Antiterrorism Assistance: State Department Should Improve Data Collection and Participant Oversight
Published: 2017-09-28T00:00:00

Fast Facts:
The State Department spends more than $100 million a year to provide counterterrorism training, such as hostage rescue techniques, to foreign law enforcement personnel.
However, State's data on training courses and participants are incomplete and sometimes inaccurate. In addition, it doesn't have a process to confirm that participants trained outside their home countries return home to use the training. State was thus unaware that some participants have failed to go home after training.
We recommended that State improve its data and develop a process to confirm participants trained outside their own country return home.

Highlights:
section_title: Why GAO Did This Study
paragraphs: State's ATA program aims to enhance foreign partners' capabilities to prevent acts of terrorism, address terrorism incidents when they do occur, and apprehend and prosecute those involved in such acts. In fiscal years 2012 through 2016, State allocated about $715 million to the ATA program, which it reports to have used to train about 56,000 security force officials from more than 34 partner nations. At least 2,700 of those participants were trained at facilities in the United States.
GAO was asked to review ATA program management. This report examines, among other objectives, (1) State's ability to oversee ATA participants trained in the United States and (2) the steps State has taken to ensure that facilities used for domestic ATA training align with applicable security requirements. GAO conducted fieldwork at two domestic training facilities selected because they provide tactical training; analyzed State and DHS data and documentation related to fiscal year 2012 through 2016 domestic training participants; and interviewed State and DHS officials, including those who oversee ATA training for three partner nations receiving significant ATA training. GAO also interviewed contractors who help implement the ATA program and analyzed related documents.
section_title: What GAO Found
paragraphs: Weaknesses exist in Department of State (State) Antiterrorism Assistance (ATA) program data and oversight of participants, including those trained in the United States. ATA course and participant data are incomplete and sometimes inaccurate, despite ATA's procedures for the collection of those data. ATA officials told GAO that procedures were not always followed. Without ensuring the implementation of procedures to collect complete and accurate program data, officials may not be able to accurately report the number of participants trained, in line with program performance indicators. Among participants trained in the United States since 2012, ATA has documented 10 participant unauthorized departures from ATA activities and provided related information to the Department of Homeland Security (DHS) for follow-up. In addition to these 10, ATA recently identified 20 ATA participants trained in fiscal years 2012 through 2016 for whom departure from the United States following the completion of training is unconfirmed. ATA officials told GAO there is no formal process to confirm participants' return to their home countries following the completion of training (see fig.). Without such a process, ATA may not be able to assess the extent to which it is using training in line with program goals. Further, State may not be able to provide information to DHS about participants whose failure to depart may warrant enforcement action.
State and the contractors who implement ATA training have taken steps to ensure that facilities used for domestic training align with applicable security requirements. State's ATA training contract requires the secure storage of weapons and explosives and that the contractors have the relevant federal, state, and local permits. State reports overseeing the contractors through the receipt of copies of relevant licenses such as those required for possessing explosives; visits to the training facilities, including surveys examining storage security; and frequent meetings. Both of the domestic tactical training facilities that GAO visited had relevant licenses and, during site visits, GAO observed some suggested security measures, including fences, secured gates, and security patrols.
section_title: What GAO Recommends
paragraphs: State should ensure implementation of its data collection procedures and establish a process to confirm and document participants' return to their home countries. State agreed with both recommendations.

section_title: Letter
paragraphs: The United States and its foreign partners face a dynamic and evolving  terrorist threat environment. Instability in key regions of the world, along  with weak or nonexistent governance, sectarian conflict, and porous  borders, continues to provide terrorist groups like the Islamic State of Iraq  and Syria the opportunity to extend their reach, terrorize civilians, and  attract and mobilize new recruits. To combat this trend, the 2015 National  Security Strategy acknowledges that the United States’ obligations do not  end at its borders and embraces the responsibility to support international  security because it serves U.S. interests, upholds commitments to allies  and partners, and addresses threats that are truly global. To this end, the  United States provides billions of dollars in assistance annually to foreign  countries to train and equip their security forces.
The Department of State’s (State) Antiterrorism Assistance (ATA)  program’s primary mission is to enhance the capabilities of foreign  partner nations in the detection, deterrence, and prevention of acts of  terrorism, the resolution of terrorism incidents when they do occur, and  the apprehension and prosecution of those involved in such acts. In fiscal  years 2012 through 2016, State allocated more than $700 million to the  ATA program for training, mentoring, equipment, and other services to  help partner countries build or enhance their counterterrorism capabilities.
In December 2015, media reports alleged potential security vulnerabilities  at a subcontracted training facility used by ATA in the United States and  suggested possible weaknesses in State’s management of the ATA  program, including the vetting of potential participants, the security of  training facilities, and ATA participant unauthorized departures from  training. You asked us to review several aspects of ATA program  management. This report examines, for fiscal years 2012 through 2016,  (1) the steps State has taken to ensure that facilities used for domestic  ATA training align with applicable facility and equipment security  requirements; (2) the extent to which State has vetted domestic ATA  participants for human rights concerns and how State screens them for  terrorist activity; and (3) State’s ability to oversee ATA participants trained  in the United States.
To address these objectives, we examined documents from State and the  Department of Homeland Security (DHS), such as agency guidance and  procedures, and analyzed State participant, course, and human rights  vetting data for fiscal years 2012 through 2016, the most recent 5 fiscal  years for which complete information was available. We discussed ATA  program management topics with officials from State and DHS and with  U.S. embassy officials in three ATA partner nations—Bangladesh,  Indonesia, and Jordan—selected based on criteria such as number of  ATA participants trained and in light of countries included in recently  completed or ongoing GAO and State Inspector General reviews of the  ATA program. To determine what steps State has taken to ensure that  facilities used for domestic ATA training align with applicable facility and  equipment security requirements, we compared requirements in the  Global Antiterrorism Training (GATA) contract used to secure services to  manage and deliver ATA training activities to (1) documents obtained  from the contractors who implement ATA training and (2) observations we  made during investigative surveillance operations and escorted facility  site visits to two domestic training facilities where a significant proportion  of ATA domestic students were trained and that secured equipment on- site. To assess the extent to which State has vetted domestic ATA  participants for human rights concerns, we developed a generalizable  random sample of 98 participant names from 2,271 available ATA  participant data records. However, we could not generalize our findings  about vetting from these participants for whom ATA had records to those  participants who were not recorded in its electronic data system. We then  cross-checked the names in our sample with human rights vetting data  from State’s International Vetting and Security Tracking (INVEST) system  to verify that the ATA participants for whom vetting was required by State  guidance were vetted before receiving the training. To describe how the  ATA program screens participants for terrorist activity, we interviewed  State officials about their processes and embassy data systems used for  terrorist activity screening. We also compared the countries on State’s list  of state sponsors of terrorism to the countries for which ATA allocated  funding in fiscal years 2012 through 2016. To examine State’s ability to  oversee ATA participants trained in the United States, we analyzed ATA  participant and course data and participant arrival and departure data  from DHS’s Arrival and Departure Information System (ADIS). While we  found some accuracy and completeness limitations for these data as a  whole, as discussed later in the report, we identified a subset of 443  participant records with sufficient information for us to use in assessing  the length of participants’ stays in the United States after completing  training. We also reviewed relevant State, DHS, and contractor  documents, including State’s report on its analysis of departure data for  ATA participants trained at domestic facilities. We determined all data to  be sufficiently reliable for the purpose of this engagement by taking steps  such as comparing similar data from different sources; reviewing agency  information regarding underlying data systems; and interviewing  cognizant agency and contractor officials. For more detail on our scope  and methodology, see appendix I.
We conducted this performance audit from May 2016 to September 2017  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
We conducted our related investigative evaluation work—site  surveillance—in accordance with investigation standards prescribed by  the Council of the Inspectors General on Integrity and Efficiency.
subsections: section_title: Background
subsections: section_title: Antiterrorism Assistance Program Management
paragraphs: The ATA program was established in 1983 to provide assistance to  foreign countries in enhancing the ability of their law enforcement  personnel to deter terrorists and terrorist groups from engaging in  international terrorist acts such as bombing, kidnapping, assassination,  hostage taking, and hijacking. The stated purposes of the ATA program’s  activities are to (1) enhance the antiterrorism skills of friendly countries by  providing counterterrorism training and equipment; (2) strengthen bilateral  ties with partner nations by offering assistance; and (3) increase respect  for human rights by sharing modern, humane, and effective antiterrorism  techniques with foreign civil authorities.
Within State, management of the ATA program is undertaken as a  partnership between the Bureau of Counterterrorism and Countering  Violent Extremism (CT), which conducts policy formulation, strategic  guidance, and oversight, and the Bureau of Diplomatic Security (DS),  which administers and implements the program. In addition, ATA officials  work with officials from State’s regional bureaus and Regional Security  Officers at U.S. posts overseas to help ensure that appropriate ATA  participants are selected to receive training. Regional Security Officers  also help ensure that ATA activities target key focus areas, including the  threat of terrorism, individual country-level operational needs, and the  advancement of U.S. national security interests. ATA uses its own  training experts as well as those from other U.S. federal, state, and local  law enforcement agencies, police associations, and private security firms  and consultants to deliver a blend of training, mentoring, equipment,  advising, and consulting to partner nations.
section_title: ATA Funding Allocations for Fiscal Years 2012 through 2016
paragraphs: As shown in figure 1, in fiscal years 2012 through 2016, State allocated  approximately $715 million to the ATA program for training, mentoring,  equipment, and other services to help partner nations build or enhance  their counterterrorism capabilities.
As shown in table 1, State has obligated or disbursed about $543 million  (76 percent) of the approximately $715 million allocated to ATA in fiscal  years 2012 through 2016. Of the $172 million in unobligated funds, $136  million (79 percent) are fiscal year 2016 funds still available for obligation  through the end of fiscal year 2017. About $36 million of that $172 million  in unobligated balances were allocated in fiscal years 2012 through 2015  and thus, funds that were not obligated within the initial period of  availability for new obligations have expired. The Joint Explanatory  Statement to the Consolidated Appropriations Act, 2017, directs State to  conduct a review of unobligated ATA balances from fiscal year 2016.
State has reported that, since its inception in 1983, the ATA program has  trained and assisted more than 84,000 foreign security and law  enforcement officials from 154 countries. As shown in figure 2, in fiscal  years 2012 through 2016, State provided bilateral ATA assistance to 34  partner nations.
section_title: ATA Contract and Training Facilities
paragraphs: State implements ATA training through the GATA contract signed in  December 2011 and in effect during fiscal years 2012 through 2016,  according to State officials. ATA officials told us that they secured two  prime contractors to implement this contract who, in turn, manage  subcontracts with several training facilities. The majority of ATA training  occurs at facilities located abroad, either at facilities in recipient nations or  at regional facilities. For example, ATA has agreements in place with the  government of Jordan to use multiple facilities there to deliver ATA  training to participants from Jordan as well as from other U.S. partner  nations. According to State officials, as of June 2017, State was also  negotiating an agreement to use facilities in Kenya for regional ATA  training. In addition to overseas locations, about 10 percent of the ATA  courses in fiscal years 2012 through 2016 were delivered at training  facilities in the United States. State officials told us that training ATA  participants at domestic facilities also offers senior U.S. government  officials an opportunity to interact with partner nation officials, both of  whom benefit from the direct diplomatic interaction. While classroom  training is conducted in various localities across the United States,  according to ATA officials, two facilities have been subcontracted to  deliver tactical training: The O’Gara Group (O’Gara) located in Montross,  VA, and Academi a Constellis Company (Academi), located in Moyock,  NC.
In addition, State officials told us about two relevant modifications to ATA  program management that they are making or plan to make in relation to  the contract used to secure services for the delivery of ATA training and  locations to be used for ATA training activities. First, in March 2017, State  issued a request for proposals (RFP) for a new GATA contract that  makes some technical modifications to language we identified during our  engagement and that ATA officials determined was unclear. Second,  according to State officials, in fiscal year 2017, State finalized a shift of  nearly all training delivered at facilities in the United States to locations in  partner nations or regional training centers outside the United States.
According to State officials, this approach is expected to generate savings  on costs such as international travel and accommodations. Further, the  RFP for the new training contract states a preference to use State’s  planned Foreign Affairs Security Training Center, when it becomes  available, for any tactical training that is delivered in the United States.
section_title: Restrictions on Security- Related Assistance Based on Human Rights Concerns
paragraphs: To help ensure that U.S. assistance is not used to support those who  violate human rights, U.S. law prohibits the provision of assistance to  foreign security forces implicated in human rights abuses. Section 620M  of the Foreign Assistance Act of 1961 (also known as the State Leahy  law) prohibits the United States from providing assistance under the  Foreign Assistance Act or the Arms Export Control Act to any unit of the  security forces of a foreign country if the Secretary of State has credible  information that such unit has committed a gross violation of human  rights.
In response to the State Leahy law, State has established a human rights  vetting process to determine whether there is credible information of a  gross violation of human rights for any potential recipient of assistance,  such as ATA training. In accordance with State guidance, State may  conduct individual or unit-level vetting, depending on the circumstances.  This process generally consists of vetting by personnel representing  selected agencies and State offices at U.S. embassies and at State  headquarters in Washington, D.C.; State’s Bureau of Democracy, Human  Rights, and Labor (DRL); and the relevant geographic bureau. These  personnel are to screen prospective recipients nominated to receive  assistance by searching relevant files, databases, and other sources of  information for credible information about gross violations of human  rights. Each embassy determines which agencies and State offices  should participate in the embassy’s vetting process and, according to  ATA officials, each individual’s unit affiliation if conducting unit-level  vetting. Among other duties, DRL is responsible for overseeing the vetting  process and for developing human rights vetting policies, in coordination  with the regional and relevant functional bureaus. State processes,  documents, and tracks human rights vetting requests and results through  its INVEST system, a web-based database. ATA is to receive a list of  vetted individuals from DRL, through INVEST, and requires the GATA  contractors to cross-check that list with the participants who attend the  first day of training to ensure that each has been vetted before any course  information is presented.
section_title: ATA Participant Nonimmigrant Visas and Admission to the United States
paragraphs: Conducting ATA training in the United States rather than at locations  abroad requires additional logistical procedures that State and DHS must  undertake, including issuing visas and granting admission to participants  traveling to the United States, respectively. Prior to training in the United  States, ATA participants must apply for a visa at a U.S. embassy or  consulate abroad or with State’s Bureau of Consular Affairs. State’s  consular officers evaluate visa applications and issue nonimmigrant A-2  visas—those for foreign government officials and employees traveling to  the United States to engage solely in official duties or activities on behalf  of their national government—to eligible travelers coming to the United  States for ATA training.
When foreign nationals arrive at a U.S. port of entry for admission to the  United States to attend domestic ATA training, DHS officials determine  whether to admit them into the United States. DHS officials grant ATA  participants admission for what the agency refers to as duration of  status. According to State officials, ATA participants’ status is generally  tied to their participation in the associated ATA course and, therefore,  they will generally only be recognized as entitled to A-2 status during  participation in the ATA training and reasonable travel to and from the  United States.
While ATA participants are in the United States, they may be permitted to  apply to DHS for certain immigration benefits and changes in immigration  status, such as for asylum. According to DHS officials, ATA participants  also are not subject to travel restrictions and can depart training facilities  for purposes such as tourism and visiting family living in the United  States, so long as they also maintain their status as participants of their  ATA courses, by not being absent from training, for example.
According to State and DHS officials, if participants miss ATA course  activities without authorization, and do not attain an alternative  immigration status, they may become subject to removal procedures.  ATA officials told us that, upon arrival at domestic training facilities, ATA  participants receive a briefing from officials or contractors to ensure that  they understand that they should not depart the facility without  authorization and that any unauthorized departure will be reported to ATA  for further action. State and DHS officials told us that, because ATA  participants are admitted “for the duration of the period for which the alien  continues to be recognized by the Secretary of State as being entitled to  that status,” it is State’s responsibility to determine whether participants  are entitled to A-2 status upon request by DHS. According to these  officials, DHS cannot take any related enforcement action until State has  confirmed that participants are no longer entitled to A-2 status. Once  State has done so, DHS officials search U.S. Citizenship and Immigration  Services databases to determine whether the participants in question  have filed for a change in status or other benefits. According to DHS  officials, if participants have not applied for or have been denied changes  in status or other benefits, DHS may seek to remove them from the  country on the grounds that they have violated the terms of their  admission.
section_title: State Officials and Contractors Have Taken Various Steps to Ensure that Domestic Tactical Training Facilities Used by ATA Align with Security Requirements
subsections: section_title: State Has Taken Steps to Oversee the Contract for ATA Training, Which Includes General Requirements for Facility Security
paragraphs: State’s steps to oversee the security of the tactical training facilities used  for domestic ATA training are predicated on the GATA contract. This  contract has general requirements for the secure storage of equipment,  including weapons and explosives, and some more specific requirements  related to obtaining licenses and for controlling access to explosives  ranges and armories. The contract requires, among other provisions, that  tactical training facilities have secure storage for all explosives,  ammunition, and equipment. The contract also states that the armory  shall be secured and alarmed and have climate-controlled weapons  storage and a maintenance shop. Finally, contractors are required to  have the necessary federal, state, and local permits for the storage of  weapons, ammunition, and explosives. The contract stipulates that  explosives storage areas and facilities shall meet all federal, state, and  local criteria for safe and secure storage. For example, the federal Bureau  of Alcohol, Tobacco, Firearms and Explosives (ATF) has promulgated a  regulatory framework for explosives storage, possession, and use,  including licensing criteria specifying that ATF may verify by inspection  that applicants for permits and licenses have places to store explosive  materials that meet certain safety and security requirements. The  regulations also dictate the type of material from which the storage  containers are to be made, depending on the type of explosives to be  stored, and the types of locks that should be used to secure the  containers.
State reports receiving copies of the facilities’ federal licenses for storing,  transporting, and handling explosives for the relevant training facilities. In  addition, State oversees the GATA contract, including facility security  provisions, through visits to the subcontracted training facilities and  frequent interactions with the contractors.
Facility visits. State officials visit the training facilities used by ATA to  review security and other aspects of training delivery. For example,  following the award of the GATA contract, ATA subject matter experts  conducted a survey of O’Gara’s training facility, which included an  examination of whether the facility had secure storage and firing  ranges. Officials said that they did not conduct a similar survey of the  Academi training facility at the time the GATA contract was awarded  because it had been previously certified under a prior ATA training  contract. State and contractor officials said that ATA program  managers who visit training facilities during course delivery also  review the sites to ensure that they are in compliance with contract  requirements.
Frequent interactions. State and prime contractor officials told us that  they meet weekly to discuss operational and planning issues. Officials  noted that there is no set agenda for these meetings because the  topics are driven by events, and all issues are open for discussion.
section_title: Contractors Have Taken Required and Voluntary Steps to Ensure the Security of Training Facilities Used for Domestic Tactical Training
paragraphs: Contractors that manage ATA’s domestic training have taken a variety of  required and voluntary steps to ensure security at the tactical training  facilities. State officials said that it is the responsibility of the prime  contractors to ensure that the training facility subcontractors have the  necessary federal, state, and local permits for the storage of weapons,  ammunition, and explosives. Both facilities we visited—O’Gara and  Academi—had relevant, unexpired licenses. For example, they had ATF  licenses for transporting, storing, and possessing explosives. They also  had state or local licenses such as the Commonwealth of Virginia  Explosives Usage Permit, the Virginia Fire Marshall’s Office Certified  Blaster Certification, and North Carolina county special use permits for  firing ranges and training facilities. Moreover, the prime contractor that  implements the majority of ATA training performs an annual audit of both  tactical training facilities to assess compliance with the GATA contract,  including its facility security provisions. The prime contractor found the  facilities in compliance with those provisions of the GATA contract. As  shown in figure 3, we also observed during our November 2016 site visits  that both the O’Gara and Academi training facilities used locked  explosives storage containers, as required by ATF. In addition, we  observed that both training facilities had locked and alarmed armories, as  required by the GATA contract, with the alarms monitored by private  security companies.
In addition to taking steps to meet the GATA contract requirements, both  training facilities we visited have taken voluntary actions related to facility  security. ATF suggests security measures including installing fences,  security cameras, and locked gates to increase security; however, the  measures are not ATF licensing requirements. During investigative  surveillance operations and escorted facility site visits in September 2016  and November 2016, respectively, we observed that both domestic  tactical training facilities included some of these suggested security  measures such as fences and natural barriers to deter and prevent  unauthorized access to the facilities, warning signs, secured gates,  security patrols, and surveillance cameras. These security measures  align with the ATF’s suggestions for storing and safeguarding explosive  materials. For example, the Academi facility has one main entrance with a  gate, warning signs, and 24-hour armed security guards. The facility’s  natural barriers include woods and farmland, and officials said that bears  and snakes also deter unauthorized access. The O’Gara facility is located  next to a highway and has a main entrance with a gate, a warning sign,  and an unarmed security guard during business hours. The facility’s other  entrance is restricted by an access code-controlled electronic gate. The  O’Gara facility’s natural barriers also include woods and farmland.  Furthermore, as shown in figure 3 above, both facilities had fences  surrounding the explosives storage containers, a practice suggested by  ATF, and contractors told us that the fences are locked when the  containers are not being used for training.
In response to the December 2015 media reports mentioned earlier that  alleged that its facility had potential security vulnerabilities, O’Gara made  several changes to the physical security of its training facility. For  example, officials said that in August 2016, the company constructed a  wood fence to block public observation of one of the areas of the facility  used during ATA training. The first photo in figure 4 shows that during our  September 2016 investigative surveillance operation, we observed this  wood fence and a lift barrier gate deterring vehicular access to the  training grounds. The second photo in figure 4 shows a locked chain link  fence that O’Gara officials told us they installed in October 2016, which  we observed during our November 2016 site visit. O’Gara officials told us  that in November 2016, they added slats to the newly installed chain link  fence, to further reduce public observation, as shown in the third photo in  figure 4.
section_title: State Completed Human Rights Vetting for a Generalizable Sample of ATA Participants and Screened for Terrorist Activity
paragraphs: Using available ATA participant data, we confirmed that all ATA  participants in a generalizable sample of 98 participants had been vetted  at the individual or unit level or were not members of a security force with  police powers and, therefore, did not require Leahy vetting, according to  State officials and guidance. Of the 98 ATA participants in our sample, we  determined that State had vetted 96 of those participants and that 2  participants were non-security forces without police powers and,  therefore, did not require vetting. U.S. law prohibits assistance from being  provided to any unit of the security forces of a foreign country if the  Secretary of State has credible evidence that such unit has committed a  gross violation of human rights. State has developed policies to prevent  U.S. assistance from being used to provide training for units or individuals  who have committed gross violations of human rights.
We selected a generalizable random sample of 98 names from 2,271  available electronic records of ATA participants who had received training  in the United States in fiscal years 2012 through 2016 and for whom ATA  officials confirmed that vetting was required by State guidance. We  cross-checked these names and associated training dates with human  rights vetting data from State’s INVEST system—used to process and  document human rights vetting—to determine if they were vetted before  receiving training. For any participants for whom we could not readily  confirm vetting, we worked with DRL and ATA officials to identify  additional supporting evidence to confirm that participants had been  vetted before training was provided. For example, DRL provided us with  records from INVEST based on the use of “ATA” in INVEST’s funding  source field. However, in some instances, vetting officials had used the  broader category of funding of which ATA funds are a subset; as a result,  those INVEST records were not included in the original data provided to  us.
In addition to prohibitions related to human rights violations, U.S. law  prohibits assistance from being provided to any country if the Secretary of  State has determined that the government of that country has repeatedly  provided support for acts of international terrorism. From fiscal years  2012 through 2016, those countries were Cuba, Iran, Sudan, and  Syria, none of which were ATA recipients during that time period.
Beyond country-level prohibitions on support for state sponsors of  terrorism, there is no formal requirement to screen individuals for terrorist  activities, according to State officials. However, State includes criminal  and terrorism screenings as part of its process at both the embassy and  headquarters levels for checking the names of potential ATA participants  before nominating them. For example, State described the process by  which U.S. embassy officials conduct name checks through access to a  variety of law enforcement databases, including the Terrorist Screening  Center’s Terrorist Screening Database. The Terrorist Screening Database  contains information about individuals known or suspected to be or to have been engaged in conduct constituting, in preparation for, in aid of, or  related to terrorism and terrorist activities. In addition, State officials said  that regional bureau personnel conduct terrorist activity screening of ATA  participants through a national counterterrorism database. Further, State  officials said that all visa applicants, including ATA participants, are  subject to a standard suite of screening tools.
section_title: Weaknesses Exist in ATA Data and Oversight of Participants, Some of Whom May Still Be in the United States
subsections: section_title: ATA Course and Participant Data Are Incomplete and Sometimes Inaccurate
paragraphs: ATA program data on the courses that ATA delivered in fiscal years 2012  through 2016, and the participants of those courses, are incomplete and  inaccurate. ATA collects and maintains electronic information about  delivered ATA courses and the participants of those courses in two  separate systems: Snapshot, for course data, and the Student Training  and Reporting Systems, for participant data. In response to our request  for data from these systems, State initially provided data from the  participant data system that included about 16,000 participants, rather  than the more than 56,000 participants ATA reported training in fiscal  years 2012 through 2016. In response to our questions about the  completeness of these data, State undertook an effort to review available  e-mail-based and other participant data that had not been systematically  added to its participant data system and provided us with a revised  response that included about 8,600 additional records. Therefore, the  revised electronic participant data, which included about 25,000  participant records, remained incomplete, missing records for more than  half of the reported 56,000 participants. In addition, the participant and  course records that were included in the revised data were not always  accurate.
Course data. ATA course data are incomplete in that the data do not  include all delivered courses. For the 4 fiscal years 2012 through  2015, ATA reported that 1,987 courses were delivered. The course  data ATA provided to us included only 1,633 courses, or about 82  percent, of the courses ATA reported to have delivered in those 4  years. Our analysis of ATA participant data similarly indicates that the  course data are incomplete, as some courses listed in the participant  data were not included in the course data. For example, we identified  25 participant records that were associated with a Senior Crisis  Management course that was not included in the course data. In  addition to being incomplete, ATA course data elements are not  always accurate. For example, the number of “participants” included  in the course records ATA provided to us was not always accurate.  ATA officials told us that while some course records may have initially  included the maximum number of participants a course could  accommodate, it was intended that records would be updated with the  number of actual participants following the conclusion of training. In  reviewing fiscal years 2012 through 2016 course records, ATA  officials noted that some records may not have been updated and,  therefore, they could not tell us if the participant numbers included in  the course data represented the maximum capacity of a course or the  number of participants who ultimately attended each course.  Notwithstanding these weaknesses, ATA officials told us that the  number of participants included in the course data system from which  data were provided to us is used to report the official number of ATA  students trained. However, the aggregate number of participants  included in the course data provided to us included about 41,000  participants, or about 75 percent of the 56,000 participants ATA  reported to have trained in fiscal years 2012 through 2016. We were  not able to determine which total participant number was more  reliable. ATA officials told us that the difference between the two  figures might be explained by “in-house” training—such as  sustainment training and mentorship—that was delivered to  participants in Afghanistan and that was not captured in electronic  data systems. ATA officials said that they plan to begin capturing such  information this fiscal year, 2017.
Participant data. Data on individual participants that the ATA program  collects and maintains in its electronic participant data system are  also incomplete. As noted above, data in ATA’s participant data  system account for only about 25,000, or less than half of the 56,000  participants ATA reported to have trained in fiscal years 2012 through  2016. In addition, some individual electronic participant records do  not contain complete information for all elements that the system is  designed to capture. For instance, while ATA policy instructs officials  to collect participant unit affiliations, we found that 15 percent of the  approximately 25,000 participant records that ATA provided to us did  not include information on each participant’s current assigned unit. In  addition to our concerns of completeness, we found that elements of  the participant records included in the electronic data were not always  accurate. For example, some participant records included course  dates that did not align either with course dates identified in ATA’s  course data or provided to us directly by the contractors who delivered  the training. Moreover, the recipient partner nation included in some of  ATA’s participant records was incorrect. For example, we identified 27  participant records with the partner nation incorrectly entered as  Jordan, which was the location of the regional training facility where  the training occurred, rather than the home country of the participants  who had received the training. Further, hundreds of records noted a  government agency, such as Ministry of the Interior, or broad job type,  such as police, in the “unit” data field, rather than a unit name. In  addition, some participant records included a job title, such as security  officer, in that data field.
ATA officials acknowledged weaknesses in their processes to capture  course and participant data and have taken some steps to improve the  completeness of their participant data since the initiation of our review.  First, as previously described, in response to our requests for data, ATA  officials undertook an effort to add participant records that previously  existed only in e-mails to the electronic participant data system. With this  effort, ATA officials identified about 8,600 records that they added to their  electronic participant data system and that we included in the data we  used for our analysis. Second, officials noted that, partly in response to  our ongoing review, ATA revised the standard operating procedures for  data collection in November 2016 to more clearly guide staff who enter  data into and use the course and participant data systems. For example,  the revised procedures clarify the information that officials should capture  in the “participant” field of the course data system, noting that when  entering the numbers under the participant field, officials should enter the  number of participants who actually participated in the course and not the  maximum number of participants the course can accommodate. In  addition, the revised procedures outline steps that officials should take to  help ensure the quality of information in the participant data system and  the alignment of that participant data with information in the separate  course data system.
State’s Foreign Affairs Manual notes the importance of producing and  maintaining adequate documentation of agency activities. In addition,  ATA policy instructs officials to collect student names and unit affiliations,  among other things, and State’s fiscal year 2014 Full Performance Plan  Report identifies the “number of individuals in the security sector trained  in counterterrorism knowledge and skills” as a performance indicator for  the ATA program for fiscal years 2014 through 2017. Further, the  Standards for Internal Control in the Federal Government state that  agencies should clearly document transactions and all significant  events. This could include records of courses delivered and participants  trained. Federal internal control standards also state that management  should periodically review procedures and related control activities to  determine that those activities are implemented appropriately. Although  ATA has revised its data collection procedures with the intent to improve  data completeness and accuracy, ATA officials told us that prior standard  operating procedures to capture electronic data have not always been  followed. For example, they explained that a series of personnel changes  involving staff responsible for data entry led to inconsistent  implementation of the data collection procedures in place during fiscal  years 2012 through 2016. Without management efforts to ensure the  implementation of ATA’s revised procedures, ATA will lack reasonable  assurance that its data collection efforts will improve data completeness  and accuracy, and officials may not be able to accurately report the  number of participants trained, in line with program performance  indicators.
section_title: State and DHS Have Acted on Incidents of Participants’ Unauthorized Departures from Domestic ATA Training Activities
paragraphs: State and DHS have acted on 10 documented participant unauthorized  departures from ATA training activities in the United States since fiscal  year 2012. Of the 10, 3 departed from their training facility during  overnight hours in 2013; 6 fled during escorted class excursions, such as  shopping trips, in 2014; and 1 absconded in 2016 during escorted transit  from the airport to the training facility. After making their unauthorized  departures, these 10 participants have pursued various courses of action.  According to DHS data, 2 of the 10 departed the United States for  countries other than their own home country, and 6 remain in the United  States, having applied to DHS for asylum and been granted a work  authorization while their asylum applications are adjudicated by DHS.  According to DHS officials, none of these 8 former ATA participants are  currently in violation of the terms of their admission to the United States,  as they each have departed or have pending applications for an  alternative immigration status. The ninth ATA participant, who made an  unauthorized departure from an October 2014 training event in the United  States, according to DHS, is believed to be in the United States without  having applied for an alternative immigration status. ATA officials  explained that, after discovering the participant’s absence, ATA notified  DHS that a participant was missing. Officials told us that when DHS  learns about this type of incident, DHS officials request notification from  State that the participant in question is no longer entitled to A-2 status,  which was predicated on their participation in State’s ATA training, as  described previously. In this case, once DHS made this request and  State determined that the ATA participant was no longer entitled to A-2  status, the participant became subject to potential removal from the  United States. As of June 2017, according to DHS, the former participant  remains the subject of an open investigation. DHS officials told us that  they are taking proactive steps to locate the individual, who was not  known to pose a threat to national security. As of September 15, 2017,  we had not received requested information regarding the status of the  tenth individual.
When each of these 10 participants made unauthorized departures, the  ATA program had standard operating procedures in place to direct  officials’ actions in cases where a participant makes an unauthorized  departure from training or during transit between the airport and training  facility before and after training. However, ATA officials noted that the  procedures were not always followed. Further, the procedures in place  through 2014 did not specifically include sharing information with DHS.  Our analysis of information related to the 9 documented unauthorized  departures during fiscal years 2013 and 2014 indicates that in 3 cases,  more than a year passed before relevant information was provided to the  DHS unit responsible for investigating nonimmigrant visa holders who  violate their immigration status. In January 2015, ATA revised these  standard operating procedures to clarify the steps to be taken if a  participant makes an unauthorized departure. For example, the revised  procedures note that if a participant attending ATA training has been  missing for 24 hours, ATA should contact the U.S. Regional Security  Officer for the participant’s partner nation and notify DHS. ATA officials  provided information to DHS on the same day that the aforementioned  2016 unauthorized departure occurred.
Both training facilities we visited also had procedures providing guidance  to their employees specifying how to respond to the unauthorized  departure of an ATA participant. For example, the facilities’ procedures  acknowledge that facility staff are not to restrain participants from  departing facilities, because the terms of their admission to the United  States do not restrict them from doing so. In addition, the Academi facility  guidelines for delivering ATA training instruct employees to “contact any  Academi ATA staff immediately” if any participants are missing during an  outing. The O’Gara facility’s procedures for hosting international students  note that “although O’Gara and our prime contractors work hard to ensure  100  accountability of all international students, they may still  decide to prematurely depart training without notice or permission. When  this occurs, O’Gara is required to immediately notify the respective prime  contractor, and in turn, the associated . O’Gara’s  role is an investigatory support role whereas we provide witness  statements, lead instructor statements, copies of associated close circuit  television camera’s footage and other information as required.”
section_title: ATA’s Domestic Participant Oversight Process Does not Include Confirming that Participants Return to Their Home Countries after Training, and the Departure of Some Participants Is Unconfirmed
paragraphs: According to ATA officials, ATA’s oversight process for domestic training  participants does not include confirming that participants return to their  home countries to use their new skills, and the departure of some  participants who completed their training is unconfirmed. ATA officials  and staff at the training facilities we visited described their responsibilities  for overseeing ATA participant departures to include escorting ATA  participants to the airport, helping them check in for their flights, and  escorting them to airport security. We spoke with Regional Security  Officers who help oversee ATA activities in three partner nations, all of  whom described informal follow-up processes with ATA participants,  including those trained abroad, but none of whom used a systematic  process to confirm the return of all participants trained in locations outside  their home countries. ATA’s standard operating procedure for  unauthorized departures does not cover this portion of a participant’s  travel home.
Prior to our review, ATA officials had not reviewed data to determine if  any participants who completed training failed to leave the United States  and return to their home country. In response to our inquiry, during fiscal  year 2017, ATA identified 20 former ATA participants for whom DHS  records do not indicate departures from the United States following the  completion of their ATA training in fiscal years 2012 through 2016, as  seen in figure 5.
Following the initiation of our engagement, ATA officials requested from  DHS all arrival and departure records for foreign nationals admitted to the  United States in fiscal years 2012 through 2016 using A-2 visas, including  ATA participants. ATA officials reported that they reviewed departure  information for more than 69,000 A-2 visa holders recorded in ADIS to  manually identify departure information for 2,773 ATA participants trained  in the United States during that time period and included in electronic  participant data. ATA’s analysis identified 20 participants for whom DHS  data did not include departure records and who, therefore, might still be in  the United States. ATA officials told us that they had asked the U.S.  Regional Security Officer for the partner nation of 1 of these participants  for any related information and that the officer had been unaware that the  participant may not have returned from training. DHS information we  requested for each of the 20 participants in question indicated that 1 had  applied for an alternative immigration status, but DHS found no records of  applications for immigration status changes for the remaining 19. Eleven  of these 19 had been participants in the same fiscal year 2013 course.  ATA officials noted that during their review of ADIS information, each of  the 20 appeared to be “in legal status,” which DHS officials explained to  us would remain the case for all nonimmigrants with A-2 status until DHS  received a determination from State that any individuals in question were  no longer entitled to A-2 status. As a result, a draft of this report provided  to State in July 2017 included a recommendation that State provide  information to DHS about former participants who may have remained in  the United States following the completion of ATA training. After reviewing  the draft report and recommendation, ATA formally notified DHS about  such former participants in August 2017.
State and DHS officials stated that A-2 status complicates the ability of  DHS officials to independently identify individuals who remain in the  United States and may warrant removal. DHS uses ADIS to maintain,  among other things, entry and departure data for tracking immigrants and  nonimmigrants and to facilitate the investigation of individuals who may  have violated their immigration status by remaining in the United States  beyond their authorized stay. DHS officials explained that for visitors  admitted with an “admit until date,” DHS systems can alert officials that an  individual who should have departed may not have complied with the  terms of their admission. However, according to DHS officials, because  all A-2 visa holders, including ATA participants, are admitted to the United  States for duration of status without a specific admit until date, as  previously described, there is no similar indicator in ADIS that an  individual may have remained in the United States beyond their  authorized stay. Instead, DHS would need other means to identify  individuals with A-2 status, including ATA participants, who may warrant  follow-up. State and DHS officials suggested that such identification could  happen if DHS officials encounter the individual in the course of other  activity or if someone tells DHS that the individual may no longer be  eligible for A-2 status. For example, DHS officials told us that for some  training programs sponsored by the Department of Defense whose  participants are also admitted to the United States on A-2 visas, the  agency asks U.S. military attachés stationed in partner nations to confirm  participants’ return so that the department can notify DHS of any who do  not. As noted previously, regardless of how DHS learns of such A-2  status individuals, State must issue an official determination that the  individuals are no longer entitled to their A-2 status before DHS can begin  removal proceedings. State officials involved in making these  determinations noted that they would similarly not be aware of such  individuals unless (a) someone familiar with the situation told them; or (b)  DHS, having otherwise learned about such individuals, requested an  official determination regarding their eligibility for A-2 status.
ATA officials at headquarters and Regional Security Officers posted in  two partner nations told us that while some domestic ATA participants  engage in personal travel following the conclusion of training, they  typically depart the United States immediately. Using a subset of 443  participants trained in the United States during fiscal years 2012 through  2016 for whom we could reliably determine departure dates, we found  that 386 participants, or 87 percent, left the United States within 2 days  following the completion of training, as shown in figure 6. The remaining  57 participants, or 13 percent, remained in the United States for 3 to 21  days before departing.
The ATA program has no process for confirming that participants return to  their home countries after completing training—either immediately or  following personal travel—because there is no legal requirement that they  do so, according to ATA officials. However, the Standards for Internal  Control in the Federal Government state that agencies should design  control activities such as policies, procedures, and mechanisms to  achieve objectives and enforce management directives. In addition, a  stated purpose of the ATA program is to enhance the antiterrorism skills  of friendly countries by providing counterterrorism training and equipment.  Without a process to confirm and document that ATA participants return  to their home countries, ATA may not be able to assess the extent to  which participants are making use of training to help detect, deter, and  prevent acts of terrorism, in line with program goals. In addition, without  some way to identify ATA participants who do not return home and,  therefore, may have remained in the United States following the  completion of ATA training, ATA may not be able to provide information to  DHS about participants whose failure to depart may warrant enforcement  action.
section_title: Conclusions
paragraphs: Building partner capacity is a central focus of U.S. counterterrorism  strategy, and the ATA program, for which State allocated more than $700  million in fiscal years 2012 through 2016, is among State’s primary  mechanisms for accomplishing that goal. ATA has demonstrated a  commitment to making improvements to the program with recent efforts  such as correcting errors and omissions in historical participant data.  However, we identified weaknesses in program data and participant  oversight that may limit the effectiveness of program management.
First, we found significant weaknesses in ATA program data. Officials told  us that procedures for the collection of course and participant data have  been inconsistently implemented. Although State revised these  procedures in 2016, in light of the limited implementation of prior  procedures, management review of related control activities could help  ensure that revised procedures are properly implemented. Without data  quality improvements, program managers may not have comprehensive  or accurate information with which to confirm compliance with human  rights vetting requirements, ensure participant compliance with the terms  of their admission to the United States, and report on and assess the  achievement of program goals.
Second, ATA does not confirm that all participants trained in the United  States or at regional training centers return to their home countries after  training because it lacks a process to do so. ATA’s analysis of the  available electronic participant data indicated that the vast majority of  participants who received ATA training in the United States during fiscal  years 2012 through 2016 departed following the completion of training.  However, their analysis of that limited data also indicates that ATA had  been unaware of at least 20 who may have remained in the United  States. Without knowing whether all participants trained in the United  States or at regional training centers return to their home countries to  implement the skills they learned during ATA training, it may be difficult to  accurately assess the effectiveness of program activities. In addition,  without this information for those trained in the United States, it will be  difficult for ATA to identify and provide information to DHS about  participants whose unconfirmed departures may warrant enforcement  action.
section_title: Recommendations for Executive Action
paragraphs: We are making the following two recommendations to the Department of  State:  The Assistant Secretary of State for Diplomatic Security should take steps  to ensure the implementation of revised standard operating procedures  for collecting electronic ATA course and participant data.  (Recommendation 1)
The Assistant Secretary of State for Diplomatic Security should develop  and implement a process to confirm and document whether future ATA  participants return to their home countries following the completion of  ATA training and, for any participants trained in the United States who do  not, share relevant information with the Department of Homeland  Security. (Recommendation 2)
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report, which included three  recommendations, to the Departments of State and Homeland Security  for comment. State provided written comments, which we have reprinted  in appendix II, concurring with all of our recommendations. In response to  the first recommendation, State noted ATA had revised its standard  operating procedures for collecting data and shared the document with  us. We will follow-up with ATA regarding steps taken to ensure the  implementation of those procedures. In response to the second  recommendation, State stated that, by the end of the year, it will  implement a process to ensure that participants sent to ATA training in  the United States return to their home countries. We will follow-up with  ATA regarding the implementation of such a process for participants sent  to ATA training in the United States or other locations outside of their  home countries. Lastly, State noted that it had already implemented the  third recommendation. Having received evidence that State had provided  the relevant information to DHS, we removed this recommendation from  the final report. The Department of Homeland Security provided technical  comments, which we incorporated as appropriate.
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If you or your staff have any questions about this report, please contact  me at (202) 512-6991 or FarbJ@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine what steps the Department of State (State) has taken to  ensure that facilities used for Antiterrorism Assistance (ATA) training in  the United States align with applicable facility and equipment security  requirements, we analyzed the security requirements in the Global  Antiterrorism Training (GATA) contract, which is used to secure third- party services to manage and deliver ATA training activities. We  compared those requirements to documents, such as federal, state and  local licenses, obtained from the contractors who implement GATA as  well as to observations we made during investigative surveillance  operations and escorted site visits to two domestic tactical training  facilities used by ATA. We selected this nongeneralizable sample of two  facilities because a significant proportion of ATA domestic students were  trained there, and they were locations with courses that had equipment  that needed to be secured on-site. We also reviewed Bureau of Alcohol,  Tobacco, Firearms and Explosives regulations for explosives licenses  and storage and suggestions for facilities that store and use explosives.  Furthermore, we reviewed additional State and contractor documents  related to facility and equipment security such as a survey and audits of  the training facilities. We interviewed State program and contracting  officials about their oversight of the GATA contract requirements. We also  interviewed contractor officials to obtain information on how they comply  with the GATA contract; federal, state and local licensing requirements;  and other facility and equipment security measures they employ.
To assess the extent to which State has vetted domestic ATA participants  for human rights concerns, we reviewed Section 620M of the Foreign  Assistance Act of 1961 (also known as the State Leahy law) and  analyzed State documents establishing its policies and procedures for  complying with that law and conducting human rights vetting. For  example, we analyzed policies and procedures documented in State’s  2012 and 2017 Leahy vetting guides and State’s 2010 International  Vetting and Security Tracking (INVEST) system user guide. Using the  fiscal years 2012 through 2016 ATA participant data, we developed a  generalizable random sample of 100 names from a population of 2,271  ATA participants who were trained in the United States and receive  foreign assistance funding for which vetting is required, in accordance  with State guidance. We then cross-checked the names in our sample  with human rights vetting data from the INVEST system to verify that the  ATA participants were vetted before receiving the training. For any  participants for whom we could not readily confirm vetting, we worked  with State’s Bureau of Democracy, Human Rights, and Labor (DRL) and  ATA officials to identify additional supporting evidence to confirm that  participants had been vetted before training was provided. After selecting  our sample, through the process of following up with DRL and ATA  officials, we discovered that our sample included one interpreter and one  participant in the Special Program for Embassy Augmentation and  Response (SPEAR) training—for whom human rights vetting would not  have been required by State guidance, according to officials. ATA officials  said that the interpreter should not have been included in the data  because interpreters are not participants and that ATA would remove all  interpreters from the participant data system. Officials also said that the  misidentification of the SPEAR participant was the result of a data entry  error in their system. Excluding these individuals reduced our sample size  from 100 to 98. As discussed in this report, ATA’s participant data were  incomplete and, therefore, we could only draw our sample from those  participants trained in the United States for whom ATA had electronic  records in its data system. We determined that the data available were  sufficiently reliable (1) to identify participants who had taken courses in  the United States and (2) that the data could be used to assess whether  the participants for whom there were records in ATA’s participant data  system had been appropriately vetted. However, we could not generalize  our findings about vetting from this group for which ATA had records to  those participants who were not recorded in its system. The confidence  interval for our estimate that all 98 participants in our sample had been  vetted to the full population of 2,271 recorded participants who were  trained in the United States and for whom vetting was required is between  97 and 100 percent, with a 95-percent confidence level. To gather  additional information on human rights vetting, we interviewed officials  from ATA and DRL, which oversees human rights vetting in coordination  with the regional and relevant functional bureaus.
To describe how State screens participants for terrorist activity, we  reviewed U.S. law that prohibits assistance from being provided to any  country if the Secretary of State has determined that the government of  that country has repeatedly provided support for acts of international  terrorism. Those states for which the Secretary has made this  determination are referred to as state sponsors of terrorism. We  compared the countries on that list of state sponsors of terrorism to the  countries for which ATA allocated funding in fiscal years 2012 through  2016 as well as the list of potential ATA partner nations as of fiscal year  2013. In addition, we interviewed State officials about their processes and  embassy data systems used for screening potential ATA participants for  terrorist activity.
To examine the extent to which State has implemented data collection  and program policies to promote oversight of ATA participants, we  analyzed ATA participant and course data and Department of Homeland  Security (DHS) arrival and departure data. We reviewed State, DHS, and  contractor documents, including State’s report on its analysis of  immigration exit records for ATA participants trained at U.S. facilities, and  interviewed cognizant agency officials and contractors. With respect to  reporting on the ATA participant and course data, our review of State’s  response to our initial data request generated questions about the quality  and completeness of the information provided. In response to our  questions, State undertook an effort to review program participant data  and provided us with a revised response. Using the revised data, we  analyzed the extent to which the data included records for all participants  ATA reported to have trained in fiscal years 2012 through 2016 as well as  the extent to which data fields were populated. We also compared  information in data fields that appeared in both ATA participant and  course data systems to determine data accuracy and consistency.  Further, we compared ATA data to data provided directly by the  contractor that implemented the majority of ATA training during fiscal  years 2012 through 2016 as an independent source of information with  which to assess the accuracy and completeness of ATA’s participant and  course data, particularly course dates used in other analyses. We  reviewed information about the systems used to house the data and  spoke with knowledgeable agency officials in Washington, D.C., and  Dunn Loring, Virginia, responsible for the databases about agency  processes for collecting the data and for ensuring data quality. While the  data provided were sufficiently reliable for the purposes of documenting  the extent to which State has implemented data collection processes to  promote oversight of ATA participants, the data in the participant and  course data systems are not comparable, and neither system contains  complete and accurate records, as discussed in this report. In addition to  reporting on these problems, we augmented a subset of records with date  of birth information that allowed us to use DHS data to analyze domestic  participant departures, as described below, but noted that the results for  this subset are not generalizable to the universe of all ATA participants. In  addition, we reviewed guidance included in ATA’s standard operating  procedures for collection of participant data. The Standards for Internal  Control in the Federal Government also state that agencies should clearly  document transactions and all significant events, such as records of  courses delivered and participants trained. Federal internal control  standards also state that management should periodically review  procedures and related control activities to determine that those activities  are implemented appropriately. Furthermore, State’s Foreign Affairs  Manual notes the importance of producing and maintaining adequate  documentation of agency activities. State’s fiscal year 2014 Full  Performance Plan Report identifies the “number of individuals in the  security sector trained in counterterrorism knowledge and skills” as a  performance indicator for the ATA program for fiscal years 2014 through  2017.
With respect to reporting on ATA’s policies regarding unauthorized  departures from training activities in the United States, we reviewed ATA  documents regarding the 10 documented unauthorized departures and  discussed these events with ATA officials and contractor staff at the  facilities that hosted some of the participants who departed. We also  discussed such events via teleconferences with U.S. embassy officials in  three ATA partner nations—Bangladesh, Indonesia, and Jordan— selected based on criteria such as number of ATA participants trained  and in light of countries included in recently completed or ongoing GAO  and State Inspector General reviews of the ATA program. We also  obtained and analyzed information from DHS regarding the departure and  immigration status for 9 of these 10 participants. We analyzed ATA and  contractor documents outlining procedures to be used if an ATA  participant makes an unauthorized departure from training activities in the  United States. Regional training facilities are outside the scope of this  review. State officials told us they were unaware of any instances of  unauthorized departure from regional training centers.
With respect to reporting on ATA’s processes regarding participants who  fail to return to their home country following training at domestic facilities,  we discussed existing related policies and procedures with  knowledgeable ATA officials. The Standards for Internal Control in the  Federal Government state that agencies should design control activities  such as policies, procedures, and mechanisms to achieve objectives and  enforce management directives. A stated purpose of the ATA program is  to enhance the antiterrorism skills of friendly countries by providing  counterterrorism training and equipment. To conduct an analysis  regarding the extent to which ATA participants trained at domestic  facilities depart immediately following the completion of training, we  identified 2,712 unique participant records among the 24,885 records  ATA provided that were associated with fiscal years 2012 through 2016  training at domestic facilities. For 535 of these 2,712 participants, we  were able to obtain dates of birth for DHS and GAO to use for data  reliability purposes in identifying and analyzing related departure data,  respectively. To identify birth dates, we used manual and automated  processes to augment ATA participant records with date of birth  information from other State systems to serve as a unique identifier for  data reliability purposes. Of these 535, we determined the departure  date for 443 using data from the DHS Arrival and Departure Information  System (ADIS). To do so, we manually matched participant names in  ATA data with names in DHS departure data using dates of birth to help  ensure that ATA participant records and DHS departure data pertained to  the same individual. As noted above, the results for this subset of 443  participants, for whom we could obtain birth dates and departure data, are  sufficiently reliable to report on the length of stay in the United States  after these participants completed training but cannot be generalized to  the other 92 participants for whom we found birth dates but not departure  records, or to the nearly 2,200 for whom we did not find birth dates, or to  participants who were not included in ATA’s participant data system.  Therefore, we cannot infer that all participants who were trained in the  United States and subsequently departed did so following the patterns we  report for this subset. For each of the 443 participant records for which we  identified departure data, we used the date identified in the ATA  participant data system as the final day of training and the departure date  from ADIS to calculate the number of days that each participant remained  in the United States following the conclusion of ATA training. In addition  to our analysis of length of stay following the conclusion of training, we  asked DHS to identify if any of the 535 participants for whom we identified  dates of birth appeared in DHS systems used to manage applications for  changes in immigration status and investigations of individuals who  violated the terms of their admission to the United States. DHS did not  find any exact matches for these 535 ATA participant names and dates of  birth in related systems. We and DHS acknowledge that the searches for  exact matches are limited for several reasons, including potential  differences in the spellings of names translated from foreign languages.  Regional training facilities are outside the scope of this review. State  officials told us they were unaware of participants who did not return to  their home countries following training at regional centers.
With respect to our reporting on ATA’s analysis of the departure status of  ATA participants trained at domestic facilities in fiscal years 2012 through  2016, we reviewed State’s report on the results of its analysis and  discussed the analysis with knowledgeable State and DHS officials. We  asked DHS to provide documentation confirming the status of the  participants whom ATA identified who may have remained in the United  States following the conclusion of ATA training and analyzed the  information provided in response. We used ATA’s analysis and DHS’s  additional information to provide insights into participants for whom there  were no departure records. We noted that ATA’s analysis and results  included only participants included in ATA’s electronic participant data,  which we determined to be incomplete.
We also provided information in the background section of this report  about funds allocated to ATA activities. To do so, we assessed funding  data, including allocations, obligations, and disbursements for fiscal years  2012 through 2016 from Nonproliferation, Anti-terrorism, Demining, and  Related Programs (NADR) funding for ATA, NADR/ATA Overseas  Contingency Operations, Global Security Contingency Fund, and  International Narcotics Control and Law Enforcement accounts. State  provided data on allocations, amounts reallocated, unobligated balances,  unliquidated obligations, and disbursements of funds for program  activities. We analyzed these data to determine the extent to which  allocated funds had been disbursed. We also discussed the status of  these funds, including the extent to which any had expired and were no  longer available for obligation, with State officials. We assessed the  reliability of these data by interviewing cognizant agency officials and  comparing the data with previously published data. We determined that  the data were sufficiently reliable for our purposes.
We conducted this performance audit from May 2016 to September 2017  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
We conducted our related investigative evaluation work—site  surveillance—in accordance with investigation standards prescribed by  the Council of the Inspectors General on Integrity and Efficiency.
section_title: Appendix II: Comments from the Department of State
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Jason Bair, Kathryn Bolduc  (Analyst-in-Charge), Ashley Alley, Kathryn Bernet, Debbie Chung, Martin  de Alteriis, April Gamble, Rebecca Gambler, Rachel Girshick, K. Ryan  Lester, Wayne McElrath, Ramon Rodriguez, Alex Welsh, Helina Wong,  and Bill Woods made key contributions to this report. Neil Doherty also  provided technical assistance.