Report to the Committee on Armed 

Services, U.S. Senate 

United States General Accounting Office 

GAO

March 2004 DEFENSE 

ACQUISITIONS 

DOD Needs to Better 

Support Program 

Managers’ 

Implementation of 

Anti-Tamper 

Protection 

GAO-04-302 
www.gao.gov/cgi-bin/getrpt?GAO-04-302.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Katherine V. 

Schinasi (202) 512-4841 or 

schinasik@gao.gov. 

Highlights of GAO-04-302, a report to the 

Senate Committee on Armed Services 

March 2004

DEFENSE ACQUISITIONS 

DOD Needs to Better Support Program 

Managers’ Implementation of Anti-Tamper 

Protection 

Program managers have encountered difficulties in implementing DOD’s 

anti-tamper policy on individual weapon systems. First, defining a 

critical technology—a basis for determining the need for anti-tamper—is 

subjective, which can result in different conclusions regarding what 

needs anti-tamper protection. While different organizations can check on

program managers’ assessments, no organization has complete 

information or visibility across all programs. Some program managers 

said they needed assistance in determining which technologies were 

critical, but resources to help them were limited or unknown and 

therefore not requested. Second, anti-tamper protection is treated as an 

added requirement and can affect a program’s cost and schedule 

objectives, particularly if the program is further along in the acquisition 

process. Programs GAO contacted experienced or estimated cost 

increases, and some encountered schedule delays when applying antitamper protection. Officials from one program stated that their existing 

budget was insufficient to cover the added cost of applying anti-tamper 

protection and that they were waiting for separate funding before 

attempting to apply such protection. Finally, anti-tamper techniques can 

be technically difficult to incorporate in some weapon systems—

particularly when the techniques are not fully developed or when the 

systems are already in design or production. One program that had 

difficulty incorporating the techniques resorted to alternatives that 

provided less security. While DOD is overseeing the development of 

generic anti-tamper techniques and tools to help program managers, 

many of these efforts are still in progress, and program managers 

ultimately have to design and incorporate techniques needed for their 

unique systems. 

The U.S. government has invested 

hundreds of billions of dollars in 

developing the most sophisticated 

weapon systems and technologies 

in the world. Yet, U.S. weapons and 

technologies are vulnerable to 

exploitation, which can weaken 

U.S. military advantage, shorten the 

expected combat life of a system, 

and erode the U.S. industrial base’s 

technological competitiveness. In 

an effort to protect U.S. 

technologies from exploitation, the 

Department of Defense (DOD) 

established in 1999 a policy 

directing each military service to 

implement anti-tamper techniques, 

which include software and 

hardware protective devices. 

This report reviews DOD’s 

implementation of the anti-tamper 

policy as required by the Senate 

report accompanying the National 

Defense Authorization Act for 

Fiscal Year 2004. 

GAO is recommending that the 

Secretary of Defense direct the 

Under Secretary of Acquisition, 

Technology, and Logistics and the 

anti-tamper Executive Agent to 

take several actions to improve 

oversight and assist program 

offices in implementing anti-tamper 

protection on weapon systems. 

DOD concurred or partially 

concurred with the 

recommendations, but it suggested 

alternative language for several, 

which GAO incorporated when 

appropriate. 
Page i GAO-04-302 Defense Acquisitions 

Letter 1

Results in Brief 1

Background 2

Anti-Tamper Implementation Has Been Hampered by Several 

Factors, and Support to Address Them Has Been Limited 5

Conclusions 12

Recommendations for Executive Action 13

Agency Comments and Our Evaluation 14

Scope and Methodology 15

Appendix Comments from the Department of Defense 17 

Figure 

Figure 1: DOD Anti-Tamper Decision Process 4

Contents 

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Page 1 GAO-04-302 Defense Acquisitions 

March 31, 2004 

The Honorable John W. Warner 

Chairman 

The Honorable Carl Levin 

Ranking Minority Member 

Committee on Armed Services 

United States Senate 

The U.S. government has invested hundreds of billions of dollars in 

developing the most sophisticated weapon systems and technologies in 

the world. Yet, U.S. weapons and technologies can be exposed to the risk 

of compromise when they are exported, stolen, lost during combat, or 

damaged during routine missions. When U.S. technologies are 

compromised, it can weaken U.S. military advantage, shorten the expected 

combat life of a system, and erode the U.S. industrial base’s technological 

competitiveness in the international marketplace. 

In an effort to protect U.S. technologies from exploitation, the Under 

Secretary of Defense for Acquisition, Technology, and Logistics1

 in 1999 

directed each military service to implement anti-tamper techniques.2

Program managers are responsible for applying the techniques on 

individual weapon systems. The Senate report accompanying the National 

Defense Authorization Act for Fiscal Year 20043

 required us to review the 

Department of Defense’s (DOD) implementation of the anti-tamper policy. 

We conducted our work between February 2003 and August 2003 in 

accordance with generally accepted government auditing standards. 

Program managers have encountered difficulties in implementing DOD’s 

anti-tamper policy. First, defining a critical technology—a basis for 

determining the need for anti-tamper protection—is subjective, which can 

result in different conclusions regarding what needs protection. While 

different organizations can check on program managers’ critical 

 1

Formerly this position was referred to as the Under Secretary of Defense for Acquisition 

and Technology. 

2

Anti-tamper techniques are applied through a systems engineering activity. Examples of 

techniques include software encryption and hardware protective coatings. 

3

S. Rept. No. 108-46, at 345 (May 13, 2003). 

United States General Accounting Office 

Washington, DC 20548 

Results in Brief 
Page 2 GAO-04-302 Defense Acquisitions 

technology assessments, no organization has complete information or 

visibility across all programs. Some program managers said they needed 

assistance in determining which technologies were critical, but resources 

to help them were limited or unknown and therefore not requested. 

Second, anti-tamper protection is treated as an added requirement and can 

affect a program’s cost and schedule objectives, particularly for those 

programs that are further along in the acquisition process. Programs we 

contacted experienced or estimated a cost increase, and some 

encountered schedule delays when applying anti-tamper protection. 

Officials from one program stated that their existing budget was 

insufficient to cover the added cost of applying the protection. Finally, 

anti-tamper techniques can be technically difficult to incorporate in some 

weapon systems—particularly when the techniques are not fully 

developed or when the systems are already in design or production. While 

DOD is overseeing the development of generic anti-tamper techniques and 

tools to help program managers, many of these efforts are still in progress, 

and program managers ultimately have to design and incorporate unique 

techniques needed for their individual systems. 

We make five recommendations to DOD to better oversee and assist 

program managers in implementing anti-tamper protection on weapon 

systems. In written comments on a draft of this report, DOD partially 

concurred with one recommendation and offered an alternative solution, 

which we did not incorporate because it did not fully address the problem. 

DOD concurred with our remaining four recommendations and provided 

alternative language for two, which we incorporated as appropriate. 

DOD increasingly relies on advanced technology in its weapons for 

effectiveness on the battlefield and actively seeks to include foreign 

partners in weapon system development and acquisition. DOD’s policy 

also encourages the sale of certain weapons to foreign governments 

through the Foreign Military Sales Program and direct commercial sales 

made by companies. While these efforts have the potential to enhance 

coalition operations and reduce weapons’ unit costs, DOD has 

acknowledged that the efforts also risk making U.S. technologies 

potentially vulnerable to exploitation. DOD reported that an increasing 

number of countries have reverse engineering capability and actively seek 

to obtain U.S. technology through various means. 

As a method to protect critical technologies, the Under Secretary of 

Defense for Acquisition, Technology, and Logistics directed the military 

services in 1999 to implement anti-tamper techniques. While the 

Background 
Page 3 GAO-04-302 Defense Acquisitions 

techniques will not prevent exploitation, they are intended to delay or 

discourage attempts to reverse engineer critical technologies in a weapon 

system or develop countermeasures to a system or subsystem. 

In 2001, the Under Secretary of Defense for Acquisition, Technology, and 

Logistics designated the Air Force as the Executive Agent responsible for 

implementing DOD’s anti-tamper policy. The Executive Agent oversees an 

annual budget of about $8 million per year to implement policy and 

manage anti-tamper technology projects through the Air Force Research 

Laboratory. DOD, in conjunction with the Air Force Research Laboratory 

and the Department of Energy’s Sandia National Laboratories, also holds 

periodic information sessions to educate the acquisition community about 

anti-tamper policy, guidance, and technology developments. In addition, 

military services and defense agencies, such as the Missile Defense 

Agency, have an anti-tamper focal point to coordinate activities. 

Program managers are responsible for considering anti-tamper measures 

on any weapon system with critical technologies.4

 Since it is not feasible to 

protect every technology, program managers are to conduct an assessment 

to determine if anti-tamper protection is needed. The first step of the 

decision process is to determine if the system has critical technologies. If 

program managers determine the system has no critical technologies, they 

are to document that decision according to draft guidance.5

 Program 

managers of systems that contain critical technologies complete the 

remaining steps of the process. Based on draft guidance, program 

managers are to conceptually address how they will implement antitamper measures at system development, otherwise known as 

milestone B. DOD’s anti-tamper decision process is illustrated in figure 1.6

 4

According to the implementation guidelines of 2000, anti-tamper measures should be 

included in requirements development for all new and upgraded programs and be 

considered for systems that are developed with allied partners or exported. Anti-tamper 

protection is not required for programs beyond the design phase or those in full 

production, unless the responsible decision authority determines otherwise. 

5

Mandatory Procedures for Research and Technology Protection within the DOD (5200.39-

R), draft, March 2002. 

6

Variations of DOD’s anti-tamper decision process can be found in different DOD 

documents. 
Page 4 GAO-04-302 Defense Acquisitions 

Figure 1: DOD Anti-Tamper Decision Process 

Program managers can obtain assistance on their assessments from 

government laboratories, contractors, and the intelligence community. 

They are required to document the decision to use or not to use antitamper techniques in a classified annex of the program protection plan,7

 7

The program protection plan documents the program’s approach for protecting critical 

program information and should include a prioritized list of critical information and an 

assessment of the threats and vulnerabilities to that information. 
Page 5 GAO-04-302 Defense Acquisitions 

which is subject to approval from the program’s milestone decision 

authority.8

Anti-tamper techniques vary depending on the type of protection the 

system requires.9

 An example of an anti-tamper technique is software 

encryption, which scrambles software instructions to make them 

unintelligible without first being reprocessed through a deciphering 

technique. Another example is a thin opaque coating placed on 

microelectronic components, which makes it difficult to extract or dissect 

the components without great damage. Programs can apply multiple antitamper techniques to a critical technology. For example, a program could 

encrypt critical data on a microelectronic chip that is also covered with a 

protective coating. Each layer of protection could act as an obstacle to 

reverse engineering. 

Implementation of the anti-tamper policy has been hampered by several 

factors. First, identification of critical technology is subject to 

interpretation and program managers and DOD officials can and have 

arrived at different conclusions about what needs to be protected. Second, 

applying anti-tamper protection can take time and money, which may 

compete with a program manager’s cost and schedule objectives. Finally, 

some programs found it difficult to apply anti-tamper techniques when the 

techniques were not fully developed, and others were unsure which 

techniques were available to them. In general, the later anti-tamper 

techniques are applied, the more difficult and costly it can be to 

implement. Thus far, support to help program managers address some of 

these factors has been limited. 

DOD officials acknowledged that the identification of critical 

technologies—a basis for determining if anti-tamper protection is 

needed—is subjective, which can result in different conclusions regarding 

what needs protection. DOD’s Program Managers Anti-Tamper Handbook 

defines technology as critical if compromise results in degrading combat 

 8

The milestone decision authority is the individual designated to approve entry of an 

acquisition program to the next phase. 

9

Information regarding the specific anti-tamper techniques used on an individual system is 

typically classified because disclosure could aid exploitation. In some cases, anti-tamper 

information is restricted at the special access level. 

Anti-Tamper 

Implementation Has 

Been Hampered by 

Several Factors, and 

Support to Address 

Them Has Been 

Limited 

Different Interpretations of 

Critical Technologies May 

Increase the Risk of Some 

Going Unprotected 
Page 6 GAO-04-302 Defense Acquisitions 

effectiveness, shortening the expected combat life of the system, or 

significantly altering program direction. While a broad definition allows 

for flexibility to determine what is critical on individual systems, it may 

increase the risk that the same technology is protected on some systems 

but not on others or that different conclusions can be reached on whether 

programs have critical technologies. For example: 

• An official from an intelligence agency described a case where two 

services used the same critical technology, but only one identified the 

technology as critical and provided protection. The intelligence agency 

official speculated that if exploited, knowledge gained from the 

unprotected system could have exposed the technology on both 

systems to compromise. While both systems were ultimately protected, 

the intelligence agency official stated that the situation could occur 

again. 

• Officials from the Executive Committee10 told us that two program 

managers stated that their systems had no critical technologies and 

therefore were not subject to the anti-tamper policy. Both managers 

were directed by the Executive Committee to reconsider their 

determination and apply anti-tamper protection. As a result, one 

program is in the process of determining which technologies are 

critical, and the other program is applying anti-tamper protection as a 

condition to export the system. 

While different conclusions can be reached regarding what is critical, 

various organizations can serve as a check on a program manager’s 

assessment. However, no organization has complete information or 

visibility of all programs across the services and agencies. For example, 

the anti-tamper Executive Agent and the military service focal points do 

not have full knowledge about which program offices have or have not 

identified critical technologies or applied anti-tamper protection.11 In 2001, 

DOD attempted to collect such information,12 but not all programs 

 10 The Low Observable/Counter Low Observable Executive Committee establishes security 

guidelines to protect stealth technology and ensures exports are consistent with DOD 

policy. 

11The Counterintelligence Field Activity and the Defense Intelligence Agency are 

developing a database that will contain information regarding critical program information 

for programs across the services. 

12This effort was in response to the Under Secretary of Defense’s direction in 1999 that the 

acquisition executives determine the extent to which anti-tamper protection was 

incorporated in weapon systems. 
Page 7 GAO-04-302 Defense Acquisitions 

provided data and DOD did not corroborate what was provided to ensure 

that program officials were consistently assessing critical technologies. 

The Executive Agent stated that there are no plans to update this data. 

Conducting oversight over program managers’ assessments may be 

difficult because of limited resources. Specifically, the Executive Agent 

has two full-time staff and the military service focal points perform duties 

other than anti-tamper management. Furthermore, according to a military 

official, program offices that determine they have no critical technologies 

are not required to obtain the focal points’ concurrence. While other 

organizations can review a program manager’s critical technology 

assessment as part of various acquisition and export processes, they may 

not have a full perspective of the assessments made by all programs across 

the services and the agencies. For example, different milestone decision 

authorities only review an individual program manager’s critical 

technology decisions for programs coming under their responsibility. Also, 

the Executive Committee may weigh in on the determinations, but it only 

reviews exports involving stealth technology. 

While it was apparent that the systems had critical technologies, some 

program managers needed assistance to determine which specific 

technologies were critical. For example, a program office tasked the 

contractor to identify critical technologies, and it has worked for months 

with the contractor to agree upon and finalize a list of critical technologies 

on the system. Also, an intelligence official, who is available to assist 

program managers in assessing their systems’ criticality, found that some 

program managers identified too many technologies as critical and that 

others did not identify all of the systems’ critical elements. In one instance, 

a program manager indicated that a system had 400 critical technologies, 

but an intelligence agency narrowed down the list to about 50 that it 

considered critical. In another case, a program manager concluded that an 

entire system was one critical technology, but the intelligence agency 

recommended that the system’s technologies be broken down and 

identified approximately 15 as critical. 

Although there are various resources to help program managers identify 

critical technologies, they may have limited utility, or may not be known, 

and therefore not requested. For example, the Militarily Critical 

Technologies List—cited in guidance as a primary reference for program 

managers—may not be up to date and may not include all technologies, 

according to some DOD officials. Another resource—the Program 
Page 8 GAO-04-302 Defense Acquisitions 

Managers Anti-Tamper Handbook—contains information regarding critical 

technology determinations, but program managers are not always aware 

that the handbook exists, in part because it is not widely distributed.13 In 

addition, the Defense Intelligence Agency can conduct an independent 

assessment of a system’s critical elements and technologies, if requested 

by the program manager. However, many officials we interviewed were 

unaware that the agency provides this assistance. According to a military 

official, the focal points are available to review a program manager’s 

assessment if requested. 

In some instances, program managers may have differing perceptions of 

what constitutes a critical technology. According to DOD’s guidance, 

critical technologies can be either classified or unclassified. However, an 

anti-tamper focal point stated that there is a perception that the antitamper policy only applies to classified programs. We found in one 

instance that the manager for a weapon program stated that the program 

did not require anti-tamper protection because it had no critical 

technologies that were classified.14

Applying anti-tamper protection takes money and time, which can affect a 

program manager’s cost and schedule objectives. Generally, anti-tamper 

implementation is treated as an added requirement that is not separately 

funded for most programs.15 Program officials acknowledged that antitamper costs can be difficult to estimate and isolate because they are 

intertwined with other costs, such as research and development or 

production costs. As we have found in prior work, the later a requirement 

is identified, the more costly it is to achieve.16

 13According to DOD officials, the handbook contains classified information and they need 

to verify that a program office can accept and store classified information before they 

distribute it. 

14This program office estimated that 30 systems had been lost during military operations. In 

addition, DOD reported that this technology has been targeted for reverse engineering. 

15One program we contacted was authorized separate congressional funding for antitamper costs. 

16Best Practices: Setting Requirements Differently Could Reduce Weapon Systems’ Total 

Ownership Costs, GAO-03-57 (Washington, D.C.: Feb. 11, 2003). 

Applying Anti-Tamper 

Protection Can Affect Cost 

and Schedule Objectives 
Page 9 GAO-04-302 Defense Acquisitions 

Most programs we visited experienced or estimated cost increases, and 

some encountered schedule delays as they attempted to apply anti-tamper 

techniques. For example: 

• A program official told us the anti-tamper protection for a program 

upgrade increased both design and production costs for the receiver 

unit. The program official stated that the anti-tamper protection 

increased total unit cost by an estimated $31 million, or 10 percent. 

Program officials expressed concern that unit cost increases may affect 

procurement decisions, particularly for one service, which is the 

largest acquirer of units and may be unable to purchase the proposed 

number. 

• A program office estimated that it needs a budget increase of 

$56 million, or 10 percent, to fund the desired anti-tamper protections. 

Officials from that program told us that the existing program budget 

was inadequate to fund the added anti-tamper requirements. As a 

result, the program manager requested, and is waiting for, separate 

funding before attempting to apply anti-tamper protection to the 

system. 

• One program office awarded a contract modification for the design, 

implementation, and testing of anti-tamper techniques valued at 

$12.5 million. Initially, the contractor had estimated the anti-tamper 

costs to be $35 million, but the program office did not approve all 

techniques suggested by the contractor. In addition, the contractor 

estimated that the recurring unit price for anti-tamper protection on 

future production lots may be $3,372 per unit. The U.S. government and 

the contractor have not completed unit price negotiations. Program 

officials told us that anti-tamper implementation contributed to a 

6-month schedule delay. 

• Another program office estimated that $87 million is needed to protect 

two critical technologies with multiple anti-tamper techniques. The 

program office expects that half of the anti-tamper budget will be used 

to test the techniques. The anti-tamper protection will only be applied if 

the system is approved for export. At that time, program officials will 

reexamine the anti-tamper cost estimates. In addition, it may take 

5 years to adequately apply the techniques. 

• Officials from an international program stated that, thus far, they have 

experienced a 60-day schedule delay while they wait for the contractor 

to estimate the system’s anti-tamper cost. Program officials stated that 

the potential for increased costs and additional schedule delays is high. 
Page 10 GAO-04-302 Defense Acquisitions 

Program officials and representatives from the Executive Committee 

stated that the cost of anti-tamper protection can be significantly 

higher for an international program for various reasons, including that 

the U.S. version and the international version of the system may require 

different anti-tamper techniques. 

Cost and schedule impacts may also be more significant if the programs 

are further along in the acquisition process when program offices first 

attempt to apply anti-tamper protection. Several programs that have 

experienced significant cost increases or delays were in or beyond the 

program development phase when they attempted to apply anti-tamper 

techniques. For example, when the anti-tamper policy was issued, one 

program had just obtained approval to begin system development and 

program officials believed it was too late to implement anti-tamper 

protection. As a result, the program received an interim waiver17 of the 

anti-tamper policy, and it only plans to apply anti-tamper techniques if the 

system is approved for export. While DOD has not systematically collected 

cost data for anti-tamper application across programs, DOD officials have 

stated that it is more cost-effective for programs to consider anti-tamper 

requirements at program inception, rather than later in the acquisition 

process. An official from a program that applied anti-tamper techniques in 

the production phase stated that ideally a program should identify its antitamper needs, including cost and technology, as early as possible. Recent 

Army anti-tamper guidance indicates that programs should receive 

approval for their preliminary anti-tamper plans at the concept stage. 

Anti-tamper techniques can be technically difficult to incorporate on a 

weapon system, such as when the technology is immature. DOD is 

working to oversee the development of generic anti-tamper techniques and 

tools to help program managers identify potential techniques, but many of 

these efforts are still in progress and it is uncertain how they will help 

program managers. While program managers want knowledge about 

generic techniques, they ultimately have to design and incorporate 

techniques needed for their unique systems to ensure protection of critical 

technologies and to meet performance objectives. 

 17According to representatives from the Executive Committee, DOD can waive the antitamper requirement when a program can make a compelling reason for forgoing the policy. 

Needs Outpace Availability 

of Techniques and Tools 
Page 11 GAO-04-302 Defense Acquisitions 

Problems in applying anti-tamper techniques typically arose when the 

programs were already in design or production or when the techniques 

were not fully developed or specifically designed for the system. For 

example: 

• Officials from a program told us that they experienced problems when 

applying an anti-tamper protective coating. Because the team applying 

the coating did not coordinate with teams working on other aspects of 

the system, the problems with the coating were not discovered until 

just before production. Prior to an initial development test, the 

program office received a temporary waiver to test the system without 

the anti-tamper technique because the coating caused malfunctioning. 

The program office and its contractor are working to resolve issues 

with the anti-tamper technique. 

• A program office was not able to copy anti-tamper techniques used by a 

similar program and, therefore, attempted to apply a generically 

developed anti-tamper coating, which resulted in problems. 

Specifically, the coating caused the system to malfunction, so the 

program office requested assistance from a national laboratory, but the 

laboratory’s solution melted key components of the system. Therefore, 

the program office requested that the contractor develop a new coating 

and other methods of protection for the system. The contractor’s antitamper techniques were successfully applied to the system. 

• One program required advanced anti-tamper techniques to protect 

miniaturized internal components, but the technology was still in 

development and not available for immediate application. According to 

program officials, research and development of the anti-tamper 

technique was originally expected to be completed in 2002 and is now 

estimated to be available in 2006. Currently, officials are uncertain that 

the technique will meet their needs because the technique is being 

generically developed. In the absence of being able to apply the antitamper technique, the program received approval from DOD to use 

procedural protections, whereby U.S. military personnel provide 

physical security of the system when it is used in foreign countries, 

which includes locking the unit in a protected room to restrict access 

by foreign nationals. DOD officials stated that physical security can be 

less reliable than actual anti-tamper protection. 

Some program managers told us that they need more help in deciding 

what anti-tamper techniques they should apply to their individual systems. 

To provide information, DOD has a classified database that describes 

current anti-tamper techniques. An Air Force Research Laboratory official 
Page 12 GAO-04-302 Defense Acquisitions 

stated that they are in the process of updating this database, developing a 

rating system on the value of various techniques to be included in the 

database, and creating a classified technology road map that will prioritize 

the needs for various anti-tamper techniques. These tools are currently 

unavailable.18 DOD and Sandia National Laboratories also have provided 

information on anti-tamper techniques and tools to program managers at 

periodic workshops where attendance is voluntary. 

To further assist program managers, DOD is in the process of overseeing 

the development of generic anti-tamper techniques, but it is uncertain to 

what extent such techniques address a program’s specific needs. In 2001, 

DOD issued several contracts to encourage anti-tamper technology 

development. To date, several defense contractors have provided antitamper technology concepts, but according to the Executive Agent, 

programs need to further develop the technology before it can be applied 

to and function on a particular system. According to Air Force Research 

Laboratory and Sandia National Laboratories officials, generic anti-tamper 

techniques can be considered, but program managers have to design and 

incorporate the techniques needed for their unique systems. Program 

managers ultimately have to ensure that the techniques protect critical 

technologies and do not adversely affect performance objectives for the 

system. 

Anti-tamper protection is one of the key ways DOD can preserve U.S. 

investment in critical technologies, while operating in an environment of 

coalition warfare and a globalized defense industry. However, 

implementation of the anti-tamper policy, thus far, has been difficult—in 

part because DOD has not developed an implementation strategy to ensure 

success. For program managers expected to implement anti-tamper 

protection, the policy can compete with their goals of meeting cost and 

schedule objectives, particularly when the anti-tamper requirement is 

identified late in the system development process. Without providing more 

oversight and guidance about what needs to be protected and how to do 

so, DOD is at risk of program managers making decisions on individual 

programs that can result in unprotected technologies and have negative 

consequences for maintaining the military’s overall technological 

advantage. 

 18According to a laboratory official, an initial prototype of an updated database is estimated 

to be available in 2004. 

Conclusions 
Page 13 GAO-04-302 Defense Acquisitions 

We are recommending that the Secretary of Defense direct the Under 

Secretary of Acquisition, Technology, and Logistics and the anti-tamper 

Executive Agent to take the following five actions to improve oversight 

and assist program offices in implementing anti-tamper protection on 

weapon systems. 

To better oversee identification of critical technologies for all programs 

subject to the anti-tamper policy, we recommend that the Secretary of 

Defense direct the Under Secretary for Acquisition, Technology, and 

Logistics, in coordination with the Executive Agent and the focal points, to 

(1) collect from program managers information they are to develop on 

critical technology identification and (2) appoint appropriate technical 

experts to centrally review the technologies identified for consistency 

across programs and services. 

To better support program managers in the identification of critical 

technologies, the Secretary of Defense should direct the Under Secretary 

for Acquisition, Technology, and Logistics, in coordination with the 

Executive Agent and the focal points, to (1) continue to identify available 

anti-tamper technical resources, (2) issue updated policy identifying roles 

and responsibilities of the technical support organizations, and (3) work 

with training organizations to ensure training includes practical 

information on how to identify critical technologies. 

To help minimize the impact to program cost and schedule objectives, the 

Secretary of Defense should direct the Under Secretary for Acquisition, 

Technology, and Logistics to work with program managers to ensure that 

the cost and techniques needed to implement anti-tamper protection are 

identified early in a system’s life cycle and to reflect that practice in 

guidance and decisions. 

To maximize the return on investment of DOD’s anti-tamper technology 

efforts, the Secretary of Defense should direct the Executive Agent to 

monitor the value of developing generic anti-tamper techniques and 

evaluate the effectiveness of the tools, once deployed, in assisting program 

managers to identify and apply techniques on individual programs. 

To ensure successful implementation of the anti-tamper policy, the 

Secretary of Defense should direct the Under Secretary for Acquisition, 

Technology, and Logistics to develop a business case that determines 

whether the current organizational structure and resources are adequate 

to implement anti-tamper protection and if not, what other actions are 

needed to mitigate the risk of compromise of critical technologies. 

Recommendations for 

Executive Action 
Page 14 GAO-04-302 Defense Acquisitions 

In written comments on a draft of this report, DOD partially concurred 

with one recommendation and offered an alternative solution, which we 

did not incorporate. DOD concurred with our remaining four 

recommendations and provided alternative language for two, which we 

incorporated as appropriate. DOD’s letter is reprinted in the appendix. 

DOD partially concurred with our recommendation to collect and centrally 

review the program’s critical technology identifications and proposed, 

instead, that it develop a standardized process to minimize subjectivity, 

incorporate that process into anti-tamper policy, and monitor subsequent 

implementation. As part of its rationale, DOD stated that technical 

representatives in the services currently work with program managers to 

implement the anti-tamper policy and that quarterly conferences and 

seminars are ways to disseminate important information to program 

managers. We believe DOD’s proposal is an improvement over the current 

process given that program managers need more technical support and 

guidance to identify critical technologies. However, we do not believe 

DOD’s proposal is sufficient because a central review mechanism is 

needed to ensure consistent critical technology identification across the 

services and the agencies. Without central visibility over program 

managers’ critical technology identifications, the risk exists that the same 

technology is protected on some systems but not on others. Knowledge 

gained from unprotected systems can expose critical technology to 

compromise, which minimizes the impact of anti-tamper protection. In 

addition, DOD’s dissemination of information at conferences may be 

limited because conference attendance is voluntary and all program 

managers may not attend and receive the information. Given the need for 

consistency and a central review, we did not revise our recommendation. 

DOD concurred with our remaining recommendations, but offered 

alternative language for two, which we incorporated. Specifically, for our 

recommendation aimed at better supporting program managers in 

identifying critical technologies, DOD proposed adding language that 

underscored the need for identifying technical resources and maintaining 

up-to-date policies on technical support organizations’ roles and 

responsibilities. While DOD has identified some resources and listed them 

in several documents, it has not developed a comprehensive list of 

resources to assist program managers. Therefore, we added to our 

recommendation that DOD continue to identify available anti-tamper 

technical resources. For our recommendation that DOD evaluate generic 

anti-tamper techniques, DOD proposed language that offered greater 

flexibility, which seemed reasonable and we incorporated. 

Agency Comments 

and Our Evaluation 
Page 15 GAO-04-302 Defense Acquisitions 

To determine how DOD implemented the anti-tamper policy, we collected 

data and interviewed officials from 17 programs, which were identified by 

DOD as having experience with implementing the policy or by us through 

our review. Twelve of the 17 programs reported that their systems had 

critical technologies, and most were in various stages of implementing the 

anti-tamper policy. From those programs we selected six for an in-depth 

review. We conducted structured interviews with the six programs that 

had identified critical technologies on their systems to understand their 

experiences with applying anti-tamper techniques. We selected systems 

that represented a cross-section of acquisition programs and various types 

of systems in different phases of development. To the extent possible, 

when selecting the programs for an in-depth review, we considered factors 

that may increase a system’s vulnerability and exposure to exploitation. 

We also considered whether the system was approved for export by 

examining the Defense Security Cooperation Agency’s data on foreign 

military sales. In addition, we analyzed available program information 

from the anti-tamper Executive Agent and the military focal points to 

determine programs reporting critical technologies and anti-tamper plans. 

DOD acknowledged that the information was incomplete, and we did not 

independently verify the reliability of the data. 

We supplemented the program information by interviewing the Executive 

Agent, the military focal points, representatives from the intelligence 

community, DOD’s Executive Committee, the Department of Energy’s 

Sandia National Laboratories, the Air Force Research Laboratory, defense 

contractors, and an electronic security specialist. We also discussed 

DOD’s anti-tamper policy with current and former officials from the Office 

of the Secretary of Defense. To observe DOD’s training of program 

managers, we attended a DOD anti-tamper information workshop and a 

quarterly review. We analyzed pertinent DOD policies, directives, 

instructions, and guidance governing anti-tamper protection on systems. 

We also conducted a literature search to obtain information on program 

protection and industry practices related to anti-tamper measures. 

We are sending copies of this report to interested congressional 

committees; the Secretary of Defense; and the Director, Office of 

Management and Budget. We will make copies available to others upon 

request. In addition, this report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 

Scope and 

Methodology 
Page 16 GAO-04-302 Defense Acquisitions 

If you or your staff have any questions concerning this report, please call 

me at (202) 512-4841. Others making key contributions to this report were 

Anne-Marie Lasowski, Yelena T. Harden, Gregory K. Harmon, and Holly 

Ciampi. 

Katherine V. Schinasi 

Managing Director 

Acquisition and Sourcing Management 
Appendix: Comments from the Department of Defense 

Page 17 GAO-04-302 Defense Acquisitions 

Appendix: Comments from the Department 

of Defense 
Appendix: Comments from the Department of Defense 

Page 18 GAO-04-302 Defense Acquisitions 
Appendix: Comments from the Department of Defense 

Page 19 GAO-04-302 Defense Acquisitions 
Appendix: Comments from the Department of Defense 

Page 20 GAO-04-302 Defense Acquisitions 
Appendix: Comments from the Department of Defense 

Page 21 GAO-04-302 Defense Acquisitions (120311) 
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