Combating Terrorism: Strategy to Counter Iran in the Western Hemisphere Has Gaps That State Department Should Address
Published: 2014-09-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The activities of Iranian government elements, such as a 2011 attempt to assassinate the Saudi Ambassador in the United States, could pose a threat to U.S. national security. Congress enacted the Countering Iran in the Western Hemisphere Act of 2012, requiring State to assess the threats posed to the United States by Iran's presence and activity in the Western Hemisphere and to develop a strategy to address those threats. This report examines (1) State's collaboration with other key U.S. agencies and foreign partners to address Iranian activities in the Western Hemisphere, (2) the extent to which the strategy addresses elements identified in the act, and (3) the extent to which the strategy includes desirable characteristics of national strategies.
GAO analyzed agency documents and interviewed agency officials in Washington, D.C.; Argentina; Brazil; Colombia; and Mexico. GAO chose these countries based on factors such as past instances of Iran-linked terrorist attacks and their bilateral relationships with the United States.
section_title: What GAO Found
paragraphs: The Department of State (State) uses a variety of mechanisms to collaborate with interagency partners and host governments to address activities of Iran in the Western Hemisphere. In developing the strategy, which includes an Intelligence Community Assessment developed by the Office of the Director of National Intelligence (ODNI), State's Bureau of Western Hemisphere Affairs worked with other U.S. agencies at the headquarters level and relied on cable reporting from posts. According to State officials, the strategy represents a consensus view of key agencies. While the Department of Defense (DOD) as a whole joined in this consensus, one part of DOD—the Southern Command—disagreed with the strategy's characterization of the Iranian threat at the time the strategy was prepared. State also uses venues such as country team meetings and law enforcement working groups to address Iranian activities.
While the strategy contains information on Iranian activities in the Western Hemisphere, it does not contain all the information that the Countering Iran in the Western Hemisphere Act of 2012 stated it should include. GAO identified 12 distinct elements that the act stated should be included in the strategy. As shown in the figure, the strategy fully addresses 2, partially addresses 6, and does not address 4 of 12 elements. For example, the strategy contains information describing the operations of Iran, but does not include a plan to address U.S. interests to ensure energy supplies from the Western Hemisphere are free from foreign manipulation. State and ODNI officials reported several reasons why the strategy may not fully address the information identified in the law. For example, State said it only included information in the strategy if it deemed the activity identified in the law to be a threat to the United States.
Note: ODNI officials did not provide documentation for three of the elements that were fully or partially addressed in the Intelligence Community Assessment.
State is not legally required to address the six desirable characteristics of effective national strategies GAO has identified, but the strategy does include some of them. The strategy fully addresses problem definition and risk assessment. It partially addresses purpose, scope, and methodology; goals, subordinate objectives, activities, and performance measures; and organizational roles, responsibilities, and coordination. The strategy does not, however, address resources, investments, and risk management; and integration into other strategies and implementation by other levels of government.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretary of State provide the relevant congressional committees with additional information that would fully address the elements in the act. In the absence of such information, State should explain why it was not included in the strategy. State generally disagreed with our assessment of the extent to which the strategy addressed the elements in the act but agreed to continue to provide Congress with information regarding Iranian activities in the Western Hemisphere.

section_title: Letter
paragraphs: Iranian government elements—including the Iranian Islamic Revolutionary  Guard Corps and its Qods Force, and Iran’s close ally Lebanese  Hizballah—have played a role in terrorist operations in the Western  Hemisphere over the past two decades. This includes the 1994 bombing  of the Jewish Community Center in Buenos Aires, Argentina, that killed  85 people. In October 2011, the United States announced charging two  men with conspiracy to assassinate the Saudi Arabian Ambassador to the  United States. The alleged plot was directed by elements of the Iranian  government to murder the Ambassador with explosives while the  Ambassador was in the United States, according to the announcement. In  December 2012, Congress enacted the Countering Iran in the Western  Hemisphere Act of 2012, which stated that the policy of the United  States is to use a comprehensive government-wide strategy to counter  Iran’s growing hostile presence and activity in the Western Hemisphere  by working together with U.S. allies and partners in the region to mutually  deter threats to U.S. interests by Iran and its proxy actors. The act further  required the Department of State (State) to assess the threats posed to  the United States by Iran’s activities in the Western Hemisphere and  submit to the relevant congressional committees the results of the  assessment and a strategy to address these threats. The act directed the  Secretary of State, in developing the strategy, to consult with the heads of  other U.S. departments and agencies, including the Departments of  Defense (DOD), Homeland Security (DHS), Justice (DOJ), and the  Responding to the act, State submitted a document to Congress that  included a seven-page classified strategy report, an unclassified  summary of policy recommendations, and an Intelligence Community  Assessment. Some Members of Congress have raised concerns about  the strategy and expressed continued concerns about Iranian activities in  the Western Hemisphere. In response to these concerns, you requested  that we review the strategy and its development. In this report, we  examine (1) State’s collaboration with other key U.S. agencies and  foreign partners to address Iranian activities in the Western Hemisphere,  (2) the extent to which the strategy on addressing Iranian activities in the  Western Hemisphere included elements identified in the act, and (3) the  extent to which the strategy on addressing Iranian activities in the  Western Hemisphere included desirable characteristics of national  strategies.
To analyze State’s collaboration with key U.S. agencies and foreign  partners to address Iranian activities in the Western Hemisphere, we  reviewed agency documents and interviewed U.S. and foreign officials.  We interviewed officials from State, DOD, DHS, Treasury, DOJ, ODNI,  and USTR. We also interviewed officials at the U.S. embassies in  Argentina, Brazil, Colombia, and Mexico, and host government officials in  Colombia and Mexico regarding input they may have provided regarding  the strategy.including whether they had experienced instances of Iran-linked terrorist  attacks, their bilateral relationships with the United States, and our  expected ability to engage with host government officials. The results of  our interviews with officials at these four locations are not generalizable to  all countries in the Western Hemisphere. To examine the extent to which   We chose these countries based on a number of factors,  the strategy on addressing Iranian activities in the Western Hemisphere  includes elements identified in the act, we analyzed State’s submission to  Congress, including State’s classified strategy report, the unclassified  summary of policy recommendations, and portions of the Intelligence  Community Assessment. We analyzed documents and interviewed State  and ODNI officials to determine how, if at all, the strategy addressed the  elements in the act. For some instances in which we could not review  portions of the documents that make up the strategy, we relied on the  testimonial information provided by agency officials and noted such  instances. We also examined the strategy to determine the extent to  which the strategy incorporated desirable characteristics of national  strategies that we have previously identified.
We conducted this performance audit from January 2014 to September  2014 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives. Appendix I provides a  detailed explanation of our objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: The Countering Iran in the Western Hemisphere Act of 2012 directed the  Secretary of State to conduct an assessment of the threats posed to the  United States by Iran’s growing presence and activity in the Western  Hemisphere, and to submit a strategy to address Iran’s growing hostile  presence and activity in the Western Hemisphere. We identified 12 broad  elements in the act that should be included in the strategy, such as  descriptions of the presence, activities, and operations of Iran and its  proxy actors in the Western Hemisphere; a description of the federal law  enforcement capability and military forces in the Western Hemisphere  that may organize to counter the threat posed by Iran and its proxy  actors; and a plan to address any efforts by foreign persons, entities, and  governments in the region to assist Iran in evading United States and  international sanctions.
In June 2013 State submitted a seven-page classified strategy report, an  unclassified annex that summarizes policy recommendations, and an  Intelligence Community Assessment at a higher security classification  level, to fulfill the requirement in the act. State’s seven-page classified  strategy report is an overview of Iran’s activities in the Western  Hemisphere, its relationships with countries in the area, and U.S. efforts  to address any concerns. It includes a summary of diplomatic and  economic ties with the Western Hemisphere countries, noting that the key  to Iran’s activities in the region has been Venezuela.
The strategy report notes that the economic relationship between Iran  and the Western Hemisphere is limited, with only 0.2 percent of Latin  American exports going to Iran. It also describes the effect of U.S.  economic sanctions and diplomatic pressure, which it says have been  successful in preventing further Iranian involvement in the Western  Hemisphere. In addition, the strategy broadly describes Iranian activities  in the Western Hemisphere.
The strategy report also describes five areas of focus for continuing to  address Iranian threats in the Western Hemisphere. The areas of focus  are to (1) expand existing efforts to share intelligence and information; (2)  identify, disrupt, and dismantle criminal networks to enhance border  security and strengthen law enforcement; (3) continue to take actions on  sanctions and implementation of the Iran Freedom and Counter- Proliferation Act of 2012; (4) improve rule of law capacity-building  initiatives in the Western Hemisphere; and (5) continue diplomatic  pressure, including at the multilateral level in the United Nations and the  International Atomic Energy Agency.
In addition to the seven-page strategy report, State submitted two  annexes. Annex A is an unclassified summary of policy recommendations  and addresses a requirement in the act to submit an unclassified  summary of policy recommendations. Annex A defines the desired end  state of U.S. efforts in this area to be a decrease in Iranian presence and  influence in the Western Hemisphere. It makes the assumption that Iran  will continue its outreach to the Western Hemisphere but also concludes  that Iranian influence in the Western Hemisphere is waning.
Annex B is an Intelligence Community Assessment that was developed  by ODNI at the request of State. According to ODNI, the Intelligence  Community Assessment includes, among other things, a discussion of  Iran’s presence in the Western Hemisphere, funding of cultural and  religious centers, military-to-military activities, economic engagements,  trade relationships, and diplomatic relations.
section_title: State Uses a Variety of Mechanisms to Collaborate with Other Stakeholders to Address Iranian Activities in the Western Hemisphere
paragraphs: In accordance with the act, officials in State’s Bureau of Western  Hemisphere Affairs developed the strategy based on consultations with  officials representing DOD, DHS, DOJ, Treasury, ODNI, and USTR in  headquarters and also conducted some outreach to overseas posts and  partner governments. The Countering Iran in the Western Hemisphere  Act of 2012 required the Secretary of State to consult with the heads of all  appropriate U.S. departments and agencies, including the Secretaries of  Defense, Homeland Security, and Treasury, and the Attorney General,  the Director of National Intelligence, and the U.S. Trade Representative.  Officials we interviewed at headquarters representing all of these  agencies noted that State sought their input into the strategy and  requested their review prior to issuing the strategy. State also consulted  with components of the intelligence community.
According to an official at the Bureau of Western Hemisphere Affairs who  helped draft the strategy, State did not conduct a specific data call to all of  the U.S. posts in the Western Hemisphere to seek the posts’ input into  the strategy. Instead, the official said State alerted embassies through e- mails from State leadership informing them of the development of the  strategy. In addition, State reviewed information in cable reports from  posts in the Western Hemisphere. Embassy officials at the four posts we  visited were generally aware of the U.S. strategy on addressing Iranian  activities in the Western Hemisphere. However, most of the embassy  officials we interviewed were not at the embassy when State was  developing the strategy and did not know if their predecessors had  contributed to the strategy’s development. State officials reported meeting  with officials from foreign embassies in Washington, D.C., including the  embassies of Argentina, Canada, Mexico, and Brazil. Foreign  government officials we met with during fieldwork in Mexico and Colombia  said that they had not provided input into the U.S. strategy. Figure 1  provides a timeline of State’s collaboration efforts.
According to State officials, the strategy represents a consensus view of  key agencies, including DOD, DHS, DOJ, and the Intelligence  Community. Of note, while DOD as a whole joined in this consensus,  one part of DOD—the Southern Command—disagreed with the strategy’s  characterization of the Iranian threat in the hemisphere at the time the  strategy was prepared.
In addition to collaboration regarding its strategy, State also collaborates  with other key agencies (DOD, DHS, DOJ, ODNI, and Treasury) in  headquarters about issues related to Iranian activities in the Western  Hemisphere through interagency working groups and informal  mechanisms. Officials representing all four U.S. embassies we visited  (Argentina, Brazil, Colombia, and Mexico) also reported effective formal  and informal collaboration efforts were in place to share information that  could include activities of Iran and its proxies; the following are examples.
Country team meetings: All four embassies we visited hold weekly  country team meetings in which agencies and sections share  information.
Working groups: The Law Enforcement Working Group is the main  venue for coordinating efforts to monitor and address potential Iranian  activity in all four embassies we visited. The law enforcement working  groups in all four locations included, at a minimum, all the relevant law  enforcement and intelligence agencies (DOD, DHS, DOJ, and others  in the Intelligence Community) at the embassy. At some embassies,  these meetings also included components not traditionally associated  with law enforcement, such as State’s Political and Economic  sections. Other working groups also played important roles in  addressing threats, sometimes including those emanating from Iran  and its proxies.  Informal collaboration and communication: Officials representing all  different sections and agencies of all four embassies also reported  that informal communications (e-mails, phone calls, in-person visits)  or ad hoc meetings are sometimes the most important means to  collaborate effectively and efficiently as issues arise.
section_title: Strategy on Iranian Activities Did Not Address All the Information Congress Requested
paragraphs: The three documents constituting the strategy contain information on  Iranian activities in the Western Hemisphere; however, they do not  contain all of the information identified in the act. We identified 12 distinct  elements that the act states should be included in the strategy. Half of  these elements request a description of specific Iranian activities and  relationships, as well as foreign and U.S. capabilities to counter the threat  posed by Iran in the Western Hemisphere. The other half request plans to  address potential threats to the United States. As shown in figure 2, the  strategy fully addresses 2 elements, partially addresses 6 elements, and  does not address the remaining 4 elements.
For the 12 strategy elements shown in table 1: of the 6 that the act states should include a description of Iranian  activities or Latin American government capabilities to address Iranian  activities, the strategy fully addresses 2 and partially addresses 4; of the 6 that the act states should include plans to address potential  threats to U.S. interests, the strategy partially addresses 2 and does  not address 4.
State and ODNI officials reported four reasons why the strategy does not  fully address the information that the act stated should have been  included.
First, State officials informed us that they only included information on  threats posed by Iran and Hizballah to the United States, based on  State’s interpretation of the act. According to State officials, State  interpreted the law to mean that if the Secretary of State deemed the  Iranian or Hizballah activity a threat to the United States, State would  be required to address it in its submission to the relevant  congressional committees; if the Secretary of State did not deem it to  be a threat to the United States, State would not be required to  address it. ODNI officials also told us that they did not report on  elements for which they had no information or for which the  information available to them indicated there was no relevant Iranian  activity. In the strategy, State and ODNI did not note elements for  which they sought but did not find relevant information.
Second, ODNI officials reported several reasons why the Intelligence  Community Assessment only partially addressed some of the  elements. The officials noted that Intelligence Community analysts  regularly provide a range of products to policymakers on the topic,  including more tactical information than is included in Intelligence  Community Assessments, which have helped policymakers as they  developed the broader strategy.
Third, State officials informed us that State’s February 2010 Executive   requires all reports to Congress to be  Secretariat Memorandumlimited to five pages and that State therefore issued its classified  strategy and unclassified summary of policy recommendations to  meet this five-page reporting limitation. According to State officials,  this requirement limited their ability to include information to  comprehensively address all of the elements identified in the act.
Fourth, ODNI officials informed us that the Intelligence Community  Assessment did not respond to some of the elements identified in the  law because these elements were related to policy matters and thus  were not appropriate for the Intelligence Community Assessment to  address.
section_title: Though Not Required to Do So, the Strategy on Iranian Activities Included Some of the Desirable Characteristics of National Strategies
paragraphs: While State was not required to include GAO’s six desirable  characteristics for national strategies in its strategy to address Iran’s  activity in the Western Hemisphere, it included some but not all of these  characteristics. These desirable characteristics are (1) purpose, scope,  and methodology; (2) problem definition and risk assessment; (3) goals,  subordinate objectives, activities, and performance measures; (4)  resources, investments, and risk management; (5) organizational roles,  responsibilities, and coordination; and (6) integration and  implementation. Ideally, a national strategy should contain all of these  characteristics. Including these characteristics in a national strategy also  enhances its usefulness as guidance for resource and policy decision  makers to better ensure accountability.
As shown in table 2, we found that the strategy for addressing Iranian  activities in the Western Hemisphere fully addresses one desirable  characteristic of national strategies, partially addresses three more, and  does not address the remaining two.
The strategy fully addresses problem definition and risk assessment.  According to ODNI officials, the Intelligence Community Assessment  goes into significant detail describing Iranian activities and assessing the  risks to U.S. interests.
The strategy partially addresses three other desirable characteristics of  national strategies: purpose, scope, and methodology; goals, subordinate  objectives, activities, and performance measures; and organizational  roles, responsibilities, and coordination. The classified strategy report  discusses the purpose of the strategy as a response to the act and a  multiagency effort to address Iranian activities in Latin America, and the  strategy also briefly discusses the various agencies consulted in its  development. However, the information contained in the strategy is too  general to be considered to fully address its methodology. The strategy  discusses an ideal “end-state,” major goals, subordinate objectives, and  specific activities to address Iranian activities in the Western Hemisphere.  However, it does not set clear desired results and priorities, specific  milestones, and outcome-related performance measures. It also does not  discuss any limitations on performance measures that may exist, nor  does it address plans to obtain better data or measurements. The  strategy identifies organizations involved with achieving the desirable  result and mechanisms for coordinating their efforts to address Iranian  activities in the Western Hemisphere, but it does not clarify organizations’  specific roles and responsibilities to address Iranian activities in the  Western Hemisphere.
The strategy does not address two desirable characteristics of national  strategies: resources, investments, and risk management; and integration  and implementation. When asked, State officials said that the strategy  outlines ongoing initiatives and programs that address Iranian activities  and does not require any additional investments or plans to implement  these initiatives.
section_title: Conclusions
paragraphs: The United States continues to face a range of threats to its national  security, among them threats emanating overseas from terrorist  organizations and their state sponsors—including Iran. Congress has  expressed serious concerns about Iranian activities in the Western  Hemisphere, including reported involvement in the attempt to assassinate  the Saudi Ambassador to the United States. To more fully understand the  nature and extent of Iranian activities in the Western Hemisphere,  Congress required State to assess and report on the threat posed to the  United States by Iran’s presence and activity in the Western Hemisphere,  and to develop a strategy for addressing Iran’s hostile presence and  activity. While State’s strategy report and the accompanying Intelligence  Community Assessment include information about Iranian activities in the  Western Hemisphere, some information that Congress stated should be  included was either partially addressed or not addressed. State and ODNI  officials provided to us reasons why they did not fully address some of the  information Congress called for in the strategy. However, the strategy did  not include State’s explanation, which may have contributed to some of  the concerns expressed by Members of Congress. Providing additional  information that addresses the topics not covered by the strategy— including the plans outlining interagency and multilateral coordination of  targeted security efforts—could help Congress understand the basis for  State’s conclusions and better inform policymakers as they continue to  monitor the potential threats posed by Iranian activities in the Western  Hemisphere.
section_title: Recommendation for Executive Action
paragraphs: For elements identified in the Countering Iran in the Western Hemisphere  Act of 2012 that were not fully addressed in the strategy, we recommend  that the Secretary of State provide the relevant congressional committees  with information that would fully address these elements. In the absence  of such information, State should explain to the congressional committees  why it was not included in the strategy.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to State, DOD, DHS, DOJ, ODNI,  Treasury, and USTR for comment. DOD, DOJ, ODNI, Treasury, and  USTR had no comments. DHS provided a technical comment, which we  addressed as appropriate. In its written comments, reproduced in  appendix II along with our responses to specific points, State generally  disagreed with our assessment of the extent to which the strategy  addressed the elements in the act. State indicated that it has provided  information and briefed Congress on these matters on a regular basis and  agreed to continue to do so.
In support of its position, State noted that our report catalogued matters  that Congress stated should be included in the strategy but that these  were not specific reporting requirements. In addition, State explained that  it did not address matters where the consensus of the intelligence  community was that there was not an identifiable threat to counter.  According to State, most of the elements we identified as not being  adequately addressed in the strategy fell into this category.
We acknowledge that State did not report on elements for which they had  no information or for which available information indicated there was no  relevant Iranian threat, and that providing all relevant existing guidance,  plans, and initiatives in its strategy would have made the report longer  than the five pages allowed under State’s guidance for reports to  Congress. However, we maintain that the strategy does not include all of  the elements that the law stated should be included. Specifically, it does  not discuss nor provide Congress with an explanation for the exclusion of  elements called for by the act for which State and ODNI did not find  relevant threat information. It also does not include summaries of existing  agency documents that State officials mentioned would address some  elements in the act. Providing such information could have more fully  informed Congress regarding State’s assessment of the threat posed by  Iranian activities in the Western Hemisphere and U.S. government efforts  to address the threat.
We are sending copies of this report to the appropriate congressional  committees, the Secretaries of State, Defense, Homeland Security, and  Treasury; the Attorney General; the U.S. Trade Representative; and the  Director of National Intelligence. In addition, the report will be available at  no charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-7331 or johnsoncm@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 III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: In December 2012, Congress enacted the Countering Iran in the Western  Hemisphere Act of 2012, which, among other things, required the  Department of State (State) to assess the threats posed to the United  States by Iran’s activities in the Western Hemisphere and submit to the  relevant congressional committees the results of the assessment and a  strategy to address these threats. In this report, we examine (1) State’s  collaboration with other key U.S. agencies and foreign partners to  address Iranian activities in the Western Hemisphere, (2) the extent to  which the strategy on addressing Iranian activities in the Western  Hemisphere included elements identified in the act, and (3) the extent to  which the strategy on addressing Iranian activities in the Western  Hemisphere included desirable characteristics of national strategies.
To analyze State’s collaboration with key U.S. agencies and foreign  partners to address Iranian activities in the Western Hemisphere, we  reviewed agency documents and interviewed U.S. and foreign officials.  We interviewed officials from the Departments of State (State), Defense  (DOD), Homeland Security (DHS), Justice (DOJ), and the Treasury  (Treasury); the Office for the Director of National Intelligence (ODNI); and  the Office of the U.S. Trade Representative (USTR). We also interviewed  officials at the U.S. embassies in Argentina, Brazil, Colombia, and Mexico  and host government officials in Colombia and Mexico regarding input  they may have provided regarding the strategy. We chose these  countries based on a number of factors including whether they had  experienced instances of Iran-linked terrorist attacks, their bilateral  relationship with the United States, and our ability to meet with host  governments. The results of our interviews with officials at these four  locations are not generalizable to all countries in the Western  Hemisphere.
To examine the extent to which the strategy to address Iranian activities  in the Western Hemisphere included elements identified in the Countering  Iran in the Western Hemisphere Act of 2012, we analyzed State’s  submission of the strategy document, including the classified strategy  report, the unclassified summary of policy recommendations, and the  Intelligence Community Assessment. We identified 12 elements that  Congress requested in the act, as the act had noted specific matters that  should be included in the strategy. We analyzed documents and  interviewed State and ODNI officials to determine how, if at all, the  strategy addressed the elements in the act. To do so, two analysts  conducted separate assessments of all three strategy documents against  the 12 elements we identified in the act. They reached agreement on the  extent to which the measures fully addressed, partially addressed, or did  not address the attributes. A manager reviewed the analysis, and the  three individuals reached a final consensus. A senior methodologist  reviewed the analysis for completeness and balance. Coding worked as  follows: the strategy “fully addresses” an element when it explicitly cites  all characteristics of an element, even if it lacks further details. The  strategy “partially addresses” an element when it explicitly cites some but  not all characteristics of an element. Within our designation of “partially  addresses,” there is a wide variation between addressing most of the  characteristics of an element and addressing few of the characteristics of  an element. The strategy “does not address” an element when it does not  explicitly cite or discuss any characteristics of an element and/or when  any implicit references are either too vague or general. For some  instances in which we could not review portions of the documents that  make up the strategy, we used the testimonial information provided by  agency officials; we noted such instances. We asked to review the entire  Intelligence Community Assessment but were unable to do so because of  concerns over its security classification. We reviewed some excerpts and  interviewed the ODNI officials who prepared the assessment regarding its  contents. In three instances, ODNI officials told us information addressing  an element included in the act was included in the Intelligence  Community Assessment, but they did not provide supporting  documentation. In those instances, we have reflected the information  provided by ODNI officials but noted that we were not able to  independently verify their statements because of a lack of documentation.
We also examined the strategy to determine the extent to which the  strategy incorporated desirable characteristics of national strategies  previously identified by GAO. Similar to our analysis of the extent to  which the strategy addressed elements identified in the act, we analyzed  all three documents that make up the strategy and assessed how, if at all,  the strategy addressed the elements in the act. Two analysts conducted  separate assessments of all three strategy documents against the six  desirable characteristics of national strategies. They reached agreement  on the extent to which the measures fully addressed, partially addressed,  or did not address the attributes. A manager reviewed the analysis and  the three individuals came together to reach a final consensus. A senior  methodologist reviewed the analysis for completeness and balance.  Coding worked as follows: the strategy “fully addresses” a desirable  characteristic of a national strategy when it explicitly cites all aspects of a  characteristic, even if it lacks further details. The strategy “partially  addresses” a desirable characteristic when it explicitly cites some but not  all aspects of a characteristic. Within our designation of “partially  addresses,” there is a wide variation between addressing most of the  elements of a characteristic and addressing few of the elements of a  characteristic. The strategy “does not address” an element when it does  not explicitly cite or discuss any aspect of a characteristic, and/or when  any implicit references are either too vague or general. As discussed  above, for some instances in which we could not review portions of the  documents that make up the strategy, we used the testimonial information  provided by agency officials; we noted such instances.
We conducted this performance audit from January 2014 to September  2014 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.
section_title: Appendix II: Comments from the Department of State
subsections: section_title: GAO Comments
paragraphs: 1.  Our report notes that Congress requested that the strategy include “a  plan to address resources, technology, and infrastructure to create a  secure United States border.”  Therefore, we evaluated the extent to  which the information sought by Congress was included in the  strategy. While other documents may contain the information sought  by Congress, it was not included or summarized in State’s strategy  report.  2.  We agree with State that its report does not contain a plan, as sought  by Congress, to address any efforts by foreign persons, entities, and  governments in the region to assist Iran in evading U.S. and  international sanctions. While State provided information regarding  past activities to enforce sanctions, a plan was not included in the  strategy.  3.  While we have included some information on security initiatives and  assistance programs in our report based on meetings with State  officials, State’s original strategy report to Congress did not contain  the plan sought by Congress.   4.  As we discuss in our report, State and the Office of the Director of  National Intelligence (ODNI) did not address elements for which State  and ODNI sought but did not find relevant information. However,  State’s original strategy report did not indicate that the plan sought by  Congress was not provided because there was a lack of a clear  threat. Explicitly indicating why the plan sought by Congress was not  included could have helped better inform Congress.  5.  ODNI—which was responsible for drafting the Intelligence Community  Assessment referred to by State—informed us that the Intelligence  Community Assessment included only some but not all of the various  descriptions identified in the act. As such, our finding is based in part  on the views of ODNI.  6.  We maintain that the strategy only partially addresses 5(b)(6)(B) of  the act, acknowledging it includes a reference to some citizen security  initiatives. The act stated that the strategy should include a plan, but  State did not provide the citizen security initiatives’ documents or a  summary of its plan in the strategy.  7.  Our report states that the language in the act requested “a plan to  support United States efforts to designate persons and entities in the  Western Hemisphere for proliferation activities and terrorist activities  relating to Iran.” Therefore, we evaluated the extent to which the  information sought by Congress was included in the strategy report  submitted to Congress, not whether it was publicly available on  State’s or Treasury’s web site. While other documents may contain  the information sought by Congress, it was not included in the  strategy.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Jason Bair (Assistant Director),  Victoria Lin (Analyst-in-Charge), Brian Hackney, Ashley Alley, David  Dayton, and David Dornisch made key contributions to this report. Oziel  Trevino and Sarah Veale provided technical assistance.