GAO

United States General Accounting Office

Report to Congressional Requesters

April 2000 COMBATING 

TERRORISM

How Five Foreign 

Countries Are 

Organized to Combat 

Terrorism

GAO/NSIAD-00-85

Page 1 GAO/NSIAD-00-85 Combating Terrorism

Contents

Letter 3

Appendixes Appendix I: Security-Related Policy Development and Incident

Leadership in Canada, France, Germany, Israel, and the United

Kingdom 16

Appendix II: Principal Law Enforcement and Intelligence

Organizations in Canada, France, Germany, Israel, and the United 

Kingdom 18

Appendix III: Principal Terrorism Laws, Definitions, and Other Legal 

Information in Canada, France, Germany, Israel, and the United

Kingdom 20

Appendix IV: Security-Related Oversight Organizations and Functions

in Canada, France, Germany, Israel, and the United Kingdom 22

Appendix V: GAO Contacts and Staff Acknowledgments 24

Related GAO Products 25
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United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-284585 Letr

April 7, 2000

Congressional Requestors

In fiscal year 1999, the federal government spent about $10 billion to 

combat terrorism. Over 40 federal departments, agencies, and bureaus 

have a role in combating terrorism. The amount of spending and the large 

number of agencies involved have prompted some Members of Congress to 

question who is in charge of U.S. efforts to combat terrorism, how the 

federal government is organized to prevent and respond to terrorism on 

U.S. soil, and how resources are being allocated.

Based on these concerns, and recognizing that other countries have had 

more experience dealing with terrorist attacks within their borders, you 

asked us to provide information on (1) how other governments are 

organized to combat terrorism and (2) how they allocate their resources to 

combat terrorism. We selected Canada, France, Germany, Israel, and the 

United Kingdom for the focus of our work.1

Over the years, we have found problems with efforts to combat terrorism in 

the United States. For example, we reported in 1999 that the overall 

command (i.e., who is in charge) at a terrorist incident was not clearly 

designated or agreed to among federal, state, and local governments.2

 In 

1998, we reported that some federal resources to combat terrorism were 

being increased without a clear link to likely threats and that programs 

were being developed based on vulnerabilities, not likely terrorist attacks.3

We also reported in 1999 that these programs potentially duplicated 

1

We selected these five countries based on terrorism-related activities within their borders, 

the type of government, and our ability to conduct work in these countries. For more details 

on our selection criteria, and how we conducted our work, see our scope and methodology 

section.

2

Combating Terrorism: Issues to Be Resolved to Improve Counterterrorism Operations

(GAO/NSIAD-99-135, May 13, 1999).

3

Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and Target 

Program Investments (GAO/NSIAD-98-74, Apr. 9, 1998).
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existing federal emergency response capabilities.4 A list of related GAO 

products appears at the end of this report.

The information in this report describes similarities we found in how the 

five countries we examined are organized and how they allocate resources 

to combat terrorism. The appendixes provide more details on each 

individual country. Since our objectives were to describe the efforts of 

these other countries, we did not compare or contrast this information with 

how the United States is organized to combat terrorism and we are not 

making any recommendations.

Results in Brief The five countries we examined have similarities in how they are organized 

to combat terrorism.

• The countries generally have the majority of organizations used to 

combat terrorism under one lead government ministry. However, 

because many other ministries are also involved, the countries have 

created interagency coordination bodies to coordinate both within and 

across ministries. For example, while many countries generally have 

their intelligence and law enforcement organizations under their 

ministries of interior or equivalent, they also need to coordinate with 

their ministries of foreign affairs, defense, and health or emergency 

services.

• The countries have clearly designated who is in charge during a terrorist 

incident—typically their national or local police.

• The countries have national policies that emphasize prevention of 

terrorism. To achieve their policies, the countries use a variety of 

strategies, including intelligence collection, police presence, and various 

security measures such as physical barriers at the entrances to public 

buildings.

• These countries primarily use their general criminal laws (e.g., those for 

murder or arson) to prosecute terrorists. The countries also have special 

terrorism-related laws that allow for special investigations or 

prosecution mechanisms and increased penalties.

• The countries’ executive branches provide the primary oversight of 

organizations involved in combating terrorism. This oversight involves 

4

Combating Terrorism: Observations on Federal Spending to Combat Terrorism

(GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).
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reviewing the programs and resources for effectiveness, efficiency, and 

legality.

The five countries we examined also had similarities in how they allocate 

resources to combat terrorism. Officials in the ministries involved said they 

make resource allocations based upon the likelihood of threats taking 

place, as determined by intelligence assessments. While the officials we 

met with discussed resource levels in general, none of the five countries 

tracked overall spending on programs to combat terrorism. Such spending 

was imbedded in other accounts for broad organizational or functional 

areas such as law enforcement, intelligence, and defense. Officials in all 

countries told us that because of limited resources, they made funding 

decisions for programs to combat terrorism based on the likelihood of 

terrorist activity actually taking place, not the countries’ overall 

vulnerability to terrorist attack. They said their countries maximize their 

existing capabilities to address a wide array of threats, including emerging 

threats, before they create new capabilities or programs.

Background All five countries we visited have parliamentary style governments with 

various ministries that provide an array of government services. For 

example, a ministry of the interior may provide national law enforcement 

and intelligence services. In a parliamentary style of government, the 

executive branch has the dominant role in the development of policy and 

strategy. Members of the legislative branch generally make up the cabinet, 

which under the prime minister or the chancellor leads the executive 

branch of government.5

 The prime minister or the chancellor also leads the 

majority political party, and because of party discipline, the majority party 

in the legislature does not provide an independent role and the minority 

party does not have much of a role in policy development.6

5

For the purposes of this report, we use the term “executive branch” to refer to those 

ministries, departments, or organizations that perform executive-type functions. The term 

“legislative branch” refers to those bodies of elected representatives that enact laws such as 

the Parliaments in Canada and the United Kingdom, the National Assembly and Senate in 

France, the Bundestag and Bundesrat in Germany, and the Knesset in Israel.

6

While minority parties generally do not have a large role in policy development, they could 

have a large role in a coalition government where they form a coalition and align with a 

larger party.
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Some of the countries we visited have strong central governments, while 

others have strong regional or state governments. For example, Canada 

with its provinces and Germany with its states represent countries that 

have relatively strong regional governments compared to France, Israel, 

and the United Kingdom that have relatively strong central governments. 

To some extent, the division of power between the central and regional 

governments determines how these countries organize their efforts to 

combat terrorism. For example, in some countries the national police play 

a key role, while in other countries the regional or local police play a key 

role.

Officials in Canada, France, and Germany told us that the current threat 

from terrorism in their countries is low. According to a 1998 Department of 

State report on global terrorism, terrorism in Europe has declined, in part, 

because of the increased vigilance by security forces and the recognition by 

some terrorist groups that long-standing political and ethnic controversies 

should be addressed by negotiations. For example, the remnants of 

Germany’s Red Army Faction, once among the world’s deadliest, 

announced the dissolution of their organization. In Israel, officials 

indicated that the level of terrorism fluctuates with the peace process—

terrorism typically increases when the peace process is working, as those 

opposed to the peace process try to derail it through violence. In the United 

Kingdom, officials said that terrorism related to Northern Ireland continues 

to take place and poses a real threat depending, in part, on developments in 

the peace process. They added that although activity is at historically low 

levels, the threat remains and is linked to developments in the peace 

process. Officials from all five countries cited the threat of terrorists using 

chemical, biological, radiological, and nuclear weapons as particularly 

unlikely.

Organization, 

Coordination, Incident 

Command, Policies, 

Laws, and Oversight 

Are Similar

The five countries we examined have similarities in how they are organized 

to combat terrorism. Specifically, each country places the majority of 

resources for combating terrorism under one ministry, but each recognizes 

that it must coordinate its efforts to develop national policy on combating 

terrorism so it has interagency coordination bodies. Each country also has 

clearly designated leadership at the scene of terrorist incidents. The five 

countries have policies and strategies that emphasize the prevention of 

terrorism using resources such as intelligence collection, police presence, 

and security measures. In addition, each country uses its general criminal 

laws (e.g., those for murder or arson) to prosecute terrorists. The countries 

also have special terrorism-related laws that allow for special investigation 
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or prosecution mechanisms, and increased penalties. In each of the five 

countries, the executive branch provides the primary oversight of 

organizations involved in combating terrorism.

Lead Organization With 

Policy Coordination

In four countries, most of the resources to combat terrorism—law 

enforcement and intelligence services—are centralized under a lead 

agency, generally the countries’ ministry of interior or equivalent.7

 For 

example, the French Ministry of Interior includes the National Police and 

the two domestic intelligence agencies that have a primary role in 

combating terrorism. However, officials from all the countries said they 

view counterterrorism as an intergovernmental effort that requires 

coordination among law enforcement, intelligence, and other parts of the 

government that may be involved in combating terrorism, including foreign 

affairs, the military, and health and emergency services. Since they view 

combating terrorism as an interagency effort, officials in each country 

identified the prime minister or the chancellor as the one person in charge 

of combating terrorism. Below that level, the effort to combat terrorism 

requires an interagency body to formulate policy, coordinate activities, and 

provide recommendations to the prime minister or the chancellor. In Israel, 

for example, there is an interagency body called the Bureau for 

Counterterrorism that coordinates activities and provides advice to the 

prime minister regarding terrorism matters. Appendix I shows the interior 

ministries or equivalent that lead efforts to combat terrorism and the 

interagency bodies that provide coordination and advice on terrorism 

issues to the prime minister or the chancellor.

Clearly Designated Incident 

Leadership

All five countries have clearly designated who is to be in charge during a 

terrorist incident. For example, in the United Kingdom, the local Chief 

Constable (i.e., chief of police) has overall control of all aspects of handling 

a terrorist incident. For Israel, the National Police are in command within 

Israel, and the military are in command in the occupied territories. 

Appendix I provides details on who is designated to command at terrorist 

incidents for the rest of the countries.

7

In Israel, the National Police are under one ministry; however, the main domestic and 

international intelligence services are not in the same ministry as the National Police and 

report directly to the prime minister.
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Incident leadership is reinforced through written agreements and 

contingency plans or other agreements. For example, in Canada, the Royal 

Canadian Mounted Police has written agreements with major municipal 

police departments on who leads the incident response. The French 

government has written interagency contingency plans with command and 

control details for such terrorist situations as a heightened threat, aircraft 

hijacking, ship hijacking, or a chemical attack. Officials in the five 

countries stated that they use the agreements or plans as the basis of their 

exercises to practice their response, which further reinforces who leads at 

the incident site. Clear incident command is also strengthened because the 

incident commander controls all response elements, including police, fire, 

medical, and other emergency services. Thus, there is one commander for 

police activities (e.g., assaults, arrest, and gathering evidence) as well as 

other emergency activities (e.g., evacuation, search and rescue, medical 

treatment, and decontamination). Officials in the United Kingdom cited the 

importance of having one person—the Chief Constable—in charge of the 

entire response. Officials in the other four countries made similar 

comments on the need for clear and unified leadership for the whole range 

of activities in a response to a terrorist attack.

Policies and Strategies 

Emphasize Prevention 

Each country had developed policies to combat terrorism through their 

experience with various terrorist groups. The five countries’ national 

policies to combat terrorism, which were not always written, emphasized 

prevention. Canadian officials were the only ones to provide us with their 

written policies on terrorism. Officials in the other countries told us they 

had no written policies. To implement their national policies, these 

countries had strategies that included intelligence collection, police 

presence, and other deterrent measures.

For example, the strategies in all five countries include domestic 

intelligence, and each has at least one security intelligence organization 

that gathers intelligence on domestic terrorist activities. Officials we spoke 

with said that an effective intelligence capability is essential for preventing 

acts of terrorism in their countries. In general, the role of their domestic 

security intelligence organizations is to prevent acts of terrorism by 

gathering information through a variety of sources and methods; assessing 

the threats to security; and monitoring and sometimes disrupting the 

activities of certain groups considered to be a threat within the country.

All of the countries’ domestic intelligence organizations are separate from 

their law enforcement organizations. In Canada, France, and the United 
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Kingdom, these organizations are under a single ministry. In Germany there 

are parallel federal and state intelligence and law enforcement 

organizations, and both are under their respective ministries of the interior. 

In Israel, the intelligence organizations report directly to the prime 

minister, and the national police are under the Ministry of Public Security. 

Cooperation between both law enforcement and intelligence organizations 

was cited by officials in all five countries as important, in part, because the 

domestic intelligence organizations do not have powers of arrest. Law 

enforcement organizations become involved in combating terrorism when 

information from the intelligence services indicates that criminal activity 

has occurred, or is likely to occur, or when their own criminal intelligence 

sources indicate such. Appendix II shows the principal law enforcement 

and intelligence organizations of the countries we visited.

In addition to a strong intelligence capability, we found that the countries’ 

strategies included using a visible police presence to prevent acts of 

terrorism. For example, in France, when there is a specific terrorist threat, 

law enforcement increases its public presence in a visible show of force. 

Likewise, the German Federal Border Police can provide additional 

manpower to supplement state police at events such as political 

demonstrations. In Israel, the National Police, as well as military personnel, 

is present at various locations throughout the metropolitan areas to 

respond to incidents as needed.

As part of their prevention strategies, the five countries use a variety of 

other techniques to deter terrorist attacks. For example, all five countries 

use physical barriers in certain critical areas and government buildings to 

deter direct attacks. Other techniques are as follows. In Israel, individuals 

and their belongings are often physically searched by police, defense 

personnel, or security contractors and pass through metal detectors before 

entering such places as shopping centers, airports, and local attractions. In 

the United Kingdom, police use video cameras to monitor daily events and 

watch for suspicious activity in London. In France, persons entering 

government buildings typically walk through metal detectors.

Countries Use Combination 

of General and Specific 

Laws

All five countries use their general criminal laws to prosecute offenses 

committed during a terrorist act, such as the crimes of murder, arson, 

kidnapping, and hijacking. According to Canadian officials, treating 

terrorism as ordinary crime removes the political element and thereby 

dilutes the effectiveness of the terrorist act. The countries have also 

enacted a variety of special laws that relate to terrorism that may include a 
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statutory definition or description of terrorism, or may invoke special 

investigation or prosecution procedures, or provide for increased penalties. 

Under French law, certain criminal offenses are considered terrorism when 

the acts are intentionally linked to an individual or group whose purpose is 

to cause a serious disruption of public order through intimidation or terror. 

Penalties may be increased if a criminal offense is related to such 

terrorism. France also has special judicial procedures to address terrorism 

such as special courts and prosecutors. Germany’s criminal code has a 

special prohibition against the formation and support of a terrorist 

association. In addition to its general criminal laws, Israel has two principal 

laws that govern terrorism that contain a number of criminal offenses such 

as supporting terrorist organizations. The United Kingdom has two 

principal terrorism laws that designate a number of criminal offenses 

relating to membership in and support of terrorist organizations. 

Appendix III provides additional information on the terrorism-related laws 

in the five countries.

Executive Branch Provides 

Oversight

Oversight reviews of programs and resources for effectiveness, efficiency, 

and legality are primarily the responsibility of those ministers in the 

executive branch that have a role in combating terrorism. Officials told us 

that in their parliamentary style of government, ministers are accountable 

for oversight and that this function is embedded in the ministers’ 

responsibilities. They generally viewed oversight as an ongoing routine 

function of agency management, not an independent or separate review 

function. For example, in France, the Minister of the Interior, through their 

daily activities, reviews or oversees the activities of those resources within 

the Ministry.

The legislatures in these countries do not hold oversight hearings or write 

reports that evaluate programs to combat terrorism. In these parliamentary 

style governments, the legislative branches do not provide ongoing 

independent oversight of efforts to combat terrorism. While the five 

countries do conduct some legislative review of national security activities 

(e.g., through designated legislative committees), these reviews generally 

have not focused on activities to combat terrorism. At times, some 

members of the legislative branch are included in standing or ad hoc 

executive oversight bodies. In Canada and Israel, independent reviews of 

activities to combat terrorism are done by their national audit agencies. 

Appendix IV summarizes oversight organizations and functions in the five 

countries we visited.
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Resource Allocations 

Based on Threat 

Assessments

Officials in the ministries involved in combating terrorism within the five 

countries we visited said they made resource allocations based upon the 

likelihood of threats taking place, as determined by intelligence 

assessments. While the officials we met with discussed resource levels in 

general, none of the five countries tracked overall spending on programs to 

combat terrorism. Such spending was imbedded in other accounts for 

broad organizational or functional areas such as law enforcement, 

intelligence, and defense. Due to resource constraints, they said their 

countries maximize their existing capabilities to address a wide array of 

threats, including emerging threats, before they create new capabilities or 

programs.

Resource Allocations 

Targeted at Likely Threats, 

Not Vulnerabilities

The five countries we reviewed receive terrorist threat information from 

their civilian and military intelligence services and foreign sources. Using 

various means, each of the countries’ intelligence services continuously 

assess these threats to determine which ones could result in terrorist 

activity and require countermeasures, which ones may be less likely to 

occur but may emerge later, and which ones are unlikely to occur. Officials 

in all countries told us that because of limited resources, they made 

funding decisions for programs to combat terrorism based on the 

likelihood of terrorist activity actually taking place, not the countries’ 

overall vulnerability to terrorist attack. For example, each of the countries 

may be vulnerable to a chemical, biological, radiological, or nuclear attack 

by terrorists, but officials believe that such attacks are unlikely to occur in 

the near future for a variety of reasons, including the current difficulty in 

producing and delivering these types of weapons. Furthermore, officials in 

one country told us that the effects of these types of weapons would 

alienate the population from the political aim of the terrorist groups and 

therefore did not view this type of attack as likely. Officials we spoke with 

believed that conventional bombs and other traditional means, such as 

hijacking, are more likely to occur.

Countries Maximize 

Existing Capabilities to 

Respond to Emerging 

Threats

For less likely but emerging threats, officials in the five countries told us 

that they generally try to maximize their existing capabilities for 

responding to such threats, rather than create new programs or 

capabilities. For example, the same capabilities used to respond to a fire, 

industrial explosion, or chemical spill would be used for a terrorist incident 

involving chemical, biological, radiological, or nuclear weapons. In 

addition, officials in each country said additional capabilities from 
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neighboring states, provinces, cities, or national governments could be 

used by local authorities if the situation exceeded their capabilities. For 

example, Germany plans to rely on existing capabilities within the states 

rather than develop new federal capabilities. Likewise, Israel has not 

developed new capabilities, but it has a nationwide program that provides 

gas masks and training to its citizens for defense against chemical or 

biological attack in wartime that officials said has use for terrorist attacks. 

The countries generally did not have major training programs in place to 

train emergency response personnel for chemical, biological, radiological, 

or nuclear attacks. However, the United Kingdom has a limited program to 

train selected police officials as incident commanders and is considering a 

training program for response personnel in selected locations. Also, 

Canada has launched a policy initiative to develop a strategy to strengthen 

national counterterrorism response capability, particularly the ability to 

respond to chemical, biological, radiological, and nuclear terrorist attacks. 

Only France has created new capabilities to respond to chemical, 

biological, radiological, and nuclear terrorist attacks.

Country Comments We provided a draft of this report to officials from all five countries for 

their review and comment. All of the officials provided us with oral 

comments indicating they agreed with the report’s overall content and our 

description of their countries’ efforts. Officials from Canada and the United 

Kingdom also provided written comments of a technical nature, and we 

incorporated their changes where appropriate.

Scope and 

Methodology

We examined how Canada, France, Germany, Israel, and the United 

Kingdom were organized to combat terrorism. In selecting these countries, 

we considered the historic level of terrorism and related activities within 

their borders, the type of government, and our ability to conduct work in 

the countries. We also consulted with officials from the U.S. State 

Department’s Office of the Coordinator for Counter Terrorism and other 

experts in the field of terrorism inside and outside the federal government 

about which countries we should examine. Based on our criteria and these 

consultations, we selected Canada, France, Germany, Israel, and the United 

Kingdom.

Our scope was limited by two factors. First, we did not have audit authority 

in the five countries; thus, we relied on the cooperation of foreign officials. 

While we had numerous meetings with officials in the five countries, we 
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usually did not have access to many of their internal documents, classified 

plans, or policy evaluations. Second, we were in each country for a 

relatively short time, ranging from 1 to 2 weeks. As a result of these 

limitations, we sought to describe how each country organized its 

programs to combat terrorism, not to evaluate the operations or the 

effectiveness of those programs. For our review of terrorism-related laws, 

we relied on officials to identify appropriate statutes and did not do our 

own comprehensive research or analysis of the countries’ laws.

Because of the limitations we faced in reviewing foreign countries’ policies 

and programs, we asked the foreign officials to comment on the accuracy 

of our work. After we conducted our overseas visits, we wrote summaries 

documenting our observations and conclusions and sent them to the 

officials for their verification, review, and comment. All of the officials 

provided written comments, and we made changes to our summaries as 

appropriate. We then used these summaries as the basis for drafting this 

report.

Our overall methodology consisted of reviewing applicable documents and 

interviewing a broad array of national-level government officials whose 

organizations had a significant role in combating terrorism. Where 

possible, we met with regional and local government officials in the 

countries we visited. We also met with contacts outside the government to 

provide us with different perspectives on the countries’ efforts to combat 

terrorism. For example, we met with experts from academia, research 

organizations, the media, and other nongovernmental organizations. For 

our specific objectives, we interviewed officials at the level of government 

most able to provide us information on our topics. 

To describe how the five governments were organized to combat terrorism, 

including oversight of terrorism programs, we met with officials from the 

prime minister’s or chancellor’s office; legislative committee members with 

responsibility regarding counter terrorism programs; and officials within 

the ministries of interior, justice, defense, and other ministries that had a 

role in combating terrorism. We also met with officials that have direct 

responsibility for responding to and managing a terrorist incident. These 

included officials who represented the countries’ national police, 

intelligence, military, and emergency medical organizations. To describe 

oversight of terrorism programs, we met with members of legislative 

committees, and national audit organizations and officials of inspector 

general offices where they were present.
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To describe how the countries allocate their resources to combat terrorism, 

we met with many of the same officials above and focused our discussions 

on how they analyzed threats and allocated resources for these programs. 

We conducted our review from May 1999 through January 2000 in 

accordance with generally accepted government auditing standards.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of this report until 

30 days after its issue date. At that time, we will send copies to appropriate 

congressional committees and the federal agencies that combat terrorism. 

We will also make copies available to other interested parties upon request.

If you have any questions about this report, please contact me or Ray 

Decker, Acting Associate Director for National Security Preparedness 

Issues, at (202) 512-5140. Other major contributors to this report are listed 

in appendix V.

Norman J. Rabkin

Director, National Security Preparedness Issues
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List of Congressional Requesters

The Honorable Ted Stevens

Chairman

The Honorable Robert Byrd

Ranking Member

Committee on Appropriations

United States Senate

The Honorable Christopher S. Bond 

Chairman

The Honorable Barbara Mikulski

Ranking Member

Subcommittee on Veterans Affairs, Housing and 

 Urban Development and Independent Agencies

Committee on Appropriations

United States Senate

The Honorable Ike Skelton

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Christopher Shays

Chairman

Subcommittee on National Security, Veterans 

 Affairs, and International Relations

Committee on Government Reform

House of Representatives
Page 16 GAO/NSIAD-00-85 Combating Terrorism

Appendix I

Security-Related Policy Development and 

Incident Leadership in Canada, France, 

Germany, Israel, and the United Kingdom ApendxiI

Canada France Germany Israel United Kingdom

Interagency policy 

coordination body

Privy Council Office 

is the office that 

provides advice to 

the prime minister 

and the cabinet on 

terrorism issues. The 

Privy Council Office 

obtains input from 

the Solicitor 

General’s Office for 

national policy and 

the Ministry of 

Foreign Affairs for 

international policy.

Interministerial 

Liaison Committee 

Against Terrorism

(Comité 

Interministériel de 

Lutte Anti-Terroriste) 

is a high level 

committee that 

develops policy and 

includes the Prime 

Minister and 

Ministers of Interior, 

Defense, Justice, 

and Foreign Affairs.

Anti-Terrorism 

Coordination Unit

(Unité de 

Coordination de la 

Lutte Anti-Terroriste) 

is a working level 

coordination group 

that includes 

agencies from the 

Ministries of Interior 

and Defense that 

coordinate 

operations.

Coordinator for 

Intelligence

(Koordinierung der 

Nachrichtendienste 

des Bundes) is a 

direct advisor to the 

Chancellor and 

develops a general 

policy framework and 

coordinates state 

issues. The Federal 

Ministry of the 

Interior includes 

police, intelligence, 

and border police, 

and provides federal 

policy for combating 

terrorism.

Bureau for 

Counterterrorism 

makes 

recommendations on 

terrorism policy and 

works with agencies 

involved in 

combating terrorism 

to formulate 

recommendations. 

The Bureau includes 

representatives from 

all agencies involved 

in combating 

terrorism and reports 

directly to the Prime 

Minister.

Official Committee 

on Terrorism 

coordinates 

interagency counterterrorism policy 

development with 

input from the 

organizations directly 

involved in 

combating terrorism 

(Home Office, 

Foreign and 

Commonwealth 

Office, and 

Association of Chief 

of Police Officers).

Organization with 

primary responsibility 

for combating 

terrorism

Solicitor General is 

the ministry that 

includes the 

intelligence and law 

enforcement 

resources for 

combating terrorism. 

Within this ministry 

the Canadian 

Security Intelligence 

Service provides the 

overall threat 

assessment for 

Canada and the 

Royal Canadian 

Mounted Police 

provides law 

enforcement.

Ministry of Interior 

(Ministère de 

L’Intérieur) hosts the 

interagency AntiTerrorism 

Coordination Unit. 

This ministry 

includes the National 

Police, the Central 

Headquarters for 

Surveillance of the 

Territory, and the 

General Intelligence 

Central Service. 

State-level Ministries 

of Interiors

(Staatsministerium 

des Innern) includes 

police, intelligence, 

and emergency 

preparedness. Each 

state ministry of 

interior is 

represented in a 

Council of Interior 

Ministers that 

addresses a variety 

of intelligence, law 

enforcement, and 

emergency 

preparedness 

issues.

Ministry of Internal 

Security includes 

resources to combat 

terrorism—the 

National Police and 

the Border Guard. 

Ministry of Defense 

provides law 

enforcement in the 

occupied territories 

and the Home Front 

Command−a 

command within the 

military−provides civil 

assistance 

management 

through out Israel.

Home Office is 

equivalent to an 

Interior Ministry and 

manages domestic 

terrorism programs. 

It has purview over 

law enforcement, 

domestic 

intelligence, and 

emergency 

management. 

Continued
Appendix I

Security-Related Policy Development and 

Incident Leadership in Canada, France, 

Germany, Israel, and the United Kingdom

Page 17 GAO/NSIAD-00-85 Combating Terrorism

Note: For overseas terrorist incidents involving its citizens, the Ministry of Foreign Affairs or equivalent 

in each country typically provides input to the interagency coordination body on terrorism policy.

Source: Our interviews with selected officials and review of documents from each country.

Canada France Germany Israel United Kingdom

Leadership during an 

incident

Royal Canadian 

Mounted Police is 

Canada’s national 

police force. Canada 

also has municipal 

police in larger cities. 

The Mounted Police 

and municipal police 

forces have 

memorandums of 

understanding 

describing how law 

enforcement will be 

coordinated and who 

will be in charge. The 

Royal Canadian 

Mounted Police are 

under the Ministry of 

the Solicitor General.

Préfet is a regional 

political appointee 

who supervises 

police and 

emergency activities 

at a terrorist scene.

Federal police would 

take command over 

the terrorist incident 

upon direction of the 

federal prosecutor, or 

at the request of the 

state. The federal 

criminal police 

(Bundeskriminalamt) 

are under the federal 

ministry of interior. 

First responders 

would be the state 

police 

(Ländeskriminalamt) 

under the state’s 

interior ministry. 

State police would 

provide support to 

their federal 

counterparts.

National Police or 

Military are in charge 

of a terrorist incident 

in Israel, depending 

on the location of the 

incident. In the 

occupied territories, 

the military responds 

to and remains in 

charge of a terrorist 

incident. In the rest of 

Israel, the National 

Police respond to an 

incident and remain 

in charge throughout 

the incident.

Local Chief 

Constable is the 

official in charge at 

the incident and 

decides whether to 

bring in other support 

as needed. The 

entire government 

works to support the 

police at the scene.

Continued from Previous Page
Page 18 GAO/NSIAD-00-85 Combating Terrorism

Appendix II

Principal Law Enforcement and Intelligence 

Organizations in Canada, France, Germany, 

Israel, and the United Kingdom ApendxiI

Canada France Germany Israel United Kingdom

Law Enforcement 

Organizations

Royal Canadian 

Mounted Police is the 

national police force 

that has primary 

responsibility for 

prevention, protection, 

and investigation of 

offenses that constitute 

a threat to the security 

of Canada. They also 

serve as provincial and 

municipal police in 

many areas across 

Canada and are under 

the Ministry of the 

Solicitor General.

Two provinces and most 

municipalities have their 

own police forces. Many 

have agreements with 

the Royal Canadian 

Mounted Police to 

facilitate cooperation 

during terrorist 

incidents. 

National Police

(Direction Générale 

de la Police 

Nationale) is the lead 

civilian national 

police force that has 

jurisdiction in large 

urban areas. It is 

divided into 

specialized 

directorates for such 

functions as border 

security and 

protection of 

dignitaries and is 

under the Ministry of 

the Interior.

National 

Gendarmerie 

(Direction Générale 

de la Gendarmerie 

Nationale) is 

responsible for law 

enforcement in small 

towns and rural 

areas and is under 

the Ministry of 

Defense.

Federal Criminal 

Police 

(Bundeskriminalamt) 

is responsible for 

protection and 

investigation of acts 

of terrorism and 

extremism and is 

under the Ministry of 

the Interior. 

State Criminal Police 

(Ländeskriminalamt) 

is responsible for 

criminal 

investigations within 

the states and may 

assist the federal 

police during 

terrorism cases. 

Under the states’ 

ministries of interior.

Federal Border 

Guard 

(Bundesgrenzschutz) 

provides security at 

the borders, 

transportation sites, 

and other federal 

areas. It assists state 

police when large 

forces are needed 

and is under the 

Ministry of the 

Interior.

Israeli National 

Police is the principal 

civilian police force 

and is under the 

Ministry of Public 

Security.

Border Guard is the 

National Police’s 

principal mobile task 

force, focuses on 

internal security, and 

has a special 

antiterrorist unit.

Israeli Defense Force 

provides law 

enforcement in the 

occupied territories.

County Police 

Forces. Each county 

or group of counties 

has a police force led 

by a chief constable. 

The Metropolitan 

Police Service in 

London has the AntiTerrorist Branch, 

which the chief 

constables of other 

police forces can call 

on for assistance. 

Continued
Appendix II

Principal Law Enforcement and Intelligence 

Organizations in Canada, France, Germany, 

Israel, and the United Kingdom

Page 19 GAO/NSIAD-00-85 Combating Terrorism

Source: Our interviews with selected officials and review of documents from each country.

Canada France Germany Israel United Kingdom

Domestic 

Intelligence 

Organizations

Canadian Security 

Intelligence Service is 

responsible for 

collection, analyses, 

production, and 

dissemination of 

security intelligence on 

terrorism. It participates 

in information sharing 

with allied countries but 

does not independently 

conduct operations 

abroad and is under the 

Ministry of the Solicitor 

General.

Central 

Headquarters for 

Surveillance of the 

Territory

(Direction de la 

Surveillance du 

Territoire) is 

responsible for 

intelligence 

regarding internal 

threats from external 

sources and is under 

the Ministry of the 

Interior, Director of 

the National Police.

General Intelligence 

Central Service

(Direction Centrale 

des 

Renseignenments 

Généraux) is 

responsible for 

intelligence 

regarding internal 

threats from internal 

sources and is under 

the Ministry of the 

Interior, Director of 

the National Police.

The Federal Office 

for the Protection of 

the Constitution 

(Bundesamt für 

Verfassungsschutz) 

collects and analyzes 

intelligence relating 

to politically 

motivated extremism, 

including terrorism, 

and coordinates with 

its state counterparts. Under the 

Ministry of the 

Interior.

State Offices for the 

Protection of the 

Constitution 

(Landesämter für 

Verfassungsschutz) 

have similar roles but 

are independent of 

the federal 

government and are 

under the states’ 

ministries of interior.

Israeli Security 

Agency is 

responsible for 

internal intelligence 

collection and 

analyses, 

counterespionage, 

and the prevention of 

terrorist acts. It 

reports directly to the 

Prime Minister and is 

formerly the General 

Security Service.

British Security 

Service gathers 

intelligence internally 

to investigate and 

disrupt terrorist 

activity, provide 

advice to the 

government on 

domestic security 

matters, and issue 

threat assessments. 

It reports directly to 

the Home Office 

and/or the Prime 

Minister and is also 

known as MI-5.

Other Intelligence 

Organizations

Department of National 

Defense established 

intelligence response 

teams to produce 

intelligence for 

supporting senior 

officials, planners, and 

the Department’s 

hostage rescue unit. 

Communications 

Security Establishment 

gathers intelligence 

through electronic 

means and is 

responsible for 

protecting information 

technology 

infrastructure.

General 

Headquarters for 

Security Overseas 

(Direction Générale 

de la Sécurité 

Exterieure) is 

responsible for 

intelligence gathering 

abroad and is under 

the Ministry of 

Defense.

Central 

Headquarters 

Military Intelligence 

(Direction 

Reseignments 

Militaire) collects and 

analyzes military 

intelligence and is 

under the Ministry of 

Defense.

German Intelligence 

Service 

(Bundesnnachrichtendienst) is 

responsible for the 

investigation of 

threats from abroad.

Military Intelligence 

Service (Militärischer 

Abschirmdienst) 

focuses on 

intelligence matters 

that are relevant to 

military affairs and is 

under the Ministry of 

Defense.

Mossad is Israel’s 

primary foreign 

intelligence service 

and reports directly 

to the prime minister.

Ministry of Defense 

has a section that 

focuses on military 

intelligence and 

works with the 

Mossad and the 

Israeli Security 

Agency to prepare 

the annual threat 

assessment.

Secret Intelligence 

Service is Britain’s 

lead foreign 

intelligence service. 

Under the Foreign 

and Commonwealth 

Office it reports 

directly to the Prime 

Minister and is also 

known as MI-6.

Government 

Communications 

Headquarters 

collects 

communications 

intelligence.

Continued from Previous Page
Page 20 GAO/NSIAD-00-85 Combating Terrorism

Appendix III

Principal Terrorism Laws, Definitions, and 

Other Legal Information in Canada, France, 

Germany, Israel, and the United Kingdom ApendxiI

Canada France Germany Israel United Kingdom

Principal terrorismrelated laws Security Offenses 

Act (1984) and 

Canadian Security 

Intelligence Service 

Act (1984)

Chapters I and II of 

title II (Terrorism) of 

the Penal Code and 

the Code of Criminal 

Procedure

Section 129(a) of the

Criminal Code

Defense and 

Emergency Act 

(1945) and the

Prevention of 

Terrorism Ordinance 

(1948)

Prevention of 

Terrorism (Temporary 

Provisions) Act of 

1989 and the 

Northern Ireland 

(Emergency 

Provisions) Act of 

1998

Definition or 

description of 

terrorism

Canadian Security 

Intelligence Service 

Act does not 

explicitly define 

terrorism but applies 

to “threats to the 

security of Canada.” 

Such threats include 

“activities within or 

relating to Canada 

directed toward or in 

support of the threat 

or use of acts of 

serious violence 

against persons or 

property for the 

purpose of achieving 

a political objective 

within Canada or 

foreign state.”

The Penal Code ties 

terrorist-related acts, 

defined as “an act by 

an individual or 

group that uses 

intimidation or terror 

to disrupt public 

order,” to the Code’s 

general criminal 

offenses. 

Officials told us that 

although this 

definition does not 

mention political 

motivation, an act 

would not be labeled 

an act of terrorism 

unless it was linked 

to some political 

motive or cause.

German law does not 

define terrorism, but 

a working definition 

provided by German 

government officials 

states that terrorism 

is the permanent 

fight for political 

goals and change of 

the political system 

through assaults 

against persons and 

property. 

Neither law 

specifically defines 

terrorism, but the 

Prevention of 

Terrorism Ordinance 

contains criminal 

prohibitions 

regarding a person’s 

activities and 

association with a 

“terrorist organization.” Such an 

organization is 

defined as a “body of 

persons resorting in 

its activities to acts of 

violence calculated 

to cause death or 

injury to a person or 

to threats of such 

acts of violence.”

Both acts define 

terrorism as “the use 

of violence for 

political ends 

[including] any use of 

violence for the 

purpose of putting 

the public, or any 

section of the public 

in fear.”

Continued
Appendix III

Principal Terrorism Laws, Definitions, and 

Other Legal Information in Canada, France, 

Germany, Israel, and the United Kingdom

Page 21 GAO/NSIAD-00-85 Combating Terrorism

Note: This table is based upon laws that country officials identified as their key statutes related to 

terrorism. It is not based upon a comprehensive review of statues in the countries. 

Source: Our interviews with country officials and review of legal documents they provided.

Canada France Germany Israel United Kingdom

Other legal 

information

Under the Security 

Offenses Act, the 

federal government, 

rather than a 

provincial or 

territorial 

government, 

prosecutes criminal 

offenses that 

constitute a threat to 

the security of 

Canada, or if the 

victim of the offense 

is an internationally 

protected person. 

The specific 

offenses, however, 

are still prosecuted 

under Canada’s 

federal criminal laws.

The maximum 

allowable criminal 

sentences are 

increased when 

certain criminal 

offenses, such as 

violent conduct, 

hijacking, or the use 

of explosives, are 

linked to terrorism. 

France has a special 

national court to 

address acts of 

terrorism under the 

Justice Ministry, 

which also permits 

this special 

independent section 

to investigate, 

prosecute, and 

adjudicate cases 

associated with 

terrorism.

Section 129(a) 

prohibits the 

formation or support 

of an association 

whose objectives or 

activities are directed 

toward committing 

murder, genocide, or 

certain other criminal 

acts against personal 

liberty or 

endangering the 

public. Convicted 

persons can be 

barred from holding 

public office and 

acquiring rights from 

public elections.

While most violations 

of the criminal code 

are prosecuted by 

the states, the 

national government can direct the 

overall investigation 

and determine if the 

state or federal police 

will conduct the 

investigation when 

violations of section 

129(a) are suspected 

or when the crime 

has national 

consequences.

The Defense and 

Emergency Act, a 

holdover from the 

British Mandate of 

Palestine, is used 

primarily in the 

occupied territories 

for administrative 

enforcement 

purposes such as 

seizure of property. 

The Prevention of 

Terrorism Ordinance, 

developed during the 

origin of the State of 

Israel, contains both 

judicial and 

administrative 

provisions, as well as 

criminal prohibitions 

against membership 

and support of a 

terrorist group. 

According to Israeli 

officials, they are 

studying ways to 

update and 

strengthen their 

terrorism laws.

The Northern Ireland 

(Emergency 

Provisions) Act of 

1996, only applies to 

Northern Ireland. 

The Prevention of 

Terrorism (Temporary 

Provisions) Act of 

1989, applies to the 

United Kingdom in 

general.

Both acts contain a 

number of 

comparable criminal 

offenses relating to 

membership, 

participation in, and 

support of proscribed 

organizations.

Subject to 

Parliamentary 

agreement, these 

temporary laws will 

be replaced later this 

year by one 

permanent law that 

would apply 

throughout the 

country and to all 

forms of terrorism.

Continued from Previous Page
Page 22 GAO/NSIAD-00-85 Combating Terrorism

Appendix IV

Security-Related Oversight Organizations and 

Functions in Canada, France, Germany, Israel, 

and the United Kingdom ApendxiIV

Level of review or 

oversight Canada France Germany Israel United Kingdom

Executive Privy Council Office 

monitors and 

coordinates activities 

related to security 

and intelligence. 

Within the Privy 

Council Office is the 

Security and 

Intelligence 

Coordinator that 

monitors such 

activities on a day-today basis. Canada 

also has 

interdepartmental 

committees, 

including the 

Interdepartmental 

Committee on 

Security and 

Intelligence. 

Interministerial 

Liaison Committee 

Against Terrorism 

(Comité 

Interministériel de 

Lutte Anti-Terroriste) 

consists of high-level 

officials involved in 

combating terrorism.

Office of the 

Chancellor, 

Coordinator for 

Intelligence, provides 

executive oversight 

for national issues. 

National Security 

Council, formed in 

1999, provides broad 

review of security 

issues.

Israel’s Security 

Cabinet also 

provides executive 

review and consists 

of the principle 

ministers who have a 

role in combating 

terrorism.

The Cabinet Office 

reviews national 

security issues for 

the Prime Minister. 

The Home Secretary 

is responsible for the 

British Security 

Service. The Foreign 

and Commonwealth 

Secretary is 

responsible for the 

Secret Intelligence 

Service and the 

Government 

Communications 

Headquarters. Other 

executive 

committees are the 

Permanent 

Secretaries’ 

Committee on the 

Intelligence Services 

and the Ministerial 

Committee on 

Intelligence Services.

Legislative The Special Senate 

Committee on 

Security and 

Intelligence reviewed 

counterterrorism in 

1998; additional 

reviews are done on 

an ad hoc basis. For 

intelligence and 

police protection 

issues Canada has 

the Security 

Intelligence Review 

Committee, the 

Royal Canadian 

Mounted Police 

Public Complaints 

Commission, and the 

Royal Canadian 

Mounted Police 

External Review 

Committee. 

Commissions are 

formed if problems 

are found.

The Parliament has a 

standing committee 

on Internal Affairs 

that monitors the 

police and the 

intelligence services’ 

compliance to the 

law (usually in 

response to a 

specific incident).

Subcommittee on 

Intelligence is part of 

the standing 

committee on 

Foreign Affairs and 

Defense.

Senior 

parliamentarians sit 

on the Intelligence 

and Security 

Committee. 

Parliamentarians 

also served as 

Commissioners for 

the British Security 

Service and the 

Secret Intelligence 

Service to review law 

enforcement and 

intelligence activities. 

There is also a 

parliamentary 

tribunal to investigate 

public complaints.

Continued
Appendix IV

Security-Related Oversight Organizations 

and Functions in Canada, France, Germany, 

Israel, and the United Kingdom

Page 23 GAO/NSIAD-00-85 Combating Terrorism

Note: In all the countries, their judicial systems served a final oversight function over the legality of 

executive branch activities in criminal prosecutions. 

Source: Our interviews with country officials and review of documents from each country.

Level of review or 

oversight Canada France Germany Israel United Kingdom

Other Auditor General, 

Canada’s 

independent 

government audit 

organization, 

reported on 

counterterrorism 

activities in 1996 with 

a follow-up report in 

1998. Canada also 

has an inspector 

general only for 

intelligence issues 

that reports to the 

Solicitor General.

The Court of 

Accounts (Cour des 

Comptes), is 

France’s 

independent 

government audit 

organization, but it 

has not focused on 

counterterrorism 

issues.

The Federal Court of 

Audit 

(Bundesrechnungshof), Germany’s 

federal auditor 

conducts fiscal 

audits, and each 

government 

department’s internal 

inspectors monitor 

compliance with 

internal regulations.

State Comptroller’s 

Office has broad 

authority and can 

choose its agenda. 

Issued a report on 

Israel’s overlapping 

intelligence activities 

in 1999.

The National Audit 

Office, the United 

Kingdom’s national 

government audit 

organization has not 

focused on 

counterterrorism 

issues.

Continued from Previous Page
Page 24 GAO/NSIAD-00-85 Combating Terrorism

Appendix V

GAO Contacts and Staff Acknowledgments ApendxiV

GAO Contact Stephen L. Caldwell (202) 512-9610

Acknowledgments In addition to the name above, Colin L. Chambers, Davi M. D’Agostino, 

Kathleen Joyce, Paul Rades, Lorelei St. James, Karen Thompson, and 

Raymond J. Wyrsch made key contributions to this report.
Page 25 GAO/NSIAD-00-85 Combating Terrorism

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