EXPORT CONTROLS

Proposed Reforms 

Create Opportunities 

to Address 

Enforcement 

Challenges

Report to Congressional Committees

March 2012

GAO-12-246

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-246, a report to 

congressional committees 

March 2012

EXPORT CONTROLS

Proposed Reforms Create Opportunities to Address 

Enforcement Challenges

Why GAO Did This Study

The U.S. government controls the 

export of sensitive defense and dualuse items (having both military and 

commercial use). The five agencies

primarily responsible for export control 

enforcement—the Departments of 

Commerce, Homeland Security (DHS), 

Justice, State and the Treasury—

conduct inspections and investigations, 

and can levy punitive actions against 

violators. A challenging aspect of 

export control enforcement is the 

detection of illicit transshipments—the 

transfer of items from place of origin 

through an intermediary country to an 

unauthorized destination, such as Iran. 

In 2010, the President announced 

reforms to the U.S. export control 

system to address weaknesses found

by GAO and others. GAO was asked 

to address how the export control 

enforcement agencies allocate 

resources, as well as the challenges 

they face and the potential impact of 

export control reform on enforcement 

activities. GAO reviewed documents 

and met with enforcement agency 

officials as well as with U.S. and 

foreign government and company 

officials in Hong Kong, Singapore, and 

the United Arab Emirates, which have 

a high volume of trade and have been 

identified as potential hubs for illicit 

transshipments. 

What GAO Recommends

GAO recommends that Commerce, 

DHS, Justice, and State take steps 

individually and with other agencies 

through the national Export 

Enforcement Coordination Center to 

better manage export control 

enforcement resources and improve 

the license determination process. 

Agencies agreed with GAO’s 

recommendations.

What GAO Found

Agencies use a risk-based approach, including workload and threat assessment data, 

to allocate resources, but most do not fully track those used for export control 

enforcement activities. As their missions are broader than export controls, agencies 

can use staff resources for other activities based on need, making tracking resources 

used solely for export control enforcement difficult. Only Commerce’s Office of Export 

Enforcement allocates its resources exclusively to export control enforcement as that 

is its primary mission. Other agencies, such as State and the Treasury, have 

relatively few export control enforcement staff to track. While several agencies 

acknowledge the need to better track export enforcement resources and have taken 

steps to do so, they do not know the full extent of their use of these resources and do

not use this information in resource allocation decisions. In some cities, agencies are 

informally leveraging export enforcement resources through voluntarily created local 

task forces that bring together enforcement resources to work collectively on export 

control cases. 

Enforcement agencies face several challenges in investigating illicit transshipments, 

both domestically and overseas, which potentially reduce the effectiveness of 

enforcement activities and limit the identification and investigation of illicit 

transshipments. These include:

• License Determination Delays. License determinations—which confirm whether 

an item is controlled and requires a license, and thereby help confirm whether an 

export control violation has occurred—are often not timely, potentially hindering 

investigations and prosecutions. 

• Limited Secure Communications and Cleared Staff. Investigators have limited 

access to secure communications and staff with high-level security clearances in 

several domestic field offices, limiting investigators’ ability to share timely and 

important information. 

• Lack of Trend Data on Illicit Transshipments. While there is a good exchange of 

intelligence between enforcement agencies and the intelligence community—to 

seize shipments and take other actions against export control violators—officials 

noted that no formal process or means existed for these groups to collectively 

quantify and identify statistical trends and patterns relating to information on illicit 

transshipments. 

• Lack of Effectiveness Measures Unique to the Complexity of Export Controls. 

Investigative agencies lack measures of effectiveness that fully reflect the 

complexity and qualitative benefits of export control cases. 

Some of these challenges may be addressed by ongoing export control reform 

initiatives, but reform presents both opportunities and challenges. Revising the 

control list could simplify the license determination process, but could also result in 

the need for increased enforcement activity overseas to validate the recipient of the 

items as fewer items may require U.S. government approval in advance of shipment. 

As most staff located overseas have other agency and mission-related priorities, their 

availability may be limited. The newly created national Export Enforcement 

Coordination Center is intended to help agencies coordinate their export control 

enforcement efforts as well as share intelligence and law enforcement information 

related to these efforts. However, it is unclear whether the center will address all of 

the challenges GAO found, as detailed plans for its operations are under 

development. 

View GAO-12-246. For more information, 

contact Belva Martin at (202) 512-4841 or 

martinb@gao.gov. 
Page i GAO-12-246 Export Controls

Letter 1 

Background 3

Agencies Use a Risk-Based Approach to Allocate Resources but Do 

Not Fully Track Those Used For Export Control Enforcement 8

Reform Initiatives May Help Address Challenges In Investigating 

Illicit Transshipments But Detailed Plans Are Unknown 17

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 31

Appendix I Scope and Methodology 34

Appendix II Comments from the Department of Commerce 36

Appendix III Comments from the Department of Homeland Security 37

Appendix IV Comments from the Department of State 41

Appendix V GAO Contact and Staff Acknowledgments 43

 

Tables

Table 1: Export Control Enforcement Activities, by Departments 

and Agency 5

Table 2: Key Investigative Tools for Investigative Export Control 

Enforcement Activities 7

Table 3: Primary Missions of the Agencies with Export Control 

Enforcement Responsibility 9

Table 4: Enforcement Agency Total Staff and Staff Allocated for 

Domestic Export Control Enforcement, Fiscal Year 2010 10

Table 5: Average License Determination Response Times (in Days) 19

Table 6: ICE Number of Arrests, Indictments and Convictions for 

Defense and Dual-Use Items, Fiscal Years 2006 through 

2010 24

Contents
Page ii GAO-12-246 Export Controls

Table 7: OEE Number of Arrests, Indictments, and Convictions for 

Dual-Use Items, Fiscal Years 2006 through 2010 24

Figure

Figure 1: Location of Export Control Enforcement Investigative 

Agency Major Field Offices and Task Forces (as of 2011) 15

Abbreviations

AECA Arms Export Control Act

CBP Customs and Border Protection

DDTC Directorate of Defense Trade Controls

DHS Department of Homeland Security

DOD Department of Defense

DTSA Defense Technology Security Administration

EAA Export Administration Act 

EAGLE Export and Anti-proliferation Global Law Enforcement 

FBI Federal Bureau of Investigation

GPRA Government Performance Results Act

ICE Immigration and Customs Enforcement

OEE Office of Export Enforcement

OFAC Office of Foreign Assets Control

UAE United Arab Emirates 

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Page 1 GAO-12-246 Export Controls

United States Government Accountability Office

Washington, DC 20548

March 27, 2012

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Jon Kyl

Ranking Member

Subcommittee on Crime and Terrorism

Committee on the Judiciary 

United States Senate

Each year, billions of dollars in defense and “dual-use” items—items that 

have both commercial and military applications—are exported to U.S. 

allies and strategic partners to further national security, foreign policy, and 

economic interests.1 The U.S. government protects these items through 

its export control system to ensure that they are transferred to foreign 

parties in a manner consistent with U.S. interests. The current system is 

governed by a complex set of laws, regulations, and processes and is 

implemented by multiple agencies, some with overlapping jurisdiction. 

Enforcement, a key function in the system, strives to prevent or deter the 

illegal export of defense and dual-use items such as controlled 

components that were shipped to countries like Iran, which were later 

found in weapons and devices used against U.S. forces in Iraq. Export 

control enforcement activities include inspecting items to be exported, 

investigating potential export control violations, and pursuing and 

imposing criminal and administrative penalties against violators. These 

activities also seek to keep defense and dual-use items from being illicitly 

transshipped through intermediary countries or locations, such as the 

United Arab Emirates (UAE), Hong Kong,2

 

1

For the purposes of this report, the term defense items refers to defense articles, defense 

services, and related technical data, as specified in 22 U.S.C. § 2778, and the term dualuse refers to items that have both commercial and military applications, such as 

computers, radars, and telecommunication equipment. 

Singapore, and Malaysia, 

where a high volume of trade provides potential opportunities for the illicit 

transshipment of export-controlled items to an unauthorized final 

2

Hong Kong is a special administrative region of China.

 
 

Page 2 GAO-12-246 Export Controls

destination, such as Iran.3

In 2006, we found that U.S. export control enforcement agencies faced 

considerable challenges and made several recommendations to improve 

interagency coordination, and we continue to include the U.S. export 

control system as a key component of a GAO high risk area on protecting 

technologies critical to U.S. national security interests.

For the purposes of this report, illicit 

transshipment is the transfer of merchandise from its place of origin 

through an intermediary country to an unauthorized destination. For 

example, in September 2011, a Pakistani citizen pleaded guilty to 

conspiring to commit export violations in connection with a scheme to 

illegally export U.S. nuclear-related materials, by exporting these 

materials from the United States through the UAE, to several restricted 

entities in Pakistan. The Department of State and other federal agencies 

have recognized illicit transshipment as a major weakness in trade and 

national security.

4

To conduct our work, we reviewed laws, regulations, and guidelines 

relating to the enforcement of U.S. export controls on defense and dualNoting challenges 

in the entire U.S. export control system, in April 2010, the President 

announced a reform strategy that included the creation of a single export 

enforcement coordination agency as a primary forum where agencies can 

coordinate and enhance export control enforcement efforts and resolve 

conflicts. However, some members of Congress have raised questions 

about existing export control activities including resources agencies are 

devoting to these activities. Moreover, they have expressed concerns that 

without addressing existing enforcement problems, reform of the export 

control system could exacerbate current shortfalls in the system designed 

to prevent countries and entities of concern from obtaining sensitive U.S. 

defense and dual-use items. In response to your request, we identified (1) 

how agencies allocate staff resources for export control enforcement 

activities, and (2) challenges that agencies face in investigating illicit 

transshipments and the potential impact of export control reform initiatives 

on enforcement activities.

 

3

U.S. exports to Iran, including defense and dual-use items are severely restricted by U.S. 

laws and regulations. Current sanctions on Iran, which are administered by the 

Department of the Treasury, ban almost all U.S. exports to that country. 

4

GAO, Export Controls: Challenges Exist in Enforcement of an Inherently Complex 

System, GAO-07-265 (Washington, D.C.: Dec. 20, 2006); and GAO’s 2011 High-Risk 

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

Page 3 GAO-12-246 Export Controls

use items and interviewed officials from the Departments of Commerce, 

Defense (DOD), Homeland Security (DHS), Justice, State, and the 

Treasury as well as private industry and foreign government officials. We 

also visited agency headquarters as well as three domestic and three 

international locations to obtain and analyze information on resources, 

knowledge of illicit transshipments, and challenges in investigating export 

controls for criminal violations. We corroborated information on resources 

with agency budget and other documents where possible. The domestic 

locations, Baltimore, MD; Los Angeles, CA; and San Francisco, CA; 

represent one or more of the following: a large percentage of the 

investigative caseload, ports with a high volume of trade of U.S. 

commodities, and a large presence of aerospace, electronics, and 

software industries and geographic dispersion. The international 

locations, Hong Kong, Singapore, and the UAE, represent three of the top 

10 ports in the world for trade volume and have been identified by federal 

agency officials as potential hubs for illicit transshipments of defense and 

dual-use items. We also met with cognizant agency officials to discuss 

progress, opportunities, and challenges of the President’s current export 

control reform initiatives. (See appendix I for more details.)5

We conducted this performance audit from February 2011 through March 

2012, in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The U.S. government’s control over the export of defense and dual-use 

items is intended to ensure that U.S. interests are protected in 

accordance with the Arms Export Control Act (AECA) and the Export 

 

5

In March 2012, we reported on export control compliance and monitoring activities. 

However, the details were deemed sensitive, but unclassified by the agencies, and so are 

not described more fully in this report. 

Background 
 

Page 4 GAO-12-246 Export Controls

Administration Act (EAA).6 Defense items can include tanks, fighter 

aircraft, submarines, firearms, satellites, missiles, and training; while dualuse items can include computers, radars, and telecommunication 

equipment. Jurisdiction over the export of defense and dual-use items is 

primarily divided between State and Commerce. Generally, unless an 

exemption applies, exporters submit a license application to State if their 

items are controlled on the U.S. Munitions List7

Export control enforcement actions consist of three primary functions—

inspecting and seizing goods, investigating potential violators, and levying 

punitive actions against violators of export control laws.

or to Commerce if their 

items are controlled on the Commerce Control List pursuant to the Export 

Administration Regulations to receive export approval. As part of the 

application review process, State and Commerce consult with other 

departments, including DOD and with Treasury in the case of sanctioned 

countries. Offices within Commerce, DHS, Justice, and State conduct 

enforcement activities. Treasury and Commerce administer the current 

sanctions program for designated countries.

8 As shown in 

table 1, these functions are largely conducted by various agencies within 

Commerce, DHS, Justice, State, and the Treasury depending on the facts 

and circumstances of the case.9

 

6

22 U.S.C. § §2751-2799aa-2 and 50 U.S.C. app. §§ 2401-2420. The Export 

Administration Act is not permanent legislation. 50 U.S.C. app. § 2419. Authority granted 

under the act lapsed in August 2001. However, Executive Order 13,222, Continuation of 

Export Control Regulations, which was issued in August 2001 under the authority provided 

by the International Emergency Economic Powers Act (50 U.S.C. §§ 1701-1707.), 

continues the controls established under the act, and the implementing Export 

Administration Regulations. Executive Order 13,222 requires an annual extension and 

was recently renewed by Presidential Notice on August 12, 2011. 76 Fed. Reg. 50,661 

(Aug. 16, 2011).

Multiple laws, regulations, and directives 

provide differing enforcement authority for U.S. agencies to inspect, 

7

U.S. defense items are also sold and exported to foreign governments through the U.S. 

government’s Foreign Military Sales program. 

8

Actions can also include compliance and monitoring, such as reviewing disclosures by 

exporters of possible export control violations, prelicense checks, and postshipment 

verifications. See GAO, Export Controls: Post-Shipment Verification Provides Limited 

Assurance That Dual-use Items Are Being Properly Used, GAO-04-357 (Washington, 

D.C.: Jan. 12, 2004); and Defense Trade: Arms Export Control System in the Post 9/11 

Environment, GAO-05-234 (Washington, D.C.: Feb. 16, 2005).

9

Other departments, including Defense and Energy, may provide technical expertise on 

items to enforcement agencies. Also, Defense and the military services have investigative 

units that may provide support to the enforcement agencies.
 

Page 5 GAO-12-246 Export Controls

investigate, and take punitive action against potential violators of U.S. 

export control laws. These authorities provide the Federal Bureau of 

Investigation (FBI) and Immigration and customs Enforcement (ICE) with 

overlapping jurisdiction to investigate defense potential violations, and 

FBI, ICE, and Commerce’s Office of Export Enforcement (OEE) with 

overlapping jurisdiction to investigate dual-use potential violations.

Table 1: Export Control Enforcement Activities, by Departments and Agency 

Inspection Investigation a Punitive action

Commerce

b

Bureau of Industry and Security

Office of Chief Counsel 

Office of Export Enforcement (OEE)Pc 

DHS

U.S. Customs and Border Protection (CBP)  

U.S. Immigration and Customs Enforcement 

(ICE) 

d



Justice

U.S. Attorneys’ Offices 

Federal Bureau of Investigation (FBI) 

State 

Directorate of Defense Trade Controls 

(DDTC)



Office of Legal Adviser for Political-Military 

Affairs 



Treasury

Office of Foreign Assets Control (OFAC) 

Source: GAO analysis of information provided by each agency and export control laws and regulations.

a

CBP and ICE both have the authority to conduct inspections at U.S. ports, but, according to CBP 

officials, CBP has a primary role in this area.

b

For purposes of this report, punitive actions can be either criminal or administrative against potential 

violators of export control laws and regulations. Criminal actions taken against violators of export 

control laws and regulations can result in imprisonment, fines, forfeitures, and other penalties. 

Administrative actions against violators can include fines, suspension of an export license, or denial 

or debarment from exporting.

c

Commerce’s Office of Enforcement Analysis provides analytic support to OEE. 

d

Inspections of items scheduled for export are routinely conducted at U.S. 

air, sea, and land ports, as part of the U.S. Customs and Border 

CBP can seize items being exported contrary to law, including those subject to export controls, and 

can also issue penalties under the Foreign Trade Regulations for false or fraudulent reporting on or 

misuse of the Automated Export System.
 

Page 6 GAO-12-246 Export Controls

Protection (CBP) officer’s responsibilities for enforcing U.S. import and 

export control laws and regulations at our nation’s ports of entry. CBP’s 

enforcement activities include inspection of outbound cargo through a 

risk-based approach using CBP’s automated targeting systems to assess 

the risk of each shipment, review and validation of documentation 

presented for licensable items, detention of questionable shipments, and 

seizure of shipments and issuance of monetary penalties for items that 

are found to be in violation of U.S. export control laws.10

Investigations of potential violations of export control laws for dual-use 

items are conducted by agents from OEE, ICE, and FBI. Investigations of 

potential export control violations involving defense items are conducted 

by ICE and FBI agents. OEE and ICE are authorized to investigate 

potential violations of dual-use items. ICE is also authorized to investigate 

potential violations of defense items. The FBI has authority to investigate 

any criminal violation of law not exclusively assigned to another agency, 

and is mandated to investigate and oversee export control violations with 

a counterintelligence concern. The investigative agencies have various 

tools for investigating potential violations (see table 2) and establishing 

cases for potential criminal or administrative punitive actions.

According to 

CBP officials, almost 3 million shipments per month are exported from the 

United States.

 

10According to CBP officials it refers most export seizures to ICE for potential case 

development, including information on all shipments where weapons are involved or CBP 

officers have some reason to believe there is a potential for criminal activity. A number of 

these referrals lead to ICE investigations.
 

Page 7 GAO-12-246 Export Controls

Table 2: Key Investigative Tools for Investigative Export Control Enforcement 

Activities

Investigative tool OEE ICE a FBI

Undercover operations   

Searches without warrants at the borders 

Wiretaps   

Overseas investigations  b  

Access and use of forfeiture funds   

Source: GAO analysis of export control laws and regulations and information provided by the agencies.

a While OEE conducts short-term undercover operations, it does not have independent authority to 

use nonappropriated funds to finance such operations or to operate undercover proprietorships. 

According to OEE, it is seeking additional statutory authorities in the areas of overseas investigations, 

undercover operations, forfeiture authority, and wiretapping authority. 

b

Punitive actions, which are either criminal or administrative, are taken 

against violators of export control laws and regulations, and may involve 

U.S. or foreign individuals and companies. Criminal violations are those 

cases where the evidence shows that the exporter willfully violated export 

control laws. U.S. Attorneys’ Offices prosecute export control 

enforcement criminal cases in consultation with Justice’s National 

Security Division. These cases can result in imprisonment, fines, 

forfeitures, and other penalties. Punitive actions for administrative 

violations can include fines, suspension of an export license, or denial or 

debarment from exporting, and are imposed primarily by State or 

Commerce, depending on whether the violation involves the export of a 

defense or a dual-use item. For example, Commerce can impose the 

administrative sanction of placing parties acting contrary to the national 

security or foreign policy interests of the United State on a list that 

prevents their receipt of items subject to Commerce controls. The 

Treasury’s Office of Foreign Assets Control (OFAC) administers and 

enforces economic sanctions programs primarily against countries and 

groups of individuals, such as terrorists and narcotics traffickers. The 

sanctions can be either comprehensive or selective, using the blocking of 

assets and trade restrictions to accomplish foreign policy and national 

security goals. In some cases, both criminal and administrative penalties 

can be levied against an export control violator. In fiscal year 2010, 

Justice data showed that 56 individuals or companies were convicted of 

Enforcement agencies can conduct overseas investigations with host government concurrence.
 

Page 8 GAO-12-246 Export Controls

criminal violations of export control laws.11 State reported over $43 million 

and Commerce reported more than $25.4 million in administrative fines 

and penalties for fiscal year 2010. In 2011, over a third of the major U.S. 

export control enforcement and embargo-related criminal prosecutions 

involved the illegal transfer of U.S. military, nuclear, or technical data to 

Iran and China.

Agencies use some form of a risk-based approach when allocating 

resources to export control enforcement as their missions are broader 

than export controls. As agencies can use these resources for other 

activities based on need, tracking resources used solely on export control 

enforcement activities is difficult. Only OEE allocates all of its resources 

exclusively to export control enforcement as that is its primary mission, 

and State and the Treasury have relatively few export control 

enforcement staff to track. Agencies’ risk-based resource allocation 

approach incorporates a variety of information, including workload and 

threat assessment data, but has not generally included data on resources 

used for export control enforcement activities as agencies did not 

implement systems to fully track this information until recently. Given the 

overlapping jurisdiction of several enforcement agencies, in some cities 

agencies have voluntarily created local task forces that bring together 

enforcement resources to work collectively on cases—informally 

leveraging resources.

Agencies determine their missions based on statutes, policy, and 

directives, and articulate their fundamental mission in their strategic 

plans.12

 

11Data provided by Justice for criminal convictions where 50 U.S.C. § 1705 or 22 U.S.C. § 

2778 was charged. 

Based on our review of these documents as well as discussions 

with senior agency officials, agencies with primary export control 

enforcement responsibility have multiple missions that extend beyond 

export controls as shown in table 3, except for OEE. As such, these 

agencies are faced with balancing multiple priorities when allocating staff 

resources.

12A strategic plan, according to the Government Performance and Results Act (as 

amended), articulates, among other things, the major functions and operations of an 

organization, and describes its long-term general goals for implementing those functions 

or operations, including the resources needed to reach these goals.

Agencies Use a RiskBased Approach to

Allocate Resources 

but Do Not Fully

Track Those Used For 

Export Control 

Enforcement 

Most Agencies—Whose 

Missions Are Broader Than 

Export Controls—Have 

Limited Data on Resources 

Used for Export Control 

Enforcement 
 

Page 9 GAO-12-246 Export Controls

Table 3: Primary Missions of the Agencies with Export Control Enforcement Responsibility

Department/agency Mission

Commerce

• OEE Investigate potential violations of dual-use and commercial exports with a priority related to weapons of 

mass destruction, terrorism, and unauthorized military use.

DHS

• CBP Detect and prevent terrorist and terrorist weapons from entering U.S. ports, and inspecting items and 

persons entering and leaving the United States.

• ICE Investigate drug smuggling, human trafficking and smuggling, financial crimes, commercial fraud, 

intellectual property rights violations, document fraud, money laundering, child exploitation, immigration 

fraud, and potential defense and dual-use export violations.

Justice

• U.S. Attorneys’ Office Prosecute violations of federal criminal laws and litigate civil matters on behalf of the United States. 

Criminal prosecutions include cases involving terrorism, counterterrorism, government contractor fraud, 

and many others.

• FBI Protect the United States against terrorist and foreign intelligence threats and enforce criminal laws. 

• National Security 

Division

Supports export control enforcement through its technical expertise to prosecutors and law enforcement 

agencies.

State 

• DDTC Control the export and temporary import of defense articles and defense services covered by the United 

States Munitions List and brokering activities by U.S. and foreign persons.

Treasury 

• OFAC Administer and enforce economic and trade sanctions based on US foreign policy and national security 

goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those 

engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the 

national security, foreign policy or economy of the United States.

Source: GAO analysis of agency information.

The agencies with export control enforcement responsibilities use some 

form of a risk-based approach to allocate staff resources, but several 

agencies, including CBP, FBI, ICE, and the U.S. Attorneys’ Offices, did 

not implement systems to fully track the staff time spent on enforcement 

activities until recently. Only OEE allocates its entire investigative staff to 

this mission. As most enforcement resources are used to enforce a wide 

variety of laws, not just export control laws, if an important need arises, 

enforcement agencies have the flexibility to use these resources for other, 

non-export control related duties. Table 4 shows the total domestic staff, 

by agency that was allocated to conduct export control enforcement 

activities in fiscal year 2010. The number of officers, agents, and 

investigators who actually work on export control enforcement may be 

less than the number allocated for each agency.
 

Page 10 GAO-12-246 Export Controls

Table 4: Enforcement Agency Total Staff and Staff Allocated for Domestic Export 

Control Enforcement, Fiscal Year 2010

Agency Total staff

Staff allocated for 

export control 

enforcement

Commerce: OEE 109 investigators 95 investigators

DHS: CBP

a

20,455 officers 658 officers

DHS: ICE/Homeland Security 

Investigations

b

6,700 investigators Data not publicly 

available

Justice: FBI 12,092 agents c Data not publicly available

Justice: U.S. Attorneys 4,005 criminal 

attorneys

d 292 criminal attorneys

State: DDTC

e

21 specialists 10 specialists

State: Office of Legal Adviser for 

Political-Military Affairs

12 attorneys 1 attorney

Commerce: Office of the Chief 

Counsel, Bureau of Industry and 

Security 

12 attorneys 9 attorneys

Treasury: OFAC 27 enforcement officers None 

Source: GAO analysis of agency information.

a

All investigators are used solely for export control enforcement activities and, according to 

Commerce, an additional 39 staff are available to provide analytic support.

b

CBP officers conduct outbound enforcement activities which include both the passenger and cargo 

environments. 

c

FBI agents are not used solely for export control enforcement activities, but generally handle these 

cases through their Counterintelligence Division. The resources that FBI uses for these activities are 

classified.

d

U.S. Attorneys are not used solely for export control enforcement activities.

e

These agencies have systems to track staff resources used for their 

primary missions and several have acknowledged the need to better track 

export control enforcement resources and have taken steps to do so. The 

Government Performance and Results Act (GPRA) of 1993 laid the 

foundation for results-oriented agency planning, measurement, and 

reporting in the federal government, highlighting the important role 

performance information plays in improving the efficiency and 

effectiveness of an agency.

This figure represents the number of attorneys who have been specially allocated to work on 

terrorism and national security cases, which includes but is not limited to export enforcement cases.

13

 

13 Pub. L. No. 103-62.

The GPRA Modernization Act of 2010 
 

Page 11 GAO-12-246 Export Controls

reinforces these principles.14 One key element of these principles 

includes having accurate data agencies can use to allocate resources, 

among other things.15

• OEE allocates all of its investigators solely to export control 

enforcement, and as such, is the only agency that has been able to 

fully track the resources used on these activities. To formulate its 

budget and allocate its investigators, OEE conducts threat 

assessments with a priority related to weapons of mass destruction, 

terrorism, and unauthorized military use; and analyzes export control 

enforcement case workload, including the prior year’s investigative 

statistics of arrests, indictments, and convictions. OEE also recently 

completed a field office expansion study to decide which cities would 

be the best locations for additional OEE field offices. In this study, 

OEE considered the volume of licensed and unlicensed exports and 

the type of high-tech items exported from different areas of the United 

States, and concluded that Atlanta, GA; Cincinnati, OH; Phoenix, AZ; 

and Portland, OR, were optimal locations, but has not received budget 

approval for expansion.

However, most of the agencies responsible for 

inspecting, investigating, and prosecuting potential export control 

violations did not know the full extent of the use of staff resources on 

these activities, and as such, have not used this information in resource 

allocation decisions, as outlined in the examples below.

• CBP reemphasized outbound operations in the creation of its 

Outbound Enforcement Division in March 2009 to help prevent 

terrorist groups, rogue nations, and other criminal organizations from 

obtaining defense and dual-use commodities; enforce sanctions and 

trade embargoes; and increase exporter compliance. CBP determines 

the number of staff to allocate to outbound inspections through a riskbased approach based on prior workload and a quarterly threat 

matrix—which includes the volume of outbound cargo and 

passengers, port threat assessments, and the numbers and types of 

seizures and arrests at the ports for items such as firearms and 

currency. As of fiscal year 2010, CBP had allocated approximately 

660 officers for outbound enforcement activities, but these officers can 

be used for other than export control-related activities at any time, 

 

14Pub. L. No. 111-352 (2011).

15GAO, National Export Initiative: U.S. and Foreign Commercial Service Should Improve 

Performance and Resource Allocation Management, GAO-11-909 (Washington, D.C.: 

Sept. 29, 2011).
 

Page 12 GAO-12-246 Export Controls

when needed. For example, the Port of Baltimore has officers 

assigned to perform outbound activities at both the airport and 

seaport, some of which focus on the enforcement of controlled 

shipments in the seaport environment. According to the Port Director, 

any of these officers can be redirected at any time and often are 

assigned to the airport during the busy airline arrival times, to perform 

inbound inspection duties—based on priorities. Further, CBP does not 

track the hours that its officers across the country spend on export 

control enforcement activities, but is in the process of implementing a 

system to do so. CBP officials stated that determining the right mix of 

officers is complex and changes to its tracking system should allow for 

better planning and accounting for resources used for outbound 

activities in the future.

• ICE’s Homeland Security Investigations, Counter-Proliferation 

Investigations Unit focuses on preventing sensitive U.S. technologies 

and weapons from reaching the hands of adversaries and conducts 

export control investigations. To determine how many investigators it 

should allocate to this unit, ICE uses information including operational 

threat assessments and case data from the previous year, by field 

office, on total numbers of arrests, indictments, convictions, seizures, 

and investigative hours expended on export control investigations. For 

example, it assigns a tier level for each of its 70 field offices, based on 

threat assessments—ranging from 1 for the highest threat, resulting in 

a larger number of agents assigned to these offices; to 5 for the 

lowest threat, with a lower number of agents assigned. To further 

prioritize resources, in 2010, ICE established Counter Proliferation 

Investigations Centers in selected cities throughout the United States, 

with staff focused solely on combating illegal exports and illicit 

procurement networks seeking to acquire vital U.S. technology. ICE 

concluded that it needed to form these centers to combat the 

specialized nature of complex export control cases and determined 

that its previous method of distributing resources needed refinement, 

noting that some ICE field office managers had difficulty in balancing 

numerous competing programmatic priorities and initiatives. 

According to ICE officials, they plan to mitigate these concerns by 

having staff and facilities focused solely on export control enforcement 

cases, which will allow ICE to track and use this information to better 

determine future resource needs.

• The FBI, with both an investigative and intelligence mission, does not 

allocate resources solely for export control enforcement and officials 

told us they view these activities as a tool to gain intelligence that may 

lead to more robust cases. Nevertheless, cases involving export 

controls are primarily led by agents within the Counterintelligence 

Division. To determine the number of agents to allocate to this 
 

Page 13 GAO-12-246 Export Controls

division, the FBI uses a risk management process and threat 

assessments. Several years ago, the FBI established at least one 

Counterintelligence squad in each of its 56 field offices. In July 2011, 

the FBI established a Counterproliferation Center, merging its 

Counterintelligence Division and its Weapons of Mass Destruction 

Directorate to better focus their efforts and resources. The FBI is in 

the process of implementing new codes within its resource tracking 

system to obtain better information on agents’ distribution of work, 

which will include time spent on investigations of defense and dualuse items.

• U.S. Attorneys’ Offices have discretion to determine the resources 

that they will allocate to export control enforcement cases, based on 

national priorities and the individual priorities of the 94 districts. These 

priorities include law enforcement concerns for their district and leads 

from investigative agencies. In response to the risk associated with 

national security, which includes export control enforcement cases, 

staffing for national security activities has increased and several 

districts have created national security sections within their office. In 

2008, the Executive Office for U.S. Attorneys provided codes for 

charging time and labeling cases to obtain better information on the 

U.S. Attorneys’ Office distribution of work and those resources used 

for export control enforcement. However, some Assistant U.S.

Attorneys told us that the time-keeping system is complicated as there 

are multiple codes and sub-categories in the tracking system and 

determining the correct codes is often subjective, making it difficult to 

track time spent on export control enforcement cases. Senior agency 

officials acknowledged this concern and are working with the U.S. 

Attorneys’ Offices to provide better guidance to improve the accuracy 

of attorney time charges.

• Other offices, such as State’s Office of the Legal Adviser for PoliticalMilitary Affairs and Commerce’s Office of the Chief Counsel for the 

Bureau of Industry and Security assist the enforcement agencies by 

providing legal support. For example, Commerce’s Office of the Chief 

Counsel pursues administrative enforcement actions against 

individuals and entities, but also reviews and advises on OEE 

recommendations for other administrative actions, such as temporary 

denials of licenses. In addition, DDTC and OFAC pursue 

administrative enforcement actions against violators. For example, 

OFAC administers and enforces U.S. economic and trade sanctions 

against designated foreign countries. While not all of staff in these 

offices are allocated to export control enforcement, these offices have 

relatively few staff to track.
 

Page 14 GAO-12-246 Export Controls

In addition to a domestic presence, most export control enforcement 

agencies also allocate resources overseas, but only Commerce allocates 

resources exclusively to export control enforcement. For example, 

Commerce maintains Export Control Officers in six locations abroad; 

Beijing and Hong Kong, China; Abu Dhabi, UAE; New Delhi, India; 

Moscow, Russia; and Singapore, to support its dual-use export control 

enforcement activities. Given that these officers have regional 

responsibilities, they cover additional locations. For example, the Export 

Control Officer assigned to Singapore also covers Malaysia and 

Indonesia. While other agencies have field locations in many overseas 

locations, these resources are to support the agencies’ broader missions 

and can be used for other duties based on the overseas mission 

priorities. For example, ICE has 70 offices in 47 foreign countries with 

more than 380 government and contract personnel which support all ICE 

enforcement activities, including export control. They can also be called 

upon to support various other DHS mission priorities. Specifically, the ICE 

agents we met with at the U.S. Embassy in Abu Dhabi also conduct 

activities in support of the full DHS mission and a great portion of their 

time is spent on visa security and a lesser amount on export control 

enforcement activities.

The export control enforcement investigative agencies often have offices 

located in the same cities or geographic areas. In many of these cities, 

agencies’ officials said that they informally leverage each others’ tools, 

authorities, and resources to coordinate investigations and share 

intelligence through local task forces allowing them to use resources 

more efficiently and avoid duplicating efforts or interfering with each 

other’s cases. In 2007, Justice’s National Export Enforcement Initiative 

encouraged local field offices with a significant export control threat to 

create task forces or other alternatives to coordinate enforcement efforts 

in their area. Since then, almost 20 U.S. Attorneys’ Offices have created 

task forces of their own initiative or in conjunction with another 

enforcement agency, primarily in cities where these agencies are colocated to facilitate the investigation and prosecution of export control 

cases. Figure 1 shows the location of investigative agencies’ major field 

offices, as well as the location of export control enforcement task forces.

Agencies Informally 

Leverage Enforcement 

Resources through Local 

Task Forces
 

Page 15 GAO-12-246 Export Controls

Figure 1: Location of Export Control Enforcement Investigative Agency Major Field Offices and Task Forces (as of 2011)
 

Page 16 GAO-12-246 Export Controls

Most of the task force members we met with in Baltimore, Los Angeles, 

and San Francisco stated that they see benefits beyond the coordination 

of cases, including investigating cases together and sharing resources.

Baltimore’s Counterproliferation Task Force: ICE and the U.S. Attorneys’ 

Office created this Task Force in 2010 and it has representatives from 

each of the enforcement agencies located in the area, as well as the 

defense and intelligence communities. Task force officials stated that they 

develop and investigate export control cases together and, to enhance 

interagency collaboration, ICE has supplied work space, allowing agents 

from other agencies to work side-by-side to pursue leads and conduct

investigations. Officials emphasized that the task force enables smaller 

agencies with fewer resources to leverage the work and expertise of the 

others to further their investigations and seek prosecutions. Sometimes 

the task force structures reap benefits that individual agencies cannot 

reach on their own, as exemplified by the Baltimore Counterproliferation 

Task Force. Among successes was a Maryland man sentenced to 8 

months in prison followed by 3 years of supervised release for illegally 

exporting export-controlled night vision equipment.

Los Angeles’ Export and Anti-proliferation Global Law Enforcement 

(EAGLE) Task Force: The U.S. Attorney established this Task Force in 

2008 as a result of Justice’s counter-proliferation initiatives. Its purpose is 

to coordinate and develop expertise in export control investigations. 

Currently, there are over 80 members from 17 Los Angeles-based federal 

agencies. According to a task force official, the EAGLE task force has 

resulted in increased priority on export control investigations and 

improved interagency cooperation since it was established. For instance, 

the enforcement agencies are now more effectively sharing information in 

their respective databases. A task force official noted that enhanced 

access to these databases allows agencies to reduce duplication of 

license determination requests and to easily retrieve information on a 

particular person or commodity’s history using the search options. 

Additionally, through the task force structure, ICE and OEE agents have 

worked together to conduct additional outreach to industry affiliates.

San Francisco’s Strategic Technology Task Force: According to officials, 

this task force was formed by FBI in 2004, with a primary focus on 

conducting joint export control outreach activities to academia and 

industry with the other investigative agencies (ICE and OEE). This task 

force also includes participation by the military service intelligence units 

and other law enforcement agencies. FBI task force leaders stated that 

this task force has helped to coordinate outreach activities as well as to 
 

Page 17 GAO-12-246 Export Controls

generate investigative leads. According to an agent from the FBI’s San 

Jose field office, that office has a performance goal to conduct 90 percent 

of their export control-related investigations jointly with investigative 

agencies at ICE and Commerce.

Although successful cases of joint collaboration among agencies can 

yield positive enforcement outcomes, as reported by the offices in the 

three cities we visited, the extent to which these alliances are effective is 

primarily dependent on personal dynamics of a given region, agency, and 

law enforcement culture. In addition, these local agency task forces for 

export control enforcement vary in structure, are voluntary, and do not 

exist nationwide. For example, while multiple investigative agencies have 

local offices in Chicago and Dallas with export control enforcement 

agents, agencies do not have a local task force in these cities to regularly 

coordinate on export control cases. While agency officials shared 

examples of agencies informally leveraging each other’s resources, 

officials told us that they do not factor in such resources when planning 

their own agency allocations for a variety of reasons, including each 

agency’s separate budgets and missions, which do not generally consider 

those of other agencies.

Enforcement agencies face several challenges in investigating illicit 

transshipments, both domestically and overseas—including license 

determination delays; limited access in some overseas locations; and a 

lack of effectiveness measures that reflect the complexity and qualitative 

benefits of export control cases. Recognizing broader challenges in 

export control enforcement, the President announced the creation of a 

national export enforcement coordination center, which may help 

agencies address some of the challenges described below, but detailed 

plans to do so have yet to be developed.

The current export control enforcement system poses several challenges 

that potentially reduce the effectiveness of activities and limit the 

identification and investigation of illicit transshipments. Export control 

enforcement agencies seek to keep defense and dual-use items from 

being illegally exported through intermediary countries or locations to an 

unauthorized final destination, such as Iran, but agencies face challenges 

that can impact their ability to investigate export control violations, both 

domestically and overseas. First, license determinations—which confirm 

whether an item is controlled and requires a license, and thereby help 

confirm whether an export control violation has occurred—can sometimes 

Reform Initiatives 

May Help Address 

Challenges In 

Investigating Illicit

Transshipments But 

Detailed Plans Are

Unknown 

Investigators Face Several 

Challenges in Investigating 

Illicit Transshipments—

Both Domestically and 

Overseas
 

Page 18 GAO-12-246 Export Controls

be delayed, potentially hindering investigations and prosecutions. 

Second, investigators have limited access to secure communications and 

cleared staff in several domestic field offices, which can limit their ability 

to share timely and important information. Third, agencies have limited 

access to ports and facilities overseas. Fourth, agencies lack consistent 

data to quantify and identify trends and patterns in illicit transshipments of 

U.S. export-controlled items. Lastly, investigative agencies lack measures 

of effectiveness that fully reflect the complexity and qualitative benefits of 

export control cases.

License Determination Delays. To confirm whether a defense or dual-use 

item is controlled and requires a license, inspectors, investigators, and 

prosecutors request license determinations from the licensing agencies of 

State and Commerce.16 These license determinations are integral to 

enforcement agencies’ ability to seize items, pursue investigations, or 

seek prosecutions. DHS’s Exodus Command Center operates the Exodus 

Accountability Referral System—an ICE database that initiates, tracks, 

and manages enforcement agency requests for license determinations 

from the licensing agencies.

17 Exodus Command Center guidance 

identifies three different levels of license determinations: initial (to seize 

an item or begin an investigation), pre-trial (to obtain a search warrant, 

among other things), and trial (to be used during trial proceedings). The 

Exodus Command Center has established internal timeliness goals for 

receiving responses to requests for initial determinations within 3 days; 

pre-trial certifications within 45 days; and trial certifications within 30 days. 

However, as shown in table 5, these goals are often not met, which can 

create barriers for enforcement agencies in seizing shipments before they 

depart the United States; obtaining search warrants; and making timely 

arrests.

 

16Depending on the license, the request can also go to Treasury’s OFAC for sanctioned 

countries.

17The Exodus Command Center was established in 1982—and now is part of DHS/ICE—

as the single point of contact for investigators and officers in the field needing operational 

support from export control agencies. 
 

Page 19 GAO-12-246 Export Controls

Table 5: Average License Determination Response Times (in Days)

License determination (goal) 

Response time

FY 2007 FY 2008 FY 2009 FY 2010 

Initial (3 days) 

 - Defense items 8 5 7 10

 - Dual-use items 19 19 23 30

Pre-Trial (45 days)

 - Defense items 126 91 64 93

 - Dual-use items 10 18 29 81

Trial (30 days)

 - Defense items N/Aa 79 64 44 

 - Dual-use items N/A N/A a 58 a N/A

Source: Data provided by the Exodus Command Center.

a

a

According to State officials, they did not participate in developing the 

Exodus Command Center’s goals, and State has different timeframes for 

responding to license determination requests. State officials noted that 

there is no statutory or regulatory requirement for the licensing agencies 

to provide license determinations and they must balance these activities 

with their primary mission of processing license applications. State 

officials told us their response to initial license determinations is a quick, 

unofficial assessment on whether or not an item is likely on the U.S. 

munitions list and it established a timeliness goal of 1-day to respond 

these requests. In 2004, State established a 30-day goal for responding 

to pre-trial and trial certification requests, but due to increased caseload 

and difficulty in meeting this goal, it revised it to 60-days. According to 

State officials, the number of requests from federal law enforcement for 

pre-trial and trial license determinations has increased significantly over 

the past 5 years—from 79 in fiscal year 2006 to 219 in fiscal year 2011, 

an increase of over 270 percent. Officials from State attribute some of the 

time it takes to process license determinations to the need to request 

interagency review and conduct additional analysis, as well as the 

complexity of the determination. For example, State sends all pre-trial and 

trial certification cases to DOD’s Defense Technology Security 

Administration (DTSA) for its review, which can add to the time in 

responding to enforcement agencies’ requests for license determinations. 

DTSA officials stated that these cases are reviewed through their normal 

licensing process and were not aware of any established timeframe 

goals, but stated that they expedite review of such license determination 

requests, for time-sensitive cases. As for complexity, according to State 

Exodus Command Center officials noted that this information was not available.
 

Page 20 GAO-12-246 Export Controls

officials, those involving firearms, their components, and ammunition are 

relatively routine requests to respond to, whereas others involving 

multiple commodities, volumes of technical data, and complex services 

take more time and may involve multiple meetings and consultations 

among licensing agencies to make a determination. Further, State 

officials noted that they continue to educate law enforcement and work 

with ICE and FBI liaisons to ensure better information is provided in the 

request.

Commerce officials also noted that they did not participate in developing 

the Exodus Command Center’s goals. Commerce has a 30-day goal for 

responding to initial license determination requests, but according to 

Commerce officials, does not have a specific timeframe for responding to 

pre-trial and trial certifications because they conduct an in-depth review in 

their initial determination. Commerce officials noted that they do not have 

a three-level system for processing license determinations and that it 

processes standard and certified license determination requests. While 

Commerce’s standard determinations are equivalent to State’s initial 

determinations, Commerce’s approach differs from State’s in that it 

conducts a more thorough review for this initial determination requiring 

more time than the 3-day goal established by the Exodus Command 

Center. Commerce’s certified license determinations are equivalent to 

State’s pre-trial and trial certifications, but these can take less time to 

complete if an initial determination was conducted. Commerce officials 

noted that, while they previously tracked and reported the timeliness of 

license determination requests in their annual reports, as of fiscal year 

2011, they no longer track this information because they are generally 

able to process these in a timely manner based on the urgency of the 

request. Commerce officials also noted that the Exodus Command Center 

data on Commerce’s response times do not reflect all license 

determinations, as OEE investigators request license determinations 

directly from Commerce licensing officers and FBI investigators can route 

such requests through OEE.

Limited Secure Communications and Cleared Staff. Limited access to 

secure communications, networks, facilities, and cleared staff by key 

investigative agencies including OEE and ICE can cause inconveniences 

and delays in the speed of export control investigations. While each of its 

field offices has access to secure telephones, none of the OEE field

offices has its own secure networks or facilities—it accesses these 

through other agencies. According to some investigators that we spoke 

with, this limited access can sometimes create difficulties in 

communicating overseas, as well as working on cases jointly with the FBI. 
 

Page 21 GAO-12-246 Export Controls

This lack of immediate access to secure networks and facilities can limit 

investigators’ ability to share timely and important information, according 

to agency officials. A field office agent from the FBI stated that the 

inability to fully communicate with investigators from other agencies can 

be challenging when working jointly on cases—including a lack of highlevel security clearances that can be needed to discuss certain export 

control cases. According to OEE officials, they plan to equip each of their 

field offices with secure networks and facilities, and expect to complete 

installation of the secure networks during 2012. In addition, OEE is 

working to provide Top Secret-Sensitive Compartmented Information 

clearances to the remaining 37 of its 95 investigators that lack this 

clearance. According to ICE officials, most of the ICE field offices have 

access to secure telephones and data networks, but about half of these 

offices lack secure facilities and typically use those of other agencies, 

when needed.

Limited Overseas Access for Investigative Agencies. Enforcement 

agencies have differing levels of access to facilities and ports overseas 

when enforcing U.S. export control laws, which can limit their ability to 

carry out certain investigative activities. To pursue investigations of 

possible illicit transshipments, the U.S. government relies on the 

cooperation of host governments. According to agency officials, the 

success of enforcement activities abroad and the level of access granted 

is often determined by the U.S. government’s relationship with the host 

government. For example, ICE in Abu Dhabi has fostered a relationship 

with the customs officials in the UAE and has worked with that 

government to create an academy and to provide UAE customs officials 

with various export control training sessions. According to the U.S. 

Deputy Chief of Mission and ICE attaché in the UAE, this collegial 

relationship has fostered better cooperation in several areas, including 

export controls. U.S. enforcement agencies overseas also rely on foreign 

counterparts to conduct enforcement activities. For example, the ICE 

attaché in Hong Kong told us that the Hong Kong government and its 

customs officials are helpful and responsive and that this relationship is 

further facilitated by the existence of a Customs Mutual Assistance 

Agreement, which allows direct contact and information exchange 

between U.S. and Hong Kong customs officials. In addition, Commerce 

has Export Control Officers stationed abroad and also has data sharing 

agreements with Hong Kong and Singapore to help ensure that U.S.-

origin items are not retransferred without appropriate authorization. 

According to some State Department and agency officials overseas, while 

the existence of formal agreements with host governments, such as a 

Mutual Legal Assistance Treaty for prosecution or a Customs Mutual 
 

Page 22 GAO-12-246 Export Controls

Assistance Agreement allow for information sharing and assistance with 

the United States, these formal agreements do not guarantee that U.S. 

law enforcement will have access to foreign persons, ports, and facilities. 

Some agency officials overseas noted that such access is often 

dependent on the U.S. relationship with the host government regardless 

of the existence of formal agreements.

The lack of reciprocity in export control laws can also make it difficult to 

pursue export control violations abroad. The three key transshipment 

locations we visited, Hong Kong, Singapore, and the UAE each had their 

own national export control laws, and according to some State and 

overseas agency officials, these governments were most responsive to 

export control violations that fell under the international legal framework of 

United Nations’ sanctions and major multilateral export control lists. 

Nevertheless, State officials noted that Hong Kong has had an extensive 

export and transshipment control system in place for over a decade. 

These officials also noted that they have identified and shared 

transshipment “best practices” that countries or locations can adopt to 

provide key legal authorities to better position them to enforce U.S. export 

control laws. In addition, investigators overseas told us that the lack of 

extradition treaties has limited their ability to pursue export control 

violators. The United States does not have an extradition treaty with the 

UAE, but it does have one with Hong Kong. While the United States has 

an extradition treaty with Singapore, it went into force over 70 years ago 

and, according to Singapore Embassy officials, it does not reflect current 

types of crimes and its renewal is unlikely. Despite these challenges, 

according to State, positive action relating to extradition has and 

continues to be achieved on a case-by-case basis.

Lack of Trend Data on Illicit Transshipments. No formal process exists 

between the investigative export control enforcement community and the 

intelligence community to share data or quantify and identify statistical 

trends and patterns relating to information on illicit transshipments.

Although the total universe of items being illicitly transshipped is 

unknown, intelligence and law enforcement information is collected by the 

intelligence community, attaches in overseas posts, and the domestic 

export control enforcement agencies.18

 

18Transshipment can occur anywhere in the world, but is more likely to occur in ports with 

high volumes of trade activity.

According to an OEE official, 
 

Page 23 GAO-12-246 Export Controls

there is a good exchange of actionable intelligence between the export 

control enforcement agencies and the intelligence community to seize 

shipments and take other actions against export control violators 

overseas. However, according to some enforcement and intelligence 

officials, intelligence leads are typically transmitted to either individual 

enforcement agencies or the enforcement community. Further, 

enforcement agencies maintain separate data related to their export 

control enforcement activities, which can include a variety of information 

such as shipment declarations listing countries of final destination and 

end-use or end-users and inspection and investigation results. Because 

the enforcement agencies have varying mission priorities in export 

controls, the availability and maintenance of data by the various agencies 

that can be used to identify illicit transshipments are not necessarily 

consistent or harmonized with each other.

Lack of Effectiveness Measures Unique to Complexity of Export Controls. 

The investigative enforcement agencies typically measure their 

effectiveness based on outcomes of enforcement activities, but these do 

not necessarily reflect the complexities involved with export control 

enforcement cases.19 Specifically, ICE has a primary performance 

measure of the percentage of closed investigations that result in a law 

enforcement consequence—arrests, indictments, convictions, and 

seizures as shown in table 6.20 OEE has similar enforcement metrics, and 

assesses impacts of their investigations by number of arrests, 

indictments, and convictions, as shown in table 7.21

 

19FBI is omitted as its measures of effectiveness include its intelligence function and these 

metrics are classified in nature.

The numbers of 

arrests, indictments, and convictions for export control violation cases 

20ICE now has a performance system that measures the percentage of high-impact or 

significant investigations that result in a transnational criminal disruption and/or 

dismantlement, and is applying this measure to its export control investigations. In 

addition, ICE is tracking systemic vulnerabilities nationally and within its respective field 

offices to prioritize efforts.

21OEE also measures effectiveness of headquarters’ and field office performance and 

accomplishment on investigative actions that result in a prevention or deterrence of export 

violations; percentage of open cases focusing on OEE’s export enforcement priorities; and 

administrative case results including the total dollar fines and other actions, such as denial 

orders.
 

Page 24 GAO-12-246 Export Controls

have generally increased from fiscal years 2006 to 2010 for ICE and 

OEE.22

Table 6: ICE Number of Arrests, Indictments and Convictions for Defense and DualUse Items, Fiscal Years 2006 through 2010

Fiscal year Arrests Indictments Convictions Total

FY 2006 151 153 116 420

FY 2007 197 200 153 550

FY 2008 213 210 150 573

FY 2009 432 285 219 936

FY 2010 505 329 221 1055

Total 1498 1177 859 3534

Source: Data provided by ICE.

Table 7: OEE Number of Arrests, Indictments, and Convictions for Dual-Use Items,

Fiscal Years 2006 through 2010

Fiscal year Arrests Indictments Convictions Total

FY 2006 11 17 36 64

FY 2007 26 17 16 59

FY 2008 20 57 40 117

FY 2009 37 69 33 139

FY 2010 22 62 31 115

Total 116 222 156 494

Source: Data provided by OEE.

While these numbers provide quantifiable performance assessments for 

the agencies’ workload related to export control violations, they do not 

necessarily reflect the complex nature of these cases or measure 

agencies progress in achieving their goals. GPRA, as amended, requires 

federal agencies to develop performance measures to assess progress in 

achieving their goals and to communicate their availability to Congress. 

Under this act, agencies are to develop measures that are objective, 

quantifiable, measurable, and to establish performance measures that 

define the level of progress to be achieved using these goals. However, 

 

22It is likely that the data provided by ICE in table 6 also include some of the same cases 

provided by OEE in table 7, thus may contain double-counting.
 

Page 25 GAO-12-246 Export Controls

current measures used by the enforcement agencies do not fully capture 

these elements. According to ICE documentation, export control 

investigations often take an average of 2 to 3 years to complete, and 

although significant to national security, these investigations result in 

enforcement statistics that are low in comparison with other law 

enforcement disciplines. The performance measures used by ICE and 

OEE during the period of this review emphasized quantifiable outcomes 

of enforcement actions and they are working towards developing 

measures that take into account the length of time and effort for 

investigators to gather intelligence that could potentially reveal a larger 

group of violators and to collect evidence from a wide variety of sources, 

including those located overseas. Although quantitative law enforcement 

metrics may be useful for the enforcement community in understanding 

the volume of activities that investigative agencies are processing, they 

may encourage agents to pursue less significant investigations in order to 

meet these performance standards. Measuring arrests does not indicate 

success at impeding criminal operations or whether the vulnerabilities 

present within export control enforcement system have been minimized. 

While developing measures of effectiveness that adequately capture the 

time and resources spent on such activities as intelligence gathering may 

be difficult and not easily quantifiable failure to consider broader 

measures may run counter to the overall goal of preventing or deterring 

illegal exports. According to ICE officials, its new performance measures, 

as well as its system to measure and track vulnerabilities nationally and in 

its field locations, will improve its ability to measure outcomes of 

enforcement actions.

In 2010, we recommended that ICE establish performance measures for 

its investigative resources in a way to fully assess progress and better 

identify and decrease vulnerabilities.23

 

23In September 2010, we reported on ICE’s allocation of investigative resources. 

However, the details were deemed sensitive, but unclassified, by the agency, and so are 

not described more fully in this report.

ICE officials told us that they have 

made progress toward this goal by implementing new performance 

measures for investigations, including those relating to export control 

enforcement. For example, ICE in Los Angeles is in the process of 

creating performance measures which include: one or more arrests, 

indictments, convictions and/or quantifiable disruption of an illicit 

procurement network in defense and dual-use items. It also plans to 

factor in special interest countries known to contain entities that post a 
 

Page 26 GAO-12-246 Export Controls

credible public safety or national security threat, and have determined ten 

country destination codes that will be counted in measuring performance 

of its export control investigations.

Our past work highlighted the need for export control reform. Over the 

past 10 years, we issued 22 reports with key findings and 

recommendations directed at State, Commerce, DOD, DHS, Justice, and 

Treasury, to improve the U.S. export control system, including 

enforcement activities.24 In April 2010, the President announced a reform 

initiative to strengthen and streamline U.S. export controls by creating a 

single control list, licensing agency, information technology system, and 

enforcement coordination agency, aimed at addressing weaknesses in 

the system. The President is in the process of implementing several 

reform efforts. To coordinate export control enforcement activities, given 

that agencies have overlapping and duplicative authorities, in November 

2010, the President announced the formation of a federal Export 

Enforcement Coordination Center to be established within DHS for 

administrative purposes. The corresponding Executive Order stated that 

to enhance enforcement efforts and minimize enforcement conflicts, 

executive departments and agencies must coordinate their efforts to 

detect, prevent, disrupt, investigate, and prosecute violations of U.S. 

export control laws, and must share intelligence and law enforcement 

information related to these efforts to the maximum extent possible 

consistent with national security and applicable law.25

• serve as the primary forum within the federal government for 

executive departments and agencies to coordinate and enhance their 

export control enforcement efforts and identify and resolve conflicts 

that have not been otherwise resolved in criminal and administrative 

investigations and actions involving violations of U.S. export control 

laws;

The Export 

Enforcement Coordination Center, which became operational in March 

2012, is to:

 

24GAO, Export Controls: Agency Actions and Proposed Reform Initiatives May Address 

Previously Identified Weaknesses, but Challenges Remain, GAO-11-135R (Washington, 

D.C.: Nov. 16, 2010).

25Exec. Order No.13,558, 75 Fed. Reg. 69,573 (Nov. 9, 2010).

Reform Initiatives Offer 

Opportunities to Address 

Some Export Control 

Enforcement Challenges 

but May Present Others
 

Page 27 GAO-12-246 Export Controls

• serve as a conduit between federal law enforcement agencies and the 

U.S. intelligence community for the exchange of information related to 

potential U.S. export control violations;

• serve as a primary point of contact between enforcement authorities 

and agencies engaged in export licensing;

• coordinate law enforcement public outreach activities related to U.S. 

export controls; and

• establish government-wide statistical tracking capabilities for U.S. 

criminal and administrative export control enforcement activities, to be 

conducted by DHS with information provided by and shared with all 

relevant departments and agencies participating in the center.

To date, a Director from ICE and Deputy Directors from the FBI and OEE 

have been appointed to lead the Export Enforcement Coordination Center 

and FBI, ICE, and OEE officials stated that they have agreed to a general 

interagency Concept of Operations, and are in the process of developing 

standard operating procedures. However, the center opened in March 

2012—a delay of 9 months due to problems with completing the building 

on time as well as some difficulty in reaching interagency agreement on 

the Concept of Operations.

While the center may improve agency coordination, it is unclear whether it 

will address some of the specific challenges in investigating export control 

cases and illicit transshipments, as identified in this report. In our recently 

issued overview of government performance issues, we noted that many 

federal program efforts generally require the effective collaboration of

more than one agency and that the GPRA Modernization Act of 2010 

calls for a more coordinated and crosscutting approach, using outcomeoriented goals to identify and reduce unnecessary duplication, overlap, 

and fragmentation.26

 

26GAO, Managing for Results: Opportunities for Congress to Address Government 

Performance Issues, 

GPRA requires each agency to submit a strategic 

plan at least every 4 years, to include a description of how the agency is 

working with other agencies to achieve its strategic goals as well as the 

strategies to be used and resources needed to achieve these goals. 

However, it is not clear to what extent the Export Enforcement

Coordination Center will coordinate efforts to increase efficiencies across 

enforcement agencies. In November 2010, we reported that co-location of 

the export control agencies in a single headquarters’-based facility may 

GAO-12-215R (Washington, D.C.: Dec. 9, 2011).
 

Page 28 GAO-12-246 Export Controls

help agencies share information, but further action may be needed to fully 

coordinate export control enforcement cases throughout the country.27

In addition, the Export Enforcement Coordination Center is to serve as a 

conduit between federal law enforcement agencies and the U.S. 

intelligence community. As noted in this report, no formal process or 

means exists between the investigative export control enforcement 

community and the intelligence community to quantify and identify 

statistical trends and patterns relating to information on illicit 

transshipments. While one of the goals of the center is to facilitate 

intelligence sharing, it has not yet been determined if this sharing of 

intelligence will go beyond specific investigative leads to obtain better 

information on trends and patterns relating to illicit transshipments of U.S. 

export-controlled items. However, an intelligence community liaison will 

be assigned to the center, which may allow for a better exchange of 

information between the enforcement and intelligence communities.

For example, agencies are unsure whether the center’s yet-to-bedeveloped standard operating procedures will encourage enforcement 

agencies to fully leverage resources, as local level offices are informally 

doing in some cities, or develop combined measures of effectiveness for 

export control enforcement.

Beyond the creation of the Export Enforcement Coordination Center, 

other reforms are underway which could impact enforcement. As many of 

these reforms are in their infancy and detailed plans have not been 

released, enforcement agency officials shared their views that the 

planned reform initiatives for export control enforcement present both 

opportunities and challenges. For example, we also reported in 

November 2010, that one of the reform initiatives involves major revisions 

to the Commerce and State lists of dual-use and defense items that are 

controlled for export from the United States. This initiative was intended to 

clarify regulations for companies seeking to export arms and dual-use 

items to more easily determine whether items are regulated by State or 

Commerce. According to a State Department official, the revision of the 

control lists and the goal of clearer adjudication of the items controlled 

could reduce the time required to review the license determinations—

allowing investigators to better focus their limited resources on those 

items critical to national security. However, as we previously reported, the 

 

27 GAO-11-135R. 
 

Page 29 GAO-12-246 Export Controls

review and possible removal of items controlled under the arms control 

list is taking longer than the agencies had originally anticipated. Some 

enforcement agency officials have raised concerns about changes to the 

control list, believing that as the U.S. Munitions List and Commerce 

Control List are revised, it could result in a decreased visibility of exports, 

requiring increased targeting by CBP to inspect items before they are 

exported overseas. Agency officials also stated that, as a result, 

increased enforcement activities may be needed overseas to validate the 

recipient of the item as fewer items would need U.S. government 

approval in advance of shipment.28 As staff located overseas have other 

agency and mission-related priorities, their availability for increased 

enforcement and compliance activities may be limited. Commerce 

officials stated that their Export Control Officers stationed abroad allows 

them to dedicate resources to providing compliance and investigative 

activities for items impacted by export control reform. In addition, staffing 

changes may require an approval process involving the agency, State 

Department, and the Chief of Mission.29 Also, some of the U.S. Attorneys 

we met with were concerned about the possible lack of a license with 

reform efforts, which they indicated is often relied upon in court to meet 

the high standards of evidence needed to prosecute export control cases. 

Other U.S. Attorneys stated that they were not as concerned, noting that 

cases involving non-licensable items have been successfully prosecuted. 

Further, as major changes to the State and Commerce control lists are 

made, investigators may need to increase outreach efforts to companies 

to provide education on U.S. export control laws. Specifically, in its fiscal 

year 2011 Performance and Accountability Report, Commerce stated that 

it will need to increase its outreach efforts to educate exporters about 

changes in export control regulations and provide the necessary guidance 

to ensure compliance with new regulations.30

 

28According to State, as long as the applicant meets the exemption criteria, the export is 

considered approved by the U.S. Government.

29National Security Decision Directive 38: Staffing at Diplomatic Missions and Their 

Overseas Constituent Posts and GAO, Overseas Staffing: Rightsizing Approaches Slowly 

Taking Hold, But More Action Needed to Coordinate and Carry Out Efforts, GAO-06-737 

(Washington, D.C., June 30, 2006).

30U.S. Department of Commerce: Performance and Accountability Report, Fiscal Year 

2011.
 

Page 30 GAO-12-246 Export Controls

Another potential challenge with planned reform efforts includes the 

potential for separating criminal and administration enforcement functions 

currently administered by OEE. While this effort would require legislation, 

it could result in the transfer of OEE enforcement personnel to ICE and 

the administrative enforcement functions to a single licensing agency. 

According to OEE officials, by separating the criminal and administrative 

functions which are often linked in export control cases, civil fines and 

penalties levied in the current system may not be as actively pursued. 

Senior enforcement agency officials acknowledged that this and other 

enforcement challenges may be resolved through the Export Enforcement 

Coordination Center.

Given the wide-ranging mission of most of the agencies involved in export 

control enforcement, it is essential that agencies track resources 

expended on export control inspections, investigations, and prosecutions 

to assess how these resources are contributing to fulfilling their missions 

and are focused on the highest priorities in export control enforcement. 

While agencies, such as DHS and Justice, have recognized the need to 

better track their resources, a more comprehensive approach, including 

enhanced measures of effectiveness, could help these and other 

enforcement agencies assess workload and efficiency in making resource 

allocations and in determining whether changes are warranted. The 

creation of the Export Enforcement Coordination Center presents such an 

opportunity for the entire export control enforcement community. The 

center has the potential to become more than a co-location of 

enforcement agencies, but can be a conduit to more effectively manage 

export control resources. As the center’s operation progresses, it has the 

opportunity to address ongoing challenges in export control enforcement, 

including reducing potential overlap in investigations, and help agencies 

to work as efficiently as possible, maximize available intelligence and 

agency investigative data, and measure the effectiveness of U.S. export 

control enforcement activities. Challenges presented by delays in license 

determinations can affect the inspection, investigation, and prosecution of 

export control cases but may be outside of the mission of the center since 

they primarily involve the licensing agencies. Having goals for processing 

license determinations can help establish transparency and accountability 

in the process. Given that the licensing agencies and the Exodus 

Command Center have not agreed to timeliness goals for responding to 

such requests, these agencies may benefit from collaborating to help 

improve the effectiveness of the process.

Conclusions 
 

Page 31 GAO-12-246 Export Controls

To better inform management and resource allocation decisions, 

effectively manage limited export control enforcement resources, and 

improve the license determination process, we are making the following 

four recommendations:

We recommend that the Secretary of Homeland Security and the Attorney 

General, as they implement efforts to track resources expended on export 

control enforcement activities, use such data to make resource allocation 

decisions.

We recommend that the Secretaries of Commerce and Homeland 

Security as they develop and implement qualitative measures of 

effectiveness, ensure that these assess progress towards their overall 

goal of preventing or deterring illegal exports.

We recommend that the Secretary of Homeland Security, in consultation 

with the departmental representatives of the Export Enforcement 

Coordination Center, including Commerce, Justice, State, and the 

Treasury

• leverage export control enforcement resources across agencies by 

building on existing agency efforts to track resources expended, as 

well as existing agency coordination at the local level;

• establish procedures to facilitate data sharing between the 

enforcement agencies and intelligence community to measure illicit 

transshipment activity; and

• develop qualitative and quantitative measures of effectiveness for the 

entire enforcement community to baseline and trend this data.

We recommend that the Secretaries of Commerce and State, in 

consultation with the Secretary of Homeland Security, the Attorney 

General, and other agencies as appropriate, establish agreed upon 

timeliness goals for responding to license determination requests 

considering agency resources, the level of determination, the complexity 

of the request, and other associated factors.

We provided a draft copy of this report to Commerce, DHS, DOD, Justice, 

State, and Treasury for their review and comment. Commerce, DHS, 

Justice, and State concurred with the report’s recommendations and, 

along with DOD, provided technical comments which we incorporated as 

appropriate. Treasury did not provide any comments on the report.

Recommendations for

Executive Action

Agency Comments

and Our Evaluation 
 

Page 32 GAO-12-246 Export Controls

As multiple agencies have responsibilities for export control enforcement, 

several of our recommendations call for these agencies to work together 

to effectively manage limited export control enforcement resources and to 

improve the license determination process. In their comments, Commerce 

and State agreed to work in consultation with DHS and Justice to 

establish timeliness goals for license determinations. In its comments, 

DHS stated its intent to work with the other agencies to improve the 

license determination process as well as take steps to deploy its 

resources in the most effective and efficient manner and provided target 

dates for completing these actions. In particular, DHS noted that ongoing 

tracking efforts by CBP and ICE will be used to improve their knowledge 

of resources expended on export control enforcement activities and that 

they will periodically review this information to determine the overall 

direction of the export control program. Additionally, DHS stated its intent 

to establish a working group with other agencies to develop performance 

measures related to export control enforcement to help estimate the 

effectiveness of all associated law enforcement activity. Written 

comments from Commerce, DHS, and State are reprinted in appendixes 

II, III, and IV, respectively.

We are sending copies of this report to interested congressional 

committees, as well as the Secretaries of Commerce, Defense, 

Homeland Security, State, and Treasury as well as the Attorney General. 

We will also make copies available to others upon request. In addition, 

the report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 
 

Page 33 GAO-12-246 Export Controls

If you or your staff have any questions on matters discussed in this report, 

please contact me at (202) 512-4841 or martinb@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. GAO staff that made key 

contributions to this report is listed in appendix V.

Belva M. Martin

Director

Acquisition and Sourcing Management
Appendix I: Scope and Methodology

Page 34 GAO-12-246 Export Controls

To determine how agencies allocate staff resources for export control 

enforcement activities, we interviewed cognizant officials and examined 

relevant documents such as agencies’ budgets, strategic plans, 

memorandum, and other documentation on resources. We interviewed 

officials about their resources at the headquarters of Commerce, DHS, 

Justice, State, and the Treasury. We also discussed with DOD officials 

their role in providing investigative support to agencies responsible for 

export control enforcement. We developed and used a set of structured 

questions to interview each agency’s resource planners to determine how 

they allocate resources, what information and factors they consider in 

resource allocation decisions, what their enforcement priorities are, 

whether they track resources expended on enforcement, if they had 

conducted an analysis of their resource need, and if they consider or 

leverage other agencies’ resources. We obtained applicable criteria 

including the Office of Management and Budget Circular A-11 and 

departmental guidance on resource allocation and tracking. We also 

reviewed previous GAO and inspector general reports regarding the 

Government Performance and Results Act (GPRA), as amended, and 

resource management for enforcement programs. To determine current 

resource levels, we obtained geographic locations of all domestic staff 

conducting export control enforcement, actual expenditures on export 

control enforcement activities, and information on staffing levels from 

each agency for fiscal years 2006 through 2010. We did not 

independently verify the accuracy of agency information on expenditures 

and staffing levels obtained, but we corroborated this information with 

cognizant agency officials. We considered agencies’ overall resources for 

the broad enforcement authorities and the resources allocated to export 

control enforcement specifically. Finally, we analyzed agencies’ budget 

requests, expenditures, and staff hours to determine agencies current 

resource commitment and how agencies have allocated resources to 

export control enforcement activities.

To determine challenges that agencies face in investigating illicit 

transshipments and the potential impact of export control reform initiatives 

on enforcement activities, we interviewed cognizant officials, examined 

and analyzed relevant export control documents and statutes, and 

conducted sites visits both domestically and overseas. We interviewed 

officials about their enforcement priorities at the headquarters of 

Commerce, DHS, Justice, and State. We also discussed with DOD

officials their role in providing license determination support to agencies 

responsible for export control enforcement. We developed and used a set 

of structured questions to interview enforcement agency officials in 

selected domestic and overseas locations and observed export 

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

Page 35 GAO-12-246 Export Controls

enforcement operations at those locations that had air, land, and 

seaports. We selected sites to visit based on various factors, including 

geographical areas where all enforcement agencies were represented 

with a large percentage of investigative caseload; areas with a mix of 

defense and high-tech companies represented; ports with a high volume 

of trade of U.S. commodities; a large presence of aerospace, electronics, 

and software industries, and based on headquarters officials’ 

recommendations on key areas of export control enforcement activities 

both domestically and abroad. On the basis of these factors, we visited 

Irvine, Long Beach, Los Angeles, Oakland, San Francisco, and San Jose, 

CA; Washington, D.C.; and Baltimore, MD domestically. Internationally, 

we interviewed United States Embassy and Consulate officials and host 

government authorities in Hong Kong, Singapore, and in Abu Dhabi and 

Dubai in the United Arab Emirates (UAE). We received briefings on the 

export control systems from the Hong Kong Government’s Trade and 

Industry Department, Customs and Excise Tax Department, from 

Singapore’s Ministry of Foreign Affairs, Singapore’s Immigration and 

Customs Authority; as well as toured ports at these locations. We also 

received a briefing from the Hong Kong Customs Airport Command on air 

cargo and air-to-air transshipment of strategic commodities and visited 

the DHL Hub at the Hong Kong International Airport. In the UAE, we 

visited the Government of Sharjah, Department of Seaports & Customs, 

Hamriyah Free Zone Authority and met with the Director and Security and 

Safety Manager to discuss the Hamriyah Free Zone. We reviewed the 

findings and recommendations of past GAO reports, documentation from 

enforcement agencies, and interviewed U.S. government officials from 

these agencies as well as their field offices. We also met with several 

agency representatives of the Export Control Reform Task Force and 

reviewed recent White House press releases on the export reform 

initiatives. Further, we examined Federal Register notices on changing 

regulations related to the export control reform initiative.

We conducted this performance audit from February 2011 through March 

2012, in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Commerce

Page 36 GAO-12-246 Export Controls

Appendix II: Comments from the Department 

of Commerce
Appendix III: Comments from the Department 

of Homeland Security

Page 37 GAO-12-246 Export Controls

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 38 GAO-12-246 Export Controls
Appendix III: Comments from the Department 

of Homeland Security

Page 39 GAO-12-246 Export Controls
Appendix III: Comments from the Department 

of Homeland Security

Page 40 GAO-12-246 Export Controls
Appendix IV: Comments from the Department 

of State

Page 41 GAO-12-246 Export Controls

Appendix IV: Comments from the 

Department of State 
Appendix IV: Comments from the Department 

of State

Page 42 GAO-12-246 Export Controls
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 43 GAO-12-246 Export Controls

Belva Martin, (202) 512-4841 or martinb@gao.gov. 

In addition to the contact names above, John Neumann, Assistant 

Director; Lisa Gardner; Desiree Cunningham; Jungjin Park; Marie Ahearn; 

Roxanna Sun; Robert Swierczek; and Hai Tran made key contributions to 

this report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(120966)
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