Defense Trade: State Department Needs to Conduct Assessments to Identify and Address Inefficiencies and Challenges in the Arms Export Process
Published: 2007-11-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: To regulate the export of billions of dollars worth of arms to foreign governments and companies, the Department of State's (State) Directorate of Defense Trade Controls (DDTC) reviews and authorizes export licenses and other arms export cases. While such reviews require time to consider national security and foreign policy interests, the U.S. defense industry and some foreign government purchasers have expressed concern that the U.S. export control process is unnecessarily time-consuming. In 2005, GAO reported that processing times for arms export cases had increased despite State efforts to streamline its process. GAO was asked to (1) describe recent trends in the processing of arms export cases and (2) identify factors that have contributed to these trends. To conduct its work, GAO obtained and analyzed State arms export case data for fiscal year 2003 through April 30, 2007; reviewed relevant laws, regulations, and guidelines, as well as DDTC funding and staffing information; and interviewed State and Department of Defense officials and selected arms exporters.
section_title: What GAO Found
paragraphs: Three key trends indicate that DDTC's arms export licensing process is under stress. First, the number of arms export cases processed by DDTC increased 20 percent between fiscal years 2003 and 2006. Most of this increase was for licenses for permanent export. Second, during the same period, median processing times almost doubled. Third, the number of open arms export cases increased 50 percent from about 5,000 in October 2002 to about 7,500 in April 2007, with a high of more than 10,000 cases in September 2006. At the beginning of fiscal year 2007, DDTC launched a campaign to reduce the growing number of open cases. Through extraordinary measures--such as canceling staff training, meetings, and industry outreach, and pulling available staff from other duties to process cases--DDTC was able to cut the number of open cases by 40 percent in 3 months. However, such measures are not sustainable in the long term, do not address underlying inefficiencies and problems, and may have negative unintended consequences for the mission. While some blips in the trends can be attributed to onetime events or efforts--such as DDTC's campaign to reduce open cases--procedural inefficiencies, electronic processing system shortcomings, and human capital challenges underlie the overall trends. For example, GAO's analysis shows that DDTC is taking increasingly longer to refer cases to other agencies or State bureaus for additional review--from 7 days in fiscal year 2003 to 20 days during the first 7 months of fiscal year 2007. In addition, implementation of DDTC's electronic system for submitting applications has been problematic, and electronic processing has not been the promised panacea for improving processing times. DDTC does not perform systematic assessments to identify root causes of increased workload, processing times, and open cases and, in turn, develop sustainable solutions.

section_title: Letter
paragraphs: The State Department (State), through the Directorate of Defense Trade  Controls (DDTC), regulates the export of billions of dollars worth of arms  by U.S. companies to foreign governments and companies and has  responsibility for reviewing and authorizing export license applications  and other arms export cases. Reviews of arms export cases require time  to deliberate because U.S. national security and foreign policy interests  must be considered. However, the U.S. defense industry and some foreign  government purchasers have expressed concern that the U.S. export  control process is unnecessarily burdensome because of the time needed  to complete these deliberations. To facilitate defense cooperation, State  announced in 2000 several efforts to reduce arms export processing times,  and began the development of a new automated system for submitting and  reviewing cases. Despite efforts to streamline the process, we reported  that processing times for arms export cases began to increase in 2003.
Over the past decade, we have reported on various problems in the U.S.  export control system. Vulnerabilities in the U.S. export control system,  along with related government programs, prompted GAO to designate the  effective protection of technologies critical to U.S. national security  interests as a new high-risk area in 2007. This report looks at a key  component of the arms export control system—the licensing review  process for arms export cases. Because of concerns about increasing  processing times and a DDTC announcement of a significant number of  open cases, you requested we evaluate the processing of arms export  control cases. Specifically, this report (1) describes recent trends in the  processing of arms export cases, including processing times and open  cases, and (2) identifies factors that have contributed to the trends in  processing these cases.
To conduct our work, we obtained and analyzed State arms export case  data for fiscal year 2003 through April 30, 2007, to identify processing  trends. We assessed the reliability of the data and determined them to be  sufficiently reliable for our purposes. We also examined DDTC and  Department of Defense (DOD) case processing guidelines, DDTC funding  and staffing information, and applicable laws and regulations. In addition,  we interviewed officials from DDTC, State’s bureaus to which cases are  referred, DOD’s Defense Technology Security Administration (DTSA), and  selected arms exporters to identify factors affecting processing trends. For  more on our scope and methodology, see appendix I. We performed our  review from February through September 2007 in accordance with  generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Under the authority of the Arms Export Control Act, State regulates and  controls arms exports by U.S. companies to help ensure that those exports  are consistent with national security and foreign policy interests. This  function has been delegated to DDTC within the Bureau of Political- Military Affairs. DDTC’s staffing levels are allocated and funded by State.  Funding for other DDTC activities and operations comes from two main  sources: (1) appropriated funds that State then allocates to DDTC through  the Bureau of Political-Military Affairs, and (2) registration fees, which  DDTC is authorized to retain to help fund certain activities related to  licensing, enforcement, and compliance.
Exporters submit arms export cases via paper or electronically through D- Trade, DDTC’s Web-based electronic processing system. Cases include  permanent arms export licenses, temporary arms exports or imports,  agreements between U.S. industry and foreign entities to provide technical  assistance or manufacturing capability, requests for amendments to  existing licenses or agreements, and requests to determine commodity  jurisdiction. Cases vary in terms of complexity and time to process. For  example, agreements generally take longer than other cases because they  are complex, require substantial work by licensing officers, and often  require interagency review.
Once cases are received, DDTC assigns them to one of five teams, based  on commodity categories: firearms, aircraft, missile and spacecraft,  military electronics, and military vehicles and naval vessels. Team leaders,  in turn, assign cases to a licensing officer, who conducts an initial review  to determine whether the case needs a referral to an agency, such as  DOD’s DTSA, and/or another State bureau for additional review—or  whether the case can be reviewed and analyzed internally. Either way, the  licensing officer conducts the final review and determines the final action.  Final action on cases can only be taken by licensing officers with  designated signature authority, which DDTC officials stated takes an  average of 18 months of training and experience to obtain. Prior to  approving cases that involve exports meeting statutory dollar thresholds  and involving selected countries, State must notify Congress. Figure 1  depicts DDTC’s licensing review process.
In addition to reviewing arms export cases, DDTC conducts outreach to  educate industry about export controls and promote compliance with laws  and regulations.
section_title: Trends Indicate DDTC’s Licensing Process Is Under Stress
paragraphs: Our analysis shows several trends have emerged in the processing of arms  export cases, which indicate the system is under stress. First, the number  of arms export cases processed by DDTC has increased since fiscal year  2003. Most of the increase was for licenses for permanent export. Second,  processing times almost doubled from fiscal year 2003 to 2006. Third, the  number of open arms cases has increased since fiscal year 2003. While  extraordinary actions taken by DDTC to address the mounting number of  open cases achieved short-term gains, these actions are not sustainable  because they strained personnel and involved deferring other mission- related activities.
subsections: section_title: Arms Export Caseload, Processing Times, and Open Cases Have Significantly Increased
paragraphs: Between fiscal years 2003 and 2006, the arms export caseload processed  by DDTC has increased 20 percent, from about 55,000 to 65,000. DDTC  officials attributed this growth to several possible factors, including  increased globalization of the defense industry and an overall increase in  arms exports. In addition, our analysis of the cases processed by DDTC  shows that permanent export licenses constituted about two-thirds of all  cases, thereby accounting for the major part of DDTC’s caseload activity.  For these cases, the greatest increase occurred in aircraft and related  components among the various types of controlled commodities. Our  analysis also showed a high concentration of cases by country of  destination—almost half consisted of seven countries, with 25 percent  involving Japan and the United Kingdom. In contrast, we found cases are  not concentrated by major defense arms exporting companies. In fiscal  year 2006, only 21 percent of cases processed involved the top 10 arms  exporting firms. (For additional analyses of cases, including type of case,  commodities, countries, and expedited cases, see app. II.)
Overall, processing times for all types of cases have increased. Between  fiscal years 2003 and 2006, median processing times nearly doubled, from  14 days to 26 days. Some types of cases take longer to process than others,  in part because of their complexity. For example, in fiscal year 2006,  technical assistance agreements took a median of 94 days to process.  However, these agreements made up less than 9 percent of the cases  processed for that year, and therefore may not be a significant driver of  overall increased processing times. Permanent exports, which constituted  the majority of cases, took a median of 25 days to process in fiscal year  2006.
For nonreferred cases, which made up about two-thirds of all cases,  DDTC’s in-house processing times increased significantly. For example,  between fiscal years 2003 and 2006, median processing times for  nonreferred cases increased from 8 to 19 days. For the first 7 months of  fiscal year 2007, the median processing time was 17 days. Moreover, the  number of nonreferred permanent export license cases taking longer than  2 weeks to process increased from 26 percent in fiscal year 2003 to   72 percent in fiscal year 2006. The increase in the percentage of  nonreferred agreements taking longer than 2 weeks was even more  dramatic—increasing from about 13 percent to 87 percent (see fig. 2).
Processing times for cases referred outside of DDTC for review, which  made up about one-third of all cases, have also increased. For example,  between fiscal years 2003 and 2006, median processing times increased  from 49 to 61 days. For the first 7 months of fiscal year 2007, the median  processing time was 50 days. Moreover, in fiscal year 2006, 70 percent of  referred agreement cases, which tend to take longer to process than other  cases, took longer than 12 weeks to process, compared to 11 percent in  fiscal year 2003. In contrast, processing times for permanent export  license cases referred outside of DDTC have held relatively steady for the  past several years (see fig. 3).
The number of open arms export cases has also increased because DDTC  has received cases at a higher rate than it processed them. Open cases  increased from about 5,000 in October 2002 to about 7,500 in April 2007,  reaching a high of more than 10,000 open cases in September 2006 (see   fig. 4).
section_title: Actions Taken by DDTC to Achieve Short-Term Gains Are Unsustainable
paragraphs: At the beginning of fiscal year 2007, DDTC launched its “winter offensive,”  a campaign to reduce the growing number of open cases. Through  extraordinary measures—such as extending work hours; canceling staff  training, meetings, and industry outreach; and pulling available staff from  other duties to process cases—DDTC was able to reduce the number of  open cases by 40 percent in 3 months. However, DDTC officials told us  that these measures were not sustainable for the long term because they  put a strain on personnel and deferred mission-related activities.
Not only are these short-term measures unsustainable, they may have  unintended adverse consequences. A DDTC official stated the short-term  emphasis during the winter offensive was necessary to reduce the number  of open cases but may have the unanticipated effect of shifting the focus  from the mission of protecting U.S. national security and promoting  foreign policy interests to simply closing cases to reduce the queue of  open cases.
section_title: Systemic Inefficiencies Underlie Overall Trends in the Licensing Process
paragraphs: While some blips in the trends can be attributed to onetime events or  efforts, such as the winter offensive, the overall trends of increased  processing times and open cases are affected by several factors, including  procedural inefficiencies, electronic processing system shortcomings, and  human capital challenges. DDTC does not perform systematic assessments  to identify overall trends and root causes, which could lead to sustainable  solutions.
subsections: section_title: Case Processing Encumbered by DDTC Procedural Inefficiencies
paragraphs: While DDTC has established a time frame goal in its guidelines for  referring cases outside of DDTC, it has not met this goal. Specifically, the  guidelines indicate that DDTC licensing officers should refer cases to  other agencies or State bureaus within 10 days of receipt by the licensing  officer. Our analysis shows that DDTC has taken increasingly longer to  refer cases. As shown in table 1, the median days from when the case was  received to outside referral increased from 7 days in fiscal year 2003 to 20  days during the first 7 months of fiscal year 2007. In contrast, the median  number of days cases spent outside of DDTC for referral has decreased  over the same period from 31 to 18 days.
DDTC has not established procedures to promptly screen most cases to  identify those that need outside referral. As a result, cases often languish  in a team leader’s or licensing officer’s queue awaiting assignment or  initial review. In contrast, DOD’s DTSA—which receives the majority of  cases referred by DDTC—uses a team to screen cases daily to determine if  cases should be reviewed solely at DTSA or whether they should be  referred to military services or other DOD components for further review.  In making the decision to refer cases, the team considers such factors as  the existence of precedent cases, the level of technology, and the  circumstances of the transaction. According to DTSA officials, this  process allows them to expedite certain cases and to focus efforts on more  complicated cases involving commodities or capabilities not previously  exported or presenting special concerns. For referred cases, DTSA  officials told us the daily screening process allows them to make the  referral in less than 2 days on average. According to DDTC officials, they  have recently established a process for promptly referring technical  assistance agreements outside DDTC but have not done so for other types  of cases.
Until recently, DDTC lacked procedures for expediting certain cases.  Specifically, the Ronald W. Reagan National Defense Authorization Act for  Fiscal Year 2005, enacted in 2004, requires the expeditious processing of  arms export cases for the United Kingdom and Australia by State, in  consultation with DOD. Although the legislation does not specify a  processing time frame goal, in fiscal year 2006, the processing times for  United Kingdom and Australia cases was 21 days, which did not differ  significantly from the processing times for other allied countries. (For  additional analysis of processing times by country, see app. II.) DDTC  officials told us they have been working with DOD on developing  procedures to expedite processing for United Kingdom and Australia  cases, and recently established a process for doing so.
section_title: D-Trade Has Yet to Achieve Case Processing Efficiencies
paragraphs: The establishment of a new automated system for processing cases had  been cited by State officials as its most significant effort to improve  efficiency. However, the anticipated efficiencies have not been realized.  Our analysis of processing times shows no significant difference between  like types of cases submitted electronically versus paper submissions. For  example, in fiscal year 2006, median processing time for permanent export  cases submitted through D-Trade was 23 days versus 25 for paper  submissions. Although 77 percent of cases are now received electronically  through D-Trade, its implementation has been problematic and electronic  processing has not been the promised panacea for improving processing  times.
According to DDTC officials, poorly defined system requirements and a  rush to production led to technical glitches and performance problems.  For example, in January 2007, DDTC released a new version of D-Trade,  but because of software problems, cases received could not be processed.  As a result, the new version was shut down after 3 days, requiring DDTC to  revert to the previous version. The 1,300 cases received during the 3-day  period had to be resubmitted by exporters, resulting in some rework and  an increase in the number of open cases.
DDTC has relied on an information technology solution without  reengineering the underlying processes or without developing tools to  facilitate the licensing officer’s job. In 2001, we reported information  systems that simply use technology to do the same work, the same way,  but only faster typically fail or reach only a fraction of their potential.  While defense industry officials told us that D-Trade simplifies the process  for submitting cases and receiving final authorizations, the system lacks  tools to aid licensing officers to process cases more efficiently. For  example, the system has limited capabilities to reference precedent cases  that would allow licensing officers to leverage work previously done on  similar cases. The system also lacks other tools, such as automated access  to regulations, guidance, or other information that may facilitate  processing. DDTC officials said they expect future versions of D-Trade will  incorporate tools to help licensing officers process cases more efficiently.
section_title: DDTC Faces Staffing Instabilities
paragraphs: The fundamental work of reviewing and analyzing arms export cases  requires an adequate number of personnel with the right skills and  knowledge—especially given the continued rise in caseload. However,  ensuring a sufficient workforce with the needed skills and knowledge has  been a challenge for DDTC because of staffing instabilities. For example,  the number of licensing officers on board has fluctuated over recent years  and was at the same level in fiscal years 2003 and 2006, yet the number of  cases processed increased about 20 percent during the same period (see  table 2).
DDTC officials have acknowledged that more work is falling on fewer  experienced staff. According to these officials, in the summer of 2006,  about one-half of licensing officers had less than 1 year of experience, and  many did not have the signature authority needed to take final action on  cases. For example, early in 2007, one team had three licensing officers  but only the team leader had the authority to approve or deny cases.  Although the staff could perform research, the team leader had to review  all cases before final action could be taken.
Staffing instabilities have also been affected by fluctuating levels of  military officers detailed to DDTC from DOD, who are generally assigned  to review agreements. The Foreign Relations Authorization Act for Fiscal  Year 2003 states the Secretary of Defense should ensure that 10 military  officers are continuously detailed to DDTC. However, the number of  officers DOD detailed to DDTC has fluctuated over recent years. In fiscal  year 2006, the number of military officers detailed to DDTC ranged from 3  to 7. From fiscal year 2005 to 2006, processing times for agreements nearly  doubled from 48 days to 94 days. In fiscal year 2007, the number of military  officers increased to 8, and by April 2007, processing times for agreements  was 72 days. To help address the potential adverse effect of insufficient  numbers of military officers, DDTC began assigning additional civilian  licensing officers to process agreements in 2006.
section_title: DDTC Does Not Conduct Systematic Assessments to Identify Root Causes of Problems and to Develop Sustainable Solutions
paragraphs: DDTC management does not systematically assess licensing data to  identify inefficiencies. Analysis of these data could allow DDTC to more  effectively structure its workforce and manage workload. Instead, DDTC  management reviews reports consisting of aggregate information on  received, processed, and open cases to determine the status of cases and  licensing officer productivity. However, DDTC cannot identify the drivers  of the workload or bottlenecks in the process from these status reports.  Using DDTC’s data, we conducted analyses of factors that can drive  workload, such as type of cases, commodities, countries, and profiles of  the exporter base (see app. II). Such analyses could provide insights to  managers on ways to reduce workload, structure the workforce, target  outreach with industry, and reengineer processes. For example:    By examining caseload by type of commodity, DDTC could assess the  impact on workload of potential changes to licensing requirements  such as application of or modification to exemptions—if such changes  are warranted given the national security risk and foreign policy  interests.
Given DDTC’s current organizational structure of teams associated  with particular commodities, DDTC could examine its licensing data to  determine if there is a concentration of cases by factors other than  commodity, such as country. Such analyses could permit DDTC to  consider possible efficiencies related to aligning its workforce to where  its workload is concentrated. Also, by monitoring processing times for  factors driving the workload, DDTC could take corrective actions and  reallocate resources before processing times for some types of cases  become a problem.
By assessing the volume and type of case submissions by exporters,  DDTC could better target its industry education and outreach activities  to help ensure the quality of submissions and compliance with export  control law and regulations.
DDTC could analyze the processing times associated with steps in the  licensing process—such as time it takes to refer cases—to assess the  flow of cases through the review process and identify possible  bottlenecks or inefficiencies in the process.
While DDTC has taken actions to achieve some short-term gains to  growing problems in its processing of cases, DDTC managers lack  systematic analyses to identify root causes and develop sustainable  solutions. Federal managers, including those at DDTC, need to monitor  and assess their systems to ensure that they are well designed and  efficiently operated, are appropriately updated to meet changing  conditions, and provide reasonable assurance that the objectives of the  agency are being achieved.
section_title: Conclusions
paragraphs: The licensing of arms exports is a key component of the U.S. export  control system to help ensure arms do not fall into the wrong hands.  Licensing officers are challenged to weigh national security and foreign  policy interests on thousands of cases a year while allowing legitimate  defense trade to occur in an efficient manner. However, systemic  inefficiencies in arms export licensing are straining the system and may be  diminishing licensing officers’ capacity to process cases efficiently and  effectively. To date, DDTC has not comprehensively analyzed its export  processing system to identify causes of inefficiencies and needed actions  to address them. Unless DDTC systematically analyzes its licensing data in  terms of drivers of workload and steps in the process, it will continue to  ineffectively and inefficiently manage its processes, workload, and  resources.
section_title: Recommendation for Executive Action
paragraphs: To improve the efficiency of processing arms export cases, we  recommend that the Secretary of State direct the Deputy Assistant  Secretary of the Directorate of Defense Trade Controls to conduct  systematic analyses of licensing data to assess root causes of inefficiencies  and to identify and implement actions to better manage workload,  reexamine its processes, determine the most effective workforce  structure, and target industry outreach.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Departments of State and Defense  and for their review and comment. DOD did not comment on our draft.   State provided written comments that are reprinted in appendix III. In  commenting on the draft, State concurred with our recommendation and  recognized the need for additional systematic analyses of data to achieve  greater efficiencies. State noted that the report does not reflect the impact  of three recent initiatives, which according to State resulted in a  30 percent reduction of open cases from April to October 2007. Because  our analysis was through April 2007, we are not able to verify what  effects—both short- and long-term—the initiatives have had on the  number of open cases. Until State engages in a continual process of  systematically analyzing its licensing data, it will have no assurance that  current or future initiatives will address the underlying causes and achieve  sustainable improvements to the processing of arms export cases.
As agreed with your office, unless you publicly release its contents earlier,  we plan no further distribution of this report until 30 days from the date of  this letter. At that time, we will send copies of this report to interested  congressional committees, as well as the Secretaries of State and Defense;  the Director, Office of Management and Budget; and the Assistant to the  President for National Security Affairs. In addition, this report will be  made available at no charge on the GAO Web site at http://www.gao.gov.
Please contact me at (202) 512-4841 or calvaresibarra@gao.gov if you or  your staff have any questions concerning this report. Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Others making key contributions to this report  are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine trends in arms export case processing by State’s Directorate  of Defense Trade Controls (DDTC), we obtained State’s arms export case  data for fiscal year 2003 through April 30, 2007. We obtained data from  State’s paper-based “legacy” system and its D-Trade system—a Web-based  electronic processing system. We merged the data from these two systems  and created a single Microsoft Access database to determine trends in  caseload, cases processed, open cases, and processing times. Our analysis  did not include cases that were approved and then subsequently  suspended or revoked because this action takes place after the original  cases were closed, and including these cases would thus skew the results.  Processing time represents the median number of calendar days between  receipt of a case and the final action. Open cases are those cases that were  received by DDTC but on which no final action has been taken. To obtain  an overview of the data systems used to accept and process license cases  at DDTC, we interviewed State officials responsible for information  technology management. We assessed data reliability by obtaining and  reviewing system documentation and performing electronic testing of  data, and determined the data to be sufficiently reliable for our intended  purposes. We also analyzed the data by type of license, commodities,  countries, cases referred, cases in support of ongoing war efforts,  exporters, and case final actions.
To identify factors contributing to trends in processing times and open  cases, we interviewed officials from DDTC, State bureaus to which cases  are most frequently referred, the Department of Defense’s (DOD) Defense  Technology Security Administration (DTSA), and selected arms exporters.  To understand the process of reviewing arms export cases referred from  DDTC, we obtained and reviewed DDTC case review guidelines,  applicable regulations, and laws. We compared DDTC procedures with  DTSA case processing procedures. To determine the status of D-Trade, we  obtained briefings and systems documentation and discussed problems  with implementing the electronic processing system and future  development plans with cognizant officials. We also compared processing  times for D-Trade and paper processing by calculating processing times  for permanent exports, which are processed through both systems. We  obtained and analyzed data on DDTC funding and staffing levels. We also  obtained and reviewed DDTC status reports used to monitor workload,  processing times, and open cases.
section_title: Appendix II: Additional Analyses Related to Arms Export Case Processing
paragraphs: This appendix provides additional analyses of licensing data related to the  composition of cases closed and case outcomes. Specifically, we analyzed  the data in terms of types of cases, commodities, countries of destination,  cases in support of ongoing war efforts, exporters, and case final actions.
Of the 14 case types processed by DDTC, licenses for permanent exports  made up the majority of cases. From fiscal year 2003 to 2006, the  percentage of licenses for permanent exports increased from about  62 percent to over 66 percent of all cases, as shown in table 3.
Processing times varied by type of case, as shown in table 4. For example,  in fiscal year 2006, technical assistance agreements took a median of  94 days to process, while licenses for permanent exports, the most  common case type, took 25 days, and amendments to existing licenses  took 13 days to process.
For cases involving permanent export licenses, aircraft and related  components were the primary driver of increased cases, increasing about  44 percent, from about 9,800 in fiscal year 2003 to over 14,000 in fiscal year  2006, as shown in table 5. Processing times for permanent export licenses  also varied by type of commodity group and were increasing for most  commodities from fiscal years 2003 through 2006, with missile and  spacecraft taking the longest to process. Several commodity groups saw  reductions in processing times during the first 7 months of fiscal year  2007, including a significant reduction in missile and spacecraft.  Processing times for aircraft increased during each period.
Arms export cases are relatively concentrated by country of destination.  As shown in table 6, in fiscal year 2006, cases identifying Japan and the  United Kingdom as destination countries represented about 25 percent of  all cases. Processing times, with the exception of those for Israel, are  similar for the top countries of destination.
DDTC has procedures to expedite cases submitted in support of ongoing  war efforts including Operation Enduring Freedom (OEF) or Operation  Iraqi Freedom (OIF). These cases did not represent a significant  caseload—-ranging from 0.8 percent to 1.5 percent from fiscal year 2003  through 2006. Median processing times for these cases ranged from 8 to  11 days, as shown in table 7.
The number of exporters registered with DDTC that submitted cases  increased about 13 percent, from almost 2,500 in fiscal year 2003 to almost  2,800 in fiscal year 2006. However, most exporters submitted relatively few  applications, as shown in table 8.
In contrast, some exporters submit thousands of applications in a given  year. In terms of all cases received, the percentage of cases received from  the top 10 exporters in terms of cases submitted ranged from about 19 to  26 percent, as shown in table 9.
As shown in table 10, most cases processed by DDTC are approved or  approved with condition, known as a proviso. Very few cases are denied.  The number of cases returned without action increased from about  13 percent in fiscal year 2003 to over 17 percent in the first 7 months of  fiscal year 2007.
section_title: Appendix III: Comments from the Department of State
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact named above, Anne-Marie Lasowski, Assistant  Director; Bradley Terry; Peter Zwanzig; Jacqueline Wade; Arthur James,  Jr.; Julia Kennon; Karen Sloan; and Alyssa Weir made key contributions to  this report.
section_title: Related GAO Products
paragraphs: 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.
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 Security Environment. GAO-05-468R. Washington, D.C.:  April 7, 2005.
Defense Trade: Arms Export Control System in the Post-9/11  Environment. GAO-05-234. Washington, D.C.: February 16, 2005.
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.
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: State and Commerce Department License Review Times  Are Similar. GAO-01-528. Washington, D.C.: June 1, 2001.
Export Controls: Reengineering Business Processes Can Improve  Efficiency of State Department License Reviews. GAO-02-203.  Washington, D.C.: December 31, 2001.
Export Controls: System for Controlling Exports of High Performance  Computing Is Ineffective. GAO-01-10. Washington, D.C.: December 18,  2000.
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: Some Controls over Missile-Related Technology Exports  to China Are Weak. GAO/NSIAD-95-82. Washington, D.C.: April 17, 1995.