Export Controls: State and Commerce Have Not Taken Basic Steps to Better Ensure U.S. Interests Are Protected
Published: 2008-04-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In controlling the transfer of weapons and related technologies overseas, the U.S. government must limit the possibility of sensitive items falling into the wrong hands while allowing legitimate trade to occur. Achieving this balance has become more challenging due to redefined security threats and a globalized economy. The export control system is a key component of the safety net of programs intended to balance multiple U.S. interests. The export control system is managed primarily by the State Department, which regulates arms exports, and the Commerce Department, which regulates dual-use exports that have military and civilian applications. Unless an exemption applies, arms exports require licenses, while many dual-use exports do not require licenses. Based on GAO's extensive body of work on the export control system, this testimony focuses on export licensing inefficiencies, poor interagency coordination, and limits in State's and Commerce's ability to provide a sound basis for changes to the system. In prior work, GAO made recommendations to address vulnerabilities in the export control system, but many have not been implemented. Because of these vulnerabilities and others identified in the larger safety net of programs, GAO has designated the effective protection of technologies critical to U.S. national security interests as a high risk area warranting strategic reexamination.
section_title: What GAO Found
paragraphs: State and Commerce have not managed their respective export licensing processes to ensure their effective operations. In November 2007, GAO reported that procedural and automation weaknesses, along with workforce challenges, created inefficiencies in State's arms export licensing process. In less than 4 years, median processing times for license applications nearly doubled, with State's backlog of open cases peaking at 10,000. According to State officials, the department has begun analyzing its licensing data and implementing actions that will allow it to better manage its workload and determine the most effective workforce structure. While Commerce's license application processing times for dual-use exports have remained relatively stable, the overall efficiency of its process is unknown. This is due in part to Commerce's lack of performance measures for all steps in its process and analyses that would allow it to identify opportunities for improvement. Poor coordination among State, Commerce, and the other departments involved in the export control system has created vulnerabilities. State and Commerce have disagreed on which department has jurisdiction over the export of certain items. In one case, Commerce determined that an item was subject to its less restrictive export requirements when, in fact, it was State-controlled. Such improper determinations and unclear jurisdiction not only create an unlevel playing field--because some companies may gain access to markets that others will not--it also increases the risk that sensitive items, such as missile-related technologies, will be exported without the appropriate review and resulting protections. Further, State and Defense took almost 4 years to reach agreement regarding when certain arms export licensing exemptions could be used by exporters in support of Defense-certified programs. This lack of agreement could have resulted in export requirements being applied inconsistently. Also, in response to a GAO recommendation, State and Commerce only recently began regularly receiving information on criminal enforcement actions--information that is important to consider upfront when reviewing license applications for approval. Despite dramatic changes in the security and economic environment, State and Commerce have not undertaken basic management steps to ensure their controls and processes are sufficient and appropriate for protecting U.S. interests. Notably, neither department has assessed its controls in recent years. Nevertheless, State and Commerce maintained that no fundamental changes to their export control system were needed. Earlier this year, the White House announced that the President signed directives intended to ensure that the export control system focuses on meeting security and economic challenges. Similarly, legislation to make changes to the export control system has been introduced. However, few details about the basis for these initiatives are known. In the past, GAO has found that export control initiatives not grounded in analyses have generally not resulted in the desired improvements to the system.

section_title: Letter
paragraphs: It is my pleasure to be here today to discuss the U.S. export control  system—one component of the government’s safety net of programs  designed to protect critical technologies while allowing legitimate defense  trade. In controlling the transfer of weapons and related technologies to  other countries and foreign companies, the U.S. government must  consider and strike a balance among multiple and sometimes conflicting  national security, foreign policy, and economic interests. Achieving this  balance has become increasingly difficult given the evolving security  threats we face, the quickening pace of technological innovation, and the  increasing globalization of the economy. GAO has examined not only the  export control system but also other components of the safety net, such as  the foreign military sales program, reviews of foreign investments in  U.S. companies, and a program for identifying militarily critical  technologies. Within each component and across the safety net, we  identified significant vulnerabilities and threats that prompted us in 2007  to designate the effective protection of technologies critical to U.S.  national security interests as a new high-risk area warranting strategic  reexamination. I believe that today’s hearing contributes to that  reexamination.
The export control system is a particularly complex component of the  government’s safety net. The system is managed primarily by the  Departments of State and Commerce, though other departments such as  Defense, Homeland Security, and Justice play active roles in the system.  State regulates arms exports, while Commerce regulates exports of dual- use items, which have both military and civilian applications. Exports  subject to State’s regulations generally require a license, unless an  exemption applies. Many Commerce-controlled items do not require a  license for export to most destinations. However, in managing their  respective systems, both departments are responsible for limiting the  possibility of export-controlled items and technologies falling into the  wrong hands while allowing legitimate trade to occur.
Over the last decade and most recently in November 2007, we have  reported on various aspects of the U.S. export control system and the  weaknesses and challenges that affect the system’s overall effectiveness.  My statement today focuses on: (1) inefficiencies in the export licensing  processes, (2) poor interagency coordination, and (3) limits in State’s and  Commerce’s ability to identify problems and provide a sound basis for  making changes to the system.
My statement is based on GAO’s extensive body of work on the export  control system. We have made a number of recommendations to address  the weaknesses and challenges we identified, but many of them have yet  to be implemented. We conducted these performance audits in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform audits 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.
subsections: section_title: Background
paragraphs: The U.S. government has a myriad of laws, regulations, policies, and  processes intended to identify and protect critical technologies so they  can be transferred to foreign parties in a manner consistent with U.S.  national security, foreign policy, and economic interests. Advanced  weapons and militarily useful technologies are sold by U.S. companies for  economic reasons and by the U.S. government for foreign policy, security,  and economic reasons. Yet, the technologies that underpin U.S. military  and economic strength continue to be targets for theft, espionage, reverse  engineering, and illegal exports. As a result, the safety net of programs,  many which were put in place decades ago, not only has to protect critical  technologies but it also has to do so in a manner that allows legitimate  trade with allies and other friendly nations.
The U.S. export control system for defense-related items involves multiple  federal agencies and is divided between two regulatory bodies—one  managed by State for arms and another managed by Commerce for dual- use items (see table 1).
State’s and Commerce’s implementing regulations contain lists that  identify the items and related technologies each department controls and  establish requirements for exporting those items. Exporters are  responsible for determining which department controls the items they  seek to export and what the regulatory requirements are for export. The  two departments’ controls differ in several key areas. In most cases,  Commerce’s controls over dual-use items are less restrictive than State’s  controls over arms. Many items controlled by Commerce do not require  licenses for export to most destinations, while State-controlled items  generally require licenses for most destinations. Also, some sanctions and  embargoes only apply to items on State’s U.S. Munitions List and not to  those on the Commerce Control List. For example, Commerce-controlled  items may be exported to China while arms exports to China are generally  prohibited.
Even when items are exempt from licensing requirements, they are still  subject to U.S. export control laws. Responsibility for enforcing those laws  and their associated regulations largely rests with various agencies within  Commerce, Homeland Security, Justice, and State. These enforcement  agencies conduct a variety of activities, including inspecting items to be  exported, investigating potential export control violations, and pursuing  and imposing the appropriate penalties. Punitive actions, which are either  criminal or administrative, can be taken against violators of export control  laws and regulations. Justice can prosecute criminal cases, where the  evidence shows that the exporter willfully and knowingly violated export  control laws. Prosecutions can result in imprisonment, fines, and other  penalties. State or Commerce can impose fines, suspend export licenses,  or deny export privileges for administrative violations.
section_title: Inefficiencies in the Processing of License Applications Hinder the Export Control System
paragraphs: Reviews of export license applications require time to deliberate and  ensure that license decisions are appropriate. Such reviews, though,  should not be unnecessarily delayed due to inefficiencies or be eliminated  for efficiency’s sake—both of which could have unintended consequences  for U.S. security, foreign policy, and economic interests. However, State  and Commerce have not managed their respective export licensing  processes to ensure their efficient operation.
As we have previously reported, inefficiencies have contributed to  increases in State’s processing times for license applications and related  cases and its inability to keep pace with a growing workload. State’s  processing times for arms export cases began increasing in fiscal year  2003—with median processing times nearly doubling from 14 days to  26 days by fiscal year 2006 (see fig. 1). During this period, State’s workload  increased by 20 percent, from about 55,000 to 65,000 cases. State was  unable to keep pace with this growing number of cases, which resulted in  a significant number of open cases awaiting review and final action. At the  end of fiscal year 2006, this so called “backlog” reached its peak at over  10,000 open cases, prompting State to undertake extraordinary  measures—such as extending work hours and canceling training and  industry outreach—to reduce the number of open cases. However, such  measures were not sustainable and did not address underlying  inefficiencies. Concerns were also raised that these measures could have  the unanticipated effect of shifting the focus from the mission of  protecting U.S. interests to simply closing cases to reduce the number of  open cases.
At the time of our 2007 review, we found that State had not analyzed  licensing data to identify inefficiencies and develop sustainable solutions  to manage its review process and more effectively structure its workforce.  Through our extensive analysis of State’s data, we determined that the  overall trend of increased processing times and open cases was  attributable to several factors, including procedural weaknesses, problems  with its new electronic processing system, and human capital challenges,  many of which had gone unnoticed and unaddressed by State.
Procedural Weaknesses: State lacked screening procedures to  promptly identify those cases needing interagency review. As a result,  cases often languished for weeks in a queue awaiting assignment or  initial review before being referred to another agency, such as Defense,  for further review. State also lacked procedures to expedite certain  cases. We found that processing times in fiscal year 2006 for exports to  the United Kingdom and Australia, which by law were to be expedited,  did not differ significantly from processing times for other allied  countries. Similarly, processing time goals for applications in support  of Operations Iraqi Freedom and Enduring Freedom were not being  met.
Electronic Processing Problems: State officials have cited D- Trade—its new automated system for processing cases—as the most  significant effort to improve efficiency. However, State’s  implementation of D-Trade has been problematic and has not been the  promised panacea for improving processing times. Our analysis  showed that there was no significant difference in processing times for  similar cases whether they were submitted via D-Trade or the  traditional paper-based system. State relied on this automated solution  without reengineering the underlying processes or developing tools to  facilitate the licensing officer’s job. For example, D-Trade has limited  capabilities to reference precedent cases that would allow licensing  officers to leverage work previously done on similar cases, which could  not only help to expedite the processing of a case but could also ensure  greater consistency among similar cases. Further, D-Trade experienced  performance problems that State officials attributed to poorly defined  requirements and a rush to production. For example, because of a  glitch in January 2007, 1,300 cases received during a 3-day period had  to be resubmitted by exporters, which resulted in rework.
Human Capital Challenges: State has also faced human capital  challenges in establishing and retaining a sufficient workforce with the  experience and skills needed to efficiently and effectively process arms  export cases. For example, the number of licensing officers on board  was at the same level in fiscal years 2003 and 2006, despite an almost  20 percent increase in cases over that period. As a point of comparison,  in fiscal year 2005, State had 31 licensing officers who closed  approximately 63,000 cases while Commerce had 48 licensing officers  who closed approximately 22,000 cases. Additionally, Defense had not  been providing State with its full complement of detailed military  officers, who are generally assigned to review complex agreements.  State officials have acknowledged that more work was falling on fewer  experienced staff. According to these officials, in the summer of 2006,  about half of State’s licensing officers had less than a year of  experience, and many lacked the authority needed to take final action  on cases.
These findings prompted us to recommend that State conduct analyses of  its licensing data to assess root causes of inefficiencies and then identify  and implement actions that would allow it to better manage its workload,  reexamine its processes, and determine the most effective workforce  structure. We are encouraged to learn that, under the direction of new  leadership responsible for managing the arms export control system, State  has recently committed to implementing these recommendations and  taking actions to address the issues we identified. Specifically, State has  informed us that it (1) has implemented procedures to more quickly  determine whether cases should be referred to other agencies or State  bureaus for review and instituted senior level reviews of cases that are  over 60 days old, (2) is planning future D-Trade upgrades that are expected  to facilitate case reviews by licensing officers and allow managers to  better oversee the processes, and (3) has restructured its licensing  divisions to ensure a more equitable distribution in the workload and skill  level of licensing officers based on our analysis. While these recently  reported actions are encouraging, we have not yet examined them to  determine their effects.
Concerns about efficiency have largely focused on State’s processing of  applications for arms exports, in part, because few dual-use exports  subject to Commerce’s controls require licenses. In 2005, for example,  98.5 percent of dual-use exports, by dollar value, were not licensed. While  few dual-use exports are licensed, the number of license applications  processed by Commerce has increased in recent years—increasing by over  50 percent from fiscal years 1998 through 2005. During that time period,  Commerce’s overall median processing times have remained stable,  around 40 days, and are consistent with time frames established by a 1995  executive order. However, the overall efficiency of Commerce’s licensing  process is unknown in part because Commerce lacks efficiency-related  measures and analyses that would allow it to identify opportunities for  improvement. For example, to determine the efficiency of its license  application review process, Commerce only measures its performance in  terms of how long it takes to refer an application to another agency for  review. Commerce does not have efficiency-related measures for other  steps in its review process, such as how quickly a license should be issued  once other agencies provide their input, or for the entire process. During  the course of our prior reviews, Commerce did not provide us with  evidence that would indicate it has undertaken analyses of licensing data  to determine if previously established time frames are still appropriate or  to identify the drivers of its workload or the bottlenecks in its processes  that would allow it to implement actions to improve efficiency.
section_title: Poor Interagency Coordination Creates Vulnerabilities
paragraphs: Since multiple departments have a role to play in the export control  system, its effective operation depends on those departments working  together. However, we have identified instances related to export control  jurisdiction, the use of license exemptions, and the dissemination of  enforcement information when poor coordination among the departments  has created vulnerabilities in the system’s ability to protect U.S. interests.  The departments have taken action to address some—but not all—of these  vulnerabilities.
Given the different restrictions State and Commerce have on the items  subject to their controls, the determination of which items fall under  State’s export jurisdiction and which fall under Commerce’s is  fundamental to the U.S. export control system. However, we have  previously reported that State and Commerce have disagreed on which  department has jurisdiction over certain items. In some cases, both  departments have claimed jurisdiction over the same items, which was the  case for certain missile-related technologies. In another case, for  example, Commerce improperly determined that explosive detection  devices were subject to Commerce’s less restrictive export control  requirements when they were, in fact, State-controlled. Such  jurisdictional disagreements and problems are often the result of minimal  or ineffective coordination between the two departments and the  departments’ differing interpretations of the regulations. Despite our  recommendations to do so, the two departments have not yet come  together to resolve these jurisdictional disputes or develop new processes  to improve coordination. Until these disagreements and coordination  problems are resolved, exporters—not the government—will continue to  determine which restrictions apply and, therefore, the type of  governmental review that will occur. Not only does this create an unlevel  playing field and competitive disadvantage—because some companies  may gain access to markets that others will not—but it also increases the  risk that critical items will be exported without the appropriate review and  resulting protections.
Even when jurisdiction over an export-controlled item is clearly  established, there is not always agreement among the departments on  when an export license is required. While State generally requires a license  for most arms exports, its regulations exempt exports that meet specific  criteria from licensing requirements. For a limited number of licensing  exemptions, Defense may confirm that the export qualifies for the use of  an exemption in support of Defense activities, such as sharing of technical  data related to defense acquisition programs and defense cooperative  agreements with allies and friendly nations. However, our work revealed  that State and Defense had different interpretations of the exemptions and  what exports could be certified by Defense. For example, State officials  maintained that one exemption was only for use by U.S. government  personnel, while Defense officials stated it was available for use by  contractors working in direct support of Defense activities. For  approximately 4 years, the lack of a common understanding of the  exemption created a vulnerability as regulations and licensing  requirements could have been inconsistently applied. Further, we found  that State and Defense lacked comprehensive data to oversee the use of  these exemptions. Such data would allow the departments to identify and  assess the magnitude of transfers certified for exemption use. Specifically,  Defense’s 2006 annual report to State on the use of the exemptions  provided data on 161 certifications, but we identified 271 additional  certifications that were not included in Defense’s report because they  were not entered into a centralized Defense database. We understand that,  in response to our recommendation, State and Defense established a  working group and recently reached agreement to resolve the issues  identified in our report.
When an exporter applies for a license, both State and Commerce are to  consider whether the parties to the proposed export are eligible to sell or  receive controlled items and technologies. Individuals or companies  indicted or convicted of violating various laws may be denied from  participating in proposed exports. Therefore, information on criminal  export control prosecution outcomes should help inform the export  control process by providing State and Commerce with a complete picture  of the individual or company seeking an export license. Prosecuting  export cases can be difficult, since securing sufficient evidence to prove  the exporter intentionally violated export control laws can represent  unique challenges, especially when the item being exported is exempted  from licensing or the case requires foreign cooperation. We reported in  2006 that while Justice and the other enforcement agencies have databases  that capture information on their enforcement activities, the outcomes of  criminal cases were not consistently shared with State and Commerce.  Instead State and Commerce relied on informal processes to obtain  information on indictments and convictions, which created gaps in their  knowledge. For example, we found that the watchlist used by Commerce  to screen applications was incomplete as it did not contain 117 companies  and individuals that had committed export control violations. Prompted by  our recommendation, Justice began providing State and Commerce with  quarterly reports on criminal enforcement actions so that such  information can be considered upfront during the license application  review process.
section_title: Absence of Assessments Limits Ability to Identify Problems and Make Improvements to the System
paragraphs: To adapt to the accelerating pace of change in the global security,  economic, and technological environment, federal programs need to  systematically reassess priorities and approaches and determine what  corrective actions may be needed to fulfill their missions. For example, to  meet the challenges of the 21st century, agency leaders need to reexamine  their programs, asking questions related to their program’s relevance and  purpose, how success should be measured, and whether they are  employing best practices. Given the two departments’ missions of  controlling defense-related exports while allowing legitimate trade, State  and Commerce should not be exceptions to this basic management tenet.  Although dramatic changes have occurred in the security and economic  environment since the start of the 21st century, State and Commerce have  not conducted systematic assessments to determine whether their  controls and processes are sufficient and appropriate or whether changes  are needed to better protect U.S. interests. Despite providing us with no  basis for their positions and the existence of known vulnerabilities, both  departments informed us that no fundamental changes to their respective  systems were needed.
Earlier this year, the President signed a package of directives that,  according to the White House, will ensure that U.S. export control policies  and practices support national security while facilitating economic and  technological leadership. Relatively few details about the directives or the  basis for particular initiatives have been publicly released, though they  reportedly incorporate recommendations provided by industry. We have  not had an opportunity to review the specifics of the directives, how they  were formulated, or how they will be implemented. Legislation has also  been introduced to make changes to the export control system.
While we have not had an opportunity to evaluate the new directives, a  note of caution may be drawn from our work regarding a prior set of  initiatives that were also designed to improve the export control system. In  2000, the Defense Trade Security Initiatives (DTSI), which was  characterized as the first major post-Cold War revision to the U.S. export  control system, was unveiled. DTSI was comprised of 17 different  initiatives developed by State and Defense to expedite and reform the U.S.  export control system. At the time, we determined that no analysis of the  problems that the initiatives were intended to remedy or demonstration of  how they would achieve identified goals had been conducted. It turned  out that the justifications for the initiatives was, in part, based on  anecdotes that were factually incorrect or only told part of the story. In  one example cited by Defense, the lengthy processing time for an export  license caused a foreign firm to cancel its contract with a U.S. aerospace  company, but upon closer examination, we learned that U.S. government  had denied the license because of concerns regarding the foreign firm’s  ties with the Chinese military. Because there was little assurance that  DTSI would result in improvements to the system, we were not surprised  during our subsequent work when we found that the initiatives had  generally not been successful. For example, D-Trade was one of the  initiatives, but as already discussed, its anticipated efficiencies have not  yet been realized. Additionally, processing time goals established in DTSI  for applications to assist allies in increasing their military capabilities have  not been met. Other initiatives have not been widely used by exporters.  For example, we reported that between 2000 and 2005, State had only  received three applications for comprehensive export authorizations for a  range of exports associated with multinational defense efforts, including  the Joint Strike Fighter. According to Defense and contractor officials,  while such authorizations were intended to lessen the administrative  burden and improve processing times for routine export authorizations,  companies have opted not to use them because of the extra costs  associated with their compliance requirements.
section_title: Conclusions
paragraphs: The government’s safety net of programs is intended to protect critical  technologies while still allowing legitimate trade. Therefore, the  components of that system must address known vulnerabilities and be  able to adapt to a changing global environment if they are to individually  and collectively protect and promote U.S. national security, foreign policy,  and economic interests. Our past work demonstrates that State and  Commerce have not managed the export control system to better ensure  its overall effectiveness in protecting U.S. interests. Recent actions taken  by the departments to begin addressing some of the management issues  and vulnerabilities identified in our prior reports are encouraging.  However, other recommendations, most notably those related to export  control jurisdiction, remain unimplemented. While the implementation of  our recommendations is an important first step for improving the  efficiency and effectiveness of the export control system, a sustained  commitment on the part of the departments to engage in a continuous  process of evaluation, analysis, and coordination is needed. It is only then  that meaningful and sustainable improvements to the export control  system can be developed and implemented to ensure the efficiency and  effectiveness of the system in protecting U.S. interests.
Mr. Chairman this concludes my statement. I would be happy to answer  any questions you or other members of the subcommittee may have.
section_title: GAO Contacts and Acknowledgments
paragraphs: For questions regarding this testimony, please contact me at (202) 512- 4841 or calvaresibarra@gao.gov. Johana R. Ayers, Assistant Director;  Marie Ahearn, Jennifer Dougherty, Karen Sloan, and Anthony Wysocki  made key contributions to this statement. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement.
section_title: Related GAO Products
paragraphs: Defense Trade: State Department Needs to Conduct Assessments to  Identify and Address Inefficiencies and Challenges in the Arms Export  Process. GAO-08-89. Washington, D.C.: November 30, 2007.
Defense Trade: Clarification and More Comprehensive Oversight of  Export Exemptions Certified by DOD Are Needed. GAO-07-1103.  Washington, D.C.: September 19, 2007.
Export Controls: Vulnerabilities and Inefficiencies Undermine System’s  Ability to Protect U.S. Interests. GAO-07-1135T. Washington, D.C.: July 26,  2007.
High Risk Series: An Update. GAO-07-310. Washington, D.C.: January  2007.
Export Controls: Challenges Exist in Enforcement of an Inherently  Complex System. GAO-07-265. Washington, D.C.: December 20, 2006.
Analysis of Data for Exports Regulated by the Department of Commerce.  GAO-07-197R. Washington, D.C.: November 13, 2006.
Export Controls: Agencies Should Assess Vulnerabilities and Improve  Guidance for Protecting Export-Controlled Information at Universities.  GAO-07-70. Washington, D.C.: December 5, 2006.
Export Controls: Agencies Should Assess Vulnerabilities and Improve  Guidance for Protecting Export-Controlled information at Companies.  GAO-07-69. Washington, D.C.: December 5, 2006.
Defense Technologies: DOD’s Critical Technologies Lists Rarely Inform  Export Control and Other Policy Decisions. GAO-06-793. Washington,  D.C.: July 28, 2006.
Export Controls: Improvements to Commerce’s Dual-Use System Needed  to Ensure Protection of U.S. Interests in the Post-9/11 Environment.  GAO-06-638. Washington, D.C.: June 26, 2006.
Defense Trade: Arms Export Control Vulnerabilities and Inefficiencies  in the Post-9/11 Environment. GAO-05-468R. Washington, D.C.: April 7,  2005.  21st Century Challenges, Reexamining the Base of the Federal  Government. GAO-05-325SP. Washington, D.C.: February 2005.
Defense Trade: Arms Export Control System in the Post-9/11  Environment. GAO-05-234. Washington, D.C.: February 16, 2005.
Nonproliferation: Further Improvements Needed in U.S. Efforts to  Counter Threats from Man-Portable Air Defense Systems. GAO-04-519.  Washington, D.C.: May 13, 2004.
Nonproliferation: Improvements Needed to Better Control Technology  Exports for Cruise Missiles and Unmanned Aerial Vehicles. GAO-04-175.  Washington, D.C.: January 23, 2004.
Export Controls: Post-Shipment Verification Provides Limited  Assurance That Dual-Use Items Are Being Properly Used. GAO-04-357.  Washington, D.C.: January 12, 2004.
Joint Strike Fighter Acquisition: Cooperative Program Needs Greater  Oversight to Ensure Goals Are Met. GAO-03-775. Washington, D.C.: July  21, 2003.
Defense Trade: Better Information Needed to Support Decisions  Affecting Proposed Weapons Transfers. GAO-03-694. Washington, D.C.:  July 11, 2003.
Nonproliferation: Strategy Needed to Strengthen Multilateral Export  Control Regimes. GAO-03-43. Washington, D.C.: October 25, 2002.
Export Controls: Processes for Determining Proper Control of Defense- Related Items Need Improvement. GAO-02-996. Washington, D.C.:  September 20, 2002.
Export Controls: Department of Commerce Controls over Transfers of  Technology to Foreign Nationals Need Improvement. GAO-02-972.  Washington, D.C.: September 6, 2002.
Export Controls: More Thorough Analysis Needed to Justify Changes in  High Performance Computer Controls. GAO-02-892. Washington, D.C.:  August 2, 2002.
Export Controls: Rapid Advances in China’s Semiconductor Industry  Underscore Need for Fundamental U.S. Policy Review. GAO-02-620.  Washington, D.C.: April 19, 2002.
Defense Trade: Lessons to Be Learned from the Country Export  Exemption. GAO-02-63. Washington, D.C.: March 29, 2002.
Export Controls: Issues to Consider in Authorizing a New Export  Administration Act. GAO-02-468T. Washington, D.C.: February 28, 2002.
Export Controls: Reengineering Business Processes Can Improve  Efficiency of State Department License Reviews. GAO-02-203.  Washington, D.C.: December 31, 2001.
Export Controls: Clarification of Jurisdiction for Missile Technology  Items Needed. GAO-02-120. Washington, D.C.: October 9, 2001.
Export Controls: State and Commerce Department License Review Times  are Similar. GAO-01-528. Washington, D.C.: June 1, 2001.
Export Controls: Regulatory Change Needed to Comply with Missile  Technology Licensing Requirements. GAO-01-530. Washington, D.C.:   May 31, 2001.
Defense Trade: Analysis of Support for Recent Initiatives.   GAO/NSIAD-00-191. Washington, D.C.: August 31, 2000.
Defense Trade: Status of the Department of Defense’s Initiatives on  Defense Cooperation. GAO/NSIAD-00-190R. Washington, D.C.: July 19,  2000.
Export Controls: Better Interagency Coordination Needed on Satellite  Exports. GAO/NSIAD-99-182. Washington, D.C.: September 17, 1999.
Export Controls: Change in Export Licensing Jurisdiction for Two  Sensitive Dual-Use Items. GAO/NSIAD-97-24. Washington, D.C.:   January 14, 1997.
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