COUNTERNARCOTICS 

DOD Should Improve 

Coordination and 

Assessment of Its 

Activities 

Report to Congressional Committees

April 2024

GAO-24-106281

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-24-106281, a report to 

congressional committees

April 2024

COUNTERNARCOTICS

DOD Should Improve Coordination and Assessment 

of Its Activities

What GAO Found

The amount of funding available for Department of Defense (DOD)

counternarcotics and counter–transnational organized crime activities changed

from about $750 million in fiscal year (FY) 2018 to about $580 million in FY 2022. 

In FY 2022, DOD allocated most of the funding to support detection and 

monitoring activities and allocated the remainder to support intelligence activities 

and efforts, such as constructing training facilities, in partner nations. 

DOD’s six geographic combatant commands—DOD components responsible for 

efforts in designated geographic areas—coordinate on activities. However, three

reported varying understandings of their roles in an overlapping joint operation 

area, including confusion over the management of air and naval operations. 

Although DOD required the three commands to develop agreements defining

their responsibilities, the three commands have not fully documented their roles 

in the overlapping joint operation area. Without such agreements, confusion 

about the commands’ responsibilities in the area may continue, reducing DOD’s

ability to disrupt the transport of illicit drugs to the U.S.

Map Showing Overlap of Joint Operation Area

DOD has not assessed the agency-wide effectiveness of its counternarcotics and 

counter–transnational organized crime activities and does not have a plan for 

future assessments. DOD has defined its strategic objectives, strategies, and 

performance goals. But contrary to key practices, it has not identified measurable 

outcomes for each strategic objective. As a result, DOD cannot measure 

progress toward these objectives. Officials also said they intend to assess 

agency-wide progress but have not developed a plan to do so. Assessing 

agency-wide progress toward its strategic objectives would better position DOD 

to make decisions about priorities, resource allocations, and strategies for 

View GAO improvements. -24-106281. For more information, 

contact Chelsa Kenney at (202) 512-2964 or 

kenneyc@gao.gov.

Why GAO Did This Study

The U.S. government has identified 

illicit drugs, as well as the criminal 

organizations that produce and traffic

them, as significant threats to both 

the U.S. and partner nations. DOD is 

the lead department responsible for 

detecting and monitoring the aerial 

and maritime transport of illicit drugs

to the U.S. 

Senate report 117-130 accompanying 

the FY 2023 National Defense 

Authorization Act contains a provision 

for GAO to examine issues related to 

counternarcotics and counter–

transnational organized crime 

activities. This report examines (1) 

funding available for DOD’s activities

and funding allocation in FYs 2018

through 2022; (2) the extent to which 

DOD components coordinate 

activities; and (3) how DOD assessed 

the effectiveness of these activities, 

and the extent to which its future 

assessments align with key practices.

GAO reviewed DOD documents and 

data about its authorities, funding,

and activities, including coordination 

and performance management. GAO 

also interviewed DOD officials,

including officials at headquarters and 

combatant commands.

What GAO Recommends

GAO is making four 

recommendations, including that 

DOD develops a plan to assess 

agency-wide progress. DOD partially 

agreed with all recommendations.

GAO maintains that fully 

implementing them is necessary to 

improve DOD’s coordination and 

assessment of activities. 
Page i GAO-24-106281 Counternarcotics

Letter 1

Background 4

Funding for DOD’s CN/CTOC Activities Changed Over Time and 

Primarily Supported Detection and Monitoring Activities 10

Inconsistent Data and Unclear Roles Affect Coordination of 

CN/CTOC Activities 17

DOD’s Performance Measurement System Does Not Enable It to 

Fully Assess Effectiveness of CN/CTOC Activities 28

Conclusions 36

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 37

Appendix I Primary Authorities Available to DOD for Its CN/CTOC Activities 41

Appendix II Objectives, Scope, and Methodology 42

Appendix III Comments from the Department of Defense 46

Appendix IV GAO Contact and Staff Acknowledgments 50

Tables

Table 1: Strategic Objectives Identified in DOD’s 2019 Framework 

to Counter Drug Trafficking and Other Illicit Threat 

Networks 7

Table 2: DOD Funding Allocations by Components and Programs, 

Fiscal Years 2018–2022 11

Table 3: Strategic Objectives and Strategies Identified in DOD’s 

2019 Framework to Counter Drug Trafficking and Other 

Illicit Threat Networks 30

Table 4: Examples of Selected 2023 Performance Measurement 

Plan Performance Goals 31

Table 5: Primary Authorities Identified by DOD as Available for Its 

Counternarcotics (CN) and Counter—Transnational 

Organized Crime (CTOC) Activities 41

Contents
Page ii GAO-24-106281 Counternarcotics

Figures

Figure 1: Selected Federal Departments and Components with 

Counternarcotics (CN) Missions and Activities 5

Figure 2: DOD Geographic Combatant Commands’ Areas of 

Responsibility 8

Figure 3: Percentages of Funding DOD Allocated to Support 

Detection and Monitoring Activities, Intelligence Activities, 

and Activities Supporting Partner Nations, Fiscal Year 

2022 12

Figure 4: JIATF-S Ship That Supports Partner Nation Interceptors 14

Figure 5: Small-Scale Infrastructure Project DOD Funded in 

Thailand to Train Partner-Country Forces in 

Counternarcotics and Counter–Transnational Organized 

Crime Activities 16

Figure 6: Overlap of Joint Interagency Task Force—South’s Joint 

Operation Area with U.S. Southern Command’s, U.S. 

Northern Command’s, and U.S. Indo-Pacific Command’s 

Areas of Responsibility 25
Page iii GAO-24-106281 Counternarcotics

Abbreviations

AFRICOM U.S. Africa Command

C2IE Command and Control of the Information 

Environment

CENTCOM U.S. Central Command

CN/CTOC counternarcotics/counter–transnational organized 

crime

DASD CN&SP Deputy Assistant Secretary of Defense for 

Counternarcotics and Stabilization Policy

DHS Department of Homeland Security

DOD Department of Defense

DOJ Department of Justice 

INDOPACOM U.S. Indo-Pacific Command

JIATF-S Joint Interagency Task Force–South

JIATF-W Joint Interagency Task Force–West

JTF-N Joint Task Force–North

NORTHCOM U.S. Northern Command

ONDCP Office of National Drug Control Policy

SOUTHCOM U.S. Southern Command

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Page 1 GAO-24-106281 Counternarcotics

441 G St. N.W.

Washington, DC 20548

April 16, 2024

Congressional Committees

Provisional data from the Centers for Disease Control and Prevention 

show nearly 110,000 drug overdose deaths during the 12-month period 

ending in May 2023—the highest number of deaths ever reported in a 12-

month period.1 Synthetic opioids, such as fentanyl, are currently involved 

in the majority of these deaths.2 Moreover, the U.S. government has 

identified illicit drugs—as well as the transnational criminal organizations 

that produce and traffic most illicit drugs consumed in this country—as 

significant threats to both the United States and partner nations.3 Among 

the federal agencies involved in efforts to reduce the availability of illicit 

drugs, the Department of Defense (DOD) is the single lead agency 

responsible for detecting and monitoring their aerial and maritime 

transport to the United States.

The Senate Report accompanying the National Defense Authorization Act 

for Fiscal Year 2023 includes a provision for us to examine issues related 

to DOD’s counternarcotics (CN) and counter–transnational organized 

crime (CTOC) activities.4 This report examines (1) funding available for 

DOD’s CN/CTOC activities, as well as DOD’s allocation of funding in 

fiscal years 2018 through 2022; (2) the extent to which DOD components 

coordinate their CN/CTOC activities; and (3) how DOD has assessed the 

effectiveness of its CN/CTOC activities, as well as the extent to which its 

1According to the Centers for Disease Control and Prevention, reported provisional counts 

for 12-month ending periods are the number of deaths received and processed for the 12-

month period ending in the month indicated. Drug overdose deaths are often initially 

reported with no cause of death (pending investigation) because they require lengthy 

investigation, including toxicology testing. Reported provisional counts may not include all 

deaths that occurred during a given time period. Therefore, they should not be considered 

comparable with final data and are subject to change.

2There were more deaths in 2023 involving synthetic opioids than from any other type of 

opioid, according to the Centers for Disease Control and Prevention. Synthetic opioids are 

highly potent drugs manufactured to mimic naturally occurring opioids such as morphine. 

3In this report, as in certain U.S. government documents we reviewed, drugs and 

narcotics are used interchangeably to refer to opioids, such as heroin and fentanyl, or to 

stimulants, such as cocaine.

4S. Rept. 117-130 at 235-236 accompanying S. 4543, the James M. Inhofe National 

Defense Authorization Act for Fiscal Year 2023 (enacted into law as Pub. L. No. 117-263, 

136 Stat. 2395 (2022)). 

Letter
Page 2 GAO-24-106281 Counternarcotics

plans for future assessments align with key practices.5 The act also 

includes a provision for us to describe the primary legal authorities 

available to DOD for its CN/CTOC activities; see appendix I for a list of 

these authorities.

To obtain information about these issues, we interviewed officials from 

DOD components and the Office of National Drug Control Policy 

(ONDCP) regarding DOD authorities, funding, coordination, and 

performance measurement. We interviewed DOD officials from 17 DOD 

components, including six geographic combatant commands. We 

selected these components on the basis of DOD’s CN/CTOC priorities.

To determine the amount of funding for DOD’s CN/CTOC activities, we 

reviewed relevant appropriations acts and DOD documents. We reviewed 

the most recent appropriations acts for fiscal years 2018 through 2022 to 

identify the amount of funding Congress directed for the CN fund.6 In 

addition, we reviewed the Drug Interdiction and Counter-Drug Activities 

President’s Budget for fiscal years 2020 through 2024 to identify the 

amount of funding DOD allocated to its components. To assess the 

reliability of the allocations data, we conducted several validity checks 

and interviewed DOD officials. We found the data related to the amounts 

DOD allocated to its components to be sufficiently reliable for the 

purposes of our reporting objective. In addition, we identified legal 

authorities available to DOD for CN/CTOC activities and confirmed with 

DOD officials the primary authorities they use. For a full list of these 

authorities, see appendix I.

To examine the extent to which DOD components coordinate their 

CN/CTOC activities, we interviewed DOD officials about how, and with 

which entities, they coordinate and the successes and challenges they 

5In this report, DOD components refers to the combatant commands, military 

departments, and defense intelligence agencies that implement counternarcotics 

activities. Combatant commands refers to the functional and geographic combatant 

commands. Geographic combatant commands refers to the geographic combatant 

commands and their respective task forces.

6Congress appropriates these funds through DOD’s Drug Interdiction and Counter-Drug 

Activities appropriation, which includes directed spending amounts for four budget 

activities. Our review focuses on the Counter-Narcotics Support budget activity, which we 

refer to as the counternarcotics (CN) fund. The additional three budget activities include 

the (1) Drug Demand Reduction Program, (2) National Guard Counter-Drug Program, and 

(3) National Guard Counter-Drug Schools Program. For a review of the National Guard 

Counterdrug and Schools Programs, see GAO, Drug Control: DOD Should Improve Its 

Oversight of the National Guard Counterdrug Program, GAO-19-27 (Washington, D.C.: 

Jan. 17, 2019).
Page 3 GAO-24-106281 Counternarcotics

have experienced. Furthermore, we interviewed DOD officials to discuss 

the data systems they use to facilitate coordination. We determined that 

an internal control principle related to using quality information for 

effective monitoring was significant to this objective.7 We also reviewed 

documents DOD components provided to us, such as memorandums of 

agreement between combatant commands and between combatant 

commands and law enforcement agencies. We evaluated DOD 

components’ coordination against selected leading practices we have 

previously identified, such as enhancing interagency collaboration and 

coordination,8 and against a DOD requirement to develop agreements 

between combatant commands.9

To examine how DOD has assessed the effectiveness of its activities, we 

reviewed information about performance metrics DOD has used in the 

past and its plans to assess its activities under a 2023 Performance 

Measurement Plan in the future. We evaluated DOD’s strategic objectives 

and performance goals against selected key practices we have previously 

identified to help agencies assess the results of their efforts.10 See 

appendix II for a full description of our scope and methodology.

We conducted this performance audit from October 2022 to April 2024 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.

7GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: Sept. 10, 2014).

8GAO, Government Performance Management: Leading Practices to Enhance 

Interagency Collaboration and Address Crosscutting Challenges, GAO-23-105520

(Washington, D.C.: May 24, 2023).

9Department of Defense, Joint Interagency Task Force (JIATF) Area Responsibilities

Memorandum (Washington, D.C.: Aug. 21, 2003). 

10GAO, Evidence-Based Policymaking: Practices to Help Manage and Assess the Results 

of Federal Efforts, GAO-23-105460 (Washington, D.C.: July 2023).
Page 4 GAO-24-106281 Counternarcotics

Multiple federal departments and components have CN missions and 

implement activities to combat the flow of illicit drugs into the United 

States (see fig. 1).

Background

Federal Agencies’ Roles in 

CN Missions and Activities
Page 5 GAO-24-106281 Counternarcotics

Figure 1: Selected Federal Departments and Components with Counternarcotics (CN) Missions and Activities

a

ONDCP is a component of the Executive Office of the President. In addition to the entities shown, 

ONDCP also coordinates with the Departments of Health and Human Services, State, and Treasury 

on CN activities. For example, Treasury’s Office of Foreign Assets Control implements economic and 

trade sanctions programs against targeted foreign countries and regimes; terrorists; international 
Page 6 GAO-24-106281 Counternarcotics

narcotics traffickers; proliferators of weapons of mass destruction; and other entities that threaten 

national security, foreign policy, or the U.S. economy.

Since 1989, the Drug Interdiction and Counter-Drug Activities 

appropriation has been the principal means used to finance DOD’s CN 

activities, according to DOD documents.11 From this appropriation, DOD 

uses the CN fund to implement CN activities as well as CTOC activities 

related to narcotics trafficking. The Office of the Deputy Assistant 

Secretary of Defense for Counternarcotics and Stabilization Policy (DASD 

CN&SP) allocates the funding among DOD’s components.

In 2019, DOD published the Framework to Counter Drug Trafficking and 

Other Illicit Threat Networks (2019 Framework) to provide guidance to 

DOD components for implementing its policies, plans, and programs to 

counter illicit drug trafficking and illicit networks. According to the 2019 

Framework, DOD’s vision is to help disrupt and degrade drug trafficking 

and other illicit threat networks to a level that allows law enforcement 

agencies, local and regional security forces, or other elements of national 

power to manage the threat. The 2019 Framework identifies three 

strategic objectives to help achieve this vision (see table 1).12

11Congress appropriates funds for these activities through DOD’s Drug Interdiction and 

Counter-Drug Activities appropriation, which includes directed spending amounts for four 

budget activities. Our review focuses on the Counter-Narcotics Support budget activity, 

which we refer to as the counternarcotics (CN) fund. The additional three budget activities 

include the (1) Drug Demand Reduction Program, (2) National Guard Counter-Drug 

Program, and (3) National Guard Counter-Drug Schools Program. For a review of the 

National Guard Counterdrug and Schools Programs, see GAO, Drug Control: DOD 

Should Improve Its Oversight of the National Guard Counterdrug Program, GAO-19-27

(Washington, D.C.: Jan. 17, 2019). 

12DOD’s 2019 Framework refers to objectives, which we identify as strategic objectives for 

the purposes of this report. DASD CN&SP officials confirmed that the objectives in the 

2019 Framework are DASD CN&SP’s strategic objectives.

DOD’s Strategic Approach 

for CN/CTOC Activities
Page 7 GAO-24-106281 Counternarcotics

Table 1: Strategic Objectives Identified in DOD’s 2019 Framework to Counter Drug Trafficking and Other Illicit Threat 

Networks

Strategic objective Definition

Disrupt and degrade threat networks Illicit threat networks lose the capacity to conduct sustained 

operations or activities.

Reduce drug trafficking and criminal activity Fewer illicit drugs enter U.S. markets, and other forms of 

transnational criminal activity decline.

Strengthen partners U.S. and international partners strengthen their combined efforts 

to combat drug trafficking and other illicit threat networks.

Source: Department of Defense (DOD). | GAO-24-106281

The 2019 Framework also lists eight priorities for DOD’s CN/CTOC 

activities. The following are the top three priorities:

1. Disrupt and degrade the flow of heroin, fentanyl, and amphetaminetype stimulants, chiefly from Mexico, focusing on the cartels that traffic 

them.

2. Support interagency partners in stopping the flow of fentanyl from 

China and elsewhere into the United States, Mexico, and Central 

America, and degrade the unlawful diversion and smuggling of 

precursor chemicals from Asia to the Western Hemisphere.

3. Build Colombia and Peru’s capacities to detect and interdict illicit 

trafficking, including drugs, precursor chemicals, and profits.

Generally, DOD implements CN/CTOC activities through its combatant 

commands, military departments, and defense intelligence agencies. 

According to DOD, these components provide assets—for example, 

aircraft, patrol ships, and military personnel—as well as intelligence 

analysis and other assistance to support U.S. law enforcement agencies 

and foreign security forces in countering narcotics trafficking.

DOD guidance outlines these components’ responsibilities.13 For 

example, the guidance states that the Chairman of the Joint Chiefs of 

Staff is responsible for developing CN/CTOC doctrine and for 

implementing, in consultation with combatant commands and DASD 

CN&SP, guidance that establishes responsibilities and procedures to 

coordinate CN/CTOC activities.

13Department of Defense, Department of Defense Instruction 3000.14: DoD Counterdrug 

and Counter-Transnational Organized Crime Policy (Washington, D.C.: Aug. 28, 2020). 

DOD Components 

Involved in CN/CTOC 

Activities
Page 8 GAO-24-106281 Counternarcotics

According to the guidance, DOD’s combatant commands plan and 

execute CN/CTOC activities and oversee funding allocated by DASD 

CN&SP. U.S. Special Operations Command, a functional combatant 

command, reviews, approves, and conducts CN/CTOC activities— 

specifically, counterthreat finance activities—to support geographic

combatant commands and federal agencies. The guidance states that 

another functional combatant command, U.S. Transportation Command, 

reviews and approves the use of DOD equipment to move personnel and 

cargo for DOD and other federal agencies.

DOD’s six geographic combatant commands plan and execute CN/CTOC 

activities, such as small-scale infrastructure projects, on behalf of DOD 

within their respective areas of responsibility (see fig. 2).

Figure 2: DOD Geographic Combatant Commands’ Areas of Responsibility 
Page 9 GAO-24-106281 Counternarcotics

Three of DOD’s geographic combatant commands also have task forces. 

In 1989, DOD created several task forces, which aimed to connect the 

military’s CN/CTOC efforts with those of civilian, federal law enforcement 

agencies. These task forces have since evolved and eventually 

developed into the following:

• Joint Interagency Task Force–South (JIATF-S), under the U.S. 

Southern Command (SOUTHCOM);

• Joint Interagency Task Force–West (JIATF-W), under the U.S. IndoPacific Command (INDOPACOM); and

• Joint Task Force–North (JTF-N), under the U.S. Northern Command 

(NORTHCOM).

JIATF-S and JIATF-W comprise representatives from several federal 

agencies and support primarily maritime and aerial activities conducted 

by both military and law enforcement entities. In contrast, JTF-N consists 

solely of DOD personnel and does not generally operate in the maritime 

domain. JIATF-S and JIATF-W include representatives from DOD, the 

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

(DOJ).

Coast Guard admirals currently serve as the Directors of both JIATF-S 

and JIATF-W. Task force officials stated that the Coast Guard, which is 

both a military and a law enforcement agency, encourages participation 

from both DOD and DHS. Previously, DOD service components led 

JIATF-S, but DOD is statutorily precluded from taking law enforcement 

actions, such as interdiction, in counternarcotics efforts.14 The deputy and 

vice leadership positions at the JIATFs are held by officers and civilians 

from DOD, DHS, and DOJ components, which allows the task forces to 

leverage various experiences and authorities across the components, 

according to task force officials.

14See 18 U.S.C. § 1385 and 10 U.S.C. § 275. 
Page 10 GAO-24-106281 Counternarcotics

The amount directed to the CN fund changed from about $750 million in 

fiscal year 2018 to about $580 million in fiscal year 2022. According to 

DOD officials, the funding levels changed in part because of changes in 

the authorized activities. For example, the National Defense Authorization 

Act for Fiscal Year 2017 shifted DOD’s authority to train and equip partner 

nations from the CN fund activities overseen by DASD CN&SP to the 

security cooperation program overseen by the Defense Security 

Cooperation Agency.15 In addition, Congress stopped providing additional 

funding designated for Overseas Contingency Operations/Global War on 

Terrorism to the Drug Interdiction and Counter-Drug Activities 

appropriation beginning in fiscal year 2021.

In fiscal years 2018 through 2022, DASD CN&SP allocated over $3 billion 

for CN/CTOC activities from the CN fund. DASD CN&SP allocated half of 

this funding—around $1.5 billion—to SOUTHCOM. According to DOD 

data, the majority of SOUTHCOM’s allocation in fiscal years 2018 through 

2022 supported JIATF-S’s operations and equipment, such as a radar 

system, aircrafts, and a ship, that JIATF-S officials use to implement 

narcotics detection and monitoring efforts. For example, in fiscal year 

2022, SOUTHCOM allocated $68 million for a multidomain radar system, 

15Section 1241 of Pub. L. No. 114-328, the National Defense Authorization Act for Fiscal 

Year 2017, established a consolidated building partner capacity authority codified at 10 

U.S.C. § 333 that authorizes train and equip programs, including those that focus on 

counter–illicit drug trafficking and counter-TOC operations. That provision included a 

requirement that these programs be funded from DOD’s Operation and Maintenance, 

Defense-Wide account and be made available to the Defense Security Cooperation 

Agency. See 10 U.S.C. § 333(g). We did not include these funds in our review. For recent 

reviews of the building partner capacity programs, see GAO, Building Partner Capacity: 

DOD Should Assess Delivery Delays in Train and Equip Projects and Improve 

Evaluations, GAO-23-106275 (Washington, D.C.: Aug. 29, 2023); and Building Partner 

Capacity: DOD and State Should Strengthen Planning for Train and Equip Projects, 

GAO-23-105842 (Washington, D.C.: Aug. 29, 2023).

Funding for DOD’s 

CN/CTOC Activities 

Changed Over Time 

and Primarily 

Supported Detection 

and Monitoring 

Activities

CN/CTOC Funding and 

Activities Changed Over 

Time

DOD Allocated Half of Its 

Funding to U.S. Southern 

Command
Page 11 GAO-24-106281 Counternarcotics

$56 million for a maritime patrol aircraft, and $23 million for a ship to 

assist partner nations’ interdiction efforts. The data also show that 

SOUTHCOM was the only component that received allocations from the 

CN fund for such equipment. SOUTHCOM officials explained that they 

have received support for this equipment since JIATF-S was established 

in 1989 as part of the anti-drug enforcement policy to disrupt cocaine and 

marijuana trafficking in the Caribbean.

Table 2 shows DOD allocations for components’ and programs’ 

CN/CTOC activities in fiscal years 2018 through 2022.

Table 2: DOD Funding Allocations by Components and Programs, Fiscal Years 2018–2022

Allocations in millions of dollars

DOD component or program

Allocated amounts Percentage of all

2018 2019 2020 2021 2022 Total allocations

U.S. Southern Command 289 307 323 328 305 1,552 50

Enterprise-wide intelligence programs 60 55 84 88 110 397 13

U.S. Central Command 160 57 73 31 20 341 11

U.S. Northern Command 35 52 69 46 86 288 9

Othera 135 14 13 8 10 180 6

National Guardb 20 30 19 19 19 107 4

U.S. Indo-Pacific Command 21 27 22 20 15 105 3

U.S. Africa Command 8 15 13 8 4 48 2

U.S. Special Operations Command 8 8 9 9 7 41 1

U.S. European Command 5 6 9 10 4 34 1

U.S. Transportation Command 3 .5 .3 0 0 4 0

Total 744 572 634 567 580 3,097 100

Source: GAO analysis of Department of Defense (DOD) data. | GAO-24-106281

Notes: The data shown reflect DOD allocations of the funding Congress directed for DOD’s CounterNarcotics Support budget activity, which we refer to as the counternarcotics (CN) fund. We rounded 

the data to calculate the totals shown. Congress appropriates these funds through DOD’s Drug 

Interdiction and Counter-Drug Activities appropriation. Amounts in the appropriation designated for 

Overseas Contingency Operations/Global War on Terrorism were not directed to a specific budget 

activity but were allocated by DOD to the CN fund. 

The data shown do not include additional funding U.S. Northern Command received in fiscal years 

2019 and 2020. According to DOD documentation, U.S. Northern Command received $2.5 billion in 

fiscal year 2019 and $3.8 billion in fiscal year 2020 from DOD transfers to the CN fund, pursuant to 

authority set forth at 10 U.S.C. § 284(b)(7), for barrier construction to block narcotics smuggling 

corridors along the U.S. southern border. In 2019, we released a legal opinion concluding that the use 

of these amounts for the border fence construction was permissible under various statutory 

provisions. See GAO, Department of Defense—Availability of Appropriations for Border Fence 

Construction, B-330862 (Washington, D.C.: Sept. 5, 2019). 

a

Other includes funding allocated to the military services, such as the Department of the Navy, and to 

the Office of the Secretary of Defense. 
Page 12 GAO-24-106281 Counternarcotics

b

DOD provided support from the CN fund to the National Guard for its general operations in 

headquarters and for its language translation, transcription, and analysis center. Through DOD’s Drug 

Interdiction and Counter-Drug Activities appropriation, Congress directs additional funding to the 

National Guard that is not included in this table. This includes funding for the National Guard CounterDrug Program and Counter-Drug Schools Program. 

DOD implements various CN/CTOC activities focused on detecting and 

monitoring illicit drugs; collecting, processing, analyzing, and 

disseminating intelligence; and supporting partner nations.16 In fiscal year 

2022, DOD allocated the largest percentage of CN funds to support 

detection and monitoring activities, such as programs to detect and 

monitor the aerial and maritime transit of illegal narcotics toward the 

United States. DOD also allocated funding to support intelligence 

activities as well as activities, such as small-scale construction, in partner 

nations. Figure 3 shows the percentages of funding that DOD allocated 

for activities in these three categories in fiscal year 2022.

Figure 3: Percentages of Funding DOD Allocated to Support Detection and 

Monitoring Activities, Intelligence Activities, and Activities Supporting Partner 

Nations, Fiscal Year 2022

Notes: The data shown reflect DOD allocations of the funding Congress appropriated for DOD’s 

Counter-Narcotics Support budget activity, which we refer to as the counternarcotics (CN) fund. 

Through DOD’s Drug Interdiction and Counter-Drug Activities appropriation, Congress directs 

spending for three other budget activities that are not included in our review: (1) the Drug Demand 

Reduction Program, (2) the National Guard Counter-Drug Program, and (3) the National Guard 

Counter-Drug Schools Program. 

16See appendix I for a list of the primary authorities DOD reported using to implement 

CN/CTOC activities.

Most DOD Funding 

Supported Detection and 

Monitoring Activities
Page 13 GAO-24-106281 Counternarcotics

DOD’s detection and monitoring activities focus on the aerial and maritime transit of illegal narcotics 

toward the United States. DOD’s intelligence activities include technology and programs used to 

collect, process, analyze, and disseminate strategic, operational, and tactical intelligence and 

information to help support interdiction operations conducted by U.S. and partner nation law 

enforcement agencies. DOD’s activities supporting partner nations include small-scale infrastructure 

projects that DOD works with U.S. law enforcement agencies to build in those nations.

Detection and monitoring activities. DOD conducts detection and 

monitoring activities to support interdiction operations of U.S. and partner 

nation law enforcement agencies.17 Funding supports logistics and base 

operations for maritime patrol, reconnaissance, and aircraft as well as the 

maintenance of DOD-owned maritime patrol aircraft and multimission 

support vessels.

According to officials, JIATF-S implements most of these activities to 

assist U.S. and partner nations’ law enforcement agencies in interdicting 

cocaine trafficking. For example, JIATF-S maintains a ship that embarks 

and refuels partner nations’ interceptor vessels (see fig. 4). The ship 

helps extend the operational reach and endurance of the vessels and 

allows them to complete interdictions in deeper waters. The ship also 

allows partner nation interceptor crews to rest, obtain food and water, and 

complete mission planning.

1710 U.S.C. § 124 designates DOD “as the single lead agency of the federal government 

for the detection and monitoring of aerial and maritime transit of illegal drugs into the 

United States.”
Page 14 GAO-24-106281 Counternarcotics

Figure 4: JIATF-S Ship That Supports Partner Nation Interceptors

Intelligence activities. DOD’s intelligence activities include personnel, 

technology, and programs used to collect, process, analyze, and 

disseminate strategic, operational, and tactical intelligence and 

information required for combatant command and interagency CN/CTOC 

operations and activities. DOD shares the technology and intelligence 
Page 15 GAO-24-106281 Counternarcotics

with U.S. and partner nation law enforcement agencies to assist their 

investigation and interdiction operations.18

Some DOD components have established groups to facilitate the sharing 

of intelligence they gather. For example, U.S. Central Command 

(CENTCOM) established the Regional Narcotics Interagency Fusion Cell, 

comprising DOD and law enforcement agency officials who analyze and 

share military and law enforcement information to support CN/CTOC 

activities in Southwest Asia, the Middle East, and East Africa. This group 

partners with other DOD components, such as U.S. Africa Command 

(AFRICOM), and with partner nations to coordinate and collaborate on 

intelligence information.

DOD components also implement counterthreat finance activities to deny, 

disrupt, destroy, or defeat the generation, storage, movement, and use of 

assets to fund activities supporting an adversary’s ability to negatively 

affect U.S. interests. According to DOD officials, they coordinate efforts 

with U.S. law enforcement agencies to assist them in reducing the supply 

of illicit substances through targeted law enforcement actions. They also 

help U.S. law enforcement agencies commercially disrupt criminal 

organizations by undermining the illicit finance networks that make drug 

trafficking both possible and profitable.

Activities in partner nations. DOD supports CN/CTOC activities that the 

geographic combatant commands implement in partner nations, such as 

activities to disrupt the cultivation and transportation of illicit drugs. 

According to officials, they also support small-scale infrastructure projects 

that they work with U.S. law enforcement to build in partner nations.19

Officials from JIATF-W said that in fiscal year 2018, they worked with the 

Drug Enforcement Administration and the Department of State’s Bureau 

of International Narcotics and Law Enforcement to implement a small18According to officials, DOD implements these activities under 10 U.S.C. § 284, which 

authorizes it to support CN/CTOC activities of any other department or agency of the 

federal government or of any state, local, tribal, or foreign law enforcement agency. 

Specifically, 10 U.S.C. § 284(b)(9) authorizes DOD to provide linguistic and intelligence 

analysis services.

19According to officials, DOD implements these activities under 10 U.S.C. § 284(c), which 

authorizes DOD to support foreign law enforcement agencies, including to establish smallscale construction to facilitate CN/CTOC activities of a foreign law enforcement agency 

outside of the United States. 
Page 16 GAO-24-106281 Counternarcotics

scale construction project in Thailand to train partner nations in CN/CTOC 

activities (see fig. 5).

Figure 5: Small-Scale Infrastructure Project DOD Funded in Thailand to Train Partner-Country Forces in Counternarcotics and 

Counter–Transnational Organized Crime Activities

Note: The photos show an indoor mock village used to train multiple partner-country forces in 

Thailand. 
Page 17 GAO-24-106281 Counternarcotics

DOD components coordinate their CN/CTOC activities with each other 

and with non-DOD entities, such as U.S. law enforcement agencies, as 

well as with foreign partners, according to documents and DOD officials 

we interviewed.

Coordination among combatant commands. To coordinate their 

CN/CTOC activities, combatant commands share intelligence with one 

another, attend working groups and conferences, and colocate 

representatives in shared spaces, according to officials. Geographic 

combatant command officials told us that they share information with 

other geographic combatant commands when it is relevant to their areas 

of responsibility. For example, officials said that JIATF-W shares 

intelligence on precursor chemicals with NORTHCOM and JIATF-S, 

because precursor chemicals often pass from Asia to North America.

According to DOD documentation, combatant commands also participate 

in coordination meetings, including working groups focused on cartels; on 

heroin and fentanyl; and on integrating detection, monitoring, and law 

enforcement with interdiction efforts. The combatant commands also 

have participated in each other’s yearly program management reviews, 

where they hear about CN/CTOC activities that other combatant 

commands have implemented.20 In addition, JIATF-S, JIATF-W, and JTFN maintain representatives in the Information Analysis Center, which 

focuses on interdiction and intelligence activities, at the U.S. embassy in

Mexico City.21 Further, officials of U.S. European Command and 

AFRICOM, which are headquartered in the same city in Germany, 

participate in each other’s meetings and share information.

20Program management reviews are an annual forum for combatant commands to discuss 

prior performance and upcoming programs, according to combatant command officials. 

DASD CN&SP also uses program management reviews to conduct performance reviews 

and plans to use them to discuss the commands’ performance metrics.

21The Information Analysis Center, managed by JTF-N, works with JTF-N’s mission 

partners in Mexico to counter transnational criminal organizations, assisting with narcotics 

interdictions.

Inconsistent Data and 

Unclear Roles Affect 

Coordination of 

CN/CTOC Activities

Combatant Commands 

Use Various Means to 

Coordinate Their Activities 

with Each Other and nonDOD Entities

Prevalence of Synthetic Drug 

Trafficking Varies in Combatant 

Commands’ Areas of Responsibility 

Although DOD components recognize 

addressing the trafficking of synthetic 

drugs as a high priority, the prevalence of 

such trafficking in their areas of 

responsibility varies. According to DOD 

officials, synthetic drugs, especially 

fentanyl and methamphetamine, are 

prevalent in U.S. Northern Command’s 

and U.S. Indo-Pacific Command’s areas of 

responsibility, because transnational 

criminal organizations purchase precursor 

chemicals from China and manufacture 

fentanyl in Mexico for its distribution. 

Officials of U.S. Africa Command, U.S. 

European Command, and U.S. Central 

Command (CENTCOM) said that fentanyl 

is not common in their areas of 

responsibility but methamphetamines are 

a concern. CENTCOM officials stated that 

Captagon is also a major concern for 

them. (Captagon is a trademark name for 

fenethylline, a synthetic amphetaminetype stimulant.) 

Source: Interviews with Department of Defense (DOD) 

officials. | GAO-24-106281
Page 18 GAO-24-106281 Counternarcotics

Combatant commands also use a variety of data systems to 

communicate with each other and with outside entities. For example, 

DASD CN&SP developed and initiated a CN/CTOC module in DOD’s 

knowledge management database, known as Command and Control of 

the Information Environment (C2IE). DASD CN&SP developed the 

CN/CTOC module to serve as a program of record for combatant 

commands’ activities and to facilitate coordination.

Coordination with U.S. law enforcement agencies. Combatant 

commands provide intelligence analysis services to U.S. law enforcement 

entities to support their counternarcotics operations, according to 

officials.22 For example, JIATF-W officials described flagging suspicious 

shipments from Asia to Mexico for U.S. Customs and Border Protection 

officials and Drug Enforcement Administration officials to review when the 

shipments arrive at port. Officials of both U.S. European Command and 

JTF-N stated that they provide support to law enforcement agencies that 

request information, analyzing intelligence to help the agencies build 

cases and target criminal networks. NORTHCOM officials stated that they 

focus on supporting law enforcement agencies’ CTOC activities.

Combatant command officials also said they coordinate with U.S. law 

enforcement by hosting liaison officers from law enforcement agencies.23

For example, liaison officers from DOJ and DHS are colocated in 

AFRICOM headquarters, according to memorandums of understanding 

between AFRICOM and these agencies. CENTCOM documentation 

shows that CENTCOM and AFRICOM officials participate in the DODfunded Regional Narcotics Interagency Fusion Cell, which hosts 

representatives from the Drug Enforcement Administration and Homeland 

Security Investigations.

JIATF-S supports law enforcement by performing detection and 

monitoring activities, tracking alerts of potential narcotics shipments, and 

targeting the shipments for law enforcement interdiction. JIATF-S 

documentation shows that it also maintains tactical analysis teams in 15 

22A Joint Chiefs of Staff 2019 Joint Publication establishes joint doctrine to govern the 

activities of DOD components when conducting counterdrug operations. The publication 

states that DOD supports federal, state, and local law enforcement agencies in their 

efforts to disrupt illicit drug trafficking. See Joint Chiefs of Staff, Counterdrug Operations, 

JP 3-07.4 (Washington, D.C.: 2019).

23Combatant commands work with DHS’s Homeland Security Investigations and DOJ’s 

Drug Enforcement Administration and Federal Bureau of Investigation. Some combatant 

commands also work with DHS’s U.S. Customs and Border Protection.
Page 19 GAO-24-106281 Counternarcotics

countries to enable information sharing with U.S. law enforcement 

officials embedded in those countries.

Coordination with foreign partners. Officials of combatant commands 

coordinate with foreign partners regarding intelligence and interdiction, 

according to officials and documents. For example:

• JIATF-S coordinates operations with foreign partners, some of which 

provide physical assets for interdiction. Also, JIATF-S documentation 

states that JIATF-S contracts a ship that offers docking capabilities for 

smaller interceptor vessels manned by foreign partners, which 

increases the vessels’ operational range.

• NORTHCOM and JTF-N officials stated that they coordinate with 

Mexican law enforcement agencies, such as by providing timesensitive information, to help them counter transnational criminal 

organizations and interdict illicit drugs.

• SOUTHCOM officials said they are working with Colombian 

government officials to help the government develop counterthreat 

finance capabilities.

• CENTCOM officials reported coordinating with the Combined Maritime 

Forces—which comprises forces from 38 nations—to conduct 

boardings, searches, and seizures of vessels in the Indian Ocean.24

In July 2019, we reported that JIATF-S and JIATF-W used mechanisms 

such as working groups and liaison officers to enhance counternarcotics 

efforts and avoid duplication of missions and activities.25 We also reported 

that task force officials had described their coordination efforts as 

effective and had expressed overall satisfaction with the level of 

coordination.

Combatant command officials we interviewed in 2023 spoke positively 

about their coordination with other combatant commands and with entities 

outside DOD, citing the benefits of collaboration and the complementary 

24The Combined Maritime Forces is a multinational maritime partnership, headquartered 

in Bahrain, that was developed to counter illicit nonstate actors on the high seas. Its main 

focus areas include counternarcotics and countersmuggling. 

25GAO, Drug Control: Certain DOD and DHS Joint Task Forces Should Enhance Their 

Performance Measures to Better Assess Counterdrug Activities, GAO-19-441

(Washington, D.C.: July 9, 2019).
Page 20 GAO-24-106281 Counternarcotics

nature of their work. Officials also described the following challenges to 

coordination as well as steps they have taken to address them:

• According to DOD components, they support multiple federal 

agencies and have observed that there is no lead agency that 

coordinates all federal agencies on counternarcotics activities at the 

tactical and operational level. Although ONDCP is responsible for the 

implementation of the National Drug Control Strategy, DOD officials 

stated that coordination between federal agencies at the tactical and 

operational level depends on each agency’s policy, leadership, or 

officials. ONDCP accomplishes its responsibilities through methods 

such as an interdiction committee that includes combatant command 

members, public health and national security working groups, and 

interagency policy committees focused on drug policy and national 

security. However, according to ONDCP officials, the extent to which 

ONDCP’s strategy’s goals and objectives inform other agencies’

priorities depends on each agency.26 Combatant command officials 

told us that they have worked to build ongoing relationships with their 

partner agencies to facilitate coordination.

• Law enforcement agencies sometimes hesitate to share sensitive 

information with combatant commands, according to combatant 

command officials. Officials noted that when coordinating with U.S. 

law enforcement agencies, DOD components have a supporting role 

and therefore follow the law enforcement agencies’ informationsharing requirements. The officials attributed law enforcement 

agencies’ hesitation to share information to their desire to protect their 

sources as well as concern that sharing information might negatively 

affect their cases against individuals and groups suspected of 

trafficking drugs. DOD officials stated that as a result, they are 

sometimes restricted from sharing information with each other. The 

officials said they have worked to address this challenge by 

embedding U.S. law enforcement liaison officers at the combatant 

commands, embedding DOD analysts at U.S. law enforcement 

agencies, and building relationships with these agencies to establish 

trust.

26GAO’s 2023 High-Risk Series report identifies the national effort to prevent, respond to, 

and recover from drug misuse as a high-risk issue. The report also highlights the 

importance to coordinate issues related to this effort across all levels of the federal 

government. See GAO, High-Risk Series: Efforts Made to Achieve Progress Need to Be 

Maintained and Expanded to Fully Address All Areas, GAO-23-106203 (Washington, D.C.: 

April 2023). In addition, ONDCP’s 2022 Strategy highlights the need to strengthen this 

coordination. See Office of National Drug Control Policy, 2022 National Drug Control 

Strategy.
Page 21 GAO-24-106281 Counternarcotics

DOD officials reported that officials from combatant commands enter 

inconsistent data in C2IE, DASD CN&SP’s main data system for sharing 

information on CN/CTOC activities, which sometimes complicates efforts 

to use the system for coordination. C2IE is a DOD-wide system described 

by officials as a program of record. In 2022, DASD CN&SP officials told 

us that they used CN funds to develop and implement a counternarcoticsspecific module in C2IE with the intention of improving coordination and 

information sharing among components.

C2IE allows components to report on their CN/CTOC activities. They are 

required to input certain information about the activities, such as the 

authorities they used, the law enforcement agencies they supported, and 

details of the activities completed. The system has a “deconfliction tab”

that allows users to view other activities or incidents that occurred in the 

same country, met the same reporting requirement, or were within a 

certain time period or geographical distance. Before C2IE was 

established, each combatant command had its own documentation 

system; however, all commands now use C2IE to record their activities, 

according to officials. Officials added that C2IE is a cost-effective way to 

increase transparency and information sharing across DOD. We have 

reported that leveraging resources and information, such as through web 

portals like C2IE, is a leading practice to enhance interagency 

collaboration.27

DASD CN&SP officials told us that they also use information from C2IE to 

develop required quarterly reports about their CN/CTOC activities for 

Congress.28 C2IE also facilitates DASD CN&SP officials’ ability to 

respond quickly to various requests for information from Congress and 

other federal agencies. For example, in response to a National Security 

Council request for information about DOD’s activities related to fentanyl, 

DASD CN&SP officials used C2IE to develop an agency-wide report on 

that topic. DASD CN&SP officials reported that as of August 2023, the CN 

module in C2IE had approximately 3,800 data entries made by about 400 

users.

27GAO-23-105520. 

28DOD is required to provide, on a quarterly basis, a report to Congress regarding the 

activities it implements using the authority set forth at 10 U.S.C. § 284(b) to conduct 

counterdrug activities and activities to counter–transnational organized crime in support of 

any other department or agency of the federal government or of any state, local, tribal, or 

foreign law enforcement agency. 10 U.S.C. § 284(h)(3).

Combatant Commands’

Data Inputs for Activities 

Are Not Consistent
Page 22 GAO-24-106281 Counternarcotics

DASD CN&SP officials stated that they continue to make changes to the 

system through working groups and have provided training materials to 

combatant commands. Currently, C2IE is available only through DOD’s 

secure network. According to officials, DASD CN&SP plans to expand 

C2IE to include additional CN/CTOC activities they conduct, such as 

small-scale construction projects. DASD CN&SP also plans to incorporate 

data from other systems used by DOD components. Further, according to 

the officials, they are considering tracking performance measurement 

metrics in C2IE.

DASD CN&SP’s standard operating procedures for C2IE state that one of

its goals is to improve transparency and effectiveness. The procedures 

also state that use of C2IE allows for increased visibility into DOD 

components’ operations, activities, and investments, leading to increased 

information sharing and collaboration.29 However, combatant command 

officials reported a lack of consistent data entry as a challenge associated 

with C2IE, noting that this complicates efforts to facilitate coordination of 

CN/CTOC activities. For example, an official at one combatant command 

stated that combatant commands’ categorization of threats varies. 

Officials at another combatant command stated that data inputs are not 

uniform across combatant commands or within their own command, 

which complicates their efforts to provide a common operating picture of 

their activities.

DASD CN&SP officials also identified a lack of consistent reporting in 

C2IE by DOD components as a challenge, despite mechanisms, such as 

drop-down menus, intended to minimize inconsistencies. According to the 

officials, the validity of data in the system depends on the consistency of 

both the information entered and the data provided by interagency 

partners. The officials said that they had found and corrected 

inconsistencies in C2IE data that they use for the reports to Congress—

for example, citations of incorrect authorities, entry of an incorrect 

descriptor or area of responsibility, or entry of a dollar amount when such 

data were not required. Given these challenges, combatant command 

officials said that C2IE is not helpful to deconflict and coordinate with 

other combatant commands and that they prefer to contact officials in 

other combatant commands directly because it is more reliable than the 

information in C2IE. However, according to officials, frequent turnover 

within DOD components, as military personnel rotate through positions, 

29Department of Defense, C2IE SOP & Business Rules: CN & CTF Activity Manager.
Page 23 GAO-24-106281 Counternarcotics

complicates the consistency in C2IE data and the ability to contact 

officials for coordination.

Although DOD staff review the quality of C2IE data, DASD CN&SP’s 

standard operating procedures for C2IE do not specifically address the 

need for data consistency or assign responsibility for verifying the data to 

ensure consistency. DASD CN&SP’s standard operating procedures for 

C2IE describe, and provide examples of, the types of data to be entered 

in each field and identify best practices for data entry.30 The procedures 

also state that each component is responsible for ensuring that the 

information it enters in C2IE is thorough and accurate. In addition, the 

procedures state that a Knowledge and Information Management Cell 

representative, who supports DASD CN&SP, should review the data for 

anomalies, missing fields, and general quality control. However, the 

procedures do not specify what constitutes quality control, such as 

accuracy and consistency, and do not assign responsibility for verifying 

that the information the combatant command officials enter is accurate 

and consistent.

According to standards for internal control in the federal government, 

effective internal control systems have certain attributes, including reliable 

internal and external sources that provide data that are reasonably free 

from error and bias.31 These standards also state that management 

makes revisions when necessary so that the information is quality 

information.

Providing guidance that specifies the measures of quality that the 

Knowledge and Information Management Cell representative should 

review, such as measures addressing the need for data accuracy and 

consistency, and that assigns responsibility for verifying the data’s 

accuracy and consistency would strengthen DASD CN&SP’s ability to 

confirm that these data are entered accurately and consistently across 

combatant commands. This would also increase confidence in the data it 

reports to Congress and other federal agencies and could encourage 

combatant commands to use the system for coordination—particularly as 

DASD CN&SP looks to expand C2IE’s use for coordination and other 

possible purposes, such as performance management.

30Department of Defense, C2IE SOP & Business Rules.

31GAO-14-704G. 
Page 24 GAO-24-106281 Counternarcotics

Officials of three geographic combatant commands whose areas of 

responsibility overlap with JIATF-S’s joint operation area reported varying 

understandings of their roles and the flow of illicit drugs in the overlapping 

area.32 In 2003, in an effort to ensure continuity of CN/CTOC operations 

and support activities, DOD published a memorandum that expanded 

JIATF-S’s joint operation area to include JIATF-W’s former joint operation 

area, which included the western coasts of the United States and Mexico. 

JIATF-S’s expanded joint operation area encompasses SOUTHCOM’s 

area of responsibility and parts of NORTHCOM’s and INDOPACOM’s 

(see fig. 6).

32GAO has previously reported on actions agencies could take in areas where federal 

programs are inefficient or ineffective because they are fragmented, overlapping, or 

duplicative. Fragmentation, overlap, and duplication exist across many areas of 

government activity. However, in some cases it may be appropriate or beneficial for 

multiple agencies or entities to be involved in the same programmatic or policy area due to 

the complex nature or magnitude of the federal effort. For more information see GAO, 

Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP (Washington, D.C.: Apr. 14, 2015).

Geographic Combatant 

Commands Have Not

Fully Documented Their 

Roles in an Overlapping 

Operation Area
Page 25 GAO-24-106281 Counternarcotics

Figure 6: Overlap of Joint Interagency Task Force—South’s Joint Operation Area 

with U.S. Southern Command’s, U.S. Northern Command’s, and U.S. Indo-Pacific 

Command’s Areas of Responsibility

Note: The dashed lines show the borders of the combatant commands’ areas of responsibility. 

Officials stated that confusion over roles in the joint operation area has 

occurred among the three geographic combatant commands and their 

task forces. For example, regarding islands in the Caribbean Sea, DOD’s 

2023 Unified Command Plan identifies that NORTHCOM’s area of 

responsibility includes the land domains of the U.S. Virgin Islands, the 

British Virgin Islands, Puerto Rico, the Bahamas, and the Turks and 

Caicos Islands. However, the 2003 memorandum identifies JIATF-S’s 

joint operation area as including all Caribbean islands and the maritime 

space around them. According to officials, this can lead to confusion 

about the management of ground and air operations in this region. They 

identified this as a top challenge and stated that one combatant command 

should be responsible for the Caribbean Sea. Officials also reported 
Page 26 GAO-24-106281 Counternarcotics

confusion over management of activities in Mexico, such as naval 

operations in the Gulf of Mexico and the Pacific Ocean. They explained 

that two combatant commands view this area as part of their 

responsibility, and they described it as an opportunity to improve 

coordination and how they approach this maritime space.

The commands prioritize supporting law enforcement agencies’ 

interdiction of the illicit drugs prevalent in the commands’ respective areas 

of responsibility, according to officials. NORTHCOM and JTF-N officials 

identified supporting the interdiction of fentanyl as a top priority, while 

SOUTHCOM and JIATF-S officials said they focus on supporting 

interdiction of cocaine trafficking. INDOPACOM and JIATF-W officials 

stated that they prioritize supporting interdiction of synthetic drugs and the 

precursor chemicals used to create them. They also said that they 

prioritize supporting the interdiction of shipments of fentanyl, 

methamphetamines, and cocaine.

Moreover, officials’ analysis has led them to different conclusions 

regarding the flow of fentanyl in the Western Hemisphere. For example:

• Officials of one geographic combatant command said that fentanyl 

flows from both Mexico and Canada into the United States.

• Officials of a second geographic combatant command said that 

fentanyl flows only from Mexico.

• Officials of the third geographic combatant command stated 

conflicting information about seeing fentanyl movement in their area of 

responsibility. Some officials said they had not seen fentanyl, but 

others said that they had recently identified fentanyl and precursor 

flows in their area of responsibility. Although these officials said 

conflicting information, other federal agencies have reported the 

presence of precursor chemicals in the area and one of DASD 

CN&SP’s priorities is to support interagency partners in stopping the 

flow of fentanyl in their area of responsibility.

When we asked combatant commands in 2023 for documentation that 

outlines their roles and responsibilities in the area, officials from two of the 

three combatant commands provided the 2003 memorandum that 

expanded JIATF-S’s joint operation area. This memorandum requires that 

the commanders of SOUTHCOM, NORTHCOM, and INDOPACOM 

“complete Command Arrangement Agreements to define . . . Task Force 

areas of responsibility and associated procedures.” When we asked the 

geographic combatant commands and task forces for documentation of 

Other Reported Factors Affecting DOD 

Efforts to Combat Synthetic Drugs

According to combatant command officials, 

there has been a recent trend by 

transnational criminal organizations to shift 

their focus from plant-based drugs, such 

as cocaine and heroin, to synthetic drugs, 

such as fentanyl. Officials explained that 

synthetic drugs are more lucrative and 

easier to produce and transport in smaller 

quantities, making them more difficult to 

detect and monitor. In addition, precursor 

chemicals diverted by transnational 

criminal organizations for illicit use can 

also have legal uses.

However, officials said that transnational 

criminal organizations generally do not 

specialize in a single drug. Thus, DOD 

component officials stated that they 

generally do not base their approach on 

the type of drug being trafficked in each 

case and instead focus on disrupting the 

transnational organized crime networks. In 

addition, officials said that synthetic drugs 

are typically trafficked through the land 

domain to the U.S., particularly through 

commercial ports of entry, and that DOD’s 

authority to monitor and detect illicit drugs 

is generally limited to the aerial and 

maritime domains.

Source: Interviews with Department of Defense (DOD) 

officials. | GAO-24-106281
Page 27 GAO-24-106281 Counternarcotics

such agreements, INDOPACOM provided a 2008 agreement between 

itself and NORTHCOM, and the other two did not provide agreements.

The 2008 agreement discusses various topics, including the commands’

support of each other’s operations, establishment of liaison officers, 

communications procedures, and training exercises. The agreement also 

states that it should be reviewed for currency and applicability every 2 

years. However, we found that the agreement had not been updated to 

address detection and monitoring of precursor chemicals used to develop 

fentanyl—currently a significant issue in both combatant commands’

areas of responsibility—or to clarify the commands’ responsibilities and 

procedures with respect to these chemicals. As a result of frequent 

turnover within DOD components, officials told us that they had been in 

their roles for less than 2 years and could only reference information 

contained in the 2008 agreement.

In March 2024, DOD provided a 2014 agreement between SOUTHCOM 

and NORTHCOM. They also provided an updated 2023 agreement 

between SOUTHCOM, NORTHCOM, and the Coast Guard that 

superseded the 2014 agreement. However, DOD has not updated the 

2008 agreement between INDOPACOM and NORTHCOM and does not 

have an existing agreement between INDOPACOM and SOUTHCOM.

We have previously identified leading practices for interagency 

collaboration, which state that agencies working together should define 

and agree on their respective roles and responsibilities.33 The leading 

practices also state that agencies should articulate these agreements in 

written guidance that is regularly updated and monitored. Without defining 

and maintaining comprehensive, up-to-date agreements, the geographic 

combatant commands whose areas of responsibility overlap with JIATFS’s joint operation area may continue to face confusion regarding their 

roles and responsibilities in the joint operation area as well as uncertainty 

about the flow of fentanyl in the area. This confusion may, in turn, reduce 

their ability to coordinate their efforts when conducting activities to disrupt 

the transport of illicit drugs into the United States by transnational criminal 

organizations.

33GAO-23-105520.
Page 28 GAO-24-106281 Counternarcotics

DOD’s performance measurement system has two key issues that limit 

DOD’s ability to assess the effectiveness of its CN/CTOC activities. First, 

it cannot use its strategic objectives—its long-term CN/CTOC goals—to 

measure progress, because each objective

• lacks measurable outcomes and

• is not clearly aligned with DOD’s CN/CTOC performance goals—its 

near-term measurable goals—or its strategies for achieving each 

goal.

Second, DOD has not assessed agency-wide progress toward its 

strategic objectives and does not have a plan to do so.

DOD’s 2019 Framework to Counter Drug Trafficking and Other Illicit 

Threat Networks (2019 Framework) establishes CN/CTOC strategic 

objectives and strategies.34 To help establish standard performance goals 

for these efforts, DASD CN&SP published the 2023 Performance 

Measurement Plan: DOD Counterdrug and Counter-Transnational 

Organized Crime Policy, Programs and Activities (2023 PMP). However, 

the 2019 Framework’s strategies do not clearly align with any of its 

strategic objectives. As a result, the 2023 PMP’s performance goals—

which are linked to the strategies—cannot be used to measure progress 

toward the strategic objectives, as called for by key practices for 

performance management.35 Without identifying measurable outcomes 

for each of its strategic objectives, DASD CN&SP cannot reasonably 

determine the effectiveness of its CN/CTOC activities.

Key practices for federal agencies’ performance management call for 

defining goals as a first step to effectively build and use evidence to 

manage its performance.36 This includes setting both long-term goals, 

such as strategic objectives, and near-term measurable goals, such as 

34The 2019 Framework refers to objectives, which we identified as strategic objectives, 

and ways, which we identified as strategies. DASD CN&SP officials confirmed that the 

objectives in the 2019 Framework are DASD CN&SP’s strategic objectives. The officials 

defined ways as providing a path to achieve the objectives and key areas to focus on. As 

a result, we determined that the ways described in the 2019 Framework meet the 

definition of strategies in key practices for performance measurement–that is, they are 

planned actions to achieve each goal (see GAO-23-105460). Officials reported that DOD 

developed these elements by reviewing interagency documents, DOD documents, joint 

publications, and intelligence priorities, as well as working with the DOD components.

35GAO-23-105460. 

36GAO-23-105460. 

DOD’s Performance 

Measurement System 

Does Not Enable It to 

Fully Assess 

Effectiveness of 

CN/CTOC Activities

Strategic Objectives Do 

Not Have Measurable 

Outcomes Needed to 

Assess CN/CTOC 

Activities
Page 29 GAO-24-106281 Counternarcotics

performance goals.37 Strategic objectives should be framed so they can 

serve as standards against which an assessment can reasonably be 

performed to determine the effectiveness of the agency’s implementation 

of its programs. Agencies should also clearly define measurable 

outcomes for each strategic objective.38 Once an agency has defined its 

goals, it should determine how it plans to achieve them by identifying 

strategies for each goal.

According to DASD CN&SP, the 2019 Framework is DOD’s overarching 

strategy to counter narcotics trafficking and transnational organized 

crime. DOD guidance requires DASD CN&SP and the DOD components 

to develop performance measurement processes and metrics to measure 

the absolute and relative success of programs and activities in the context 

of the strategic objectives of DOD’s 2019 Framework.39

Table 3 shows the three strategic objectives and five strategies that the 

2019 Framework identifies.

37Performance goals are target levels of performance to be accomplished within a time 

frame. They are generally expressed as tangible, measurable objectives, or as 

quantitative standards, values, or rates. See GAO-23-105460.

38GAO, Managing for Results: Practices for Effective Agency Strategic Reviews,

GAO-15-602 (Washington, D.C.: July 29, 2015).

39Department of Defense, Department of Defense Instruction 3000.14.
Page 30 GAO-24-106281 Counternarcotics

Table 3: Strategic Objectives and Strategies Identified in DOD’s 2019 Framework to Counter Drug Trafficking and Other Illicit 

Threat Networks 

Strategic objectives Strategies

• Disrupt and degrade threat 

networks

• Reduce drug trafficking and 

criminal activity

• Strengthen partners

Strategy and plans. DOD develops, synchronizes, and implements doctrine, strategies, 

plans, and programs to facilitate and support operations with U.S. and international partners.

Intelligence and information sharing. DOD conducts intelligence and information-sharing 

activities to support partner activities to detect, disrupt, degrade, and disable illicit drug 

trafficking and other forms of transnational organized crime.

Operational support. DOD supports and enables U.S. and international partners to disrupt 

and disable illicit threat networks by targeting the networks’ leadership, operations, logistics, 

communications, finances, and key facilitators.

Domain awareness. DOD will collect, integrate, and analyze surveillance, intelligence, and 

all-source information, and will share this information among U.S. and international partners 

in order to make decisions or operate effectively to identify and target illicit drug trafficking 

and other illicit threat networks.

Capacity building. DOD assists foreign partners to improve their capability and capacity to 

disrupt and degrade illicit drug trafficking, transnational organized crime, and other illicit 

threat networks.

Source: Department of Defense (DOD). | GAO-24-106281

Note: We have previously defined strategic objectives as the outcomes or impacts the agency is 

intending to achieve through its activities and strategies as planned actions to achieve each goal. See 

GAO, Evidence-Based Policymaking: Practices to Help Manage and Assess the Results of Federal 

Efforts, GAO-23-105460 (Washington, D.C.: July 2023). 

According to DASD CN&SP officials, each of the strategies defined in the 

2019 Framework supports, and provides guidance for, activities that can 

be used to achieve all three strategic objectives. For example, the officials 

said that the intelligence and information sharing strategy relates to all of 

the strategic objectives because activities implemented under the strategy 

help to reduce criminal activity, improve intelligence, and strengthen 

foreign partners’ activities. Similarly, they said that activities implemented 

under the domain awareness strategy help to disrupt cartels, reduce 

trafficking, and strengthen partners. While it may be possible to find 

associations between all of the strategies and all of the strategic 

objectives, without making these links readily apparent, DASD CN&SP 

cannot identify activities that contribute most effectively to achieving any 

single objective or measure their contribution.

In January 2023, DASD CN&SP issued the 2023 PMP to provide 

guidance for establishing performance goals that could be used to 
Page 31 GAO-24-106281 Counternarcotics

measure progress toward the achievement of the strategic objectives.40

DASD CN&SP subsequently published the performance goals in 

September 2023. However, instead of developing the performance goals 

as near-term, measurable goals directly connected to each strategic 

objective, DASD CN&SP developed them under each of the 2019 

Framework strategies (see table 4).41

Table 4: Examples of Selected 2023 Performance Measurement Plan Performance Goals 

Strategic objectives Strategiesa Examples of performance goals

• Disrupt and degrade threat 

networks

• Reduce drug trafficking and 

criminal activity

• Strengthen partners

Strategy and plans Number of DOD counterdrug component–sponsored/hosted crosscombatant command events, venues, and entities.

Intelligence and information 

sharing

Requests for information/requests for support answered in support 

to partners is equal to or greater than 90 percent of the previous 3 

fiscal years’ average.

Operational support Ninety-five percent of total support directed toward a high-priority 

transnational criminal organization network.

Domain awareness Eighty percent of detected events in Joint Interagency Task 

Force–South area of responsibility successfully handed off to 

interdiction and apprehension forces.

Capacity building Greater than 90 percent total number of Deputy Assistant 

Secretary of Defense approved projects are used as intended 1 

year from Full Operational Capability.

Source: Department of Defense (DOD). | GAO-24-106281

Note: The Office of the Deputy Assistant Secretary of Defense for Counternarcotics and Stabilization 

Policy did not set quantitative targets for the “strategy and plans” performance goals because the 

goals are meant to measure the relative presence of the counternarcotics mission set in government 

strategy, plans, and doctrine over time and to identify organizations and areas where the 

counternarcotics mission set is not represented. DOD identifies the strategic objectives and strategies 

in its 2019 Framework to Counter Drug Trafficking and Other Illicit Threat Networks and 2023 

Performance Measurement Plan: DOD Counterdrug and Counter-Transnational Organized Crime 

Policy, Programs and Activities.

a

The 2023 Performance Measurement Plan also includes two additional strategies, Readiness and 

Workplace Safety (Drug Demand Reduction) and Program Management, that are not included in the 

2019 Framework and are outside the scope of this review. 

40DASD CN&SP officials told us that they had recognized the absence of standardized 

performance goals in the 2019 Framework as an issue for several years but were not able 

to address it until 2023 due to resource constraints.

41The 2023 PMP also includes two additional strategies, Readiness and Workplace Safety 

(Drug Demand Reduction) and Program Management, that are not included in the 2019 

Framework and are outside the scope of this review.
Page 32 GAO-24-106281 Counternarcotics

Since DASD CN&SP has not clearly defined how each strategy aligns 

with each strategic objective, it is unclear how the new performance goals 

can be used as measurable outcomes to assess progress toward each 

strategic objective. For instance, as table 4 shows, one of DASD 

CN&SP’s new performance goals under the operational support strategy 

is that 95 percent of total support should be directed toward a high-priority 

transnational criminal organization. However, the lack of defined 

alignment between the operational support strategy and any one, or all 

three, of the strategic objectives makes it unclear how DASD CN&SP 

would determine which strategic objective this performance goal 

contributes to, or the extent to which achieving this performance goal 

would result in progress toward one or more of the strategic objectives.

According to DASD CN&SP officials, combatant commands began using 

the new performance goals in October 2023.42 Officials said that they 

intend to use the information collected with these goals primarily for 

DASD CN&SP’s annual program management review and program 

objective memorandum processes, which will help leadership to make 

decisions across the agency, such as personnel and technology 

investment decisions, and to determine return on investment.43 The 

officials also emphasized that developing the 2023 PMP and its 

performance goals is an iterative process, and they will review and revise 

the plan after its implementation. However, because the performance 

goals developed under the 2023 PMP are directly linked to the strategies 

defined in the 2019 Framework and not to the strategic objectives, the 

lack of direct alignment between the strategies and each strategic 

objective limits DASD CN&SP’s ability to use the performance goals to 

assess progress toward the objectives.

We have previously reviewed and reported on approaches that federal 

agencies have used to clarify and clearly define measurable outcomes for 

each strategic objective.44 For example, agencies have developed a 

matrix or logic model to illustrate and define the linkages between specific 

strategic objectives and specific strategies and performance goals. 

Agencies have also used a detailed written narrative to ensure that each 

of its strategies and performance goals, and their alignment to individual 

42All combatant commands participated in developing the 2023 PMP performance goals, 

and combatant command officials we spoke with gave positive feedback about the plan.

43The program objective memorandum is an annual assessment that projects funding and 

activities for 5 future fiscal years.

44GAO-15-602.
Page 33 GAO-24-106281 Counternarcotics

strategic objectives, is specific enough to enable assessment of how the 

strategy or goal helps to achieve each objective. Agencies with long-term, 

complex outcomes have developed subgoals for each strategic objective 

that directly connect to, and can be measured by, performance goals.

By identifying measurable outcomes for its strategic objectives, DASD 

CN&SP will gain reasonable assurance that its activities contribute to 

achieving these objectives and will better understand the extent of their 

contribution. As a result, DASD CN&SP will be able to use this evidence 

to inform possible management actions, such as revising its strategies to 

achieve better results and address emerging threats or reallocating 

resources to effectively use funding to meet its targets.

Although DASD CN&SP has processes to evaluate the performance of 

individual DOD components’ CN/CTOC activities, it has not assessed 

agency-wide progress in achieving its CN/CTOC strategic objectives and 

does not have a plan to conduct such assessments. DOD guidance 

requires DASD CN&SP to measure the absolute and relative success of 

programs and activities in the context of the strategic objectives that 

DOD’s 2019 Framework identifies.45 Moreover, key practices for 

performance management identify a number of uses for the information 

produced by assessing progress toward an agency’s strategic 

objectives.46 Such uses include informing long-term strategy, informing 

annual planning and budget formulation, and improving decision-making 

response time. Performance data could also inform DASD CN&SP’s 

investment decisions, such as determining allocations of CN/CTOC 

resources across combatant commands.

In fiscal years 2018 through 2022, combatant commands used a variety 

of performance metrics to assess the results of their CN/CTOC efforts. 

DASD CN&SP did not provide guidance specifying the performance 

metrics they should use, and the metrics the commands used were not 

standardized across combatant commands. As a result, both the 

performance metrics and the number of metrics used differed among 

combatant commands. For example, one combatant command used 

about 30 metrics for its activities, while another used about 70 metrics.

However, DASD CN&SP did not use the performance data collected by 

combatant commands for fiscal years 2018 through 2022 to assess 

45Department of Defense, Department of Defense Instruction 3000.14.

46GAO-23-105460.

DOD Has Not Assessed 

Agency-Wide Progress 

toward CN/CTOC 

Strategic Objectives and 

Does Not Have a Plan to 

Do So

Previous GAO Findings and 

Recommendations on DOD’s 

Counternarcotics Performance 

Measurement 

We have previously reported on, and 

provided recommendations related to, 

performance measurement for the 

Department of Defense’s (DOD) 

counternarcotics (CN) activities. 

• In 2005, we recommended that DOD 

develop and coordinate CN 

performance measures (see GAO-06-

200). In response to our 

recommendation, in May 2009, DOD 

submitted to the Office of National Drug 

Control Policy performance measures 

for its CN activities.

• In 2010, we reported that DOD did not 

have an effective performance 

measurement system to track the 

progress of its CN activities. We also 

reported that DOD’s performance 

measures did not align with a number 

of leading practices, such as measures 

being clearly stated and objective (see 

GAO-10-835). DOD reviewed its CN 

performance measures and made 

improvements in response, but GAO 

found that DOD’s measures still lacked 

key attributes. DOD officials we spoke 

with in 2023 said that they no longer 

use the performance measurement 

system or performance measures we 

reviewed in 2010.

Source: GAO. | GAO-24-106281
Page 34 GAO-24-106281 Counternarcotics

agency-wide progress toward its strategic objectives. According to 

officials, combatant commands reported results for some of their 

performance metrics to DASD CN&SP as part of the annual program 

management review process and the program objective memorandum 

process.47 Combatant commands may also have used performance data 

to support their requests for funding and project approval, although DASD 

CN&SP did not require this, and officials said that some combatant 

commands provided fewer metrics than others. Combatant command 

officials said that DASD CN&SP is primarily concerned about combatant 

commands’ return on investment. DASD CN&SP officials stated that they 

focus primarily on whether combatant commands are operating within the 

bounds of DOD’s CN-related authorities and appropriations.

DASD CN&SP issued the 2023 PMP to standardize metrics across 

combatant commands but has no plan to assess agency-wide progress 

toward its strategic objectives. The assessment, monitoring, and 

evaluation guidance in the 2023 PMP applies to the DOD components 

and does not include requirements for DASD CN&SP to assess agencywide performance. Officials told us that the collection of metrics data is 

not solely for assessment of individual CN-funded programs or entities. 

According to officials, the data will be used to compare performance 

across combatant commands, assess the totality of DASD CN&SP’s 

efforts, and expand future reporting to ONDCP and Congress.

However, DASD CN&SP has not developed or documented a plan 

outlining how it will use the data to assess progress toward the strategic 

objectives, when it will begin conducting such assessments, and what 

management decisions the data will inform. Officials told us that as they 

further develop the 2023 PMP and reporting, they will determine how they 

can use the 2023 PMP to assess DOD-wide progress toward the strategic 

objectives. They added that because the combatant commands will report 

most of the performance data on an annual basis, DASD CN&SP officials 

will focus their efforts on the program management review and program 

objective memorandum processes, which center on the performance of 

individual combatant commands rather than DOD’s overall performance.

47DOD also reports some performance data collected by combatant commands to 

ONDCP. As a National Drug Control Program agency, DOD is required to report some 

performance data in ONDCP’s Budget and Performance Summary Report. For example, 

DOD reports the percentage of detected events successfully handed-off to interdiction and 

apprehension resources, a JIATF-S performance metric. Decision makers use these 

performance measures to guide the allocation of CN/CTOC budgetary resources during 

the annual planning, programming, budgeting, and execution process.
Page 35 GAO-24-106281 Counternarcotics

DASD CN&SP officials also emphasized that their strategic objectives 

reflect goals shared by multiple agencies, and they stated that it can be 

challenging to assess agency-wide performance when DOD often plays a 

supporting role to law enforcement agencies and partner nations. 

Although assessing the effectiveness of DASD CN&SP’s and the DOD 

components’ support to partners may be difficult—especially when such 

assessments rely on data from those partners—this does not negate the 

benefit of DOD assessing its own efforts. Given DOD’s role as the lead 

agency for detection and monitoring of the aerial and maritime transit of 

illegal drugs to the United States, assessing progress toward DASD 

CN&SP’s strategic objectives and collecting reliable data across the 

organization will help ensure that its efforts and use of resources achieve 

the desired outcomes.

Since DASD CN&SP and the DOD components have already developed 

the 2023 PMP performance goals, which includes standardized metrics 

across DOD, they are well positioned to assess agency-wide progress 

without needing to rely on external partners for data. If DOD determines 

that assessing its support to its external partners would provide a more 

complete view of its progress, then it could work with these partners to 

develop performance goals for those collaborative efforts.48

DASD CN&SP officials also told us that, rather than reviewing CN/CTOC 

activities as a whole, from a management perspective, they have regular 

discussions about how funding is spent in relation to their priorities. They 

added that it is difficult to collectively assess CN/CTOC activities because 

each combatant command focuses on different priorities. According to 

officials, it therefore makes more sense to focus on assessing the 

individual performance of combatant commands during the annual 

performance review processes.

However, evaluating only individual combatant commands’ performance 

rather than overall progress toward the strategic objectives will provide 

DASD CN&SP an incomplete picture of the extent to which the agency is 

achieving its desired outcomes. Consequently, DOD will lack complete 

evidence to understand the effectiveness of its CN/CTOC mission, what 

led to the results it achieved, or why desired results were not achieved. 

This will, in turn, limit DOD’s ability to efficiently and effectively determine 

48We have previously identified leading interagency collaboration practices, which include 

defining common outcomes and ensuring accountability. See GAO-23-105520.
Page 36 GAO-24-106281 Counternarcotics

priorities, allocate resources, and identify strategies for improvement, and 

to maintain accountability for results.

DOD has the lead role in the federal government’s efforts in detecting and 

monitoring the aerial and maritime transport of illicit drugs into the United 

States and plays a significant role in supporting federal agencies’ 

CN/CTOC activities. For these reasons, and as priorities and types of 

narcotics evolve—such as the recent trend away from plant-based toward 

synthetic drugs—it is important that DOD is able to coordinate and assess 

the effectiveness of its CN/CTOC activities. DASD CN&SP collects 

information about some CN/CTOC activities in its C2IE data system, but 

officials reported that lack of consistency in the data entered is a 

challenge. DASD CN&SP reviews the data but has not provided guidance 

that specifies the measures of quality they should review, such as 

measures addressing the need for data accuracy and consistency, and 

that assigns responsibility for verifying the data’s accuracy and 

consistency. Documenting this information would help increase trust in 

C2IE as a data system and coordination tool.

In addition, DOD established a joint operation area that overlaps with 

three combatant commands that are focusing on addressing the 

trafficking of cocaine, fentanyl, and precursor chemicals, among other 

threats. DOD also required the commands to complete agreements 

defining their responsibilities in the joint operation area. However, DOD 

has not updated a 2008 agreement between INDOPACOM and 

NORTHCOM and does not have an existing agreement between 

INDOPACOM and SOUTHCOM. As a result, the three combatant 

commands, and their associated task forces, do not have up-to-date 

agreements that outline their individual and joint responsibilities in the 

overlapping operation area. Defining and documenting these 

responsibilities would help the combatant commands address any 

confusion and prevent different understandings of the flow of narcotics in 

the area and improve the commands’ ability to coordinate their efforts to 

disrupt the transport of illicit drugs into the United States.

Finally, the lack of measurable outcomes for each strategic objective in 

the 2019 Framework makes it unclear that DOD will be able to assess 

progress toward these objectives or use this information to make 

management decisions that may allow it to adapt to emerging threats. 

Moreover, a plan to assess agency-wide progress toward its strategic 

objectives would better position DOD to make decisions about priorities, 

resource allocations, and strategies for improvement. Assessing progress 

toward DASD CN&SP’s strategic objectives and collecting reliable data 

Conclusions
Page 37 GAO-24-106281 Counternarcotics

across DOD are essential to ensure that its efforts and use of resources 

achieve the desired outcomes.

We are making a total of four recommendations to DOD:

The Secretary of Defense should ensure that the Deputy Assistant 

Secretary of Defense for Counternarcotics and Stabilization Policy 

updates standard operating procedures for the C2IE data system to 

specify the quality control measures that should be reviewed and to 

assign responsibility for verifying that the information is accurate and 

consistent across combatant commands. (Recommendation 1)

The Secretary of Defense should ensure that the Deputy Assistant 

Secretary of Defense for Counternarcotics and Stabilization Policy works 

with INDOPACOM, SOUTHCOM, and NORTHCOM to develop up-todate agreements that clarify and define their and their task forces’ 

respective roles and responsibilities in the overlapping operation area. 

(Recommendation 2)

The Secretary of Defense should ensure that the Deputy Assistant 

Secretary of Defense for Counternarcotics and Stabilization Policy 

identifies measurable outcomes for each of DOD’s CN/CTOC strategic 

objectives that can be used to assess progress toward the objective. 

(Recommendation 3)

The Secretary of Defense should ensure that the Deputy Assistant 

Secretary of Defense for Counternarcotics and Stabilization Policy 

develops a plan to assess DOD-wide progress toward its CN/CTOC 

strategic objectives. (Recommendation 4)

We provided a draft of this report to ONDCP and DOD for review and 

comment. ONDCP did not provide any comments. DOD provided 

comments that we have reproduced in appendix III. DOD also provided 

technical comments that we incorporated as appropriate. 

In its comments, DOD stated that it partially agreed with our four 

recommendations. The following summarizes DOD’s comments and our 

evaluation:

Recommendation 1. DOD agreed to update its standard operating 

procedures for the C2IE data system to specify the quality control 

measures that should be reviewed. However, DOD did not agree to 

assign responsibility for verifying the accuracy and consistency of 

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
Page 38 GAO-24-106281 Counternarcotics

information across combatant commands. DOD asserted that each of its 

components that enters information in C2IE is responsible for verifying 

the information’s accuracy. As our report describes, the procedures 

include guidance stating that each component is responsible for ensuring 

that the information it enters is thorough and accurate. Yet even with this 

guidance, combatant command officials identified a lack of consistent 

data entry as a challenge associated with C2IE, noting that this 

complicates efforts to facilitate coordination of CN/CTOC activities. 

Further, DASD CN&SP officials told us that they had found and corrected 

inconsistencies in C2IE data that they use for reports to Congress. 

Holding components solely responsible for ensuring the accuracy of the 

data they enter in the system has not been sufficient to ensure the data’s 

accuracy or their consistency across the combatant commands. 

Therefore, we maintain that updating its procedures to assign 

responsibility for verifying the information would help DOD ensure that 

C2IE data are both accurate and consistent across combatant 

commands.

Recommendation 2. Having stated that it partially agreed with the 

recommendation, DOD sent us copies of agreements after we sent our 

draft report to DOD. Officials provided copies of two agreements. The first 

agreement is from 2014 between NORTHCOM and SOUTHCOM and the 

other from 2023 between NORTHCOM, SOUTHCOM, and the Coast 

Guard. Nevertheless, these agreements do not fully satisfy the intent of 

our recommendation or DOD’s requirement. Specifically, there is no 

existing agreement between INDOPACOM and SOUTHCOM and no 

updated agreement between INDOPACOM and NORTHCOM. We 

maintain that in the absence of such agreements, confusion about the 

commands’ responsibilities in the joint operation area may continue, 

reducing DOD’s ability to disrupt the transport of illicit drugs to the U.S.

Recommendation 3. DOD agreed that developing measurable outcomes 

to assess progress toward its strategic objectives would be helpful. 

Developing these outcomes would satisfy the intent of our 

recommendation. In its comment letter, DOD asserted that it does not 

concur with our assessment that its strategic objectives are not clearly 

aligned with its performance goals or its strategies for achieving each 

goal. However, DOD did not offer evidence to show how its performance 

goals or strategies align with the objectives. As our report describes, 

alignment between performance goals, strategies, and strategic 

objectives is important to show how progress toward performance goals 

collectively contributes to progress toward each strategic objective.
Page 39 GAO-24-106281 Counternarcotics

Recommendation 4. DOD agreed that a plan to assess agency-wide 

programs supporting its CN/CTOC strategic objectives would be helpful, 

but it did not agree that it lacks an assessment plan to evaluate the 

totality of its CN/CTOC efforts. As our report states, officials told us that 

the data they collect, as described in the 2023 PMP, will be used to 

compare performance across combatant commands, assess the totality 

of DASD CN&SP’s efforts, and expand future reporting to ONDCP and 

Congress. However, although DASD CN&SP has a plan to collect the 

data, it has not documented a plan outlining how it will use the data to 

assess agency-wide progress toward each strategic objective, when it will 

begin conducting such assessments, and what management decisions 

the data will inform. Therefore, we maintain that it should develop a plan 

to document these and other critical decisions.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Office of National Drug Control 

Policy, and other interested parties. In addition, the report is available at 

no charge on the GAO website at https://www.gao.gov.

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

me at (202) 512-2964 or kenneyc@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 who made key contributions to this 

report are listed in appendix IV.

Chelsa Kenney

Director, International Affairs and Trade
Page 40 GAO-24-106281 Counternarcotics

List of Committees

The Honorable Jack Reed

Chairman

The Honorable Roger Wicker

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Jon Tester

Chair

The Honorable Susan Collins

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Mike Rogers

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Ken Calvert

Chair

The Honorable Betty McCollum

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: Primary Authorities Available to 

DOD for Its CN/CTOC Activities 

Page 41 GAO-24-106281 Counternarcotics

The Department of Defense (DOD) identified various authorities it uses to 

support its counternarcotics (CN) and counter–transnational organized 

crime (CTOC) activities (see table 5).

Table 5: Primary Authorities Identified by DOD as Available for Its Counternarcotics (CN) and Counter—Transnational 

Organized Crime (CTOC) Activities

Authoritya Description

1 10 U.S.C. § 124: Detection and Monitoring of Aerial 

and Maritime Transit of Illegal Drugs

Designates DOD as “the single lead agency of the federal government for 

the detection and monitoring of aerial and maritime transit of illegal drugs 

into the United States.” 

2 10 U.S.C. § 284: Support for Counterdrug Activities 

and Activities to Counter Transnational Organized 

Crime

Authorizes support for CN/CTOC activities of any other department or 

agency of the federal government or of any state, local, tribal, or foreign 

law enforcement agency.

3 10 U.S.C. § 333: Foreign Security Forces- Authority 

to Build Capacityb 

Authorizes provision of training and equipment to foreign national security 

forces for the purpose of building the capacity of such forces to conduct, 

among other things, CN/CTOC operations.

4 Section 1021 of Pub. L. No. 108-375, the Ronald W. 

Reagan National Defense Authorization Act for 

Fiscal Year 2005, as amended

Authorizes support of a unified campaign by the government of Colombia 

against narcotics trafficking and against activities by organizations 

designated as terrorist organizations. 

5 Section 1022 of Pub. L. No. 108-136, the National 

Defense Authorization Act for Fiscal Year 2004, as 

amended (10 U.S.C § 271 note)

Authorizes uses of DOD joint task forces to provide support to law 

enforcement agencies conducting CN/CTOC and counterterrorism 

activities. 

6 Executive Order 12333: Support to the intelligence 

community

Directs DOD, in accordance with priorities set by the President, to support 

the collection of information concerning, and conduct activities to protect 

against, international criminal narcotics activities.

Source: Department of Defense (DOD) documentation. I GAO-24-106281

a

The Department of Defense has additional CN/CTOC authorities that are not applicable to this 

review. These include 10 U.S.C. § 978, which mandates the testing of people applying for an original 

enlistment or for appointment in the armed forces; 32 U.S.C. § 112, which authorizes the Secretary of 

Defense to provide funds to support National Guard drug interdiction and counternarcotics activities; 

and 5 U.S.C. § 7301, which authorizes the President to prescribe regulations that support the 

continuation of random drug testing program for certain DOD employees. 

b

Section 1241 of Pub. L. No. 114-328, the National Defense Authorization Act for Fiscal Year 2017, 

established a consolidated security cooperation authority codified at 10 U.S.C. § 333 that authorizes 

train and equip programs, including those that focus on CN/CTOC operations. That provision included 

a requirement that these programs be funded from DOD’s Operation and Maintenance, DefenseWide account and be made available to the Defense Security Cooperation Agency. See 10 U.S.C. § 

333(g). Because 10 U.S.C. § 333 programs are not funded through the CN fund, they are outside the 

scope of our review. For recent reviews of DOD’s building partner capacity programs, see GAO, 

Building Partner Capacity: DOD Should Assess Delivery Delays in Train and Equip Projects and 

Improve Evaluations, GAO-23-106275 (Washington, D.C.: Aug. 29, 2023); and Building Partner 

Capacity: DOD and State Should Strengthen Planning for Train and Equip Projects, GAO-23-105842

(Washington, D.C.: Aug. 29, 2023). 

Appendix I: Primary Authorities Available to 

DOD for Its CN/CTOC Activities 
Appendix II: Objectives, Scope, and 

Methodology

Page 42 GAO-24-106281 Counternarcotics

The Senate Report accompanying the National Defense Authorization Act 

for Fiscal Year 2023 includes a provision for us to examine issues related 

to the Department of Defense’s (DOD) counternarcotics (CN) and 

counter–transnational organized crime (CTOC) activities.1 This report 

examines (1) funding available for DOD’s CN/CTOC activities and how 

DOD allocated funding in fiscal years 2018 through 2022; (2) the extent to 

which DOD components coordinate their CN/CTOC activities; and (3) 

how DOD has assessed the effectiveness of its CN/CTOC activities, as 

well as the extent to which DOD’s plans for future assessments align with 

key practices. The act also includes a provision for us to describe the 

primary legal authorities available to DOD for CN/CTOC activities; see 

appendix I for a list of these authorities.

To obtain information for all of our objectives, we reviewed relevant DOD 

documents, such as DOD Instruction 3000.14: DOD Counterdrug and 

Counter-Transnational Organized Crime Policy, DOD’s 2019 Framework 

to Counter Drug Trafficking and Other Illicit Networks (2019 Framework), 

and DOD’s Drug Interdiction and Counter-Drug Activities President’s 

Budgets. We also interviewed officials from the Office of National Drug 

Control Policy and 17 DOD components to discuss authorities and 

funding, coordination, and performance measurement. DOD components 

included the Office of the Deputy Assistant Secretary of Defense for 

Counternarcotics and Stabilization Policy (DASD CN&SP), combatant 

commands, intelligence agencies, and the Joint Chiefs of Staff. We 

selected these components on the basis of DOD’s CN/CTOC priorities.

To identify the legal authorities available to DOD for CN/CTOC activities, 

we reviewed the authorities noted in DOD Instruction 3000.14 and the 

Drug Interdiction and Counter-Drug Activities President’s Budgets. We 

compiled a list of possibly relevant authorities and interviewed DOD 

officials to confirm the authorities that are available to DOD for its 

CN/CTOC activities. We also asked DOD component officials to identify 

the authorities the components use to conduct their CN/CTOC activities. 

We list these authorities in appendix I.

We reviewed the fiscal years 2018 through 2022 appropriations acts to 

identify the amounts of funding that Congress most recently directed to 

CN/CTOC activities. Congress provides CN/CTOC funds through DOD’s 

Drug Interdiction and Counter-Drug Activities appropriation. This 

1S. Rept. 117-130 at 235-236 accompanying S. 4543, the James M. Inhofe National 

Defense Authorization Act for Fiscal Year 2023 (enacted into law as Pub. L. No. 117-263, 

136 Stat. 2395 (2022)). 

Appendix II: Objectives, Scope, and 

Methodology
Appendix II: Objectives, Scope, and 

Methodology

Page 43 GAO-24-106281 Counternarcotics

appropriation supports four budget activities; our review focuses on one, 

the Counter-Narcotics Support budget activity, which we refer to as the 

CN fund.2 Further, we reviewed the fiscal years 2020 through 2024 Drug 

Interdiction and Counter-Drug Activities President’s Budgets to identify 

the amount of funding DASD CN&SP allocated to DOD components in 

fiscal years 2018 through 2022 and the amount it allocated to support 

various CN/CTOC activities in fiscal year 2022.

To assess the reliability of the funding data, we conducted several validity 

checks, including developing an analysis of the information in the 

President’s Budgets, creating charts and tables to identify totals for each 

combatant command across multiple data points, and comparing data we 

received from combatant commands to the data in the President’s 

Budgets. We also interviewed DOD officials and verified whether 

information they provided was shown in the data. We found the data to be 

sufficiently reliable for the purposes of reporting the amounts DOD 

allocated to its components. We also interviewed officials from DASD 

CN&SP and the DOD components about the amount of funding they 

received, changes in the funding over time, and the activities they used 

the funding to support.

To examine the extent to which DOD components coordinate their 

CN/CTOC activities, we interviewed DOD officials to discuss the data 

systems they use to facilitate coordination. We reviewed guidance and 

training documentation for these data systems as well as reports to 

Congress that DOD used the systems to produce. We determined that 

the internal control principle related to using quality information for 

effective monitoring was significant to this objective.3 Officials from a 

combatant command also showed us how they use the Command and 

Control of the Information Environment data system and described some 

benefits and challenges of using the system to coordinate efforts with 

other combatant commands.

Furthermore, we interviewed DOD officials about how and with which 

entities they coordinate as well as successes and challenges they have 

2The other three budget activities are the (1) Drug Demand Reduction Program, (2) 

National Guard Counter-Drug Program, and (3) National Guard Counter-Drug Schools 

Program. For a review of the National Guard Counterdrug and Schools Programs, see 

GAO, Drug Control: DOD Should Improve Its Oversight of the National Guard 

Counterdrug Program, GAO-19-27 (Washington, D.C.: Jan. 17, 2019).

3GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: Sept. 10, 2014).
Appendix II: Objectives, Scope, and 

Methodology

Page 44 GAO-24-106281 Counternarcotics

experienced in coordinating their CN/CTOC activities. We reviewed 

documents that DOD components provided to us, such as memorandums 

of agreement between combatant commands and between combatant 

commands and law enforcement agencies. We also reviewed DOD 

guidance on how combatant commands should coordinate. An analyst 

evaluated DOD components’ coordination against selected leading 

practices to enhance interagency collaboration and coordination that we 

have previously identified.4 These practices include clarifying roles and 

responsibilities and developing and updating written guidance and 

agreements. The analyst also evaluated components’ coordination 

against a 2003 DOD requirement that certain combatant commands 

complete agreements to define areas of responsibility and associated 

procedures.5 A second analyst independently verified this evaluation.

To determine how DOD has assessed the effectiveness of its activities, 

we identified performance metrics that DASD CN&SP and the DOD 

components used for fiscal years 2018 through 2022. We interviewed 

officials from DASD CN&SP and the DOD components to discuss 

performance data they had collected, reported, and assessed. To 

examine DOD’s plan to assess its activities in the future, we reviewed 

DOD’s 2019 Framework as well as DOD’s 2023 Performance 

Measurement Plan: DOD Counterdrug and Counter-Transnational 

Organized Crime Policy, Programs and Activities (2023 PMP) and related 

performance metrics. An analyst evaluated the strategic objectives 

identified by the 2019 Framework and the performance goals identified by 

the 2023 PMP against selected key practices for performance 

management that we had previously identified to help agencies assess 

the results of its efforts.6 A second analyst independently verified this 

evaluation. Additionally, we interviewed officials from DASD CN&SP and 

the DOD components about the development and planned 

implementation of the new performance measurement plan and its 

metrics.

4GAO, Government Performance Management: Leading Practices to Enhance 

Interagency Collaboration and Address Crosscutting Challenges, GAO-23-105520

(Washington, D.C.: May 24, 2023). 

5Department of Defense, Joint Interagency Task Force (JIATF) Area Responsibilities 

Memorandum (Washington, D.C.: Aug. 21, 2003).

6GAO, Evidence-Based Policymaking: Practices to Help Manage and Assess the Results 

of Federal Efforts, GAO-23-105460 (Washington, D.C.: July 2023).
Appendix II: Objectives, Scope, and 

Methodology

Page 45 GAO-24-106281 Counternarcotics

We conducted this performance audit from October 2022 to April 2024 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 objectives.
Appendix III: Comments from the Department 

of Defense

Page 46 GAO-24-106281 Counternarcotics

Appendix III: Comments from the 

Department of Defense 
Appendix III: Comments from the Department 

of Defense

Page 47 GAO-24-106281 Counternarcotics
Appendix III: Comments from the Department 

of Defense

Page 48 GAO-24-106281 Counternarcotics
Appendix III: Comments from the Department 

of Defense

Page 49 GAO-24-106281 Counternarcotics
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 50 GAO-24-106281 Counternarcotics

Chelsa Kenney, (202) 512-2964 or kenneyc@gao.gov

In addition to the contact named above, Valérie L. Nowak (Assistant 

Director), Katya E. Rodriguez (Analyst-in-Charge), Emma O’Shea, Megan 

Ferren, Mark Dowling, Reid Lowe, Christopher Keblitis, and Pamela 

Davidson made key contributions to this report. Marcus Oliver, Rich 

Geiger, Triana McNeil, Fred Lyles, Anthony Patterson, Susan Murphy, 

Benjamin T. Licht, and Sarah E. Veale also contributed.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
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