Review of Domestic 

Sharing of Counterterrorism 

Information 

Prepared by the Inspectors General of the: 

INTELLIGENCE COMMUNITY
 

DEPARTMENT OF HOMELAND SECURITY
 

DEPARTMENT OF JUSTICE
 

MARCH 2017
 

OIG-17-49
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

March 30, 2017 

MEMORANDUM FOR: Patricia F.S. Cogswell 

Acting Under Secretary 

Office of Intelligence and Analysis 

FROM: John Roth ~~'\(oh. Inspector General 

SUBJECT: Review ofDomestic Sharing ofCounterterrorism 

Information 

Attached for your information is our final report, Review ofDomestic Sharing of 

Counterterrorism Information. We incorporated the formal comments from the 

Office of Intelligence and Analysis and the DHS Intelligence Enterprise 

components in the final report. 

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

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website. 

Please call me with any questions, or your staff may contact Laurel Loomis 

Rimon, Acting Assistant Inspector General for Inspections and Evaluations, or 

Angela E. Garvin, Deputy Assistant Inspector General for Inspections and 

Evaluations, at (202) 254-4100. 

Attachment 
 

 

 

 

 

 

 

 

 

REVIEW OF DOMESTIC SHARING OF 

COUNTERTERRORISM INFORMATION 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY .................................................................................................................................... i
 

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

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

FIELD-BASED COUNTERTERRORISM INFORMATION SHARING...................................................................................... 3
 

FINDINGS AND RECOMMENDATIONS ............................................................................................................ 7
 

INTEGRATION, COORDINATION, AND NATIONAL STRATEGY .......................................................................... 7
 

EXAMPLES OF INFORMATION SHARING AND COORDINATION...................................................................................... 7
 

SUMMARY OF CHALLENGES ................................................................................................................................. 8
 

INTERCONNECTED MISSIONS OF FEDERAL PARTNERS................................................................................................ 9
 

STRATEGY AND COORDINATION IN DOMESTIC INTELLIGENCE AND INFORMATION SHARING............................................ 11
 

DHS INTELLIGENCE ENTERPRISE ......................................................................................................................... 14
 

Limited Cohesiveness and Coordination of Effort across the DHS Intelligence Enterprise ................................... 14
 

I&A Staffing Issues ..................................................................................................................................................... 16
 

Insufficient Reporting of Counterterrorism Information......................................................................................... 17
 

Delays in I&A Intelligence Product Review and Approval ....................................................................................... 18
 

DHS Lacks Consistent Access to C-LAN and SCIFs in the Field................................................................................. 20
 

DOJ SUPPORT OF COUNTERTERRORISM INFORMATION SHARING ............................................................................. 21
 

DOJ Strategy for Internal Counterterrorism Information Sharing .......................................................................... 22
 

JTTF Executive Board Meeting Participation and Content ...................................................................................... 23
 

Anti-Terrorism Advisory Council (ATAC)................................................................................................................... 27
 

FBI Threat Review and Prioritization ........................................................................................................................ 29
 

ODNI FIELD BASED ELEMENTS SUPPORT TO COUNTERTERRORISM INFORMATION SHARING .......................................... 31
 

The Domestic DNI Representative Program............................................................................................................. 31
 

The NCTC Domestic Representative Program.......................................................................................................... 38
 

FUSION CENTERS ............................................................................................................................................. 42
 

Federal Investment and Support to Fusion Centers ................................................................................................ 42
 

National Network Maturity Model ........................................................................................................................... 47
 

Need to Coordinate Granting of Security Clearances .............................................................................................. 49
 

National Mission Cell Initiative.................................................................................................................................. 50
 

CONCLUSION ............................................................................................................................................... 51
 

APPENDIX A: OBJECTIVES, SCOPE & METHODOLOGY .................................................................................. 52
 

APPENDIX B: RECOMMENDATIONS............................................................................................................. 54
 

APPENDIX C: THE OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE’S RESPONSE TO THE DRAFT
 

REPORT........................................................................................................................................................ 63
 

APPENDIX D: THE DEPARTMENT OF HOMELAND SECURITY’S RESPONSE TO THE DRAFT REPORT ............... 67
 

APPENDIX E: THE DEPARTMENT OF JUSTICE’S RESPONSE TO THE DRAFT REPORT ...................................... 77
 

APPENDIX F: THE FEDERAL BUREAU OF INVESTIGATION’S RESPONSE TO THE DRAFT REPORT.................... 80
 
REVIEW OF DOMESTIC SHARING OF
 

COUNTERTERRORISM INFORMATION
 

EXECUTIVE SUMMARY 

Fifteen years after the September 11, 2001, terrorist attacks on the 

United States, the terrorist threat remains in the United States and abroad, as 

evidenced by recent attacks in Paris, France; San Bernardino, California; 

Brussels, Belgium; Orlando, Florida; and Nice, France. The U.S.’s national 

security depends on the ability to share the right information with the right 

people at the right time. This requires sustained and responsible collaboration 

among federal, state, local, and tribal entities, as well as the private sector and 

international partners. 

In response to a request from the Senate Select Committee on 

Intelligence, the Senate Homeland Security and Governmental Affairs 

Committee, and the Senate Judiciary Committee, the Offices of Inspector 

General (OIG) of the Intelligence Community (IC), Department of Homeland 

Security (DHS), and the Department of Justice (DOJ) conducted a review of the 

domestic sharing of counterterrorism information. 

The OIGs concluded that the partners in the terrorism-related 

Information Sharing Environment – components of the Office of the Director of 

National Intelligence (ODNI), DHS, DOJ, and their state and local partners – 

are committed to sharing counterterrorism information. The partners’ 

commitment to protecting the nation is illustrated by the actions taken before, 

during, and following terrorism-related incidents, as well as by programs and 

initiatives designed to improve sharing of counterterrorism information. 

However, the OIGs also identified several areas in which improvements could 

enhance information sharing. 

To share information effectively, the federal, state, and local entities 

actively involved in counterterrorism efforts must understand each other’s 

roles, responsibilities, and contributions, especially with the involvement of 

multiple agencies, such as the DOJ’s Federal Bureau of Investigation (FBI) and 

DHS’ U.S. Immigration and Customs Enforcement (ICE), in complex 

investigations. Updating or establishing new information sharing agreements 

among such entities should enhance coordination and collaboration, and 

reaffirm and formalize the roles and responsibilities of partners in the current 

information sharing environment. Similarly, although there is a national 

information sharing strategy, its implementation has been viewed to be uneven. 

The OIGs believe that the ODNI, DHS, and DOJ should review the interagency 

information sharing memorandum of understanding (MOU) and take necessary 

actions to update intelligence information sharing standards and processes 

among the departments, which we believe would result in better 

implementation of the strategy. 

i 
 

The OIGs also identified improvements in various practices and 

processes of the partners involved in counterterrorism. At DHS, a lack of unity 

in its Intelligence Enterprise, issues in the field related to staffing and access to 

classified systems and facilities, as well as problems with intelligence reporting 

processes, have made the DHS Intelligence Enterprise less effective and 

valuable to the IC than it could be. DOJ can improve its counterterrorism 

information sharing efforts by developing and implementing a consolidated 

internal DOJ strategy, and evaluating the continued need and most effective 

utilization for the United States Attorney’s Offices’ Anti-Terrorism Advisory 

Council (ATAC) meetings. Further, the FBI should spur participation 

associated with Joint Terrorism Task Forces (JTTF) and improve its efforts to 

obtain partners’ input in the process of identifying and prioritizing 

counterterrorism threats. Within the ODNI, the Domestic DNI Representative 

program is hindered by large geographic regions, as well as the lack of a clear 

strategic vision and guidance. In addition, the National Counterterrorism 

Center (NCTC) Domestic Representative program, although well received in the 

field, has also struggled to sufficiently cover its regions. At the state and local 

level, due to unpredictable federal support, fusion centers are focused on 

sustaining operations rather than enhancing capabilities. Further, varying 

requirements for state and local security clearances sponsored by federal 

agencies can impede access to classified systems and facilities. 

Our review resulted in 23 recommendations to help improve the sharing 

of counterterrorism information and ultimately, enhance the Nation’s ability to 

prevent terrorist attacks. We discuss our findings in detail in the Findings and 

Recommendations section of the report. 

ii 
 

INTRODUCTION 

The Senate Select Committee on Intelligence, the Senate Homeland 

Security and Governmental Affairs Committee, and the Senate Judiciary 

Committee requested that the Inspectors General (IG) of the Intelligence 

Community (IC), Department of Homeland Security (DHS), and Department of 

Justice (DOJ) conduct a performance audit of federally supported entities 

engaged in field-based domestic counterterrorism, homeland security, 

intelligence, and information-sharing activities in conjunction with state and 

local law enforcement agencies. The oversight committees requested that the 

joint audit examine these entities’ overall missions, specific functions, 

capabilities, funding, personnel costs to include full-time employees and 

contractors, and facility costs. 

In response to this request, the Offices of the Inspector General (OIG) of 

the IC, DHS, and DOJ conducted a coordinated, joint review focusing on 

domestic sharing of counterterrorism information. The objectives of this review 

were to: (1) identify and examine the federally supported field-based 

intelligence entities engaged in counterterrorism information sharing to 

determine the overall missions, specific functions, capabilities, funding, and 

personnel and facility costs; (2) determine if counterterrorism information is 

being adequately and appropriately shared with all participating agencies; and 

(3) identify any gaps or duplication of effort among these entities. 

The review was conducted by three teams from the OIGs of the IC, DHS, 

and DOJ. The OIGs interviewed more than 450 individuals, including senior 

Office of the Director of National Intelligence (ODNI), DHS, DOJ, and state and 

local officials. In addition, the OIGs reviewed policies, procedures, and other 

relevant documentation, as well as prior studies. While the OIG teams shared 

relevant documents, attended briefings, and participated jointly in interviews of 

officials and subject matter experts, each OIG team was responsible for 

evaluating the actions of, and information available to, its respective agencies. 

Background 

Post 9/11 investigations proposed sweeping change in the IC, resulting 

in congressional passage of the Intelligence Reform and Terrorism Prevention 

Act of 2004 (IRTPA).1 As a result of the IRTPA, the ODNI was officially 

established to lead and integrate the 16 members of the Intelligence 

Community, and the IRTPA codified the establishment of the National 

1 Intelligence Reform and Terrorism Prevention Act of 2004, PL 108–458, December 17, 2004, 118 Stat 

3638. 

1 
 

 

 

Counterterrorism Center (NCTC) as part of the ODNI.2 The IRTPA also directed 

the establishment of an Information Sharing Environment (ISE) for the sharing 

of terrorism information.3 In addition, the IRTPA required the President to 

“designate an individual as the Program Manager (PM) for information sharing 

across the Federal Government,” as well as an interagency Information Sharing 

Council (ISC) to advise the President and PM.4 

EO 13388, Further Strengthening Terrorism-related Information Sharing, 

established the policy framework for the terrorism-related ISE. In particular, 

ISE Presidential Guideline 2 – Sharing Among and Between Federal, State, 

Local, Tribal, and Private Sector Entities and its Report expanded the scope of 

the terrorism-related ISE to crimes of national security concern and involved a 

step forward from initial interagency information sharing established earlier. 

Under the statute, both the PM-ISE and ISC would expire after 2 years. 

In August 2007, the Implementing Recommendations of the 9/11 Commission 

Act permanently established the PM-ISE and ISC. The PM-ISE is responsible 

for facilitating the sharing of terrorism information among all appropriate 

federal, state, local, and tribal entities, as well as the private sector, through 

the use of policy guidelines and technologies. The office of the PM-ISE 

facilitates the development of responsible information sharing by bringing 

together mission partners and aligning business processes, standards and 

architecture, security and access controls, privacy protections, and best 

practices. The IRTPA mandated the PM-ISE to annually report to Congress on 

the ISE’s progress, status of efforts, and targeted next steps. 

In October 2007, the White House issued a national strategy for 

terrorism-related information sharing (2007 NSIS), which provided the 

Administration’s vision for the information sharing environment.5 In 2009, the 

White House established the Information Sharing and Access Interagency 

2 IRTPA supra note 2 at § 1021, codified at 50 U.S.C. § 3056(a). President Bush initially established the 

NCTC by Executive Order 13354, on August 27, 2004. In July 2008, Executive Order 13354 was 

rescinded by Executive Order 13470 because the IRTPA codified the establishment of the NCTC. 

3 ISE broadly refers to the people, projects, systems, and agencies that enable responsible information 

sharing for national security. This includes many different communities: law enforcement, public safety, 

homeland security, intelligence, defense, and foreign affairs. The people in these communities may work 

for federal, state, local, tribal, or territorial governments. 

4 IRTPA § 1016 (f)(1), codified at 6 U.S.C. § 485(f); established the responsibilities for the ISE PM. IRTPA § 

1016(g)(1); codified at 6 U.S.C. § 485(g)(1) established the responsibilities for the ISC. 

5 National Strategy for Information Sharing: Successes and Challenges in Improving Terrorism-Related 

Information Sharing (October 2007). 

2 
 

 

 

Policy Committee (ISA IPC).6 The ISA IPC is co-chaired by the National Security 

Staff’s Senior Director for Information Sharing Policy and the PM-ISE.7 The ISA 

IPC’s mission is to implement the national information sharing strategy and to 

lead information sharing policy on national security issues across the federal 

government.8 The President issued an updated national strategy in December 

2012 (2012 Strategy).9 The 2012 Strategy outlined 5 goals and 16 priority 

objectives for the national security information sharing environment. 

Field-Based Counterterrorism Information Sharing 

Various components of the ODNI, DHS, DOJ, and state and local law 

enforcement are among the ISE partners that contribute to the nation’s 

field-based homeland security and counterterrorism missions and information 

sharing. Within the ODNI, the NCTC serves as the federal government’s 

primary organization for analyzing and integrating all intelligence possessed or 

acquired pertaining to terrorism or counterterrorism (except intelligence 

pertaining exclusively to domestic terrorists and domestic counterterrorism). 

In addition, the NCTC ensures that agencies have access to and receive 

intelligence support needed to execute their counterterrorism plans to perform 

independent, alternative analysis and serves as the “central and shared 

knowledge bank on known and suspected terrorists and international terror 

groups, as well as their goals, strategies, capabilities, and networks of contacts 

and support.”10 The NCTC is staffed by personnel from multiple departments 

and agencies from across the IC, including the CIA, FBI, DHS, Department of 

State, Department of Defense, and other federal entities. In addition to the 

NCTC, the following ODNI programs and entities are involved in domestic fieldbased sharing of counterterrorism information. 

6 The Executive Office of the President, establishes Interagency Policy Committees (IPC) on a variety of 

issues. These IPCs are the primary day-to-day forums for interagency coordination on particular issues. 

They provide policy analysis for consideration by senior committees and staff and ensure timely responses 

to decisions made by the President. The ISA IPC subsumed the role of a predecessor body, the 

Information Sharing Council, which was established by Executive Order 13356: Strengthening the 

Sharing of Terrorism Information to Protect Americans in 2004. 

7 The ISA IPC consists of representatives from the ODNI; Joint Chiefs of Staff; Office of Management and 

Budget; Office of the Secretary of Defense; Central Intelligence Agency (CIA); National Security Agency; 

Federal Bureau of Investigation (FBI); and the Departments of Agriculture, Commerce, Energy, Health and 

Human Services, Homeland Security, Interior, Justice, State, Transportation, and Treasury. 

8 In a July 2009 memorandum, the Assistant to the President for Homeland Security and 

Counterterrorism made clear that the Administration regarded information sharing as extending beyond 

terrorism-related issues to encompass the sharing of information more broadly to enhance the national 

security of the United States and the safety of the American people. 

9 National Strategy for Information Sharing and Safeguarding (December 2012). 

10 IRTPA of 2004, § 1021(d); codified at 50 U.S.C. § 3056(d). 

3 
 

 

 

 

 

Table 1: ODNI Programs and Entities Engaged in Field-Based
 

Counterterrorism Information Sharing
 

Entity Mission 

Domestic Director of 

National Intelligence 

Representative 

Program 

Represent the DNI within the U.S. to senior field 

representatives of each IC element and lead the IC effort to 

create a single IC enterprise that is coordinated, integrated, 

agile, and effective. 

NCTC Domestic 

Representative 

Program 

Provide tailored counterterrorism-related information and serve 

as the liaison for the NCTC Director with IC agencies and 

counterterrorism officials at the federal, state, and local levels. 

Program ManagerInformation Sharing 

Environment 

Provide and facilitate the means for sharing terrorism 

information among all appropriate federal, state, local, and 

tribal entities, as well as the private sector through the use of 

policy guidelines and technologies.

 Source: NCTC, ODNI Partner Engagement, and PM-ISE documentation 

The Homeland Security Act of 2002, as amended, created DHS and 

established its primary mission to prevent terrorist attacks in the United States 

and enhance security. While not all DHS components have specific programs 

or groups dedicated to domestic field-based counterterrorism information 

sharing, they contribute to this mission through their areas of expertise and 

authorities. 

The Office of Intelligence and Analysis (I&A) is one of DHS’ two IC 

elements and is obligated and authorized to access, receive, and analyze law 

enforcement information, intelligence information, and other information from 

federal, state, and local government agencies and private sector entities, and to 

disseminate such information to those partners.11 I&A’s Field Operations 

consists of intelligence officers, reports officers, and regional directors deployed 

nationwide to manage DHS’ role in information sharing with state and local 

entities. The U.S. Coast Guard is the other DHS element of the IC and has the 

authority to “collect (including through clandestine means), analyze, produce, 

and disseminate foreign intelligence and counterintelligence including defense 

and defense-related information and intelligence to support national and 

departmental missions” and to “conduct counterintelligence activities.”12 Other 

DHS components, such as the Transportation Security Administration (TSA) 

and U.S. Citizenship and Immigration Services (USCIS), also have intelligence 

programs though they are not IC elements. These programs, in addition to I&A 

and the U.S. Coast Guard, compose the DHS Intelligence Enterprise. 

DHS components, such as U.S. Customs and Border Protection (CBP), 

U.S. Immigration and Customs Enforcement (ICE), and Federal Protective 

Service (FPS), deploy representatives nationwide to leverage their law 

11 6 U.S.C. § 121. 

12 Executive Order No. 12333 at § 1.7(h). 

4 
enforcement authorities in counterterrorism investigations with federal, state, 

and local partners. For example, CBP personnel at land, air, and sea ports of 

entry have the authority to search people and their belongings entering the 

United States and collect personal information for all travelers entering or 

leaving the United States. ICE Homeland Security Investigations (HSI) agents 

across the country enforce more than 400 federal statutes focused on the 

illegal movement of people, goods, and currency. Table 2 lists the DHS 

components engaged in this review and their respective missions. 

Table 2: DHS Entities Engaged in Field-Based Counterterrorism Information Sharing 

Entity Mission 

I&A Equip the Homeland Security Enterprise with the intelligence and 

information it needs to keep the homeland safe, secure, and resilient. 

U.S. Coast 

Guard Ensure the safety, security, and stewardship of the Nation’s waters. 

CBP 

Safeguard America’s borders thereby protecting the public from 

dangerous people and materials while enhancing the Nation’s global 

economic competitiveness by enabling legitimate trade and travel. 

Federal 

Emergency 

Management 

Agency 

Build, sustain, and improve the Nation’s capability to prepare for, 

protect against, respond to, recover from, and mitigate all hazards. 

FPS 

Prevent, protect, respond to, and recover from acts of terrorism and 

other hazards threatening the U.S. Government’s critical 

infrastructure and essential services. 

ICE 

Promote homeland security and public safety through the criminal 

and civil enforcement of federal laws governing border control, 

customs, trade, and immigration. 

National 

Protection and 

Programs 

Directorate 

Lead the national effort to protect critical infrastructure from all 

hazards by managing risk and enhancing resilience through 

collaboration with the critical infrastructure community. 

U.S. Secret 

Service 

Protect the Nation’s leaders and the financial and critical 

infrastructure of the United States. 

TSA Protect the nation’s transportation systems to ensure freedom of 

movement for people and commerce. 

USCIS 

Determine eligibility for immigration and citizenship benefits, promote 

an awareness and understanding of citizenship, and ensure the 

integrity of the U.S. immigration system. 

Source: DHS OIG compilation of DHS information 

Within DOJ, there are two components that are primarily involved in the 

field-based sharing of counterterrorism information – the FBI and the U.S. 

Attorney’s Offices (USAO). By law, the FBI is the lead agency within the federal 

government responsible for investigating crimes involving terrorist activity 

within the statutory jurisdiction of the United States.13 Each U.S. Attorney is 

13 18 USC 2332b(f). 

5 
 

 

 

 

 

the chief federal law enforcement officer within his or her particular 

jurisdiction. The following table shows the missions of specific entities within 

the FBI and USAOs that are predominantly involved in the field-based sharing 

of counterterrorism information. 

Table 3: DOJ Entities Engaged in Field-Based Counterterrorism Information Sharing 

Entity Mission 

FBI – Joint 

Terrorism Task 

Forces 

Leverage the collective resources of federal, state, and local agencies 

for the prevention, preemption, deterrence, and investigation of 

terrorist acts that affect the United States’ interests, and for the 

purpose of disrupting and preventing terrorist acts and apprehending 

individuals who may commit or plan to commit such acts. 

FBI – Field 

Intelligence 

Groups 

Coordinate, manage, and execute all functions of the intelligence 

cycle, including collection, analysis, production, and dissemination, 

for the FBI in field offices throughout the country. 

U.S. Attorney’s 

Offices – 

Anti-Terrorism 

Advisory

Councils 

Cross-section of federal, state, and local law enforcement, first 

responders, and private sector security personnel who coordinate 

counterterrorism efforts in their communities. 

Source: FBI and Executive Office for U.S. Attorneys documentation 

As acknowledged in the 2007 NSIS, state, local, and tribal governments 

serve as the nation’s first “preventers and responders,” and are critical to the 

nation’s efforts to prevent future terrorist attacks and to respond if an attack 

occurs. Often, these state, local, and tribal entities are best able to identify 

potential threats that exist within their jurisdictions. In our review, we 

identified the National Network of Fusion Centers and the Regional Information 

Sharing Systems (RISS) as the two primary state and local counterterrorism 

information sharing entities. The following table provides the missions of these 

non-federal entities. 

Table 4: Non-Federal Entities Engaged in Field-Based
 

Counterterrorism Information Sharing

 Entity Mission 

Fusion Centers 

Serve as a focal point within the state and local environment for the 

receipt, analysis, gathering, and sharing of threat-related information 

between the federal government and state, local, tribal, territorial, and 

private sector partners. 

Regional 

Information 

Sharing 

Systems 

Support regional law enforcement, public safety, and homeland 

security efforts to combat major crimes and terrorist activity, as well 

as to promote officer safety by linking federal, state, local, and tribal 

criminal justice agencies through secure communications. In 

addition, provide users with information sharing resources, analytic 

and investigative support, and training.

 Source: 2013 National Network of Fusion Centers Final Report and RISS website 

6 
 

FINDINGS AND RECOMMENDATIONS 

INTEGRATION, COORDINATION, AND NATIONAL STRATEGY 

In general, the OIGs found that federal, state, and local entities are 

committed to sharing counterterrorism information. The participating entities 

have shown their commitment to this effort by undertaking programs and 

initiatives that have improved information sharing, yet the participating entities 

were unable to quantify the significant personnel and funding resources 

dedicated to this effort. The OIGs also identified areas that require 

improvement to further strengthen the sharing of counterterrorism 

information. 

Examples of Information Sharing and Coordination 

During our review, several terrorism-related incidents occurred. We 

believe that many actions taken by federal, state, and local law enforcement 

agencies prior to, during, and following these incidents reflect their 

commitment to sharing counterterrorism information. For example: 

x	 In June 2015, Ali Saleh, a resident of New York, was arrested after he 

systematically made multiple attempts to travel to the Middle East to join 

Islamic State of Iraq and the Levant (ISIL). Saleh, who allegedly was 

inspired by ISIL propaganda, expressed his support for ISIL online, and 

took steps to carry out acts encouraged in the ISIL call to arms. This 

arrest resulted from the efforts of the New York Joint Terrorism Task 

Force (JTTF) working collaboratively with its federal, state, and local task 

force officers. 

x	 In June 2015, the Boston JTTF stopped and ultimately used deadly force 

against Usaamah Rahim, who had been under investigation and 

surveillance. According to an FBI affidavit, Rahim, along with coconspirators, was initially plotting to kill a prominent blogger but had 

abandoned that plot and instead targeted police officers. During the 

course of the review, we learned that the successful disruption of this 

plot was based, in large part, on information shared between federal and 

local law enforcement authorities in Boston. 

x	 During and following recent terrorism-related events, such as those in 

Chattanooga, Tennessee; Paris, France; and San Bernardino, California, 

fusion centers along with their federal, state, and local partners used the 

Homeland Security Information Network (HSIN) to share real-time 

updates, submit and respond to information requests, and support one 

another nationwide. The majority of fusion center personnel interviewed 

considered the use of HSIN as a best practice in information sharing 

across the National Network of Fusion Centers. 

7 
x	 Following the Paris, France; San Bernardino, California; and Brussels, 

Belgium, terrorist attacks, the FBI linked partner agencies using 

technology, including Secure Video Teleconference (SVTC), to quickly 

provide up-to-date threat information. For example, on the day of the 

Paris attacks, November 13, 2015, the FBI conducted a 3-hour 

conference call with representatives from all 78 Fusion Centers, DHS, 

executives from national law enforcement associations, the Criminal 

Intelligence Coordinating Council (CICC), Governor’s Homeland Security 

Advisors, and state and local law enforcement. 

In addition to these specific events, federal, state, and local partners 

exhibited a continued commitment to certain programs or initiatives, which 

further enhanced the sharing of counterterrorism information. For instance: 

x	 The National Fusion Center Association, with federal support from DHS, 

DOJ, FBI, and the PM-ISE, is leading an initiative to share Real-time 

Open Source Analysis of Social Media (ROSM). The goal of the ROSM 

initiative focuses on how law enforcement agencies can and should 

analyze and share social media information and related criminal 

intelligence to help identify common indicators that can support 

intervention with potentially violent extremists and thereby prevent 

and/or disrupt attacks. 

x	 In FY 2015, state and local partners initiated 623 terrorist watchlist 

nominations through I&A’s Watchlisting Enterprise, 79 percent of which 

were accepted. 

x	 As of FY 2014, about half of the almost 18,000 state and local law 

enforcement agencies in the United States had staff members who 

participated in their respective fusion center’s Fusion Liaison Officer 

(FLO) Program. In FY 2014, there were a reported 40,187 FLOs, 

representing a 104-percent increase from about 19,700 in FY 2011. 

x	 The FBI and DHS-led Nationwide Suspicious Activity Reporting Initiative 

is a collaborative effort for federal, state, and local law enforcement 

entities to share information on suspicious activities. Suspicious activity 

reporting increased by 96 percent between FY 2012 and FY 2015, with a 

majority of reports coming from the FBI’s partners, including fusion 

centers. 

Summary of Challenges 

Although the above examples evidence positive and proactive information 

sharing between federal and non-federal partners, the OIGs identified several 

areas in which improvements could strengthen the sharing of counterterrorism 

information, as summarized below. 

x	 Because both the FBI and DHS have counterterrorism-related missions 

and a role in gathering and disseminating counterterrorism information, 

8 
 

some DHS and FBI officials expressed concerns about potential overlaps 

in their counterterrorism missions and activities. 

x Although there is a national-level information sharing strategy, the PMISE determined that its implementation across the information sharing 

environment has been uneven. 

x The DHS Intelligence Enterprise is not as effective and valuable to the IC 

as it could be. For example, there is a lack of unity across the DHS 

Intelligence Enterprise, problems with I&A staffing levels in the field, 

issues with the internal intelligence product review and approval 

processes, and difficulty accessing classified systems and facilities in the 

field. 

x DOJ can improve its counterterrorism information sharing efforts by 

implementing a consolidated internal DOJ strategy and evaluating the 

continued need and most effective utilization for the USAOs’ AntiTerrorism Advisory Council (ATAC) meetings. In addition, the FBI should 

spur participation associated with JTTFs and improve its efforts to obtain 

partners’ input to the process for identifying and prioritizing 

counterterrorism threats. 

x Within the ODNI, the Domestic DNI Representative (DDNIR) program is 

hindered by large geographic regions, as well as the lack of a clear 

strategic vision and guidance. In addition, the NCTC Domestic 

Representative program has also struggled to sufficiently cover its 

regions. 

x At the state and local level, fusion centers are focused on sustaining 

operations rather than enhancing capabilities due to unpredictable 

federal support, including potential reductions in grant funding. 

Further, varying requirements for state and local security clearances 

sponsored by federal agencies can impede access to classified systems 

and facilities. 

Based on the results of this review, the OIGs concluded that sharing of 

counterterrorism information among federal, state, and local partners could be 

strengthened. Details of the above issues are contained in the following 

sections, including recommended actions to further improve the sharing of 

counterterrorism information. We believe that implementing these 

recommendations will help enhance and coordinate information sharing, 

which, in turn, can lead to a more comprehensive picture of the terrorist threat 

and greater national security. 

Interconnected Missions of Federal Partners 

Both the FBI and DHS have counterterrorism-related 

missions and both have a role in gathering and 

disseminating counterterrorism information. The working 

relationships between DHS components and the FBI relating 

9 
 

 

to counterterrorism investigations reflect the challenges of 

these interconnected missions. During our review, some 

DHS and FBI officials expressed concerns about potential 

overlaps in law enforcement and counterterrorism missions 

and activities. 

The FBI is the primary federal government agency responsible for 

handling counterterrorism investigations. However, these complex 

investigations often involve multiple possible violations of law, some of which 

may fall under another agency’s primary jurisdiction, and thus, require 

information and expertise from different source agencies, such as travel 

information, nuclear regulatory information, or watchlist information. An 

executive within the FBI’s Counterterrorism Division told the DOJ OIG that the 

FBI relies upon the JTTF concept to provide the coordination, information 

sharing, and deconfliction of investigative efforts. For example, multiple 

entities contributed to the investigation of the April 2013 bombing at the 

Boston Marathon, including the Boston JTTF, CBP, TSA, and USCIS.14 

Although officials said that they generally understood the missions of the 

other partners, the involvement of multiple agencies in counterterrorism 

investigations increases the risk that field personnel may interpret sharing 

requirements and guidance differently than what is articulated in the 

interagency information sharing MOU.15 The actions resulting from those 

differences in interpretations may contribute to a lack of trust among law 

enforcement agents, perpetuate negative perceptions about the other agency’s 

ability and willingness to share information, and foster an atmosphere in which 

individuals rely on their personal relationships with other law enforcement 

partners rather than establishing standardized coordination mechanisms that 

remain in place despite any personnel changes. 

The OIGs found that the quality of the working relationships between 

DHS components and the FBI varies widely in the field. For example, ICE HSI 

and FBI officials reported a challenging working relationship. According to the 

FBI, its field division leadership has consistently expressed to headquarters its 

concerns with ICE HSI performing work within the FBI’s mission. ICE HSI has 

learned of these reports, which has perpetuated its negative perceptions about 

the FBI’s willingness to work cooperatively with other law enforcement 

agencies. In general, ICE HSI said it believes the FBI does not sufficiently 

14 Inspectors General for the Intelligence Community, Central Intelligence Agency, Department of 

Justice, and the Department of Homeland Security, Information Handling and Sharing Prior to the April 

15, 2013, Boston Marathon Bombings, April 10, 2014. 

15 The interagency information sharing MOU is discussed in the following section of this report. 

10 
 

understand or recognize ICE HSI’s functions, capabilities, and abilities to 

contribute to counterterrorism investigations and information sharing. ICE 

HSI officials reported similar issues when discussing their involvement in the 

JTTFs. 

However, CBP reported that it generally has good working relationships 

with FBI field offices and personnel. Some CBP officials suggested that this is 

most likely because CBP has distinct authorities and unique access to 

information about travelers, which is often used in counterterrorism 

investigations. CBP officials said their relationship with the FBI has come a 

long way in recent years so that it feels more like a partnership than previously 

when it was one-sided with CBP sharing information with the FBI but not vice 

versa. CBP officials added that their involvement in the JTTFs has led to better 

awareness by the FBI of CBP functions and capabilities. 

Because agency missions are connected, it is critical that all partners 

understand and value the roles and contributions of its partners. The OIGs 

concluded that the issues cited above largely reflect struggles for this type of 

respect and cooperation in the counterterrorism arena. To achieve a shared 

vision and foster greater and more consistent cooperation, entities involved in 

counterterrorism should standardize practices and processes, as well as 

update and implement information sharing agreements. Throughout this 

report, the OIGs make recommendations to encourage and institutionalize 

such coordination through improvements to various practices and processes of 

the parties involved. 

Strategy and Coordination in Domestic Intelligence and Information 

Sharing 

To move away from personality-based coordination and codify 

interagency information sharing, the federal partners involved in 

counterterrorism efforts need formal agreements at the national level. The 

formal agreement governing information sharing, which includes priorities, 

requirements, and responsibilities, is outdated. The OIGs believe reviewing the 

interagency information sharing MOU and taking necessary actions to update 

intelligence information sharing standards and processes among the 

departments would reaffirm and formalize the roles and responsibilities of 

partners in the current information sharing environment. The agencies 

involved in counterterrorism should also establish processes to implement the 

overall strategy in the field. Clearly designating a capstone coordination and 

engagement body for the terrorism-related ISE would further assist in 

implementing the overall strategy and establishing field-level processes. 

As previously noted, in October 2007, the White House issued the 

National Strategy for Information Sharing: Successes and Challenges in 

Improving Terrorism-Related Information Sharing, which outlined the 

Administration’s vision for the information sharing environment. The White 

11 
 

 

 

House issued an updated national strategy, the National Strategy for 

Information Sharing and Safeguarding in December 2012 (2012 Strategy). The 

2012 Strategy outlined goals and priority objectives for the information sharing 

environment. In December 2013, the PM-ISE issued its Strategic 

Implementation Plan for the National Strategy for Information Sharing and 

Safeguarding, which established a construct for executing the 2012 Strategy.16 

However, in its annual report to Congress for 2014, the PM-ISE reported that 

federal department and agency implementation of the 2012 Strategy had been 

uneven. The PM-ISE attributed some of the challenges in implementing the 

2012 Strategy to the broad-based nature of the 2012 Strategy’s priority 

objectives, as well as differences in department and agency prioritization, 

maturity, and operating environments. 

In addition, although the White House updated the national strategy and 

the PM-ISE issued a strategic implementation plan, the Memorandum of 

Understanding between the Intelligence Community, Federal Law Enforcement 

Agencies, and the Department of Homeland Security Concerning Information 

Sharing dates back to 2003. This MOU outlines information sharing priorities, 

reciprocity and transparency, sharing requirements, coordination and 

deconfliction, and officials responsible for information sharing. However, the 

MOU predates the establishment of the ODNI and NCTC. 

The ODNI, DHS, and DOJ need to review the interagency MOU and 

determine what actions are necessary to update intelligence information 

sharing standards and processes among the departments. Such standards 

and processes should reflect the current structure, roles, and responsibilities of 

the ISE and the current threat environment and priorities. Based on these 

determinations, the NCTC, I&A, and FBI should continue to develop guidance 

for future intelligence information sharing, particularly in the field, that 

accounts for the roles and responsibilities the agencies have according to 

statute. Such guidance would enhance the sharing of intelligence information 

among federal representatives in the field and help create a unified and 

consistent federal contribution for state and local partners. 

16 Some members of the ISE, such as DHS and the FBI, have also developed departmental and agencylevel information sharing strategies to align with the national strategy. 

12 
 

 

 

 

 

 

 

 

 

The OIGs identified multiple entities (to include boards, committees, and 

councils) that are involved in the coordination and governance of domestic 

counterterrorism information sharing. Table 5 below provides examples of 

these entities and their missions. 

Table 5: Examples of Information Sharing Coordinating Entities 

Entity Mission 

Information Sharing and Access 

Interagency Policy Committee 

(ISA IPC) 

Established by the White House to implement a national 

information sharing strategy and to lead information 

sharing policy across the federal government. 

Information Sharing Council 

(ISC) 

Advises the President and the PM-ISE in developing 

policies, procedures, guidelines, roles, and standards 

necessary to establish, implement, and maintain the ISE. 

Homeland Security & Law 

Enforcement Partners Board 

Established by the ODNI as an External Advisory Body 

that provides the DNI and IC leaders with external 

perspectives on the intelligence and information needs, 

equities, and capabilities of state, local, and tribal 

governments. 

Intelligence Community 

Information Sharing and 

Safeguarding Executive 

As the DNI’s senior accountable officer, provides 

oversight and program management of all Offices of the 

ODNI and IC information sharing efforts; as well as leads, 

coordinates, facilitates, and as appropriate, manages all 

ODNI and IC information sharing. 

Global Justice Information 

Sharing Initiative (Global) 

Serves as a Federal Advisory Committee to advise 

the U.S. Attorney General on justice information sharing 

and integration initiatives.17 Global supports the broad 

scale exchange of pertinent justice and public safety 

information and promotes standards-based electronic 

information exchange to provide the justice community 

with timely, accurate, complete, and accessible 

information in a secure and trusted environment. 

Criminal Intelligence

Coordinating Council (CICC) 

Supports state, local, and tribal law enforcement and 

homeland security agencies in their ability to develop and 

share criminal intelligence nationwide. The CICC helps 

to facilitate the nationwide coordination on various 

efforts and initiatives to improve law enforcement’s ability 

to share information and intelligence. 

Homeland Security Advisory 

Council (HSAC) 

Serves as a Federal Advisory Committee to provide 

organizationally independent, strategic, timely, specific, 

and actionable advice to the DHS Secretary and senior 

leadership on matters related to homeland security. The 

HSAC comprises leaders from state and local 

government, the private sector, and academia. 

Source: OIGs’ compilation of White House, ODNI, DHS, and DOJ information 

17 Federal advisory committees,which may also be designated as commissions, councils, or task forces, 

are used to collect various viewpoints on specific policy issues. These committees are often created to 

help the government manage and solve complex or divisive issues. Such committees may be mandated by 

congressional statute, created by presidential executive order, or required by fiat of an agency head to 

render independent advice or make recommendations to federal agencies. 

13 
 

These multiple entities, with their differing roles and jurisdictions, lack 

an interconnectedness to facilitate collaboration, coordination, and integration 

of domestic information sharing. The OIGs believe that codifying an 

overarching engagement and coordination body for the terrorism-related ISE 

would help further these objectives. 

Recommendations: The IC IG and DHS and DOJ OIGs recommend that 

the ODNI, DHS, and DOJ: 

1. Review the 2003 interagency MOU on information sharing and 

determine what actions are necessary to update intelligence 

information sharing standards and processes among the 

departments. 

2. Codify an overarching engagement and coordination body for the 

terrorism-related ISE. 

DHS Intelligence Enterprise 

The DHS Intelligence Enterprise is not as effective and 

valuable to the IC as it could be. For example, there is still a 

lack of unity among I&A and other DHS component 

intelligence programs, which also affects intelligence 

reporting. In addition, DHS OIG concluded that I&A staffing 

levels in the field may be making it difficult to fully support 

the DHS Intelligence Enterprise. Complications in its 

relationship with the FBI, as well as internal issues 

associated with the review and approval process are also 

negatively affecting I&A’s production of intelligence reports. 

DHS must provide its stakeholders with information needed 

to disrupt and prevent terrorist threats and attacks. 

However, DHS intelligence personnel in the field have 

inconsistent access to the systems and facilities needed to 

receive, view, store, and share classified information above 

the Secret level. 

Limited Cohesiveness and Coordination of Effort across the DHS Intelligence 

Enterprise 

The DHS Intelligence Enterprise is fragmented, with elements operating 

independently and with few repercussions or incentives to coordinate better 

outside of actual events. The Under Secretary for Intelligence and Analysis, as 

14 
DHS’ Chief Intelligence Officer (CINT), is responsible for integrating and 

standardizing DHS component intelligence program products, including 

products with terrorism information and national intelligence, but has not fully 

exerted its authority over the DHS Intelligence Enterprise. The DHS 

components involved have their own intelligence programs with their own cadre 

of intelligence professionals. Further, I&A is subject to IC directives and 

standards, but component intelligence programs are not, unless IC directives 

and standards have been institutionalized into DHS guidance. 

I&A is taking several steps to help unify the DHS Intelligence Enterprise. 

For example, in 2014 I&A established a DHS Intelligence Rotational 

Assignment Program to promote a broader understanding of the various 

intelligence missions and functions across the intelligence enterprise and 

fusion centers. Efforts are also underway to ensure all intelligence products, 

briefings, and production plans are shared more evenly across the intelligence 

enterprise. However, the CINT has been unable to effectively require other DHS 

components to comply with its policies or to compel DHS component personnel 

to participate in its initiatives. Therefore, the CINT and key intelligence officials 

from the components should create incentives to encourage compliance and 

participation. 

To enhance cooperation with other DHS components, I&A needs to better 

communicate its mission and role to component management. DHS OIG 

observed increased collaboration between I&A and DHS components where 

intelligence enterprise meetings are held regularly. This best practice builds 

relationships, conveys missions and roles, and enhances information sharing 

across DHS components. Although I&A intelligence officers are now required 

to hold such meetings quarterly, the differing locations of component field 

offices, caps on the number of I&A intelligence officers, and reshuffling of 

assignments have caused meetings in some areas to lose momentum. 

There is also a lack of coordination between I&A and DHS components in 

intelligence reporting, but steps are being taken to address this issue. In 2012, 

DHS components established their own reporting programs, and at the same 

time, the Under Secretary for Intelligence and Analysis ended I&A’s production 

of intelligence reports based on information from the components. According 

to officials from I&A Field Operations, some DHS components are now working 

with I&A on pilot programs to facilitate intelligence reporting. For example, the 

ICE HSI Intelligence Unit Chief sends information to an I&A senior reports 

officer in the field who then sends it to the region it impacts. I&A reports 

officers in the field then produce ICE intelligence reports for which both 

components receive reporting credit. CBP, TSA, and USCIS have expressed 

interest in developing similar pilots. Because DHS component intelligence 

programs have limited personnel in the field and the majority are not 

authorized to produce intelligence reports, these efforts could lead to more 

efficient and effective intelligence reporting. Rather than sending intelligence 

information to component headquarters to produce reports, DHS field officials 

15 
 

 

with subject matter expertise, access to information systems, and an 

understanding of local context could work with I&A field officials to produce 

reports. 

Recommendations: DHS OIG recommends that I&A: 

3. In conjunction with the key intelligence officials from DHS 

components, ensure DHS component intelligence programs comply with 

policies and create incentives for personnel to participate in initiatives 

that enhance the cohesion of the DHS Intelligence Enterprise. 

4. Formalize agreements that enable I&A field officials to develop 

intelligence reporting with DHS components in the field, based on pilot 

program results. 

I&A Staffing Issues 

The Intelligence Authorization Act for Fiscal Year 2014 required I&A to 

limit the number of intelligence officers in the field. As of December 2015, I&A 

had 59 intelligence officers in the field, primarily located at the nation’s 78 

fusion centers, serving as the IC’s lead conduits to state, local, tribal, and 

territorial governments.18 Nineteen of the 78 fusion centers did not have a 

dedicated I&A intelligence officer, although two of those centers are in the same 

location as fusion centers that have a dedicated intelligence officer. Nine 

intelligence officers and one regional director each serve two or three fusion 

centers; five of the nine intelligence officers serve fusion centers located more 

than 100 miles apart. Two regional directors are the only I&A personnel at 

their respective area’s fusion centers. State and local entities expressed 

concern that recent changes to I&A Field Operations, such as the removal of 

some intelligence officer positions, have stretched these officers too thinly. 

Because they are thinly staffed, I&A intelligence officers cannot fully 

support the DHS Intelligence Enterprise in the field. For example, I&A does 

not have intelligence officers at all the fusion centers near major DHS 

component field concentrations, such as along borders, including those fusion 

centers in El Paso and San Antonio, Texas; and San Diego, California. In 

addition, most DHS component intelligence program personnel are located at 

headquarters with few in the field, and intelligence-related work is largely a 

18 I&A also has 26 reports officers in the field. However, they are trained and dedicated to producing 

intelligence reports, not to the additional functions performed by intelligence officers. 

16 
 

collateral duty for component field personnel. I&A could potentially fill this role 

through its intelligence officers assigned to fusion centers, but I&A does not 

have sufficient staffing in the field. 

Insufficient Reporting of Counterterrorism Information 

To develop a comprehensive and accurate threat picture, I&A field 

officials are expected to share information related to the missions of DHS and 

its components (e.g., information on homeland security, terrorism, and 

weapons of mass destruction) with state, local, and tribal entities. I&A field 

officials are also responsible for reviewing homeland security-relevant 

information, creating intelligence and other information products, and 

disseminating the products to the appropriate federal, state, local, and tribal 

government entities.19 Given that DHS is largely responsible for travel-related 

security (e.g., borders, transportation, and immigration), DHS has unique 

access to information about travelers, including known or suspected terrorists, 

and is well-situated to intercept and identify travel by potential terrorists and 

foreign fighters. I&A field officials could use this information to enhance state 

and local information to identify and analyze trends. Although I&A has 

increased its focus on intelligence reporting by sending all intelligence officers 

and regional directors to reports officer training, converting some intelligence 

officer positions to reports officer positions, and developing additional reporting 

lines, it does not have formal guidance for field officials on the collection and 

coordination needed to create these reports. 

In addition, none of the I&A field officials with whom DHS OIG spoke 

said they regularly develop intelligence reports from terrorism and 

counterterrorism information. I&A has a responsibility to produce intelligence 

reports based on counterterrorism information from state and locals for the IC, 

and the FBI has a responsibility to investigate terrorism-related matters and 

share counterterrorism information with the IC and outside agencies. Fulfilling 

these responsibilities can create tension because intelligence reports go to the 

IC while information that contributes to an investigation is generally closely 

held within the investigative team. Thus, I&A and the FBI may have difficulty 

coordinating these interrelated counterterrorism missions. Also, I&A has not 

asserted its reporting responsibility, leading the majority of I&A field officials to 

feel they needed permission from FBI field offices to develop counterterrorism 

reports. Without clear guidance on how to balance and coordinate these 

responsibilities, and with the desire to maintain good relationships with the 

FBI, about 43 percent of the I&A field officials interviewed said they no longer 

try to report on terrorism and counterterrorism information and about 21 

19 6 U.S.C. § 124h. 

17 
 

 

 

percent have developed ad hoc arrangements with their respective FBI field 

office regarding reporting in general. For example, one I&A field official said he 

has informally agreed to write reports with information the FBI cannot or 

chooses not to report. Following DHS OIG’s fieldwork, one I&A field official 

said I&A was working with the FBI to establish an agreement allowing I&A to 

create reports based on terrorist watchlisting. 

I&A should help its field officials fulfill their responsibilities by developing 

and implementing guidance for intelligence reporting. In addition, better 

coordination with the FBI and other partners would help to create intelligence 

products that address investigative concerns and include terrorism- and 

counterterrorism-related information. Therefore, I&A should also clarify its 

role and improve coordination with its federal partners, including the FBI, by 

formalizing agreements and policies regarding intelligence reporting. 

Recommendations: DHS OIG recommends that I&A: 

5. Develop and implement guidance for intelligence reporting in the field. 

6. Coordinate with the FBI to formalize guidance and policies for the 

reporting of terrorism and counterterrorism information. 

Delays in I&A Intelligence Product Review and Approval 

According to I&A field officials, approval and dissemination of I&A 

intelligence reports is often delayed, which could be the result of several 

factors. All I&A intelligence reports from the field must first be sent to I&A’s 

Reporting Branch for review and approval. Then, the clearing offices - DHS 

Privacy Office, Civil Rights and Civil Liberties (CRCL), Office of the General 

Counsel-Intelligence Law Division, and I&A Intelligence Oversight – 

concurrently review the reports. However, reports are emailed, and there is no 

formal system to log and track the review process. Further, although each 

clearing office is supposed to complete its review reports within 2 business 

days, it is not clear how long it actually takes.20 The Reporting Branch’s review 

and approval appears to take the most time, which may be due in part to the 

branch’s staffing levels and reviewing assignments. By the fall of 2015, the 59 

20 DHS OIG requested statistics on review times from each clearing office and the Reporting Branch but 

did not receive comprehensive statistics from each office. The statistics received from the DHS Privacy 

Office, CRCL, Office of the General Counsel-Intelligence Law Division, and the I&A Intelligence Oversight 

indicated a review time of less than 1 business day. 

18 
 

 

I&A intelligence officers in the field completed reports officer training. In 

addition to the 26 reports officers in the field, these 59 intelligence officers can 

now produce intelligence reports, but Reporting Branch staff have not had 

commensurate increases. Ten senior reports officers review all reports from 

the field. In addition, by assigning reviews to senior reports officers based on 

regions, the Reporting Branch may be creating backlogs for officers responsible 

for regions with a greater number of reports or more complex reporting. 

During our review, I&A field officials also said they did not have local release 

authority, that is, the authority to send intelligence reports directly to the 

clearing offices for review and approval without first sending them to the 

Reporting Branch. The Under Secretary for Intelligence and Analysis recently 

approved granting local release authority to I&A field officials, but formal 

guidance had not been issued prior to the end of DHS OIG’s fieldwork. 

Because of the delays in I&A reporting, even though they would like to 

develop joint products, many fusion centers had given up on doing so. In one 

often cited example, a joint product with the New Jersey, New York, and New 

Hampshire fusion centers about homegrown violent extremists targeting 

military assets was in production for about 2 years. Several fusion centers said 

they still coordinate products with I&A field personnel who contribute 

informally, but without joint seals or official reporting credit. These types of 

timeliness issues were raised in an October 2012 Senate report and a July 

2013 House report.21 

For more flexibility and continued coordination with and support from 

fusion center partners, I&A has introduced new intelligence products and 

reports, such as Field Analysis Reports and Field Intelligence Reports. Field 

Analysis Reports are finished intelligence products designed to highlight 

analysis from the National Network of Fusion Centers on national, regional, 

and local issues of concern. Topics must meet I&A’s statutory missions and 

authorities and should contain unique state, local, tribal, or territorial and/or 

DHS Intelligence Enterprise information or perspectives. Field Intelligence 

Reports are used to formally report raw, unevaluated information of potential 

intelligence value that responds to departmental requirements but not IC 

requirements. These new products have been well received by I&A 

stakeholders, including Congress, who had expressed concern about I&A’s 

production levels. 

21 United States Senate, Committee on Homeland Security and Governmental Affairs: Federal Support 

for and Involvement in State and Local Fusion Centers, Majority and Minority Staff Report, Permanent 

Subcommittee on Investigations (October 2012); and the United States House of Representatives, 

Committee on Homeland Security, Majority Staff Report on the National Network of Fusion Centers (July 

2013). 

19 
 

 

. 

 

Although I&A has taken steps to increase the timeliness and number of 

intelligence products, establishing formal review mechanisms and 

implementing formal guidance would further improve its intelligence reporting. 

Recommendation: DHS OIG recommends that the DHS clearing offices: 

7. Develop and implement a formal mechanism for reviewing I&A 

intelligence reporting from the field, including a logging and tracking 

process. 

Recommendation: DHS OIG recommends that I&A: 

8. Develop and implement guidance for field officials granting them local 

release authority for intelligence reporting. 

DHS Lacks Consistent Access to C-LAN and SCIFs in the Field 

Access to the C-LAN and Sensitive Compartmented Information Facilities 

(SCIF) are necessary for DHS intelligence personnel to fulfill their duties and to 

meet the goals of the DHS Information Sharing and Safeguarding Strategy.22 

However, while DHS I&A and other DHS Intelligence Enterprise personnel in 

the field have Top Secret/Sensitive Compartmented Information (TS/SCI) 

security clearances, they lack the supporting infrastructure to receive, view, 

store, and share information classified above the Secret level. Altogether, DHS 

components have SCIFs located at 19 sites outside of the National Capital 

Region that field personnel may reasonably use, such as to access the C-LAN. 

Of these 19, only 2 are I&A-certified SCIFs. 

I&A’s effectiveness as an IC member, in particular, is hampered by its 

limited access to classified systems and facilities. Nearly all I&A field personnel 

work in fusion centers, which now all have access to Secret-level classified 

information through the Homeland Secure Data Network (HSDN). However, 

counterterrorism information is often classified above the Secret level. 

22 C-LAN operates as the DHS information technology network for the Top Secret/Sensitive 

Compartmented Information level. A SCIF is an accredited area, room, group of rooms, buildings, or 

installation where sensitive compartmented information may be used, stored, discussed, and/or 

processed. 

20 
Several DHS field personnel have brokered informal agreements through 

personal relationships with Department of Defense facilities and other federal 

field offices to gain access to the C-LAN. Some of these facilities require 

personnel to drive up to 3 hours, thereby limiting the frequency with which 

personnel may use them. Some DHS field personnel rely on the FBI for access 

to TS/SCI systems and space. For example, DHS task force officers have 

access to FBI SCIFs and systems through their participation in JTTFs, but this 

applies only to special agents. Of the 96 I&A field officials surveyed, about 43 

percent hold active FBI badges similar to those that DHS task force officers 

receive and about 20 percent have access to FBI systems such as FBINet or the 

Top Secret/Sensitive Compartmented Information Operational Network 

(SCION). 

To enhance the efficiency and effectiveness of counterterrorism 

information sharing, DHS needs to increase field personnel’s access to 

classified systems and facilities above the Secret level. DHS should determine 

whether establishing more SCIFs in the field, formalizing agreements with 

other federal agencies, or pursuing a combination of the two, will resolve this 

issue and take the appropriate action. 

Recommendation: DHS OIG recommends that DHS: 

9. Develop and implement a plan that will allow DHS intelligence officials 

in the field practical access to classified systems and infrastructure above 

the Secret level. 

DOJ Support of Counterterrorism Information Sharing 

The DOJ OIG identified improvements that could be made to 

internal DOJ processes, JTTFs, and other field-based 

activities to enhance counterterrorism information sharing. 

Specifically, the DOJ OIG found that DOJ does not have a 

consolidated internal strategy to ensure that DOJ’s 

counterterrorism information sharing efforts align with the 

President’s strategic plan and that all DOJ components 

understand their respective roles and responsibilities. In 

addition, the FBI should further promote the JTTF Executive 

Board concept by increasing Board membership and 

spurring participation in Board meetings through 

standardization of content. Moreover, the DOJ OIG believes 

the ATAC meetings often duplicate other field-based 

counterterrorism information sharing efforts, and we believe 

that DOJ should evaluate the ATAC program to ensure the 

purpose of the ATAC meetings are not duplicative of other 

21 
 

 

 

counterterrorism information sharing partner initiatives. 

Finally, although the FBI has a well-defined process to 

identify and prioritize counterterrorism threats in each field 

division’s jurisdiction, it could improve its efforts to obtain 

its partners’ input on regional threats and mitigation 

strategies. 

DOJ Strategy for Internal Counterterrorism Information Sharing 

Based on discussions with an official from the Office of the Deputy 

Attorney General (ODAG), DOJ has not developed an internal strategy for 

counterterrorism information sharing separate from the President’s strategic 

plan. This official stated that DOJ determined that its existing framework of 

policies and procedures constitutes DOJ’s information sharing strategy. 

The DOJ OIG believes that additional DOJ leadership is needed to 

ensure that DOJ’s overall information sharing efforts and investments align 

with the 2012 Strategy and are coordinated and prioritized both within DOJ 

and with external partners. The DOJ OIG team discussed this issue with the 

DOJ Chief Information Officer (CIO) who agreed that coordination among the 

various DOJ components could be improved. According to the DOJ CIO, DOJ 

lacks an internal forum singularly dedicated to reviewing information sharing 

initiatives and investments across all DOJ components. The Law Enforcement 

Information Sharing Coordinating Committee (LCC), which was created in 

December 2006 by the Deputy Attorney General, was responsible for ensuring 

a department-wide collaborative and integrated focus on information sharing 

policy objectives. However, this group stopped meeting in 2009 because the 

group determined that it had accomplished its goal of enhancing 

interconnectivity with the Department’s law enforcement partners following the 

establishment of the National Data Exchange.23 

The lack of an internal strategy and forum for sharing information may 

hamper DOJ’s ability to define and execute a comprehensive and unified plan 

for its information sharing initiatives and investments across all of DOJ’s 

components. Officials from each DOJ component attend other information 

sharing working groups. For example, the DOJ CIO said that DOJ uses the 

Criminal Intelligence Coordinating Council (CICC) as a forum for components 

to discuss information sharing initiatives with external partners. The DOJ OIG 

is concerned that because DOJ does not have a consolidated internal strategy, 

23 The National Data Exchange (N-DEx) provides criminal justice agencies with an online tool for 

sharing, searching, linking, and analyzing information across jurisdictional boundaries. 

22 
there is a risk that DOJ components may present or discuss initiatives that do 

not align with DOJ’s unified vision. 

The DOJ CIO said that he had recently proposed the establishment of a 

new council, the Law Enforcement Information Sharing Council (LEISC), that 

would be led by the Deputy Attorney General and help coordinate the 

information sharing efforts within DOJ. The proposed LEISC would provide a 

platform for DOJ entities to discuss and develop a unified vision regarding 

information sharing initiatives and investments, as well as ensure that DOJ 

actions are consistent with the 2012 Strategy. The DOJ CIO stated that DOJ is 

evaluating the LEISC, or a similar initiative, to determine how best to meet 

DOJ’s operational and strategic planning needs. The DOJ OIG believes that 

the LEISC or a similar initiative could provide a valuable forum for the 

discussion and coordination of DOJ information sharing efforts, including 

overall strategy and investments. Information gleaned from this council’s 

discussions could then be used during discussions with the PM-ISE and the 

CICC. 

Recommendations: DOJ OIG recommends that DOJ: 

10. Develop a comprehensive internal counterterrorism information 

sharing strategic plan based on a review of the President’s strategic plan 

and in consultation with relevant partners. 

11. Implement a council, led by a senior Department official, for the 

internal coordination of DOJ information sharing strategy and 

investments, and ensure that relevant components designate senior-level 

officials responsible for monitoring their component’s efforts and 

communicating their efforts to DOJ as requested. 

JTTF Executive Board Meeting Participation and Content 

JTTFs, which are squads within each of the FBI’s Field Divisions and 

select Resident Agency Offices, focus primarily on addressing terrorism threats 

and preventing terrorist incidents. The JTTFs leverage the resources and 

expertise of multiple member agencies to collect and share counterterrorism 

information. As of March 2016, the JTTFs were comprised of 54 federal 

agencies and 449 state, local, and other agencies. For example, DHS has more 

than 600 agents who participate on the 104 JTTFs nationwide. These DHS 

personnel help enhance the JTTFs’ efforts through their unique expertise in 

areas such as immigration and customs enforcement. 

In 2003, FBI field divisions were instructed to establish a JTTF Executive 

Board if they did not already have one. While the JTTFs conduct joint 

23 
 

 

counterterrorism investigations, JTTF Executive Boards are forums for sharing 

critical terrorism threat intelligence and ongoing investigative efforts to address 

those threats with law enforcement executives in their respective jurisdictions. 

As a result, the JTTF Executive Boards encompass a wider coverage of agencies 

within each respective jurisdiction because not all agencies are able to 

participate on a JTTF due to restrictions such as resources. In 2005, FBI field 

divisions were instructed to ensure that the JTTF Executive Board met on an 

as-needed basis but at least three times per year. The 2005 guidance further 

said that JTTF Executive Boards should be comprised of key federal, state, 

local, and tribal law enforcement officials, but at a minimum, include the heads 

of the agencies that have full-time agents and/or officers assigned to the JTTF 

within the respective field division’s territory. 

During the review, the DOJ OIG found that the JTTF Executive Board 

meetings in the sites the team visited were generally occurring at least 

quarterly. However, we are concerned with the number of agencies not 

represented on the JTTF Executive Boards and with the level of participation of 

those agencies on the JTTF Executive Boards. To assess the level of 

engagement and participation of executive management of the agencies that 

have full-time agents or officers assigned to a JTTF, the team reviewed JTTF 

task force officer and JTTF Executive Board member rosters and meeting 

attendance records maintained by the FBI for the eight FBI field divisions 

visited.24 

24 The DOJ OIG requested the JTTF Executive Board member rosters and meeting attendance records 

for the preceding 2 years from each of the eight FBI field divisions. In reviewing the documentation 

provided, the total number of JTTF Executive Board meetings conducted by each site varied. Our 

analysis was based upon the data provided by each site. 

24 
 

As shown in the following table, 167 agencies assigned at least one task 

force officer to the JTTFs in the 8 locations reviewed. However, we found that 

34, or 20 percent, of the 167 agencies did not have an agency representative on 

the JTTF Executive Board. For example, the FBI Boston Division’s JTTF 

Executive Board only had representation from 40 percent of the agencies 

participating on the Boston JTTF. 

Table 6: Analysis of JTTF Executive Board Engagement and Participation for Agencies 

with a Task Force Officer Assigned to a JTTF 

Number of Agencies: 

Not Attending More 

FBI Field 

Location With a JTTF Task 

Force Officer 

Without an 

Executive 

Board Member 

With an 

Executive 

Board Member 

Than Half of the 

Executive Board 

Meetings (excludes 

agencies without a 

Boston 

Chicago 

Dallas 

Denver 

Houston 

New York 

Portland 

Springfield 

Total 

20 

16 

20 

18 

37 

39 

12 

5 

167 

12 

0 

2 

1 

7 

12 

0 

0 

34 

8 

16 

18 

17 

30 

27 

12 

5 

133 

Board Member) 

3 

3 

3 

7 

19 

6 

10 

1 

52 

Source: DOJ OIG analysis of Federal Bureau of Investigation Data 

Using the FBI-provided meeting attendance records, we found that 39 

percent of the 133 agencies represented on the JTTF Executive Board did not 

attend at least half of the JTTF Executive Board meetings, as shown in 

preceding table.25 This 39 percent included federal, state, and local agencies. 

The Special Agents in Charge (SAC) in two FBI field divisions we visited told us 

that the need to obtain appropriate security clearances prevented some state 

and local law enforcement representatives from attending the JTTF Executive 

Board meetings. Officials from federal agencies reported that they may miss 

meetings because of competing work demands, such as training and other 

meetings. While we recognize that individuals may not be able to attend every 

meeting, agency representation at the JTTF Executive Board meetings is 

25 According to the FBI, not everyone who attends a JTTF Executive Board meeting may have signed the 

meeting attendance sheet. Because there was no other documentation available to confirm attendance, 

the DOJ OIG considered an individual to have regularly attended the meetings if she/he attended more 

than half of the meetings within the date ranges provided by the FBI based upon the meeting attendance 

sheets. 

25 
 

 

important, and we believe that the FBI and participating agencies should place 

greater emphasis on attendance because these meetings provide another 

avenue for obtaining relevant information concerning their jurisdictions that 

they may not obtain otherwise. To help place greater emphasis on these 

meetings, we believe it is essential that the FBI ensure that a management 

representative (and an alternate) from each agency with a task force officer 

assigned to the JTTF has been designated as a JTTF Executive Board member 

and ensure that those individuals are notified of upcoming meetings. 

During the review of JTTF Executive Board data, the DOJ OIG found that 

representatives from agencies without full-time JTTF task force officers also 

attend JTTF Executive Board meetings. For example, regional representatives 

from the NCTC, I&A, and fusion centers attended meetings although these 

agencies did not have full-time JTTF task force officers. 

The DOJ OIG also noted that representatives from local fire departments 

attended the JTTF Executive Board meetings in some FBI field divisions. The 

DOJ OIG discussed this issue with the Assistant Director for the FBI’s Office of 

Partnership Engagement who said that he believed it was a “best-case 

scenario” to have first responders, such as fire departments, attend JTTF 

Executive Board meetings. He further indicated that if state and local first 

responders cannot participate on the JTTF Executive Board, then the first 

responders should be engaged with the fusion center. This official also stated 

that it was important to have the first responders on the JTTF so that they are 

aware of the threat picture and have situational awareness so they may 

respond appropriately in the event of a terrorist attack, such as Paris or San 

Bernardino. Therefore, the DOJ OIG recommends that the FBI ensure its field 

divisions encourage agencies that do not participate on the JTTF, including 

first responders, to attend JTTF Executive Board Meetings. 

In addition to our concerns with the engagement and participation on the 

JTTF Executive Board, we believe the content of the meetings needs to be more 

standardized. Representatives from partner agencies who attended the JTTF 

Executive Board meetings reported the meetings provided valuable 

opportunities to share investigative and operational information, and that the 

meetings have improved in content and depth in recent years. The DOJ OIG 

attended a JTTF Executive Board meeting hosted by the FBI’s Chicago Division. 

The meeting included an overview of the FBI’s current threat environment, a 

roundtable discussion about emerging counterterrorism issues, and in-depth 

briefings on open terrorism investigations and threats, which were presented 

by various agencies, including the FBI, DHS, NCTC, and the area’s two fusion 

centers -- the Illinois State Terrorism and Information Center (STIC) and the 

Chicago Crime Prevention and Information Center (CPIC). 

However, in other locations, some partner agency officials reported that 

the depth to which the topics were covered varied from meeting to meeting, and 

that in some instances, the varying coverage coincided with changes in FBI 

26 
field division management. For example, a DHS official who attends the FBI 

Denver Division’s JTTF Executive Board meetings said the meeting content 

varied in conjunction with three changes in the FBI Denver Division’s 

leadership. This DHS official said that it would be more useful if the meetings 

were more consistent and provided both an overview of terrorism threats and 

specific cases. An official from the Colorado Division of Homeland Security and 

Emergency Management also said that he would like more strategic analysis of 

emerging threats, and that this type of information would assist him in his 

duties for the state of Colorado. 

Although the DOJ OIG recognizes that some level of flexibility is needed 

to accommodate local needs, we believe the FBI should ensure that the JTTF 

Executive Board meetings across FBI field divisions consistently approach 

sharing information, which may well improve attendance at the meetings. 

Therefore, the DOJ OIG recommends that the FBI identify the structure and 

content of JTTF Executive Board meetings that would give attendees the most 

meaningful information on a consistent basis. The FBI should then inform 

field divisions to use this structure and content, perhaps as a template, at a 

minimum when planning their JTTF Executive Board meetings. 

Recommendations: DOJ OIG recommends that the FBI: 

12. Require FBI field divisions to stress to participating agencies the 

importance of designating an individual and an alternate to serve as their 

representatives to the JTTF Executive Board, as well as of regularly 

attending the meetings. 

13. Ensure FBI field divisions encourage agencies that do not participate 

on the JTTF, including first responders, to attend JTTF Executive Board 

Meetings. 

14. Identify an appropriate structure and content of JTTF Executive 

Board meetings that FBI field divisions should use at a minimum when 

conducting these meetings. 

Anti-Terrorism Advisory Council (ATAC) 

In 2001, the Attorney General established the ATAC program. As part of 

this program, each USAO designated an ATAC Coordinator to help enhance the 

nation’s counterterrorism efforts. Each USAO also formed a committee 

comprised of federal, state, and local law enforcement agencies and often 

pertinent public health and safety and security officials from private industry. 

The program has three primary functions, including: (1) convening the ATAC 

(or committee) to facilitate counterterrorism efforts and information sharing in 

their communities; (2) supporting the investigative efforts of the JTTFs; and (3) 

27 
 

 

facilitating counterterrorism information sharing between DOJ field and 

headquarters components regarding threats, litigation, criminal enforcement, 

intelligence, and training. Each USAO was required to complete an ATAC Plan 

that defined how each office implemented the ATAC Program, and each USAO 

is supposed to update its plan every 6 months.26 

Beginning at a March 2010 ATAC training event and continuing 

thereafter at training events, the ATAC National Program Coordinator 

instructed the ATAC Coordinators to coordinate their efforts with other entities 

within their jurisdiction to reduce duplication as it pertained to convening the 

committee to share counterterrorism information. For example, the USAO may 

not need to maintain its own distribution list for sharing counterterrorism 

information if the fusion center provides the primary information sharing 

responsibilities for national security matters within the district. Nonetheless, 

the USAO must remain a full-time participant with the agencies leading 

counterterrorism information sharing efforts and be willing to certify that the 

USAO is actively engaged in information sharing. Similarly, if the JTTF in the 

USAO’s district conducts effective meetings and trainings that include the 

same law enforcement partners as the ATAC, then the USAO is not required to 

conduct duplicative ATAC meetings or trainings. However, the ATAC 

Coordinator should have a substantial role in developing the agenda, 

presenting information, and participating in the JTTF meeting or training. 

To assess the USAOs’ efforts to reduce the potential duplication between 

ATAC meetings and those of their partners, the DOJ OIG reviewed the 2006 

and the most recent version of the ATAC plans for the USAOs located within 

eight FBI field division jurisdictions.27 The DOJ OIG found that half of the 

USAOs’ ATAC Plans had not been updated for nearly 10 years (from the initial 

submission in 2006 until the DOJ OIG requested them). As a result, the DOJ 

OIG was unable to determine the evolution of the ATACs and the USAOs’ 

efforts to reduce the potentially unnecessary duplication of counterterrorism 

information sharing. 

26 The ATAC Plan sets forth required objectives that must be achieved in each district. These objectives 

include defining the duties and responsibilities of the ATAC Coordinator and other USAO personnel who 

assist on counterterrorism matters, ensuring that the USAO has established a mechanism for effectively 

distributing time-sensitive information throughout the district, outlining collaboration between the ATAC 

Coordinator and DOJ’s National Security Division, and ensuring the USAO has a plan for convening the 

ATAC. 

27 We requested the most recent ATAC Plans for the USAOs located in the headquarter cities of the FBI 

field divisions we visited. The ATAC Plans for six of the USAOs were dated September 2015, one was 

dated April 2013, and one was not dated. We did not speak to the ATAC Coordinators about the plans 

because we were not informed of them until after our site visits. 

28 
In addition, the DOJ OIG found that several of the most recent ATAC 

Plans indicated fewer ATAC meetings being held or a consolidation of ATAC 

meetings with JTTF Executive Board meetings (the latter of which might or 

might not be consistent with the instructions to increase coordination and 

reduce duplication). Moreover, based on the review of attendance rosters, the 

DOJ OIG determined that, in general, representatives from the USAOs 

regularly attended JTTF Executive Board meetings within the eight FBI field 

divisions visited, and that the ATAC Coordinators said they participated in the 

meetings. 

Given the progression of other counterterrorism information sharing 

efforts by other field-based entities, it is recommended that DOJ assess the 

ATAC program and ensure that the purpose of the ATAC meetings are not 

duplicative of other counterterrorism information sharing partner initiatives 

and are used in the most effective manner. For instance, instead of holding 

separate ATAC meetings, USAOs could be committed to fully participating in 

the JTTF Executive Board meetings and fusion center meetings, thereby 

standardizing the ATACs’ roles and reducing possible duplication of efforts. 

Following this evaluation, the DOJ should ensure that each USAO updates its 

ATAC plan accordingly and that the plans are updated as required by the 

program. 

Recommendation: DOJ OIG recommends that DOJ: 

15. Ensure that each USAO updates its ATAC Plan as required by the 

program. 

16. Evaluate the ATAC program to ensure the purpose of the ATAC 

meetings is not duplicative of other counterterrorism information sharing 

partner initiatives and is used in the most effective manner. 

FBI Threat Review and Prioritization 

The FBI Directorate of Intelligence implemented the Threat Review and 

Prioritization (TRP) process to assess, triage, and prioritize threats. The TRP 

process was designed to integrate intelligence and operations to provide a 

construct that synchronizes prioritization between FBI headquarters and field 

divisions. FBI field divisions use FBI National Threat Priorities and nationallevel mitigation strategies developed by FBI headquarters in completing their 

individual TRP process. 

According to FBI policy, appropriate representatives from the USAO must 

be invited to participate in the TRP process. Officials from the USAOs the team 

visited said that USAO representatives participate in the TRP process and 

29 
 

believe the USAOs being involved in this process is beneficial. For example, an 

ATAC Coordinator from one of the USAOs visited said that she attended TRP 

meetings, and it helped her to understand the FBI’s priorities and thought 

processes, which enhanced the USAO’s awareness of the threat environment in 

the area. In addition, she said that she believes having the USAO participate in 

the TRP adds credibility to the TRP process and shows the FBI that the USAO 

cares about its issues. 

Although not required by FBI policy, FBI SACs in two of the field 

divisions the team visited said that JTTF task force officers and other partner 

agencies participate in the TRP process. For example, the SAC for the FBI 

Denver Division said that the Denver Police Department attends the annual 

TRP meeting. Similarly, the SAC for the FBI Houston Division said that the 

USAO and JTTF task force officers participate in the TRP process. Further, he 

said that there would be a benefit to have even more agencies participate in the 

TRP process. However, some JTTF task force officers in the locations the teams 

visited said that they did not participate in the TRP meetings. 

The DOJ OIG believes that it is important for the FBI to obtain its 

partners’ input regarding the threats and mitigation strategies for the region. 

As a result, we recommend that the FBI direct FBI field divisions to identify 

and invite key stakeholders to TRP sessions. 

The DOJ OIG also noted differences as to the individuals and entities 

with whom FBI field divisions shared their TRP results and, specifically, their 

prioritization of threats in their regions. For example, the FBI Boston Division 

shared its TRP outcomes with the command staff of the fusion center and the 

JTTF task force officer home agencies. In contrast, in the FBI Houston Division 

the JTTF task force officers who participate in the TRP process are responsible 

for providing such information to the management of their home agencies. 

The results of the FBI’s TRP process could provide important information 

to the FBI’s counterterrorism information sharing partners. For example, the 

SAC for the FBI Houston Division said that there could be value in sharing the 

TRP results with JTTF Executive Board members, as well as the Texas 

Homeland Security Advisor. Similarly, the Homeland Security Advisor for the 

state of Colorado said that he believed it would be helpful to obtain the FBI 

Denver Division’s TRP results for both the Denver area and the state of 

Colorado. As such, the DOJ OIG recommends that the FBI determine with 

whom it could share its counterterrorism-related TRP results and implement a 

process by which it shares counterterrorism TRP results with the appropriate 

partners on a systemic and regular basis. 

30 
Recommendations: DOJ OIG recommends that FBI: 

17. Direct FBI field divisions to identify and invite key stakeholders to 

TRP sessions. 

18. Determine the agencies with which it should share its 

counterterrorism-related TRP results and implement a process to ensure 

the TRP results are appropriately shared with those agencies on a 

systemic and regular basis. 

ODNI Field Based Elements Support to Counterterrorism Information 

Sharing 

The ODNI has two programs focused on the field-based 

sharing of counterterrorism information: the Domestic DNI 

Representative (DDNIR) program and the NCTC Domestic 

Representative program. The OIGs found that although the 

DDNIR program has gained momentum and progress has 

been made, the program is hindered by large geographic 

regions, as well as the lack of a clear strategic vision and 

guidance for it to reach its full potential. The OIGs found 

that the NCTC Domestic Representative program, although 

well received in the field, has also struggled to sufficiently 

cover its regions. 

The Domestic DNI Representative Program 

The DDNIR program plays a role in facilitating the sharing of 

counterterrorism information. A November 2011 Memorandum of Agreement 

(MOA), “Domestic Director of National Intelligence Representatives,” governs 

the DDNIR program between the ODNI and the FBI under Intelligence 

Community Directive 402, “Director of National Intelligence Representatives.” 

31 
 

 

Domestic DNI Regions – The Director of National Intelligence and the FBI 

launched the DDNIR program in February 2012 and designated 12 FBI 

executives as DDNIRs. As shown in the map below, the DDNIRs are the 

Assistant Directors in Charge of Los Angeles, New York, and Washington DC, 

and the SACs of Atlanta, Boston, Chicago, Denver, Houston, Miami, 

Pittsburgh, San Francisco, and Seattle, with each representative being 

responsible for covering a designated geographic region.28 

FBI Field Offices: 

28 The OIGs were unable to find any documentation describing how the selection of the initial DDNIR 

locations were determined. However, officials familiar with the history of the program told us the regions 

were originally selected by identifying cities with a large presence of multiple IC elements. 

32 
 

 

The DHS Chief Intelligence Officer designated the I&A regional directors 

to serve as the DHS senior field representatives to the DDNIR program in 

specified geographic regions. I&A regional directors serve as the DHS focal 

point for all engagements with the DDNIR program. They maintain awareness 

of all DDNIR or ODNI staff visits to DHS components in their specified 

geographic region, coordinate actions with affected elements of the DHS 

Intelligence Enterprise, share program-related data, and work collaboratively 

with the U.S. Coast Guard national intelligence element to support its 

interaction with DDNIRs and ensure unity of effort and consistency in 

departmental messaging of DHS activities. While in some regions DHS 

Intelligence Enterprise field personnel participate in the program, the DDNIR is 

not authorized to task DHS components that are not elements of the IC. The 

scope of the DDNIR’s authorities extends only to those DHS components that 

are elements of the IC: I&A and the U.S. Coast Guard’s intelligence and 

counterintelligence elements. 

Domestic DNI Quarterly Meetings – DDNIRs hold quarterly meetings with 

the IC representatives in their region to help foster collaboration, effective 

partnerships, and integration of the IC team in the domestic field. Quarterly 

meetings generally focus on a particular threat or issue that is of interest to the 

region.29 To help ensure that the DDNIR program meetings are productive and 

support the primary mission of the program, the FBI has incorporated metrics 

into its field division performance measures. To actively participate in the 

DDNIR program, FBI field divisions are required to complete a combination of 

the following activities: serve as lead on a DDNIR region product; chair a subgroup; substantively contribute to a sub-group or region product; host a 

quarterly meeting; and/or complete a collaborative interagency action item. 

The OIGs found that the differing sizes of some of the 12 geographic 

regions cause challenges for some of the DDNIRs when conducting quarterly 

meetings. For example, the DDNIR for the Rocky Mountain Region is 

responsible for the coordination of nine states in his region.30 The Program 

Coordinator within that region reported challenges in identifying DDNIR 

meeting topics because issues and threats throughout the region differ 

29 ODNI National Intelligence Managers and/or FBI Senior Intelligence Officers may travel to the 

quarterly meetings to provide threat briefings or relevant information. 

30 The DDNIR Rocky Mountain Region encompasses nine states and four FBI field divisions, including 

the Minneapolis Division (Minnesota, North Dakota, and South Dakota), Salt Lake City Division (Idaho, 

Montana, and Utah), Denver Division (Wyoming and Colorado), and the Albuquerque Division (New 

Mexico). In terms of geographic territory, the Salt Lake City Division, Minneapolis Division, and the 

Denver Division are the 2nd, 3rd, and 4th largest territories in the FBI, respectively, trailing only the 

Anchorage Division (Alaska), making for an immense territory within the DDNIR Rocky Mountain Region. 

33 
 

 

 

considerably.31 When her team surveyed meeting attendees for discussion 

topics, they often received no input. 

In contrast, in the much smaller Northeast Region, the DDNIR found it 

easier to collaborate and plan meetings because he was close to the other SACs 

in his region and the field divisions have similar interests. According to the 

DDNIR for the Northeast Region, it is difficult for larger regions that are more 

geographically dispersed to collaborate and find commonality on topics. 

According to officials with whom the IC IG spoke, the DNI had originally 

considered designating all heads of the 56 FBI field divisions as DDNIRs, which 

would have made the domestic program more closely resemble the overseas 

DNI representative program in which all CIA Chiefs of Station are designated as 

DNI representatives. Others with whom the team spoke, such as a former ISAIPC chair, felt the idea had merit, stating that he never understood why some 

SACs are designated as representatives and others are not. In contrast, a 

senior FBI official currently assigned to the ODNI expressed the belief that 

having 56 DDNIRs may not be practical given that there are many competing 

priorities within the FBI. 

The DHS OIG also discussed the geographical structure of the DDNIR 

program with I&A officials because Congress directed I&A to realign its field 

operations to the DDNIR Program regional construct.32 Effective November 

2014, I&A transitioned from 9 regions to the 12 DDNIR program regions. 

However, several I&A officials said they do not believe this structure makes 

sense for I&A. They expressed concern that conforming to the DDNIR regional 

construct hampered DHS’ internal Unity of Effort message and that I&A should 

have realigned with other DHS regional constructs, in particular, FEMA 

regions. FEMA regions are well-established and already known by state and 

local entities that are primary customers for I&A field officials. DHS OIG 

concluded that should the DDNIR program modify its regional structure, I&A 

would likely be required to as well, thereby further impacting I&A personnel 

and resource allocation. 

31 As part of the FBI implementation of the program, each of the 12 DDNIRs has designated an analyst 

within their office to serve as a DDNIR Program Coordinator. These Program Coordinators, who are 

typically located in the field division’s Field Intelligence Group, are responsible for the day-to-day 

operation of the program to include coordinating with the other FBI field divisions and IC elements in 

their region to develop the agendas for the quarterly meetings, arrange speakers, and conduct a variety of 

other administrative and logistical tasks associated with the program. In some regions, FBI field divisions 

have full-time positions dedicated to the program coordinator role while in others it is a corollary duty. 

The role of the DDNIRs is an additional duty and DDNIRs do not receive any additional funding or 

personnel to execute their DDNIR responsibilities. 

32 Classified Annex to the Intelligence Authorization Act for Fiscal Year 2014 (P.L. 113-126). 

34 
 

 

 

 

 

Per the MOA, the DNI and FBI may, through mutual agreement, add or 

remove ADICs or SACs as DDNIRs. While it may not be feasible to designate 

the heads of all 56 FBI field divisions as DDNIRs, in light of the current 

challenges posed by the large geographic regions, it may be feasible to 

designate some additional DDNIRs to help improve counterterrorism 

information sharing and coordination within larger existing regions. The OIGs 

recommend that the DNI, in coordination with the FBI, evaluate the existing 

DDNIR regional structure to ensure that regions are appropriately sized and 

defined to better align common areas of interest and geographic coordination 

among participating partners. 

Mission and Program Guidance – The OIGs found that the DDNIR 

program lacks in-depth guidance and a well-defined strategy for ensuring the 

program is well-understood and implemented consistently across regions. All 

DDNIRs are required to attend a four-hour orientation at the ODNI before 

assuming their DDNIR role. However, we found that some of the DDNIRs want 

more guidance and clarification on what the DNI expects them to do. 33 

The OIGs also found that the objectives of the program had not been 

clearly communicated to the IC-member representatives. According to the 

DDNIR Southeast Region’s October 2014 semi-annual report, despite 

messaging from ODNI and FBI leadership regarding the importance of the 

program, many of the participants in the region continue to express 

uncertainty as to the purpose of the DDNIR program and regional integration.34 

For example, one official who regularly attended meetings in the DDNIR 

Southeast Region stated that if the objective of the program is to “foster 

relationships,” then the program is working well; but if the goal of the program 

is to collaborate on regional issues and produce a regional product, then the 

program is not succeeding. The DDNIR Southeast Region’s October 2014 semiannual report also noted that many of the region’s partners have few or no 

analytic resources, and that for many, the analysis is conducted at the 

headquarters level. 

33 Similarly, the Congressionally directed 9/11 Review Commission found in their March 2015 report, 

“The FBI: Protecting the Homeland in the 21st Century,” that the DDNIR program is experiencing 

“growing pains,” and that, “It is not well defined by the ODNI or well understood by the ADICs and SACs 

who serve in this capacity. Some confusion stems from the question of which functions the ADIC/SAC is 

performing for the DNI as opposed to performing as part of his/her FBI responsibilities, because the 

stakeholder groups are not the same. Most ADICs/SACs understand that the Domestic DNI 

Representative role is to lead coordination, but are not clear what should be coordinated, and to what 

end. ADICs/SACs did not believe that they had adequate guidance on how to manage the Domestic DNI 

Representative responsibilities beyond their own field office’s geographic area, given that some of the 12 

regions are quite large.” 

34 Each DDNIR is required to submit to the DNI semi-annual updates on the DDNIR’s evaluations and 

recommendations of DNI policies and procedures and IC performance. 

35 
 

 

 

In reviewing the DDNIR quarterly meeting agendas and minutes, the 

DOJ OIG found that the meetings are generally maturing in structure and 

detail and that the depth of content covered has increased.35 However, in some 

regions, the DDNIR quarterly meetings were seen primarily as networking 

opportunities where various officials also were invited to give topical 

presentations. In other regions, the DDNIRs were more involved in proactively 

establishing joint working groups and sub-working groups to address areas of 

common concern within the region ranging from border security to threats 

involving the oil and gas industry and ISIL. 

At an annual meeting in May 2015, FBI Director Comey and DNI Clapper 

directed the DDNIRs to examine the Homegrown Violent Extremist (HVE) threat 

associated with ISIL in each of their regions in order to identify key intelligence 

gaps. The product was due October 31, 2015. However, specific guidance and 

project expectations were not provided to the DDNIRs until July 2015, which 

the DOJ OIG and IC IG were told resulted in significant confusion and wasted 

effort. According to an official from the ODNI’s Office of Partner Engagement, 

most of the DDNIR regions produced External Intelligence Notes, which involve 

a much longer turn-around time due to various FBI requirements. This official 

said that by the time the products were available, the information was no 

longer valid or helpful to inform the DNI and FBI Director on emerging trends. 

Although this assignment provided a good opportunity to highlight interagency 

cooperation and further maturation of the DDNIR program in order to identify 

existing ISIL challenges at the regional level, the OIGs believe that this instance 

highlights the need for the program to have explicit and timely guidance on 

specific tasks. Although the DDNIR program needs to be sufficiently flexible to 

adapt to each region’s issues and culture, clarifying guidance as to the 

intended outcomes of the meetings, as well as the roles and responsibilities of 

partners would be beneficial. Therefore, the OIGs recommend that the ODNI, 

in coordination with the FBI, develop and disseminate to IC-member partners 

more guidance and a strategy for ensuring the DDNIR program is implemented 

consistently across regions. 

In addition to the need for more guidance, the OIGs noted that the 

original MOA, signed in 2011, is outdated and no longer reflects the current 

state of the program. Moreover, the MOA does not provide guidance on the 

35 The DOJ OIG reviewed DDNIR meeting agendas and minutes for each of the DDNIR regions since the 

program’s 2012 implementation, as well as copies of the briefings and presentations conducted during 

these meetings. 

36 
 

 

inclusion of non-IC members, such as state and local entities, in the DDNIR 

Program.36 

In that regard, according to one regional representative, the DDNIRs 

should be better leveraging other partners, including fusion centers, state and 

local law enforcement, and the private sector. In his October 2014 semiannual report to the ODNI, the former DDNIR for the Central Region indicated 

that he believed that incorporating both IC and non-IC members into the 

DDNIR process would encourage greater participation and exhibit trust in 

regional partners, which builds confidence in domestic intelligence collection, 

analysis, and reporting. The DDNIR for the Central Region suggested that 

perhaps the quarterly meetings should be expanded to two days—with one day 

for federal partners to meet and a second day for the DDNIR to meet with 

fusion center personnel. Conversely, DHS officials expressed varied opinions 

on the inclusion of non-IC partners in the program. The IC IG believes that 

non-IC partners may provide valuable information and perspective regarding 

the regional threat environment and recommend that the DNI, in coordination 

with the FBI, evaluate the regional structure and issue additional guidance, 

and explore the feasibility of also incorporating non-IC members into the 

DDNIR program in an appropriate fashion. 

Recommendations: The IC IG recommends that the DNI, in coordination 

with the FBI: 

19. Evaluate the existing DDNIR regional structure, in consultation with 

I&A, to ensure that regions are appropriately sized and defined to provide 

common areas of interest and geographic coordination among 

participating partners. 

20. Develop and disseminate to IC-member partners additional guidance 

and a strategy for ensuring the DDNIR program is implemented 

consistently across regions and update the 2011 Memorandum of 

Agreement to more accurately reflect the current state of the program. 

21. Evaluate the feasibility of incorporating non-IC members into the 

DDNIR program in an appropriate fashion. 

36 The Congressionally-directed 9/11 Review Commission in their March 2015 report, “The FBI: 

Protecting the Homeland in the 21st Century,” stated that the ODNI and FBI provide policy guidance on 

how state and local law enforcement and other non-Title 50 elements in the Homeland can legally and 

appropriately intersect with the Intelligence Community via the DDNIRs. 

37 
 

The NCTC Domestic Representative Program 

NCTC’s Domestic Representative Program was established through an 

MOU with the FBI. Currently, there are NCTC Domestic Representatives 

stationed at 11 locations across the United States. These representatives serve 

as the front-line liaison for the Director of NCTC with regional IC agencies and 

counterterrorism officials at the federal, state, and local levels. NCTC Domestic 

Representatives typically sit in FBI spaces and have a wide-range of job duties. 

One of their primary responsibilities is to deliver tailored counterterrorismrelated intelligence support to a range of customers in the region, including FBI 

field divisions; regional FBI Field Intelligence Groups and JTTFs; DHS 

elements; local police; and other federal, state, and local entities. In addition, 

the NCTC representatives act as a liaison between NCTC and FBI field elements 

and between NCTC and the regional police departments by facilitating 

collaboration to enable the targeting, collection, processing, and reporting of 

targets of mutual interest. The NCTC retains primary control of the 

representatives and is responsible for covering the costs of all salary and 

official travel expenses. 

The NCTC representative program has domestic representatives in 11 

major cities across the country. Each representative is responsible for 

providing coverage to a distinct geographic region that aligns in some but not 

all of the regions covered by the 12 DDNIRs. DDNIRs and NCTC 

representatives are in the same locations, except in Pittsburgh, which has a 

DDNIR but not an NCTC representative. The geographic regions covered by the 

DDNIRs and the NCTC representatives differ in the Washington, DC, Chicago, 

Denver, and Seattle regions. 

38 
NCTC Representative Coverage – NCTC representatives frequently travel 

throughout their regions to perform their duties. Several representatives told 

the OIGs that they struggle to provide sufficient coverage for their region. For 

example, according to the NCTC representative in Los Angeles, his biggest 

challenge is the sheer number of customers he is responsible for supporting, 

which includes the FBI, DHS, fusion centers, and state and local entities 

dispersed across the three FBI field divisions (Los Angeles, Phoenix, and Las 

Vegas) that his area of responsibility encompasses. Accordingly, he must 

carefully pick and choose his engagements and make time to visit the more 

distant offices in Phoenix and Las Vegas. 

Similarly, the NCTC representative in Atlanta, whose region covers five 

states, seven FBI field divisions, and five state fusion centers, told the OIGs 

that she would like to visit the major port cities—Charleston, Savannah, and 

Mobile—and other cities in her region, such as Memphis and Raleigh more 

frequently. Even the NCTC representative in Boston, whose area of 

responsibility includes six states relatively easy to visit by car—Connecticut, 

Massachusetts, Maine, New Hampshire, Rhode Island, and Vermont—stated 

that his principal challenge was finding the time to adequately support all six 

states and not wanting to turn down opportunities when asked to provide 

support. 

In light of the regional differences between the NCTC Representative 

program and the DDNIR program, the DOJ OIG and IC OIG received feedback 

for the need for additional NCTC representatives. For instance, the DOJ OIG 

talked to the SAC in the FBI Pittsburgh Division who said that the NCTC 

representatives were an invaluable resource for their intelligence expertise and 

training and that having an NCTC representative would enhance collaboration 

in the area. The NCTC representative for New York (whose area of 

responsibility currently includes Pittsburgh) agreed that it might make sense to 

assign an NCTC representative to Pittsburgh but stated that the workload in 

Pittsburgh was lighter than in New York, and that NCTC might be better served 

by adding a representative in New York. 

According to the NCTC representative for New York, the New York area 

generates enough work for two representatives, and one representative could 

stay fully occupied solely supporting the New York JTTF. If an NCTC 

representative were to be assigned to Pittsburgh, the NCTC representative for 

New York suggested that person could assume responsibility for some of the 

area of responsibility that currently falls within the NCTC representative for 

Chicago’s region. 

Another location that we were told should receive consideration for the 

assignment of an NCTC representative is Detroit. Currently, the NCTC 

representative for Chicago also has responsibility for Detroit but has difficulty 

providing adequate coverage because the area of responsibility is so large. It 

was suggested to the IC IG that the workload might be more manageable if 

39 
 

Chicago were to have its own NCTC representative and new representatives 

were added to cover the region outside of Chicago. An NCTC representative 

told the IC IG that she has heard from USAOs and other officials in the 

Midwest that they would like to establish closer relationships with and have 

more access to NCTC representatives. 

As the OIGs conducted their fieldwork, they observed that some NCTC 

representative regions and the FBI Field divisions they support had more 

counterterrorism activity than others. For example, the NCTC representative 

for Denver explained that her region has less activity, which has impacted 

negatively her ability to obtain briefers from NCTC Headquarters to support her 

customers. Similarly, the NCTC representative for Miami estimated that she 

spends 85 to 90 percent of her time supporting the FBI Miami Division. Due to 

the FBI Miami Division’s demands for her time, the NCTC representative for 

Miami had not yet had an opportunity to visit the FBI or state and local entities 

in Jacksonville, or the primary Florida Fusion Center in Tallahassee. 

NCTC Representatives’ Reception in the Field – During field visits, the 

OIGs received positive feedback on the contributions that the NCTC 

representatives are making to the FBI field divisions (e.g., one FBI field division 

stated that it would like to obtain an additional representative) and the Fusion 

Centers with respect to their role in furthering the sharing of counterterrorism 

information. NCTC representatives attend weekly FBI JTTF meetings, as well 

as quarterly JTTF Executive Board and DDNIR meetings where they brief on 

current threats and counterterrorism products. They provide case support 

ranging from conducting name traces through NCTC’s Operations Center to 

arranging deeper dives on subjects of FBI investigations. 

In addition, NCTC representatives request and coordinate on-site 

briefings and trainings by NCTC Headquarters subject matter experts on topics 

of interest, such as the Terrorist Screening Center and the Terrorist Identities 

Datamart Environment and their capabilities. NCTC representatives are highly 

valued for their ability to send information from the FBI field divisions directly 

to NCTC leadership. 

NCTC representatives also work closely with I&A field personnel in their 

regions.37 For example, the NCTC representative for Houston stated that his 

37 I&A serves as the IC’s lead conduit to state, local, tribal, and territorial governments. According to the 

Memorandum of Understanding between the Intelligence Community, Federal Law Enforcement Agencies, 

and the Department of Homeland Security Concerning Information Sharing, no analytic conclusions of 

any covered entity shall be disseminated to state, local, or private sector officials, or to the public, without 

the prior approval of the Secretary of Homeland Security, his designee, or in accordance with approval 

mechanisms established by the Secretary except in exigent circumstances. 

40 
best set of customers are the I&A intelligence officers at the fusion centers. 

The NCTC representative for San Francisco also explained that she collaborates 

with the I&A intelligence officers at the Northern California Regional 

Intelligence Center, the State Threat Assessment Center, and Central California 

Intelligence Center to conduct joint briefings for the Fusion Center Terrorism 

Liaison Officer program. 

The majority of I&A field officials the team interviewed said that the 

NCTC representatives serve as force-multipliers and that they complement the 

I&A intelligence officers as the representatives are in similar positions as 

themselves, “armies of one” alone in areas without field offices. Many I&A field 

officials conduct joint briefings with the NCTC representatives because the 

representatives have different access and provide greater insight into IC 

processes. Overall, both I&A field officials and NCTC representatives seem to 

value these joint briefings as they present “one government voice” to state and 

locals. However, there are some within I&A who are concerned about mission 

overlap. As the NCTC representative program continues to mature, further 

clarification of its roles and responsibilities and formalized coordination with 

I&A field officials will continue to be essential to avoid any potential duplication 

of effort or conflicting lines of inquiry. 

Recommendation: The IC IG recommends that the Director, National 

Counterterrorism Center: 

22. Consider assigning additional NCTC representatives to the field 

and/or revising the existing territorial regions, potentially to align with 

the DNI domestic regions, to ensure effective NCTC representation within 

the domestic field. 

41 
 

 

Fusion Centers 

State and local entities own and operate fusion centers, but 

to develop and mature into the best partners, they depend 

on direct support and funding from federal agencies. Fusion 

centers also receive grant funding from FEMA indirectly; 

however, FEMA cannot identify how much funding fusion 

centers receive and spend on counterterrorism efforts. 

Based on self-reported data from fusion centers, direct 

federal expenditures for fusion centers are decreasing and 

state and local expenditures are increasing. Finally, the 

majority of state and local officials told DHS OIG that rather 

than enhancing and maturing their capabilities, given the 

unpredictability of resources, they are focused on sustaining 

operations. 

Federal Investment and Support to Fusion Centers 

According to the 2007 NSIS, state and major urban area fusion centers 

are vital assets to sharing terrorism-related information. Because fusion 

centers are state and locally owned and operated, federal influence to develop 

and mature fusion centers into the best potential partners depends on direct 

support and grant funding. 

In June 2011, the PM-ISE issued the Federal Resource Allocation 

Criteria (RAC) Policy, which provides objective criteria for federal agencies to 

use when making resource allocation decisions to fusion centers. According to 

the RAC Policy, federal agencies will prioritize federal resource allocation in the 

following order: primary fusion centers, recognized fusion centers, and 

nodes.38 Entities within each category must meet certain criteria for federal 

entities to continue their prioritization. 

To guide federal resource allocation, the Federal RAC Policy 

Implementation Guidance, published in September 2014, offers best practices 

and recommendations about how to better develop, implement, and adhere to 

the Federal RAC Policy. 

38 Each state, the District of Columbia, and U.S. territory may have one primary fusion center designated 

by the Governor or equivalent. A recognized fusion center is any designated fusion center, including 

major urban area fusion centers, not designated as a primary fusion center. Nodes refer to criminal 

intelligence units, real-time crime analysis centers, and other law enforcement or homeland security 

analytic centers that have not been designated as fusion centers by state governments. 

42 
I&A is required to provide the Office of Management and Budget (OMB) 

and the PM-ISE an annual inventory of all federal funding and personnel 

dedicated to the National Network of Fusion Centers. Direct federal 

expenditures are primarily salaries and benefits for federal personnel assigned 

to or directly supporting fusion centers, but also include federal information 

technology systems deployed to fusion centers, security clearances sponsored 

by federal agencies, and training and other resources specifically intended to 

help fusion centers build and sustain capabilities. The majority of fusion 

centers occupy space with other federal, state, or local agencies, resulting in 

commingled operating costs. Therefore, it is difficult to identify the total cost of 

fusion centers to the federal government because agency support serves 

multiple functions and purposes. For example, for the 14 fusion centers 

collocated with the FBI, providing access to IT systems may not be an 

additional cost to the FBI as their installation and maintenance would occur 

regardless of the presence of the fusion center. In addition, supporting a 

fusion center may be a part-time or collateral duty for DHS and DOJ 

personnel. Table 7 below provides the federal personnel support levels as 

reported to I&A for its annual inventory; Table 8 denotes whether those staff 

provided full- or part-time support to fusion centers as gathered by I&A. These 

numbers reflect a decline in total federal personnel support to fusion centers 

and of those personnel, fewer are full-time than when the reporting of such 

information began in FY 2011. 

Table 7: Federal Personnel Support to Fusion Centers, 2011-2014 

FY 

2011 

DHS Personnel 

272 

DOJ Personnel 

125 

Others 

--

Total 

397 

2012 246 124 -- 370 

2013 258 122 10 390 

2014 241 116 9 366 

Source: 2011 and 2012 Federal Cost Inventory and 2013 and 2014 National Network of 

Fusion Centers Final Reports 

Table 8: Level of Federal Personnel Supporting Fusion Centers, 2011Ǧ2014 

FY 

2011 

FullǦTime 

321 (81% of total) 

PartǦTime 

76 (19% of total) 

Total 

397 

2012 293 (79% of total) 77 (21% of total) 370 

2013 268 (69% of total) 122 (31% of total) 390 

2014 266 (73% of total) 100 (27% of total) 366 

Source: 2014 National Network of Fusion Centers Final Report 

Within its 2014 report on the National Network of Fusion Centers, I&A 

identified three significant challenges associated with collecting, validating, and 

analyzing federal investment data: 

43 
 

1. Funding to support fusion centers is generally not a budget line item for 

most federal departments and agencies, so collecting and reporting 

investment data requires significant time and effort. 

2. Some department and agency field offices directly support fusion centers 

at the field level, but the existence and extent of this support is not 

frequently shared with headquarters elements. 

3. For those departments and agencies with organizationally separate 

operations and intelligence units or functions, one unit may engage with 

fusion centers without the knowledge of the other. 

In addition to direct federal support, DHS indirectly provides grant 

funding to fusion centers through FEMA’s Homeland Security Grant Program 

(HSGP).39 However, FEMA cannot identify how much grant funding fusion 

centers receive and spend on counterterrorism efforts. Fusion centers do not 

directly receive HSGP funding but instead apply for funding and request 

reimbursements from the state. The governor-appointed State Administrative 

Agency applies for and administers HSGP funds. FEMA grant guidance simply 

requires that of the 25 percent of grant funding set aside for “law enforcement 

terrorism prevention activities,” a portion must go to fund fusion centers; state 

and local governments determine that portion from year to year. The majority 

of interviewed state and local officials involved in the process said they would 

prefer that fusion centers be a specific line item in state and local budgets or 

FEMA grant requirements. 

FEMA currently tracks grant funding through self-reported data received 

through state-submitted investment justifications and Biannual Strategy 

Implementation Reports. FEMA relies on states to appropriately and 

consistently categorize funding for all fusion center projects, but as GAO noted 

in a November 2014 report, this data is unreliable.40 GAO reported cases in 

which projects supported broader capabilities not directly related to fusion 

centers, as well as some that did not specifically support center operations. 

For example, one grantee reported $14 million given to a fusion center for 

automated license plate readers and video surveillance equipment, although 

the fusion center was one of a number of system users. 

39 Fusion centers may receive HSGP funding through HSGP’s State Homeland Security Program and 

Urban Areas Security Initiative. 

40 Government Accountability Office: Information Sharing: DHS is Assessing Fusion Center Capabilities 

and Results, but Need to More Accurately Account for Federal Funding Provided to Centers (GAO-15-155) 

(November 2014). 

44 
 

Further complicating accurate accounting is FEMA’s 3-year performance 

cycle under which fusion centers can spend up to 3 years of grant funding at 

any given time. Although the 3-year performance cycle is beneficial and 

welcomed by grant recipients, it makes it difficult to determine the portion of 

funds that has been expended each grant year. In addition, each of the 12 

states DHS OIG visited operates on different fiscal year calendars than DHS; 

only the District of Columbia follows DHS’ fiscal year calendar. 

Based on self-reported data from fusion centers during the annual 

assessment process, direct federal expenditures for fusion centers are 

decreasing and state and local expenditures are increasing. In addition to 

decreased direct federal expenditures, the total amount of FEMA HSGP funding 

available for which U.S. states and territories may apply and thus may 

distribute to fusion centers has declined since its overall peak in FY 2010 as 

shown in Figure 1 below. 

Figure 1: Total HSGP Funding Available for which States and Territories May 

Apply from FY 2009 to FY 2015 

$2,000,000,000 

$1,800,000,000 

$1,600,000,000 

$1,400,000,000 

$1,200,000,000 

$1,000,000,000 

$800,000,000 

$600,000,000 

$400,000,000 

$200,000,000 

$0 

2009 2010 2011 2012 2013 2014 2015 

Source: DHS OIG analysis of FEMA data 

45 
 

 

Although the total level of grant funding made available by FEMA has 

decreased, state and local agencies reported expending about 41 percent more 

grant funding on fusion centers in FY 2014 than in FY 2011. This is generally 

indicative of state and local governments’ commitment to fusion centers, which 

are considered valuable, worthwhile investments. As a result of this 

commitment by the state and local agencies that own and operate fusion 

centers, fusion centers are in a better position to sustain capabilities. Table 9 

below displays sources of funding to fusion centers as reported by fusion 

centers. 

Table 9: Sources of Funding to Fusion Centers, FY 2011-FY 201441 

Source FY 201142 FY 201243 FY 2013 FY 2014 

Direct Federal 

Expenditures 

Federal Grants 

Expended by State, 

Local, Territorial, 

and Tribal Agencies 

State 

Local 

Tribal45 

Territorial46 

$97,456,195 

$52,258,930 

$83,338,580 

$34,144,222 

Data not 

available 

Data not 

available 

$76,888,66244 

$71,219,656 

$90,980,473 

$63,778,109 

$0 

$57,000

$69,653,432 

$65,231,769 

$102,150,253 

$70,304,104 

$100,256 

 $153,658 

$68,216,940 

$73,499,366 

$113,297,136 

$71,519,890 

$0 

$860,307 

Private Sector Data not 

available $1,293,000 $642,770 $892,685 

TOTALS $267,197,927 $304,216,900 $308,236,242 $328,286,324 

Source: DHS OIG Analysis of DHS Data 

41 Data for FY 2015 was not available at the time of this draft report. 

42 Federal grant, State, and local expenditure data for 60 of 72 fusion centers.
 

43 Federal grant, State, local, territorial, tribal, and private sector expenditure data for the 77 fusion
 

centers designated at the time. 

44 These estimates are from the 2011 Federal Cost Inventory and reflect only costs for the 72 fusion 

centers designated at the time; Federal staff costs are estimated.
 

45 SLTT Government Fiscal Year varies and may include multiple-year grant awards. 

46 SLTT Government Fiscal Year varies and may include multiple-year grant awards. 

46 
Although increased state and local funding is a positive development, 

there are some concerns related to a decrease in federal funding. With DHS 

support decreasing, DHS may lose oversight and influence over fusion centers. 

Only fusion centers receiving FEMA grant funding must participate in DHS 

annual assessments of fusion centers. In recent years, Alaska, for instance, 

has not used FEMA grants to fund its fusion center and has declined to 

participate in the annual assessment process. Although DHS officials have 

worked with Alaska to ensure its participation in the assessment process for 

the time being, without a link to grant funding, DHS lacks enforcement 

capability. 

In addition, fusion centers utilizing FEMA grant funds must meet I&A 

requirements, such as conducting exercises and addressing resulting corrective 

actions, developing privacy policies, and completing annual training. These 

requirements establish standards for the national network and hold fusion 

centers more accountable to the public. Although all 78 fusion centers have 

complied with the requirement examples above aimed at the development and 

maturation of the national network, fusion centers losing or choosing not to 

accept FEMA grant funding may cut some of these important programs and 

activities to cover other mission-essential areas. Further, one fusion center 

director said, “if DHS has no skin in the game, the state and locals will not give 

them anything.” Fusion centers must balance the sometimes conflicting 

priorities of state and local partners providing more funding with those of the 

federal government. 

National Network Maturity Model 

DHS and DOJ worked together to establish fusion center guidelines for 

developing and operating a fusion center within a state or region. Additionally, 

they worked with fusion center leadership to outline four Critical Operational 

Capabilities (COC), which reflect the operational priorities of the National 

Network of Fusion Centers, and four Enabling Capabilities (EC), which provide 

a programmatic foundation for the fusion process. I&A is responsible for the 

annual fusion center assessments, which began in 2011, to measure individual 

fusion center compliance with the guidelines and achievement of the COCs and 

ECs. 

47 
In its last annual assessment in FY 2014, I&A determined the National 

Network of Fusion Centers had reached the “Emerging Stage” on the National 

Network Maturity Model, as shown in Figure 2. The Maturity Model is a 

multistage framework designed to evaluate and categorize the overall progress 

of the national network as a whole in achieving the COCs and ECs. The 

Maturity Model consists of 46 attributes aligned to the four distinct stages. For 

each stage, the community established an outcome-oriented, qualitative 

definition and aligned capability attributes based on each attribute’s 

contribution to the defined outcome for that stage. The National Network 

advances through each of the four stages of the maturity model when 75 

percent of fusion centers achieve all of the attributes associated with that level. 

Figure 2: National Network Maturity Model 

Source: 2014 National Network of Fusion Centers Final Report 

48 
 

 

At the Fundamental Stage, fusion centers across the National Network 

have approved plans, policies, or standard operating procedures for each of the 

four COCs and EC 1 (Privacy, Civil Rights, and Civil Liberties Protections). At 

the Emerging Stage, the National Network has the systems, mechanisms, and 

processes needed to implement the plans, policies, or standard operating 

procedures and the COCs and ECs as a whole. At the Enhanced Stage, the 

National Network has the operational capability to produce products and 

provide services to federal, state, and local customers. Finally, at the Mature 

Stage, the National Network has the full capability to leverage the collective 

resources among individual fusion centers and adjust to both the changing 

threat environment and evolving requirements. Based on this model, the 

National Network is currently halfway through the stages to achieve maturity. 

However, the majority of state and local officials DHS OIG interviewed said 

given the unpredictability of resources allocated, fusion centers are focused on 

sustaining rather than enhancing operations and capabilities.47 

Need to Coordinate Granting of Security Clearances 

Access to classified information, systems, and facilities is vital for the 

domestic sharing of counterterrorism information. State and local analysts at 

fusion centers require security clearances to receive classified information, and 

these clearances may be granted by multiple federal agencies, including DHS 

and the FBI. By Executive Order, all clearances granted to state and local 

personnel by one agency are to be accepted reciprocally by other agencies.48 

However, DHS’ and the FBI’s various and sometimes differing requirements for 

obtaining clearances and accessing classified information can complicate this 

reciprocity. Without full coordination, these various requirements may lead to 

duplication of effort in conducting background investigations or gaps in 

information sharing due to the inability to access classified areas and attend 

meetings. Currently, there are no formal agreements among the federal 

partners on state and local security clearance reciprocity; such agreements 

might mitigate the effects of varying requirements and improve information 

sharing. 

For example, DHS OIG and DOJ OIG identified one instance at the New 

York State Intelligence Center (where some fusion center analysts are co47 Fusion centers categorize expenditures in five major areas: staff; information systems and technology; 

management and administration; training, technical assistance and exercise; and programmatic. In 

recent years, the greatest expenditure has been staff, an average of about 83 percent of total fusion center 

expenditures. 

48 Executive Order 13549 of August 18, 2010, Classified National Security Information Program for 

State, Local, Tribal, and Private Sector Entities. 

49 
 

 

located with FBI personnel and systems) in which state and local 

representatives had difficulty accessing the FBI’s “open storage areas.” 

Specifically, in January 2015, the FBI revised its security policy to require 

Single Scope Background Investigations (SSBI) and Top Secret clearances for 

individuals to have unescorted access to the FBI’s open storage areas. As a 

result, fusion center personnel with Secret clearances granted by DHS had to 

be escorted into the FBI areas. After reviewing the situation, to meet 

information sharing and MOU requirements, the FBI agreed to waive the SSBI 

requirement for the New York State Intelligence Center. 

Recommendation: DHS OIG recommends that DHS: 

23. Coordinate with the ODNI and FBI to develop and implement a 

strategy to efficiently and effectively provide security clearances and 

reciprocity to state and local personnel. 

National Mission Cell Initiative 

The National Mission Cell (NMC) concept was designed to help fusion 

centers fulfill their mission to support counterterrorism threat analysis and 

information sharing by standardizing and formalizing the processes for 

information collection, production, and dissemination. Personnel from the 

National Fusion Center Association, PM-ISE, DHS, and the FBI devised an 

NMC pilot program for four fusion centers, which ran from January 2014 

through July 2015. NMCs were intended to be small standardized cells of 

intelligence analysts within a fusion center, consisting of a limited number of 

existing personnel from DHS, the FBI, and state and local partners. The 

entities involved in conceptualizing the NMC believed the concept would 

advance federal counterterrorism efforts; enhance information sharing; 

advance fusion centers’ intelligence capabilities and accelerate their maturity; 

and increase integration, interaction, coordination, and intelligence sharing 

within the fusion centers and with other partners. 

According to the FBI, it had witnessed significant maturation of the 

National Network of Fusion Centers with increased coordination, cooperation, 

and information sharing between FBI field offices and the fusion centers. At 

the same time, the threat from ISIL-inspired individuals and homegrown 

violent extremists had increased significantly. To address the threat, the FBI 

plans to enhance FBI field office engagement with fusion centers. I&A intends 

to remain fully engaged with and continue support to fusion centers. A new 

pilot phase will be conducted in six fusion centers, and the partner agencies 

will leverage their respective authorities and existing resources. 

50 
Conclusion 

Ensuring the United States is well-prepared to counter the threat of 

terrorism requires efficient and effective information sharing. The OIGs found 

that components of the ODNI, DHS, and DOJ are committed to sharing 

counterterrorism information. However, we also believe that the components 

can more fully commit to and improve their practices in this arena. The 

numerous partners involved in this vital endeavor must fully understand each 

other’s missions and have clearly defined roles and responsibilities at the 

federal, state, and local level. Further, partners need to implement strong 

overall governance at the national level to ensure their field representatives 

fully embrace their roles according to the national strategy. Representatives in 

the field need to actively participate in information sharing forums, have access 

to information, and work in concert to leverage their resources and expertise 

and to expand their knowledge of national security threats. These 

improvements are paramount to national security partners effectively 

cooperating with each other to mitigate gaps and overlaps in sharing 

information, which is crucial to the United States’ ability to prevent terrorist 

attacks. 

51 
APPENDIX A: OBJECTIVES, SCOPE & METHODOLOGY 

The Senate Select Committee on Intelligence, the Senate Homeland 

Security and Governmental Affairs Committee, and the Senate Judiciary 

Committee requested that the Inspectors General (IG) of the Intelligence 

Community (IC), Department of Homeland Security (DHS), and Department of 

Justice (DOJ) conduct a performance audit of federally supported entities 

engaged in field-based domestic counterterrorism, homeland security, 

intelligence, and information-sharing activities in conjunction with state and 

local law enforcement agencies. The oversight committees requested that the 

joint audit examine the entities’ overall missions, specific functions, 

capabilities, funding, personnel costs to include full-time employees and 

contractors, and facility costs. 

In response to this request, the OIGs for the IC, DHS, and DOJ 

conducted a coordinated, joint review focusing on domestic sharing of 

counterterrorism information. The objectives of this review were to: (1) identify 

and examine the federally supported field-based intelligence entities engaged in 

counterterrorism information-sharing to determine the overall missions, 

specific functions, capabilities, funding, and personnel and facility costs; (2) 

determine if counterterrorism information is being adequately and 

appropriately shared with all participating agencies; and (3) identify any gaps 

or duplication of effort among these entities. 

The review was conducted by three teams from the OIGs of the IC, DHS, 

and DOJ. The OIGs reviewed previous studies and conducted interviews with 

more than 450 individuals, including senior Office of the Director of National 

Intelligence (ODNI), DHS, DOJ, and state and local officials. While the review 

teams shared relevant documents, attended briefings, and participated jointly 

in interviews of certain officials and subject matter experts, each OIG was 

responsible for evaluating the actions of, and information available to, its 

respective department or agency. The teams attended, at least in part, 

meetings of the DNI’s Homeland Security and Law Enforcement Partners’ 

Board, interviews with DNI representatives and members of multiple JTTFs, 

and a teleconference with the Criminal Intelligence Coordinating Council 

(CCIC). 

52 
In total, the teams visited field-based domestic information sharing 

entities in 25 cities in 13 states and the District of Columbia: 

x Massachusetts: Boston, Maynard 

x California: Sacramento, Los Angeles, San Francisco 

x Illinois: Chicago, Springfield 

x Colorado: Denver 

x Texas: Dallas, Houston, Garland, McKinney 

x Missouri: Kansas City, Jefferson City, St. Louis 

x New Hampshire: Concord 

x Virginia: Fairfax 

x New York: Albany, New York City 

x New Jersey: Trenton 

x Oregon: Salem, Portland 

x Rhode Island: Providence 

x Washington, DC 

x Washington: Seattle 

Of those reviews, all three teams travelled together to five cities: Denver, 

Colorado; Dallas, Houston, and Garland Texas; and New York, New York. Over 

70 meetings were conducted by at least two of the OIGs. 

The OIGs conducted their work in accordance with the Council of 

Inspectors General on Integrity and Efficiency’s 2012 Quality Standards for 

Inspection and Evaluation. Those standards require an OIG plan and perform 

its work to obtain sufficient and appropriate evidence, provide reasonable 

bases for the findings, and put forth conclusions based on stated objectives. 

The evidence obtained in this review provides a reasonable basis for the 

findings and conclusions based on the objectives. 

53 
APPENDIX B: RECOMMENDATIONS 

This appendix lists the report recommendations. 

Recommendations: The IC IG and DHS and DOJ OIGs recommend that the 

ODNI, DHS, and DOJ: 

1. Review the 2003 interagency MOU on information sharing and 

determine what actions are necessary to update intelligence information 

sharing standards and processes among the departments. 

Joint OIG Analysis and Summary of Actions to Close Recommendation 1 

Open. DHS and DOJ concurred with the recommendation as shown in 

Appendices D and E. ODNI provided comments on the recommendation 

as shown in Appendix C. The joint OIG team will continue to collaborate 

and monitor the actions of the components throughout the resolution 

phase to ensure each relevant component has taken the necessary steps 

to adequately address the recommendation. 

2. Codify an overarching engagement and coordination body for the 

terrorism-related ISE. 

Joint OIG Analysis and Summary of Actions to Close Recommendation 2 

Open. DHS and DOJ concurred with the recommendation as shown in 

Appendices D and E. ODNI provided comments on the recommendation 

as shown in Appendix C. The joint OIG team will continue to collaborate 

and monitor the actions of the components throughout the resolution 

phase to ensure each relevant component has taken the necessary steps 

to adequately address the recommendation. 

54 
Recommendations: DHS OIG recommends that I&A: 

3. In conjunction with the key intelligence officials from DHS 

components, ensure DHS component intelligence programs comply with 

policies and create incentives for personnel to participate in initiatives 

that enhance the cohesion of the DHS Intelligence Enterprise. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 3 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

that the DHS’ Chief Intelligence Office (CINT) has implemented changes 

that will better integrate the DHS Intelligence Enterprise. 

4. Formalize agreements that enable I&A field officials to develop 

intelligence reporting with DHS components in the field, based on pilot 

program results. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 4 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives 

evidence, once finalized, of DHS’ instruction for the process by which I&A 

reports officers will work with DHS Intelligence Enterprise field elements 

to produce Intelligence Information Reports at the local level. 

Recommendations: DHS OIG recommends that I&A: 

5. Develop and implement guidance for intelligence reporting in the field. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 5 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

of the finalized guidance for intelligence reporting in the field and 

documented implementation of such guidance. 

55 
6. Coordinate with the FBI to formalize guidance and policies for the 

reporting of terrorism and counterterrorism information. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 6 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

of formal, written guidance, developed in coordination with the FBI, on 

the reporting of terrorism and counterterrorism information. 

Recommendation: DHS OIG recommends that the DHS clearing offices: 

7. Develop and implement a formal mechanism for reviewing I&A 

intelligence reporting from the field, including a logging and tracking 

process. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 7 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

that the clearing offices – Privacy Office, Civil Rights and Civil Liberties 

(CRCL), Office of the General Counsel-Intelligence Law Division, and I&A 

Intelligence Oversight – are using this SharePoint tracking tool to 

document each office’s review of I&A field intelligence reporting. 

Recommendation: DHS OIG recommends that I&A: 

8. Develop and implement guidance for field officials granting them local 

release authority for intelligence reporting. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 8 

Open. DHS I&A concurred with the recommendation as shown in 

Appendix D. This recommendation can be closed when DHS OIG 

receives evidence of the final establishment and implementation of a field 

release capability. 

56 
Recommendation: DHS OIG recommends that DHS: 

9. Develop and implement a plan that will allow DHS intelligence 

officials in the field practical access to classified systems and 

infrastructure above the Secret level. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 9 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

of the development and implementation of plans to ensure DHS 

intelligence officials in the field have practical access to classified 

systems and infrastructure above the Secret level. 

Recommendations: DOJ OIG recommends that DOJ: 

10. Develop a comprehensive internal counterterrorism information 

sharing strategic plan based on a review of the President’s strategic plan 

and in consultation with relevant partners. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 10 

Open. DOJ concurred with the recommendation as shown in Appendix 

E. This recommendation can be closed when the DOJ OIG receives, once 

established, the comprehensive internal DOJ counterterrorism 

information sharing strategic plan. 

11. Implement a council, led by a senior Department official, for the 

internal coordination of DOJ information sharing strategy and 

investments, and ensure that relevant components designate senior-level 

officials responsible for monitoring their component’s efforts and 

communicating their efforts to DOJ as requested. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 11 

Open. DOJ concurred with the recommendation as shown in Appendix 

E. This recommendation can be closed when the DOJ OIG receives 

documentation that it implemented a council, led by a senior DOJ 

official, that is responsible for the internal coordination of DOJ 

information sharing strategy and investments. Further, DOJ OIG will 

need to receive evidence that each relevant component has designated 

senior-level officials who are responsible for monitoring their 

component’s efforts and communicating their efforts to DOJ leadership 

as requested. 

57 
Recommendations: DOJ OIG recommends that the FBI: 

12. Require FBI field divisions to stress to participating agencies the 

importance of designating an individual and an alternate to serve as their 

representatives to the JTTF Executive Board, as well as of regularly 

attending the meetings. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 12 

Open. The FBI concurred with the recommendation as shown in 

Appendix F. This recommendation can be closed when the DOJ OIG 

receives evidence that the FBI notified its field divisions to stress to JTTF 

participants the importance of designating representatives to the JTTF 

Executive Board, as well as regularly attending meetings. Further, the 

DOJ OIG will need evidence that FBI field divisions, in turn, 

communicated to the participating agencies the importance of the JTTF 

Executive Board meetings, including designating representatives and 

regularly attending. 

13. Ensure FBI field divisions encourage agencies that do not participate 

on the JTTF, including first responders, to attend JTTF Executive Board 

Meetings. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 13 

Open. The FBI concurred with the recommendation as shown in 

Appendix F. This recommendation can be closed when the DOJ OIG 

receives evidence that the FBI instructed its field divisions to encourage 

agencies that do not participate on the JTTF, including first responders, 

to attend JTTF Executive Board meetings. Further, DOJ OIG will need 

evidence that the FBI field divisions, in turn, reached out to such 

agencies to encourage participation on the JTTF Executive Board. 

58 
14. Identify an appropriate structure and content of JTTF Executive 

Board meetings that FBI field divisions should use at a minimum when 

conducting these meetings. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 14 

Open. The FBI concurred with the recommendation as shown in 

Appendix F. This recommendation can be closed when the DOJ OIG 

receives evidence of the FBI’s review and establishment of an appropriate 

structure and content of JTTF Executive Board meetings, and that FBI 

field divisions have been notified of the new structure and content. 

Recommendation: DOJ OIG recommends that DOJ: 

15. Ensure that each USAO updates its ATAC Plan as required by the 

program. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 15 

Open. DOJ concurred with the recommendation as shown in Appendix 

E. This recommendation can be closed when the DOJ OIG receives 

evidence that DOJ has developed a mechanism for ensuring USAOs 

update their ATAC Plans as required by the program. 

16. Evaluate the ATAC program to ensure the purpose of the ATAC 

meetings is not duplicative of other counterterrorism information sharing 

partner initiatives and is used in the most effective manner. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 16 

Open. DOJ concurred with the recommendation as shown in Appendix 

E. This recommendation can be closed when the DOJ OIG receives the 

results of DOJ’s evaluation of the ATAC program and whether the 

purpose of the ATAC meetings are not duplicative of other 

counterterrorism information sharing partner initiatives and are used in 

the most effective matter. 

59 
Recommendations: DOJ OIG recommends that FBI: 

17. Direct FBI field divisions to identify and invite key stakeholders to 

TRP sessions. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 17 

Open. The FBI concurred with the recommendation as shown in 

Appendix F. This recommendation can be closed when the DOJ OIG 

receives the FBI’s guidance to FBI field divisions about identifying and 

inviting key stakeholders to TRP sessions. Further, the DOJ OIG will 

need evidence that FBI field divisions, in turn, identified and invited key 

stakeholders to attend the TRP sessions. 

18. Determine the agencies with which it should share its 

counterterrorism-related TRP results and implement a process to ensure 

the TRP results are appropriately shared with those agencies on a 

systemic and regular basis. 

DOJ OIG Analysis and Summary of Actions to Close Recommendation 18 

Open. The FBI concurred with the recommendation as shown in 

Appendix F. This recommendation can be closed when the DOJ OIG 

receives evidence of the agencies with which the FBI should share 

counterterrorism-related TRP results and of the process for ensuring the 

TRP results are shared with these agencies on a systemic and regular 

basis. Further, the DOJ OIG will need evidence that FBI field divisions 

have been notified of this process, and that FBI field divisions are 

sharing the TRP results with the identified agencies on a regular basis. 

60 
Recommendations: The IC IG recommends that the DNI, in coordination with 

the FBI: 

19. Evaluate the existing DDNIR regional structure, in consultation with 

I&A, to ensure that regions are appropriately sized and defined to provide 

common areas of interest and geographic coordination among 

participating partners. 

IC IG Analysis and Summary of Actions to Close Recommendation 19 

Open. ODNI provided comments on the recommendation as shown in 

Appendix C. This recommendation can be closed when the IC IG receives 

an update on the status of their activity to meet the intent of the 

recommendation. 

20. Develop and disseminate to IC-member partners additional guidance 

and a strategy for ensuring the DDNIR program is implemented 

consistently across regions and update the 2011 Memorandum of 

Agreement to more accurately reflect the current state of the program. 

IC IG Analysis and Summary of Actions to Close Recommendation 20 

Open. ODNI provided comments on the recommendation as shown in 

Appendix C. This recommendation can be closed when the IC IG receives 

an update on the status of their activity to meet the intent of the 

recommendation. 

21. Evaluate the feasibility of incorporating non-IC members into the 

DDNIR program in an appropriate fashion. 

IC IG Analysis and Summary of Actions to Close Recommendation 21 

Open. ODNI provided comments on the recommendation as shown in 

Appendix C. This recommendation can be closed when the IC IG receives 

an update on the status of their activity to meet the intent of the 

recommendation. 

61 
 

Recommendation: The IC IG recommends that the Director, National 

Counterterrorism Center: 

22. Consider assigning additional NCTC representatives to the field 

and/or revising the existing territorial regions, potentially to align with 

the DNI domestic regions, to ensure effective NCTC representation within 

the domestic field. 

IC IG Analysis and Summary of Actions to Close Recommendation 22 

Open. ODNI provided comments on the recommendation as shown in 

Appendix C. This recommendation can be closed when the IC IG receives 

an update on the status of their activity to meet the intent of the 

recommendation. 

Recommendation: DHS OIG recommends that DHS: 

23. Coordinate with the ODNI and FBI to develop and implement a 

strategy to efficiently and effectively provide security clearances and 

reciprocity to state and local personnel. 

DHS OIG Analysis and Summary of Actions to Close Recommendation 24 

Open. DHS concurred with the recommendation as shown in Appendix 

D. This recommendation can be closed when DHS OIG receives evidence 

that a strategy has been developed and implemented to efficiently and 

effectively provide security clearances and reciprocity to state and local 

personnel. 

62 
 

APPENDIX C: THE OFFICE OF THE DIRECTOR OF NATIONAL
 

INTELLIGENCE’S RESPONSE TO THE DRAFT REPORT
 

63 
UNCLASSIFIED 

SUBJECT: Office of the Director of National Intelligence Respoase to rhe Inspector 

General's Re,;ew of Domestic Sharing of Co1L11terrerro1;sm Information 

In June 2016, the Director of National Intelligence (DNI), in consultation with the Executive 

Office of the President, decided to integrate the Program Manager for the Information Sharing 

Environment (PM-ISE) under the authority and direction of the Office of the Assistant DNI for 

Partner Engagement (ADNllPE). This decision reflects the DNI's ongoing conu11itment to 

ensure our Nation and the Intelligence Collllllunity (IC) can maximize intelligence integration 

and government-wide information safeguarding and sharing ii: the most efficient and effective 

manner possible. The fusion of PM-ISE and PE will further strengthen, empower, and unify 

whole-of-government safeguarding and sharing of terrorism-related infomiation across federal, 

state, local, tribal, territorial (FSLTT), private sector, and inteniational mission partners. 

While the Federal Government has made significant progress to advance terrorism-related 

safeguarding and sharing of intelligence and inforniation, more work remains to ensure 

implementation of the best mechanisms to protect the homeland. The evolving terrorist threat 

highlights the critical need for strong partnerships and interoperable, and coordinated capabilities 

between and among FSLTT agencies. These partnerships enable appropriate information 

safeguarding and sharing and build trust, consistent \\~th the missions and authorities of each 

age.ncy and fully integrating the need to protec.t privacy, civil rights, and civil liberties. 

It is important to emphasize the need for the IC's role inside the U.S. to be carefully constrained. 

The IC's authorities, tools, and tradecraft are properly focused on foreign threats to national 

security. While we must also look to their manifestations inside the country, we must carefully 

reniain within the bounds of the limited domestic authorities and the defmed roles entmsted to 

us. It is imperative that we continue to strengthen the national security apparatus to best protect 

our citizens while also protecting their privacy, civil rights, and civil liberties. 

This response incorporates integrated respon<;es from both IC and ISE authorities articulated in 

the Intelligence Refom1 and Terrorism Prevention Act of 2004, as amended (IRTP A). 

Recommenclation l: Review the 2003 interagency MentorandtUll of Understanding (MOU) on 

information sharing and determine what actions are necessary to update intelligence infomiation 

sharing standards and processes among the depart111ents. 

OD;'ll! Response: A recent review by DHS in coordination v.ith the ODNI concluded that the 

lllformauon sbarmg proVlS!ons of the MUU are overtaken by t:xecullve Urder and the 

IRTPA. The ODNI, in coordination with IC elentents, and as a member of the Information 

Sharing Council, maintains ongoing discussions with ISE stakeholders to ensure domestic 

sharing of cotmterterrorism information is executed in an e.ffe.:tive and responsible manner. 

UNCLASSIFI ED 

64 
UNCLASSIFI ED 

Recommenclation 2: Codify an overarching engagement and coordination body for terroriSlllrelated ISE. 

ODNI Response: Tue Information Sharing Council is the body codified within IRTP A for the 

terrorism related ISE. 

Recommenclation 19: Evahiate the existing Domestic DNI Representative (DDNIR) regional 

structure, in consultation with the Office of Intelligence and Analysis (I&A), to ensure that 

regions are appropriately sized and defined to provide common areas of interest and geographic 

coordination among participating partnets. 

ODNI Response: ODNI, in consul.talion with the Federal Bureau of Investigation (FBI), 

believes the existing 12 regions are appropriately sized to meet the roles and responsibilities of 

the DDNIR program. The current structure allows for effective connmmication and coordination 

among IC organizations represented in the respective regions. A reduction in the mnnber of 

regions could undermine effective conununications and coordination because regionally assigned 

DDNIRs would see a corresponding increase in the utnuber of IC regional offices (to inchide 

FBI Field Offices) in their regions. Conversely, increasing the nwnber ofDDNIR regions could 

lead to duplicative IC collaboration and increase travel costs. 

Recommenclation 20: Develop and disseminate to IC-member partners additional guidance and 

a strategy for ensuring the DDNIR program is in1plemented consistently across regions and 

update the 2011 Men1orandum of Agreement to more accurately reflect the current state of the 

prograni. 

ODNI Response: Tue IC, integrated through the Homeland Strategy Board, bas already begun 

to address these and other identified needs. The Homeland Strategy Board bas adopted a number 

of initiatives focused on imp o~ing 1he discoverability of intelligence and the transparency of 

activities across the Homeland domains, as well as working to enhance intelligence integration 

between the IC enterprise and regional levels. Strategic guidance and direction will continue 

through e.xisting mechanisms to ensure IC equities are all addressed. Tue 2011 Men1orandum of 

Agreen1ent will be reviewed and revised as appropriate to ensure that it reflects existing strategic 

IC coordination; better defines the roles and mission~ of all partners involved in the DDNIR 

program; and is updated to capture recent changes \\~thin the ODNI and FBI. 

Recommendation 21: Evaluate the feasibility of incorporating non-IC members into the 

DDNIR progran1 in an appropriate fusbion. 

OD'.'11 Response: Tue ODNI. FBI, and IC partners believe the DDNIR program is first and 

foremost a National Intelligence, Title 50, responsibility focused on effectively dealing with 

Foreign Intelligence priorities that might pose threats to the Homeland and/or those foreign and 

foreign-inspired threats that have a direct nexus to the Hon1eland. Some DDNIR regions have 

informally included uou-IC members in qt13rterly meetings and working groups and found that 

their participation provides valuable information and perspectives regarding the regional threat 

enviromneut. ODNI and FBI will consult with IC and FSLTT partners to consider the merits of 

appropriately formalizing this approach across the DDNIR program. Successes have been 

2 

UNCLASSIFI ED 

65 
 

66 
APPENDIX D: THE DEPARTMENT OF HOMELAND SECURITY’S 

RESPONSE TO THE DRAFT REPORT
 

67 
68 
69 
70 
71 
72 
73 
74 
75 
76 
 

APPENDIX E: THE DEPARTMENT OF JUSTICE’S RESPONSE TO THE 

DRAFT REPORT49 

49 Subsequent to DOJ’s formal response, the language for recommendation #2 was revised as reflected in 

the body of the report. DOJ OIG discussed the revised language with DOJ. DOJ stated that it concurred 

with the revised recommendation and did not submit a new formal response. 

77 
78 
Memorandum to Michael E. Horowitz Page 3 

Subject: Response: Joint Review of Domestic Sharing 

of Counterterrorism Information 

Recommendation No. 15: The DOJ OIG recommends that DOJ: (U) Ensure that each USAO 

updates its ATAC Plan as required by the ATAC program. 

Response: Concur. As part of its evaluation of the AT AC program, DOJ will assess 

how frequently plans should be updated in the future and will ensure that AT AC plans 

are modified accordingly. 

Recommendation No. 16: The DOJ OIG recommends that DOJ: (UllFOUO) Evaluate the 

ATAC program to ensure the purpose of the ATAC meetings are not duplicative of other 

counterterrorism information sharing partner initiatives and are used in the most effective 

manner. 

Response: Concur. DOJ will evaluate the ATAC program to ensure the purpose of the 

ATAC meetings are not duplicative of other counterterrorism information sharing partner 

initiatives and are used in the most effective manner. 

cc: Andrew McCabe, Deputy Director, Federal Bureau oflnvestigation 

Lee Lofthus, Assistant Attorney General, Justice Management Division 

79 
APPENDIX F: THE FEDERAL BUREAU OF INVESTIGATION’S 

RESPONSE TO THE DRAFT REPORT
 

80 
81