a

GAO

United States General Accounting Office

Report to Senator Jon Kyl,

U.S. Senate

January 2004 EXPORT CONTROLS

Post-Shipment 

Verification Provides 

Limited Assurance 

That Dual-Use Items 

Are Being Properly 

Used

GAO-04-357
www.gao.gov/cgi-bin/getrpt?GAO-04-357.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Joseph A. 

Christoff at (202) 512-8979 or 

christoffj@gao.gov. 

Highlights of GAO-04-357, a report to 

Senator Jon Kyl 

January 2004

EXPORT CONTROLS

Post-Shipment Verification Provides 

Limited Assurance That Dual-Use Items 

Are Being Properly Used 

The Department of Commerce approved 26,340 licenses for the export of 

dual-use items during fiscal years 2000 to 2002. Twenty-eight percent of 

these licenses involved dual-use exports to countries of concern such as 

China, India, and Russia. However, Commerce conducted PVC checks on 

few of these licenses. We found that, during fiscal years 2000 to 2002, 

Commerce completed PSV checks on 428, or about 6 percent, of the dual-use 

licenses it approved for countries of concern. Commerce and other 

departments attached conditions to nearly all (99 percent) of the licenses for 

countries of concern to alleviate concerns about potential diversion or 

misuse. 

Department of Commerce Approved Dual-Use Export Licenses and PSVs, Fiscal Years 

2000-2002 

We identified three key weaknesses in the PSV process that reduce the 

effectiveness of this important activity. First, PSVs do not confirm 

compliance with license conditions because U.S. officials frequently do not 

check license conditions, they often lack the technical training to assess 

compliance, and end users may not be aware of the license conditions by 

which they are to abide. Second, some countries of concern, most notably 

China, limit the U.S. government’s access to facilities where dual-use items 

are shipped, making it difficult to conduct a PSV. Third, PSV results have 

only a limited impact on future licensing decisions. Companies receiving an 

unfavorable PSV may receive greater scrutiny in future license applications, 

but they can still receive an export license. In addition, according to 

Commerce officials, past PSV results play only a minor role in future 

enforcement actions. 

The United States controls certain 

dual-use technologies that could be 

used to enhance the military 

capabilities of countries of 

concern. The Department of 

Commerce (Commerce) conducts 

post-shipment verification (PSV) 

checks to ensure that these 

technologies arrive at their 

intended destination and are used 

for the purposes stated in the 

export license. 

GAO was asked to (1) assess the 

number of dual-use export licenses 

approved and subject to postshipment verification and (2) 

evaluate how the PSV process 

ensures that sensitive exports are 

used as intended. 

We recommend that the 

Department of Commerce 

• improve technical training for 

enforcement personnel 

conducting PSV checks, 

• ensure that personnel 

conducting PSV checks assess 

compliance with license 

conditions, and 

• require that the exporter 

inform the end user in writing 

of the license conditions. 

The Department of Commerce 

generally agreed with our 

recommendations and indicated it 

had taken steps to strengthen the 

PSV process. 
Page i GAO-04-357 Export Controls

Contents

Letter 1

Results in Brief 2

Background 3

Few Dual-Use Exports to Countries of Concern Are Subject to PSV 

Checks 5

PSVs Provide Limited Assurance That Dual-Use Items Are Not 

Diverted or Misused 10

Conclusion 16

Recommendations 17

Agency Comments and Our Evaluation 17

Appendixes

Appendix I: Scope and Methodology 19

Appendix II: Department of Commerce’s Statutory Framework and 

Enforcement Activities 21

Appendix III: Comments from the Department of Commerce 24

GAO Comments 28

Appendix IV: GAO Contact and Staff Acknowledgments 29

GAO Contact 29

Staff Acknowledgments 29

Tables Table 1: Export Licenses to Countries of Concern, Fiscal Years 2000 

to 2002 6

Table 2: Maximum Penalties under EAA and IEEPA 23

Figures Figure 1: Department of Commerce Approved Dual-Use Export 

Licenses and PSVs, Fiscal Years 2000-2002 8

Figure 2: Results of PSV Checks in Countries of Concern, Fiscal 

Years 2000-2002 9
Contents

Page ii GAO-04-357 Export Controls

Abbreviations

EAA Export Administration Act

ECASS Export Control Automated Support System

FCS U.S. Foreign Commercial Service

FOUO For Official Use Only

HPC High Performance Computer

IEEPA International Emergency Economic Powers Act

PSV Post Shipment Verification

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-04-357 Export Controls

United States General Accounting Office

Washington, D.C. 20548

A

January 12, 2004 Letr

The Honorable Jon Kyl

United States Senate

Dear Senator Kyl:

The U.S. government seeks to control the export of dual-use technologies1

to prevent countries of concern2 and terrorists from using them to bolster 

their military capabilities. The Department of Commerce (Commerce) is 

responsible for licensing dual-use exports and relies on post-shipment 

verification (PSV) checks to confirm that exported items are not misused 

or diverted. To conduct a PSV check, Commerce personnel visit foreign 

companies to verify the use and location of the item. According to 

Commerce, a PSV check strengthens assurances that exporters, importers, 

and end users comply with the terms of export licenses and licensing 

conditions.

Because of your concerns about the current PSV process in countries of 

concern such as China and India, you asked that we (1) assess the number 

of dual-use export licenses approved and subject to PSV and (2) evaluate 

how the PSV process ensures that sensitive exports are used as intended.

To address these objectives, we reviewed laws and procedures governing 

export licensing, analyzed export licensing data, and reviewed the 

enforcement outcomes of Commerce’s PSV activities, including the 

penalties levied and their deterrent value. We also interviewed Commerce 

officials in Washington, D.C., surveyed export enforcement personnel in 

Commerce’s field offices, met with Commerce export enforcement 

attachés in Russia and China, and observed a Commerce-led team 

conducting PSV checks in Russia. In addition, we met with officials from 

the Department of State (State); Department of Homeland Security; 

1

“Dual-use” items are those that have both commercial and military uses and can be used in 

the development or production of advanced conventional weapons or weapons of mass 

destruction.

2

For the purposes of this report, we use “countries of concern” to describe those countries 

the United States believes may support terrorism or contribute to the proliferation of 

weapons of mass destruction. Our list includes Azerbaijan, Belarus, China, Egypt, India, 

Iran, Iraq, Israel, Kazakhstan, North Korea, Pakistan, Russia, Syria, and Ukraine. We 

developed this list by selecting those countries that appeared on at least 5 of 12 different 

U.S. government lists of countries of concern.
Page 2 GAO-04-357 Export Controls

Department of Defense (Defense), including the Defense Security and 

Threat Agency and Defense Intelligence Agency; Department of Justice; 

Central Intelligence Agency; National Ground Intelligence Center; and 

private firms in Hong Kong, India, and Russia that were the subject of 

Commerce’s PSV checks. Finally, we interviewed officials from the 

governments of China, Hong Kong, and India about their views on the PSV 

process. For more on our scope and methodology, see appendix I.

Results in Brief During 2000 to 2002, Commerce approved 70 percent of the licenses it 

received for exporting dual-use items to countries of concern. The vast 

majority of these approved licenses—99 percent—had conditions attached 

during the interagency process to alleviate concerns about potential 

diversion or misuse. However, few dual-use export licenses were subject 

to PSV checks, Commerce’s primary mechanism for checking that dual-use 

items arrive at their proper location and are used in compliance with the 

conditions of the export license. Our analysis of Commerce’s export 

licensing data found that during fiscal years 2000 to 2002, Commerce 

completed PSV checks on 428 (6 percent) of the 7680 dual-use licenses it 

approved for countries of concern.

We found three key challenges to the PSV process that reduce the 

effectiveness of this important activity. First, the process of conducting the 

checks has several weaknesses. U.S. officials do not always verify 

compliance with license conditions. As a result, 36 percent of the 

companies we visited or company representatives we spoke with in China, 

Hong Kong, India, and Russia reported that U.S. officials did not ask them 

about compliance or attempt to verify compliance with license conditions. 

In addition, in response to our survey, three-fourths of the U.S. officials 

who conducted checks between 2000 to 2002 reported that they lacked 

technical training in key technologies such as electronics, 

telecommunications, and information security systems. These 

technologies accounted for 89 percent of the checks conducted in 

countries of concern during fiscal years 2000 through 2002. Furthermore, 

end users of dual-use technology may not be aware of the license 

conditions they are supposed to abide by because Commerce does not 

require exporters to inform end users in writing of the license conditions. 

Only 5 of the 25 companies we visited had a copy of the license conditions. 

Second, some countries of concern, most notably China, limit the U.S. 

government’s access to facilities where dual-use items are shipped, making 

it difficult to verify whether exported items are being used as intended. 

Third, PSV results have only a limited impact on future licensing decisions. 
Page 3 GAO-04-357 Export Controls

Companies receiving an unfavorable PSV will be scrutinized more carefully 

in the future, but they can still obtain an export license. In addition, past 

PSV results play only a minor role in future enforcement actions.

We are recommending that the Secretary of Commerce (1) improve 

technical training for enforcement personnel conducting PSV checks, (2) 

ensure that personnel conducting PSV checks assess compliance with 

license conditions, and (3) require that the exporter inform the end user in 

writing of the license conditions. In commenting on our report, the 

Department of Commerce generally agreed with our recommendations and 

stated that it has already taken significant steps to strengthen the PSV 

process along the lines we recommended.

Background Commerce’s authority to conduct PSV checks is established in the Export 

Administration Act of 1979, which provides the legal and administrative 

basis for U.S. controls on dual-use exports and is supplemented by the 

Export Administration Regulations. Commerce’s Control List, which is 

included in the regulations, specifies the items and technologies to be 

controlled.3

 The United States uses export controls to prevent sensitive 

items from reaching persons, entities, or countries involved in terrorism or 

the proliferation of weapons of mass destruction and the vehicles to deliver 

them.

Commerce seeks to ensure that exports from the United States and 

reexports of U.S.-origin items to other countries are consistent with U.S. 

national security and foreign policy objectives. At the same time, 

Commerce works to avoid impeding the flow of legitimate trade. PSV 

checks are Commerce’s primary method to detect and prevent illegal 

transfer of controlled U.S.-origin goods and technology already shipped 

overseas. Commerce may conduct a PSV check on any controlled item it 

licenses that is exported from the United States. According to Commerce, 

PSV checks strengthen assurances that exporters, shippers, importers, and 

end users comply with the terms of export license and licensing conditions. 

3

The Commerce Control List includes certain nuclear materials, facilities, and equipment; 

chemicals, microorganisms, and toxins; materials processing; electronics; computers; 

telecommunications and information security; lasers and sensors; navigation and avionics; 

marine systems; and propulsion systems and space vehicles.
Page 4 GAO-04-357 Export Controls

U.S. exporters submit license applications to Commerce. The applications 

include information on (1) the importer who takes delivery of the item, (2) 

the end user who will use the item, and (3) the item’s intended use. The 

importer and end user may or may not be the same company. An importer 

may use, sell, or distribute the item to other companies for their use. For 

example, a U.S. company could export thermal imaging cameras to an 

Indian company. The Indian company, also known as the importer, might 

then sell the cameras to other Indian companies, the end users.

Several agencies review license applications for the national security, 

domestic, or foreign policy implications of exporting dual-use items. After 

the U.S. exporter submits a license application to Commerce, an 

interagency team comprised of officials from Commerce, Defense, State, 

and the Department of Energy determines whether the application should 

be approved for a license, denied, or returned without action.4

 If potential 

concerns are raised about the end user or the end use, a prelicense check 

may be conducted to verify the legitimacy of the importing company that 

seeks to purchase U.S. items or technology. If concerns about the end user 

or end use persist, conditions may be added to the license application 

before approval. Once approved, Commerce issues the license, including 

conditions, to the U.S. exporter.

Commerce conducts PSV checks to confirm that the dual-use item arrived 

at its destination and is being used as intended. Commerce special agents 

or other U.S. government personnel visit companies overseas to meet with 

importers or end users in an attempt to verify the use and location of these 

items. These checks are usually conducted by Commerce special agents, 

Commerce export control attaché posted at select U.S. embassies 

overseas,5

 or by Foreign Commercial Service (FCS) or State officials in 

country. The majority of PSVs are conducted by Commerce’s special 

agents; these U.S.-based officials conduct investigations of potential 

violations of export controls. Special agents have traditional police powers, 

including the authority to make arrests and execute warrants domestically. 

Agents may also issue administrative subpoenas and detain and seize goods 

4

An application is generally returned without action when there is insufficient information 

to make a licensing decision. 

5

Commerce’s Office of Export Enforcement assigns special agents to selected U.S. 

embassies overseas as export enforcement attachés. Currently, attachés are posted in China 

and the United Arab Emirates. Commerce plans to place attaches in Hong Kong, India, and 

Russia in fiscal year 2004.
Page 5 GAO-04-357 Export Controls

to be illegally exported. They cannot, however, conduct investigations 

while performing PSVs overseas.

Commerce guidelines for conducting PSV checks state that an on-site visit 

to the company is mandatory. These guidelines also indicate that the 

agents’ most important responsibility is physically inspecting the goods or 

the records that detail their disposition. The guidelines also require 

Commerce officials conducting the PSV to determine if (1) the goods are 

located at the facility, (2) the entire shipment can be accounted for, (3) the 

equipment is being used as stated in the license, (4) indications of 

impropriety exist, and (5) the company’s answers are evasive.

Few Dual-Use Exports 

to Countries of 

Concern Are Subject to 

PSV Checks

Commerce approves the majority of all export license applications. During 

fiscal years 2000 to 2002, Commerce approved 70 percent of the license 

applications it received for exports of dual-use items to countries of 

concern. The vast majority—99 percent—of approved licenses had 

conditions attached during the interagency license review to deter misuse 

or diversion. However, only 6 percent of licenses to countries of concern 

were subject to PSV checks. During fiscal years 2000 to 2002, Commerce 

conducted 428 PSVs on the 7,680 dual-use export licenses it approved for 

countries of concern.

Commerce Approves Most 

Dual-Use Export Licenses to 

Countries of Concern

Between 2000 and 2002, Commerce approved 70 percent of dual-use export 

licenses to countries of concern—a total of 7,680 licenses for exports to 

China, India, Israel, Russia, and others. As table 1 shows, China and India 

received more dual-use licenses than all other countries of concern. These 

two countries accounted for almost 62 percent of dual-use licenses 

approved to countries of concern during fiscal years 2000 to 2002. 
Page 6 GAO-04-357 Export Controls

Table 1: Export Licenses to Countries of Concern, Fiscal Years 2000 to 2002

Source: GAO analysis of Commerce data.

Most U.S. exports of dual-use items go to countries other than countries of 

concern. Our analysis of Commerce data found that Commerce was less 

likely to approve exports of dual-use items to countries of concern than to 

other countries. Whereas the approval rate for countries of concern was 70 

percent, the approval rate for other countries was 86 percent.

Commerce Attaches 

Conditions to Most Licenses

Between fiscal years 2000 and 2002, 99 percent of all approved dual-use 

export licenses to countries of concern contained conditions requiring the 

exporter to provide certain documentation and reports, such as a shipper’s 

export declaration or encryption licensing information, and to restrict the 

item’s use. Commerce, Defense, and State develop conditions during an 

interagency licensing approval process to alleviate concerns that the items 

might be misused or might contribute to proliferation activities. According 

to the Undersecretary for Commerce, in a speech at the annual Update 

2002 Export Control and Policy Conference, these conditions alleviate 

agency concerns that might otherwise result in a denial of the export. Once 

a license is issued, the departments rely on Commerce to ensure 

compliance with the conditions.

Country Licenses approved

People’s Republic of China 2,644

India 2,110

Israel 1,456

Russia 824

Syria 311

Egypt 111

Ukraine 58

Pakistan 52

Iran 51

North Korea 26

Kazakhstan 21

Belarus 10

Azerbaijan 5

Iraq 1

Total 7,680
Page 7 GAO-04-357 Export Controls

Commerce has 54 standard conditions that establish requirements 

exporters and end users must follow, including how an item may be used 

and who may have access to it. Conditions are placed on a license 

according to the particular item’s intended use and final destination. A 

standard condition might state that no wide-area network connectivity is 

allowed without specific U.S. government authorization or that military end 

users or end uses are prohibited. In addition to the 54 standard conditions, 

Commerce sometimes uses customized conditions to restrict specific end 

uses and/or end users of an item. For example, a license for semiconductor 

manufacturing equipment might contain a condition stipulating the 

characteristics, such as the feature size of the integrated circuits, that could 

be produced using the equipment. A license for a chemical might have a 

condition specifically written for that item stating that the item could only 

be used in the manufacture of pharmaceutical products.

Few Licenses Are Subject to 

PSV

Although 99 percent of licenses worldwide have conditions placed on 

them, few dual-use export licenses issued to countries of concern are 

subjected to PSV checks. Between fiscal years 2000 and 2002, Commerce 

approved 26,340 dual-use export licenses worldwide, including 7,680 

licenses to countries of concern. However, during this same time period, 

Commerce conducted PSVs on approximately 6 percent (428) of approved 

licenses to countries of concern (see fig. 1).
Page 8 GAO-04-357 Export Controls

Figure 1: Department of Commerce Approved Dual-Use Export Licenses and PSVs, 

Fiscal Years 2000-2002

Commerce officials stated that it would be impossible to conduct checks 

on every exported item because of the vast number of licenses. Because of 

this, Commerce developed guidance for selecting the licenses on which to 

conduct PSVs. These selection criteria are based on the destination, item, 

end use, and parties to the transaction. Commerce primarily targets PSVs 

on items it refers to as “choke-point” technologies. These are items and 

technologies that would significantly advance the development of soughtafter weapons systems or are on the “shopping lists” of terrorists or 

countries seeking to develop weapons of mass destruction. Commerce 

also targets PSVs on items destined for countries it has identified as having 

the potential to divert or misuse dual-use items. Commerce also stated that 

it has revised its priorities for future PSVs to focus on several countries 

including Hong Kong, Russia, India, Israel, and the United Arab Emirates. 

Commerce is also posting new export control attachés in Moscow, New 

Delhi, and Hong Kong (in addition to the ones in Beijing and Dubai) to 

conduct end-use verification visits and educate local industry on U.S. 

export controls.

We reviewed 428 Commerce reports on PSV checks for countries of 

concern that were completed between fiscal years 2000 and 2002. Of these 

PSV checks, 72 percent checks included items identified as choke-point 

technologies. Commerce targeted the remaining 27 percent on other items 

and technologies controlled for export but that are not seen to be as critical 
Page 9 GAO-04-357 Export Controls

to proliferation activities as are choke-point technologies. Commerce 

conducted some of these PSV checks on items exported with no license 

required or without an export control classification number. These checks 

allow Commerce to determine if exporters are appropriately classifying 

items on export licenses and if the items are being used properly.

Between fiscal years 2000 and 2002, most PSV checks in countries of 

concern that we reviewed were favorable. We examined trip reports and 

cables of 428 PSV checks completed during this period in eight countries of 

concern, including China, Egypt, India, Israel, Pakistan, Syria, Russia, and 

Ukraine.6

 Eighty-two percent of PSV checks in countries of concern were 

rated favorable by the U.S. officials conducting the PSV (see fig. 2).

Figure 2: Results of PSV Checks in Countries of Concern, Fiscal Years 2000-2002

6

This figure represents both PSVs conducted by Commerce enforcement personnel and 

PSVs conducted in country by State Department staff or an export enforcement attaché.
Page 10 GAO-04-357 Export Controls

According to Commerce’s program guidance, a favorable PSV check 

indicates that U.S. officials found (1) no discrepancies between the actual 

and stated end use of the item and (2) that the item was at the location 

indicated on the license. An unfavorable PSV result indicates that U.S. 

officials found discrepancies between the actual and stated end use. In one 

case, special agents conducting a PSV found no business location for the 

end user at the address on the license. According to Commerce officials, an 

inconclusive check indicates that U.S. officials were unable to complete the 

check. For example, the serial number obtained from a manufacturer might 

not match the end-user’s item, the agents may have been denied access to a 

facility, or the importer might not have responded to the agents’ request to 

meet while they were in the country. According to Commerce officials, a 

limited check indicates that U.S. officials were unable to account for the 

entire shipment. In India, for example, a computer shipped to a company 

in one city had been sent to the company’s office in a different city. The 

agents were thus unable to inspect the entire shipment.

PSVs Provide Limited 

Assurance That DualUse Items Are Not 

Diverted or Misused

The PSV process has several weaknesses that call into question 

Commerce’s ability to ensure dual-use items are not diverted or misused. 

First, PSVs do not confirm compliance with license conditions because 

U.S. officials frequently do not check license conditions; they often lack the 

technical training to assess compliance; and end users may not be aware of 

the license conditions by which they are to abide. Second, some countries 

of concern, most notably China, limit the U.S. government’s access to 

facilities where dual-use items are shipped, making it difficult to verify 

whether exported items are being used as intended. Third, PSV results have 

only a limited impact on future licensing decisions. Companies receiving 

an unfavorable PSV will be subject to greater scrutiny in the future but can 

still obtain an export license. Additionally, according to Commerce 

officials, past PSV results play only a minor role in future enforcement 

actions.

PSVs Do Not Always 

Confirm Compliance with 

License Conditions

The PSV process has several weaknesses. U.S. officials frequently do not 

check compliance with license conditions. In addition, officials conducting 

PSV checks often lack the technical training necessary to verify compliance 

with some license conditions. Furthermore, foreign end users are often 

unaware of the license conditions with which they are to comply.
Page 11 GAO-04-357 Export Controls

U.S. Officials Frequently Do Not 

Check Compliance with Export 

License Conditions or Inspect 

Dual-Use Items

According to Commerce guidance, the objective of PSV checks is to ensure 

that dual-use items reach the intended user and are being used properly. 

Commerce’s guidelines require officials to visit the end user, and they 

strongly recommend that officials physically inspect the exported items. 

These guidelines help ensure that the sensitive technology is being used as 

intended under the terms of the license and that the conditions of the 

license are being followed. However, U.S. officials frequently do not check 

compliance with license conditions.

Based on our review of PSV trip reports and our observations and 

discussions with companies where PSVs were conducted, we found that 

special agents frequently only asked end users if they complied with license 

conditions rather than physically verifying their compliance with them. In 

some instances, officials did not attempt to ask about license conditions. 

For example, 36 percent of the companies (9 of 25) we visited or company 

representatives we spoke with in China, Hong Kong, India, and Russia 

reported that U.S. officials did not ask them about compliance or attempt 

to verify compliance with license conditions.

U.S. officials also frequently do not physically inspect the dual-use item 

subject to the PSV because they conduct the PSV at the company that 

imported the item rather than the company using the item. For example, an 

Indian company imported thermal cameras and sold them to other Indian 

companies. Since Commerce conducted its PSV at the importing 

company's headquarters, it had to rely on the statements of the company 

representatives that the end users were using the cameras in compliance 

with license conditions. Our review of PSV trip reports and cables, 

between fiscal years 2000 and 2002, found that 104 of 428 (24 percent) PSV 

checks were performed at the importer’s rather than the end user’s office. 

The agents rated 57 (55 percent) of these checks favorable; that is, the item 

had arrived at its intended destination and was being used for the purposes 

stated in the license, although the agents did not visit the end user.
Page 12 GAO-04-357 Export Controls

Also, on several occasions, officials rated PSVs as favorable without 

physically inspecting the item or observing its use. Of the 428 PSV checks 

we reviewed, Commerce special agents rated 62 PSV checks favorable, 

although the item was not inspected or seen by an agent. Based on PSV trip 

reports, agents may not have seen an item because (1) the item was at a 

location other than the one stated on the license, (2) the item had been 

integrated into another product or was a consumable item, or (3) the item 

was portable. For example, in January 2003, special agents visited a 

company in Russia that imported thermal imaging cameras.7

 The company 

purchased the cameras for sales promotion and demonstration purposes 

across Russia. Consequently, during the PSV check, all but one of the 

cameras were in the field. Agents were unable to physically inspect the 

cameras or determine if they were being used in compliance with the 

license conditions. The agents had to rely on the company’s word rather 

than personally verifying adherence to the condition. The agents gave the 

PSV a favorable rating based on discussions with company officials.

Commerce’s Special Agents Lack 

the Training to Help Assess 

Compliance with License 

Conditions

Commerce agents frequently do not have the training needed to assess an 

end-user’s compliance with license conditions on a wide range of sensitive 

technologies. We surveyed all 35 special agents who participated in PSV 

checks between fiscal years 2000 and 2002. Our survey focused on the 

training and guidance that agents had received to conduct PSVs and the 

ease or difficulty of assessing compliance with license conditions on 

certain dual-use items. We received replies from 26 agents (74 percent).

According to the agents who conduct PSVs, the license conditions of some 

items are easier to assess than others. About two-thirds of the agents 

surveyed reported that it was very easy or generally easy for them to assess 

compliance with license conditions in digital computers, general-purpose 

electrical equipment, and machine tools. However, about three-fourths of 

the agents reported that it was difficult or as easy as difficult for them to 

assess compliance with conditions related to toxic chemicals, information 

systems (including software), and biological pathogens.

The agents conducting the PSVs have limited training in many technologies 

that are subject to PSVs. Although most agents responding to our survey 

stated that they received Commerce training in key technologies—namely 

biological, chemical, and nuclear weapons—over three-fourths reported 

7

A thermal imaging camera can be used to check transmission lines at civilian power plants 

or it may be used for surveillance or reconnaissance of enemy troop movements.
Page 13 GAO-04-357 Export Controls

that they had not received any training in electronics, telecommunications 

systems, information security systems, sensors and lasers, marine systems, 

or propulsion systems for space vehicles. These technologies accounted 

for 89 percent of the PSVs conducted in countries of concern during fiscal 

years 2000 through 2002. Our survey also found that training in these 

technologies would be helpful. Twenty-two of the 26 agents (85 percent) 

reported that more training on key technologies such as computers, 

telecommunications systems, and electronics would improve their ability 

to conduct PSV checks.

Commerce officials recognize that special agents do not always have the 

skills and training necessary to verify compliance with some license 

conditions. For example, to verify compliance with a license for 

semiconductor manufacturing tools, Commerce brought together a team of 

DOD and Commerce engineers for training on these tools. In February 

2003, the engineers spent a day learning about the items on the license and 

ways to determine if the exported equipment was being used in compliance 

with the license conditions. The engineers then examined the exported 

item in China and determined that the company had complied with the 

license conditions. 

In October 2003, Commerce released new guidelines to improve technical 

training for special agents. This 1-day training is designed to provide agents 

with additional technical expertise about the dual-use items they are to 

check during upcoming PSVs. Commerce expects that this training will 

allow agents to ensure that the items they check are the actual items in 

question and that they are being used in compliance with license 

conditions. Commerce officials stated that they planned to initiate this 

training in November 2003. 

End Users May Not Be Aware of 

License Conditions

End users of dual-use technology may not be aware of the license 

conditions by which they are to abide. Only 5 of the 25 companies we 

visited had a copy of the license conditions. According to Commerce, it is 

the U.S. exporter’s responsibility to ensure that end users are aware of the 

terms of the license, including the conditions that apply to them. However, 

Commerce does not require exporters to provide a copy of the export 

license containing the conditions either to importers taking delivery of an 

item or end users that use the item. Although Commerce requires the 

exporter to convey license conditions to its “customer” or other parties to 

whom the license conditions apply, the department does not specify 

whether the conditions should be conveyed verbally or in writing. Unless 

there is a condition in the license that requires the exporter to inform the 
Page 14 GAO-04-357 Export Controls

end user of the conditions placed on the license, there is no guarantee that 

the exporter will convey the conditions to the end user. In 24 percent of the 

PSVs we reviewed, the checks were conducted at the site of the importer 

rather than the end user; therefore, the end user may not have been aware 

of the license conditions.

During our visits to China, Hong Kong, India, and Russia, we found that 

only 5 (20 percent) of the 25 companies we visited had a copy of the 

license, which included the conditions. Representatives from 13 other 

companies stated that they were aware of the conditions but did not have a 

copy of the license or any document outlining the conditions. At nine 

companies we found that the agents conducting the PSV did not raise the 

topic of conditions. In at least one case in Russia, a company had signed a 

document indicating that it was aware of the conditions but did not have a 

copy of the license or any other documentation describing the conditions; 

it was unclear how the conditions were conveyed to the company. In India 

when we requested that a company produce a copy of the license 

conditions that the exporter was required to provide, the company 

produced a copy of the sales contract describing the terms and financial 

conditions of the sale. The company representative believed that the sales 

contract listed the license conditions. Indian companies we visited were 

frequently confused about the term “conditions,” associating it with the 

sale of the item as opposed to the conditions imposed by Commerce on the 

item’s use. 

Some Countries of Concern 

Limit the U.S.’s Ability to 

Conduct PSV Checks

To successfully conduct a PSV, Commerce needs the cooperation of host 

governments and the companies it must visit. In some countries, 

Commerce can conduct PSVs without notifying the host government. 

However, in other countries, Commerce’s ability to conduct PSVs is more 

limited. China, India, Russia, and Hong Kong8 offer the United States 

varying levels of access. A discussion of the four countries follows.

• The Chinese government requires that Commerce follow a set of 

protocols for arranging and conducting PSVs. Commerce officials stated 

that the Chinese government limits the number of checks each year. A 

Chinese Ministry of Commerce official we met with in September 2003 

stated that the scope of items that can be subject to PSVs will be 

8

Hong Kong is not a country of concern; however, it is a transshipment point and has been a 

conduit for illegal reexports of U.S. controlled technology.
Page 15 GAO-04-357 Export Controls

expanded under the terms of an end-use arrangement currently under 

negotiation with the United States.

• India restricts Commerce from conducting PSVs to a limited extent. 

According to our review of trip reports from India, India denied 

Commerce access to some facilities and items for PSV checks through 

2003; however, U.S. access to Indian facilities improved during 2003. In 

May 2003, the Indian government allowed PSVs and gave Commerce’s 

special agents access to all the facilities they requested.

• The Russian government does not require the United States to notify it 

of plans to conduct PSVs or limit the types of items on which the United 

States may conduct checks. Based on our review of trip reports and 

documentation from Russian companies, Commerce was always 

allowed access to conduct PSVs, although government entities 

sometimes required advanced clearance.

• Hong Kong authorities allow U.S. enforcement personnel to conduct 

PSVs on whatever items are of interest to the United States. Based on a 

review of safeguard trip reports and a meeting with Hong Kong officials 

in September 2003, we found that Hong Kong does not require 

Commerce to inform it about pending PSV checks.

Additional discussion of U.S. access to conduct PSVs in these four 

countries is contained in an “Official Use Only” version of this report. 9

 

PSVs Have Limited Role in 

Future Licensing Decisions 

and Enforcement Actions

Commerce places all companies that receive unfavorable PSVs on its 

Watch List. Commerce placed 53 companies on its Watch List in response 

to 81 unfavorable PSV checks worldwide, between fiscal years 2000 and 

2002.10 However, the list is not public, and end users and potential U.S. 

exporters would not know if a company had been placed on the list. To 

help ensure that companies that get unfavorable PSVs receive greater 

scrutiny in the future, Commerce screens new license applications against 

9

See Export Controls: Post-Shipment Verification Provides Limited Assurance That DualUse Items Are Being Properly Used, GAO-04-199 (Washington D.C.: December 22, 2003).

10We asked Commerce to determine if any of the companies that had received unfavorable 

PSV checks had received licenses in the past or been granted licenses after the check. 

Commerce was unable to provide us this information.
Page 16 GAO-04-357 Export Controls

the Watch List. Licensing officers at Commerce use this information when 

making subsequent licensing decisions. 

According to Commerce officials, however, the results of PSVs play a less 

important role in approving a license than do other sources of information. 

Commerce considers other information sources when making licensing 

decisions, including industry leads, self-disclosure, visa referrals, and 

information sharing from other agencies. PSV results play a minor role 

relative to these other sources. According to a senior Commerce official, 

an unfavorable PSV check is the opinion of two individuals and does not 

represent a vetted and approved interagency position, which a licensing 

decision does.

In addition, unfavorable PSV checks cannot be linked to enforcement 

actions. Commerce views an unfavorable PSV as one of many leads in a 

potential criminal case, but an unfavorable alone does not provide 

sufficient evidence to take enforcement action against an end user. An 

unfavorable PSV check is only an initial step in the investigation and 

enforcement process. Before taking action against a criminal activity, 

Commerce must review leads, open an investigation, and collect evidence. 

If Commerce believes that it has enough evidence for a criminal case, it 

must convince the Department of Justice to prosecute. If the criminal court 

finds the defendant guilty, it can levy penalties (see app. II for additional 

information on Commerce’s enforcement activities). If Commerce lacks 

sufficient evidence to prosecute the case in a criminal court, it may seek 

administrative penalties.

Commerce cannot identify enforcement cases generated as the result of an 

unfavorable PSV check because its database does not identify the source of 

an investigation. Commerce officials stated that they would have to 

conduct a manual search of the files to determine whether an enforcement 

action started with a PSV. However, Commerce officials also stated that no 

closed enforcement cases began as PSV leads. Commerce officials 

recognized that their database had limitations and stated that they have 

instituted the Investigative Management System, which will track the total 

number of leads, their sources (such as a PSV), and the significant actions 

resulting from them.

Conclusion Commerce currently lacks an effective way to ensure that dual-use items 

are being used as required under the terms of export licenses. PSV checks 

are Commerce’s primary means to verify the end use of an item after it has 
Page 17 GAO-04-357 Export Controls

been exported. The fact that Commerce conducts PSVs may have some 

deterrent value. However, during fiscal years 2000 to 2002, Commerce only 

checked 6 percent of dual-use licenses for countries of concern. In 

addition, deficiencies in Commerce’s implementation of this important 

process limit its overall effectiveness in ensuring that dual-use items are 

not misused or diverted. Most significantly, although 99 percent of dual-use 

exports to countries of concern have license conditions, the U.S. officials 

who carry out PSVs do not always verify that these conditions are met. 

Even if agents wanted to check license compliance, they may lack the 

necessary technical expertise to determine whether a license condition is 

being met. In addition, the foreign end users of the dual-item may not be 

aware of the license conditions they are to comply with. Finally, some 

countries limit Commerce’s access to conduct PSVs. As a result, Commerce 

cannot ensure that dual-use items exported to countries of concern are not 

misused or diverted.

Recommendations To improve the PSV process, we recommend that the Secretary of 

Commerce

• improve technical training for enforcement personnel conducting PSV 

checks to ensure they are able to verify compliance with license 

conditions,

• ensure that personnel conducting PSV checks assess compliance with 

license conditions, and

• require that the exporter inform the end user in writing of the license 

conditions.

Agency Comments and 

Our Evaluation

The Department of Commerce provided written comments on a draft of 

this report, which are reproduced in appendix III. Commerce generally 

agreed with our recommendations. However, Commerce disagreed with 

our conclusion that PSVs provide limited assurances that dual-use items 

are being used as intended. Commerce stated that we assumed PSVs play a 

greater role in ensuring compliance with the terms and conditions of 

export licenses than they actually play. However, Commerce’s June 2000 

program guidance on how to conduct PSVs states that PSVs are the first 

line of defense in preventing illegal technology transfer after dual-use items 

have been exported. Commerce documents show that PSVs are 
Page 18 GAO-04-357 Export Controls

Commerce’s primary mechanism to verify that dual-use items are used as 

intended after they have been exported. Commerce also stated that we 

underestimated the value of PSVs for informing future licensing decisions. 

However, during the course of our review, Commerce officials stated that 

PSVs played a less important role in future licensing decisions than other 

sources of information, such as industry leads and information from other 

agencies, that were more highly valued. Accordingly, we have not modified 

our conclusions or recommendations.

As arranged with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days after the 

date of this letter. At that time we will send copies of this report to 

appropriate congressional committees and to the Secretary of Commerce. 

Copies will be made available to others upon request. In addition, this 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

Please contact me at (202) 512-8979 if you or your staff has any questions 

concerning this report. A GAO contact and staff acknowledgments are 

listed in appendix IV.

Sincerely yours,

Joseph A. Christoff, Director

International Affairs and Trade
Page 19 GAO-04-357 Export Controls

Appendix I

Scope and Methodology AAppenednxidexiIs

We were asked to (1) assess the number of dual-use export licenses 

approved and subject to post-shipment verification (PSV), and (2) evaluate 

how the PSV process ensures that sensitive exports are used as intended. 

To address these objectives, we reviewed laws and regulations governing 

export licensing, analyzed export licensing data, and reviewed the activities 

and outcomes of the Department of Commerce’s (Commerce) Export 

Enforcement Office. We also interviewed Commerce officials in 

Washington, D.C.; surveyed Commerce’s special agents who conduct PSV 

reviews; met with Commerce enforcement attachés in Russia and China; 

and observed a Commerce-led team conducting PSV checks in Russia. In 

addition, we met with officials from the Department of State; Department 

of Homeland Security; Department of Defense, including the Defense 

Technology Security Administration and Defense Intelligence Agency; 

Department of Justice; Central Intelligence Agency; National Ground 

Intelligence Center; and private firms in Hong Kong, India, and Russia that 

were the subject of Commerce’s PSV reviews. Finally, we interviewed 

government officials from China, Hong Kong, and India about their views 

on U.S. export controls.

To assess the number of dual-use export licenses approved and subject to 

PSV, we reviewed Commerce documentation on how the licensing process 

works and how it determines which items will be subject to PSV checks. 

We interviewed knowledgeable Commerce officials about the licensing 

process and the role of PSV checks in that process. Additionally, we 

obtained statistical data from Commerce, including portions the Export 

Control Automated Support System (ECASS), to analyze data on licenses 

selected for PSVs. We assessed the reliability of the ECASS data by 

performing electronic testing of required data elements and by interviewing 

agency officials knowledgeable about the data. We determined that the 

data were sufficiently reliable for the statistical purposes of this report. We 

also obtained PSV trip reports and cables for fiscal years 2000 through 2002 

for countries of concern where PSVs were conducted.

To evaluate how the PSV process ensures that sensitive exports are used as 

intended, we reviewed Commerce’s Special Agent Manual, guidance on 

conducting PSV checks, trip reports, and cables for countries of concern. 

We identified key countries of concern by performing a content analysis of 

12 lists used by U.S. government agencies to designate countries they 

believe may support terrorism or contribute to proliferation of weapons of 

mass destruction. Any country that appeared on 5 or more of the 12 lists 

was selected as a country of concern for the purposes of this report. The 
Appendix I

Scope and Methodology

Page 20 GAO-04-357 Export Controls

resulting list includes Azerbaijan, Belarus, China, Egypt, India, Iran, Iraq, 

Israel, Kazakhstan, North Korea, Pakistan, Russia, Syria, and Ukraine.

As part of our audit work, we traveled to Russia and observed a team 

conduct a PSV check. We also traveled to China, Hong Kong, and India to 

determine the host governments’ requirements for conducting PSV checks 

and to conduct follow-up meetings with companies and persons subject to 

previous PSV checks. We surveyed special agents at Commerce field 

offices who had participated in PSV trips during 2000, 2001, and 2002, and 

from January to April in 2003. We identified 35 active agents who 

conducted PSV trips during this time frame, based on reports Commerce 

provided to us. We did not survey six agents who had conducted PSVs and 

had left the department or had been temporarily reassigned. We developed 

and pretested a questionnaire that we administered by e-mail and fax. We 

received responses from 26 officers, or 74 percent of the active agents. 

Finally, we interviewed Commerce officials and asked Commerce to 

provide us with data to determine how the results of PSVs are used in 

future licensing and enforcement actions. We initially planned to use the 

ECASS data to determine if companies that had received an unfavorable 

PSV obtained a subsequent license. Due to limitations in Commerce’s 

database, however, this could not be done. We therefore relied on 

Commerce officials’ testimony about how unfavorable PSVs are used in the 

licensing process.

We conducted our review from October 2002 through October 2003 in 

accordance with generally accepted government auditing standards.
Page 21 GAO-04-357 Export Controls

Appendix II

Department of Commerce’s Statutory 

Framework and Enforcement Activities ApendxiI

Commerce undertakes a number of enforcement activities to deter 

violations of export control laws and regulations, including prosecuting 

both civil-administrative and criminal cases. If U.S. exporters or foreign 

importers are not following U.S. export law and regulations, they may face 

penalties including fines, denial of export privileges, or imprisonment. In 

accordance with the governing authority, when Commerce identifies a 

potential dual-use violation, it may seek criminal or civil administrative 

action, or both, against the U.S. company that exported the product, 

employees at the U.S. exporting company, or foreign companies and 

persons involved in importing the product. 

When Commerce obtains an unfavorable PSV or other indication that a 

dual-use export control violation may have occurred, Commerce may 

engage in an investigation.1

 After an investigation, if Commerce determines 

the violator acted with full knowledge and willful intent of breaking the 

law, Commerce develops a criminal case and seeks an attorney in the 

Department of Justice (Justice) to prosecute the violation. If Justice 

accepts the case, they assign an assistant U.S. attorney for criminal 

prosecution. If the criminal court finds a defendant guilty of dual-use 

violations, then sanctions for criminal conduct are imposed; companies 

may be fined while individuals may be fined and or imprisoned. In addition 

to or in lieu of criminal penalties, Commerce may pursue civil 

administrative action. Civil-administrative penalties are issued directly by 

Commerce. Attorneys working at Commerce handle these cases, which are 

heard by an administrative law judge. Civil-administrative penalties may be 

issued to either an individual or to companies and may include:

• Denial of export privileges – This denies the violator the right to export 

or to participate in the export of goods from the United States.

• Civil-administrative fines – Commerce charges the violator(s) monetary 

penalties.

In addition to civil-administrative penalties, Commerce may use the 

following as preventative measures in response to export control law 

violations: 

1

Commerce lacks authority to lead overseas investigations but may request Customs’ 

assistance to conduct investigatory activity for Commerce leads. 
Appendix II

Department of Commerce’s Statutory 

Framework and Enforcement Activities

Page 22 GAO-04-357 Export Controls

• Warning letter - A warning letter is an informal notification Commerce 

issues to a company or person who may have violated the law. It 

describes the alleged violations and possible sanctions, but does not 

impose fines or restrictions on export privileges due to a lack of 

evidence. Commerce considers any future violations in light of the 

warning.

• Placement of an entity or individual on the Watch List – The Watch List 

lists individuals and companies that Commerce has determined warrant 

increased scrutiny for export licensing purposes.

In fiscal year 2001 and 2002, Commerce closed 9 cases yielding criminal 

convictions and issued 340 warning letters. During that same time period, 

Commerce approved 17,500 licenses for dual-use exports. 

Commerce’s authority to enforce dual-use export controls was originally 

authorized by the Export Administration Act (EAA) of 1979. Since August 

20, 1994, when the EAA first expired, temporary statutory extensions and 

executive orders continued the application of this act. Most recently, the 

application of the act has been extended under an executive order issued 

pursuant to the International Emergency Economic Powers Act (IEEPA).2

While the executive order gives Commerce authority to enforce dual-use 

export controls, IEEPA provides for maximum penalties that are 

significantly lower than those permitted under the EAA, both for criminal 

and civil administrative fines. For example, criminal penalties for 

companies that willfully violate dual-use export control laws under IEEPA 

are limited to a $50,000-per-violation fine. Under the EAA, offenders were 

subject to a fine of either $1 million per violation or five times the value of 

the exports, whichever was greater. A violation is constituted as the 

intentional export of a good in violation of export control law. For a 

comparison of fines under the EAA and IEEPA, see table 3.3

 

2

Executive Order 13222, August 7, 2003 (66 Reg. 47833).

3

IEEPA violations constitute a felony. Higher fines may therefore be imposed under the 

authority of 18 U.S.C. 3571, a criminal code provision that establishes a maximum criminal 

fine for a felony that is the greatest of (1) the amount provided by the statute that was 

violated; (2) an amount not more than $250,000 for an individual or not more than $500,000 

for an organization; or (3) an amount based on a dollar value of the offense. The maximum 

fine amounts are subject to inflation adjustments made pursuant to the Federal Civil 

Penalties Inflation Adjustment Act of 1990 (Pub. L 101-410 as amended, codified as a note to 

28 U.S.C. 2461).
Appendix II

Department of Commerce’s Statutory 

Framework and Enforcement Activities

Page 23 GAO-04-357 Export Controls

Table 2: Maximum Penalties under EAA and IEEPA

Sources: Export Administration Act: 50 U.S.C. app. 2410; International Emergency Economic Powers Act, 50 U.S.C. 1705.

Note: The goods involved in any violation may be subject to seizure.

a

The penalties listed for violations of the EAA are for willful violations of the act with knowledge that the 

exports involved will be used for the benefit of, or that the destination of the goods or technology 

involved is, any country to which exports are controlled for national security or foreign policy purposes. 

Other violations of the act are subject to lesser penalties.

b

The EAA has lapsed several times since it was originally enacted, with the first lapse occurring before 

1990. Between August 1993 and November 2000, the President continued the regulations in effect 

under the authority of IEEPA. In November 2000, Congress reauthorized the IEEPA, and it remained in 

effect through August 2001. Executive Order 13222, which has been extended by several Presidential 

Notices, continues the regulations in effect.

Criminal Penaltiesa EAAb IEEPAb

Individual fine Not to exceed $250,000 per 

violation

Not to exceed $50,000 per 

violation

Corporate fine Not to exceed $1,000,000 

per violation, or five times 

the value of the exports, 

whichever is greater

Not to exceed $50,000 per 

violation

Individual imprisonment Not to exceed 10 years per 

violation

Not to exceed 10 years per 

violation

Civil administrative 

penalties EAAb IEEPAb

Individual and corporate Not to exceed $11,000 per 

violation, ($120,000 per 

violation may be imposed 

for each violation involving 

national security controls) 

Not to exceed $11,000 per 

violation
Page 24 GAO-04-357 Export Controls

Appendix III

Comments from the Department of 

Commerce ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.
Appendix III

Comments from the Department of 

Commerce

Page 25 GAO-04-357 Export Controls

See comment 2.
Appendix III

Comments from the Department of 

Commerce

Page 26 GAO-04-357 Export Controls

See comment 3.
Appendix III

Comments from the Department of 

Commerce

Page 27 GAO-04-357 Export Controls

See comment 4.
Appendix III

Comments from the Department of 

Commerce

Page 28 GAO-04-357 Export Controls

GAO Comments The following are GAO’s comments on the Department of Commerce letter, 

dated December 3, 2003.

1. Commerce states that we overemphasized the use of PSVs as a method 

for ensuring license compliance and underestimated their value for 

informing future licensing decisions. We disagree. Commerce’s June 

2000 guidance on how to conduct PSVs states that PSVs are the first 

line of defense in preventing illegal technology transfer after dual-use 

items have been exported. We also found that PSVs play a less 

important role in future licensing decisions than other sources of 

information. As noted in the report, Commerce officials stated that 

industry leads, information from other agencies, self-disclosures, and 

visa referrals are more highly valued in licensing decisions than 

information gathered during a PSV. 

2. Commerce stated that the effectiveness of PSVs cannot be assessed in 

isolation from other enforcement and compliance efforts of Commerce. 

We agree. Our report includes discussions of several of these 

mechanisms, including prelicense checks (p. 4), screening against its 

Watch List (p. 15), and using information on export transactions from 

industry and other agencies (p. 16). We also discuss the deterrent 

effect of prosecuting criminal and administrative enforcement cases 

(pp. 21-23, app. II). 

3. Commerce notes that its new safeguards protocol requires training for 

all safeguards trip team members prior to their departure. However, as 

of December 2003, two agents had received this training.

4. Commerce noted that it had undertaken to revise the priority of license 

checks in countries of concern, by focusing on Hong Kong, Russia, 

India, Israel, and the United Arab Emirates. We have added information 

in the report to reflect the new efforts.
Page 29 GAO-04-357 Export Controls

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact David Maurer (202) 512-9627

Staff 

Acknowledgments

In addition, Julie Hirshen, Eugene Beye, Joseph Brown, Lynn Cothern, 

Jeanine Lavender, Steve Lord, and Minette Richardson made significant 

contributions to this report.

(320242)
GAO’s Mission The General Accounting Office, the audit, evaluation and investigative arm of 

Congress, exists to support Congress in meeting its constitutional responsibilities 

and to help improve the performance and accountability of the federal government 

for the American people. GAO examines the use of public funds; evaluates federal 

programs and policies; and provides analyses, recommendations, and other 

assistance to help Congress make informed oversight, policy, and funding 

decisions. GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

Obtaining Copies of 

GAO Reports and 

Testimony

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and fulltext files of current reports and testimony and an expanding archive of older 

products. The Web site features a search engine to help you locate documents 

using key words and phrases. You can print these documents in their entirety, 

including charts and other graphics.

Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its Web site 

daily. The list contains links to the full-text document files. To have GAO e-mail this 

list to you every afternoon, go to www.gao.gov and select “Subscribe to 

e-mail alerts” under the “Order GAO Products” heading.

Order by Mail or Phone The first copy of each printed report is free. Additional copies are $2 each. A check 

or money order should be made out to the Superintendent of Documents. GAO 

also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a single 

address are discounted 25 percent. Orders should be sent to:

U.S. General Accounting Office

441 G Street NW, Room LM

Washington, D.C. 20548

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Public Affairs Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Service Requested

Presorted Standard

Postage & Fees Paid

GAO

Permit No. GI00