Anti-Money Laundering: Better Communication Could Enhance the Support FinCEN Provides to Law Enforcement
Published: 2010-04-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Financial investigations are used to combat money laundering and terrorist financing, crimes that can destabilize national economies and threaten global security. The Financial Crimes Enforcement Network (FinCEN), within the Department of the Treasury, supports law enforcement agencies (LEAs) in their efforts to investigate financial crimes by providing them with services and products, such as access to financial data, analysis, and case support. This statement discusses the extent to which the law enforcement community finds FinCEN's support useful in its efforts to investigate and prosecute financial crimes. This statement is based on work GAO completed and issued in December 2009.
section_title: What GAO Found
paragraphs: In December 2009, we reported that the majority of 25 LEAs GAO surveyed found FinCEN's support useful in their efforts to investigate and prosecute financial crimes, but FinCEN could enhance its support by better informing LEAs about its services and products and actively soliciting their input. Of the 20 LEAs that responded to a question GAO posed about which FinCEN services they found most useful, 16 LEAs cited direct access to Bank Secrecy Act data--records of financial transactions possibly indicative of money laundering that FinCEN collects--as the most valuable service FinCEN provides. Additionally, 11 federal LEAs cited a tool that allows federal LEAs to reach out, through FinCEN, to financial institutions nationwide to locate financial information related to ongoing investigations as a key service offered by FinCEN. To further enhance the value and relevance of its analytic work to LEAs, FinCEN has sought to increase development of complex analytic products, such as reports identifying trends and patterns in money laundering. Sixteen law enforcement agencies GAO surveyed reported that they generally found these complex analytic products useful. However, we reported that three of five LEAs that are among FinCEN's primary federal customers stated that FinCEN does not provide detailed information about the various types of complex analytic products it can provide. Three of FinCEN's primary customers also stated that they would like more information about when completed products become available. In December 2009, we recommended that FinCEN clarify the types of complex analytic products it can provide to LEAs. FinCEN agreed with our recommendation and in April 2010 outlined plans to improve communication with law enforcement regarding FinCEN's services, products, and capabilities. All five LEAs also reported that FinCEN does not actively seek LEAs' input about ongoing or planned analytic products, though four of these LEAs believed that doing so could improve the quality and relevance of the products FinCEN provides to its customers. We recommended that FinCEN establish a process for soliciting input regarding the development of its analytic products. FinCEN agreed with our recommendation and in April 2010 outlined a number of steps it plans to take to better assess law enforcement needs, including ongoing efforts to solicit input from LEAs. Finally, liaisons from four of FinCEN's top five federal LEAs reported that their agencies do not have sufficient opportunities to provide input when FinCEN is considering regulatory changes because their comments often contain sensitive information that may compromise investigative techniques or strategies used in ongoing investigations. We recommended that FinCEN develop a mechanism to collect sensitive information regarding regulatory changes from LEAs. In April 2010, FinCEN reported that it developed an approach for collecting sensitive information without making the comments publicly available.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the services and products that the  Department of the Treasury’s Financial Crimes Enforcement Network  (FinCEN) provides to law enforcement in support of their efforts to  investigate money laundering, terrorist financing, and other financial  crimes. Successful investigations into financial crimes can support the  prosecution of money laundering, drug trafficking, and terrorist  financing—crimes that have the potential to destabilize national  economies and threaten global security. The Bank Secrecy Act (BSA),  enacted in 1970, authorized the Secretary of the Treasury to establish anti- money laundering record keeping and reporting requirements for domestic  financial institutions to help prevent abuse of the nation’s financial  system. The BSA has three main objectives: create an investigative audit  trail through regulatory reporting standards; impose civil and criminal  penalties for noncompliance; and improve the detection of criminal, tax,  and regulatory violations. Under the BSA’s reporting requirements,  financial institutions must retain records and file BSA reports when doing  so would have a high degree of usefulness in criminal, tax, and regulatory  investigations or in the conduct of intelligence activities to protect against  international terrorism. For example, suspicious activity reports (SARs)  are filed by financial institutions to inform the federal government of any  suspicious transaction related to a possible violation of law or regulation.
FinCEN, established in 1990 to oversee the administration of the BSA,  helps to prevent financial crime by serving as a governmentwide, service- oriented, financial information-sharing agency to more than 275 federal  and state law enforcement agencies. In supporting law enforcement,  FinCEN administers the financial transaction reporting system for the  recordkeeping and reporting requirements mandated or authorized under  the BSA. FinCEN is also responsible for the administration of BSA  compliance in the financial industry and, as such, indirectly works to  support law enforcement by developing and implementing regulatory  standards so that law enforcement agencies have accurate and relevant  information for conducting financial crimes investigations. Among other  things, the support FinCEN provides to domestic law enforcement  agencies in their efforts to investigate and prosecute financial crimes  includes providing access to the BSA data to identify individuals, financial  transactions, or accounts suspected of being connected to money  laundering, terrorist financing, or other financial crimes. FinCEN also  responds to requests from law enforcement agencies for information  pertaining to specific investigations, and produces analytic products  covering a range of issues related to financial crimes. For example,  FinCEN has produced strategic reports examining the processes and  actors, both licit and illicit, involved in the flow of currency between the  United States and neighboring countries along various regions of the U.S.  borders. We issued a report in December 2009 that addressed FinCEN’s  role in supporting law enforcement efforts to investigate and prosecute  financial crimes such as money laundering and terrorist financing. My  statement today highlights findings and recommendations from that report  and addresses the extent to which the law enforcement community finds  FinCEN’s support useful in their efforts to address such crimes.
For our December 2009 report, among other things, we surveyed a  nonprobability sample of 29 federal and state law enforcement agencies  that included the primary users of FinCEN’s services and products in fiscal  years 2001 through 2007. In total, we received usable questionnaires from  25 of the 29 agencies we surveyed. We asked them about the extent to  which they found FinCEN’s services and products useful. We also  interviewed officials from 8 of the 25 federal and state law enforcement  agencies responding to our questionnaire including the agencies that  FinCEN has identified as its top five federal law enforcement customers  regarding the extent to which FinCEN’s support has contributed to their  investigations of financial crimes. We also reviewed a number of FinCEN  reports and strategic plans including an internal assessment of the support  FinCEN’s Analysis and Liaison Division (ALD) provides to its domestic  law enforcement customers. We conducted this work in accordance with  generally accepted government auditing standards. More detail on our  scope and methodology is included in our December 2009 report.
subsections: section_title: Law Enforcement Finds a Number of FinCEN’s Services and Products Useful, but Would Like More Information about Select Products and Opportunities to Provide FinCEN with Input about Some Types of Support
paragraphs: In our December 2009 report, we found that law enforcement agencies we  surveyed generally reported finding FinCEN’s services and products  useful, citing direct access to BSA data, on-site liaisons, and access to  financial information on people or organizations suspected of being  involved in significant money laundering or terrorist financing activities— known as the 314(a) process—as those that are among the most useful.  However, we found that FinCEN could (1) better inform law enforcement  of the types of complex analytic products that it can provide, (2) more  clearly define the types of requests for complex analytic support that it  will accept, and (3) actively solicit input on the development of complex  analytic products in order to help law enforcement better utilize FinCEN’s  expertise and enhance the value of the products it provides to law  enforcement. Finally, we found that while FinCEN has taken initial steps  to more actively solicit law enforcement input on proposed regulatory  actions, FinCEN lacks a mechanism to allow law enforcement agencies to  submit sensitive information regarding the potential impact of proposed  regulatory actions on financial crimes investigations.
Law enforcement agencies cited direct access to BSA Data, the  314(a) process, and on-site liaisons as the most useful services  FinCEN provides. Most law enforcement agencies responding to our  survey (16 out of 20) cited direct access to BSA data as most useful and 19  out of 22 agencies responding indicated that BSA data was the FinCEN  service they used most often. Liaisons from three of FinCEN’s top five  federal law enforcement customers noted that direct access to the BSA  database provides law enforcement a means to access these data in order  to help identify, deter, and detect money laundering or other potential  financial crimes related to a range of criminal activity. As a result of the  Uniting and Strengthening America By Providing Appropriate Tools  Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT  Act), FinCEN also introduced a new tool to further assist federal law  enforcement agencies in their investigations of financial crimes. This  tool, developed by FinCEN in response to Section 314(a) of the USA  PATRIOT Act, enables federal law enforcement agencies to reach out to  financial institutions across the country for potential information related  to financial crimes investigations. FinCEN facilitates the 314(a) process  through the use of a secure communications system. This system allows  law enforcement to quickly locate financial data, such as open accounts  and financial transactions related to ongoing investigations of persons,  entities, or organizations suspected of being involved in significant money  laundering or terrorist financing activities. Federal law enforcement  agencies reported that the 314(a) process is a key service offered by  FinCEN that provides case-specific and timely information to support  ongoing law enforcement investigations. Specifically, all 11 federal  agencies we surveyed that had a basis to judge the 314(a) process  responded that it was either very or extremely helpful. Finally, law  enforcement agencies reported that being able to maintain agency liaisons  on-site at FinCEN is another valuable service FinCEN provides, facilitating  law enforcement agency access to FinCEN’s services and products.  Specifically, all 9 of the federal law enforcement agencies responding to  the questionnaire that indicated they had on-site liaisons reported that it  was extremely helpful.
FinCEN has sought to increase its production of more complex  analytic products, which law enforcement agencies report are also  helpful in financial crimes investigations. As more law enforcement  agencies gained the ability to directly access the BSA data and conduct  their own searches of the data, their reliance on FinCEN to conduct basic  queries on their behalf has decreased. We reported that from 2004 through  2007, requests to FinCEN to conduct such queries decreased 80 percent  from 2,048 to 409.As a result, FinCEN has identified a need to redefine its  role in supporting law enforcement agencies and to enhance the value and  relevance of its analytic work. As part of this effort, in recent years  FinCEN has sought to increase its production of more sophisticated  complex analytic products. These products range from complex tactical  case support requiring large-scale BSA data analysis, to a variety of  strategic projects, studies, and trend analyses intended to identify and  explain money laundering methodologies or assess threats posed by large- scale money laundering and terrorist financing activities. For example, in  2007 FinCEN provided a study to one law enforcement agency that  identified currency flows between the United States and another country  which helped this agency to identify potential patterns in drug trafficking.  Based on responses to our survey and interviews, law enforcement  agencies reported general satisfaction with FinCEN’s analytic products.  For example, when asked why they requested analytic support from  FinCEN, 15 out of 17 agencies that indicated they had made such requests  reported that they did so because they believed FinCEN has unique  expertise related to analyzing the BSA data. Additionally, liaisons from all  of FinCEN’s top five federal law enforcement customers specifically  highlighted technical reference manuals as one of the most useful complex  analytic products FinCEN produces. FinCEN’s technical reference  manuals provide practical information on a variety of issues, including  how particular financial transfer or payment mechanisms may be used to  launder money.
FinCEN could better inform law enforcement about the types of  complex analytic products it can provide and when those products  become available. We reported that according to liaisons from three of  FinCEN’s top five federal law enforcement customers, FinCEN does not  provide detailed information about each type of product that would help  law enforcement agencies to fully understand the various types of support  FinCEN can provide. Senior ALD officials also acknowledged that they  could clarify and better communicate to their law enforcement customers  the various types of complex analytic products FinCEN can provide. In  addition, in both interviews and in response to open-ended survey  questions, officials from 7 of the 25 law enforcement agencies we  surveyed, including three of FinCEN’s top five federal law enforcement  customers, also indicated that they would like more information about  when completed products become available. These liaisons noted that  because FinCEN does not actively communicate with them about when  completed products are available, they may not be aware of all of  FinCEN’s products that could be useful in their investigations of financial  crimes. Similarly, an official from one of FinCEN’s top five federal law  enforcement customers noted that, in some cases, analyses FinCEN  conducts for one customer might also be useful to the investigations of  other financial crimes.
In an internal report generated by ALD staff in August 2008, ALD officials  acknowledged that law enforcement liaisons reported that they would like  FinCEN to provide clear guidance on the dissemination of its products.  FinCEN officials also noted that they typically observe the “third-party  rule” on dissemination of information obtained from the requesting agency  and, in some cases, this may limit their ability to share products that are  completed in response to a request from a single customer. The rule  generally provides that information properly released by one agency to  another agency cannot be released by the recipient agency to a third  agency without prior knowledge and consent of the agency that originally  provided the information. The third-party rule applies to all data and  information FinCEN receives from the agencies with which it works on a  specific project. However, officials further stated that they are committed  to looking for ways to better publicize FinCEN’s analytic work and will  continue to do so within the framework of adequately protecting the  information provided to them. While we recognize the need for FinCEN to  protect sensitive information, establishing a process to clarify and  communicate to law enforcement when and under what circumstances  FinCEN can or will attempt to share analytic products with other law  enforcement customers will help ensure that it is effectively carrying out  its mission to support the investigation and prosecution of financial  crimes. We recommended that FinCEN clarify and communicate to law  enforcement agencies the various types of complex analytic products  FinCEN can provide and establish a process for informing law  enforcement agencies about the availability of these products. FinCEN  agreed with our recommendation and outlined plans it would take in order  to improve communication with law enforcement regarding the services,  products, and capabilities FinCEN offers. In response to our report,  FinCEN officials stated that they would compile an inventory of analytic  products historically produced, those FinCEN should produce, and those  requested by law enforcement. FinCEN officials reported that it would  consult with law enforcement partners to refine its recommendations, and  then categorize and describe the types of analytic products for law  enforcement.
In April 2010, we obtained updated information from FinCEN on the  status of its efforts to address our recommendations. Specifically,  FinCEN officials stated that its Office of Law Enforcement Support  (OLE) created a draft “Menu of Products and Services” which is  intended to clarify the types of products and services FinCEN’s  analytical operation can provide. According to FinCEN officials, OLE  also created a draft “Menu of Resources” which describes the data  sources and other tools available to FinCEN analysts that can be  utilized in the course of their analytical support operations. These  officials explained that, while these documents are still in draft form,  once they are finalized, they will be distributed to its law enforcement  customers through FinCEN’s Secure Outreach Portal, on their intranet,  and through direct and e-mail contact between FinCEN personnel and  external agencies.
Defining the types of requests for complex analytic support that  FinCEN will accept could also help law enforcement better utilize  FinCEN’s expertise in analyzing the BSA data. While FinCEN has  informed law enforcement that it is now focusing the support it provides  predominantly on those requests that it considers to be for complex  analytic support, we found that it could better inform law enforcement  about its decision-making process regarding what requests it will accept or  reject. Law enforcement agencies may submit requests for complex  analysis in support of specific investigations; however, in interviews with  officials from FinCEN’s top five federal law enforcement customers,  liaisons from two of these agencies stated that they did not fully  understand what types of cases FinCEN is willing and able to support.  Furthermore, in response to an open-ended survey question on FinCEN’s  analytic support, officials from two other law enforcement agencies  reported that they do not fully understand FinCEN’s decision-making  process for accepting or rejecting requests for support. These agencies  indicated that while they understand that FinCEN has limited staff and  resources to dedicate to analytic support, FinCEN has not been consistent  in responding to their requests for support and does not always provide  explanations why specific requests were rejected.
In addition, in the internal report generated by ALD staff in August 2008,  ALD officials acknowledged confusion among law enforcement customers  about the types of requests FinCEN will accept, as well as law  enforcement agencies’ concern that FinCEN does not sufficiently explain  the reasons for declining specific requests for support. Senior officials  acknowledged the report’s findings and as a first step, reorganized ALD in  October 2009 in order to realign resources to better meet law  enforcement’s needs. For example, FinCEN officials reported that they  created a new office within ALD that is responsible for providing proactive  analysis of BSA data and communicating regularly with law enforcement  agents in the field. The officials stated that they believe the creation of this  office will allow them to leverage analytical assets and abilities across  FinCEN to better inform all of their partners within the law enforcement,  intelligence, regulatory, and financial communities.  ALD also identified  the development and implementation of processes to improve  communication with its law enforcement customers as a 2010 priority.    We recommended that FinCEN complete a plan, including identifying the  specific actions FinCEN will take to better assess law enforcement needs,  and make the division’s operations more transparent to FinCEN’s law  enforcement customers. This plan should include a mechanism for  FinCEN to communicate to law enforcement agencies its decision-making  process for selecting complex analytic products to pursue and why  FinCEN rejects a request. FinCEN agreed with our recommendation and  stated that in October 2009, it began an effort to address communication  with law enforcement on three levels: analytical products, workflow  process, and outreach. The teams assessing workflow processes and  outreach efforts will make recommendations that will include provisions  for better assessment of law enforcement needs and more insight into  FinCEN’s decision-making on complex analytical products.
In April 2010, FinCEN officials reported that they have taken steps to  collect information about law enforcement customer’s priorities, needs,  and plans. For example, FinCEN officials reported plans to create a survey  to capture law enforcement agencies’ specific investigative focus and  needs. Furthermore, the officials stated that personnel from the Office of  Law Enforcement Support working in consultation with law enforcement  representatives drafted a new data collection form for documenting  requests for analytic support from law enforcement. FinCEN officials also  reported that they have established a process for reviewing and  responding to requests and informing the requester of FinCEN’s final  decision. According to FinCEN officials, once requests have been  reviewed, completed forms will be scanned and retained for future  reference so that requestors may be informed as to why requests were  accepted or denied.
Actively soliciting input on the development of complex analytic  products could help FinCEN enhance their value to law  enforcement agencies. While FinCEN communicates with its law  enforcement customers about a variety of issues, we reported that the  agency could enhance the value of its complex analytic work by more  actively soliciting law enforcement’s input about ongoing or planned  analytic work. In interviews with officials from FinCEN’s top five federal  law enforcement customers, liaisons from all five agencies reported that  FinCEN does not consistently seek their input about ongoing or planned  analytic work. Four of the liaisons stated that, as a result, they do not have  regular opportunities to provide FinCEN with meaningful input about  what types of products would be useful to them, potentially creating a gap  between the products the agency generates and the products that its law  enforcement customers need and want. Similarly, three other law  enforcement liaisons noted that FinCEN does not provide them with  regular opportunities to make proposals regarding the types of complex  analytic products FinCEN should undertake. According to FinCEN  officials, while the agency primarily relies on ad hoc communication with  law enforcement agencies—such as talking with law enforcement  representatives located on-site, with law enforcement representatives at  conferences, or with individual agents in the field—FinCEN does not have  a systematic process for soliciting input from law enforcement agencies on  the development of its complex analytic work.
In their August 2008 internal report, ALD officials acknowledged the  concerns of its law enforcement customers regarding their lack of  opportunities to provide input on FinCEN’s planned complex analytic  work, and that FinCEN does not always solicit or incorporate law  enforcement input in the selection of these products. As a solution, the  internal report recommended that the law enforcement roundtable be  used as a forum to discuss proposals for analytic products with FinCEN’s  law enforcement customers. While this is a productive step, relying solely  on the roundtable may not allow opportunities for some of FinCEN’s other  law enforcement stakeholders to provide input because the roundtable is  typically only attended by federal law enforcement customers.  Furthermore, not all of FinCEN’s federal law enforcement customers are  able to regularly attend these meetings.
FinCEN does use annual surveys and feedback forms to obtain feedback  from law enforcement on the usefulness of some completed products,  although these surveys and forms are not designed to obtain detailed  information on the full range of services and products FinCEN provides.  For example, the annual surveys do not cover other analytic products such  as FinCEN’s strategic analysis reports or its technical reference guides.  Actively soliciting stakeholder input and providing transparency with  regard to decision making are GAO-identified best practices for effectively  meeting stakeholder needs. Incorporating these best practices could help  FinCEN maximize the usefulness of its support. FinCEN officials  emphasized that law enforcement also has a responsibility to provide  constructive input on FinCEN’s services and products. While we recognize  that communication between FinCEN and its law enforcement customers  is a shared responsibility, actively soliciting stakeholder input will allow  FinCEN to capture stakeholder interests and better incorporate law  enforcement perspectives into the development of complex analytic  products. As a result, we recommended that FinCEN establish a  systematic process for actively soliciting input from law enforcement  agencies and incorporating this input into the selection and development  of its analytic products. FinCEN agreed with this recommendation and  outlined efforts it plans to undertake in response to our findings.  In  October 2009, according to FinCEN officials, ALD established an Office of  Trend and Issue Analysis (OTI) which is to focus on the development of  strategic-level analysis of Bank Secrecy Act data. FinCEN officials also  reported that ALD reassigned a number of its field representatives to OLE  in order to better utilize their experience and to enhance communication  with law enforcement customers. Finally, FinCEN stated that it also plans  to design an institutional process for collecting the kind of information  required to gain broader insight into its law enforcement partners’  priorities. In providing updates on their efforts to address our  recommendations, FinCEN officials stated that they are making a  concerted effort to engage their law enforcement customers at a variety of  o rganization levels to determine their key priorities and how FinCEN can  est support their priorities and strategic goals.
FinCEN has taken initial steps to more actively solicit law  enforcement input on proposed regulatory actions, but lacks a  mechanism for collecting sensitive information about these  actions. Regulatory changes instituted by FinCEN can affect the content  or structure of BSA data used in law enforcement investigations as well as  law enforcement’s efforts to indict and prosecute financial crimes.  However, we reported that liaisons from four of FinCEN’s top five federal  law enforcement customers reported concerns that their agencies do not  have sufficient opportunities to provide input when FinCEN is considering  proposed regulatory changes. The internal report ALD generated in August  2008 also recognized that changes to BSA regulations have the potential to  alter the kind of information that financial institutions report. The report  also acknowledged federal law enforcement agencies’ concerns that  FinCEN does not generally engage them in the identification and  resolution of regulatory issues that might influence law enforcement  operations. According to senior FinCEN officials, the agency recognizes  the need to do a better job of obtaining law enforcement input on  proposed regulatory changes in the future and did so in one recent case.  Specifically, in developing regulations in 2009 related to stored value  cards, such as prepaid debit cards and gifts cards, FinCEN held multiple  meetings with representatives from its top five federal law enforcement  customers specifically designed to obtain their input and provide  recommendations on developing the proposed regulation. FinCEN also  used the law enforcement roundtable to inform agencies about the  planned regulatory changes. FinCEN’s efforts to actively solicit law  enforcement input in this case are encouraging, and continuing such  efforts would help ensure that law enforcement input is considered before  regulatory changes are made.
Once FinCEN has decided to move forward with a proposed regulatory  change, it follows the process laid out in the Administrative Procedure Act  (APA) for obtaining official comments on the proposal from interested  stakeholders including regulators, financial institutions, and law  enforcement agencies. The APA prescribes uniform standards for  rulemaking and most federal rules are promulgated using the APA- established informal rulemaking process, also known as “notice and  comment” rulemaking. Generally, a notice of proposed rulemaking  (NPRM) is published in the Federal Register announcing an agency’s  intent to promulgate a rule to the public. However, we reported that  liaisons from four of FinCEN’s top five federal law enforcement customers  reported that the public record is not always the most appropriate venue  for providing comments on proposed regulatory changes because their  comments often contain law enforcement sensitive information. According  to these officials, raising these concerns in a public forum may  compromise key investigative techniques or strategies used in ongoing  investigations. According to FinCEN officials, at the time of our review,  they did not have a systematic process for soliciting law enforcement- sensitive comments on proposed regulatory changes in a nonpublic  docket. The importance of stakeholder input in the process of proposing  regulatory changes is well established—it is the basis for the public  comment period in the NPRM process. In order to improve FinCEN’s  efforts to receive important information necessary to making decisions  about proposed regulatory changes, we recommended that FinCEN  develop a mechanism to collect law enforcement sensitive information  from law enforcement agencies during the public comment period of the  NPRM process. FinCEN agreed with our recommendation and stated that  it would determine and implement appropriate ways to communicate to  the law enforcement community its ability to receive and use law  enforcement sensitive information in this context. In April 2010, FinCEN  officials stated that they have developed an approach for collecting law  enforcement sensitive information during the public notice and comment  period of the NPRM process without making the comments publicly  available. According to FinCEN officials, FinCEN will advise law  enforcement, through the law enforcement liaisons, that they may provide  law enforcement sensitive information at the time of publication of each  NPRM and inform them that FinCEN will not post those comments or  make them publicly available.
Mr. Chairman, this concludes my statement. I would be pleased to respond  to any questions that you or other Members of the Subcommittee may  have.
section_title: Contacts and Acknowledgements
paragraphs: For questions about this statement, please contact Eileen R. Larence at  (202) 512-8777 or larencee@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement.
In addition to the contact above, individuals making key contributions to  this statement include Kirk Kiester, Assistant Director; Samantha Carter,  and Linda Miller. Additionally, key contributors to our December 2009  report include Hugh Paquette, Miriam Hill, David Alexander, George  Quinn, Jr., Billy Commons, Jan Montgomery, and Sally Williamson.
This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.