United States General Accounting Office

GAO Report to the Honorable

Dianne Feinstein, U.S. Senate

July 1998 CUSTOMS SERVICE

DRUG INTERDICTION

Internal Control

Weaknesses and Other

Concerns With

Low-Risk Cargo Entry

Programs

GAO/GGD-98-175

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-279229 

July 31, 1998

The Honorable Dianne Feinstein

United States Senate

Dear Senator Feinstein:

The Customs Service faces a major challenge in effectively carrying out its

drug interdiction and trade enforcement missions while facilitating the

flow of persons and cargo into the United States. To assist in performing

these seemingly contradictory activities, Customs recognized that because

of the high volume of imported cargo entering the country, processes were

needed to identify low-risk cargo and facilitate its movement so that

inspectors could focus on shipments that were potentially higher risk for

narcotics smuggling. Toward this end, Customs developed several

low-risk, cargo entry programs designed to process certain cargo

expeditiously and at the same time target, for additional scrutiny, those

shipments considered to be high risk for drug smuggling.

In response to your request that we review Customs’ drug-enforcement

operations along the Southwest border of the United States, this report

describes Customs’ low-risk, cargo entry programs in use at three ports on

the Southwest border and discusses the results of our evaluation of the

internal controls over the Line Release Program and processes used to

assess the risk of narcotics smuggling in other cargo entry programs. In

developing information for this report, we (1) interviewed key officials and

reviewed program documents at Customs’ headquarters and at three

Customs Management Centers located along the Southwest border and

(2) visited three cargo ports of entry—Otay Mesa, CA; Laredo, TX; and

Nogales, AZ. At each port we visited, we interviewed key officials,

reviewed program documents, and observed cargo entry

processes—including inspection and enforcement activities—used by the

ports to detect illegal drugs. Our objectives, scope, and methodology are

discussed in more detail in appendix I. Appendix II describes the three

ports we visited.

We requested comments on a draft of this report from the Secretary of the

Treasury or his designee. The Under Secretary (Enforcement) provided

written comments, which are discussed near the end of this letter and

reprinted in appendix III. We performed our work between November

1997 and May 1998 in accordance with generally accepted government

auditing standards.

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Results in Brief To balance the objectives of facilitating trade through ports and

interdicting illegal drugs being smuggled into the United States, Customs

has initiated and encouraged its ports to use several programs to identify

and separate “low-risk” shipments from those with apparently higher

smuggling risk. One such program is the Line Release Program, designed

to expedite cargo shipments that Customs determined to be repetitive,

high volume, and low risk for narcotics smuggling. Beginning on the

Northern border in 1986 and expanded to most ports along the Southwest

border by 1989, this program requires importers, brokers (companies who

process the paperwork required to import merchandise) and

manufacturers to apply for the program and to be screened by Customs to

ensure that they have no past history of narcotics smuggling and that their

prior shipments have been in compliance with trade laws and Customs’

commercial importing regulations. In 1996, Customs implemented the

Carrier Initiative Program; this program required that Line Release

shipments across the Southwest border be transported by

Customs-approved carriers—trucks and trucking companies—and driven

by Customs-approved drivers. After the Carrier Initiative Program was

implemented, the number of Southwest border Line Release shipments

dropped significantly.

We identified internal control weaknesses in one or more of the processes

used at each of the three ports we visited to screen Line Release

applicants for entry into the program. These weaknesses included (1) lack

of specific criteria for determining applicant eligibility at two of the three

ports, (2) incomplete documentation of the screening and review of

applicants at two of the three ports, and (3) lack of documentation of

supervisory review and approval of decisions. We also noted that the ports

were not able to locate some of the application files and background

checklists that served as support for approving applications. Further,

although one port had implemented a recertification process based on

volume of shipments, the other two ports did not require program

participants to be recertified. In May 1998, Customs representatives from

northern and southern land-border cargo ports approved draft Line

Release volume and compliance eligibility criteria for program applicants

and draft recertification standards for program participants; Customs

expects to finalize and issue these standards by the end of fiscal year 1998.

The Three Tier Targeting Program—a method of targeting high-risk

shipments for narcotics inspection—was being used at the three

Southwest border ports that we visited. Customs published draft guidance,

which was never finalized, to help ports classify cargo shipments into

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three tiers, from little risk to significant risk for narcotics smuggling.

Customs officials were unable to explain why the guidance had never been

finalized.

According to officials at the three ports we reviewed, the Three Tier

Targeting Program had two operational problems that contributed to their

loss of confidence in the program’s ability to distinguish high- from

low-risk shipments: (1) there was little information available in any

database for researching foreign manufacturers; and (2) local officials

doubted the reliability of the designations, citing some examples of

narcotics seizures from shipments designated as “low-risk,” and the lack of

a significant number of seizures from shipments designated as “high-risk.”

In addition, they said that the research necessary to assign and recertify

tier designations was very time consuming given the questionable

reliability of the designations.

One new targeting method—the Automated Targeting System—is being

pilot tested at Laredo. Used in conjunction with the Prefile Program, this

system is designed to enable port officials to identify and direct

inspectional attention to high-risk shipments. Under the Prefile Program,

port analysts are to receive entry information on an expected shipment at

least 4 hours before the shipment arrives at the port. Receiving this

information in advance should enable ports to research Customs and other

databases for information on the manufacturer, importer, and broker; this

research, which is to include a review of companies’ trade compliance

history and a criminal record check, can help inspectors determine

whether the shipment is high risk for narcotics smuggling. The Automated

Targeting System, which automatically assesses shipment entry

information for known smuggling indicators, is designed to enable

inspectors to target high-risk shipments more efficiently. However, the

Prefile Program, used in conjunction with the Automated Targeting

System, does not require companies to use carriers approved under the

Carrier Initiative Program. This is a significant disadvantage because past

seizures have indicated that most illegal drugs are smuggled in the

conveyance, not in the cargo. Also, Customs is in the process of evaluating

the Automated Targeting System, as tested at Laredo, for expansion to

other land-border cargo ports.

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Background The Office of National Drug Control Policy has reported1

 that international

drug trafficking organizations have become sophisticated,

multibillion-dollar industries that quickly adapt to new U.S. drug control

efforts. According to Customs’ Strategic Plan: Fiscal Years 1997 - 2002,

drug smugglers have moved from (1) using small planes and fast boats to

smuggle drugs into the Southeastern United States in the early 1980s, to

(2) using commercial cargo and international carriers in the mid- to

late-1980s, and (3) exploiting the Southwest border in the 1990s.

In addition to collecting revenue from international trade, the mission of

the Customs Service is to enforce customs and related laws. It also

processes persons, carriers, cargo, and mail into and out of the United

States. One of Customs’ major goals is to prevent the smuggling of drugs

into the country by creating an effective drug interdiction, intelligence,

and investigation capability that disrupts and dismantles smuggling

organizations.

Customs performs its mission with a workforce of about 19,000 personnel

at its headquarters in Washington, D.C., and at 20 Customs Management

Centers, 20 investigative offices, and 301 ports of entry around the

country. Of the 301 ports, 24 are located along the Southwest border

and—through 39 crossing points (such as bridges)—handle both

passengers and commercial cargo entering the United States. At the end of

fiscal year 1997, Customs had deployed about 28 percent of its inspectors

and about 62 percent of its canine enforcement officers at ports along the

Southwest border.

The Commissioner of Customs has designated drug enforcement to be

Customs’ highest priority. As 1 of more than 50 federal agencies involved

in the national drug control effort, Customs is responsible for stopping the

flow of illegal drugs through the nation’s ports of entry. Customs’

inspectional, investigative, intelligence, canine, marine, and air

interdiction assets combine with the efforts of other agencies to reduce

the supply of narcotics coming into the country. In addition to routine

(primary) inspections to search passengers, cargo, and conveyances

(including cars, buses, trucks, aircraft, and vessels), Customs’ drug

interdiction efforts include (1) preprimary and postprimary inspections;

(2) a more thorough, intensive inspection (secondary) of suspicious

shipments or those automatically selected by Customs’ computer system;

(3) canine enforcement inspections; (4) inspections using X-ray machines

1

Report to Congress, Volume 1, United States and Mexico Counterdrug Cooperation, Enhanced

Multilateral Drug Control Cooperation, and Enhanced Truck Inspections, Executive Office of the

President, Office of National Drug Control Policy, Sept. 1997.

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for cargo and trucks; and (5) inspections of randomly selected groups of

vehicles using canines and other inspection tools.

Internal Control

Weaknesses and

Other Issues Raise

Concerns About the

Line Release Program

Line Release is one of two programs the Customs Service is using at its

land-border cargo ports to segregate low-risk shipments from other

shipments. The Line Release Program was established on the assumption

that port officials would know enough about the companies—the brokers,

importers, and manufacturers—that participated in the program to assume

that they would be unlikely to smuggle drugs. Our review indicated that

the internal controls over the Line Release Program at three ports were lax

and that port officials could not be reasonably assured that companies

approved as low risk under this program should have been designated as

such and afforded the benefits that go with it.

Description of the Line

Release Program

The theory behind the Line Release Program is that companies that

routinely import goods through a port and are generally in compliance

with trade laws and Customs regulations pose significantly less risk for

drug smuggling than other companies. Customs believes that if ports could

identify and designate certain companies as low risk for drug smuggling,

inspectors would have more assurance that these companies’ shipments

may pose a lower risk than those of other companies. Truck drivers

transporting shipments for companies approved under the Line Release

Program are not required to stop inside the port at the dock to process

paperwork; this procedure expedites their entry processing, frees dock

space for trucks that are required to stop, and allows inspectors to focus

their attention on higher-risk shipments.2

The Line Release Program was first implemented in 1986 on the Northern

border and was designed to expedite the release and tracking of

high-volume, low-risk shipments by prescreening manufacturers, brokers,

and importers to ensure that they did not present a threat of drug

smuggling. In 1987, Customs began implementing the Line Release

Program at cargo ports along the Southwest border; by the end of 1989,

most of the major Southwest border cargo ports had fully implemented the

program.

2

Line Release shipments are subject to several types of enforcement actions, such as random

compliance and enforcement examinations.

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Customs’ regulations for the Line Release Program, which became

effective in 1992, are published in the Code of Federal Regulations.3

Customs port directors are responsible for screening, reviewing, and

approving Line Release applicants. Program applicants are required to

complete and submit an application to the port director for review and

approval.

In 1993, Customs issued guidance4

 on the administration and use of the

Line Release Program. According to Customs, this guidance combined all

the Line Release policies and procedures issued since the program’s

inception. The guidance instructed port directors to establish their own

procedures for screening, reviewing, and approving applications; and it

suggested that specific port personnel, such as import specialists, review

the applications. The guidance did not specify what criteria ports should

consider in approving applicants or what the reviews should entail,

although it did state that the purpose of the reviews would be to conduct

risk analyses of applicants to determine if they qualified for Line Release.

The guidance did not require port officials to maintain any specific

documentation on the review and approval process.

In August 1997, Customs developed national Draft Line Release Quality

Standards that, among other things, established volume and compliance

eligibility criteria for program applicants and recertification standards for

program participants. The volume criterion proposes that applicants

should have had “at least 50 shipments . . . within the previous 12 months

prior to the filing of the application.” The compliance criterion proposes

that the applicants should have had “at least five Customs intensive

examinations with no discrepant findings, or more than five Customs

examinations with no more than a 10 percent discrepancy rate.” The

recertification standards propose that Line Release participants be

reviewed at least annually to ensure they have had 50 shipments within the

preceding 12 months. Biennially, participants are to be reviewed to ensure

they have met a minimum compliance rate of 90 percent. In May 1998,

Customs convened a Line Release Conference in San Diego, CA, during

which representatives from northern and southern land-border cargo ports

discussed, among other things, the above eligibility criteria and

recertification standards, and agreed to finalize and issue the Line Release

Quality Standards at the end of fiscal year 1998.

3

See 19 C.F.R. § 142.41 - 142.52 (1997).

4

Customs Directive 099 5610-003 (Jan. 14, 1993).

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Each of the three ports we reviewed had developed a two-part process for

screening, reviewing, and approving Line Release applicants, although the

eligibility criteria and review procedures differed somewhat among the

ports. Part one of each port’s process involved screening applicants to

determine whether they met the port’s eligibility criteria for participating

in Line Release—a high-volume of shipments each year and a history of

compliance with trade laws and Customs commercial importing

regulations. The second part of each port’s process involved several

components, including (1) verification of the data submitted by the

applicants (i.e., verification of company name, address, identification

number, etc.); (2) review of the application by an import specialist to

ensure that, among other things, the commodity (merchandise) was

properly classified; and (3) a background check on the applicants to

ensure they had no past history of drug smuggling.

Each port had developed a Line Release checklist that was used to

evaluate the applications and track them through this process, as well as a

checklist that recorded the results of the background checks conducted

on applicants. Although the ports’ Line Release checklists varied, they

included some of the same elements, such as approval by an import

specialist and the Line Release coordinator. In addition, the checklists

used to record and track background checks also included many of the

same elements, such as name and address verifications, Internal Revenue

Service numbers, and smuggling history.

In July 1996, Customs implemented the Land Border Carrier Initiative

Program (Carrier Initiative Program). The program requires participating

carriers to be prescreened by Customs—through background checks and

site visits—and approved as low risk for drug smuggling. At the time this

program was implemented, Customs established a new requirement that

all Line Release participants (brokers, importers, and manufacturers) on

the Southwest border use carriers (trucks and drivers) approved under the

Carrier Initiative Program.

In fiscal year 1996, cargo entries5

 along the Southwest border totaled

1,408,7906

 of which 277,382 or about 20 percent, were Line Release entries.

In fiscal year 1997, total entries increased by nearly 15 percent to

1,617,445, while Line Release entries dropped by almost 29 percent to

5

Merchandise arriving at a U.S. port must be “entered” with Customs unless specifically exempted.

“Entry” refers to the required documentation filed with Customs to secure the release of imported

cargo from Customs’ custody. A shipment is a quantity of cargo that is transported together.

6

Includes only entries from cargo ports that also process Line Release entries (see table 1).

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197,344, or about 12 percent of total entries. Customs officials attributed

the drop in Line Release entries to the implementation of the Carrier

Initiative Program in July 1996. Of the three ports we reviewed, Otay Mesa

had the largest number of Line Release entries during fiscal years 1996 and

1997 (see table 1) and, in fiscal year 1997, the greatest number of

participants. Officials at the Laredo and Nogales cargo ports told us that

Line Release entries dropped significantly at their ports at the time the

Carrier Initiative Program went into effect. Laredo and Nogales officials

said companies did not want to participate in the program either because

they already had contracts with nonprogram carriers or because they did

not want to tie themselves to Carrier Initiative—approved carriers, many

of whom were located near the border and not the Mexican interior, where

many of the commodities were produced.

Table 1: Decline in Line Release

Entries Following Start of Land Border

Carrier Initiative Program

FY 1996a FY 1997

Location

Line Release

entries

Percent of total

entries

Line Release

entries

Percent of total

entries

Southwest

borderb

277,382 19.7% 197,344 12.2%

Otay Mesa, CA 91,730 39.9 90,172 35.6

Laredo, TX 43,665 12.0 18,834 4.1

Nogales, AZ 35,645 20.2 679 0.4

aThe Land Border Carrier Initiative Program started in July 1996.

bIncludes all Southwest border Line Release ports: Calexico, CA; Otay Mesa, CA; Tecate, CA;

Douglas, AZ; Nogales, AZ; San Luis, AZ; Brownsville, TX; Eagle Pass, TX; Laredo, TX; Hidalgo,

TX; Pharr, TX; Progresso, TX; and El Paso, TX.

Source: U.S. Customs Service.

Weak Internal Controls

Over the Line Release

Program at Three Ports

Although each of the three ports we reviewed had developed a process for

screening and approving applicants, we found internal control weaknesses

in the procedures actually followed. These weaknesses included (1) the

lack of specific criteria for determining applicant eligibility at two of the

three ports, (2) incomplete documentation of the screening and review of

applicants at two of the three ports, and (3) lack of documentation of

supervisory review and approval of decisions. We also noted that the ports

were not able to locate some of the application files and background

checklists that served as support for approving applications, and that two

ports had not recertified Line Release companies.

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Lack of Specific Criteria

for Determining Applicant

Eligibility at Two of the

Three Ports

Otay Mesa had specific criteria for determining program eligibility and had

established a standard review process for assessing Line Release

applicants. To be considered for the Line Release Program, applicants

were expected to have a minimum of 50 shipments during the 12 months

prior to filing an application and to have at least 5 negative examinations.7

However, until recently the other two ports—Nogales and Laredo—did not

have specific criteria by which reviewers were to judge an applicant’s

eligibility. Lack of specific eligibility criteria could allow individual

reviewers at a port to reach different conclusions about an applicant’s

eligibility.

The former and current Nogales Line Release coordinators told us that,

until recently, Nogales did not have specific eligibility criteria in place for

screening Line Release applicants. Instead, each application was to be

reviewed on a case-by-case basis. The current Line Release coordinator

said that in fiscal year 1997, to screen applicants, the port adopted the

volume and compliance criteria specified in Customs’ Draft Line Release

Quality Standards—50 shipments within the prior 12 months and at least 5

Customs intensive examinations with no discrepant findings. However, the

coordinator could not provide port guidance that addressed this change,

nor was the port’s Line Release checklist revised to reflect the new

eligibility criteria.

The Laredo Line Release coordinator told us that until recently, Laredo

had no specific eligibility criteria for volume and discrepancy rates, relying

instead on the Line Release coordinator’s subjective evaluation of

applicants. The coordinator said that applications are judged on a

case-by-case basis and that theoretically all companies are eligible for the

Line Release Program, except those that have a history of drug violations.

To be approved, Laredo requires that applicants can only have had

relatively minor compliance “discrepancies” or violations on their

examination records, with no record of drug violations. The Line Release

coordinator told us that in fiscal year 1997 Laredo also began using the

volume standard cited in Customs’ 1997 Draft Line Release Quality

Standards. However, the coordinator could not provide documentation to

substantiate this change, nor did the port’s Line Release checklist reflect

the new criteria.

7

Otay Mesa defined a “negative” examination, or inspection, of a shipment as one in which only

“minor” infractions, such as marking violations, of Customs trade laws and regulations—less than a

6 percent discrepancy rate—were found, and no illegal drugs were discovered.

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Incomplete Documentation of

the Screening and Review of

Applicants at Two of the Three

Ports

The Comptroller General’s Standards for Internal Controls in the Federal

Government (June 1983)8 requires that “documentation of transactions or

other significant events should be complete and accurate and should

facilitate tracing the transaction or event and related information from

before it occurs, while it is in process, to after it is completed” and that

transactions and other significant events be promptly recorded and

properly classified.

Officials at all three of the ports we visited said they routinely reviewed

applicants’ trade history—specifically, volume and compliance history—as

part of their Line Release review process. However, Otay Mesa did not

include volume and compliance history on the Line Release checklist, nor

did reviewing officials document in the files9

 we reviewed that this

information had been verified. In addition, 20 of the 46 Line Release

checklists10 we reviewed at Otay Mesa had not been fully completed. For

example, in 12 cases, review officials had failed to check off all applicable

review elements. For 8 of 46 Line Release checklists, reviewers had failed

to either sign and/or date the checklist. Also, one of the application files

did not have a Line Release checklist. None of the files we reviewed

contained supporting documentation—the Line Release coordinator told

us that the port did not require supporting documentation, such as

computer printouts of applicants’ trade histories. The Comptroller

General’s Standards for Internal Controls in the Federal Government

specifies that “Internal controls systems and all transactions and other

significant events are to be clearly documented, and the documentation is

to be readily available for examination.”

Both Laredo and Nogales had applicants’ trade history as an element to be

checked off on either their Line Release or background checklist. At

Laredo, 64 of the 65 background checklists we reviewed documented

applicants’ trade history—volume of shipments and compliance with

Customs regulations. In addition, 69 of the 72 Line Release checklists we

reviewed had been completed. At Nogales, the port could locate only one

8

Although these standards remain conceptually sound and are used throughout the federal

government, they are being updated and enhanced to recognize recent internal control evaluation

guidance developed by the private sector with assistance from us and others as well as to give greater

recognition to the increasing use of information technology.

9

At Otay Mesa, because the universe of participants was large, we randomly selected 42 applications,

approved between 1988 and 1997, for review. This sample was not large enough to be considered

representative of the universe of Line Release participants at Otay Mesa, and the results of our review

should not be projected beyond the sample. At Laredo and Nogales, because the universe of

participants was small, we reviewed the applications for all active participants on Line Release during

fiscal year 1997.

10Some Otay Mesa application files included more than one Line Release checklist.

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of the seven Line Release checklists associated with the application files

we reviewed. Although the applicants’ trade history was documented on

the checklist as required, the entire checklist had not been completed.

Further, the Nogales Line Release coordinator told us that there was no

port requirement to retain supporting documentation for record checks

conducted on Line Release applicants; however, one of the application

files we reviewed included supporting documentation. Laredo had

provided supporting documentation for 65 of the 66 files we reviewed.

Lack of Documentation of

Supervisory Review for Aspects

of the Review and Approval

Process

According to the Comptroller General’s Standards for Internal Controls in

the Federal Government,

• qualified and continuous supervision is to be provided to ensure that

internal control objectives are achieved. Assignment, review, and approval

of a staff’s work should result in the proper processing of transactions and

events including (1) following approved procedures and requirements;

(2) detecting and eliminating errors, misunderstandings, and improper

practices; and (3) discouraging wrongful acts from occurring or from

recurring.

We found that aspects of the ports’ Line Release review and approval

processes lacked documentation of supervisory review. At Otay Mesa, the

Line Release coordinator told us he is responsible for reviewing the Line

Release checklists to ensure they have been completed, signed, and dated.

The coordinator also said he is responsible for documenting the progress

of the application through the approval process but is not required to

review other officials’ research. None of the 46 checklists we reviewed

documented a supervisory review, either by the coordinator or his

supervisor. Further, the operations analyst told us there is no supervisory

review required for the background checks he performs on importers and

manufacturers.

The Laredo Line Release coordinator also told us that he is responsible for

ensuring that the port’s Line Release checklists are properly completed.

The coordinator said he reviews the research performed on the

applications, including the background checks and trade history recorded

on the background checklists, but there was no documentation of

supervisory review on either the 72 Line Release checklists or the 65

background checklists provided by the port.

At Nogales, applications are researched by the Line Release coordinator

and others, including import specialists. Although the Line Release

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checklist provides for the chief inspector to document whether the

application was approved or disapproved, the one checklist located by the

port did not indicate whether the chief inspector had reviewed the

checklist. According to the coordinator, the checklist used to document

background checks performed on applicants does not have to have

supervisory review.

Other Concerns About the

Line Release Approval

Process

Our work at the three ports raised other issues, which could compromise

the integrity of the Line Release Program. First, Nogales officials were

unable to locate two of the seven application files for the companies

currently using Line Release; in addition, they could only locate one of the

seven Line Release checklists identified with the application files. The

current and former Line Release coordinators told us the port had not

received any Line Release applications since July 1996, when the Carrier

Initiative Program went into effect. At Otay Mesa, officials were unable to

provide 15 of the background checklists for the 46 Line Release checklists

we reviewed; at all three ports, background checks served as the basis for

approving applicants. The operations analyst responsible—as of

May 1998—for completing the background checklists at Otay Mesa told us

that although he is not required to retain copies of the checklists or to

provide documentation in support of his findings—e.g., database check

printouts—he does both.

Second, although neither the Code of Federal Regulations nor Customs’

implementing guidelines require ports to recertify companies already

approved for the Line Release Program, Otay Mesa had recertified

participants based on their volume criteria. The port does not recheck

(recertify) participants for compliance or perform follow-up background

checks. Without recertification, there is no assurance that the participants

continue to meet the volume and compliance criteria or that they remain

low risk for drug smuggling. We verified that Otay Mesa had performed the

volume recertifications for the 42 application files we reviewed. These 42

files included 93 commodities; 52 were recertified as meeting Otay Mesa’s

volume criteria. The remaining 41 were either inactive or had been on Line

Release for less than 12 months. Officials at Laredo and Nogales told us

that they are planning to recertify Line Release participants, as required in

the Draft Line Release Quality Standards, as soon as the standards are

finalized.

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Customs Officials at

Three Ports Have

Little Confidence in

the Three Tier

Targeting Program

Customs developed the Three Tier Targeting Program to help identify lowand high-risk shipments so that inspectors along the Southwest border

could focus their attention on shipments determined to be high-risk for

narcotics smuggling. Low-risk shipments were to receive expedited

treatment for release, while high-risk shipments were to be subject to a

higher rate of narcotics examinations. Customs headquarters defined how

cargo shipments would be divided into three tier categories and allowed

the ports to develop their own policies and procedures for assigning risk.

Officials at the ports we visited said they did not think the Three Tier

Targeting Program was a viable program because it did not appear to have

Customs headquarters’ support. They also said they had little confidence

in the system as a method for assessing risk because (1) there was little

information available in any database for researching foreign

manufacturers and (2) they doubted the reliability of the designations: two

ports cited examples of narcotics seizures from shipments designated as

“low risk” and the lack of a significant number of seizures from shipments

designated as “high risk.” In addition, they said that the research necessary

to assign and recertify tier designations has been very time consuming

given the questionable reliability of the tier designations.

Description of the Three

Tier Targeting Program

In 1992, Customs implemented the Three Tier concept—a method of

targeting shipments for narcotics examinations—at Southwest border

ports. According to Customs’ draft Three Tier Targeting Directive, this

concept was devised to assist ports in classifying shipments according to a

narcotics risk assessment so that they could better identify or “target”

shipments that were “high risk” for smuggled narcotics. The intent of the

program was for ports to better focus inspectional resources. According to

a 1994 report11 by Customs’ Office of Regulatory Audit, ports were to start

using the program in April 1992.

Under the Three Tier concept, ports were to conduct research on

importers and foreign manufacturers who shipped through their ports. The

draft directive called for port analysts to check Customs databases and

other available sources for information on importers’ and manufacturers’

business histories and criminal activities. Commercial cargo shipments

were to be divided into three categories, or tiers, according to perceived

risk factors:

11U.S. Customs Service, Southwest Region: Management Review of the Three Tier Targeting Program,

Feb. 1994.

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Tier I: bearing little risk for narcotics smuggling, based on analytical

assessment.

Tier II: an unknown degree of risk for narcotics smuggling. (All shipments

that are not clearly Tier I or Tier III were to fall into Tier II.)

Tier III: a significant risk for narcotics smuggling. (Shipments designated

as Tier III were to be identified as high risk in Customs’ Automated

Commercial System so that inspectors would know they were to receive

narcotics examinations.)

Table 2: Number of Tier I and Tier III

Designations at Three Ports Port Tier I Designations Tier III Designations

Otay Mesa, CA (as of 08/97) 1,576 16

Laredo, TX (as of 11/97) 2,035 29

Nogales, AZ (as of 03/96) 246 4

Note 1: Tier II designations were not included because the universe is unknown.

Note 2: Most recent data available at the time of our visit.

Source: U.S. Customs Service.

Port Officials Have Little

Confidence in the Three

Tier Targeting Program

Officials at the three ports we visited expressed reservations about the

viability of the Three Tier Targeting Program. The officials remarked that

the program did not appear to have the full support of Customs

headquarters because formal program directives were issued in draft but

were not finalized. Officials at Customs headquarters could not explain

why the Three Tier directive was not finalized. Customs’ current Narcotics

Interdiction Guide calls for continued use of the program.

Officials at the three ports told us they had little confidence in the program

as a method for assessing risk for two reasons. First, program officials said

sufficient information is not available to assess the risk of foreign

companies. For example, a Nogales official told us that it was impossible

to get enough information on Mexican manufacturers on which to base a

reliable narcotics risk assessment. He said that no matter how much

research was conducted through Customs’ automated databases and other

sources, there were no data available on Mexican companies, particularly

data identifying those that had been involved in narcotics smuggling.

Second, port officials told us that inspectors had become suspicious about

the reliability of Three Tier designations. In Laredo, for example, a

Page 14 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

program official told us the port had made two marijuana seizures from

shipments classified as Tier I, or low risk. Conversely, in Nogales, the

analyst responsible for the program told us there had been no narcotics

seizures found in Tier III, high-risk shipments. Laredo officials also told us

that inspectors were more suspicious of shipments classified as low risk

because they had doubts about the reliability of the tier designations.

These doubts could lead them to order more examinations of low-risk

shipments, in direct conflict with the original intent of the program—to

process low-risk shipments quickly so that inspectors could focus their

attention on high-risk shipments.

Port officials also told us that the research necessary to assign and

recertify tier designations has been very time consuming given the

questionable reliability of the tier designations. In addition to conducting

the initial research necessary to assign tier designations, ports are to

annually recertify Tier I designations by updating the research. An official

at Otay Mesa told us that because of time constraints, port analysts were

unable to both recertify companies for Tier I and certify companies for the

Line Release Program. He said that in fiscal year 1997, port analysts would

have needed to do 50 recertifications per month to keep the database

current; but they had only been able to recertify—update the research

for—39 Tier I companies for the entire year from a total of 1,576 Tier I

designations in their database. According to the port official, other

operations, such as providing research support to the port’s investigative

team, take priority over Tier I recertifications. At Laredo, a port official

told us that for the past two years, the port has continued to maintain the

Tier I database but has not added any new companies to the Tier I

database.

Officials at the three ports said that the Three Tier Targeting Program

should be discontinued and that, although the program had worked well in

facilitating cargo, it had not been effective in distinguishing between highand low-risk shipments. In February 1994, Customs had also reported in its

Management Review of the Three Tier Targeting Program12 that “. . . the

Three Tier Targeting Program is a good cargo facilitation tool, however,

because of the lack of reliable intelligence, it has not been effective in

targeting narcotics in cargo shipments . . . .” Port officials told us their

inspectors now rely on other cargo entry programs—such as Line

Release—to identify shipments that are low risk for drug smuggling.

12U.S. Customs Service, Southwest Region: Management Review of the Three Tier Targeting Program,

Feb. 1994.

Page 15 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

Customs’ 1994 Management Review also stated that “. . . no narcotic

seizures have resulted from Three Tier Targeting . . . .” Customs

headquarters officials told us that they did not know if any seizures had

been made from Tier III, high-risk shipments. Further, they said they did

not know whether any of the 61 narcotics seizures in commercial cargo in

fiscal year 1997 were made from Tier III shipments. The officials also told

us that there is no headquarters oversight of the Three Tier Targeting

Program, and consequently no evaluations of the program or measures of

success.

Prefile Process and

Automated Targeting

System Provide More

Current Information

to Assist in Identifying

High-Risk Shipments

“Prefile” is a cargo entry process used at the Port of Laredo to expedite

low-risk shipments. The Prefile Process, which began in 1989, requires

participating brokers to file cargo entry paperwork at least 4 hours prior to

a shipment’s arrival at the port. This advance filing is to enable port

officials to review the paperwork and perform computerized background

checks on the manufacturer, importer, and broker to assess the smuggling

risk of each shipment before it arrives at the port. The Prefile Process is

complemented by the Automated Targeting System, which evaluates and

scores arriving shipments through the use of approximately 400 “rules”

designed to identify or profile high-risk shipments. The higher the score,

the more the shipment warrants attention. This process is being evaluated

to establish its effectiveness.

The Prefile Process Allows

Inspectors to Review

Current Information on

Shipments for Potential

Drug Smuggling

According to Laredo officials, the Prefile Process was designed to expedite

processing cargo through the port. Customs officials said it facilitates

processing by identifying, before the cargo reaches the port, low-risk

shipments that can be released at the primary inspection gate and

shipments that should be held at the dock for intensive examinations.

Compared with other low-risk cargo entry programs (e.g., Line Release

and the Three Tier Targeting Program), which rely on initial research of

applicants before they are approved or designated as “low risk,” the Prefile

Process involves reviewing the most current—“real-time”—information

available on companies and their potential for drug smuggling before the

shipments reach the port. Although the databases may not include

information on foreign manufacturers, the data accessed is the most

current information available.

When a broker uses the Prefile Process, the port is to receive the

hard-copy entry paperwork—the entry summary, for example—at least 4

hours before the shipment arrives at the port. Under Customs’ standard

Page 16 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

entry-filing process, drivers park their trucks at the dock and give a hard

copy of the entry paperwork to Customs for processing. While the drivers

wait, Customs compares the hard copy with entry information that was

filed electronically in advance by the broker. Any comparison of the hard

copy and the electronic filing for consistency must be conducted while the

trucks are parked at the dock.

Under the Prefile Process, Customs inspectors are to perform the same

reviews of the electronic and hard-copy entry documents that they would

do under the standard entry-filing process, including additional research;13

but receiving the hard-copy entry paperwork in advance allows the port to

perform these reviews, and any necessary additional research, before the

shipment arrives at the port. If the research does not provide a reason to

inspect the shipment, it is to be cleared for release. The inspector in the

primary inspection booth can then allow the cleared shipment to proceed

directly to the exit gate when it arrives at the port. (For other

reasons—such as a driver acting suspiciously or a random,

computer-generated order for an inspection—a Customs inspector may

order the shipment held at the dock for an intensive examination.) One

official estimated that approximately 70 percent of cargo shipments at

Laredo are Prefile shipments, although statistics were not maintained to

confirm this figure.

A disadvantage of the Prefile Process is that unlike the Line Release

process, Prefile focuses on the importer, broker, and manufacturer and

does not require the use of prescreened carriers. Companies participating

in the Line Release Program are required to use preapproved carriers and

drivers cleared under the Carrier Initiative Program. According to a

September 1997 report from the Office of National Drug Control Policy,14

76 percent of the seizures made in the Southwest border commercial cargo

environment during 1997 were found in the conveyance (truck and trailer),

not in the actual cargo.

13Additional research is to be performed if the reviewing inspector identifies suspicious or unusual

information in the electronic and hard-copy entry paperwork. This research might include more

extensive background checks in Customs’ automated databases for information or intelligence on the

importer, broker, and manufacturer.

14Report to Congress, Volume 1, United States and Mexico Counterdrug Cooperation, Enhanced

Multilateral Drug Control Cooperation, and Enhanced Truck Inspections, Executive Office of the

President, Office of National Drug Control Policy, Sept. 1997.

Page 17 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

Automated Targeting

System Designed to Assist

in Identifying Shipments

Warranting Extra

Inspectional Attention

In May 1997 Laredo began pilot testing, in conjunction with the Prefile

Process, a computerized system called the Automated Targeting System.

The Automated Targeting System assists the port in identifying shipments

that could pose a high risk for drug smuggling. According to Customs, the

system is designed to help the port prioritize shipments according to

threat, in order to allow the port to more effectively use resources and to

ensure that shipments that pose the highest risk for smuggling are

researched first.

The Automated Targeting System standardizes entry and entry-summary

data received from the broker and creates integrated records called

“shipments.” The shipments are to be evaluated and scored by the

Automated Targeting System through the use of approximately 400

weighted “rules” designed to identify or profile high-risk shipments.

According to the system’s program officer, the rules are based on targeting

and evaluation methods successfully used by experienced Customs

inspectors. The higher the score, the more the shipment warrants

attention.

Customs inspectors may use the score to determine whether the shipment

should be detained for inspection after it reaches the port. For example, a

shipment going to a “first-time importer” might be selected for an intensive

inspection. One of the rules used for scoring a potentially high-risk

shipment is a first-time importer because little information is available

about first-time importers on which to assess the risk of drug smuggling.

The Automated Targeting System also allows Customs inspectors to query

several databases simultaneously to conduct background checks on

importers, brokers, and manufacturers associated with a shipment.

Because data from several systems are displayed on a computer screen at

one time, inspectors are able to compare information for potential

irregularities and inconsistencies.

Customs Is Currently

Evaluating the

Effectiveness of the

Automated Targeting

System

Customs officials told us that Laredo is the first land-border port of entry

to test the Automated Targeting System. Depending on the outcome of

Laredo’s pilot test, Customs may expand the system to all major seaports,

airports, and land-border ports of entry. Customs is currently evaluating

the pilot test at Laredo. According to the system’s program officer,

Customs does not plan to expand the system to other land-border, cargo

ports of entry until an evaluation has been completed. According to the

program officer, the system will be assessed for use at other Southwest

Page 18 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

border ports on the basis of three factors: (1) drug threat, (2) volume of

shipments and method of processing (i.e., Line Release, etc.), and

(3) technological capability. Laredo port officials told us they are tracking

drug seizures attributed to the Automated Targeting System; as of

May 1998, three marijuana seizures had been made, totaling over 5,000

pounds.

Conclusions The Customs Service is faced with the challenge of facilitating the flow of

legitimate cargo into the United States while, at the same time, detecting

and intercepting illegal drug smuggling. Customs has developed several

programs to try to identify shipments that are lower risk than others and

give more inspectional attention to the higher-risk shipments.

Theoretically, these programs would facilitate the processing of lower risk

cargo and enable Customs to use its inspectional resources more

efficiently and effectively.

The key to the success of these programs is Customs’ ability to identify the

risk that any given shipment poses. Our review of three programs at three

Southwest border ports raises several concerns about the implementation

of two of these programs. The weak internal controls over the Line

Release Program at three ports may not assure Customs that program

participants, at these three ports, are fully researched and properly

designated as low risk.

Further, port officials’ concerns about the Three Tier Targeting Program

raise questions about the continued value or utility of the program at the

three ports we visited. Officials at all three ports said that the program

should be discontinued, and that they relied on other programs for

distinguishing high- and low-risk shipments. These reasons cause us to

conclude that the Three Tier Targeting Program may not be an effective

tool for assessing narcotics risk.

We recognize that under current operating conditions, Customs will not be

able to subject all cargo entering the United States to intensive inspections

to detect drug smuggling. We also recognize that inadequately controlled

processes for identifying low-risk shipments can give Customs inspectors

a false sense of confidence that those shipments are low risk for drug

smuggling. While the Prefile Process, used in conjunction with the

Automated Targeting System, seems to have the potential to offer the

advantage of basing inspection decisions on more current information

Page 19 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

than the Line Release and the Three Tier Targeting programs, it does not

cover the carriers, and has not been thoroughly evaluated.

Recommendations We recommend that the Commissioner of Customs

• strengthen internal control procedures for the Line Release application

and review process to ensure fully researched and documented

risk-assessment decisions on applicants;

• suspend the Three Tier Targeting Program until it can be determined if

more complete and comprehensive data are available on which to base

“low risk for narcotics smuggling” risk assessments; and

• evaluate the effectiveness and efficiency of the Automated Targeting

System, as designed and implemented at Laredo, and use the evaluation

results to determine whether other land-border cargo ports should

implement the system or whether additional testing is needed.

Agency Comments Treasury provided written comments on a draft of this report, and its

comments are reprinted in appendix III. Overall, Treasury and Customs

management generally agreed with our conclusions, and Customs is taking

action, or is planning to take action, on all of our recommendations.

Regarding our first recommendation, Treasury stated in its written

comments that Customs’ Office of Field Operations plans to publish the

Line Release Quality Standards in the form of a Headquarters Directive by

the end of fiscal year 1998. According to Treasury, this directive will create

consistent national criteria and guidance with regard to the application

procedures. Included will be a requirement for ports to retain the original

approved applications and supporting documentation on file for as long as

the applicants are active participants in the program.

Regarding our second recommendation, Treasury agreed that the Three

Tier Program should be suspended until more reliable information is

developed for classifying low-risk importations. Treasury stated in its

written comments that Customs believes its other targeting methods,

including the Line Release Program, the Automated Targeting System, the

Prefile Program, and the Land Border Carrier Initiative Program, are better

able to fulfill Customs’ narcotic interdiction goals and responsibilities.

Regarding our third recommendation, Treasury said Customs is currently

evaluating the Automated Targeting System as implemented at the port of

Page 20 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
B-279229 

Laredo. It also plans to assess data regarding cargo volume and cargo

processes used—e.g., Line Release—on other Southwest border ports of

entry to determine future deployment of the system.

Customs management, in their written comments, acknowledged that the

Prefile Process, used in conjunction with the Automated Targeting System,

does not require the use of preapproved carriers and drivers cleared under

the Carrier Initiative Program and that this could be seen as a

disadvantage. They also stated that the Prefile approach narrows the

scope of Customs’ interdiction efforts to focus on the driver and

conveyance because the cargo has been determined to be low risk.

Customs pointed out that Prefile shipments are also subject to other

enforcement actions, including (1) random checks performed on all

companies using the Prefile Process, (2) X-ray and detection dogs, and

(3) the experience and knowledge of Customs inspectors. Nevertheless,

we still feel that the fact that the Prefile Process does not require

shipments to use carriers preapproved under the Carrier Initiative

Program is a significant disadvantage. Line Release shipments are also

subject to the same enforcement actions mentioned above. Yet, in

July 1996, Customs strengthened the Line Release Program by requiring all

participants on the Southwest border to use carriers approved under the

Carrier Initiatives Program.

We are sending copies of this report to the Secretary of the Treasury, the

Acting Commissioner of Customs, and to the Chairmen and Ranking

Minority Members of the congressional committees that have

responsibilities related to these issues. Copies also will be made available

to others upon request. The major contributors to this report are listed in

appendix IV. If you or your staff have any questions about the information

in this report, please contact me on (202) 512-8777 or Darryl Dutton,

Assistant Director, on (213) 830-1000.

Sincerely yours,

Norman J. Rabkin

Director, Administration

 of Justice Issues

Page 21 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

24

Appendix II 

Description of Ports

Visited

26

Otay Mesa, California 26

Laredo, Texas 26

Nogales, Arizona 27

Appendix III 

Comments From the

Department of

Treasury

28

Appendix IV 

Major Contributors to

This Report

31

Tables Table 1: Decline in Line Release Entries Following Start of Land

Border Carrier Initiative Program

8

Table 2: Number of Tier I and Tier III Designations at Three Ports 14

Page 22 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Page 23 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix I 

Objectives, Scope, and Methodology

Our objectives for this report were to (1) describe Customs’ low-risk,

cargo entry programs in use at three ports on the Southwest border and

(2) discuss the results of our evaluation of the internal controls over the

Line Release Program and processes used to assess the risks of narcotics

smuggling in other low-risk, cargo entry programs. As agreed with your

office, we focused our work on three of the busiest commercial cargo

ports of entry along the Southwest border—Otay Mesa, CA; Laredo, TX;

and Nogales, AZ.

To identify Customs’ low-risk, cargo entry programs on the Southwest

border, we interviewed Customs headquarters officials in the offices of

Anti-Smuggling and Trade Compliance. We also reviewed agency program

documents, including Customs’ Southern Border Cargo Action Plan,

Narcotics Interdiction Guide, Line Release Directive and draft standards,

draft of the Three Tier Targeting Directive, and other program documents.

We also reviewed program documents at the three cargo ports of entry,

including local guidance and directives for the programs. At each of the

three ports and their Customs Management Centers, we interviewed key

officials, including the center director, port director, the Line Release

coordinator, and senior operations and analysis officials responsible for

developing and overseeing the low-risk, cargo entry programs.

At each port, we observed both low-risk and standard cargo entry

processes—including inspection techniques and enforcement

activities—used by the ports to facilitate commercial shipments and to

detect illegal drugs contained in these shipments. We also observed the

use of nonintrusive technology, such as the pallet X-rays used at all three

ports and the truck X-ray system used at Otay Mesa.

To examine the processes Customs uses for screening cargo shipments

designated as low risk for narcotics smuggling, we began by reviewing

each port’s processes and procedures and internal controls for reviewing

and approving applicants for the Line Release Program. We also attempted

to determine whether ports were following their local criteria and

procedures in evaluating Line Release applications. Of the three ports we

visited, Otay Mesa had the largest number of Line Release entries during

fiscal year 1997 and the greatest number of participants. Because Otay

Mesa’s universe of participants was large, we randomly selected a sample

of 42 application files,15 approved between 1988 and 1997, for review to

determine whether Otay Mesa was following its local criteria and

15For the purposes of this review, Line Release “application files” are defined as the completed forms

companies submit to a port when they apply for the Line Release Program and the documentation

ports produce during their review and approval of the applicants.

Page 24 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix I 

Objectives, Scope, and Methodology

procedures in approving Line Release applicants in accordance with

applicable internal control standards. This sample was not large enough to

be representative of the universe of Line Release participants at Otay

Mesa, and the results of our review should not be projected beyond the

sample. At Laredo and Nogales, because the universe of participants was

small, we reviewed the applications for all active participants on Line

Release during fiscal year 1997.

To examine Customs’ processes for designating cargo shipments as low

risk for narcotics smuggling under the Three Tier Targeting Program and

to determine the extent to which selected ports had implemented the

program, we interviewed key officials at Customs headquarters and

reviewed program documentation. At all three ports, we interviewed

officials responsible for overseeing the program, including the analysts

who performed the background reviews leading to low-risk designations.

We also reviewed checklists that the ports had developed to facilitate their

background reviews, and obtained the most recent data available on the

number of Tier I (low-risk) and Tier III (high-risk) designations in place at

each port. We did not review port files to determine whether ports were in

compliance with local policies and procedures for assigning the tier

designations.

At Customs headquarters and at the Port of Laredo, we reviewed

applicable program guidance and interviewed key officials concerning the

Prefile Process and the Automated Targeting System. We also received a

demonstration of the Automated Targeting System, including the

computer research, from Customs inspectors at Laredo.

We performed our work between November 1997 and May 1998 in

accordance with generally accepted government auditing standards. We

discussed the contents of this report with relevant Customs officials, and

we incorporated their comments where appropriate.

Page 25 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix II 

Description of Ports Visited

Otay Mesa, California Otay Mesa, CA, is the third busiest commercial cargo facility on the

Southwest border. In fiscal year 1997, Otay Mesa handled over 585,000

vehicles, which was an average of 1,604 vehicles per day.16 The port

processes a variety of imports, including produce, television sets, and

electronic components. Otay Mesa has over 100 dock spaces available for

inspections and, as of December 1997, had 140 inspectors, canine

enforcement officers, and supervisors.17 The port utilizes standard

technology, such as pallet X-ray and tanker scales, as well as a truck X-ray

system to inspect commercial vehicles and cargo for narcotics. In fiscal

year 1997, the port seized about 24,000 pounds of marijuana, but no

cocaine. Otay Mesa is located about 15 miles south of San Diego, CA.

Laredo, Texas Laredo, TX, consists of two separate cargo facilities, the downtown Laredo

facility and the Colombia Bridge facility. Together, they form the busiest

commercial cargo port along the Southwest border. Customs considers,

for administrative purposes, the two facilities as one port and does not

track data separately for each facility (e.g., volume of entries, inspections,

etc.). Although we examined cargo entry operations at both facilities, for

purposes of this review and data collection, we considered the Laredo and

Colombia facilities as one port. Therefore, the Laredo data included in this

report incorporate both Laredo and Colombia operations.

During fiscal year 1997, Laredo handled about 994,600 vehicles, which was

an average of 2,722 vehicles per day. Both facilities handled auto parts,

steel, and chemical products; Colombia also processed hazardous

materials. The Laredo facility has 13 dock spaces to examine trucks and

cargo, while the Colombia facility has 100 dock spaces available for

inspections. As of December 1997, Laredo and Colombia had a combined

staff of 139 inspectors, canine enforcement officers, and supervisors. Both

Laredo and Colombia had pallet X-ray systems and tanker scales; and, at

the time of our review, Colombia was scheduled to receive a truck X-ray

system in September 1998. In fiscal year 1997, the two-facility port seized

3,252 pounds of marijuana and 450 pounds of cocaine. The Laredo facility

is located 154 miles south of San Antonio, TX, and the Colombia facility is

located 22 miles west of Laredo.

16The average number of vehicles per day reflects the traffic average over a 1-year period, which

includes both weekdays, when the traffic volume is much higher, and weekends, when the traffic

volume is much lower.

17Twelve inspectors and three supervisors from Otay Mesa were assigned to the San Diego

airport/seaport.

Page 26 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix II 

Description of Ports Visited

Nogales, Arizona Nogales, AZ, is the fifth busiest commercial cargo port on the Southwest

border. Nogales handled about 223,000 vehicles during fiscal year 1997,

which was an average of 611 vehicles per day. During the winter season,

the port’s busiest period, Nogales mainly handles produce; during the

summer months, it primarily processes industrial commodities such as

auto parts and medical supplies. Nogales has 92 dock spaces dedicated to

Customs inspections and, as of December 1997, had a staff of 36

inspectors, canine enforcement officers, and supervisors. Nogales has

both a pallet X-ray and a scale for weighing tanker trucks; and, at the time

of our review, it expected to receive a truck X-ray system in August 1998.

In fiscal year 1997, Nogales seized 3,304 pounds of marijuana and 960

pounds of cocaine. The port is located 67 miles south of Tucson, AZ.

Page 27 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix III 

Comments From the Department of

Treasury

Page 28 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix III 

Comments From the Department of

Treasury

Page 29 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix III 

Comments From the Department of

Treasury

Page 30 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
Appendix IV 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Darryl W. Dutton, Assistant Director

Barry J. Seltser, Assistant Director, Design, Methodology,

 and Technical Assistance

Sidney H. Schwartz, Senior Mathematical Statistician,

 Design, Methodology, and Technical Assistance

Office of the General

Counsel, Washington,

D.C.

Ann H. Finley, Senior Attorney

Los Angeles Field

Office

Kathleen H. Ebert, Project Manager

Barbara A. Guffy, Senior Evaluator

(264442) Page 31 GAO/GGD-98-175 Low-Risk Cargo Entry Programs
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