Department of Homeland Security

Office of Inspector General 

Customs and Border Protection’s 
 


Importer Self-Assessment Program
 
 

OIG-10-113 August 2010 
Office ofInspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

AUG 30 2010 

Preface 

The Department of Homeland Security (DRS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the need for Customs and Border Protection to strengthen key 

management controls for the Importer Self-Assessment program. It is based on 

interviews with employees and officials of relevant agencies and institutions, direct 

observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all ofthose who contributed to the preparation of this report. 

~~~~£ Anne L. Richards 

Assistant Inspector General for Audits 
Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 
 

Background..........................................................................................................................2 
 


Results of Audit ...................................................................................................................3 
 


Management Controls....................................................................................................3 
 


ISA Applicants’ Internal Controls .................................................................................5 
 


ISA Importer Oversight .................................................................................................6 
 


Recommendations..........................................................................................................7 
 


Management Comments and OIG Analysis ..................................................................7 
 


Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................10 
 


Appendix B: Management Comments to the Draft Report.......................................11 
 


Appendix C: Major Contributors to This Report ......................................................14 
 


Appendix D: Report Distribution ..............................................................................15 
 


Abbreviations 

CBP U.S. Customs and Border Protection 

FY Fiscal Year 

ISA Importer Self-Assessment 
Customs and Border Protection's Importer Self-Assessment Program 
 


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OIG
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

We reviewed U.S. Customs and Border Protection’s management 

and oversight of the Importer Self-Assessment program. The 

objective of our audit was to determine the efficacy of the Importer 

Self-Assessment program, by which U.S. Customs and Border 

Protection permits importers to conduct self-assessments to verify 

their compliance with federal trade requirements in exchange for 

decreased agency oversight and other benefits. 

U.S. Customs and Border Protection has not fully established key 

management controls for the Importer Self-Assessment program. 

U.S. Customs and Border Protection has not clearly defined the 

program’s purpose, established performance measures, issued 

operating procedures, verified the effectiveness of applicants’ 

internal controls prior to acceptance into the program, or exercised 

effective oversight of participants’ compliance with program 

requirements. As a result, the agency does not have adequate 

assurance that participating importers comply with federal trade 

requirements and, therefore, that government revenues are being 

protected. 

We are making four recommendations to U.S. Customs and Border 

Protection to improve the effectiveness of the Importer SelfAssessment program. The U.S. Customs and Border Protection 

agreed with all four recommendations and has initiated action to 

implement them. 
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Background 

The primary goal of U.S Customs and Border Protection (CBP) in 

the trade compliance process is to maximize importer compliance 

with U.S. trade laws, while at the same time facilitating the 

importation and entry of admissible merchandise. With the 

enactment in 1993 of the Customs Modernization Act, CBP1 

fundamentally changed its relationship with the importing 

community to promote greater shared responsibility for 

compliance with trade laws and regulations. Under the Act’s 

provisions, importers are responsible for declaring the value, 

classification, and duty for imports, while CBP is responsible for 

informing importers of their rights and responsibilities for trade 

compliance. To implement these new responsibilities, CBP 

developed a strategy built around the concept of “informed 

[importer] compliance.” 

The Importer Self- ISA Program Benefits Assessment (ISA) program 

was initiated in 2002 as a • Consultation with CBP 

• Coverage of multiple business voluntary approach to trade units 

compliance. It is based on • Removal from CBP’s 

the premise that importers Comprehensive Audit pool 

with strong internal • Access to key liaison officials 

controls achieve the 	 • Access to summaries of 

highest level of compliance participant’s trade data 

• Expanded prior disclosure with federal trade laws and privileges regulations and require less • Mitigated penalties and liquidated 

enforcement review and damages 

oversight. Importers • Greater business certainty 

enrolled in the ISA 

program assume responsibility for self-governance in exchange for 

less government oversight and other benefits. 

The ISA program is administered through CBP’s Office of 

International Trade, Partnership Programs Branch. To apply for 

admission into the program, an importer signs a Memorandum of 

Understanding with CBP agreeing to comply with ISA program 

requirements and submits an application package including 

information on its internal controls. The Office of Regulatory 

Audit staff within the Office of International Trade assesses the 

importer’s application and conducts an onsite review. After CBP’s 

1

 The trade functions of the former U.S. Customs Service were formally transferred to the U.S. Customs 

and Border Protection upon the creation of the Department of Homeland Security in March 2003. 
review, the agency accepts or rejects the importer for the ISA 

program. 

CBP Account Managers have primary responsibility for 

conducting oversight of participating ISA importers, including 

identifying and analyzing potential trade compliance risks. For 

this purpose, ISA participants are assigned either to a National 

Account Manager under the authority of the Office of International 

Trade or to a Port Account Manager under the authority of CBP’s 

Office of Field Operations. As of fiscal year (FY) 2009, 148 ISA 

participating importers were assigned to National Account 

Managers and 47 were assigned to Port Account Managers. The 

195 importers in the ISA program represented an estimated $288 

billion (17%) of the total $1.7 trillion in imports processed by CBP 

that year. 

Each ISA importer must provide annual written notification to 

CBP that it is continuing to meet the requirements of the ISA 

program. CBP Trade Liaisons analyze information provided by 

both the responsible Account Manager and the importer to make a 

risk-based determination of whether the importer should be 

allowed to continue participating in the ISA program. 

Results of Audit 

CBP has not fully established key management controls for the ISA program. 

CBP has not clearly defined the program’s purpose, established performance 

measures, issued operating procedures to agency personnel, verified the 

effectiveness of applicants’ internal controls prior to acceptance into the program, 

or exercised effective oversight of participants’ compliance with program 

requirements. As a result, CBP does not have adequate tools to gain assurance 

that participating importers comply with federal trade requirements and, therefore, 

that government revenues are being protected. 

Management Controls 

CBP has not clearly defined the purpose of the ISA program, developed 

appropriate program performance metrics, or issued the official procedural 

guidance necessary to implement the program. Office of Management and 

Budget Circular A-123, Management’s Responsibility for Internal 

Control, establishes that internal control is a major part of managing an 

organization and “in the broadest sense, includes the plan of organization, 

methods and procedures adopted by management to meet its goals. 

Customs and Border Protection's Importer Self-Assessment Program 
 

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Internal control includes processes for planning, organizing, directing, 

controlling, and reporting on agency operations.”2 

The purpose of the ISA program contained in agency documents differs 

from the purpose that CBP officials communicated to us. The ISA 

Handbook states that the program’s purpose is to maintain a high level of 

trade compliance, while agency personnel asserted that the program’s 

primary purpose is to allow the agency to focus its limited resources on 

high-risk and unknown importers. Although these purposes are not 

mutually exclusive, each would use different metrics to measure program 

success. Nonetheless, CBP has not established or used metrics to measure 

program performance for either purpose. 

CBP does not assess the ISA program’s impact on importer trade 

compliance. To measure program effectiveness, CBP currently compares 

the collective trade compliance rate of ISA importers with that of the 

larger universe of all domestic importers. In FY 2009, CBP reported that 

ISA importers had a collective 99.5% rate of compliance with federal 

trade laws and regulations, while all U.S. importers had a compliance rate 

of 98.5%. This metric does not indicate whether the reported higher level 

of trade compliance among ISA participants was the direct result of their 

participation in the program. CBP does not prepare an assessment on the 

impact of the ISA program on providing oversight to other, higher risk 

importers. 

The ISA program also does not have adequate procedures to guide agency 

staff in performing their program-related responsibilities. Since the 

program’s launch in 2002, CBP personnel have relied on either draft or 

insufficiently detailed guidance to implement the program. For example, 

the ISA Handbook provides only limited information to CBP personnel on 

the procedures for assessing importers’ ISA applications and conducting 

ongoing compliance monitoring. We previously reported that CBP was 

not properly reviewing ISA importers’ annual notifications of their 

continued compliance with program requirements and recommended that 

CBP update the ISA Handbook or issue other internal guidance to 

formalize this process.3

 CBP concurred with our recommendation but had 

not completed implementation as of June 15, 2010. 

2

 Office of Management and Budget Circular A-123, Management’s Responsibility for Internal Control, 

states that the term “internal control” is intended to be synonymous with “management controls.”

3

 DHS OIG, Management Letter for the FY 2008 DHS Financial Statement Audit, DHS OIG-09-46, March 

2009. 

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ISA Applicants’ Internal Controls 

CBP’s oversight does not ensure that all ISA participants have internal 

controls that demonstrate their ability to comply with federal trade laws 

and regulations. The ISA Handbook requires that CBP conduct reviews of 

the applicant’s internal controls prior to accepting an importer into the 

program. In a May 2009 policy statement, CBP’s Office of International 

Trade stated that these reviews do not include substantive testing of 

applicants’ controls, and therefore do not provide reasonable assurance as 

to the effectiveness of importers’ internal controls.4

 As a result, importers 

were accepted into the ISA program without adequate assurance that their 

internal controls would result in compliance with federal trade laws and 

regulations. 

CBP also circumvented its official process for accepting importers into the 

ISA program. Since December 2005, CBP recruited 13 importers into the 

ISA program based on their successful completion of Focused 

Assessments. During a Focused Assessment, CBP evaluates an importer’s 

internal control systems to ensure that the filing of transactions and 

declarations is in compliance with trade laws and regulations. In contrast 

to the review processes established in the ISA Handbook, Focused 

Assessments are based on historical information about an importer’s 

compliance history rather than on the current state of its system of internal 

controls. As such, the internal controls of recruited importers were not 

assessed according to the same process as those of importers reviewed 

before being accepted into the ISA program. CBP officials told us that 

this recruitment process was suspended in 2008 until the agency develops 

specific policy and procedures for the process. However, this action did 

not resolve the issue of ensuring that the recruited importers are qualified 

for the program. 

To ensure that the recruited importers are adhering to ISA program 

requirements, CBP is conducting continuation reviews on the importers. 

Although no procedures exist for conducting such reviews, CBP officials 

told us that the process is similar to the internal control assessments 

conducted on importers prior to their acceptance in the ISA program. As 

of April 2010, CBP had completed continuation reviews on 6 of the 13 

recruited ISA importers. Of these, one importer was found to have 

inadequate internal controls to support ongoing trade compliance selfassessment and voluntarily withdrew from the program. Although CBP 

plans to conduct continuation reviews on two more of these importers, no 

such follow-up reviews are currently scheduled for the remaining five. 

4

 CBP Policy Memorandum 09-04, May 18, 2009. 

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ISA Importer Oversight 

The ISA program’s organizational structure does not support consistent or 

effective oversight of ISA importers. CBP National Account Managers 

and Port Account Managers have primary responsibility for overseeing 

ISA program importers, including identifying and analyzing potential 

trade compliance risks. National Account Managers operate in the Office 

of International Trade, which administers the ISA program. Port Account 

Managers are assigned to Office of Field Operations staff. As a result, the 

Office of International Trade is limited in its ability to require Port 

Account Managers to conduct ISA program specific oversight activities. 

For example, CBP’s Office of International Trade issued a draft 

guidebook to National Account Managers identifying the protocols for 

conducting ISA importer oversight. Port Account Managers follow no 

written procedures in performing their ISA-specific oversight 

responsibilities. Based on our analysis of National Account Manager and 

Port Account Manager reviews of ISA importers’ annual notification 

letters, we determined that National Account Managers exercised 

sufficient oversight over their ISA accounts in FY 2009, while Port 

Account Managers did not. 

We are also concerned that the National Account Managers and Port 

Account Managers do not adequately review the results of ISA importers’ 

annual self-assessments. The ISA Handbook requires that ISA importers 

assess their compliance with CBP laws and regulations by annually 

conducting risk-based self-testing. Importers are required to implement 

changes to their internal controls based on the result of their selfassessments. According to CBP, Account Managers do not routinely 

request importers’ annual self-assessment results because of the volume of 

information and a lack of the skills necessary to analyze them effectively. 

Reviewing annual self-testing results would allow CBP to monitor ISA 

importers’ compliance with program requirements more completely. 
Recommendations 

We recommend that the Assistant Commissioner for the Office of 

International Trade: 

Recommendation #1: Establish policy and procedures that document the 

management controls needed for ISA program operations, including: 

•	 The purpose, goals, and objectives of the ISA program; 

•	 The performance metrics to measure the effectiveness of the program 

in meeting the established purpose, goals, and objectives; and 

•	 The formal procedural guidance necessary to support consistent and 

effective implementation of the program. 

Recommendation #2: Assess the risks to trade compliance associated 

with the current policies and procedures for accepting importers into the 

ISA program, and establish internal controls to ensure that risks identified 

are mitigated to provide reasonable assurance of ISA participants’ 

compliance with trade laws and regulations. 

Recommendation #3: Require Port Account Managers to follow the 

same policy and procedures for oversight of ISA importers as National 

Account Managers, or remove ISA program oversight responsibilities 

from Port Account Managers. 

Recommendation #4: Establish policy and procedures to ensure that ISA 

importers’ annual self-testing results are requested and reviewed for 

compliance with program requirements. 

Management Comments and OIG Analysis 

 CBP Comments to Recommendation 1: 

 

Concur. CBP plans to establish and strengthen internal controls to clearly 

define the ISA program’s purpose and achieve more consistent and 

effective program implementation. Currently under development, these 

controls will ultimately be reflected in formal agency policy and 

procedures addressing program goals and objectives, appropriate measures 

of program performance, and uniform operational guidance to personnel. 

 OIG Analysis: 

As described in its response, CBP’s current and planned actions satisfy the 

intent of this recommendation, which we consider resolved. However, 

Customs and Border Protection's Importer Self-Assessment Program 
 

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this recommendation will remain open until we verify through a review of 

appropriate supporting documentation provided by CBP that the stated 

corrective actions have been fully implemented. 

CBP Comments to Recommendation 2:

 

 Concur. CBP plans to develop and implement improved management 

controls over the ISA program designed to mitigate risks to participating 

importers’ non-compliance with trade laws and regulations. These 

planned improvements will provide for enhanced procedures governing 

the on-going monitoring and oversight of ISA importers by responsible 

CBP personnel. CBP’s plans also describe actions it believes will help it 

to more proactively assess and act upon identified risks to participating 

importers’ trade compliance as they emerge. 

 OIG Analysis: 

Because CBP’s response does not address risks to trade compliance posed 

by its current policy and procedures for accepting importers into the ISA 

program, we consider this recommendation to be unresolved. In our 

report, we indicate the internal controls of all ISA importers were not 

assessed consistently prior to program acceptance, which raised questions 

about certain participants’ qualifications for admission. We further report 

that CBP policy does not provide for substantive testing of applicants’ 

internal controls, which precludes CBP from providing adequate assurance 

as to the effectiveness of an importer’s internal controls in support of ongoing trade compliance self-assessment once enrolled. 

This recommendation will remain unresolved until we receive a 

supplemental response from CBP that sufficiently addresses its plans for 

assessing the trade compliance risks associated with its current importer 

acceptance policy and procedures, and for reasonably assuring that all 

applicants’ internal controls are verified as sufficiently effective to support 

on-going trade compliance self-assessment. Further, this recommendation 

will remain open until we verify through a review of appropriate 

supporting agency documentation that these and the remaining planned 

actions concerning improved ISA importer compliance monitoring and 

oversight have been fully implemented. 

CBP Comments to Recommendation 3:

 Concur. By the end of the current fiscal year, CBP plans to assign 

exclusive responsibility for conducting all ISA importer oversight and 

monitoring activities to National Account Managers. 

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 OIG Analysis: 

Because CBP’s stated actions satisfy the intent of the recommendation, we 

consider it resolved. However, the recommendation will remain open 

until we can verify through a review of supporting agency documentation 

that National Account Managers have been assigned to conduct 

monitoring and oversight of each importer actively enrolled in the ISA 

program by the end of the current fiscal year. 

CBP Comments to Recommendation 4:

 Concur. CBP plans to enhance several procedures related to ISA 

importers’ required annual testing of internal controls and notification to 

CBP of their continued readiness to assume the responsibilities of trade 

compliance self-assessment. These planned enhancements specifically 

concern how participating importers are to conduct self-testing, what 

information they are to annually provide to CBP, and actions CBP may 

take to review the testing results. 

OIG Analysis: 

Although CBP’s plans to take several near-term actions related to 

importers’ annual self-testing and notification procedures, it provided 

insufficient details for us to resolve the recommendation. As such, the 

recommendation will remain unresolved until CBP provides us with 

additional information specifically describing what elements of ISA 

importers’ annual self-testing results are to be reported to CBP, how CBP 

will annually request and review this information, and how CBP plans to 

respond to trade compliance risks identified during the review of 

importers’ testing results. Further, this recommendation will remain open 

until we verify through a review of appropriate supporting agency 

documentation that these and the remaining planned actions designed to 

enhance CBP’s review of ISA importers’ annual self-testing results have 

been fully implemented. 
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Appendix A 

Purpose, Scope, and Methodology 

The objective of our audit was to determine the efficacy of the 

Importer Self-Assessment (ISA) program. We obtained and 

reviewed Customs and Border Protection (CBP) policies and 

procedures pertaining to the ISA program for the period ending 

September 30, 2009. We also interviewed CBP personnel 

responsible for the management, oversight, and execution of the 

ISA program. 

We reviewed CBP draft and official program documentation; trade 

compliance data; federal laws, regulations, and notices; planning 

documents; and status and monitoring reports related to the ISA 

program. We reviewed prior Government Accountability Office, 

DHS OIG, and other external third-party reports relating to the ISA 

program. In addition, we selected and reviewed a judgmental 

sample of ISA importer files. 

We conducted interviews with officials from CBP’s Office of 

International Trade, including Trade Facilitation and 

Administration, Partnership Programs Branch, and Regulatory 

Audit. 

We evaluated CBP’s internal controls to the extent necessary to 

accomplish our objective. Specifically, we developed an 

understanding of internal controls over the ISA program by 

reviewing the ISA Handbook and other agency guidance and 

interviewing CBP officials assigned to oversee the ISA program. 

The understanding we gained was used to plan the audit and 

determine the nature, timing, and extent of the tests we performed. 

We conducted this performance audit between January and June 

2010 under the authority of the Inspector General Act of 1978, as 

amended, and according to generally accepted government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

on our audit objectives. 
Customs and Border Protection's Importer Self-Assessment Program 
 


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U.S. Depanment of Homeland Security

Washington. DC 20229

u.s. Customs and

Border Protection

August 4, 20 I0

MEMORANDUM FOR RICHARD L. SKINNER

INSPECTOR GENERAL

DEPARTMENT OF HOMELAND SECURITY

FROM: Assistant commissioneiflj{

Office of Internal Affai s

U.S. Customs and Borde Protection

SUBJECT: Response to the Office of Inspector General's Draft Report

Entitled, ·'Customs and Border Protection's Importer SelfAssessment Program"

Thank you for providing us with a copy of your draft report entitled "Customs and

Border Protection's Importer Self-Assessment Program," and the opportunity to comment

on the issues in this report.

The report contains four recommendations for CBP action. A summary ofCSP actions

and corrective plans to address the four recommendations is provided below:

Recommendation #1: Establish policy and procedures that document the

management controls needed for lSA program operations, induding:

The purpose, goals, and objectives of the (SA program;

The performance metrics to measure the effectiveness of the program in

meeting the established purpose, goals, and objectives; and

The formal procedural guidance necessary to support consistent and

effective implementation of the program.

eRP Response: CBP concurs with the recommendation. CBP is currently working on

enhancing the Importer Self-Assessment (ISA) Program's Standard Operating Procedures

(SOP) to clearly stipulate the program purpose, goals and objectives. As part of our

ongoing efforts to strengthen the monitoring and oversight of ISA. we are identifying

performance measures to validate the benefits oflhe ISA Program and how to improve

the program. The performance measures will focus on whether the program has achieved

its objectives, as expressed by measurable standards. CBP will develop formal

procedures and issue guidance to the port personnel, national account managers, and

other stakeholders as necessary to ensure uniformity, consistency and monitoring of the

ISA Program.

Due Date: October 3\, 2010

Appendix B 

Management Comments to the Draft Report 
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2

Recommendation 2: Assess the risks to trade compliance associated with the

current policies and procedures for accepting importers into the ISA program, and

establish internal controls to ensure that risks identified are mitigated to provide

reasonable assurance of ISA participants' compliance witb trade laws and

regulation.

CBP Response: CBP concurs with the recommendation. The ISA program will be

managed 10 mitigate risks to CBP by the following processes:

1. An enhanced Annual Notification Letter (ANL) will be developed that will

substantively broaden the reporting information from member companies. The

infonnation will provide additional criteria to better evaluate a company's risk

from the prior year. In addition, the information will enable CBP to determine if

the action the company implemented to mitigate those risks meets the new

standards ofthe ISA program.

2. Enhanced processes and procedures will be developed and implemented to

provide a higher level of evaluation ofthe ANL. This will allow CBP to identify

the emergence of risk factors from the prior year. and will aid in the selection of

candidates for closer national account manager reviews or revisits by Regulatory

Audit.

3. The role ofthe national account manager relative to ISA oversight will be

fonnally defined and strengthened to increase the depth and scope ofthe

membership monitoring.

4. The ISA Continuation Review Meeting (1·3) will be expanded with the

development of criteria that will identify member companies subject to 1-3

reviews utilizing both criteria for cause and other measures such as length of

membership without any or recent review.

5. Guidelines will be established for unifonnity to monitor ISA member companies

by CBP which will reinforce the oversight process.

Overall, new and reinforced processes and fonnal procedures will be implemented to

identify potential issues and adopt additional follow-up actions on member companies to

mitigate risks on a continuing basis.

It should be noted that CBP has implemented several control and monitoring activities

that will strengthen the monitoring and oversight of the program. Specifically, CBP:

Modified the internal review checklist to verify that the key components of the

nationaJ account manager's risk assessment and the variances. changes, and

modifications reported by the company on its annual notification have been

considered and adequately addressed;

Established a unifonn process which entail key factors to be included in the

national account manager's annual risk assessment; and.

Developed a process to issue timely notifications to (SA members and created

standardized correspondence templates to acknowledge ISA applications received

notification of incomplete applications, results of ANL review. etc.

Due Date: February 28,2011

Appendix B 

Management Comments to the Draft Report 
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3

Recommendation 3: Require Port Account Managers to follow the same policy and

procedures for oversight of ISA importers as National Account Managers, or

remove ISA program oversight responsibilities from Port Account Managers.

eRP Response: CBP concurs with the recommendation. CBP is phasing out the port

account manager's role in monitoring and providing annual risk assessments in regards to

ISA participants. All ISA accounts will be assigned to a national account manager by the

end ofthe fiscal year.

Due Date: September 30, 20 I0

Recommendation 4: Establish policy and procedures to ensure that ISA importers

annual self-testing results are requested and reviewed for compliance with program

requirements.

COP Response: CBP concurs with the recommendation. CBP is in the process of

enhancing and strengthening the ISA Annual Notification and reporting ofself-testing

results. Some of the enhancements include:

Clarifying the required elements to be included in the annual notification letter.

Initiate periodic Continuation Review Meetings (CRM) of ISA participants.

Review of ISA participants self testing results during the CRM.

Develop and provide improved guidance on developing the self-testing plan. CBP will

publish the final policy document.

Due Date: October 3 L 2010

With regard to the classification of the draft report, CBP did not identify any infonnation

that would warrant a ""For Official Use Only" classification.

If you have any questions regarding this response. please contact me or have a member of

your staff contact Ms. Ashley Bush, CBP Audit Liaison, at (202) 344-2539.

Appendix B 

Management Comments to the Draft Report 
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Appendix C 

Major Contributors to this Report 

Brooke Bebow, Director 

Lorinda Couch, Desk Officer 

Robert Greene, Team Leader 

Gary Alvino, Analyst-in-Charge 

Dawn Pizarro, Auditor 

Elizabeth Clark, Program Analyst 

Tessa May-Fraser, Program Analyst 

Joseph Faulk, Program Analyst 

Brian Blaha, Independent Referencer 
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Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Policy 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Commissioner for U.S. Customs and Border Protection 

Audit Liaison for U.S. Customs and Border Protection 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

The Honorable Charles E. Grassley, Ranking Member, Senate 

Committee on Finance 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

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To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

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• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

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The OIG seeks to protect the identity of each writer and caller.