PROLIFERATION 

SECURITY 

INITIATIVE

Agencies Have 

Adopted Policies and 

Procedures but Steps 

Needed to Meet 

Reporting 

Requirement and to 

Measure Results

Report to Congressional Committees

March 2012 

GAO-12-441

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-441, a report to 

congressional committees

March 2012

PROLIFERATION SECURITY INITIATIVE

Agencies Have Adopted Policies and Procedures but 

Steps Needed to Meet Reporting Requirement and to 

Measure Results

Why GAO Did This Study

In 2003, the Bush Administration 

announced the Proliferation Security 

Initiative (PSI) to enhance U.S. efforts 

to prevent the spread of weapons of 

mass destruction (WMD). PSI is not a 

program housed in only one agency, 

but instead is a set of activities with 

participation by multiple U.S. agencies 

and other countries. Congress 

recommended that the Department of 

Defense (DOD) and Department of 

State (State) establish policies, 

procedures, and indicators to measure 

results and required that they submit 

annual reports. It also mandated that 

GAO report on PSI effectiveness. In 

2008, GAO likewise recommended that 

law enforcement agencies also 

establish policies, procedures, and 

performance indicators. 

This report assesses (1) the progress 

relevant agencies have made since 

2008 in establishing recommended PSI 

policies and procedures and issuing 

required annual reports; and (2) the 

extent to which PSI activities have 

enhanced and expanded U.S. 

counterproliferation efforts.

GAO reviewed and analyzed agency 

documents and interviewed officials 

from State, DOD, and other agencies 

with PSI responsibilities.

What GAO Recommends

GAO recommends that State and DOD

provide all required expenditure 

information in PSI annual reports and 

develop a framework for measuring 

PSI’s results. DOD partially concurred 

with both recommendations and State 

partially concurred with the reporting 

recommendation. State disagreed with 

the framework recommendation, but 

noted its support for analysis 

consistent with it. 

What GAO Found

U.S. agencies have adopted interagency guidance documents that establish PSI 

policies and procedures and have submitted annual reports; however, these 

reports do not contain expenditure data for all agencies as required by law. The 

agencies produced documents that contain general PSI policies and procedures. 

In addition, DOD and the Department of Homeland Security’s Customs and 

Border Protection (CBP) developed policies and procedures specifically to guide 

their agencies’ PSI activities. The annual reports submitted in 2009, 2010, and 

2011 met requirements to describe PSI-related activities planned for future years 

and those that took place in the preceding year. Although the reports included an 

account of DOD’s PSI expenditures, they did not contain all expenditures for 

other agencies for PSI activities as required by law.

U.S. officials participated in a range of PSI activities since 2008 to meet their 

objective of expanding and enhancing counterproliferation efforts, but it is unclear 

to what extent these activities have achieved the objective because agencies 

lack measures of results. The agencies either led or participated in 22 PSI 

activities from fiscal year 2009 through fiscal year 2011 including multilateral 

meetings and exercises. Officials stated that their outreach efforts contributed to 

increased support for PSI since GAO’s 2008 report, such as the increase from 93 

to 98 countries endorsing PSI. In addition, they have extended access to PSI 

activities to more countries that are not part of the group of 21 PSI Operational 

Experts Group countries, for example by holding regional planning meetings. 

Despite recommendations of Congress and GAO that agencies develop PSI 

performance indicators, DOD, State, CBP, and the Federal Bureau of 

Investigation have not developed indicators that can be used to systematically 

measure progress toward the stated PSI objective. Further, the agencies have 

not systematically evaluated PSI activity results. Although some officials 

indicated plans to develop PSI performance indicators, officials from DOD and 

State also cited several challenges to developing indicators to measure PSI 

activities’ results including difficulty quantifying how PSI activities improved 

capacity. However, GAO has previously reported that, despite such challenges, 

developing measures that help link activities to results is possible. PSI agencies 

could develop a framework that links performance measures to outcomes. For 

example, such a framework could link the number of participants trained to 

changes in national policies that strengthen participant countries’ authority to 

interdict the shipment of WMD, their delivery systems, and related materials.

View GAO-12-441. For more information, 

contact Thomas Melito at (202) 512-9601 or 

melitot@gao.gov.
Page i GAO-12-441 Proliferation Security Initiative

Letter 1 

Background 3

Agencies Have Adopted Policies and Procedures, but Annual 

Reports Lack Some Required Information 5

Extent to Which Activities Meet PSI Objective Is Unclear because 

Agencies Lack Measures of Results 11

Conclusions 19

Recommendations for Executive Action 20

Agency Comments and Our Evaluation 20

Appendix I Scope and Methodology 24

Appendix II Full Text of the Statement of Interdiction Principles 26

Appendix III Proliferation Security Initiative Activities from Fiscal Year 2009 

to December 2011 29

Appendix IV Comments from the Department of State 31

Appendix V Comments from the Department of Defense 36

Appendix VI GAO Contact and Staff Acknowledgments 39

Contents
Page ii GAO-12-441 Proliferation Security Initiative

Tables

Table 1: Annual Estimated Expenditures for Department of 

Defense Support to PSI-Related Exercises and Other 

Events, Fiscal Years 2012-2014 8

Table 2: Prior Year Expenditure Data Included in Annual Reports 

to Congress 9

Table 3: Number and Type of PSI Activities with U.S. Participation, 

Fiscal Years 2009-2011 12

Figure

Figure 1: Sample Logic Model 18

Abbreviations

9/11 Act Implementing Recommendations of the 9/11 Commission 

 Act of 2007

CBP Customs and Border Protection

CCP Critical Capabilities and Practices

DHS Department of Homeland Security 

DOD Department of Defense

DOE Department of Energy

DOJ Department of Justice

FBI Federal Bureau of Investigation

OEG Operational Experts Group

PSI Proliferation Security Initiative

State Department of State 

Treasury Department of the Treasury

WMD weapons of mass destruction

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-441 Proliferation Security Initiative

United States Government Accountability Office

Washington, DC 20548

March 27, 2012

Congressional Committees

For almost 10 years, the United States has been actively participating in 

the Proliferation Security Initiative (PSI) to assist in U.S. efforts to break 

up black markets, detect and intercept weapons of mass destruction 

(WMD) materials in transit, and use financial tools to disrupt this 

dangerous trade. The U.S. government issued the National Strategy to 

Combat Weapons of Mass Destruction in 2002, and the proliferation of 

WMD, such as nuclear- or missile-related goods or technology, remains 

one of today’s key challenges to international security.1 In May 2003, 

President Bush announced PSI, a multinational effort, including the 

United States, to focus on building WMD interdiction capabilities by 

endorsing the Statement of Interdiction Principles. According to the 

Department of State (State), PSI’s objective is to enhance and expand 

U.S. efforts to prevent the flow of WMD, their delivery systems, and 

related materials on the ground, in the air, and at sea, to and from states 

and nonstate actors of proliferation concern. The current administration 

has continued to support PSI, and agencies with PSI responsibilities have 

reaffirmed that objective. Furthermore, the administration has declared 

PSI an important global tool for countering the spread of WMD-related 

materials, while President Obama has called for it to be turned into a 

“durable international institution.”2

In our September 2006 report on PSI, we found that U.S. agencies did 

not have the policies and procedures in place to plan and manage their 

PSI activities or performance indicators to measure their results. We 

recommended that they correct these deficiencies. Following our report, 

Congress passed the Implementing Recommendations of the 9/11 

Commission Act of 2007 (the 9/11 Act), in which it expresses its sense 

that relevant agencies and departments take actions to expand and 

strengthen PSI, including establishing clear PSI policies and procedures 

 

1

For example, a North Korean cargo ship was reportedly suspected of carrying shortrange missiles to Burma in late May 2011. See Arms Control Today (July 2011-August

2011). 

2

See President Obama’s remarks in Prague, Czech Republic, April 5, 2009. 

 
 

Page 2 GAO-12-441 Proliferation Security Initiative

and performance indicators to measure the results of PSI activities.3 The 

9/11 Act also required DOD and State to submit annual PSI reports and 

mandated GAO to assess and report periodically on PSI’s effectiveness, 

including progress made in implementing the law’s provisions. In 2008, 

we reported that agencies had taken some steps but needed to do more 

to strengthen and expand PSI, such as taking actions on some of the 

law’s provisions.4

To assess what agencies have done since 2008 to establish 

recommended PSI policies and procedures and issue required annual 

reports, we reviewed the findings and recommendations in GAO’s 2006 

and 2008 reports on PSI and the congressional mandate. We reviewed 

documentation of policies and procedures developed since 2008. We also 

requested and reviewed annual reports submitted to Congress by State 

and the Department of Defense (DOD) and analyzed them for compliance 

with the requirements in the 9/11 Act. We reported expenditure data as it 

appeared in the annual reports to Congress and determined the data 

were sufficiently reliable for the purposes of our report. To assess how 

PSI activities have enhanced and expanded U.S. efforts to prevent the 

flow of WMD materials and to determine what actions, if any, agencies 

have taken to develop indicators of PSI’s success, we reviewed and 

analyzed documents from DOD, State, the Department of Homeland 

Security (DHS), and the Department of Justice (DOJ). For both 

objectives, we also interviewed relevant officials from those agencies.

(See app. I for a detailed discussion of our scope and methodology.)

This report updates and provides information on the 

agencies’ actions and the progress evaluating PSI since our 2008 report. 

Specifically, this report assesses (1) the progress relevant agencies have 

made since 2008 in establishing recommended PSI policies and 

procedures and issuing required annual reports; and (2) the extent to 

which PSI activities have enhanced and expanded U.S. 

counterproliferation efforts.

We conducted this performance audit from June 2011 to March 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

 

3

Pub. L. 110-53, sec. 1821(d). 

4

See GAO, U.S. Agencies Have Taken Some Steps, but More Effort Is Needed to 

Strengthen and Expand the Proliferation Security Initiative, GAO-09-43 (Washington, 

D.C.: Nov. 10, 2008).
 

Page 3 GAO-12-441 Proliferation Security Initiative

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

PSI is a multinational effort to prevent the trafficking of WMD, their 

delivery systems, and related materials to and from states and nonstate 

actors of proliferation concern. PSI has no formal organization or 

bureaucracy. In the United States, PSI is not a program housed in a 

single agency, but instead is a set of activities with participation by seven 

agencies and the intelligence community.5

The U.S. government’s PSI efforts involve participation in three broad 

activities: multilateral PSI planning meetings called Operational Experts 

Group (OEG) meetings, PSI exercises, and other efforts to encourage 

support and capacity for interdictions, such as workshops and 

PSI encourages partnership 

among states to work together to develop a broad range of legal, 

diplomatic, economic, military, law enforcement, and other capabilities to 

prevent WMD-related air, land, or sea transfers to states and nonstate 

actors of proliferation concern. International participation is voluntary, and 

there are no binding treaties on those who choose to participate. 

Countries supporting PSI are expected to endorse PSI principles, 

embodied in four broad goals in the Statement of Interdiction Principles of 

September 2003, by a voluntary, nonbinding “political” commitment to 

those principles. See appendix II for the full text of the Statement of 

Interdiction Principles. They also voluntarily participate in PSI activities 

according to their own capabilities. According to the principles, PSI 

participants use existing national and international authorities to put an 

end to WMD-related trafficking and take steps to strengthen those 

authorities, as necessary.

 

5

U.S. agencies participating in PSI are the Departments of Defense, State, Homeland 

Security, Justice, Energy, Commerce, and the Treasury. 

Background 
 

Page 4 GAO-12-441 Proliferation Security Initiative

conferences.6

PSI exercises vary in size and complexity, and some involve military 

personnel and assets from participating PSI countries. Other exercises 

examine the use of law enforcement or customs authorities to stop WMD 

proliferation. There are also “tabletop” exercises or simulations, which 

explore scenarios and determine solutions for hypothetical land, air, or 

sea interdictions. Among the most visible PSI exercises are those that 

combine a tabletop and a live interdiction exercise using military assets 

from multiple PSI countries, such as practicing the tracking and boarding 

of a target ship.

According to State, at multilateral PSI planning meetings, 

military, law enforcement, intelligence, legal, and diplomatic experts from 

the United States and other OEG countries meet to consider ways to 

enhance the WMD interdiction capabilities of PSI participants, build 

support for the initiative, develop operational concepts, organize PSI 

exercises, and share information about national legal authorities. The 

policy office in the Office of the Secretary of Defense heads the U.S. 

delegation to these multilateral meetings.

Other activities include both outreach to countries that have not endorsed 

PSI principles and cooperation and collaboration with countries that have 

endorsed PSI and are seeking assistance to increase their capacity to act 

in accordance with the Statement of Interdiction Principles. These efforts 

include workshops, training, conferences, and bilateral discussions with 

foreign government officials. U.S. officials said they engage in bilateral 

discussions, for example, to conclude PSI shipboarding agreements or to 

seek ways to overcome obstacles to support for PSI principles. State 

takes the lead in diplomatic outreach efforts.

 

6

The 21 OEG countries are Argentina, Australia, Canada, Denmark, France, Germany, 

Greece, Italy, Japan, the Netherlands, New Zealand, Norway, Poland, Portugal, Republic 

of Korea, Russia, Singapore, Spain, Turkey, United Kingdom, and the United States. 

According to State officials, the OEG is the steering committee for the initiative and 

participants are generally best positioned to routinely contribute to and host PSI activities, 

share best practices, and provide lessons learned on activities. OEG meetings provide an 

essential coordination function and are a venue for nations to discuss counterproliferation 

interdiction in a multinational setting. 
 

Page 5 GAO-12-441 Proliferation Security Initiative

U.S. agencies have adopted interagency guidance documents that 

establish policies and procedures for all agencies participating in PSI 

activities. In addition, agencies have submitted annual reports, though 

they lacked required estimated and actual expenditure information from 

most participating agencies.

The 9/11 Act expresses Congress’ sense that DOD and State should 

establish, among other things, clear policies and procedures and roles 

and responsibilities for PSI.7 As we noted in our 2008 report, while DOD 

and Customs and Border Protection (CBP) had established some policies 

and procedures for their PSI activities, State and some law enforcement 

agencies had not.8 Since then, an interagency group, including 

representatives from all agencies participating in PSI, produced two 

companion guidance documents, Guidance for U.S. Government 

Activities in Support of the Proliferation Security Initiative and Insuring the 

Durability of PSI: An Action Plan, that the interagency group adopted in 

2010 and 2011, respectively.9 According to National Security Staff 

officials, these documents are a primary source of policies and

procedures for all relevant agencies—defining PSI activities, providing 

guidance on interagency communication, and addressing objectives and 

responsibilities.10 For example, they establish that State has primary 

responsibility for diplomatic outreach activities and that DOD leads the 

U.S. delegation at OEG meetings.11

 

7

Pub. L. 110-53, sec. 1821. 

According to officials, such 

8

In our 2008 report, since PSI activities had been increasingly focused on law 

enforcement issues, we recommended that some law enforcement agencies also 

establish clear PSI policies and procedures. These agencies concurred with our 

recommendation. 

9

See appendix I for more information on GAO’s access to these interagency policy 

documents. 

10While not otherwise directly involved in PSI activities, the National Security Staff

participates in interagency meetings and is the official custodian of these documents. 

11Within DOD, the Office of the Secretary of Defense for Policy is directly responsible for 

this function. 

Agencies Have 

Adopted Policies and 

Procedures, but 

Annual Reports Lack 

Some Required 

Information

Interagency PSI Policies 

and Procedures 

Established 
 

Page 6 GAO-12-441 Proliferation Security Initiative

interagency policies and procedures also allow all U.S. agencies involved 

in PSI to plan activities without duplicating efforts and to properly and 

coherently articulate the U.S. government’s vision and strategy on PSI.

In addition to interagency guidance, DOD and CBP also have their own 

PSI-specific policy documents. As we reported in our 2008 review of PSI, 

DOD had PSI-specific policies and procedures in place, specifically those 

encouraging combatant command participation in PSI exercises.12 DOD 

Joint Staff provided guidance directing combatant commands to leverage 

the staff, assets, and resources of the existing DOD exercise program in 

support of PSI exercises. This Joint Staff guidance provided procedures, 

including roles and responsibilities, for the planning and execution of U.S. 

military support to PSI. Among other things, the guidance encouraged 

combatant commands to change existing DOD exercises by adding a PSI 

component. Our 2008 review also reported that CBP, a component of 

DHS, produced a PSI-specific directive that provides roles and 

responsibilities, policies and procedures, and PSI-relevant definitions.

Approved in 2006, CBP is currently revising this document to reflect 

updated roles and responsibilities.

The 9/11 Act required DOD and State to submit to Congress in February 

an annual comprehensive joint report, beginning in 2008.13 The report is 

to consist of a 3-year plan describing PSI-related activities and identifying 

estimated expenditures for these activities, and a description of the PSIrelated activities and associated expenditures carried out during the fiscal 

year preceding the year of the report.14

 

12Through DOD’s Joint Staff, we submitted questions to and received responses from the 

following DOD combatant commands: U.S. Africa Command, U.S. Central Command, 

U.S. European Command, U.S. Northern Command, U.S. Pacific Command, U.S. 

Southern Command, and U.S. Strategic Command.

DOD and State co-author each 

report, although responsibility for leading the annual effort alternates 

13Pub. L. 110-53, sec. 1821(b). The 9/11 Act required that the 2008 report include a 

description of PSI-related activities carried out during the 3 fiscal years preceding the year 

of the report, and for the reports submitted in 2009 and each year thereafter, a description 

of the PSI-related activities carried out during the fiscal year preceding the year of the 

report. In November 2008, GAO reported that the relevant agencies had not submitted the 

2008 report as required. 

14The 3-year plan in each report is to begin with the fiscal year for the current budget 

request; for example, the 2011 report includes a 3-year plan covering fiscal years 2012 to 

2014. 

Agencies Submitted 

Reports, but They Lacked 

Some Required 

Information 
 

Page 7 GAO-12-441 Proliferation Security Initiative

between the two. The lead agency solicits input from all U.S. agencies 

participating in PSI and consolidates the information provided to produce 

the final report for submission to Congress. State and DOD have 

submitted annual PSI reports in 2009, 2010, and 2011 including 

descriptions of PSI activities, but these reports do not include all required 

estimated expenditures for PSI activities over the next 3 fiscal years and 

the amount expended in the prior year.15

DOD is the only agency performing PSI activities that has provided all 

required planned and prior year expenditure information for these reports.

For example, the 2011 report includes information from DOD stating that 

it plans to conduct a regional PSI exercise called Leading Edge in Central 

Asia in fiscal year 2012 and in the Middle East in fiscal year 2014 and that 

each exercise is estimated to cost $600,000 for staff travel to support 

planning events and exercise execution. Table 1 shows annual planned 

expenditures from that report for PSI-related exercises in fiscal years 

2012 to 2014 for DOD combatant commands and Joint Staff only, 

including many of the major PSI-related activities expected in that period. 

The report indicates that these expenditures include travel expenses, 

conference hosting fees, contracting support, training expenses, and 

other uniquely PSI-attributable expenses and lists all agencies consulted 

in the preparation of the report.16

 

15According to DOD officials, all three reports were submitted to Congress after the 

February deadline due to interagency coordination issues. For example, the 2011 report 

was submitted about 6 months late, in September 2011.

16The 2011 report states that the following U.S. departments and agencies were consulted 

in the preparation of the report: DOD, including the Office of the Secretary of Defense, the 

Joint Staff, and pertinent combatant commands; State; DHS, including CBP, U.S. Coast 

Guard, and Immigration and Customs Enforcement; the Department of the Treasury; the 

Department of Energy, including the National Nuclear Security Administration; DOJ, 

including the Federal Bureau of Investigation; the Department of Commerce; and the 

intelligence community. 
 

Page 8 GAO-12-441 Proliferation Security Initiative

Table 1: Annual Estimated Expenditures for Department of Defense Support to PSI-Related Exercises and Other Events, 

Fiscal Years 2012-2014 

Expenditures rounded to nearest thousands

Fiscal year Anticipated activities

Total estimated 

expenditures

2012 • Approximately 1 Operational Experts Group (OEG) meeting

• Approximately 3 regional OEG meetings

• U.S. Central Command (CENTCOM) - 1 regional exercise

• U.S. Pacific Command (PACOM) - 1 regional exercise

• U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise

• U.S. European Command (EUCOM) - unspecified

• U.S. Africa Command (AFRICOM) - 2 PSI scenarios in 2 exercises

$1,063,000

2013 • Approximately 1 OEG meeting

• Approximately 3 regional OEG meetings

• U.S. Pacific Command (PACOM) - 1 regional exercise

• U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise

• U.S. European Command (EUCOM) - unspecified

• U.S. Africa Command (AFRICOM) - 1 PSI scenario in 1 exercise

$1,123,000

2014 • Approximately 1 OEG meeting

• Approximately 3 regional OEG meetings

• U.S. Central Command (CENTCOM) - 1 regional exercise

• U.S. Pacific Command (PACOM) - 1 regional exercise

• U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise

• U.S. European Command (EUCOM) - unspecified

• U.S. Africa Command (AFRICOM) - 1 PSI scenario in 1 exercise

$973,000

Source: GAO analysis of the 2011 PSI annual report to Congress.

Note: Amounts above represent estimated expenditures for DOD’s combatant command and Joint 

Staff support. They reflect minimum anticipated annual expenditures and do not account for unknown 

funding requirements resulting from future exercises and other activities hosted by PSI partner 

nations.

In addition, DOD has fully reported its prior year expenditures and, in 

many cases, includes expenditure amounts by activity. For example, the 

2011 report states that DOD’s total PSI expenditures for that year were 

approximately $519,000. Further, the report includes activity-specific 

expenditure information, such as the $31,400 DOD spent for training aids 

and staff travel in support of the Phoenix Express PSI exercise.17

 

17DOD amounts do not include expenditures for pay and salaries, ship fuel, other 

operating costs of military assets, or general overhead costs related to the offices and 

departments whose personnel participate in PSI activities. 
 

Page 9 GAO-12-441 Proliferation Security Initiative

The annual reports do not uniformly include expenditure data for any 

other agencies participating in PSI. For example, the 2010 report states 

that the United States hosted an OEG meeting in Miami, Florida, for 

which the United States had a delegation of 34 representatives from 

DOD, State, DHS, the Federal Bureau of Investigation (FBI), the 

Department of the Treasury (Treasury), and the Department of Energy 

(DOE), among others. The report states that DOD contributed about 

$145,000 but does not include expenditure data from other agencies for 

the event. Table 2 shows the extent to which PSI annual reports include 

expenditure information for U.S. agencies participating in PSI activities.

Table 2: Prior Year Expenditure Data Included in Annual Reports to Congress

2009 report 2010 reporta 2011 reporta

DOD Yes Yes Yes

State Partial No No

DHS No Nob No

DOJ (FBI) No Partial No

DOE Yes Yes No

Treasury Yes No No

Commerce Yes No ——c

Source: GAO analysis of PSI annual reports to Congress.

a

The 2010 and 2011 reports state that all unreported expenditure amounts in fiscal years 2009 and 

2010 were for PSI-related travel.

b

DHS provided its PSI expenditures to State for the 2010 report; however, these data were not 

included in the report. 

c

There is no indication in the report that Commerce participated in PSI activities this year.

Although reports contain some expenditure data from agencies other than 

DOD, none of the other agencies provide this data for all of the annual 

reports. For example, for fiscal years 2008 and 2009, DOE reported total 

PSI expenditures of $69,000 and $55,000 respectively. Also, FBI reported 

that it spent a total of about $750,000 to organize and sponsor PSI events 

in Hungary and Australia in fiscal year 2009. However, no expenditure 

data were provided for activities in which DOE participated for fiscal year 

2010 and for FBI’s activities in fiscal years 2008 and 2010. From DHS, 

CBP officials could document submitting PSI-specific expenditures of 

about $35,000 for the 2010 report; however, the report did not include this 
 

Page 10 GAO-12-441 Proliferation Security Initiative

information, stating that the only costs DHS incurred were associated with 

travel to PSI events.18

Of the four agencies we spoke with, only DOD makes a specific budget 

request for PSI-related activities. U.S. Strategic Command has a fiscal 

year 2011 budget of $800,000 to provide financial assistance for 

combatant commanders to plan, participate in, and execute WMD 

interdiction exercises. This fund is used routinely but not exclusively to 

support PSI activities such as hosting a PSI exercise, embedding PSI 

scenarios into broader military exercises, ensuring that appropriate 

subject matter experts can participate in PSI exercises, or purchasing 

interdiction-related training aids. According to State officials, they prefer 

funding PSI expenditures from their general operating accounts because 

this practice allows them greater flexibility and the ability to fund PSIrelated travel when the need arises. FBI and CBP officials also reported 

that they provide PSI funding when necessary through more general 

operating accounts.

According to State officials, State does not identify 

and track its PSI-related expenditures because it made the decision that 

such a breakout is unnecessary. However, officials said they could 

calculate State’s total PSI-related expenditures because these are almost 

entirely for travel to OEG meetings or bilateral negotiations. FBI officials 

also reported that they do not separately track PSI expenditures.

19

Agencies that do not track and report their expenditures are not providing 

Congress sufficient information for Congress to assess U.S. participation 

in PSI. If agencies are unable to provide requested assistance, but are 

not tracking or reporting on expenditures, it is difficult for the agencies to 

determine and demonstrate to Congress whether they are effectively 

prioritizing their use of limited resources. For example, FBI officials stated 

they could not provide PSI-related training requested in 2011 by 

Colombian national police because they did not have sufficient funding.20

 

18CBP officials also provided documentation of having submitted PSI-specific expenditure 

data for inclusion in the 2012 report. 

19FBI draws funding for its PSI-related expenditures from its External Policy and Planning 

Unit budget. CBP draws funding for its PSI-related expenditures from its Security 

Initiatives budget. 

20In this case, FBI officials were able to use the PSI network to put the Colombian officials 

in contact with officials from Spain’s law enforcement community who already scheduled 

relevant training for Latin American countries. 
 

Page 11 GAO-12-441 Proliferation Security Initiative

Moreover, the lack of required expenditure information limits Congress’ 

ability to oversee agencies’ commitment to the PSI objective.

DOD, State, CBP, and FBI officials participated in a range of PSI activities 

since 2008 to meet their objective of expanding and enhancing 

counterproliferation efforts, but it is unclear to what extent these activities 

have achieved the objective because agencies lack measures of results.

The agencies either led or participated in 22 PSI activities from fiscal year 

2009 through fiscal year 2011, including multilateral meetings and 

exercises. In addition, they have extended access to PSI activities to 

more countries that are not part of the 21-country OEG. Despite 

recommendations in the 9/11 Act and by GAO that agencies develop PSI 

performance indicators, DOD, State, CBP, and FBI have not developed 

indicators that can be used to systematically measure progress toward 

the stated PSI objective.21 Further, the agencies have not systematically 

evaluated PSI activity results. Although some officials indicated plans to 

develop PSI performance indicators, officials from DOD and State also 

cited several challenges to developing indicators to measure PSI 

activities’ results, including difficulty quantifying how PSI activities 

improved capacity. However, GAO has previously reported that, despite 

challenges, evaluating results and developing measures are possible. 

One approach PSI agency officials could consider is developing a 

framework to link performance measures, such as number of participants 

trained, to outcomes, such as changes in national policies that strengthen 

their authority to perform interdictions.

PSI’s objective is to enhance and expand our capacity to prevent the flow 

of WMD, their delivery systems, and related materials on the ground, in 

the air, and at sea, to and from states and nonstate actors of proliferation 

concern. Agency officials provided us with a range of PSI activities they 

have participated in since our 2008 report to support the PSI objective.

U.S. agencies led or participated in 22 PSI activities from fiscal year 2009 

through fiscal year 2011 and State officials reported numerous informal 

bilateral consultations designed to provide tools that increase countries’ 

 

21In our 2008 report, we specifically recommended that relevant law enforcement 

agencies work toward developing performance indicators because of the increasing focus 

of PSI activities on law enforcement issues. DHS and FBI concurred with this 

recommendation.

Extent to Which 

Activities Meet PSI 

Objective Is Unclear 

because Agencies 

Lack Measures of 

Results 

U.S. Agencies Participated 

in PSI Activities to Support 

PSI’s Objective
 

Page 12 GAO-12-441 Proliferation Security Initiative

capacity to interdict illicit shipments of WMDs and WMD-related materials. 

As table 3 shows, these activities fall under the three broad categories of 

the U.S. government’s PSI efforts: multilateral OEG meetings, PSI 

exercises, and other activities such as workshops and training sessions.

See appendix III for a summary of each of the PSI activities with U.S. 

participation from fiscal year 2009 to December 2011. For example, the 

U.S. Naval Forces Africa hosted an exercise in May 2010 that included a 

PSI maritime interdiction scenario designed to improve regional 

cooperation and maritime security in the Mediterranean basin. Also, a 

U.S. delegation participated in an Australia-hosted exercise in September 

2010 that focused on an aircraft counterproliferation scenario and 

associated customs and law enforcement authorities and challenges. A 

regional PSI planning meeting was held in conjunction with the exercise.

Table 3: Number and Type of PSI Activities with U.S. Participation, Fiscal Years 

2009-2011

Activity type FY 2009 FY 2010 FY 2011

Multilateral meeting 2 0 1 

Exercise 3 3 4 

Other activitya 1 0 1 

Multilateral meeting and other activity 2 0 1 

Exercise and other activity 0 0 3 

Multilateral meeting and exercise 0 1 0 

Total 8 4 10

Source: GAO analysis of DOD and State data.

a

Other activities include, for example, workshops and training sessions. 

Officials from DOD, State, DHS, and FBI stated that their outreach efforts, 

including State’s diplomatic efforts, have contributed to an increased 

number of countries supporting PSI since our 2008 report. For example, 

the number of countries that became PSI countries by endorsing the 

Statement of Interdiction Principles has increased from 93 to 98 since 

2008 and DOD officials said that they have ongoing efforts with several 

non-endorsing countries and believe that the number of endorsing 

countries will continue to rise. The most recent endorsees are Antigua 

and Barbuda, Colombia, the Republic of Korea (South Korea), St. Vincent 

and the Grenadines, and Vanuatu. Further, the number of signed bilateral 

shipboarding agreements between the United States and individual PSI 
 

Page 13 GAO-12-441 Proliferation Security Initiative

countries increased between November 2008 and February 2012 from 9 

to 11.22 Bilateral shipboarding agreements put procedures into place and 

identify points of contact to permit the timely inspection by either party of 

vessels flying their flags suspected of transporting proliferation-related 

cargo. State officials said these agreements are significant because they 

have been signed by countries with some of the largest ship registries.23

U.S. agencies, in cooperation with the 20 other OEG countries, also have 

extended access to PSI activities to additional countries since our last 

report. In 2008, we reported that U.S. agencies had not built relationships 

with PSI countries that are not OEG countries by involving them in PSI 

planning and activities. We recommended that U.S. agencies work in 

conjunction with other leading PSI countries to increase cooperation, 

coordination, and information exchange with PSI countries that were not 

invited to multilateral OEG planning meetings.24

U.S. officials provided examples of expanded efforts to cooperate with 

non-OEG countries. For example:

In May 2009, the 

countries of the OEG committed to consider ways to involve more 

countries in future PSI planning meetings. According to U.S. officials, they 

also agreed to increase the number of PSI activities, including regional 

PSI planning meetings, that include PSI-endorsing countries beyond the 

OEG countries and, in some cases, non-endorsing countries. In addition, 

the 2011 U.S. interagency PSI report to Congress stated that activities 

planned for fiscal years 2012 through 2014 are designed to increase 

cooperation, coordination, and information exchange with the broad range 

of PSI-endorsing countries beyond the countries that normally participate 

in the OEG.

 

22In addition to the shipboarding agreements signed in 2010 with Antigua and Barbuda 

and St. Vincent and the Grenadines, the United States also has agreements with The 

Bahamas, Belize, Croatia, Cyprus, Liberia, Malta, Marshall Islands, Mongolia, and 

Panama.

23A country’s ship registry includes vessels that sail bearing the flag of that country. Many 

of the countries with the largest ship registries have open registries, meaning they engage 

in the business practice allowing ships to be registered with their country and fly their flag 

even when the ship owners are from another country. The ability to interdict a shipment 

depends, in part, on the legal authorities of the country whose flag a ship is flying and 

vulnerabilities in legal codes may be exploited by merchants shipping WMD or WMDrelated materials. 

24GAO-09-43. 
 

Page 14 GAO-12-441 Proliferation Security Initiative

• Eight of the 17 participating delegations at a PSI activity hosted in 

September 2010 by Australia represented countries not normally 

invited to multilateral PSI planning meetings. The activity included an 

aircraft counterproliferation scenario exercise and a regional PSI 

planning meeting.

• According to U.S. officials, the Republic of Korea endorsed PSI in 

May 2009 as a result of its participation in PSI activities and became 

one of the 21 leading PSI countries in November 2010. It organized a 

PSI exercise and hosted a regional PSI workshop in 2010.

U.S. officials said they are also currently developing the Critical 

Capabilities and Practices effort, a clearinghouse for PSI-related 

information and tools, designed to make PSI lessons learned and best 

practices available both to PSI activity participants and to endorsing 

countries that were unable to participate in the activities.25 The OEG 

countries discussed and confirmed support for the development of the 

Critical Capabilities and Practices effort. Officials said they have not set a 

target date for the effort to begin making PSI-related information and tools 

available.

While U.S. agencies have undertaken a range of PSI efforts since 2008, 

they have not established a framework to measure PSI activities’ results 

and, therefore, it is unclear to what extent these activities have enhanced 

and expanded capacity to prevent the flow of WMD, their delivery 

systems, and related materials on the ground, in the air, and at sea, to 

and from states and nonstate actors of proliferation concern. The 9/11 Act 

recommended that DOD and State establish indicators to measure results 

of their PSI activities. It is the responsibility of the implementing agencies 

to measure the results of PSI activities. Linking the activities to the 

initiative’s overall objective could help the agencies better organize and 

prioritize future activities. In 2008, we reported that agencies had not 

established PSI performance indicators. We also recommended that law 

enforcement agencies, such as DHS and FBI, which we found to have 

become increasingly involved in PSI activities, establish PSI performance 

indicators and they concurred.

 

25Officials report that the Critical Capabilities and Practices effort will include 

documentation of past activities and notice of future activities.

U.S. Agencies Have Not 

Established a Framework 

to Measure PSI’s Results
 

Page 15 GAO-12-441 Proliferation Security Initiative

The four agencies we reviewed have not established formal performance 

indicators that can be used to systematically measure progress toward 

the stated PSI objective. DOD officials said they have general 

counterproliferation goals but have not developed PSI indicators.26 FBI 

officials said that they have performance measures applying to activities 

of their Weapons of Mass Destruction Directorate, and that their PSIspecific goal is the commitment to participate in PSI activities as 

appropriate, including at least one PSI exercise per year. Although FBI 

officials consider this to be a performance indicator, participation alone 

does not provide information to measure the results of PSI activities. 

State has identified as its PSI indicator “An Effective Global Network 

Countering WMD Proliferation-Related Trafficking.”27 However, the 

measures used to track the indicator’s progress change from year to year, 

making it difficult for State to assess systematically the results of its PSI 

activities. For example, although State did not meet its fiscal year 2009 

target to have 100 PSI-endorsing countries, it did not set targets for the 

number of PSI endorsees for fiscal years 2010 or 2011. We reported in 

2008 that CBP developed a PSI Implementation Plan with expected goals 

and targets, but that it had not been updated since June 2006.28

In addition, although some agencies have made efforts to assess 

individual PSI activities, the four agencies we reviewed have not 

performed a systematic evaluation of the results of PSI activities. Some 

officials draft summary reports following individual activities to identify 

issues to address in planning for future activities. For example, FBI 

As of 

February 2012, CBP officials stated that many of the goals are outdated 

and that the plan has not been updated because they wanted to wait and 

align their plan with the interagency PSI policy documents that were 

completed in 2010 and 2011. The officials acknowledged that 

performance measurement is important and said they are working to 

include indicators in their updated plan.

 

26Officials from DOD's U.S. Southern Command (USSOUTHCOM) reported that they 

anticipate working with the U.S. Strategic Command Center for Combating Weapons of 

Mass Destruction to develop performance indicators and evaluation criteria.

27State's indicator is part of the annual Bureau Strategic and Resource Plan for the 

Bureau of International Security and Nonproliferation. 

28CBP officials said they believe their Implementation Plan contained indicators. In our 

2008 report, however, we found that although the plan contained expected goals and 

targets, they were not performance indicators. 
 

Page 16 GAO-12-441 Proliferation Security Initiative

officials said they conducted a formal evaluation of the two workshops 

they sponsored in 2009.29

State and DOD officials cited a number of challenges to developing 

indicators to measure the impact or results of the U.S. government’s PSI 

activities. According to the officials, results that can be quantified can also 

be misleading. For example, the officials stated the following:

The report from the September 2009 workshop 

in Australia included some reporting of feedback from a written survey 

conducted at the end of the activity. Similarly, a CBP official provided 

examples of post-activity reports that include recommendations for future 

PSI efforts. However, these reports do not represent a systematic 

evaluation that links the activity results to the PSI objective. The officials 

with whom we met said they consider past activities when planning for the 

future, but they have no systematic evaluation of the activity results or 

impact to aid their planning. Further, the annual PSI reports to Congress 

do not generally document results of U.S. agencies’ activities beyond the 

names of the participating countries.

• Tracking the overall number of new countries endorsing PSI ignores 

the fact that U.S. agencies have strategic reasons for focusing efforts 

on a certain country or subset of countries, even if a larger number of 

other countries might be persuaded more quickly to endorse.

• Tracking the number of interdictions does not necessarily link PSI 

activities to the initiative’s objective. According to the officials, the 

initiative’s activities are focused on building capacity to perform 

interdiction, but actual interdictions are not performed as part of PSI.30

They emphasized that they cannot credit successful interdictions to 

PSI activities, in part because there are many efforts in addition to PSI 

that are focused on counterproliferation. Also, a change in the number 

of interdictions over the previous year could be attributed to a range of 

positive and negative factors, including better capacity to interdict, 

increased transfers of illicit material, or failure to deter transfers.

 

29FBI officials could not locate documentation of the evaluation report from the FBIsponsored July 2009 workshop in Budapest, Hungary. 

30Officials stated that although PSI complements and supports interdiction efforts, the act 

of performing interdictions is beyond the scope of PSI.

Agency Officials Cited 

Challenges to Developing PSI 

Performance Measures 
 

Page 17 GAO-12-441 Proliferation Security Initiative

• Tracking measures of U.S. efforts, such as the number of activities 

hosted by the United States, ignores the fact that PSI is a 

multinational effort.

Further, State officials said some of the results of PSI activities are 

difficult to quantify. For example, although the officials said tools and 

expertise provided to participants at activities are used by participants to 

enhance their ability to interdict illicit cargo, the extent of the improvement 

is often difficult to measure and track.

Despite the challenges U.S. agencies face in developing performance 

indicators, it is possible for agencies to measure performance. One 

possible approach agencies could consider is to develop a framework 

that links PSI activities to the initiative’s objective. GAO has previously 

identified such frameworks, called logic models, that agencies could 

adopt even if they face performance measurement challenges similar to 

some of the ones identified by PSI implementing agencies.31

 

31A logic model is an evaluation tool used to describe a program’s—or initiative’s, in the 

case of PSI—components and desired results and explain the strategy—or logic—by 

which the program is expected to achieve its goals. See GAO, Program Evaluation: 

Strategies for Assessing How Information Dissemination Contributes to Agency Goals, 

Specifically, 

GAO reported that using a logic model could allow the agencies to 

consider indirect outcomes and unquantifiable benefits when linking 

activities and outputs to the overall objective. By specifying the program’s 

theory of what is expected, a logic model can help evaluators define 

measures of the program’s progress toward its ultimate goals. In 

particular, GAO found that logic models were used or could be used to 

measure results in programs with challenges similar to some of PSI’s, 

including, for example, difficulty in observing changes in behavior 

occurring after activity completion and difficulty in attributing outcomes to 

activities because of external factors’ influence on the outcomes. Figure 1 

provides generic guidance on how a logic model framework could be 

used to link agencies’ program inputs and outputs to outcomes or impact. 

A logic model can help identify pertinent variables and how, when, and in 

whom they should be measured, as well as other factors that might affect 

program results.

GAO-02-923 (Washington, D.C.: Sept. 30, 2002). For another example of how a logic 

model could be applied to a specific program or set of activities, see appendix IV in GAO, 

Security Assistance: State and DOD Need to Assess How the Foreign Military Financing 

Program for Egypt Achieves U.S. Foreign Policy and Security Goals, GAO-06-437

(Washington, D.C.: Apr. 11, 2006). 

Performance Measurement 

Possible Despite Challenges 
 

Page 18 GAO-12-441 Proliferation Security Initiative

Figure 1: Sample Logic Model

A logic model can be used by agencies to guide their efforts to link 

activities to high-level objectives or impact, and agency officials could 

adapt the general framework to the individual program they plan to 

evaluate. For PSI, a logic model could link inputs and activities to 

outcomes while also documenting the challenges in measuring results.

For example, officials could track quantitative inputs, such as the amount 

of money spent on a training activity about overcoming gaps in legal 

authority to interdict illicit shipments. They could link that input to 

measurable outputs, such as the number of participants trained. To link 

the outputs to short term results, they could make efforts to elicit feedback 

from participants to measure changes in participants’ knowledge of ways 

to strengthen legal authorities. Agencies may be able to identify medium 

and long-term results, such as participants who successfully implement 

new national policies that strengthen their authority to perform 

interdictions. Together with the linkage of quantifiable measures, 

agencies could include narrative explanation of unquantifiable results that 

they believe contribute to the initiative’s objective. They could also 
 

Page 19 GAO-12-441 Proliferation Security Initiative

describe external factors that make it difficult to demonstrate or quantify 

the extent of the causal link between activities and results, such as the 

existence of other programs or initiatives that may also result in improved 

legal capacity to perform interdictions. Over time, the use of such a 

framework can help determine whether the results of the initiative’s 

activities match the expected outcomes.

Federal agencies are increasingly expected to focus on achieving results 

and to demonstrate, in annual performance reports, how their activities 

help achieve agency or governmentwide goals. Because U.S. agencies

have not developed indicators that can be used to measure 

systematically the results of their PSI activities, it is difficult for Congress 

and the public to know whether PSI activities hosted or participated in by 

the agencies are achieving their stated objective. As GAO has previously 

reported, in programs that inform and persuade others to act to achieve a 

desired outcome, it would seem all the more important to assure decision 

makers that this strategy is credible and likely to succeed.32

PSI has the potential to increase global capacity to recognize and

interdict the flow of WMD, their delivery systems, and related materials on 

the ground, air, or sea, to and from states and nonstate actors of 

proliferation concern. The previous and current administrations have 

committed to implementing PSI and President Obama has called for it to 

be turned into a durable international institution. Given this commitment, it 

is important that agencies ensure that PSI is fully implemented according 

to legislative recommendations and requirements. Since our 2008 report, 

U.S. agencies have developed interagency PSI policies and procedures 

that satisfy a recommendation of the 9/11 Act. They have also submitted 

annual reports covering fiscal years 2008 through 2010 documenting their 

PSI activities, but these reports have not included the associated funding 

information for all PSI implementing agencies, as required by law. While 

all agencies we spoke with except DOD stated that they fund their PSI 

activities from their general funds, rather than request an annual PSI 

budget, it does not eliminate the requirement that they provide 

expenditure information for their PSI activities under the 9/11 Act. Without 

reports that include the required information for all agencies’ PSI 

activities, Congress will not know how much the U.S. government is 

 

32GAO-02-923. 

Conclusions 
 

Page 20 GAO-12-441 Proliferation Security Initiative

spending on PSI and how such funds are being allocated. Also, while 

U.S. agencies have provided years of documentation of a range of 

activities they have performed or plan to perform under PSI, they have 

been unable to demonstrate if or how these activities are linked to the PSI 

objective. Without performance indicators that can be used to 

systematically measure progress toward the stated PSI objective and a 

framework for measuring the results of PSI activities, Congress and the 

public do not have a sufficient basis to judge whether PSI activities are 

successful. 

To ensure that Congress has information to assess U.S. participation in 

PSI, we recommend that the Secretaries of Defense and State take the 

following two actions:

1. Include in the annual PSI report to Congress the required expenditure 

information for all U.S. agencies participating in PSI activities; and

2. Develop a framework for measuring PSI activities’ results, including 

performance measures where possible that help link the results to 

PSI’s objective.

We provided a draft of this report to DOD, State, FBI, and DHS. DOD and 

State provided written comments on a draft of this report, which are 

reprinted in appendixes IV and V along with our responses to specific 

points. FBI and DHS, along with DOD and State provided technical 

comments that we have incorporated into this report, as appropriate.

In commenting on the draft report, DOD partially concurred with both of 

our recommendations. Consistent with our recommendation, DOD agreed 

that the annual PSI report should include expenditure information for all 

U.S. agencies. DOD stated that the reports have included information on 

expenditures by DOD and other agencies that are unique to PSI, while 

excluding items that are accounted for in agency general operating 

budgets. However, we found that some expenditure amounts not reported 

in the annual reports were unique to PSI and, therefore, should have 

been included. In a 2009 e-mail to CBP, a DOD official stated that travel 

expenses could be included in its submission to the annual report, as long 

as they were specifically for a PSI event. However, after CBP submitted 

such expenditures to DOD, they were excluded from the 2010 annual

report even though they were for PSI-specific travel. DOD also partially 

concurred with our recommendation to develop a results framework. The 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 21 GAO-12-441 Proliferation Security Initiative

department cited challenges in establishing objective and quantifiable 

measures of success but committed to make an effort to implement the 

recommendation by using the Critical Capabilities and Practices (CCP) 

concept as a results framework and to identify meaningful performance 

measures, where appropriate.

State partially concurred with the recommendation to provide expenditure 

information for all U.S. agencies participating in PSI activities. The 

department explained that it is difficult to define some expenditures as 

unique to PSI, for example, because travel in support of PSI events often 

coincides with travel in support of other department operational activities.

However, the department said it would closely examine travel-related and 

other expenses unique to PSI in order to include them in future reports to 

Congress. State did not concur with our recommendation that it should 

develop a results framework. State said it had some indicators, such as 

the numbers of PSI-endorsing countries, for use in measuring PSI 

progress, but cautioned that PSI does not lend itself to collective data that 

would provide reasonable approximation of results. Nonetheless, State 

cited the CCP effort as one tool it intends to use, in coordination with 

other participating U.S. agencies, “which could contribute to an effective 

future analysis of the outcomes of coordinated PSI activity,” which is 

consistent with our recommendation. Although we made a written request 

for documentation of State’s PSI performance indicators in July 2011, 

State did not provide documentation of its PSI indicator and targets until 

March 2012, after it provided its response to our draft report. We have 

revised our report findings to include this documentation and our 

assessment. Upon reviewing the documentation provided, we found that 

the metrics State identified were not consistently listed as annual metrics 

in the strategic plan to which they refer. For example, neither the number 

of endorsing states nor the conclusion of shipboarding agreements were 

listed as metrics for fiscal years 2010 or 2011. In addition, State set no 

numeric targets for its participation in PSI activities for fiscal years 2010 

or 2011. Without an overall results framework including, where possible, 

consistent indicators and targets that can be tracked over time, State 

cannot systematically evaluate its PSI activities.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Secretary of State, the 

Secretary of Homeland Security, the Attorney General, and other 

interested parties. In addition, this report is available at no charge on the

GAO website at http://www.gao.gov. 
 

Page 22 GAO-12-441 Proliferation Security Initiative

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

contact me at (202) 512-9601 or melitot@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors are listed in appendix VI.

Thomas Melito

Director, International Affairs and Trade
 

Page 23 GAO-12-441 Proliferation Security Initiative

List of Committees 

The Honorable Carl Levin 

Chairman 

The Honorable John McCain 

Ranking Member 

Committee on Armed Services 

United States Senate 

The Honorable John Kerry 

Chairman 

The Honorable Richard G. Lugar 

Ranking Member 

Committee on Foreign Relations 

United States Senate 

The Honorable Howard P. McKeon 

Chairman 

The Honorable Adam Smith 

Ranking Member 

Committee on Armed Services 

House of Representatives 

The Honorable Ileana Ros-Lehtinen 

Chairman 

The Honorable Howard L. Berman

Ranking Member 

Committee on Foreign Affairs 

House of Representatives
Appendix I: Scope and Methodology

Page 24 GAO-12-441 Proliferation Security Initiative

To assess the progress agencies have made since 2008 in establishing 

recommended Proliferation Security Initiative (PSI) policies and 

procedures, and issuing required annual reports, we reviewed the 

findings and recommendations in GAO’s 2006 and 2008 reports on PSI 

and the Implementing Recommendations of the 9/11 Commission Act of 

2007 (the 9/11 Act).

1

To assess the extent to which PSI activities have enhanced and 

expanded U.S. efforts to prevent the flow of weapons of mass destruction 

(WMD) materials, we reviewed and analyzed documents from DOD, 

State, the Department of Homeland Security (DHS), and the Department 

of Justice (DOJ). We analyzed the information on each PSI activity in the 

annual reports covering fiscal years 2009 and 2010. We reported the 

number of PSI activities with U.S. participation based on agency 

documents. Because the agencies have not yet submitted the annual 

report for PSI activities in fiscal year 2011, we analyzed information on 

fiscal year 2011 activities provided by agency officials. We also 

interviewed relevant agency officials and solicited responses from seven

DOD combatant commands to a list of questions about the PSI. In 

particular, we requested and analyzed documentation of actions relevant 

agencies have taken, if any, to develop indicators of PSI’s success. In 

addition, we compared our findings with those of the 2008 GAO PSI 

review and reviewed GAO reports assessing agencies’ evaluation 

frameworks and performance measurement.

We requested and reviewed documentation of 

policies and procedures developed since 2008. Because the National 

Security Staff is the custodian of the interagency policy documents, we 

discussed the contents of those documents with National Security Staff 

officials and reviewed the documents to confirm that they contained PSI 

policies and procedures. We also reviewed PSI annual reports submitted 

to Congress by the Departments of State (State) and Defense (DOD) and 

analyzed them for compliance with the requirements in the 9/11 Act. We

reported expenditure data as they appeared in the annual reports to 

Congress and discussed the reliability of the data with agency officials.

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

report. Further, we interviewed relevant agency officials to better 

understand the extent to which they implemented the requirements and 

recommendations in the 9/11 Act and any compliance challenges they 

faced.

 

1

Pub. L. 110-53, sec. 1821. 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 25 GAO-12-441 Proliferation Security Initiative

For both objectives, we focused on DOD and State because the 

applicable recommendations and requirements in the mandate were 

addressed to them. In addition, we assessed DHS and DOJ progress 

because GAO made recommendations to those agencies in 2008 to 

develop policies, procedures, and performance indicators because of the 

increased involvement of law enforcement agencies in U.S. PSI efforts.
Appendix II: Full Text of the Statement of 

Interdiction Principles

Page 26 GAO-12-441 Proliferation Security Initiative

The PSI is a response to the growing challenges posed by the 

proliferation of WMD, their delivery systems, and related materials 

worldwide. The PSI builds on efforts by the international community to 

prevent proliferation of such items, including existing treaties and 

regimes. It is consistent with, and a step in the implementation of the UN 

Security Council Presidential Statement of January 1992, which states 

that the proliferation of all WMD constitutes a threat to international peace 

and security, and underlines the need for member states of the UN to 

prevent proliferation. The PSI is also consistent with recent statements of 

the G8 and the European Union, establishing that more coherent and 

concerted efforts are needed to prevent the proliferation of WMD, their 

delivery systems, and related materials. PSI participants are deeply 

concerned about this threat and of the danger that these items could fall 

into the hands of terrorists and are committed to working together to stop 

the flow of these items to and from states and nonstate actors of 

proliferation concern.

The PSI seeks to involve, in some capacity, all states that have a stake in 

nonproliferation and the ability and willingness to take steps to stop the 

flow of such items at sea, in the air, or on land. The PSI also seeks 

cooperation from any state whose vessels, flags, ports, territorial waters, 

airspace, or land might be used for proliferation purposes by states and 

nonstate actors of proliferation concern. The increasingly aggressive 

efforts by proliferators to stand outside or to circumvent existing 

nonproliferation norms, and to profit from such trade, requires new and 

stronger actions by the international community. We look forward to 

working with all concerned states on measures they are able and willing 

to take in support of the PSI, as outlined in the following set of 

“Interdiction Principles.” 

PSI participants are committed to the following interdiction principles to 

establish a more coordinated and effective basis through which to impede 

and stop shipments of WMD, delivery systems, and related materials 

flowing to and from states and nonstate actors of proliferation concern, 

consistent with national legal authorities and relevant international law 

and frameworks, including the UN Security Council. They call on all states 

concerned with this threat to international peace and security to join in 

similarly committing to:

1. Undertake effective measures, either alone or in concert with other 

states, for interdicting the transfer or transport of WMD, their delivery 

systems, and related materials to and from states and nonstate actors 

Appendix II: Full Text of the Statement of 

Interdiction Principles

Interdiction Principles for 

the Proliferation Security 

Initiative 
Appendix II: Full Text of the Statement of 

Interdiction Principles

Page 27 GAO-12-441 Proliferation Security Initiative

of proliferation concern. “States or nonstate actors of proliferation 

concern” generally refers to those countries or entities that the PSI 

participants involved establish should be subject to interdiction 

activities because they are engaged in proliferation through: (1) efforts 

to develop or acquire chemical, biological, or nuclear weapons and 

associated delivery systems; or (2) transfers (either selling, receiving, 

or facilitating) of WMD, their delivery systems, or related materials.

2. Adopt streamlined procedures for rapid exchange of relevant 

information concerning suspected proliferation activity, protecting the 

confidential character of classified information provided by other 

states as part of this initiative, dedicate appropriate resources and 

efforts to interdiction operations and capabilities, and maximize 

coordination among participants in interdiction efforts.

3. Review and work to strengthen their relevant national legal authorities 

where necessary to accomplish these objectives, and work to 

strengthen when necessary relevant international law and frameworks 

in appropriate ways to support these commitments.

4. Take specific actions in support of interdiction efforts regarding 

cargoes of WMD, their delivery systems, or related materials, to the 

extent their national legal authorities permit and consistent with their 

obligations under international law and frameworks, to include:

a. Not to transport or assist in the transport of any such cargoes to or 

from states or nonstate actors of proliferation concern and not to 

allow any persons subject to their jurisdiction to do so.

b. At their own initiative, or at the request and good cause shown by 

another state, to take action to board and search any vessel flying 

their flag in their internal waters or territorial seas, or areas beyond 

the territorial seas of any other state, that is reasonably suspected 

of transporting such cargoes to or from states or nonstate actors 

of proliferation concern, and to seize such cargoes that are 

identified.

c. To seriously consider providing consent under the appropriate 

circumstances to the boarding and searching of its own flag 

vessels by other states, and to the seizure of such WMD-related 

cargoes in such vessels that may be identified by such states.

d. To take appropriate actions to (1) stop and/or search in their 

internal waters, territorial seas, or contiguous zones (when 
Appendix II: Full Text of the Statement of 

Interdiction Principles

Page 28 GAO-12-441 Proliferation Security Initiative

declared) vessels that are reasonably suspected of carrying such 

cargoes to or from states or nonstate actors of proliferation 

concern and to seize such cargoes that are identified and (2) to 

enforce conditions on vessels entering or leaving their ports, 

internal waters, or territorial seas that are reasonably suspected of 

carrying such cargoes, such as requiring that such vessels be 

subject to boarding, search, and seizure of such cargoes prior to 

entry.

e. At their own initiative or upon the request and good cause shown 

by another state, to (a) require aircraft that are reasonably 

suspected of carrying such cargoes to or from states or nonstate 

actors of proliferation concern and that are transiting their airspace 

to land for inspection and seize any such cargoes that are 

identified and/or (b) deny aircraft reasonably suspected of carrying 

such cargoes transit rights through their airspace in advance of 

such flights.

f. If their ports, airfields, or other facilities are used as transshipment 

points for shipment of such cargoes to or from states or nonstate 

actors of proliferation concern, to inspect vessels, aircraft, or other 

modes of transport reasonably suspected of carrying such 

cargoes, and to seize such cargoes that are identified.
Appendix III: Proliferation Security Initiative 

Activities from Fiscal Year 2009 to December 

2011

Page 29 GAO-12-441 Proliferation Security Initiative

Month Year Type of activity Event Description Location

Fiscal year 2012

November 2011 meeting OEG Operational Experts Group 

(OEG) meeting

Germany

November 2011 exercise Vigilant Shield PSI portion of tabletop 

exercise

Norfolk, VA

Fiscal year 2011

September 2011 other Bilateral activity Bilateral activity with 

Colombia

Colombia

August 2011 exercise Panamax PSI portion of live maritime 

exercise and tabletop 

exercise

Panama

June 2011 meeting and other Regional OEG Regional OEG meeting and 

Critical Capabilities and 

Practices workshop

Honolulu, HI

May 2011 exercise Phoenix Express PSI portion of live maritime 

exercise 

Mediterranean Sea

April 2011 exercise Austere Challenge PSI portion of live maritime 

exercise 

Germany

April 2011 exercise Saharan Express PSI portion of live maritime 

exercise 

Cape Verde/Senegal

April 2011 exercise and other Bilateral activity PSI tabletop exercise and 

workshop with St. Vincent 

and the Grenadines

St. Vincent and the 

Grenadines

February 2011 exercise and other Bilateral activity PSI tabletop exercise and 

workshop with Mongolia

Mongolia

November 2010 meeting OEG OEG meeting Japan

October 2010 exercise and other Eastern Endeavor PSI portion of live maritime 

exercise and tabletop 

exercise; PSI workshop

Republic of Korea

Fiscal year 2010

September 2010 meeting and 

exercise

Regional OEG / Pacific 

Protector 

Regional OEG meeting and 

PSI portion of port exercise

Australia 

May/June 2010 exercise Phoenix Express PSI portion of live maritime 

exercise 

Mediterranean Sea

January 2010 exercise Leading Edge PSI portion of live maritime 

exercise, port exercise, and

tabletop exercise

United Arab Emirates

October 2009 exercise Deep Sabre PSI portion of live maritime 

exercise, port exercise, and 

tabletop exercise

Singapore

Appendix III: Proliferation Security Initiative

Activities from Fiscal Year 2009 to December 

2011
Appendix III: Proliferation Security Initiative 

Activities from Fiscal Year 2009 to December 

2011

Page 30 GAO-12-441 Proliferation Security Initiative

Month Year Type of activity Event Description Location

Fiscal year 2009

September 2009 exercise Panamax PSI portion of live maritime 

exercise and tabletop 

exercise

Panama

September 2009 meeting and other Regional OEG and 

counterproliferation 

workshop

Regional OEG meeting and 

3-day workshop organized by 

FBI and Australia for PSI 

endorsing countries in Asia 

Pacific region

Australia 

July 2009 other Bilateral workshop 2-day workshop with Republic 

of Korea 

Republic of Korea 

July 2009 meeting and 

other

Regional OEG and

counterproliferation 

workshop

Regional OEG meeting and 

3-day workshop organized by 

FBI and Hungary for PSI 

endorsing countries in the 

Middle East and North Africa 

region

Hungary

June 2009 meeting Regional OEG Regional OEG meeting Poland

May 2009 meeting OEG OEG meeting Miami, FL

April 2009 exercise Bilateral exercise Bilateral tabletop exercise 

with Israel

Israel

April/May 2009 exercise Phoenix Express PSI portion of live maritime 

exercise

Mediterranean Sea

Source- GAO analysis based on DOD and State data.
Appendix IV: Comments from the Department 

of State

Page 31 GAO-12-441 Proliferation Security Initiative

Appendix IV: Comments from the 

Department of State

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this 

appendix.
Appendix IV: Comments from the Department 

of State

Page 32 GAO-12-441 Proliferation Security Initiative

See comment 1.
Appendix IV: Comments from the Department 

of State

Page 33 GAO-12-441 Proliferation Security Initiative

See comment 3.

See comment 2.
Appendix IV: Comments from the Department 

of State

Page 34 GAO-12-441 Proliferation Security Initiative

See comment 5.

See comment 4.
Appendix IV: Comments from the Department 

of State

Page 35 GAO-12-441 Proliferation Security Initiative

The following are GAO’s comments on the Department of State’s letter, 

dated March 9, 2012.

1. Our recommendation focuses on developing a framework that links 

PSI activities to the initiative’s objective, and not just on indicators, 

which alone do not link the activities to the desired outcomes. 

Although we made a written request for documentation of State’s PSI 

performance indicators in July 2011, State did not provide 

documentation of its PSI indicator and targets until March 2012, after 

it provided its response to our draft report. We have revised our report 

findings to include this documentation and our assessment. Upon 

reviewing the documentation provided, we found that the metrics 

State identified were not consistently listed in its bureau strategic plan 

as annual metrics. For example, neither the number of endorsing 

states nor the conclusion of shipboarding agreements were listed as 

metrics for fiscal years 2010 and 2011. In addition, State set no 

numeric targets for its participation in PSI activities for fiscal years 

2010 and 2011. Without an overall results framework including, where 

possible, consistent indicators and targets that can be tracked over 

time, State cannot systematically evaluate its PSI activities.

2. State’s decision to consider including PSI-specific expenditures in 

future reports to Congress is consistent with our recommendation.

3. If the Critical Capabilities and Practices (CCP) concept is developed 

as a framework that links PSI activities to outcomes and the objective 

of PSI, it will be consistent with our recommendation. (See also 

comment 1.)

4. Based on State’s response, we have revised the report to reflect 

State’s justification for not breaking out PSI expenditures. However, 

State’s decision not to track PSI expenditures is inconsistent with the 

requirement to report such information annually.

5. The description of OEG meetings as planning meetings is consistent 

with our 2008 report on PSI. State concurred with this decision. In 

addition, we believe that the activities currently listed by State are 

consistent with PSI planning. We have added a footnote in the 

background more fully explaining OEG meetings.

GAO Comments
Appendix V: Comments from the Department 

of Defense

Page 36 GAO-12-441 Proliferation Security Initiative

Appendix V: Comments from the Department 

of Defense

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix V: Comments from the Department 

of Defense

Page 37 GAO-12-441 Proliferation Security Initiative

See comment 2.

See comment 1.
Appendix V: Comments from the Department 

of Defense

Page 38 GAO-12-441 Proliferation Security Initiative

The following are GAO’s comments on the Department of Defense’s 

letter, dated March 9, 2012.

1. The 9/11 Act requires that DOD, in conjunction with State, report to 

Congress annually on the amount expended for the prior year’s PSI 

activities. Because DOD is the only agency we spoke with that makes 

a specific budget request for PSI-related activities, its decision not to 

report expenditure amounts accounted for in agency general 

operating budgets limits Congress’ knowledge of the amount the U.S. 

government is spending on PSI and how those funds are being 

allocated. In addition, we found that some expenditure amounts not 

included in the annual reports were unique to PSI and, therefore, 

should have been included. In a 2009 email to CBP, a DOD official 

stated that travel expenses could be included in its submission to the 

annual report, as long as they were specifically for a PSI event. 

However, after CBP submitted such expenditures to DOD, they were 

excluded from the 2010 annual report even though they were for PSIspecific travel.

2. DOD’s willingness to work with interagency partners toward 

developing and using a framework to assess PSI activities and toward 

identifying meaningful performance measures is consistent with our 

recommendation. If the CCP is developed as a framework that links 

PSI activities to outcomes and the objective of PSI, it will be 

consistent with our recommendation.

GAO’s Comments
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-12-441 Proliferation Security Initiative

Thomas Melito, (202) 512-9601, or melitot@gao.gov

In addition to the contact named above, Godwin Agbara (Assistant 

Director), Jeffrey Baldwin-Bott, Lynn Cothern, and Mattias Fenton made 

key contributions to this report. Martin de Alteriis, Mark Dowling, and Mary 

Moutsos also provided technical assistance.

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(320847)
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