MCC New York. Because of 

the loss of 2 of 3 telephone monitor positions, only 3 of 

1,385 (0.2 percent) Alert calls were monitored in 

August 2005, leaving 99.8 percent of the calls 

unmonitored. 

At that time, John Gotti, Jr., a high-profile organized 

crime figure, was incarcerated there while on trial for 

kidnapping, attempted murder, racketeering, and other 

charges. According to MCC staff, Gotti made 50 calls 

between August 20, 2005, and September 20, 2005 – 

none of which were monitored. 

The elimination of two telephone monitor positions in 

the MCC’s SIS office required the MCC to reprioritize 

the duties of the one remaining telephone monitor. 

Previously, the three telephone monitors read mail, 

monitored phone calls, monitored all the institution’s 

surveillance cameras, and responded to subpoenas. 

Once two positions were eliminated, the remaining 

telephone monitor was told to focus on getting the mail 

out. When he arrived in the morning, he spent the first 

4 hours reading mail from inmates on the mail 

monitoring list, reading and copying SAMs letters and 

envelopes, and filling subpoenas. When he was 

finished with those activities, he could then monitor 

phone calls. 

Alert telephone calls of 

terrorist and other 

high-risk inmates are 

not always monitored. 

Despite the 

importance of telephone 

monitoring and the 

requirement to monitor 

100 percent of Alert 

calls for high-risk 

inmates, we found the 

percentage of Alert calls 

monitored varied widely 

by month and by 

institution.76 When we 

reviewed the 

institutions’ SIS records 

and INTRUDR data for 

FY 2005, we found that 

only 3 of the 10 

institutions we visited 

consistently monitored 

close to 50 percent of 

Alert telephone calls 

each month. Even the 

country’s highest 

security prison, ADX Florence, which houses the largest number of and 

most dangerous terrorist inmates, did not monitor 50 percent of Alert calls 

 

U.S. Department of Justice 53

76 During a December 2005 interview, the BOP Assistant Director for the 

Correctional Programs Division told us that “the BOP expects 100-percent review and 

reading of mail [of inmates on mail monitoring lists] and 100 percent of [Alert] telephone 

calls listened to by staff.” Also, a BOP memorandum, Handling of Terrorist/Suspected 

Terrorist Inmates, March 15, 2005, directs BOP institutions to monitor 100 percent of 

international terrorist inmates’ mail and telephone calls. 

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 54

Office of the Inspector General 

Evaluation and Inspections Division 

each month. Only 2 of 10 institutions monitored close to 100 percent of 

Alert calls almost every month – USP Allenwood and USP Beaumont. 

Subsequent to our field work, we requested telephone monitoring data 

from INTRUDR and SIS records from October 2005 to February 2006 for the 

10 institutions we visited. We found that of the eight institutions that 

monitored significantly less than 100 percent of Alert telephone calls during 

FY 2005, six had markedly increased the percentage monitored after our 

visits, and three of these institutions reached 100-percent monitoring 

during these 5 months of FY 2006. SIS staff at the six institutions told us 

that the rate of monitoring had improved either because they were ordered 

by their Regional Director to increase their Alert monitoring numbers or 

because their SIS office had focused on streamlining its Alert telephone call 

list by ensuring that only appropriate inmates were included on the list. 

Additionally, in December 2005, the BOP Central Office re-allocated a 

telephone monitor position to the SIS offices who lost these positions earlier 

in 2005 as a result of the mission critical roster. 

Telephone calls of other inmates on telephone monitoring lists are not 

consistently monitored. 

Although the BOP does not track and could not estimate how many 

telephone calls were monitored for inmates on institutions’ regular 

telephone monitoring lists, all SIS staff at the 10 institutions we visited told 

us that 100 percent of these calls were not being monitored as required by 

the BOP Assistant Director for the Correctional Programs Division.77 SIS 

staff told us that monitoring for these inmates was affected by the same 

factors that affected the monitoring of Alert calls – frequent rotation of staff 

in the telephone monitor position and staffing reallocations. 

The frequent rotation of telephone monitors and the reallocation of some 

positions in the SIS offices reduce intelligence gathering and analysis. 

As discussed in the mail monitoring section, many SIS telephone 

monitor positions are filled on a rotational basis and have been subject to 

staff reductions. We found that the loss of continuity caused by the rotation 

of telephone monitors reduced intelligence gathering from inmate telephone 

calls. Like most post assignments at BOP institutions, the telephone 

 77 Only Alert telephone calls are registered in the INTRUDR system. The regular 

telephone monitoring list is not registered in INTRUDR. Therefore, only Alert calls are 

tracked. 
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Office of the Inspector General 

Evaluation and Inspections Division 

 

monitor is a “bid” post subject to quarterly rotation.78 Frequent rotation of 

telephone monitors reduces the SIS offices’ knowledge of inmate behavior 

patterns and requires time-consuming training that reduces productivity. 

Also, SIS offices at 5 of the 10 institutions we visited had lost at least 1 

telephone monitor position, through the reallocation of this position, which 

decreased the amount of telephone monitoring accomplished. One SIS 

official at an institution where multiple terrorists were housed told us his 

office lost two of three telephone monitor positions and all three intelligence 

officer positions that also helped monitor telephone calls, due to the 

reallocation of the positions elsewhere in the institution. 

SIS staff at each institution we visited told us that not all telephone 

calls were being monitored adequately. For example, a Special Investigative 

Agent at one institution told us that during a 3-month period when an 

experienced telephone monitor was outbid for the position and a new staff 

member rotated in, the new staff member could monitor only 45 to 50 

percent of what the experienced staff member had monitored and wrote no 

incident (misconduct) reports. The experienced telephone monitor 

subsequently returned to the SIS office, and in his first month back he 

monitored 100 percent of the telephone calls for inmates on the monitoring 

list and issued eight incident reports to inmates. An FBI Special Agent who 

conducted investigations in this same prison told us that “the key to 

effective monitoring is continuity in the SIS department, which requires a 

full-time, dedicated staff.” 

A reduction in telephone monitoring directly affects the amount of 

intelligence gathered at an institution. SIS staff said they rely heavily on 

this type of intelligence to keep them abreast of planned criminal and 

other unauthorized activity in the institutions. At one SIS office, staff 

stated that the BOP was “missing critical information from not monitoring 

phone calls.” One Special Investigative Agent told us, “Phone calls are 

SIS’s main source of intelligence.” Another Special Investigative Agent 

said, “We’d be flying in the dark if not for mail and telephone monitoring.” 

The BOP Assistant Director for the Correctional Programs Division, 

told the OIG that he supported a quarterly rotation in the telephone monitor 

position because Correctional Officers should be “out walking around and 

talking to the inmates” to bring a current knowledge of inmates and inmate 

activity to the SIS office. However, the Assistant Director said he would 

consider less frequent rotation of the telephone monitor position in SIS 

offices after being briefed on the results of our review. 

78 A bid position is a post in which a Correctional Officer can make a request for 

assignment. Post assignments are generally based on seniority. 
U.S. Department of Justice 56

Office of the Inspector General 

Evaluation and Inspections Division 

Translation of foreign language telephone calls is sporadic. 

The same concerns BOP staff expressed about the lack of guidance on 

translating foreign language inmate mail apply to translating foreign 

language telephone calls. The March 15, 2005, BOP memorandum that 

discussed the Language Translation Services Project addressed only 

translations of mail and telephone calls for specific international terrorist 

inmates. The BOP has no foreign language translation guidelines for any 

other group of inmates. Institution staff, primarily the SIS staff, decide 

what priority will be placed on obtaining telephone translations for inmates 

other than non-SAMs terrorists. 

We found that BOP staff often do not listen to or translate calls in a 

foreign language from inmates on telephone monitoring lists (including Alert 

calls). Or, in some cases, BOP staff listen to the calls but do not understand 

the language. Staff who conducted telephone monitoring in 5 of the 10

institutions we visited informed us that if the institution did not have a staff 

member readily available to translate a foreign language phone call, the call 

was unlikely to get translated, even though the calls were recorded. 

Spanish is the foreign language most frequently spoken by BOP 

inmates. Staff at 7 of the 10 institutions we visited told us that there were 

not enough Spanish-speaking staff to translate telephone calls. The 

telephone monitor in one SIS office told us that when he was monitoring 

Alert calls and came across one in Spanish, he “just moves on to the next 

one,” and the call does not get translated. The SIS Technician in that same 

office stated, “I’m going to be honest with you, on mail and Alert phone 

calls, 9 out of 10 times, Spanish goes untranslated.” We also found a 

similar situation at a penitentiary we visited. An SIS Technician there told 

us: 

If the call is in Spanish [and the tower officer does not 

understand Spanish], the officer notes in the [INTRUDR] system 

“not able to monitor.” If the call is not picked up by SIS, the 

call is probably not listened to. If it’s an Alert call, it may also 

fall through the cracks. We only have so many staff. 

At another penitentiary because of quarterly staff rotations, the SIS 

office lost the telephone monitor who translated Spanish telephone calls 

that could not be translated by the tower officers. Because the new 

telephone monitor who rotated in did not speak Spanish, the calls went 

untranslated. An SIS Lieutenant at another institution stated, “Foreign 

language never gets translated – we operate on faith.” 
U.S. Department of Justice 57

Office of the Inspector General 

Evaluation and Inspections Division 

Although some institutions meet or exceed their goals for random telephone 

monitoring, random monitoring is still inconsistent. 

In addition to not meeting the BOP goal of monitoring 100 percent of 

calls for inmates on Alert and regular telephone monitoring lists, we found 

that only 3 of the 10 institutions we visited met or surpassed their goals for 

randomly monitoring between 10 and 15 percent of all other monthly 

telephone calls placed by inmates. While the BOP has a 5-percent goal for 

random monitoring of inmate telephone calls, the Regional Directors require 

institutions within their regions to randomly monitor a higher percentage of 

all calls from inmates not on monitoring lists, percentages that vary by 

region from 10 to 15 percent. Officials at several institutions we visited said 

they strive to monitor 100 percent of all inmate phone calls. For example, 

between October 2004 and February 2006 ADX Florence randomly 

monitored 100 percent of inmate telephone calls for inmates not on 

monitoring lists (except in December 2004, when 85.7 percent of calls were 

randomly monitored). Also during this same period, USP Allenwood 

consistently monitored between 90 and 100 percent of inmate telephone 

calls for inmates not on monitoring lists.79 

We found that in FY 2005, 7 of the 10 institutions we visited did not 

consistently meet their Regional Directors’ random telephone monitoring 

goals of between 10 to 15 percent. Four of these seven institutions never 

reached their Regional Director’s goal for random monitoring of inmate 

telephone calls during the entire fiscal year, and two of the seven 

institutions met their Regional Director’s goal only 1 and 2 months of FY 

2005. One of the institutions met the goals for only 6 months of the fiscal 

year. Additionally, one of these seven institutions was unable to meet even 

the minimum 5-percent random monitoring goal established by the Central 

Office.80 From October 2005 to February 2006, four of seven institutions 

that previously were not meeting the Regional Director’s goals increased 

their random telephone monitoring percentages and met the goals for each 

 79 USPs and the ADX Florence can be more successful at randomly monitoring a 

higher percentage of inmate calls than other BOP institutions because they have tower 

officers on the 12 a.m. to 8 a.m. morning shift who can monitor phone calls (recorded on 

the previous day) when there is limited activity in the facility. Institutions that have no 

towers must rely on the small SIS staff to monitor inmate calls or allow other staff members 

such as Unit Managers, Case Managers, or Associate Wardens to monitor phone calls from 

their computers. 

80 FCI Beaumont failed to meet the Central Office goal of monitoring 5 percent of 

random telephone calls in any month in FY 2005. MDC Brooklyn failed to meet the 5-

percent goal for 8 of 12 months, and MCC New York failed to meet the 5-percent goal for 

7 of 12 months. 
U.S. Department of Justice 58

Office of the Inspector General 

Evaluation and Inspections Division 

of those 5 months. However, the other three institutions were still not 

meeting the Regional Director’s goals during this 5-month period. 

Developments and Future Plans 

In interviews with the OIG, the BOP Director and the Assistant 

Director for the Correctional Programs Division emphasized their 

commitment to 100-percent monitoring of telephone calls of inmates on 

telephone monitoring lists. They acknowledged receiving feedback from 

institution staff describing the negative effects of losing telephone monitor 

positions on their monitoring and intelligence gathering. The Assistant 

Director said that despite its budget limitations, in December 2005 the BOP 

reallocated one telephone monitor position to all medium- and high-security 

and administrative institutions that previously lost this position. 

Recommendations 

7. The BOP should ensure that it monitors 100 percent of Alert telephone 

calls and translate all foreign language Alert calls. 

8. The BOP should ensure that it monitors 100 percent of the calls of 

inmates on the SIS telephone monitoring lists and translate all foreign 

language calls from inmates on this list. 

9. The BOP should review the frequency of the rotation and need for 

longer-term assignment of telephone monitor positions in SIS offices. 

10. The BOP should ensure that foreign language telephone calls randomly 

selected for monitoring are translated either live or from the INTRUDR 

recordings. 

Audio recording of cellblock conversations of SAMs inmates occurs at 

only one institution. 

Although SAMs authorize the BOP to audio record SAMs inmates’ 

cellblock conversations, three of the four institutions we visited that house 

SAMs inmates were not recording these conversations.81 Only ADX 

Florence was recording cellblock conversations for SAMs inmates, using 

 81 The authority to audio record inmate cellblock conversations is outlined in the 

SAMs as follows: “Pursuant to 28 C.F.R. § 501.3 . . . Recording Conversations Between 

Cells . . . USMS/BOP/Detention Facility/FBI are hereby authorized to place microphones 

in the hallways and elsewhere outside the inmate’s cell to record any statements made by 

the inmate to other inmates or staff . . . . The Notice of SAM given to the inmate shall notify 

the inmate that he is subject to such recording.” 
U.S. Department of Justice 59

Office of the Inspector General 

Evaluation and Inspections Division 

 

recording equipment available as part of the cellblock construction. The 

BOP has not issued guidance for when or under what circumstances 

cellblock conversations of SAMs inmates should be recorded. The BOP 

Director told us he does not see the value of putting recording devices in all 

cellblocks where SAMs inmates are housed. He stated that the BOP is 

capable of audio recording on a case-by-case basis when intelligence 

indicates a need. 

All Special Investigative Agents and SIS Lieutenants at the 

institutions we visited which house SAMs inmates informed us that they 

would like to listen to cellblock conversations of SAMs inmates but were 

unable to do so because they lacked specialized recording equipment and 

the SIS staff and translators to listen to the recordings. A manager at MCC 

New York told us that it would be helpful to monitor what terrorist inmates 

were saying, particularly when they were incarcerated during their trials. 

He said terrorist inmates under SAMs were conversing with other inmates at 

the facility and he believes the FBI would be interested in these 

conversations. However, neither the FBI nor the USAOs at the sites we 

visited had ever asked the BOP to record the cellblock conversations of 

SAMs inmates. 

Recommendation 

11. The BOP should consider implementing audio recording of cellblock 

conversations of all SAMs inmates and establish guidelines regarding 

when and under what circumstances to record these conversations. 

The BOP has limited capability to monitor conversations of terrorist 

and other high-risk inmates during social visits. 

The BOP does not audio record the social visits of non-SAMs terrorist 

and other high-risk inmates for monitoring purposes. As a result, despite 

the challenges of recording in a visiting room setting, the BOP may be 

missing opportunities to detect terrorist or criminal activity.82 Additionally, 

the BOP has not issued guidance for when or under which circumstances 

social visits of non-SAMs inmates should be recorded. As with cellblock 

conversations, the BOP Director stated that the BOP has the authority and 

82 The BOP has the authority to audio record social – but not legal – visits of 

inmates. In December 2005, ADX Florence informed us that it had begun recording some 

non-contact social visits of non-SAMs inmates. All social visits for SAMs inmates are noncontact and are monitored contemporaneously by the FBI as well as recorded for later 

monitoring and analysis. All other inmates, including terrorist and other high-risk 

inmates, may have contact social visits in a large, open visiting room. These contact visits 

are not recorded. 
U.S. Department of Justice 60

Office of the Inspector General 

Evaluation and Inspections Division 

 

tools to audio monitor specific visits with special advance preparation when 

intelligence indicates the need. 

None of the 10 institutions we visited had the capability to routinely 

audio record conversations in the institution’s large contact visiting room. 

Many of the non-SAMs international terrorist and other high-risk inmates 

are housed in the general population of BOP institutions and are allowed 

contact visits. All visiting room staff we interviewed at each of the 10 

institutions said the capability to listen to the visiting room conversations of 

selected inmates to detect planned terrorist and criminal activities or 

inappropriate behavior would be helpful. SIS staff told us that because 

inmates realized their telephone conversations and mail were monitored, 

they directed their family and friends to visit because they knew the 

conversations would not be audio monitored.83 

Most SIS staff members we interviewed said that while recording visits 

would be beneficial for intelligence gathering purposes, it would be 

extremely difficult to carry out. Correctional Officers told us that the 

visiting room gets very noisy during peak visiting hours, making it almost 

impossible to listen “live” to a specific conversation without special 

equipment. Limited staff resources within the SIS offices would be further 

stretched by the additional responsibility of listening to recordings of social 

visits, and translation of some of these conversations would be required. 

Additionally, all of the visiting rooms we observed were staffed with the 

minimum number of Correctional Officers to process the visits (i.e., search 

and escort inmates, escort visitors, and visually monitor the visiting room). 

Consequently, operating and monitoring audio recording equipment in these 

visiting rooms with the current staff contingent would not be viable. 

Recommendation 

12. The BOP should consider periodically audio recording social visits of 

non-SAMs terrorist inmates and other selected high-risk inmates in 

institution visiting rooms. 

83 The BOP can audio record inmates in non-contact visiting booths in only 8 of 

more than 100 BOP institutions nation-wide. 
U.S. Department of Justice 61

Office of the Inspector General 

Evaluation and Inspections Division 

 

The Department does not have a mandatory review 

process that requires all international terrorist inmates 

to be considered for SAMs upon initial incarceration and 

after conviction. In addition, the FBI’s intelligence 

gathering and information sharing with BOP institutions 

on terrorist inmates are inconsistent. Moreover, the FBI 

and U.S. Attorneys do not adequately share information 

about newly incarcerated (pretrial) terrorists with MCC 

New York, which increases the security risk to the 

institution. 

The Department does not have a mandatory review process to require 

that all international terrorist inmates are considered for SAMs upon 

initial incarceration and after conviction. 

We found that the Department has no policy requiring that all 

inmates arrested for international terrorism-related crimes are reviewed to 

determine whether they should be placed under SAMs.84 Unless a review is 

required, there is no guarantee that international terrorist inmates will be 

considered for SAMs. Consequently, terrorist inmates who pose a risk for 

continuing their terrorist activities while incarcerated may not receive the 

heightened security and communications monitoring they require during 

pretrial and post-conviction incarceration. 

Several documents provide information about the criteria and 

procedures for requesting SAMs for inmates – the Code of Federal 

Regulations, the U.S. Attorneys’ Manual, and Criminal Division guidelines. 

However, none of these documents requires that all international terrorist 

inmates be considered for SAMs. For example, the Code of Federal 

Regulations states that requests for SAMs may be submitted in writing to 

the Attorney General, through the Criminal Division’s OEO, by the head of a 

federal law enforcement agency (e.g., the prosecuting USAO) or the head of 

an agency in the U.S. intelligence community. The U.S. Attorneys’ Manual

includes a section on Procedures for Special Confinement Conditions, dated 

October 1997, which defines SAMs and provides brief guidance about where 

a written request is to be sent (OEO) and what information to include in the 

request. It also states that the USAO, if requesting SAMs, should first 

contact and discuss the request with FBI field personnel familiar with the 

inmate. 

84 Title 28 of the Code of Federal Regulations authorizes the BOP Director, upon the 

direction of the Attorney General, to implement the restrictive housing and communications 

monitoring conditions known as SAMs for national security reasons or to prevent acts of 

terrorism or violence. 
U.S. Department of Justice 62

Office of the Inspector General 

Evaluation and Inspections Division 

 

In March 2006, the Criminal Division’s Counterterrorism Section, in 

coordination with OEO, distributed SAMs guidance to coordinators of the 

USAOs’ Anti-Terrorism Advisory Councils (ATACs).85 This document states 

in part: 

Consideration of the appropriate use of SAMs is the 

responsibility of every Assistant U.S. Attorney handling a 

terrorism or terrorism-related matter and should be part of the 

overall planning and case strategy at the pre-charging stage. 

Even where SAMs are not sought or obtained at the detention 

hearing or other initial stage of the prosecution, they may 

become appropriate at later stages, during trial or post 

conviction, for example. Thus prosecutors must remain vigilant 

as to appropriate circumstances which would call for the 

imposition of SAMs at any stage of the prosecution.86 

The guidance encourages USAOs to discuss the proposed SAMs with 

the FBI (or other involved law enforcement or intelligence agencies) and also 

encourages the USAO to consult with the Criminal Division. We consider 

these guidelines, which are detailed and informative, to be a positive 

development, but they are not mandatory Department requirements. We 

believe that policy issued by the Attorney General or Deputy Attorney 

General requiring a SAMs review process and coordination among the 

USAOs, FBI, Criminal Division, and the Department’s newly formed 

National Security Division when inmates charged with international 

terrorism-related crimes are incarcerated initially and after they are 

convicted would better ensure that inmates who require the highest level of 

communications monitoring will receive it. 

The FBI’s intelligence gathering on terrorist inmates and information 

sharing with BOP institutions are inconsistent. 

We found that the FBI’s interaction with the BOP for intelligence 

gathering and information sharing on incarcerated terrorists varied widely 

among FBI field offices at the sites we visited. We also found that the FBI 

was not always timely in translating the foreign language communications 

of SAMs inmates, which could contain valuable sources of intelligence. 

85 The purpose of the ATACs is to facilitate the exchange of information at the 

federal, state, and local levels and between the public and private sectors; conduct 

counterterrorism training; and coordinate terrorism prosecutorial and investigative 

strategies within the Department. There is one ATAC Coordinator, who is an Assistant 

U.S. Attorney, for each of the 93 Judicial Districts. 

 

86 Criminal Division, Guidance on Special Administrative Measures (SAMs), 

February 14, 2006. 
U.S. Department of Justice 63

Office of the Inspector General 

Evaluation and Inspections Division 

The FBI assigns a Special Agent to each BOP institution from the field 

office or resident agency office with geographic jurisdiction for the 

institution. The Special Agent is responsible for investigating inmate-related 

criminal incidents that occur at the BOP institution.87 Depending on the 

size of the FBI office and the number of terrorist inmates housed at 

institutions in its jurisdiction, the Special Agent also may be responsible for 

handling terrorism-related inmate issues, or a second agent may be 

assigned to that task.88 

We found that two of the five FBI offices at sites we visited conducted 

little to no proactive intelligence gathering regarding the activities of the 

terrorist inmates or inmates described as terrorist associates. The ADX 

Florence SIS staff told us that the FBI showed little interest in the 17 

international terrorist inmates held at ADX until August 2004, when the FBI 

was told by Spanish authorities that three of those inmates – the 1993 

World Trade Center bombers – had been corresponding with Islamic 

extremists in Spanish prisons and with a fugitive wanted for questioning in 

a planned courthouse bombing in Madrid. After discovery of the World 

Trade Center bombers’ letter writing, these three inmates were placed under 

SAMs, and the FBI assigned two Special Agents from its resident agency 

office in Pueblo, Colorado, to handle terrorist issues at the Florence 

complex. 

The three FBI agents we interviewed who were responsible for both 

terrorism and criminal matters at the Beaumont Federal Correctional 

Complex in Texas were unaware that two inmates at the USP were 

incarcerated for international terrorism crimes. The SIS staff informed us 

that the local FBI office did not coordinate or proactively gather intelligence, 

share information, or monitor the activities of any terrorist inmate or those 

inmates described as terrorist associates at the complex. 

Backlogs in SAMs translations can result in missed intelligence. The 

FBI is required by SAMs provisions to complete translations of SAMs inmate 

communications within 60 days. However, staff in at least three of the 

 87 Inmate-on-inmate crimes are normally investigated by the FBI. The Department 

of Justice OIG, however, is responsible for investigating allegations of abuse, civil rights 

violations, bribery, fraud, and other violations by Department employees, contractors, and 

grantees, including allegations regarding BOP employees. The OIG does not have the 

authority to investigate violence by one inmate against another, unless it was done with the 

involvement of a BOP employee. 

 

88 In two of the four BOP facilities we visited, the FBI had assigned one agent for 

criminal issues and another agent for terrorist issues. MCC New York and MDC Brooklyn 

each had one FBI agent assigned to criminal issues, while terrorism inmates each had a 

separate case agent assigned. 
U.S. Department of Justice 64

Office of the Inspector General 

Evaluation and Inspections Division 

institutions we visited experienced delays of 6 to 18 months in obtaining 

Arabic translations of SAMs inmate communications from the FBI.89 For 

example, staff at the Allenwood complex in Pennsylvania sent nine letters to 

the FBI in New York for translation between April 2004 and August 2005 

that were not translated until November 2005. Officials from MCC New 

York said they waited 12 to 18 months for translations of SAMs inmates’ 

letters they sent to the FBI. Although the FBI is responsible for monitoring 

SAMs inmates, the FBI and the BOP must work together and use 

information from inmate mail and calls to detect and deter activities by 

SAMs inmates that pose a security risk to the institution and to the public. 

When asked about the delay in translation, the FBI stated that it does not 

have enough Arabic translators to meet the demand for translations for all 

its ongoing counterterrorism efforts.90 Consequently, the FBI said it must 

prioritize the translation workload, which leads to delays in providing some 

translations. Additionally, the lengthy delays in FBI translations create a 

management problem for the BOP because the SAMs inmates are not 

permitted to send out or receive their mail until it is translated. We believe 

that a delay of 6 to 18 months to send and receive mail is unreasonable, 

and it causes numerous complaints from the inmates. In one case, after a 

BOP Special Investigative Agent inquired to the FBI about a delay in mail 

translation for a SAMs inmate, he was verbally told by the FBI agent to 

release the mail to the inmate even though the FBI had not yet translated 

the mail and the contents were unknown. 

Examples of positive collaboration between the BOP and FBI. The 

Assistant Director of the Counterterrorism Division at FBI headquarters told 

us that the level of communication between the BOP and FBI is “very good, 

open, and fluid.” He believed the level of monitoring for terrorist inmates 

depends on the individual, the charges, the individual’s role in the crime, 

and on the FBI’s available resources. He stated that while the FBI has 

limited resources, the inmates have an unlimited ability to correspond. 

According to this FBI official, the FBI tries to “pick and choose those 

[inmates]” for monitoring and translation that can yield intelligence to “help 

the U.S. government.” 

During our site visits, we found instances where the FBI Special 

Agents assigned to BOP institutions were actively working with the BOP and 

 89 The BOP keeps copies of all SAMs inmates’ mail and forwards the originals to the 

FBI for translation. 

90 The FBI’s challenges in securing reliable translation resources were addressed in 

two OIG reports, Federal Bureau of Investigation’s Foreign Language Translation Follow-up, 

Audit Report 05-33, July 2005, and the Federal Bureau of Investigation’s Foreign Language 

Program – Translation of Counterterrorism and Counterintelligence Foreign Language 

Material, Audit report 04-25, July 2004. 
U.S. Department of Justice 65

Office of the Inspector General 

Evaluation and Inspections Division 

collecting intelligence on terrorist inmates. For example, the FBI Special 

Agents assigned to the Allenwood Correctional Complex and FCI Sheridan 

are proactively gathering intelligence, monitoring international terrorist 

inmates’ activities, and communicating with the SIS staff at the institutions 

on a regular basis. These FBI agents stated that their relationships with the 

SIS staff were excellent. Both agents were knowledgeable about the terrorist 

inmates’ communications, visits, associations, and movements inside and 

outside the prisons. These agents also referred leads and passed on 

information to other FBI field offices regarding potential terrorism activity in 

those jurisdictions that resulted from intelligence collected within the 

prisons. 

Developments and Future Plans

The FBI Assistant Director for Counterterrorism stated that during 

FY 2005 the FBI had sought to identify more systematically where terrorist 

inmates are incarcerated, as well as monitor their activities and with whom 

they were communicating. Toward that end, the FBI, through the National 

Joint Terrorism Task Force’s (NJTTF) Correctional Intelligence Initiative, 

directed all FBI field offices to open intelligence case files on any 

incarcerated international terrorist inmates within the field offices’ 

jurisdictions.91 Before this change in policy, the FBI case agent who 

arrested an inmate was responsible for monitoring that inmate, no matter 

where the inmate was incarcerated. For example, many international 

terrorists are investigated and prosecuted in the Southern District of New 

York but are sent to prisons all over the country to serve their sentences. 

Therefore, an FBI Special Agent in New York City was still responsible for an 

international terrorist inmate incarcerated in ADX Florence in Colorado. 

The FBI Assistant Director said he expected this policy change to increase 

communication and information exchange between the FBI and the BOP 

because the jurisdiction and responsibility for monitoring the international 

terrorist inmates is now transferred to the local FBI office where the prison 

is located. Case monitoring for inmates housed at, for example, ADX 

Florence is now conducted by the FBI Resident Agency Office located in 

Pueblo, Colorado. Closer proximity of the monitoring agent to the 

international terrorist inmate should assist the FBI in proactively gathering 

intelligence available within the BOP. 

 91 The FBI has two BOP staff working full time at the NJTTF, a multi-agency task 

force with representatives from the intelligence, law enforcement, defense, diplomatic, 

public safety, and homeland security communities. The NJTTF provides administrative, 

logistical, policy, financial, and training support and guidance to the JTTFs. According to 

the FBI, the NJTTF serves as the “point of fusion” for terrorism intelligence for the JTTFs, 

member agencies, and others in the intelligence community. 
U.S. Department of Justice 66

Office of the Inspector General 

Evaluation and Inspections Division 

 

MCC New York does not receive adequate information about newly 

incarcerated terrorist inmates to determine required monitoring. 

Management staff at the MCC New York reported that they routinely 

receive “remarkably little” information other than a single page synopsis of 

charges when they receive terrorist inmates.92 The BOP depends on the 

arresting agency and the prosecuting USAOs to provide information on the 

inmates’ background, criminal history, and security threat to determine the 

level of security monitoring for newly incarcerated inmates. However, we 

found that the FBI and USAOs do not always communicate this information 

to the BOP. MCC staff told us that the lack of information about pretrial 

inmates, who are unclassified as to their security level, prevents them from 

doing their job effectively and also puts the security of staff and the 

institution at risk. 

For example, MCC staff discovered in a news article, rather than from 

the FBI or USAO, that an international terrorist inmate housed at the MCC, 

and currently under SAMs, was a high-ranking member of al Qaeda, had 

martial arts and urban warfare training, and had trained to be a bodyguard 

for Osama bin Laden. Staff stated that when a new inmate is received, they 

have to generate a call to the FBI or USAO to ask, “What’s the story? [We] 

shouldn’t have to call them – they should call us. They’re very reluctant to 

give specifics . . . .” Staff told us that they need this information to plan for 

appropriate security monitoring, which includes monitoring mail, telephone 

calls, visitors, and inmate-to-inmate communications. 

As mentioned previously, an institution’s participation in the FBI’s 

JTTF and other task forces may affect the level of information sharing 

between the FBI and the BOP. All MCCs and MDCs have an Intelligence 

Operations Officer (IO) whose primary function is to oversee information 

gathering and sharing. The SIS staff we interviewed from five additional 

FDCs and MCCs where IOs were members of the JTTF cited a high level of 

information sharing. At MCC New York, however, the IO is not a member of 

the JTTF and therefore does not receive background information on 

incoming inmates. 

92 After an inmate’s conviction, the BOP receives a presentence investigation report 

containing information on the inmate’s offense, sentence, case background information, 

and personal information, including previous criminal history. Based on the information 

from the presentence investigation, the BOP determines each inmate’s security 

classification. 
U.S. Department of Justice 67

Office of the Inspector General 

Evaluation and Inspections Division 

Recommendations 

13. The Criminal Division and the National Security Division, on behalf of 

the Department, should develop a coordinated and mandatory review 

process for each newly incarcerated pretrial or convicted inmate 

associated with terrorism to determine the applicability of SAMs. This 

process should ensure, at a minimum, that the FBI, the prosecuting 

USAOs, the Criminal Division, and the National Security Division each 

review these inmates for SAMs applicability. 

14. The FBI should continue to develop and reinforce procedures for 

interacting with the BOP regarding international terrorist inmates, 

including monitoring of inmates, intelligence gathering, and sharing of 

information and intelligence. 

15. The BOP should review the information sharing procedures at the MCC 

New York and work with the FBI and the USAO to establish protocols 

for providing required inmate information about incoming terrorist and 

other high-risk inmates. The BOP should consider similar protocols at 

all MCCs and MDCs. 
U.S. Department of Justice 68

Office of the Inspector General 

Evaluation and Inspections Division 

CONCLUSION 

We concluded that the BOP’s procedures for monitoring inmate mail 

and verbal communications are deficient and limit the ability of BOP staff to 

detect terrorist and other criminal activities. The BOP does not adequately 

read the mail or listen to the telephone calls, visitor communications, or 

cellblock conversations of terrorist and other high-risk inmates. 

Furthermore, the BOP does not have sufficient resources to translate inmate 

communications in foreign languages and lacks staff adequately trained in 

intelligence analysis techniques to properly assess terrorist 

communications. 

Historically, the BOP’s monitoring efforts have been predominantly 

focused on detecting and deterring traditional criminal activities (such as 

inmate gang violence and drug trafficking) rather than terrorist activities. 

However, the BOP incarcerates international terrorist inmates who require 

sophisticated monitoring and analyses of their communications and 

activities. The BOP’s monitoring procedures, intelligence analysis, and 

foreign language capabilities have not evolved to that level. Consequently, 

serious lapses in security can occur, such as the letter writing incident at 

ADX Florence – the BOP’s highest security prison. 

Although the BOP has significant experience with high-risk inmates 

incarcerated for crimes unrelated to terrorism, its monitoring of these 

inmates also needs improvement. The BOP does not consistently monitor 

all of the written and verbal communications for high-risk inmates on 

monitoring lists, including foreign language communications. Therefore, the 

value of monitoring lists as a security and intelligence gathering technique 

is diminished. 

The random reading of inmate mail – another important security and 

intelligence gathering technique – is under-emphasized in the BOP. Unlike 

random telephone monitoring, which has improved in part through 

implementation of monitoring goals, the BOP has not set goals for the 

random reading of inmate mail. At the 10 institutions we visited, random 

reading varied widely and was a lesser priority than delivering the mail 

within BOP time frames. Giving too little attention to the random reading of 

inmate mail may prevent the BOP from identifying information that is 

important to the security of its institutions and the public. 

We also concluded that the BOP may be missing opportunities to 

gather intelligence about terrorist and other high-risk inmates by 

monitoring their conversations with visitors in the visiting rooms and with 
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other inmates in the cellblocks. Monitoring verbal exchanges in these 

settings poses challenges to the BOP, but inmates may plan and conduct 

illegal activities during visits or in the housing units if they know their mail 

and telephone calls are being monitored. 

We concluded that intelligence gathering and information sharing 

between some Department agencies and the BOP should be improved. The 

FBI was not consistently conducting proactive intelligence gathering at BOP 

institutions housing terrorist inmates. Also, the FBI and the USAOs did not 

consistently share information about newly incarcerated terrorist inmates so 

that appropriate monitoring and other security precautions could be 

determined by the BOP. This limited intelligence gathering and information 

sharing raises the risk of security incidents. 

Additionally, we concluded that after the ADX Florence incident, the 

BOP took proactive steps to improve its monitoring of terrorist and other 

high-risk inmates. For example, the BOP hired full-time Arabic language 

translators, established a Counterterrorism Unit, started planning to 

consolidate terrorist inmates into a few institutions, and continued to 

develop policies to limit the communications of these inmates. 

We also concluded that the Department should assess whether SAMs 

are applicable to each international terrorist inmate. Although the Criminal 

Division and the USAOs have guidance about the use of SAMs and how to 

submit a SAMs request, the Department does not have a mandatory process 

to ensure that every international terrorist has been reviewed for SAMs and 

that the Department’s components agree to forgo or apply SAMs for any 

particular inmate. Currently, the Department’s Office of Enforcement 

Operations reviews only the appropriateness of SAMs requests for terrorist 

inmates that USAOs, law enforcement agencies, or intelligence agencies 

choose to submit. If no requests are received, no Department-level 

evaluation of SAMs applicability occurs. We believe the Department must 

have a coordinated approach to decision-making about each terrorist 

inmate’s potential for continued terrorism activity while incarcerated and 

the level of monitoring required. 

To assist in the improvement of monitoring mail and verbal 

communications of terrorist and high-risk inmates, this report makes 15 

recommendations. Most of the recommendations address BOP issues, but 

several recommendations address other component or Department issues. 

We believe that if our recommendations are pursued to correct deficiencies 

in monitoring inmates, the security of BOP institutions and the public can 

be enhanced. 
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APPENDIX I: BOP PROGRAM STATEMENT 5265.11, 

POLICY FOR REJECTING INMATE CORRESPONDENCE 

The Warden may reject correspondence sent by or to an inmate if it is 

determined detrimental to the security, good order, or discipline of the 

institution, to the protection of the public, or if it might facilitate criminal 

activity. Correspondence which may be rejected by a Warden includes, but 

is not limited to, correspondence containing: 

• Matter which is nonmailable under law or postal regulations; 

• Matter which depicts, describes, or encourages activities which 

may lead to the use of physical violence or group disruption; 

• Information of escape plots, of plans to commit illegal activities, or 

to violate Bureau rules or institution guidelines; 

• Direction of an inmate’s business. An inmate, unless a pretrial 

detainee, may not direct a business while confined; 

• Threats; 

• A code; 

• Sexually explicit material (for example, personal photographs) 

which by its nature or content poses a threat to an individual’s 

personal safety or security, or to institution good order; or 

• Contraband (A package without prior authorization by the Warden 

is considered to be contraband). 
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APPENDIX II: JOB DUTIES OF SIS POSITIONS 

Position Major Job Duties 

Special 

Investigative Agent 

(GS-12) 

• Acts as lead investigator in SIS operations, 

• Supervises daily activities of SIS office: 

 Investigations of staff misconduct, criminal or 

administrative 

 Investigations of inmate misconduct, 

administrative or criminal 

 Phone monitoring 

 Mail monitoring 

 Intelligence gathering 

 Security threat analyses 

 Urinalysis testing 

• Serves as law enforcement liaison for the institution 

• Serves as intelligence officer for the institution (in the 

absence of an Intelligence Operations Officer) 

• Provides staff training in investigative issues, crime scenes, 

high-risk inmates 

• Maintains Administrative files on: 

 Staff 

 High-risk inmates 

 Use of force 

SIS Lieutenant 

(GS-9/11) 

• In the absence of an Special Investigative Agent, serves as 

lead investigator in SIS operations and assumes all the 

duties as listed under the Special Investigative Agent 

above 

• Where a Special Investigative Agent is assigned, serves as 

the subordinate Lieutenant to the Special Investigative 

Agent 

SIS Technician 

(GS-8)

• Serves as assistant to the Special Investigative Agent or 

SIS Lieutenant 

• Provides assistance during investigations, developing 

reports, preparing correspondence, maintaining evidence, 

and computer support 

• Assists in case preparation for presentation to the 

Disciplinary Hearing Officer, Office of Inspections, or the 

U.S. Attorney for possible prosecution 

• Loads, manages, and maintains advanced computer 

database systems and conducts computer searches within 

databases; trains SIS staff in operation of computer 

databases systems 

• Publishes automated computer reports 

• Performs standard and evidence photography, and 

maintains evidence files 

• Aids in evidence testing, handling, labeling, packaging 

and submission to federal crime labs 

• Serves as drug testing coordinator for inmate population 
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Position Major Job Duties 

Intelligence 

Operations Officer 

(GS-12)* 

* Reports directly to 

the Intelligence 

Officer at the BOP 

Central Office, 

Washington, D.C., 

and works closely 

with the Captain of 

the assigned 

institution 

Located only in select metropolitan areas at MDCs, MCCs and 

similar facilities 

• Actively serves as the agency liaison with all local Federal 

law enforcement task force operations, such as the Joint 

Terrorism Task Force (JTTF) and others which are engaged 

in operations that could provide meaningful intelligence 

information regarding offenders in BOP custody 

• In the capacity of team leader: 

 serves as the corrections expert in inmate 

activities within the institution 

 manages the local intelligence collection and 

dissemination plan 

 conducts databases research for task force 

dissemination and other law enforcement agencies 

 assists with criminal investigations 

 provides meaningful intelligence information 

regarding offenders already in BOP custody or 

projected as entering BOP custody in the future 

• Actively gathers intelligence regarding the identity of 

individual high-risk inmates entering custody 

• Obtains law enforcement documents on inmates pending 

indictment or in BOP custody. Particular attention is 

given to high-risk inmates. 

• Serves as subject matter expert for specific high-risk 

inmates in assigned geographic area; conducts detailed 

intelligence debriefs of high-risk inmates wishing to “drop 

out” of gangs – or provides interview strategies and 

background intelligence to those conducting the interview 

• Provides gang seminars and training on high-risk inmates 
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Position Major Job Duties 

Telephone Monitor • Responsible for maintaining security of institution 

• Regularly performs as a law enforcement officer during 

specifically appointed times 

• Will provide the Special Investigative Agent with gathered 

intelligence retrieved from the Inmate Telephone System 

• Information involving drug trafficking, involvement in 

other illicit activities, and linked communications relative 

to inappropriate behavior will be monitored on a daily 

basis 

• Responsible for maintaining information gathered from the 

remote listening sites (towers), analyzing this information, 

providing follow-up, and determining its content. Any 

information obtained will be reported to Special 

Investigative Agent/SIS 

• Responsible for identifying inmates who are making 

excessive telephone calls. Identification of the telephone 

number called, any other inmate using the telephone 

number, and if an inmate has been identified as making 

an excessive number of calls 

• Responsible for researching inmate’s assigned schedule, 

and if the inmate is using the telephone system when he is 

assigned to be at work, reporting this to the Special 

Investigative Agent/SIS 

• Responsible for maintaining profiles on specific high-risk 

inmates. 

• Responsible for assisting the Special Investigative 

Agent/SIS in referring criminal cases to the FBI, U.S. 

Marshals Service, U.S. Secret Service, or similar law 

enforcement agency 

• Assists the Special Investigative Agent/SIS during the 

investigation of complex criminal investigations 

• Assists the Special Investigative Agent/SIS in collecting, 

analyzing, and disseminating strategic intelligence as it is 

related to high-risk inmates 

• Assists in conducting counterintelligence operations 

• Responsible for information and intelligence exchange with 

other institutions 

• Must be familiar with BOP Program Statements, manuals, 

and general principles of investigation 
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Position Major Job Duties 

Intelligence 

Research Specialist 

• Assigned only in select metropolitan areas and serves as a 

member of a team led by the Intelligence Operations 

Officer (IO) 

• Serves as the link between the IO and local institution 

staff to gather/share raw information and intelligence 

derived from the assigned IO’s collection activities into 

intelligence databases, summaries, briefing papers, threat 

assessments, training materials, and similar intelligence 

products for BOP-wide use 

• As a member of the intelligence team: 

 serves as a corrections expert on inmate activities 

within the institution 

 conducts BOP database research for task forces 

and other agencies 

 assists with criminal investigations 

 provides meaningful intelligence information 

regarding offenders already in BOP custody or 

projected as entering BOP custody in the future 

• Performs analysis of materials obtained by the IO as well 

as other documents (such as indictments, arrest warrant 

affidavits, sentencing memoranda, pretrial detention 

reports, and similar sensitive original source law 

enforcement documentation) regarding inmates pending 

indictment, or already being held in BOP custody to use 

for operational intelligence purposes and for intelligence 

forecasting. Also directly collects “open source” materials 

from the press, broadcast media, internet, and similar 

sources which will aid in the analysis of issues of security 

concern to the BOP 

• Assists in developing interdiction strategies to include 

telephone monitoring strategies, work assignments, 

housing, and special accountability controls 

• Assist the IO in coordinating the release and sharing of 

BOP intelligence with law enforcement agencies 

• Is the alternate BOP Subject Matter expert for specific 

high-risk inmates home based in the assigned BOP 

geographical area 

• Assists in providing training 
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APPENDIX III: INMATE RESTRICTIONS AND FBI 

RESPONSIBILITIES RELATED TO 

SPECIAL ADMINISTRATIVE MEASURES 

Issue SAMs Restriction FBI Responsibilities 

Telephone 

Calls 

• Non-legal calls limited to 

immediate family members 

• One non-legal call a month 

• Calls will be recorded 

• To contemporaneously 

monitor the phone call. 

• To analyze the recorded 

phone call (recording 

provided by the BOP) 

• To confirm relationship of 

immediate family members 

Mail • Non-legal mail restricted to 

immediate family members 

• Will be copied, forwarded to 

the FBI, and analyzed by 

the FBI 

• To review and analyze all 

non-legal mail 

• To return any English 

language mail within 14 

business days and nonEnglish mail within 60 

business days to allow for 

translation 

• To return any mail where 

there is suspicion of a code 

within 60 business days to 

allow for decoding 

• To confirm relationship of 

immediate family members 

Visits • Non-legal visits limited to 

immediate family members 

• All non-legal visits will be in 

English, unless a fluent FBI, 

U.S. Marshals Service 

(USMS), BOP, or Detention 

Facility (DF)-approved 

translator can 

contemporaneously monitor 

the visit 

• Minimum of 14 calendar 

days in advance written 

notice to the USMS, BOP, or 

DF 

• No physical contact 

• One adult visitor at a time 

(FBI-verified children may 

visit with pre-approved 

adult visitor) 

• Contemporaneously 

monitor the non-legal visit 

• Analyze translation of visit 

• To confirm relationship of 

immediate family members 
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Issue SAMs Restriction FBI Responsibilities 

Periodicals, 

Newspapers, 

Television 

and Radio 

• May have access to 

publications determined not 

to facilitate criminal activity 

or be detrimental to 

national security 

• Shall have access to 

publications after a delay of 

at least 30 days 

• Not allowed to share 

publications with other 

inmates 

• Restricted from access to 

channels/stations which 

primarily broadcast news 

• Review and determine 

which publications inmate 

may have access to 

• Determine which parts of 

publication to remove 

before giving to inmate 

• Translate any publications 

and review/analyze the 

translations 

 

Source: BOP 
 APPENDIX IV: THE FEDERAL BUREAU OF 

PRISONS’ RESPONSE 

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APPENDIX V: OIG’S ANALYSIS OF THE FEDERAL 

BUREAU OF PRISONS’ RESPONSE 

On August 18, 2006, the OIG sent a copy of the draft report to the 

Federal Bureau of Prisons (BOP) with a request for written comments on 

Recommendations 1 through 12 and 15. The BOP responded to the OIG in 

a memorandum dated September 19, 2006. The BOP concurred with all the 

recommendations. 

Recommendation 1: The BOP should ensure that all mail of inmates 

on its mail monitoring lists is read, including translating and reading of 

foreign language mail, and that the institutions’ monitoring of this mail is 

tracked. 

 

 Status. Resolved – Open. 

Summary of the BOP’s Response. The BOP concurred with the 

recommendation stating that inmates placed on mail monitoring status 

should be held to a higher correctional management standard based on 

identified risk factors, and that these inmates’ communications should be 

reviewed by appropriately trained staff as soon as practical. Toward that 

end, the BOP is exploring procedural modifications and technology aides to 

develop uniform standards and tracking of inmate communications. The 

BOP anticipates completing this initiative by December 2007. 

 

The OIG’s Analysis. The actions planned by the BOP are responsive 

to the recommendation. Please provide a status report on the development 

of the procedural modifications and tracking system by December 1, 2006. 

Recommendation 2: The BOP should set minimum target 

percentages of incoming and outgoing mail for random reading, including 

translating and reading foreign language mail, and track the institutions’ 

efforts to comply with these goals. 

Status. Resolved – Open. 

Summary of the BOP’s Response. The BOP stated that it has some 

concerns about implementing this recommendation because the resources 

needed to raise the level of current random reading of mail would be 

significant. Instead, the BOP proposed delaying targets for random reading 

until it fully implements a new electronic messaging system called the Trust 

Fund Limited Inmate Communication System (TRULINCS). TRULINCS, 

which is in the pilot testing stage at 11 BOP facilities, allows inmates to 
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communicate with family and friends through the use of electronic 

messaging via a secure work station. The BOP stated that it intends to 

implement TRULINCS Bureau-wide in the next several months and expects 

the amount of incoming and outgoing inmate mail through the U.S. postal 

system to be greatly reduced. The BOP believes use of TRULINCS along 

with reading all mail for inmates on mail monitoring lists will ensure that a 

high percentage of inmate mail is read daily. 

The OIG’s Analysis. The BOP’s implementation of TRULINCS as a first 

step in improving random reading of inmate mail is responsive to the 

recommendation. However, TRULINCS may not preclude the need for 

setting targets for random reading of inmate mail written in English and 

foreign languages. Inmates are not required to use TRULINCS instead of the 

U.S. postal system, and the amount of hardcopy inmate correspondence 

may remain significant. Therefore, mailroom and housing unit staff may 

still be required to randomly read a meaningful percentage of hardcopy 

incoming and outgoing mail for inmates not on mail monitoring lists. The 

BOP’s response also does not state whether TRULINCS is to be used by 

inmates who communicate in foreign languages. By December 1, 2006, 

please provide the results of the pilot tests, which should include data about 

TRULINCS’s effect on intelligence gathering and the amount of U.S. mail as 

well as TRULINCS’s applicability to foreign language communication, and a 

status report on the implementation of TRULINCS Bureau-wide. 

Recommendation 3: The BOP should develop a policy for in-house 

translation services that includes: 

a. Guidelines for when and how translations are to be conducted (e.g., 

when word-for-word translation or a summary is required), 

including translations of communications to and from international 

terrorist inmates; 

b. Guidelines for the random verification of the accuracy of staff 

translations; 

c. Guidelines on the minimum proficiency levels for volunteer BOP 

staff who translate communications for terrorist inmates, inmates 

on mail or phone monitoring lists, or other high-risk inmates; 

d. Guidelines requiring supervisors to support collateral translation 

duties, and when work conflicts exist, to seek resolution with the 

Associate Warden or Warden; 
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e. Guidelines that require BOP staff who volunteer as translators to 

track the number of hours and the languages for which they 

perform translation services as a collateral duty to allow future 

resource needs to be determined; and 

f. Guidelines that ensure institutions use the existing incentive 

awards program, especially cash awards, to encourage and 

recognize BOP volunteer staff translators. The BOP also should 

consider developing additional incentives and awards to encourage 

BOP staff to volunteer for collateral translation duties. 

 

 Status. Resolved – Open. 

Summary of the BOP’s Response. The BOP concurred with the 

recommendation. 

a. The BOP stated that the Special Investigative Supervisor (SIS) 

Manual is undergoing review and revision and will include 

language about timely completion of summary translations for all 

forms of foreign communication for all international terrorist 

inmates. Verbatim translations will be required for suspicious 

content. 

b. The BOP stated that staff working as volunteer translators require 

sufficient language proficiency to recognize noteworthy intelligence 

for further analysis. The BOP stated that it has formed a work 

group to develop language competency criteria for BOP staff 

serving as volunteer translators or full-time translators and has 

developed a Reimbursable Agreement between agencies for 

language testing that is pending approval for fiscal year (FY) 2007. 

The BOP anticipated implementing language proficiency guidelines 

by January 2008. 

c. The BOP referred to its response for item b above. 

d. The BOP stated that it will issue a procedural directive in 

December 2006 mandating local support for staff performing 

approved collateral language translation services. 

e. The BOP stated that monitoring of foreign language telephone calls 

is tracked automatically through the INTRUDR system. The BOP 

will consider uniform tracking of translations performed for inmate 

correspondence. 
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f. The BOP stated that it will reiterate existing incentive awards 

policy to wardens to ensure staff volunteer translators are 

recognized for their efforts. The BOP also will consider developing 

additional incentives and awards to encourage staff to volunteer for 

collateral translation duties. The BOP will issue guidance to 

wardens by December 2006. 

The OIG’s Analysis. The actions planned by the BOP are generally 

responsive to the recommendation. We believe the BOP’s translation policy 

requires some additional steps for items a, b, and e. 

 

a. The policy should include directions on whether outside contract 

services or volunteer staff (whose language proficiency levels have 

been untested in the past) should be used for translating foreign 

language communications of international terrorist inmates. 

 

b. The policy should include procedures for randomly verifying the 

accuracy of staff translations. 

e. The policy should require staff to track the time spent translating 

correspondence and telephone calls and the languages translated. 

It is unclear whether INTRUDR automatically tracks this type of 

information for inmate calls. 

Please provide a status report on the translation policy by December 1, 

2006. 

Recommendation 4: The BOP should offer Spanish and other 

language training to staff, as dictated by translation needs. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP stated that a contractor is providing Arabic 

language training to BOP’s full-time translators at ADX Florence. The BOP 

is exploring the use of this contractor for in-house language training at 

other institutions. Additionally, the BOP is reviewing courses at the Defense 

Language Institute, which provides a variety of language training to federal 

agencies. The BOP scheduled three Spanish Language Training Program 

courses during FY 2007 and will explore development of an advanced 

Spanish language course. The BOP anticipates the completion of these 

initiatives by October 2008. 
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 The OIG’s Analysis. The actions planned by the BOP are responsive 

to the recommendation. By December 1, 2006, please provide the dates for 

the scheduled Spanish courses and the status of the BOP’s decisions on 

developing an advanced Spanish course and using the contractor and the 

Defense Language Institute as sources for other language training. 

Recommendation 5: The BOP should provide advanced and 

continuing counterterrorism intelligence training to its full-time SIS staff, 

Language Specialists, and Intelligence Operations Officers (IO), especially in 

those institutions that house terrorist inmates. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP stated that in August 2006, the Central Office 

Intelligence Section provided Terrorist Management Training for SIS staff 

that had not previously attended the course. The BOP further stated that 

the Federal Bureau of Investigation (FBI) agreed to conduct an ongoing 40-

hour course on intelligence gathering and analysis and that the first class 

will occur the week of December 4, 2006. The FBI also agreed to provide an 

abridged form of this training to newly appointed SIS staff. Select BOP staff 

will become certified as trainers and will train the remaining BOP 

intelligence and SIS staff. The BOP also is evaluating a variety of computerbased training programs. The BOP anticipates completing these initiatives 

by October 2007. 

 The OIG’s Analysis. The actions planned by the BOP are responsive 

to the recommendation. By December 1, 2006, please provide a copy of the 

40-hour course content, number of planned participants, dates scheduled 

for the course, and plans for providing training to other intelligence and SIS 

staff. 

Recommendation 6: The BOP should clarify the role of Intelligence 

Operations Officers (IO) regarding membership on the FBI’s Joint Terrorism 

Task Forces (JTTF) and ensure that the institutions support the IOs in 

carrying out their full-time task force coordination, intelligence gathering, 

and information sharing duties. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred in part with the 

recommendation. The BOP stated that many IOs participate on task forces 

other than JTTFs and therefore cannot participate full time on JTTFs. 

However, by November 2006, the BOP stated that it will issue guidance to 
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wardens that requires every institution to identify at least one staff member 

to be a certified liaison with the local JTTF. 

 The OIG’s Analysis. The actions planned by the BOP are responsive 

to the recommendation. Please provide a copy of the guidance to wardens 

by December 1, 2006. 

 Recommendation 7: The BOP should ensure that it monitors 100 

percent of Alert telephone calls and translates all foreign language Alert 

calls. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation and stated that it will revise its policy to ensure all 

communications for inmates on monitoring lists are properly translated, if 

applicable, and reviewed by trained staff. The BOP anticipates completing 

the policy revision by July 2008. 

 The OIG’s Analysis. The action planned by the BOP is responsive to 

the recommendation. However, the anticipated completion date is untimely. 

By December 1, 2006, please provide an earlier completion date or an 

explanation for the delayed date and the BOP’s interim plans to ensure that 

telephone calls for inmates on telephone monitoring lists (which include 

Alert calls) are translated and monitored during the policy revision period. 

 Recommendation 8: The BOP should ensure that it monitors 100 

percent of the calls of inmates on the SIS telephone monitoring lists and 

translates all foreign language calls from inmates on this list. 

Status. Resolved – Open. 

Summary of the BOP’s Response. The BOP concurred with the 

recommendation and referred to Recommendation 7 for its planned actions. 

 The OIG’s Analysis. Please see our analysis for Recommendation 7. 

 Recommendation 9: The BOP should review the frequency of the 

rotation and need for longer-term assignment of telephone monitor positions 

in SIS offices. 

Status. Resolved – Open. 
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Summary of the BOP’s Response. The BOP concurred with the 

recommendation and stated that it will review the roster rotation for the 

telephone monitor position because of the position’s importance in providing 

timely and proficient monitoring of telephone communications. The BOP 

anticipates a decision on the rotation policy by May 2007. 

 The OIG’s Analysis. The action planned by the BOP is responsive to 

the recommendation. Please provide a status report on the roster rotation 

review by December 1, 2006. 

Recommendation 10: The BOP should ensure that foreign language 

telephone calls randomly selected for monitoring are translated either live or 

from the INTRUDR recordings. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP is conducting an internal assessment of 

language translation procedures and will decide whether to include random 

sampling or selection of foreign language telephone calls. The BOP 

anticipates a decision on translating foreign language telephone calls by 

June 2008. 

 The OIG’s Analysis. The action planned by the BOP is responsive to 

the recommendation. However, the anticipated completion date of the 

internal assessment and decision on randomly translating foreign language 

telephone calls is untimely. By December 1, 2006, please provide an earlier 

completion date or an explanation for the delayed date and your interim 

plans for ensuring that a meaningful percentage of foreign language 

telephone calls for inmates not on telephone monitoring lists will be 

translated during the internal assessment period. 

Recommendation 11: The BOP should consider implementing audio 

recording of cellblock conversations of all Special Administrative Measures 

(SAMs) inmates and establish guidelines regarding when and under what 

circumstances to record these conversations. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP stated that it will consult with the FBI to assess 

the current recording practices to determine if discretionary recording would 

be beneficial. The BOP will convey its final decision by May 2007. 
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 The OIG’s Analysis. The action planned by the BOP is responsive to 

the recommendation. Please provide the status of the assessment of 

recording practices by December 1, 2006. 

Recommendation 12: The BOP should consider periodically audio 

recording social visits of non-SAMs terrorist inmates and other selected 

high-risk inmates in institution visiting rooms. 

Status. Resolved – Open. 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP stated that it will assess the non-contact 

visitation process at ADX Florence. The BOP expects to provide the 

assessment, final decision, and implementation plan, if applicable, by 

March 2007. 

 The OIG’s Analysis. The action planned by the BOP is responsive to 

the recommendation. Please provide the status of the assessment by 

December 1, 2006. 

Recommendation 15: The BOP should review the information 

sharing procedures at Metropolitan Correctional Center (MCC) New York 

and work with the FBI and the U.S. Attorney’s Office (USAO) to establish 

protocols for providing required inmate information about incoming terrorist 

and other high-risk inmates. The BOP should consider similar protocols at 

all MCCs and Metropolitan Detention Centers (MDC). 

Status. Resolved – Open. 

 

 Summary of the BOP’s Response. The BOP concurred with the 

recommendation. The BOP stated that the Warden of MCC New York will 

work with the local FBI and USAO to develop protocols for sharing 

information about terrorist and other high-risk inmates. The Assistant 

Director of the Correctional Programs Division will review the protocols for 

possible application at the national level. 

 The OIG’s Analysis. The actions planned by the BOP are responsive 

to the recommendation. Please provide the status of the protocols by 

December 1, 2006. 
APPENDIX VI: THE CRIMINAL DIVISION’S 

RESPONSE 

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APPENDIX VII: OIG’S ANALYSIS OF THE CRIMINAL 

DIVISION’S RESPONSE 

On August 17, 2006, the OIG sent a copy of the draft report to the 

Criminal Division with a request for written comments on Recommendation 

13. The Criminal Division responded to the OIG in a memorandum dated 

August 28, 2006. The Criminal Division concurred with the 

recommendation but proposed minor language changes. 

Recommendation 13: The Criminal Division and the National 

Security Division, on behalf of the Department, should develop a 

coordinated and mandatory review process for each newly incarcerated 

pretrial or convicted inmate associated with terrorism to determine the 

applicability of SAMs. This process should ensure, at a minimum, that the 

FBI, the prosecuting USAOs, the Criminal Division, and the National 

Security Division each review these inmates for SAMs applicability. 

 

 Status. Resolved – Open. 

Summary of Criminal Division’s Response. The Criminal Division 

concurred with the recommendation that the Department should develop a 

coordinated and mandatory review process for each newly incarcerated 

pretrial or convicted inmate associated with terrorism to determine the 

applicability of SAMs. The Criminal Division stated that since its 

Counterterrorism, Counterespionage, and Office of Intelligence Policy and 

Review sections will be moving to the Department’s newly created National 

Security Division, the new Division should share the responsibility with the 

Criminal Division in developing this coordinated and mandatory review. In 

March 2006, the National Security Division of the Department was 

authorized in the USA Patriot Improvement and Reauthorization Act of 

2005. The Division will be formed once the nominated Assistant Attorney 

General for this new Division is confirmed. 

The Criminal Division plans to implement this recommendation by 

proposing a change to provisions of the U.S. Attorneys’ Manual and is 

currently drafting the text for this change, which will eventually be 

submitted to the Attorney General Advisory Committee for its approval. The 

Criminal Division anticipates the entire process will take 6 months. 

The OIG’s Analysis. The action planned by the Criminal Division to 

update the U.S. Attorneys’ Manual with language that requires a coordinated 

and mandatory SAMs review process for each newly incarcerated pretrial or 

convicted inmate associated with terrorism is responsive to the 
U.S. Department of Justice 97

Office of the Inspector General 

Evaluation and Inspections Division 

recommendation. Please provide us with a status report on the updated 

U.S. Attorneys’ Manual language reflecting this requirement by December 1, 

2006.
APPENDIX VIII: THE FEDERAL BUREAU OF 

INVESTIGATION’S RESPONSE 

U.S. Department of Justice 98

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 99

Office of the Inspector General 

Evaluation and Inspections Division 
U.S. Department of Justice 100

Office of the Inspector General 

Evaluation and Inspections Division 

APPENDIX IX: OIG’S ANALYSIS OF THE FEDERAL 

BUREAU OF INVESTIGATION’S RESPONSE 

On August 17, 2006, the OIG sent a copy of the draft report to the 

Federal Bureau of Investigation (FBI) with a request for written comments 

on Recommendation 14. The FBI responded to the OIG in a memorandum 

dated September 22, 2006. The FBI concurred with the recommendation. 

Recommendation 14: The FBI should continue to develop and 

reinforce procedures for interacting with the BOP regarding international 

terrorist inmates, including monitoring of inmates, intelligence gathering, 

and sharing of information and intelligence. 

Status. Resolved – Open. 

 Summary of the FBI’s Response. The FBI concurred with the 

recommendation and stated that it will continue to reinforce and improve its 

Correctional Intelligence Initiative (CII), which facilitates coordination of 

terrorism issues between the FBI, the BOP, and state and local correctional 

agencies. The FBI will continue its training of CII Coordinators in each field 

office, who in turn help train correctional personnel. Further, the FBI will 

continue to grant BOP representatives to the Joint Terrorism Task Forces 

full access to FBI counterterrorism resources. 

 The OIG’s Analysis. The actions planned by the FBI are responsive to 

the recommendation. Please provide the status of the FBI’s improvements 

to the CII and its training of CII Coordinators and BOP personnel by 

December 1, 2006.