TERRORIST 

WATCHLIST

Routinely Assessing 

Impacts of Agency 

Actions since the 

December 25, 2009, 

Attempted Attack 

Could Help Inform 

Future Efforts

Report to Congressional Requesters

May 2012

GAO-12-476

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-476, a report to 

congressional requesters 

May 2012 

TERRORIST WATCHLIST

Routinely Assessing Impacts of Agency Actions since 

the December 25, 2009, Attempted Attack Could 

Help Inform Future Efforts

Why GAO Did This Study

The December 25, 2009, attempted 

bombing of Northwest Flight 253 

exposed weaknesses in how the 

federal government nominated 

individuals to the terrorist watchlist and 

gaps in how agencies used the list to 

screen individuals to determine if they 

posed a security threat. In response, 

the President tasked agencies to take 

corrective actions. GAO was asked to 

assess (1) government actions since 

the incident to strengthen the 

nominations process, (2) how the 

composition of the watchlist has 

changed based on these actions, and 

(3) how agencies are addressing gaps 

in screening processes. GAO analyzed 

government reports, the guidance used 

by agencies to nominate individuals to 

the watchlist, data on the volumes of 

nominations from January 2009 

through May 2011, the composition of 

the list, and the outcomes of screening 

agency programs. GAO also 

interviewed officials from intelligence, 

law enforcement, and screening 

agencies to discuss changes to 

policies, guidance, and processes and 

related impacts on agency operations 

and the traveling public, among other 

things. This report is a public version of 

the classified report that GAO issued in 

December 2011 and omits certain 

information, such as details on the 

nominations guidance and the specific 

outcomes of screening processes.

What GAO Recommends

GAO recommends that the Assistant to 

the President for Homeland Security 

and Counterterrorism ensure that the 

outcomes and impacts of agencies’ 

actions to strengthen nominations and 

screening processes are routinely 

assessed. Technical comments were 

provided and incorporated.

What GAO Found

In July 2010, the federal government finalized guidance to address weaknesses 

in the watchlist nominations process that were exposed by the December 2009 

attempted attack and to clarify how agencies are to nominate individuals to the 

watchlist. The nominating agencies GAO contacted expressed concerns about 

the increasing volumes of information and related challenges in processing this 

information. Nevertheless, nominating agencies are sending more information for 

inclusion in the terrorist watchlist after the attempted attack than before the 

attempted attack. Agencies are also pursuing staffing, technology, and other 

solutions to address challenges in processing the volumes of information. In 

2011, an interagency policy committee began an initiative to assess the initial 

impacts the guidance has had on nominating agencies, but did not provide 

details on whether such assessments would be routinely conducted in the future. 

Routine assessments could help the government determine the extent to which 

impacts are acceptable and manageable from a policy perspective and inform 

future efforts to strengthen the nominations process.

After the attempted attack, federal agencies took steps to reassess the threat 

posed by certain individuals already identified in government databases and 

either add them to the watchlist or change their watchlist status, which included 

adding individuals to the watchlist’s aviation-related subset lists. For example, the 

number of U.S. persons (U.S. citizens and lawful permanent residents) on the 

subset No Fly List the government uses to deny individuals the boarding of 

aircraft more than doubled after the attempted attack.

Screening agencies are addressing gaps in processes that were exposed by the 

attempted attack. For example, based on the growth of lists used to screen 

aviation passengers and continued implementation of Secure Flight—which 

enabled the Transportation Security Administration to assume direct 

responsibility for conducting watchlist screening from air carriers—more 

individuals have been denied boarding aircraft or subjected to additional physical 

screening before boarding. Secure Flight has also reduced the likelihood of 

passengers being misidentified as being on the watchlist and has allowed 

agencies to use a broader set of watchlist records during screening. U.S. 

Customs and Border Protection has built upon its practice of evaluating 

individuals before they board flights to the United States, resulting in hundreds 

more non-U.S. persons on the watchlist being kept off flights because the agency 

determined they would likely be deemed inadmissible upon arrival at a U.S. 

airport. The Department of State revoked hundreds of visas shortly after the 

attempted attack because it determined that the individuals could present an 

immediate threat to the United States. These actions are intended to enhance 

homeland security, but have also impacted agency resources and the traveling

public. An interagency policy committee is also assessing the outcomes and 

impacts of these actions, but it did not provide details on this effort. Routine 

assessments could help decision makers and Congress determine if the watchlist 

is achieving its intended outcomes and help information future efforts. View GAO-12-476. For more information, 

contact Eileen Larence at (202) 512-6510 or 

larenceej@gao.gov. 
Page i GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Letter 1 

Background 6

2010 Guidance Addresses Weaknesses in Nominations Process, but 

Agencies Face Challenges in Managing Increased Volumes of 

Information 10

The Number of Individuals on the Watchlist and Aviation-Related 

Subsets Increased after the Attempted Attack 14

Screening Agencies Are Addressing Vulnerabilities Exposed by the 

Attempted Attack, but Assessing Their Impacts Could Help 

Inform Future Efforts 15

Conclusions 27

Recommendations for Executive Action 29

Agency Comments 29

Appendix I Objectives, Scope, and Methodology 32

Appendix II Overview of the Watchlist Nominations Process 36

Appendix III Transportation Security Administration’s Secure Flight Program and 

Related Activities 41

Appendix IV Information on Redress Process for Individuals Experiencing 

Difficulties during Travel-Related Screening and 45

Appendix V GAO Contact and Staff Acknowledgments 47

Figures

Figure 1: Summary of Information on Mr. Abdulmutallab Contained 

in U.S. Government Holdings before the December 2009 

Attempted Attack 9

Figure 2: Overview of the Watchlist Nominations Process 39

Contents
Page ii GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Abbreviations

CBP U.S. Customs and Border Protection

CIA Central Intelligence Agency

DHS Department of Homeland Security

FBI Federal Bureau of Investigation

NCTC National Counterterrorism Center

State U.S. Department of State

TIDE Terrorist Identities Datamart Environment

TRIP Traveler Redress Inquiry Program

TSA Transportation Security Administration

TSC Terrorist Screening Center

TSDB Terrorist Screening Database

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

United States Government Accountability Office 

Washington, DC 20548

May 31, 2012

Congressional Requesters

The attempt on December 25, 2009, to detonate a concealed explosive 

on board a U.S.-bound aircraft raised questions as to why warnings about 

the attempted bomber did not result in the U.S. government including him 

on its consolidated terrorist watchlist. The Terrorist Screening Center 

(TSC)—administered by the Federal Bureau of Investigation (FBI)—is 

responsible for maintaining this list of known or suspected terrorists and 

making records from the watchlist database available as appropriate to 

agencies that screen individuals for possible threats. For instance, 

subsets of the watchlist are used by the Transportation Security 

Administration (TSA) to screen individuals before they board an aircraft, 

by U.S. Customs and Border Protection (CBP) to inspect or vet 

individuals traveling to and from the United States, and by the 

Department of State (State) to screen visa applicants.

The Executive Office of the President’s review of the attempted attack 

found that the U.S. government had sufficient information to have 

uncovered and potentially disrupted the attack, but shortcomings in the 

watchlisting process prevented the attempted bomber—Umar Farouk 

Abdulmutallab—from being nominated for inclusion on the watchlist.1

Thus, screening agencies that could have identified him as a potential 

threat were unable to identify him and take action. The Executive Office of 

the President tasked departments and agencies to undertake a number of 

corrective actions to help ensure that known or suspected terrorists are 

identified and nominated to the watchlist and that agencies can use the 

list to screen individuals for potential links to terrorism.2

 

1

Executive Office of the President, Summary of the White House Review of the December 

25, 2009, Attempted Terrorist Attack (Washington, D.C.: Jan. 7, 2010).

2

Executive Office of the President, Memorandum on Attempted Terrorist Attack on 

December 25, 2009: Intelligence, Screening, and Watchlisting System Corrective Actions

(Washington, D.C., Jan. 7, 2010). Terrorism and terrorist activities are, in general, acts 

that (1) involve violent acts or acts dangerous to human life, property, or infrastructure that 

may be a violation of U.S. law and (2) appear intended to intimidate or coerce a civilian 

population, influence the policy of a government by intimidation or coercion, or affect the 

conduct of government by mass destruction, assassination, kidnapping, or hostage taking. 

This includes activities that facilitate or support terrorism and terrorist activities. 

 
 

Page 2 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

We have been monitoring the government’s efforts to improve its ability to 

share terrorism-related information to further homeland security. In 

January 2005, we designated information sharing a high-risk area 

because the federal government faced formidable challenges in analyzing 

and disseminating this information in a timely, accurate, and useful 

manner. The federal government’s sharing of terrorism-related 

information remained a high-risk area in our biennial update that we 

issued in February 2011.3 Also, in October 2007, we reported on how the 

watchlist is created and maintained and how federal, state, and local 

security partners use the list to screen individuals for potential threats to 

the homeland.4 We identified potential vulnerabilities—including ones 

created because agencies were not screening against all watchlist 

records—and concluded that an up-to-date strategy could help the 

government optimize use of the watchlist. We made recommendations to 

enhance the effectiveness of the watchlisting and screening processes, 

which agencies implemented or have actions under way to address. 

Further, after the attempted attack, we reported that weighing and 

responding to the potential impacts that changes to the criteria used to 

nominate individuals to the terrorist watchlist would have on the traveling 

public will be an important consideration in determining what changes 

may be needed.5

In response to your request, we issued a classified report in December 

2011 that addressed the following questions:

• What actions has the federal government taken since the December 

25, 2009, attempted attack to strengthen the watchlist nominations 

process, and to what extent are departments and agencies 

experiencing challenges implementing these actions and assessing 

impacts of the actions they have taken?

• How did the composition of the watchlist change as a result of actions

taken by departments and agencies after the attempted attack?

 

3

GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011).

4

GAO, Terrorist Watch List Screening: Opportunities Exist to Enhance Management 

Oversight, Reduce Vulnerabilities in Agency Screening Processes, and Expand Use of the 

List, GAO-08-110 (Washington, D.C.: Oct. 11, 2007).

5

GAO, Homeland Security: Better Use of Terrorist Watchlist Information and 

Improvements in Deployment of Passenger Screening Checkpoint Technologies Could 

Further Strengthen Security, GAO-10-401T (Washington, D.C.: Jan. 27, 2010).
 

Page 3 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

• How are screening agencies addressing vulnerabilities exposed by 

the attempted attack, what have been the outcomes of related 

screening since the incident, and to what extent are federal agencies 

assessing the impacts of this screening?

This report is a public version of the classified report that we provided to 

you. The various departments and agencies we reviewed deemed some 

of the information in the restricted report as classified or sensitive (e.g., 

Sensitive Security Information or For Official Use Only), which must be 

protected from public disclosure. Therefore, this report omits certain 

information associated with vulnerabilities in watchlisting and screening 

processes that were exposed by the December 25, 2009, attempted 

attack and government actions to address these vulnerabilities. This 

report also omits key details regarding (1) certain policies and procedures 

associated with the development and use of the terrorist watchlist and (2) 

specific outcomes of encounters with individuals who were positively 

matched to the watchlist. Although the information provided in this report 

is more limited in scope, it addresses the same questions as the 

restricted report. Also, the overall methodology used for both reports is 

the same.

To determine federal government actions to strengthen the watchlist 

nominations process and related challenges, we analyzed postattack 

government reports issued by the Executive Office of the President and 

the Senate Select Committee on Intelligence.6 We also compared the 

July 2010 Watchlisting Guidance—issued by the TSC to standardize 

watchlisting policies and processes—to the 2009 watchlisting protocol 

(the most recent operational policy before the December 2009 attempted 

attack) to identify changes that were intended to strengthen agencies’ 

abilities to nominate known or suspected terrorist to the watchlist.7

 

6

Senate Select Committee on Intelligence, Unclassified Summary of the Committee 

Report on the Attempted Terrorist Attack on Northwest Airlines Flight 253 (Washington, 

D.C.: May 18, 2010).

To 

help us determine how postattack changes in the watchlisting guidance 

have affected the volume of nominations and any resulting impacts, we 

obtained data for the period January 2009 through May 2011 from seven 

7

TSC issued versions of the watchlisting protocol in 2008 and 2009, and it issued the 

Watchlisting Guidance in 2010.
 

Page 4 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

federal entities involved in the nominations process.8 Specifically, we 

obtained data from five entities that nominate individuals for inclusion on 

the terrorist watchlist (nominating agencies). We also obtained 

information from the National Counterterrorism Center (NCTC), an entity 

that processes these nominations and submits them to TSC, as does the 

FBI, and TSC.9

To identify how the composition of the watchlist has changed since the 

December 2009 attempted attack, we analyzed agency documents and 

TSC data for 2009 and 2010 on the number of individuals on the terrorist 

watchlist and its subset No Fly and Selectee lists, and on the number of 

U.S. persons (U.S. citizens and lawful permanent residents) on these 

lists.

Further, we analyzed documentation on the watchlisting 

nominations process and interviewed agency officials—including the 

Director of TSC, NCTC’s Deputy Director for Terrorist Identities, and 

agency watchlisting program officials—to discuss nomination processes, 

how changes instituted as a result of the July 2010 Watchlisting Guidance 

have impacted agencies, and related challenges.

10

To identify how screening and law enforcement agencies are addressing 

vulnerabilities exposed by the attempted attack, the outcomes and 

impacts of agency actions, and the extent to which agencies are 

assessing the outcomes and impacts, we focused on screening, 

inspection, and vetting conducted by the Department of Homeland 

Security’s (DHS) TSA and CBP, and State. These are the primary 

agencies that use the watchlist to screen and vet individuals traveling to 

We also analyzed the July 2010 Watchlisting Guidance and 

interviewed the TSC Director and other center officials to obtain their 

perspectives on the reasons for changes in the size and composition of 

the watchlist and subset lists.

 

8

In general, our work focused on the federal entities that the Executive Office of the 

President tasked to take corrective actions in response to the December 2009 attempted 

attack (see app. I).

9

NCTC—within the Office of the Director of National Intelligence—serves as the primary 

organization in the U.S. government for, among other things, analyzing and integrating all 

intelligence pertaining to terrorism and counterterrorism, except for intelligence pertaining 

exclusively to domestic terrorists and domestic counterterrorism. See 50 U.S.C. § 

404o(d)(1).

10In general, individuals on the No Fly List are to be precluded from boarding an aircraft 

and individuals on the Selectee List are to receive additional screening prior to boarding 

an aircraft.
 

Page 5 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

the United States. We obtained data—generally for 2009 and 2010 but in 

some cases through May 2011—on how often these agencies have 

encountered individuals on the watchlist and the outcomes of these 

encounters to help determine what impact changes in agency screening 

or vetting procedures have had on the traveling public and agency 

operations, among other things.11

To assess the reliability of data on watchlist nominations, number of 

watchlist records, and screening outcomes, we questioned 

knowledgeable officials about the data and the systems that produced the 

data, reviewed relevant documentation, examined data for obvious errors, 

and (when possible) corroborated the data among the different agencies. 

We determined that the data were sufficiently reliable for the purposes of 

this report. We conducted this performance audit from February 2010 to 

May 2012 in accordance with generally accepted government auditing 

standards.

We also interviewed officials from each 

agency to discuss how their screening and vetting procedures have 

changed since the attempted attack and how they are assessing the 

impacts of the changes. Further, to better understand the impacts of 

watchlist screening on the traveling public, we analyzed data for 2009 and 

2010 on individuals who had inquiries or sought resolution regarding 

difficulties they experienced during their travel screening and interviewed 

DHS officials who are responsible for providing redress for these 

individuals.

12 Those standards require that we plan and perform the audit 

to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. Appendix I 

contains more details about our objectives, scope, and methodology.

 

11As used in this report, the term encounter refers to an event in which an individual is 

identified to be a positive match to an individual on the terrorist watchlist.

12We issued a classified report on this work in December 2011.
 

Page 6 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Pursuant to Homeland Security Presidential Directive 6, TSC was 

established to create and maintain the U.S. government’s consolidated 

watchlist—the Terrorist Screening Database (TSDB)—and to provide for 

the use of watchlist records during security-related and other screening 

processes.13

TSC receives watchlist information for inclusion in the TSDB from two 

sources: NCTC and the FBI. TSC receives the vast majority of its 

watchlist information from NCTC, which compiles information on known or 

suspected international terrorists.

The watchlisting and screening processes are intended to 

support the U.S. government’s efforts to combat terrorism by 

consolidating the terrorist watchlist and providing screening and law 

enforcement agencies with information to help them respond 

appropriately during encounters with known or suspected terrorists, 

among other things.

14 NCTC receives this information from 

executive branch departments and agencies—such as the Central 

Intelligence Agency (CIA), State, and the FBI—and maintains the 

information in its Terrorist Identities Datamart Environment (TIDE) 

database. Agencies that submit nominations to NCTC are to include 

pertinent derogatory information and any biographic information—such as 

name and date of birth—needed to establish the identity of individuals on 

the watchlist.15

 

13Homeland Security Presidential Directive/HSPD-6, Integration and Use of Screening 

Information (Sept. 16, 2003).

The FBI provides TSC with information about known or 

14In general, international terrorists engage in terrorist activities that occur primarily 

outside the territorial jurisdiction of the United States or that transcend national boundaries 

and include individuals in the United States with connections to terrorist activities outside 

the United States. See, e.g., 18 U.S.C. § 2331 and 22 U.S.C. § 2656f(d) (defining 

domestic and international terrorism in a criminal context, and international terrorism in a 

foreign relations context, respectively).

15In general, a nominator is a department or agency that has determined that an individual 

is a known or suspected terrorist and nominates that individual to TIDE and the TSDB 

based on information that originated with that agency or another agency. An originator is a 

department or agency that has appropriate subject matter interest and classification

authority, and collects terrorism information and disseminates it to other U.S. government 

entities. 

Background

Overview of the 

Watchlisting and Screening 

Processes
 

Page 7 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

suspected domestic terrorists.16

In accordance with Homeland Security Presidential Directive 6—and built 

upon through Homeland Security Presidential Directives 11 and 24—the 

TSDB is to contain information about individuals known or suspected to 

be or have been engaged in conduct constituting, in preparation for, in aid 

of, or related to terrorism and terrorist activities.

In general, the FBI nominates individuals 

who are subjects of ongoing FBI counterterrorism investigations to TSC 

for inclusion in the TSDB, including persons the FBI is preliminarily 

investigating to determine if they have links to terrorism.

17 Nominating agencies, 

NCTC, and the FBI apply a reasonable-suspicion standard to determine 

which individuals are appropriate for inclusion in the TSDB.18

To support agency screening processes, TSC sends applicable records 

from the TSDB to screening and law enforcement agency systems based 

NCTC and 

the FBI are to consider information from all available sources to 

determine if there is a reasonable suspicion of links to terrorism that 

warrants a nomination. Once NCTC and the FBI determine that an 

individual meets the reasonable-suspicion standard and that minimum 

biographic information exists, they extract sensitive but unclassified 

information on the individual’s identity—such as name and date of birth—

from their classified databases and send the information to TSC. TSC 

reviews these nominations—evaluating the derogatory and biographic 

information—to decide whether to add nominated individuals to the 

TSDB. Appendix II contains additional information on the watchlist 

nominations process.

 

16According to the FBI’s Domestic Terrorist Operations Unit, domestic terrorists engage in 

activities that (1) involve acts dangerous to human life that are a violation of the criminal 

laws of the United States or of any state; (2) appear to be intended to intimidate or coerce 

a civilian population, influence the policy of a government by intimidation or coercion, or 

affect the conduct of a government by mass destruction, assassination, or kidnapping; and 

(3) occur primarily within the territorial jurisdiction of the United States. See 18 U.S.C. § 

2331(5).

17See Homeland Security Presidential Directive 11, Comprehensive Terrorist-Related 

Screening Procedures (Aug. 27, 2004); and Homeland Security Presidential Directive 24,

Biometrics for Identification and Screening to Enhance National Security (June 5, 2008).

18In general, to meet the reasonable-suspicion standard, the nominator shall consider the 

totality of information available that, taken together with rational inferences from that 

information, reasonably warrants a determination that an individual is known or suspected 

to be or have been knowingly engaged in conduct constituting, in preparation for, in aid of, 

or related to terrorism or terrorist activities.
 

Page 8 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

on the agency’s mission responsibilities and other factors. For instance, 

applicable TSC records are provided to TSA for use in screening airline 

passengers, to CBP for use in inspecting and vetting persons traveling to 

and from the United States, and to State for use in screening visa 

applicants. Regarding individuals who are not citizens or nationals of the 

United States seeking to travel to and lawfully enter the United States, 

screening and law enforcement agencies rely on immigration laws that 

specify criteria for determining whether to issue visas to individuals and 

whether to admit them into the country.19 In many instances, individuals 

who are not citizens or nationals of the United States who have engaged 

in or are likely to engage in terrorist-related activities may be ineligible to 

receive visas or inadmissible for entry to the United States, or both.20 U.S. 

citizens returning to the United States from abroad are not subject to the 

admissibility requirements of the Immigration and Nationality Act, 

regardless of whether they are subjects of watchlist records. In general, 

these individuals only need to establish their U.S. citizenship to the 

satisfaction of the examining officer—by, for example, presenting a U.S. 

passport—to obtain entry into the United States.21 U.S. citizens are 

subjected to inspection by CBP before being permitted to enter and 

additional actions may be taken, as appropriate.

On December 25, 2009, Umar Farouk Abdulmutallab, a 23-year old 

Nigerian man, attempted to detonate a concealed explosive device on 

Northwest Airlines Flight 253 en route from Amsterdam to Detroit as the 

plane descended into the Detroit Metropolitan Wayne County Airport. 

 

19See, e.g., 8 U.S.C. § 1182 (codifying § 212 of the Immigration and Nationality Act, as 

amended, which articulates many of the grounds upon which an alien—any person not a 

citizen or national of the United States—may be determined to be ineligible for a visa or 

inadmissible to the United States). Before traveling to the United States, an alien who is 

not a lawful permanent resident must generally obtain a State-issued nonimmigrant visa 

for temporary stay (such as for business, tourism, or other reasons) or immigrant visa for 

permanent residence. See 8 U.S.C. § 1101(a)(15) (defining “immigrant”). 

20See 8 U.S.C. § 1182(a)(3).

21See 8 C.F.R. § 235.1(b) and 8 U.S.C. § 1185(b). Lawful permanent residents generally 

are not regarded as seeking admission to the United States and are not subject to the 

grounds for inadmissibility unless they fall within certain criteria listed at 8 U.S.C. § 

1101(a)(13)(C) that describe the circumstances under which an alien lawfully admitted for 

permanent residence would be regarded as seeking admission. However, lawful 

permanent residents may be subject to the grounds of removability under 8 U.S.C. § 

1227(a) after admission.

Weaknesses Exposed by 

the December 2009 

Attempted Attack
 

Page 9 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

According to the Executive Office of the President’s and Senate Select 

Committee on Intelligence’s inquiries into events that led to the attempted 

attack, failures across the intelligence community—including human 

errors, technical problems, and analytic misjudgments—contributed to the 

government’s failure to identify the subject as a threat that would qualify 

him for inclusion on the terrorist watchlist. The inquiries concluded that 

the intelligence community held information on Mr. Abdulmutallab—he 

was included in TIDE at the time of the attempted attack—but that it was 

fragmentary and ultimately not pieced together to form a coherent picture 

of the threat he posed (see fig. 1).

Figure 1: Summary of Information on Mr. Abdulmutallab Contained in U.S. 

Government Holdings before the December 2009 Attempted Attack

• Mr. Abdulmutallab held an active U.S. visa, issued on June 16, 2008.

• U.S. Embassy officers in Abuja, Nigeria, met with Mr. Abdulmutallab’s father on 

November 18, 2009, to discuss his concerns that his son may have come under the 

influence of “Yemeni-based extremists” and had planned to travel to Yemen.

• State sent a cable on November 20, 2009, to intelligence and law enforcement 

officials stating concerns about Mr. Abdulmutallab’s potential involvement with 

Yemeni-based extremists, but did not include the source of the information.

• Mr. Abdulmutallab was entered into NCTC’s TIDE database on November 23, 2009.

• The intelligence community had reports related to Mr. Abdulmutallab, but agencies 

did not search other databases that would have identified additional relevant 

information and intelligence that when pieced together, might have warranted his 

nomination to the terrorist watchlist.

Source: GAO analysis of published government reports and testimonies.

The government inquiries also raised issues regarding how agencies 

used and interpreted the 2009 watchlisting protocol for nominating 

individuals to the watchlist. For example, according to the Executive 

Office of the President’s review, although Mr. Abdulmutallab was entered 

into TIDE in November 2009, NCTC determined that the associated 

derogatory information did not meet the criteria for nominating him to the 

terrorist watchlist. Therefore, NCTC did not send the nomination to TSC. 

Also, according to the Senate Select Committee on Intelligence report, 

agencies may have interpreted the 2009 watchlisting protocol’s standards 

for placing individuals on the watchlist too rigidly, thereby preventing Mr. 

Abdulmutallab from being nominated for inclusion on the watchlist.

Under the auspices of the Information Sharing and Access Interagency 

Policy Committee, TSC—in coordination with watchlisting and screening 

agencies—reviewed the 2009 watchlisting protocol and made 
 

Page 10 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

recommendations regarding whether adjustments to the protocol were 

warranted.22 The Deputies Committee—a senior interagency forum that 

considers policy issues affecting national security—initially approved new 

watchlisting guidance for issuance to the watchlisting and screening 

communities in May 2010. After a multiagency classification review was 

completed, the Deputies Committee approved a final version of the 

Watchlisting Guidance in July 2010, which TSC issued to the watchlisting 

and screening communities.23

The July 2010 Watchlisting Guidance includes changes that were 

intended to address weaknesses in the nominations process that were 

exposed by the December 2009 attempted attack and to clarify how 

agencies are to nominate individuals to the watchlist.24

 

22The Interagency Policy Committees are the main day-to-day forums for interagency 

coordination of national security policy, providing policy analysis and ensuring timely 

responses to decisions made by the President. See Presidential Policy Directive 1,

Organization of the National Security Council System (Feb. 13, 2009). 

Since the 

guidance was approved, nominating agencies have expressed concerns 

23According to the TSC Director’s memorandum that was released with the revised 

guidance, although the Deputies Committee officially approved the guidance in May 2010, 

agencies had been implementing certain modifications prior to this date.

24Details regarding information contained in the July 2010 Watchlisting Guidance were 

deleted from this report because agencies considered them to be Sensitive Security 

Information. 

2010 Guidance 

Addresses 

Weaknesses in 

Nominations Process, 

but Agencies Face 

Challenges in 

Managing Increased 

Volumes of 

Information

Changes to Watchlisting 

Guidance and Impacts on 

Agencies
 

Page 11 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

about the increasing volumes of information and related challenges in 

processing this information and noted that the long-term impacts of the 

revisions may not be known for some time. For example, the watchlisting 

unit director from one agency reported that the agency is experiencing an 

increasing intake of information from its sources, which has impacted its 

analysts’ reviews of this information. Also, officials from some agencies 

reported that at times they have had to temporarily add personnel to 

review and process the large volumes of information.

Data from the nominating agencies we contacted show that the agencies 

sent more nominations-related information to NCTC after the attempted 

attack than before the attack. According to NCTC officials, the center 

experienced receiving an increase in nominations beginning in February 

2010. The officials noted that in May 2010, the volume of incoming 

nominations exceeded NCTC’s ability to process it, resulting in a backlog. 

NCTC has applied additional resources—both staffing and 

technological—to address its backlog. As a result, in October 2011, 

NCTC officials noted that the center had virtually eliminated its backlog. 

Moreover, unless TSC has the ability to process the information it 

receives, it cannot add information to the TSDB for use by screening and 

law enforcement agencies.25

Since the December 25, 2009, attempted attack, agencies involved in the 

watchlist nominations process have pursued staffing, technology, working 

groups, and other solutions to strengthen the process and manage 

increasing volumes of information. Specifically, officials from four of the 

seven agencies we contacted reported that they are in the process of 

developing and implementing certain technological solutions to address 

watchlisting issues. For example, NCTC, in consultation with other

members of the intelligence community, reported that it is developing 

information technology tools to strengthen analysts’ abilities to identify 

potential links to terrorism. The government has also created interagency 

Overall, the volume of nominations TSC is 

receiving from the FBI and NCTC has generally increased since the 

attempted attack. According to TSC officials, the center has avoided 

backlogs by employing a variety of strategies to address its workload, 

including management of personnel resources and use of more advanced 

technology.

 

25We discuss the impacts that increasing nominations could have on screening agencies 

later in this report.
 

Page 12 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

working groups to address watchlist-related issues. Further, NCTC 

reported that training programs have been developed and administered to 

its watchlisting analysts, as well as nominating and screening agency 

personnel.

Our review of the July 2010 Watchlisting Guidance and discussions with 

relevant agency officials indicated that in drafting the guidance, the 

watchlist community emphasized quality-assurance mechanisms as well 

as civil rights and civil liberties protections that should be considered 

when nominating individuals.

While agencies are pursuing actions to strengthen the watchlisting 

process, no single entity is accountable for routinely assessing the overall 

impacts the July 2010 Watchlisting Guidance is having on the watchlisting 

community, the extent to which these impacts are acceptable and 

manageable from a policy perspective, and if the impacts indicate the 

need for any adjustments. Further, no entity is routinely collecting and 

analyzing data needed to conduct such governmentwide assessments 

over time. In general, officials from the nominating agencies we contacted 

and from NCTC and TSC said that they participated in developing the 

July 2010 Watchlisting Guidance and agreed with the changes, but noted 

that they did not know at the time how changes implemented through the 

2010 guidance would impact them. Routinely assessing these impacts 

could help agencies address any challenges they are having in 

implementing the watchlisting guidance.

Agencies involved in the nominations process are taking actions to 

address challenges related to implementing the 2010 guidance. For 

example, officials from the Information Sharing and Access Interagency 

Policy Committee’s Subcommittee on Watchlisting noted that 

departments and agencies within the watchlisting community are 

responsible for assessing the impacts of their individual watchlisting 

efforts and for bringing issues, as needed, to the subcommittee.26

 

26The Subcommittee on Watchlisting is attended by members of the watchlist community 

and provides an interagency forum to which agencies can bring watchlist-related issues 

for discussion and resolution.

 They 

explained that agencies react to and address issues and challenges as 

they arise. However, this approach has not allowed them to proactively 

and systematically assess the watchlisting process and identify emerging 

Assessing Impacts of 

Guidance Could Help 

Ensure That Challenges 

Are Resolved and Inform 

Future Efforts to 

Strengthen the 

Watchlisting Process
 

Page 13 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

issues; achieve consensus on solutions to potential challenges before 

they manifest themselves; and determine if adjustments to the 

watchlisting guidance are needed.

Because of the collaborative nature of the watchlisting process, any 

assessment of impacts must be an interagency effort. However, none of 

the interagency entities we contacted were routinely performing these 

assessment functions. In February 2011, officials from the Subcommittee 

on Watchlisting noted that the subcommittee was preparing a report on 

watchlisting efforts since the December 2009 attempted attack and had 

requested that subcommittee members provide input. At that time, the 

subcommittee officials noted that the Information Sharing and Access 

Interagency Policy Committee did not plan to conduct routine 

assessments of the watchlisting processes. In August 2011, a 

representative of the National Security Staff informed us that the 

Information Sharing and Access Interagency Policy Committee recently 

began performing an assessment function related to the July 2010 

Watchlisting Guidance. The representative noted that the depth and 

frequency of specific reviews will vary as necessary and appropriate. The 

staff did not provide us details on these efforts, so we could not determine 

to what extent the assessments will be routine or involve collecting and 

analyzing data needed to conduct such assessments over time.

Since we found no single entity that is responsible and accountable for 

routinely assessing the overall impacts the 2010 guidance is having on 

the watchlisting community—and collecting the data needed to conduct 

such assessments—the Assistant to the President for Homeland Security 

and Counterterrorism may be best positioned to ensure that 

governmentwide assessments are conducted. The President tasked this 

individual to be responsible and accountable for ensuring that agencies 

carry out actions to strengthen the watchlisting process after the 

December 2009 attempted attack. Thus, it likewise follows that this 

individual could be responsible and accountable for ensuring that the 

impacts from these actions are routinely assessed and that the results of 

the assessments are used to inform future watchlisting changes.

According to Standards for Internal Control in the Federal Government, 

ongoing monitoring of programs and activities should occur during the 
 

Page 14 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

course of normal operations.27 Working collaboratively to ensure that 

appropriate agencies routinely evaluate or assess the impact of the 2010 

guidance on the watchlisting community could help decision makers 

determine if the guidance is achieving its intended outcomes or needs 

any adjustments, and help inform future efforts to strengthen the 

watchlisting process. Such assessments could also help the Information 

Sharing and Access Interagency Policy Committee and the watchlisting 

community understand longer-term impacts of changes to the watchlisting 

guidance, such as how increasing volumes of information are creating 

resource demands. Finally, such assessments could help to improve 

transparency and provide an accurate accounting to the Executive Office 

of the President and other stakeholders, including Congress, for the 

resources invested in the watchlisting process.

Immediately after the December 2009 attempted attack, federal agencies 

took steps that resulted in an increase in the number of individuals in the 

TSDB and its aviation-related subsets—the No Fly and Selectee lists—

based on new intelligence and threat information. Specifically, in the 

months following the attempted attack, agencies added these individuals 

to the TSDB from TIDE or from the TSDB to the No Fly or Selectee lists. 

Also, upon completion of this initiative, the number of U.S. persons on the 

No Fly List more than doubled and the number of U.S. persons on the 

Selectee List increased by about 10 percent. According to TSC data, the 

number of individuals on the No Fly List generally continued to increase 

during the remainder of 2010, while the number of individuals on the 

Selectee List remained relatively constant.

To carry out these upgrades, TSC and NCTC—at the direction of the 

Deputies Committee and in consultation with other intelligence 

agencies—reviewed available intelligence and threat information that 

existed on certain individuals. At the same time, TSC worked with NCTC 

and intelligence community agencies to ensure that (1) the information 

that supported changing the watchlist status of the individuals was as 

complete and accurate as possible and (2) the individuals were placed in 

 

27GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

The Number of 

Individuals on the 

Watchlist and 

Aviation-Related 

Subsets Increased 

after the Attempted 

Attack
 

Page 15 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

the TSDB and, when applicable, on the No Fly or Selectee lists, in 

accordance with standards and criteria for inclusion on these lists.28

Agencies that screen individuals against TSDB records are addressing 

vulnerabilities and gaps in processes that were exposed by the December 

2009 attempted attack to enhance homeland security. For example, TSA 

actions have resulted in more individuals being denied boarding aircraft or 

subjected to enhanced screening before boarding. The number of U.S. 

persons (U.S. citizens and lawful permanent residents) denied boarding 

has also increased and, for such persons abroad, required the 

government to develop procedures to facilitate their return. TSA is also 

screening airline passengers against additional TSDB records to mitigate 

risks. CBP has implemented a program to build upon its practice of 

evaluating the risk posed by individuals attempting to enter the United 

States before they board flights bound for the United States. As a result, 

air carriers have permitted fewer individuals in the TSDB to board such 

flights, particularly nonimmigrant aliens. State took actions to revoke 

hundreds of U.S. visas immediately after the attempted attack because it 

determined that the individuals could present an immediate threat. These 

and other agency actions are intended to enhance homeland security, but 

no entity is routinely assessing governmentwide issues, such as how the 

changes have impacted agency resources and the traveling public, 

whether watchlist screening is achieving intended results, or if 

adjustments to agency programs or the watchlisting guidance are 

needed.

After the attempted attack, TSA continued implementation of the Secure 

Flight program, which enabled TSA to assume direct responsibility for 

 

28Certain details regarding government actions to add individuals to the TSDB and its 

aviation-related subsets after the December 2009 attempted attack and the number of 

individuals added were deleted from this report because they are considered to be 

Sensitive Security Information.

Screening Agencies 

Are Addressing 

Vulnerabilities 

Exposed by the 

Attempted Attack, but 

Assessing Their 

Impacts Could Help 

Inform Future Efforts

TSA Has Encountered 

More Individuals on the No 

Fly and Selectee Lists and 

Is Screening against More 

Watchlist Records

No Fly and Selectee List 

Encounters
 

Page 16 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

determining if individuals are matches to the No Fly or Selectee lists from 

air carriers. Secure Flight requires that air carriers collect—and that 

passengers provide—full name and date-of-birth and gender information, 

thereby improving TSA’s ability to correctly determine whether individuals 

are on these lists.29 Before Secure Flight, air carriers were not required to 

collect date-of-birth and gender information, and each airline conducted 

watchlist matching differently with varying effectiveness.30

Since the December 2009 attempted attack and subsequent increase in 

the number of U.S. persons nominated to and placed on the No Fly List, 

there have been instances when U.S. persons abroad have been unable 

to board an aircraft bound for the United States. Any individual—

regardless of nationality—can be prohibited from boarding an aircraft if 

the threat represented by the individual meets the criteria for inclusion on 

the No Fly List. In general, however, U.S. citizens are permitted to enter 

the United States at a U.S. port of entry if they prove to the satisfaction of 

a CBP officer that they are in fact U.S. citizens.

According to 

TSA, the increase in individuals added to the No Fly and Selectee lists, 

combined with the implementation of Secure Flight, resulted in an 

increase in the number of times airlines encountered individuals on these 

lists. TSA data show that the encounters involved both domestic flights 

(flights to and from locations within the United States) and international 

flights (flights to or from the United States or over U.S. air space).

31 Lawful permanent 

residents, who in limited circumstances independent of the No Fly List 

may be rendered an applicant for admission, are usually entitled to 

removal proceedings prior to having their status as a lawful permanent 

resident terminated for immigration purposes.32

 

29Air carriers must also request that passengers provide a redress number, if available, 

though passengers are not required to provide this information. See 49 C.F.R. § 

1560.101. In general, the term redress refers to an agency’s complaint resolution process 

whereby individuals may seek resolution of their concerns about an agency action.

30See GAO, Aviation Security: TSA Is Enhancing Its Oversight of Air Carrier Efforts to 

Identify Passengers on the No Fly and Selectee Lists, but Expects Ultimate Solution to Be 

Implementation of Secure Flight, GAO-08-992 (Washington, D.C.: Sept. 9, 2008).

31See 8 U.S.C. § 1185(b); 8 C.F.R. § 235.1(b). 

32See 8 U.S.C. §§ 1101(a)(13)(C), 1229a.
 

Page 17 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

In our October 2007 watchlist report, we recommended that DHS assess 

to what extent security risks exist by not screening against more watchlist 

records and what actions, if any, should be taken in response.33 DHS 

generally agreed with our recommendation but noted that increasing the 

number of records that air carriers used to screen passengers would 

expand the number of misidentifications to unjustifiable proportions 

without a measurable increase in security. In general, misidentifications 

occur when a passenger’s name is identical or similar to a name in the 

TSDB but the passenger is not the individual on the watchlist. Since then, 

TSA assumed direct responsibility for this screening function through 

implementation of the Secure Flight program for all flights traveling to, 

from, or within the United States.34 According to TSA, Secure Flight’s full 

assumption of this function from air carriers and its use of more 

biographic data for screening have improved watchlist matching. This 

includes TSA’s ability to correctly match passenger data against TSDB 

records to confirm if individuals match someone on the watchlist and 

reduce the number of misidentifications.35

TSA’s actions discussed below fully respond to the recommendation we 

made in our October 2007 report. Specifically, TSA has implemented 

Secure Flight such that as circumstances warrant, it may expand the 

scope of its screening beyond the No Fly and Selectee lists to the entire 

TSDB.

Appendix III contains additional 

information on how Secure Flight has reduced the likelihood of 

passengers being misidentified as being on the watchlist and related 

inconveniences.

36

 

33

According to the program’s final rule, in general, Secure Flight is 

to compare passenger information only to the No Fly and Selectee lists 

because, during normal security circumstances, screening against these 

components of the TSDB will be satisfactory to counter the security 

threat. However, the rule also provides that TSA may use the larger set of 

GAO-08-110. 

34Secure Flight also performs this screening function for covered airline flights that travel 

over the United States and “point-to-point” international flights operated by covered U.S.-

based airlines.

35See GAO, Aviation Security: TSA Has Completed Key Activities Associated with 

Implementing Secure Flight, but Additional Actions Are Needed to Mitigate Risks,

GAO-09-292 (Washington, D.C.: May 13, 2009).

36See generally Secure Flight Program; Final Rule, 73 Fed. Reg. 64,018 (Oct. 28, 2008) 

(codified at 49 C.F.R. pt. 1560).

TSA Is Screening Airline 

Passengers against Additional 

Watchlist Records 
 

Page 18 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

“watch lists” maintained by the federal government when warranted by 

security considerations, such as if TSA learns that flights on a particular 

route may be subject to increased security risk.

Also, after the attempted bombing in December 2009, DHS proposed and 

the Deputies Committee approved the Secure Flight program’s expanded 

use of TSDB records on a routine basis to screen passengers before they 

board flights. In April 2011, TSA completed the transition of the Secure 

Flight program to conduct watchlist matching against this greater subset 

of TSDB records and notify air carriers that those passengers who are 

determined to be a match should be designated for enhanced screening 

prior to boarding a flight. According to TSA, the impact on screening 

operations has been minimal given the relatively low volume of matches 

against these additional records each day.

TSA noted that the entire TSDB is not used for screening since matching 

passenger data against TSDB records that contain only partial data could 

result in a significant increase in the number of passengers who are 

misidentified as being on the watchlist and potentially cause unwarranted 

delay or inconvenience to travelers. TSA also noted that as with potential 

misidentifications to the No Fly and Selectee lists, passengers who feel 

that they have been incorrectly delayed or inconvenienced can apply for 

redress through the DHS Traveler Redress Inquiry Program (DHS 

TRIP).37

In fiscal year 2011, TSA reprogrammed $15.9 million into Secure Flight to 

begin screening against the additional TSDB records. TSA’s fiscal year 

2012 budget request proposed funding to make screening against the 

additional records permanent. According to TSA, for fiscal year 2012, 

Secure Flight requested an increase of $8.9 million and 38 full-time 

personnel to continue supporting this expanded screening effort. 

According to TSA, the funding will be used for information technology 

enhancements that will be required to implement this expanded screening 

and will allow TSA to handle the increased workload.

DHS noted that TSA regularly monitors the Secure Flight 

program and processes and makes adjustments as needed.

 

37DHS TRIP is a single point of contact for individuals who have inquiries or seek 

resolution regarding difficulties they experienced during their travel screening. Additional 

information on DHS TRIP is discussed in app. VI. 
 

Page 19 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

For individuals traveling by air to the United States, CBP has established 

programs whereby it assesses individuals before they board an aircraft to 

determine whether it is likely they will be found inadmissible at a port of 

entry. The following sections discuss how CBP’s Pre-Departure Targeting 

Program and Immigration Advisory Program handle the subset of 

travelers who are in the TSDB.38

In response to the attempted attack in December 2009, and as part of its 

border and immigration security mission, CBP implemented the PreDeparture Targeting Program in January 2010 to build upon its process of 

assessing if individuals would likely be found inadmissible at a port of 

entry before they board an aircraft to cover all airports worldwide with 

direct flights to the United States. Before the attempted attack, CBP 

assessed individuals who were departing from airports that had CBP 

Immigration Advisory Program officers on site. At airports without such a 

program, passengers in the TSDB but not on the No Fly List generally 

were allowed to board flights and travel to U.S. airports. Upon arrival at a 

U.S. port of entry, CBP would inspect the passengers and determine their 

admissibility. CBP continues to assess passengers through the 

Immigration Advisory Program for flights departing from airports that have

a program presence.

Other high-risk and improperly 

documented passengers handled by these programs include passengers 

who have criminal histories; have had their visas revoked; are in 

possession of fraudulent, lost, or stolen passports; or otherwise appear to 

be inadmissible.

For both the Pre-Departure Targeting Program and the Immigration 

Advisory Program, if CBP determines that a passenger would likely be 

deemed inadmissible upon arrival at a U.S. airport, it recommends that 

the air carrier not board that passenger (that is, it makes a no board 

recommendation). CBP generally makes these no board 

recommendations based on provisions for admissibility found in the 

Immigration and Nationality Act.39

 

38CBP’s Pre-Departure Targeting Program was designed specifically for vetting aviation 

passengers. The Immigration Advisory Program was established in 2004 to place trained 

CBP officers at certain foreign airports to assist with passenger vetting, such as

interviewing high-risk or improperly documented passengers and evaluating the 

authenticity of travel documents prior to a passenger’s departure.

U.S. citizens are generally not subject 

39See, e.g., 8 U.S.C. § 1182 (codifying section 212 of the Immigration and Nationality Act, 

as amended, and establishing conditions under which an alien—any person not a citizen 

or national of the United States—may be deemed inadmissible to the United States).

CBP Expansion of 

PreDeparture Vetting Has 

Kept Hundreds More 

Aliens in the TSDB off 

Airplanes Bound for the 

United States

Pre-Departure Program 

Expanded CBP Vetting to 

Cover All Airports with Direct 

Flights to the United States
 

Page 20 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

to these recommendations since they are generally permitted to enter the 

United States at a U.S. port of entry if they prove to the satisfaction of a 

CBP officer that they are in fact U.S. citizens. CBP may also decide to not 

issue such recommendations for aliens in the TSDB if, for example (1) 

CBP officers determine that, based on a review of all available 

information, the individual is not likely to be denied admission to the 

United States, or (2) the individual was granted a waiver of inadmissibility 

by DHS, if such a waiver is available.40

For flights departing from airports without an Immigration Advisory 

Program officer on site, CBP is leveraging the capabilities of its officers 

within its Regional Carrier Liaison Groups to issue no board 

recommendations to air carriers. These groups were established in 2006 

to assist air carriers with U.S. entry-related matters—with a primary focus 

on verifying the authenticity of travel documents—and to work directly 

with commercial air carriers on security-related matters. Regional Carrier

Liaison Group staff who are located in the United States handle PreDeparture Targeting Program no board recommendations to air carriers 

remotely by delivering the recommendations via phone, fax, or e-mail.41

Upon receiving a no board recommendation from CBP for a passenger, 

air carriers make the ultimate decision whether to deny boarding or to 

transport the individual to the United States. According to CBP officials, 

air carriers almost always follow no board recommendations because (1) 

they do not want to transport high-risk individuals and (2) such alien 

passengers will almost always be found inadmissible at the U.S. port of 

entry. In this case, the air carrier is responsible for ensuring space for 

such an individual on the next available flight to the originating airport.

CBP policy instructs staff to give no board recommendations priority over 

other duties, given the time and security sensitivities involved.

42

 

40See 8 U.S.C. § 1182(d) (governing the temporary admission of aliens otherwise deemed 

inadmissible). See also 8 C.F.R. §§ 212.4, 212.7. 

In 

addition, the air carrier could be fined for transporting an alien to the 

41There are three Regional Carrier Liaison Groups, which are located in Honolulu, Hawaii; 

Miami, Florida; and New York City, New York. Each of the three locations has authority 

over a region of the world, with the Honolulu location covering U.S.-bound flights from 

Asia and the Pacific; the New York City location covering flights from Africa, Europe, and 

the Middle East; and the Miami location covering flights from Latin America and the 

Caribbean.

42See 8 U.S.C. § 1231(c), (d).
 

Page 21 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

United States who does not have a valid passport and visa, if a visa is 

required.43

Since the attempted attack, CBP predeparture vetting programs—the 

Pre-Departure Targeting Program and the Immigration Advisory 

Program—have resulted in hundreds more aliens being kept off flights 

bound for the United States because CBP determined that they likely 

would be deemed inadmissible upon arrival at a U.S. airport and made 

corresponding no board recommendations to air carriers. In addition to 

the increase in no board recommendations that resulted from 

implementing the Pre-Departure Targeting Program in January 2010, the 

increase during 2010 was in response to the new threats made evident by 

the attempted attack, according to CBP officials. CBP data also show that 

there have been instances when individuals have boarded flights bound 

for the United States and arrived at U.S. airports. According to CBP 

officials, the vast majority of these cases involved either (1) U.S. citizens 

and lawful permanent residents who generally may enter the United 

States, and therefore, CBP generally does not recommend that air 

carriers not board these passengers, or (2) aliens in the TSDB who were 

deemed inadmissible but were granted temporary admission into the 

United States under certain circumstances, such as DHS granting a 

waiver of inadmissibility.

When CBP does not recommend that an individual in the 

TSDB be denied boarding and the passenger boards a flight bound for 

the United States, CBP inspects the passenger upon arrival at a U.S. 

airport. For aliens seeking admission to the United States, determinations 

on admissibility are generally made by CBP officers during this inspection 

in accordance with applicable provisions of the Immigration and 

Nationality Act. In general, aliens who are deemed inadmissible are 

detained by DHS until the individual can board a return flight home.

44

At the time of our review, CBP did not have readily available data on how 

often aliens in the TSDB boarded flights bound for the United States—

 

43See 8 U.S.C. § 1323; 8 C.F.R. pt. 273.

44See, e.g., 8 U.S.C. § 1182(d)(3)(B) (authorizing the Secretary of Homeland Security, in 

certain circumstances, and after consultation with the Attorney General and Secretary of 

State, to grant temporary admission to an alien otherwise deemed inadmissible thereby, in 

effect, waiving a determination of inadmissibility). See also, e.g., 8 U.S.C. § 1182(d)(5) 

(authorizing the Attorney General to parole—that is, grant temporary permission to enter 

and be present in the United States—any alien into the United States on a case-by-case 

basis for urgent humanitarian reasons or significant public benefit).

CBP Made Hundreds More No 

Board Recommendations after 

the Attempted Attack
 

Page 22 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

information that could help CBP assess how its predeparture programs 

are working and provide transparency over program results, among other 

things. According to CBP officials, the agency was working on adding 

data fields to CBP systems to capture more information related to these 

programs. The officials noted that these changes will allow CBP to break 

down and retrieve data by U.S. citizens, lawful permanent residents, and 

aliens, and that related reports will be produced. At our request, CBP 

conducted a manual review of data it compiled on the results of its 

processing of passengers at U.S. airports from April 2010 through 

September 2010.45

CBP officials stated that the Pre-Departure Targeting Program increased 

the workload for Regional Carrier Liaison Group staff and that two of the 

three groups increased the number of CBP officers assigned to handle 

this workload.

During this period, CBP data show that there were 

instances when aliens in the TSDB boarded flights bound for the United 

States and were admitted into the country. These occurrences are in 

addition to instances where aliens in the TSDB were able to board flights 

bound for and enter the United States because they had been granted 

admission to the country on a temporary basis under certain 

circumstances, such as by DHS granting a waiver of inadmissibility. 

According to CBP officials, for each of these occurrences, CBP officers 

determined—based on a review of all available and relevant 

information—that the derogatory information on the individual was not 

sufficient to render that person inadmissible under the Immigration and 

Nationality Act.

46

In cases where an individual expresses concern about not being able to 

board a flight to the United States, CBP Immigration Advisory Program 

officers or air carrier personnel are instructed not to reveal to the 

In addition, CBP officials noted that personnel at its 

facility that supports these programs experienced increased workloads, 

which they handled through additional hiring, overtime hours, and 

assignment of temporary duty personnel.

 

45CBP compiles reports on these data twice each fiscal year, and at the time we 

requested the information, the April 2010 through September 2010 report was the most 

recently compiled. We did not request that CBP conduct manual reviews of other reports 

because of the labor intensive nature of the reviews.

46Regional Carrier Liaison Group positions are not specifically funded but are staffed from 

existing CBP port personnel, with CBP port management determining the staffing levels 

required at each location.
 

Page 23 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

individual any law enforcement sensitive information. Rather, the CBP 

officers or air carrier personnel are to advise the individual to go to the 

U.S. consulate or the person’s home country passport office, as 

appropriate, to address the issue. CBP officials also noted that individuals 

who have travel-related concerns are advised to file an inquiry through 

DHS TRIP. According to DHS TRIP officials, about 20 percent of all 

requests for redress that it receives involve CBP inspections conducted at 

land, sea, or air ports of entry.

After the December 2009 attempted attack, the Executive Office of the 

President directed TSC to determine the visa status of all known or 

suspected terrorists in the TSDB. TSC then worked with State to 

determine whether individuals who held U.S. visas should continue 

holding them in light of new threats made evident by the incident. 

Specifically, in January 2010, State revoked hundreds of visas because it 

determined that the individuals could present an immediate threat to the 

United States. State officials noted that these revocations were largely 

related to individuals who were added to the TSDB—or moved to the No 

Fly or Selectee lists—after the attempted attack based on new 

intelligence and threat information.

In March 2010, TSC and State initiated another review and identified 

hundreds of cases in which individuals in the TSDB held U.S. visas. 

These cases included individuals who were in the TSDB at the time of the 

December 2009 attempted attack but did not have their visas revoked 

during the January 2010 review. According to State officials, all 

individuals who could present an immediate threat to the United States 

had their visas revoked within 24 hours. In cases involving a less clear 

nexus to terrorism, the officials noted that visas were not immediately 

revoked. The officials explained that investigating these cases can take 

several months and involve extensive coordination with law enforcement 

and intelligence officials. According to State officials, of these remaining 

cases, the department revoked a number of visas based on intelligence 

community recommendations and determined that other visas had been 

issued properly following the completion of an interagency review process 

and, in applicable cases, ineligibility waivers provided by DHS.

State Revoked Hundreds 

of Visas Held by 

Individuals on the 

Watchlist after the 

Attempted Attack

State Revoked Hundreds of 

Visas after Attempted Attack
 

Page 24 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Regarding the cases in which State determined that individuals could 

continue to hold visas, State officials noted that an individual’s presence 

in the TSDB does not itself render that person ineligible for a visa. For 

example, State will issue a visa if it determines that the available 

information supporting the TSDB record does not meet the statutory 

conditions under which an individual may be deemed ineligible for a visa 

to the United States, and the individual is not otherwise ineligible for a 

visa.47 The officials added that in those instances where State finds that 

an individual is ineligible for a visa—based on provisions in the 

Immigration and Nationality Act that define terrorist activities—the 

department may still, in certain circumstances, issue a visa if DHS agrees 

to grant a waiver of inadmissibility, if such a waiver is available.48

In addition to the hundreds of visa revocations involving individuals in the 

TSDB that were related to the reviews directed by the Executive Office of 

the President, State data show that the department revoked hundreds 

more visas based on terrorism-related grounds during 2010. The total 

number of visas State revoked during 2010 was more than double the 

number of visas the department revoked based on terrorism-related 

grounds during 2009. According to State, as of May 2011, a number of 

individuals in the TSDB continued to hold U.S. visas because the 

department found that (1) they were ineligible to hold a visa under the 

According to State officials, reasons an individual found ineligible for a 

visa may receive a waiver include significant or compelling U.S. 

government interests or humanitarian concerns. According to State 

officials, while the department consulted with law enforcement and 

intelligence community officials regarding whether to revoke the visas, 

State has final authority over all visa decisions.

 

47See 8 U.S.C. § 1182(a)(3) (codifying § 212(a)(3) of the Immigration and Nationality Act, 

which identifies terrorist activities as one of the grounds for finding an alien ineligible for a 

visa or admission to the United States, and describes in broad terms the types of activities 

or circumstances that could lead to such a finding on terrorism grounds). Section 1182 

identifies other security and nonsecurity grounds on which an individual may be deemed 

ineligible for a visa.

48See 8 U.S.C. § 1182(d)(3)(B) (authorizing the Secretary of State, in certain 

circumstances and after consultation with the Attorney General and Secretary of 

Homeland Security, to grant temporary admission to an alien otherwise deemed 

inadmissible thereby, in effect, waiving a determination of inadmissibility). A decision by 

the Secretary of State to issue a visa to an otherwise ineligible applicant would not, 

however, overcome DHS authority to determine admissibility at a port of entry into the 

United States.
 

Page 25 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

terrorism-related provisions of the Immigration and Nationality Act but 

received waivers of that ineligibility or (2) they were not ineligible to hold 

visas under the terrorism-related provisions of the act following standard 

interagency processing of the visa applications.

Under current procedures, State screens visa applicant data against 

sensitive but unclassified extracts of biographical information drawn from 

TSDB records as part of its evaluation process for issuing U.S. visas. If 

an applicant for a visa is identified as a possible match with a TSDB 

record, consular officers are to initiate a process to obtain additional 

information on the individual’s links to terrorism, including information 

maintained by law enforcement and intelligence agencies. State data 

show that the department denied about 55 percent more nonimmigrant 

visas based on terrorism-related grounds during 2010 than it did during 

2009, which includes denials involving individuals in the TSDB. Further, 

State found that in cases where individuals were ineligible to hold 

nonimmigrant visas based on terrorism-related grounds—but evinced 

significant or compelling U.S. government interest or humanitarian 

concern—the department recommended, and DHS granted, waivers of 

ineligibility.

According to State officials, the department’s automated systems do not 

capture data on the number of individuals in the TSDB who applied for 

visas—or the related outcomes of these applications (e.g., issued or 

denied)—because this information is not needed to support the 

department’s mission. State officials noted that it would be costly to 

change department databases to collect information specific to individuals 

applying for visas who are in the TSDB, but the department is working 

with TSC on a process to make these data more readily available through 

other means. State is also partnering with other agencies to develop a 

new, more automated process for reviewing visa applications that is 

intended to be more efficient than the current process. The new process 

is also intended to help minimize the inconvenience of protracted visa 

processing times for applicants incorrectly matched to TSDB records, 

among other things.

Outcomes of Visa Screening 

and Status of New State Efforts 

to Screen Visa Applicants
 

Page 26 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Since the December 2009 attempted attack, agencies have taken actions 

to strengthen their respective processes for screening and vetting 

individuals against TSDB records. However, no entity has acknowledged 

that it is responsible and accountable for routinely conducting 

governmentwide assessments of how agencies are using the watchlist to 

make screening or vetting decisions and related outcomes or the overall 

impact screening or vetting programs are having on agency resources 

and the traveling public. Also, no entity is assessing whether watchlistrelated screening or vetting is achieving intended results from a policy 

perspective, or if adjustments to agency programs or the watchlisting 

guidance are needed. Further, no entity is routinely collecting and 

analyzing data needed to conduct such governmentwide assessments 

over time. According to the TSC Director, conducting such assessments 

and developing related metrics will be important in the future.

The actions screening and law enforcement agencies have taken since 

the attempted attack have resulted in more individuals in the TSDB being 

denied boarding flights, being deemed inadmissible to enter the United 

States, and having their U.S. visas revoked, among other things. These 

outcomes demonstrate the homeland security benefits of watchlist-related 

screening or vetting, but such screening or vetting and related actions 

have also had impacts on agency resources and the traveling public. For 

example, new or expanded screening and vetting programs have required 

agencies to dedicate more staff to check traveler information against 

TSDB records and take related law enforcement actions. Also, any new 

or future uses of the watchlist for screening or vetting may result in more 

individuals being misidentified as the subject of a TSDB record, which can 

cause traveler delays and other inconveniences. Agencies are 

independently taking actions to collect information and data on the 

outcomes of their screening or vetting programs that check against TSDB 

records, but no entity is routinely assessing governmentwide issues, such 

as how U.S. citizens and lawful permanent residents are being affected 

by screening or the overall levels of misidentifications that are occurring. 

Routinely assessing these outcomes and impacts governmentwide could 

help decision makers determine if the watchlist is achieving its intended 

results without having unintended consequences or needs further 

revisions.

Because watchlist-related screening or vetting is a governmentwide 

function, any effort to assess the overall outcomes and impacts must be 

an interagency effort. The federal government has established 

interagency working groups to address screening and related issues. 

However, according to agency officials we contacted, these groups have 

Assessing Outcomes and 

Impacts of Screening and 

Vetting Agency Programs 

Could Help Ensure That 

the Watchlist Is Achieving 

Intended Results
 

Page 27 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

not conducted governmentwide assessments because they have been 

focused on implementing new or expanding screening or vetting 

programs and revising related policies and procedures, among other 

things.

Similar to watchlisting issues, in August 2011, a representative of the 

National Security Staff informed us that the Information Sharing and 

Access Interagency Policy Committee recently began performing an 

assessment to support its oversight of new screening processes. The 

representative noted that the depth and frequency of specific reviews will 

vary as necessary and appropriate. The staff did not provide us details on 

these efforts, so we could not determine to what extent the assessments 

will be routine or involve collecting and analyzing data needed to conduct 

such governmentwide assessments over time. As discussed previously, 

the President tasked the Assistant to the President for Homeland Security 

and Counterterrorism to be responsible and accountable for ensuring that 

agencies carry out actions to strengthen the watchlisting process after the 

December 2009 attempted attack. As such, the Assistant to the President 

may be best positioned to ensure that governmentwide assessments of 

the outcomes and impacts of agency screening programs are conducted.

According to Standards for Internal Control in the Federal Government, 

ongoing monitoring of programs and activities should occur during the 

course of normal operations. These standards also note that performance 

data on agency programs be available as a means to hold public service 

organizations accountable for their decisions and actions, including 

stewardship of public funds, fairness, and all aspects of performance.49

Routine, governmentwide assessments of screening agency programs 

could help the government determine if the watchlist is achieving its 

intended results, identify broader issues that require attention, and 

improve transparency and provide an accurate accounting to the 

Executive Office of the President and other stakeholders, including 

Congress, for the resources invested in screening processes.

The attempt on December 25, 2009, to detonate a concealed explosive 

on board a U.S.-bound aircraft highlights the importance of the U.S. 

government placing individuals with known or suspected ties to terrorism 

 

49GAO/AIMD-00-21.3.1. 

Conclusions
 

Page 28 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

on its watchlist. The Executive Office of the President’s review of the 

attempted attack found that the U.S. government had sufficient 

information to have uncovered and potentially disrupted the attempted 

attack, but shortcomings in the watchlisting process prevented the 

attempted bomber from being nominated for inclusion on the watchlist. 

The July 2010 Watchlisting Guidance includes changes that were 

intended to address weaknesses in the nominations process. Since the 

guidance was approved, agencies have expressed concerns about the 

increasing volumes of information and related challenges in processing 

this information. The federal entities involved in the nominations process 

are taking actions to address challenges related to implementing the 

guidance. However, no single entity is routinely assessing the overall 

impacts of the watchlisting guidance or the steps taken to strengthen the 

nominations process. Working collaboratively to ensure that the 

watchlisting community periodically evaluates or assesses the impacts of 

the revised guidance on the watchlisting community could (1) help 

decision makers determine if the guidance is achieving its intended 

outcomes or needs any adjustments, (2) inform future efforts to 

strengthen the watchlisting process, (3) help the watchlisting community 

understand longer-term impacts of changes to the watchlisting guidance, 

and (4) improve transparency and provide an accurate accounting to the 

Executive Office of the President and other stakeholders, including 

Congress, for the resources invested in the watchlisting process.

Just as agencies are not routinely assessing the impacts of the revisions 

made to the watchlisting guidance or the steps taken to strengthen the 

nominations process, no single entity is routinely assessing information or 

data on the collective outcomes or impacts of agencies’ watchlist 

screening operations to determine the effectiveness of changes made to 

strengthen screening since the attempted attack or how changes to the 

watchlisting guidance have affected screening operations. Routine, 

governmentwide assessments of the outcomes and impacts of agencies’ 

watchlist screening or vetting programs could help ensure that these 

programs are achieving their intended results or identify if revisions are 

needed. Such assessments could also help identify broader issues that 

require attention, determine if impacts on agency resources and the 

traveling public are acceptable, and communicate to key stakeholders 

how the nation’s investment in the watchlist screening or vetting 

processes is enhancing security of the nation’s borders, commercial

aviation, and other security-related activities.
 

Page 29 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

To help inform future efforts to strengthen watchlisting and screening 

processes, we recommend that the Assistant to the President for 

Homeland Security and Counterterrorism establish mechanisms or use 

existing interagency bodies to routinely assess

• how the watchlisting guidance has impacted the watchlisting 

community—including its capacity to submit and process nominations 

in accordance with provisions in the guidance—and whether any 

adjustments to agency programs or the guidance are needed, and

• whether use of the watchlist during agency screening processes is 

achieving intended results, including whether the overall outcomes 

and impacts of screening on agency resources and the traveling 

public are acceptable and manageable or if adjustments to agency 

programs or the watchlisting guidance are needed.

We provided a draft of the classified version of this report for comment to 

the National Security Staff; the Office of the Director of National 

Intelligence; the Departments of Defense, Homeland Security, Justice, 

and State; and the CIA. In its written comments, DHS noted that it 

appreciated the report’s identification of enhancements the department 

has made to several screening programs to address vulnerabilities 

exposed by the December 25, 2009, attempted attack, including actions 

taken by CBP and TSA. DHS also noted that it is committed to working 

with interagency stakeholders, including the Interagency Policy 

Committee, to ensure that its use of the watchlist in its screening 

programs is achieving intended results.50 DHS also provided technical 

comments, in addition to its written comments. National Security Staff; the 

Office of the Director of National Intelligence; and the Departments of 

Defense, Justice, and State did not provide written comments to include 

in this report, but provided technical comments, which we have 

incorporated in this report where appropriate. The CIA did not provide any 

comments.

We are sending copies of this report to National Security Staff; the 

Attorney General; the Secretaries of the Departments of Defense, 

Homeland Security, and State; the Directors of National Intelligence and 

 

50DHS’s written comments are not included in this report because the department 

considered them to be Sensitive Security Information.

Recommendations for 

Executive Action

Agency Comments
 

Page 30 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Central Intelligence; and appropriate congressional committees. This 

report is also available at no charge on the GAO website at 

http://www.gao.gov.

Should you or your staff have any questions about this report, please 

contact Eileen R. Larence at (202) 512-6510 or larencee@gao.gov. Key 

contributors to this report are acknowledged in appendix V. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report.

Eileen R. Larence

Director

Homeland Security and Justice Issues
 

Page 31 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

List of Requesters

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable John F. Tierney

Ranking Member

Subcommittee on National Security, Homeland Defense and Foreign

 Operations

Committee on Oversight and Government Reform

House of Representatives

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Brian Higgins

Ranking Member

Subcommittee on Counterterrorism and Intelligence

Committee on Homeland Security

House of Representatives

The Honorable Sheila Jackson Lee

Ranking Member

Subcommittee on Transportation Security

Committee on Homeland Security

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Our reporting objectives were to determine (1) the actions the federal 

government has taken since the December 25, 2009, attempted attack to 

strengthen the watchlist nominations process, the extent to which 

departments and agencies are experiencing challenges in implementing 

revised watchlisting guidance, and the extent to which agencies are 

assessing impacts of the actions they have taken; (2) how the 

composition of the watchlist has changed as a result of actions taken by 

departments and agencies after the attempted attack; and (3) how 

screening and law enforcement agencies are addressing vulnerabilities 

exposed by the attempted attack as well as the outcomes of related 

screening, and to what extent federal agencies are assessing the impacts 

of this screening.

In general, we focused on the federal entities that were tasked by the 

Executive Office of the President to take corrective actions after the 

attempted attack:1 the Department of Homeland Security (DHS); 

Department of Justice’s Federal Bureau of Investigation (FBI) and 

Terrorist Screening Center (TSC); Department of State (State); 

Department of Defense; Office of the Director of National Intelligence’s 

National Counterterrorism Center (NCTC); Central Intelligence Agency 

(CIA); and Executive Office of the President’s National Security Staff.2

To determine actions the federal government has taken to strengthen the 

watchlist nominations process, we analyzed postattack government 

reports, including reports issued by the Executive Office of the President 

and the Senate Select Committee on Intelligence.3

 

1

Executive Office of the President, Memorandum on Attempted Terrorist Attack on 

December 25, 2009: Intelligence, Screening, and Watchlisting System Corrective Actions

(Washington, D.C.: Jan. 7, 2010).

We analyzed the 

2

NCTC—within the Office of the Director of National Intelligence—serves as the primary 

organization in the U.S. government for, among other things, analyzing and integrating all 

intelligence pertaining to terrorism and counterterrorism, except for intelligence pertaining 

exclusively to domestic terrorists and domestic counterterrorism. See 50 U.S.C. § 

404o(d)(1).

3

Executive Office of the President, Summary of the White House Review of the December 

25, 2009, Attempted Terrorist Attack (Washington, D.C.: Jan. 7, 2010), and Senate Select 

Committee on Intelligence, Unclassified Summary of the Committee Report on the 

Attempted Terrorist Attack on Northwest Airlines Flight 253 (Washington, D.C.: May 18, 

2010).

Appendix I: Objectives, Scope, and 

Methodology 

Objectives

Scope and 

Methodology

Watchlist Nominations 

Process
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Watchlisting Guidance that was approved in July 2010 and compared it to 

the February 2009 watchlisting protocol—the last version that was 

published before the attempted attack—to identify changes that were 

intended to strengthen agencies’ abilities to nominate known or 

suspected terrorist to the watchlist. We interviewed officials from five 

entities that nominate individuals for inclusion on the terrorist watchlist, as 

well as NCTC’s Deputy Director for the Terrorist Identities and TSC’s 

Director.4 We also met with officials from the Executive Office of the 

President’s Information Sharing and Access Interagency Policy 

Committee and its Subcommittee on Watchlisting, which provides an 

interagency forum to which agencies can bring watchlist-related issues for 

discussion and resolution.5

To identify to what extent agencies are experiencing challenges 

implementing changes to the watchlisting guidance, we analyzed data 

and documentation provided by seven federal entities involved in the 

nominations process—such as nominations data for the period January 

2009 through May 2011—as well as the congressional testimony of 

NCTC, TSC, and FBI leadership and program directors.6

To determine to what extent agencies are assessing for the impacts of 

the actions they have taken, we interviewed officials from five federal 

entities who participate in the Information Sharing and Access 

We also 

interviewed the watchlisting unit directors and program staff at each of the 

five nominating agencies, NCTC’s Deputy Director for the Terrorist 

Identities, and the TSC Director to discuss their nominations processes, 

the number of nominations they send to NCTC, and how, if at all, the 

changes to the nominations process have created challenges for each 

agency.

 

4

In general, a nominating agency is any federal department or agency that has 

determined that an individual is a known or suspected terrorist and nominates that 

individual for inclusion in Terrorist Identities Datamart Environment (TIDE) database and 

the Terrorist Screening Database (TSDB).

5

The Interagency Policy Committees are the main day-to-day forums for interagency 

coordination of national security policy, providing policy analysis and ensuring timely 

responses to decisions made by the President. See, Presidential Policy Directive 1,

Organization of the National Security Council System (Feb. 13, 2009). 

6

Regarding nominations data, we did not review or assess the derogatory information 

available on individuals nominated to the terrorist watchlist, partly because such 

information involved ongoing counterterrorism or counterintelligence investigations.
Appendix I: Objectives, Scope, and 

Methodology 

Page 34 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Interagency Policy Committee’s Subcommittee on Watchlisting and 

related working groups.

To identify how the composition of the watchlist has changed since the 

attempted attack, we reviewed TSC data from late December 2009 

through March 2010 on the number of individuals who were added to 

TSC’s Terrorist Screening Database and its subset No Fly and Selectee 

lists that are used to screen airline passengers before boarding, and 

related efforts to determine whether the individuals should remain on 

these lists.7 To identify broader trends in the size and composition of the 

watchlist and subset lists, we reviewed TSC monthly data for 2009 and 

2010 on the number of individuals on these lists, including U.S. citizens 

and lawful permanent residents. We also determined how the revised 

watchlisting guidance has impacted the size of these lists. Further, we 

interviewed senior-level officials from TSC and NCTC to identify factors 

that contributed to trends in the size of the lists during 2009 and 2010, 

and to obtain their perspectives on how changes in the watchlist guidance 

had impacted growth in the lists.

To identify how screening and law enforcement agencies have addressed 

vulnerabilities exposed by the attempted attack and how they are 

assessing the outcomes and impacts of screening or vetting, we focused 

on the departments and agencies that use the watchlist to screen 

individuals traveling to the United States—the Transportation Security 

Administration (TSA), which screens passengers before they board 

aircraft; U.S. Customs and Border Protection (CBP), which inspects 

travelers to determine their admissibility into the United States; and State, 

which screens individuals who apply for U.S. visas.

To determine agency actions to address vulnerabilities in screening or 

vetting and related outcomes, we analyzed TSA, CBP, and State 

documentation—such as documents that discuss new or expanded 

screening programs—as well as testimonies and inspector general 

reports. We obtained data—generally for 2009 and 2010 but in some 

cases through May 2011—on how often these agencies have 

 

7

In general, individuals on the No Fly List are to be precluded from boarding an aircraft, 

and individuals on the Selectee List are to receive additional screening prior to boarding 

an aircraft.

Composition of the 

Watchlist

Screening and Law 

Enforcement Agency 

Actions
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

encountered individuals on the watchlist and the outcomes of these 

encounters to help determine what impact changes in agency screening 

or vetting procedures has had on operations and the traveling public, 

among other things. We also interviewed senior-level officials from these 

agencies; these interviews included discussions about how agencies’ 

screening or vetting procedures have changed since the attempted attack 

and how they are assessing the impacts of the changes. Further, to better 

understand the impacts of watchlist screening or vetting on the traveling 

public, we analyzed data for 2009 and 2010 on individuals who had 

inquiries or sought resolution regarding difficulties they experienced 

during their travel-related screening or inspection and interviewed DHS 

officials who are responsible for providing redress for these individuals. 

Regarding federal government efforts to assess the outcomes and 

impacts of actions agencies have taken to strengthen screening or vetting 

processes since the December 2009 attempted attack, we obtained 

information on the extent to which federal monitoring activities and 

practices are consistent with GAO’s Standards for Internal Control in the 

Federal Government.8

To assess the reliability of data on watchlist nominations, number of 

watchlist records in databases, and screening outcomes, we interviewed 

knowledgeable officials about the data and the systems that produced the 

data, reviewed relevant documentation, examined data for obvious errors, 

and (when possible) corroborated the data among the different agencies. 

We determined that the data were sufficiently reliable for the purposes of 

this report. We conducted this performance audit from February 2010 to 

May 2012 in accordance with generally accepted government auditing 

standards. 9

 

8

GAO, Standards for Internal Control in the Federal Government, 

Those standards require that we plan and perform the audit 

to obtain sufficient, appropriate evidence to provide a reasonable basis

for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

9

We issued a classified report on this work in December 2011. 
Appendix II: Overview of the Watchlist 

Nominations Process 

Page 36 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Pursuant to Homeland Security Presidential Directive 6, the Terrorist 

Screening Center (TSC) was established to develop and maintain the 

U.S. government’s consolidated watchlist—the Terrorist Screening 

Database (TSDB)—and to provide for the use of watchlist records during 

security-related screening processes.1

TSC receives watchlist information for inclusion in the TSDB from two 

sources: the National Counterterrorism Center (NCTC) and the Federal 

Bureau of Investigation (FBI). TSC receives the vast majority of its 

watchlist information from NCTC, which compiles information on known or 

suspected international terrorists from executive branch departments and 

agencies—such as the Central Intelligence Agency (CIA), Department of 

State (State), and the FBI—and maintains the information in its Terrorist 

Identities Datamart Environment (TIDE) database.

The watchlisting and screening 

processes are intended to support the U.S. government’s efforts to 

combat terrorism by consolidating the terrorist watchlist and providing 

screening and law enforcement agencies with information to help them 

respond appropriately during encounters with known or suspected 

terrorists, among other things.

2

• engage in international terrorist activity;

According to NCTC, 

the TIDE database includes, to the extent permitted by law, all information 

the U.S. government possesses related to the identities of individuals 

known or suspected to be or have been involved in activities constituting, 

in preparation for, in aid of, or related to terrorism, with the exception of 

purely domestic terrorism information. Examples of conduct that will 

warrant an entry into TIDE include persons who

• prepare or plan international terrorist activity;

• gather information on potential targets for international terrorist 

activity;

• solicit funds or other things of value for international terrorist activity or 

a terrorist organization;

• solicit membership in an international terrorist organization;

• provide material support, such as a safe house, transportation, 

communications, funds, transfer of funds or other material financial 

 

1

Homeland Security Presidential Directive 6: Integration and Use of Screening Information 

(Sept. 16, 2003).

2

TIDE is the U.S. government’s central repository of information on known or suspected 

international terrorists and is maintained by NCTC.

Appendix II: Overview of the Watchlist 

Nominations Process
Appendix II: Overview of the Watchlist 

Nominations Process

Page 37 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

benefit, false documentation or identification, weapons, explosives, or 

training; or

• are members of or represent a foreign terrorist organization.3

In general, nominating agencies submit terrorism-related information to 

NCTC to add information to existing records in TIDE as well as to 

nominate new individuals to be included in TIDE, with the additional 

purpose of nominating known or suspected terrorists to the TSDB.

Nominations are to include pertinent derogatory information and any 

biographic information—such as name and date of birth—needed to 

establish the identity of individuals on the watchlist.

The FBI provides TSC with information about known or suspected 

domestic terrorists. According to the FBI’s Domestic Terrorist Operations 

Unit, domestic terrorists engage in activities that (1) involve acts 

dangerous to human life that are a violation of the criminal laws of the 

United States or any state; (2) appear to be intended to intimidate or 

coerce a civilian population, influence the policy of a government by 

intimidation or coercion, or affect the conduct of a government by mass 

destruction, assassination, or kidnapping; and (3) occur primarily within 

the jurisdiction of the United States.4

In general, the FBI nominates individuals who are subjects of ongoing FBI 

counterterrorism investigations to TSC for inclusion in the TSDB, 

including persons the FBI is preliminarily investigating to determine if they 

have links to terrorism. In determining whether to open an investigation, 

the FBI uses guidelines established by the Attorney General, which 

contain specific standards for opening investigations. The FBI also has a 

process for submitting requests to NCTC to nominate known or 

suspected international terrorists who are not subjects of FBI 

investigations.

In accordance with Homeland Security Presidential Directive 6—and built 

upon through Homeland Security Presidential Directives 11 and 24—the 

TSDB is to contain information about individuals known or suspected to 

 

3

In general, these types of conduct are related to provisions in the Immigration and 

Nationality Act that establishes grounds for alien admissibility on terrorist-related grounds. 

See, e.g., 8 U.S.C. § 1182(a)(3) (codifying section 212(a)(3) of the Immigration and 

Nationality Act, as amended). 

4

See 18 U.S.C. § 2331(5).
Appendix II: Overview of the Watchlist 

Nominations Process

Page 38 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

be or have been engaged in conduct constituting, in preparation for, in aid 

of, or related to terrorism and terrorist activities.5

Once NCTC and the FBI determine that an individual meets the 

reasonable-suspicion standard and that minimum biographic information 

exists, they extract sensitive but unclassified information on the 

individual’s identity—such as name and date of birth—from their classified 

databases and send the information to TSC. TSC reviews these 

nominations—evaluating the derogatory and biographic information, in 

accordance with the watchlisting guidance—to determine whether to add 

nominated individuals to the TSDB. As TSC adds individuals to the 

watchlist, the list may include persons with possible ties to terrorism in 

addition to people with known links, thereby establishing a broad 

spectrum of individuals who are considered known or suspected 

terrorists. Figure 2 provides an overview of the process used to nominate 

individuals for inclusion in the TSDB.

NCTC and the FBI apply 

a reasonable-suspicion standard to determine which individuals are 

appropriate for inclusion in the TSDB. Determining whether individuals 

meet this standard, however, can involve some level of subjectivity. 

NCTC and the FBI are to consider information from all available sources 

and databases—including information forwarded by nominating agencies 

as well as information in their own holdings—to determine if there is a 

reasonable suspicion of links to terrorism that warrants a nomination.

 

5

See, Homeland Security Presidential Directive 11: Comprehensive Terrorist-Related 

Screening Procedures (Aug. 27, 2004) and Homeland Security Presidential Directive 24: 

Biometrics for Identification and Screening to Enhance National Security (June 5, 2008).
Appendix II: Overview of the Watchlist 

Nominations Process

Page 39 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Figure 2: Overview of the Watchlist Nominations Process

Consistent with Homeland Security Presidential Directive 6, to ensure that 

watchlist information is current, accurate, and complete, nominating 

agencies generally are to provide information to remove an individual 

from the watchlist when it is determined that no nexus to terrorism exists.

To support agency screening or law enforcement processes, TSC sends 

applicable records from the TSDB to screening or law enforcement 

agency systems for use in efforts to deter or detect the movement of 
Appendix II: Overview of the Watchlist 

Nominations Process

Page 40 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

known or suspected terrorists. For instance, applicable TSC records are 

provided to TSA for use in screening airline passengers, to U.S. Customs 

and Border Protection (CBP) for use in vetting and inspecting persons 

traveling to and from the United States, and to State for use in screening 

visa applicants. Regarding individuals who are not citizens or nationals of 

the United States seeking travel to and entry into the United States, 

screening and law enforcement agencies rely on immigration laws that 

specify criteria and rules for deciding whether to issue visas to individuals 

or to admit them into the country.6 In many instances, individuals who are 

not citizens or nationals of the United States who have engaged in or are 

likely to engage in terrorist-related activities may be ineligible to receive 

visas or inadmissible for entry to the United States, or both. If a foreign 

citizen is lawfully admitted into the United States—either permanently or 

temporarily—and subsequently engages in or is likely to engage in a 

terrorist activity, the individual, in certain circumstances, may be removed 

to his or her country of citizenship. U.S. citizens returning to the United 

States from abroad are not subject to the admissibility requirements of the 

Immigration and Nationality Act, regardless of whether they are subjects 

of watchlist records. In general, these individuals only need to establish 

their U.S. citizenship to the satisfaction of the examining officer—by, for 

example, presenting a U.S. passport—to obtain entry into the United 

States.7

 

6

See, e.g., 8 U.S.C. § 1182 (codifying § 212 of the Immigration and Nationality Act, as 

amended, and establishing conditions under which an alien—any person not a citizen or 

national of the United States—may be deemed ineligible for a visa or inadmissible to the 

United States). 

U.S. Citizens are subject to inspection by CBP before being 

permitted to enter, and additional actions may be taken, as appropriate.

7

See 8 C.F.R. § 235.1. Similarly, lawful permanent residents generally are not regarded 

as seeking admission to the United States and are not subject to the grounds for 

inadmissibility unless they fall within certain criteria listed at 8 U.S.C. § 1101(a)(13)(C) that 

describe why an alien lawfully admitted for permanent residence would be regarded as 

seeking admission. Lawful permanent residents, however, may be subject to the grounds 

of removability under 8 U.S.C. § 1227(a) after admission.
Appendix III: Transportation Security 

Administration’s Secure Flight Program and 

Related Activities

Page 41 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

This appendix presents an overview of the Transportation Security 

Administration’s (TSA) Secure Flight program, which began 

implementation before the December 25, 2009, attempted attack and is a 

key part of TSA’s efforts to address vulnerabilities that were exposed by 

the incident. This appendix also discusses how the program has reduced 

the likelihood of passengers misidentified as being on the watchlist and 

provides an update on the status of TSA efforts to validate the information 

that passengers report when making a reservation that is used in the 

watchlist-matching process.

The matching of airline passenger information against terrorist watchlist 

records is a frontline defense against acts of terrorism that target the 

nation’s civil aviation system. In general, passengers identified by the 

TSA as a match to the No Fly List are prohibited from boarding flights to, 

from, and within the United States, while those matched to the Selectee 

List are required to undergo additional screening prior to boarding such 

flights.1 Historically, airline passenger prescreening was performed by air 

carriers pursuant to federal requirements. However, in accordance with 

the Intelligence Reform and Terrorism Prevention Act of 2004, TSA 

developed an advanced passenger prescreening program known as 

Secure Flight that enabled TSA to assume from air carriers the function of 

watchlist matching.2

• eliminate inconsistencies in passenger watchlist matching procedures 

conducted by air carriers and use a larger set of watchlist records 

when warranted,

Secure Flight is intended to

• reduce the number of individuals who are misidentified as being on 

the No Fly or Selectee lists,

• reduce the risk of unauthorized disclosure of sensitive watchlist 

information, and

 

1

The No Fly and Selectee lists are subsets of the consolidated terrorist watchlist that is 

maintained by the Federal Bureau of Investigation’s Terrorist Screening Center. 

2

See Pub. L. No. 108-458, § 4012(a), 118 Stat. 3638, 3714-18 (2004) (codified at 49 

U.S.C. § 44903(j)(2)(C)). See also Secure Flight Program; Final Rule, 73 Fed. Reg. 

64,018 (Oct. 28, 2008).

Appendix III: Transportation Security 

Administration’s Secure Flight Program and 

Related Activities 

Secure Flight 

Overview
Appendix III: Transportation Security 

Administration’s Secure Flight Program and 

Related Activities

Page 42 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

• integrate information from DHS’s redress process into watchlist 

matching so that individuals are less likely to be improperly or unfairly 

delayed or prohibited from boarding an aircraft.3

In January 2009, the Secure Flight program began initial operations—

assuming the watchlist-matching function for a limited number of 

domestic flights for one airline—and subsequently phased in additional 

flights and airlines. TSA completed assumption of this function for all 

domestic and international flights operated by U.S. air carriers in June 

2010 and completed assumption of this function for covered foreign air 

carriers flying to and from the United States in November 2010.4

Since the December 2009 attempted attack, TSA has completed its 

assumption of the watchlist-matching function from air carriers—under the 

Secure Flight program—which has reduced the likelihood of passengers 

misidentified as being on the watchlist. According to TSA data, Secure 

Flight is consistently clearing over 99 percent of passengers automatically 

(less than 1 percent of passengers are being misidentified as being on 

the No Fly List or Selectee List). When misidentifications occur, a 

passenger may not be able to print a boarding pass from a computer or

an airport kiosk. Rather, the individual may have to go to the airline ticket 

counter to provide identifying information that is used to determine if the 

person is a positive match to the No Fly List or Selectee List. Before 

Secure Flight, more passengers had to go through this process to verify 

their identities, since each airline conducted watchlist matching differently 

with varying effectiveness.

The Secure Flight program increases the effectiveness of watchlist 

matching, applying an enhanced watchlist-matching system and process 

consistently across the airline industry. Under Secure Flight, air carriers 

are required to (1) collect full name and date-of-birth and gender 

information from airline passengers and (2) be capable of collecting 

 

3

See GAO, Aviation Security: TSA Has Completed Key Activities Associated with 

Implementing Secure Flight, but Additional Actions Are Needed to Mitigate Risks,

GAO-09-292 (Washington, D.C.: May 13, 2009). In general, the term redress refers to an 

agency’s complaint resolution process whereby individuals may seek resolution of their 

concerns about an agency action.

4

Secure Flight also performs this screening function for covered airline flights that travel 

over the continental United States and “point-to-point” international flights operated by 

covered U.S.-based airlines.

Secure Flight Has 

Reduced 

Misidentifications
Appendix III: Transportation Security 

Administration’s Secure Flight Program and 

Related Activities

Page 43 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

redress control numbers from passengers.5

Further, people who have been denied or delayed airline boarding, have 

been denied or delayed entry into or exit from the United States at a port 

of entry or border crossing; or have been repeatedly referred to additional 

(secondary) inspection can file an inquiry to seek redress. After 

completing the redress process—which includes submitting all applicable 

documents—an individual will receive a redress control number that may 

facilitate future travel. For example, airline passengers who have 

completed the redress process and are determined by DHS as not being 

the subject of a watchlist record are put on the department’s list of 

individuals who are “cleared” to travel. Using the redress control number 

when making reservations for future travel may help to prevent 

misidentifications.

Collecting such information 

helps reduce misidentifications. According to TSA, Secure Flight is 

required to submit an annual report to the Office of Management and 

Budget certifying that the program has met its baseline goal for reducing 

misidentifications.

To mitigate future risks of performance shortfalls and strengthen 

management of the Secure Flight program moving forward, in May 2009, 

we recommended that TSA periodically assess the performance of the 

Secure Flight system’s matching capabilities and results to determine 

whether the system is accurately matching watchlisted individuals while 

minimizing the number of false positives, consistent with the goals of the 

program; document how this assessment will be conducted and how its 

results will be measured; and use these results to determine whether the 

system settings should be modified.6

TSA has developed performance measures to report on and monitor 

Secure Flight’s name matching capabilities. According to TSA, Secure 

Flight leadership reviews the daily reports, which reflect quality, match 

rate, false positive rates, and other metrics. Reviews are to include 

analysis, discussion with program leadership, and identification of 

 TSA’s actions discussed below fully 

respond to the recommendation we made in our May 2009 report.

 

5

The Secure Flight Final Rule provides that air carriers must request a passenger’s full 

name, gender, date of birth, and Redress or Known Traveler Number (if available), but it 

only requires that passengers provide their full name, gender, and date of birth.

6

GAO-09-292. 
Appendix III: Transportation Security 

Administration’s Secure Flight Program and 

Related Activities

Page 44 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

process and data quality improvements to increase efficiency and reduce 

possible false positive matches to the watchlist. In addition, DHS 

established a multidepartmental Match Review Board Working Group and 

a Match Review Board to, among other things, review the performance 

measures and recommend changes to improve system performance. 

According to TSA, the working group meets on a biweekly basis and the 

board meets monthly, or as required, to review working group findings 

and to make system change recommendations. For example, the board 

has recommended changes in the threshold used for determining whether 

an individual is a match to a watchlist record and has decided to 

implement additional search tools to enhance Secure Flight’s automated 

name-matching capabilities. Furthermore, TSA plans to periodically 

assess the extent to which the Secure Flight program fails to identify 

individuals who are actual matches to the watchlist.
Appendix IV: Redress Process for Individuals 

Experiencing Difficulties during Travel-Related 

Screening and Inspection 

Page 45 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

The DHS Traveler Redress Inquiry Program (DHS TRIP) is a single point 

of contact for individuals who have inquiries or seek resolution regarding 

difficulties they experienced during their travel screening at transportation 

hubs—like airports and train stations—or crossing U.S. borders, including

• watchlist issues;

• inspection problems at ports of entry; and

• situations where travelers believe they have been unfairly or 

incorrectly delayed, denied boarding, or identified for additional 

screening or inspection at our nation’s transportation hubs.

While serving as the point of contact for the receipt, tracking, and 

response to redress applications, DHS TRIP generally refers cases to the 

appropriate screening agency for review and adjudication.

According to DHS TRIP officials, since the December 2009 attempted 

attack, the office implemented a new procedure to ensure that (1) the 

office is promptly notified when an individual who is determined by DHS 

TRIP as not being the subject a watchlist record—and, therefore, has 

been put on the department’s list of individuals who are “cleared” to

travel—is subsequently added to the watchlist and (2) redress applicants 

are provided additional information regarding the resolution of their cases. 

Prior to the attempted attack, DHS TRIP would conduct electronic 

comparisons once each day to ensure that someone who had been 

cleared as a result of the redress process had not subsequently been 

added to the watchlist. Since the attempted attack, DHS TRIP now 

conducts continuous checks (on a 24/7 basis) of cleared individuals 

against the watchlist every time the watchlist is updated. According to 

DHS TRIP officials, this change provides the office immediate notification 

if an individual who is cleared through the redress process is 

subsequently added to the watchlist. In turn, DHS TRIP officials can alert 

screening agencies more quickly that an individual should not be cleared 

if encountered during screening.

Separately, DHS TRIP—at the direction of the Secretary of Homeland 

Security and in partnership with the Terrorist Screening Center (TSC), 

Departments of Justice and State, Federal Bureau of Investigation (FBI), 

and other members of the interagency redress community—has taken 

steps intended to help provide transparency to redress applicants 

regarding the resolution of their cases.

Appendix IV: Redress Process for Individuals 

Experiencing Difficulties during TravelRelated Screening and Inspection 

Changes to DHS TRIP 

Watchlist-Related 

Procedures since the 

Attempted Attack
Appendix IV: Redress Process for Individuals 

Experiencing Difficulties during Travel-Related 

Screening and Inspection 

Page 46 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

According to DHS TRIP data, individuals submitted approximately 32,000 

applications for redress during 2009 and 36,000 applications during 

2010.1

According to DHS TRIP, less than 1 percent of individuals who apply for 

redress have been confirmed matches to the watchlist or have identifying 

information (e.g., name and date of birth) that closely matches someone 

on the watchlist. In such cases, DHS TRIP forwards the inquiry to TSC for 

resolution. TSC data show that the government has procedures in place 

to review the information that supports a watchlist record upon receipt of 

a redress inquiry and has revised the watchlist status of individuals based 

on these reviews. We did not review the effectiveness of these 

procedures.

The DHS TRIP redress application asks travelers to identify their 

areas of concern, but the information collected generally does not allow 

DHS TRIP officials to determine if individuals were misidentified as being 

on the watchlist. DHS TRIP officials explained that since the application 

allows travelers to list multiple reasons for applying—and the individuals 

generally do not know why they were subject to additional screening, 

inspection, or delay—the office cannot conclude with certainty that being 

misidentified as being on the watchlist was the cause of an applicant’s 

inconvenience. In late 2009, as part of the rollout of TSA’s Secure Flight 

program, several air carriers instituted a public awareness campaign 

encouraging travelers to submit redress inquiries if they believed that they 

have been misidentified in the past. Finally, DHS TRIP officials noted that 

individual screening and law enforcement agencies are in the best 

position to understand if their screening and law enforcement systems 

and procedures incorrectly identify individuals as matches with watchlist 

records. The officials explained that these agencies have access to more 

detailed records that would identify reasons for a delay or inconvenience, 

including a misidentification to the watchlist.

 

1

According to DHS TRIP officials, these numbers could include multiple inquiries from 

individuals providing additional supporting documentation, reapplying regarding the same 

issue, or reporting other travel-related difficulties. In addition, the officials said that a small 

number of inquiries are related to misdirected communications sent to DHS TRIP from 

outside parties, including law offices.

DHS TRIP Redress 

Data and Related 

Information
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 47 GAO-12-476 Terrorist Watchlist Nominations and Screening Processes 

Eileen R. Larence, (202) 512-6510 or larencee@gao.gov

In addition to the contact named above, Eric Erdman, Assistant Director; 

Mona Blake; Jeffrey DeMarco; Michele Fejfar; Lisa Humphrey; Richard 

Hung; Thomas Lombardi; Linda Miller; Victoria Miller; Jan Montgomery; 

Timothy Persons; and Michelle Woods made key contributions to this 

report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(441047)
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