Maritime Security: Federal Agencies Have Taken Actions to Address Risks Posed by Seafarers, but Efforts Can Be Strengthened
Published: 2011-01-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The State Department and two components of the Department of Homeland Security (DHS), Customs and Border Protection (CBP) and the Coast Guard, are responsible for preventing illegal immigration at U.S. seaports and identifying individuals who are potential security risks. The International Labor Organization (ILO) adopted the Seafarers' Identity Documents Convention (ILO 185) to establish an international framework of seafarer identification documents and reduce their vulnerability to fraud and exploitation. GAO was asked to examine (1) measures federal agencies take to address risks posed by foreign seafarers and the challenges, if any, DHS faces; (2) the challenges, if any, DHS faces in tracking illegal entries by foreign seafarers and how it enforces penalties; and (3) the implementation status of ILO 185. GAO reviewed relevant requirements and agency documents on maritime security, interviewed federal and industry officials, and visited seven seaports based on volume of seafarer arrivals. The visits provided insights, but were not projectable to all seaports.
section_title: What GAO Found
paragraphs: Federal agencies use a layered security strategy to address foreign seafarer risks, but opportunities exist to enhance DHS seafarer inspection methods. Federal actions include: (1) State Department screening of seafarer non-immigrant visa applicants overseas and (2) DHS advance screening of commercial vessels' seafarer manifests and admissibility inspections of all arriving seafarers. CBP conducts cargo vessel admissibility inspections on board the vessel without the benefit of tools to electronically verify a seafarer's identity or immigration status because of a lack of available connectivity to network communications in the maritime environment. DHS has prioritized the acquisition of a mobile version of this technology capability but expects it to take several years before the technology is developed and available. CBP agrees that obtaining this capability is important but has not assessed the risks of not having it. Until CBP obtains the capability, identifying the risks and options to address them could better position CBP in preventing illegal immigration at seaports. DHS faces challenges in ensuring it has reliable data on illegal entries by foreign seafarers at U.S. seaports and has not adjusted related civil monetary penalties. First, both CBP and Coast Guard track the frequency of absconder (a seafarer CBP has ordered detained on board a vessel in port, but who departs a vessel without permission) and deserter (a seafarer CBP grants permission to leave a vessel, but who does not return when required) incidents at U.S. seaports, but the records of these incidents varied considerably. The Coast Guard reported 73 percent more absconders and almost double the deserters compared to CBP for fiscal years 2005 through 2009. As a result, the data DHS uses to inform its strategic and tactical plans are of undetermined reliability. Second, CBP is responsible for imposing civil monetary penalties on vessel operators whose seafarers illegally enter the United States; however, as of December 2010, CBP and DOJ had not met legal requirements for adjusting the penalties for inflation. Officials reported taking steps to meet these requirements, but have not developed a plan with timelines for doing so. Such a plan would better position CBP and DOJ to demonstrate progress to comply with legal requirements. International implementation of ILO 185 has been limited--18 countries, representing 30 percent of the global seafarer supply, have ratified ILO 185--and key ILO mechanisms to promote compliance are not expected to be in place until later this year. As of January 2011, the United States had not ratified ILO 185 largely due to concerns over a provision for facilitating visa-free shore leave for foreign seafarers. Perspectives varied among the four federal agencies GAO interviewed within DHS and the departments of State, Transportation, and Labor. Within DHS, the Coast Guard reported that it supported U.S. ratification, while CBP stated that ILO 185's lack of oversight did not serve U.S. law enforcement interests. The U.S. has recently undertaken an interagency review to consider ratification but has no timeline for completion.
section_title: What GAO Recommends
paragraphs: GAO recommends that DHS assess risks of not electronically verifying cargo vessel seafarers for admissibility, identify reasons for absconder and deserter data variances, and, with the Department of Justice (DOJ), develop a plan with timelines to adjust civil monetary penalties for inflation. DHS and DOJ concurred with GAO's recommendations.

section_title: Letter
paragraphs: The United States faces the challenge of balancing the need to secure its  borders to prevent the illegal entry of persons while also facilitating  legitimate trade and travel. In fiscal year 2009, maritime crew—known as  seafarers—made about 5 million entries into U.S. ports on commercial  cargo and cruise ship vessels. The overwhelming majority of the seafarers  entering U.S. ports are aliens. Because the U.S. government has no  control over foreign government seafarer credentialing practices,  concerns have been raised that extremists may fraudulently obtain  seafarer credentials as a way to gain entry into the United States or  conduct attacks against maritime vessels or port infrastructure. Although  there have been no reported terrorist attacks involving seafarers on  vessels transiting to U.S. seaports, the Department of Homeland Security  (DHS) considers the illegal entry of an alien through a U.S. seaport by  exploitation of maritime industry practices to be a key concern.
Screening foreign seafarers to identify those who pose security threats to  the United States is a shared responsibility among federal stakeholders.  For example, overseas, State Department consular officers screen seafarer  applicants for non-immigrant visas—a prerequisite to be eligible for a  permit to depart the vessel and enter the United States—and may deny a  visa if, for example, they determine that an applicant poses a potential  security or immigration risk. Within DHS, U.S. Customs and Border  Protection (CBP), the unified federal agency responsible for border  security, inspects all seafarers arriving from foreign waters to determine  their admissibility into the United States and prevent illegal immigration at  U.S. seaports. CBP obtains key support from the Coast Guard, the lead  federal agency responsible for a wide array of maritime safety and security  activities.
In 2003, the United States and other member states of the International  Labor Organization (ILO)—a specialized agency of the United Nations— adopted the Seafarers’ Identity Documents Convention (Revised) No. 185  (ILO 185). One goal of the Convention was to establish an international  framework for harmonizing seafarers’ identity document (SID) issuance to  strengthen the reliability of the documents and reduce their potential  vulnerability to fraud and exploitation. To support this goal, among other  things, ILO 185 requires ratifying countries to adopt certain credential  features including fingerprint biometrics and issuance processes,  establishes database requirements to support validation of SIDs at ports of  entry, and establishes an oversight mechanism for assessing country  compliance.
You requested that we review the security procedures federal agencies  take to identify and screen foreign seafarers arriving in U.S. seaports and  to analyze ILO 185 and its potential impact on U.S. maritime security. This  report answers three questions:    What measures do federal agencies take to address risks posed by foreign  seafarers transiting U.S. seaports, and what challenges, if any, does DHS  face in addressing these risks?
What challenges, if any, has DHS faced in tracking incidents involving  illegal entry by foreign seafarers at U.S. seaports, and how does DHS  enforce penalties related to these incidents?
What is the implementation status of ILO 185, including prospects for U.S.  ratification, and what are the perspectives of select international and  national stakeholders?
To answer the first question, we analyzed relevant statutes, such as  provisions of the Immigration and Nationality Act (INA) and the Maritime  Transportation Security Act (MTSA),  plus relevant regulations—such as  DHS’s Advanced Passenger Information System (APIS) rule and Coast  Guard’s Advanced Notice of Arrival (ANOA) rule—that set out  requirements for how DHS identifies, screens, inspects, and determines  admission of aliens to the United States. We also reviewed documentation  issued by the State Department and DHS for screening and inspecting  seafarers, including guidance and policy, memoranda, and strategic and  operational plans, as well as risk assessments prepared by DHS  components that detail threats, vulnerabilities, and consequences  associated with foreign seafarers on board vessels arriving at U.S.  seaports. To obtain information on federal screening and inspection  practices and intelligence information on risks identified, we interviewed  headquarters officials at relevant federal agencies at the State Department  (Consular Affairs) and DHS (CBP, Coast Guard, Immigration and Customs  Enforcement, Office of Policy, and Science and Technology Directorate).  We also visited or held teleconferences with CBP seaport field unit  officials and Coast Guard Sector officials responsible for security at a non- probability sample of eight domestic seaport areas. We visited officials at  seven of these locations (Baltimore, Maryland; Jacksonville, Florida; Los  Angeles/Long Beach, California; Miami, FL; New York/New Jersey;  Oakland/San Francisco, California; and Seattle/Tacoma, Washington) and  held a teleconference with officials from one additional port  (Houston/Galveston, Texas). We selected these eight seaports based on  the variety of foreign seafarer arrival activity (collectively, CBP reported  these ports received approximately 35 percent of fiscal year 2009 foreign  seafarer arrivals) and commercial vessel activity at the port—i.e., cargo  and/or cruise vessel. During these visits, we interviewed CBP field unit and  Coast Guard Sector officials responsible for advance-screening and  seafarer inspections, and observed port operations, including seafarer  inspection activities. While the information we obtained from personnel at  these locations cannot be generalized across all U.S. seaports, it provided  us with a perspective on the potential risks posed by foreign seafarers  transiting to U.S. seaports and actions taken by federal agencies to address  those risks.
To answer the second question, we reviewed and compared fiscal year  2005 through 2009 data of seafarer illegal immigration incidents at  seaports reported by (1) CBP headquarters and the eight CBP seaport field  units we contacted, and (2) Coast Guard headquarters and the eight  Sectors we contacted, as well as Coast Guard’s two regional intelligence  centers that track maritime-security related events that occur in the  Pacific area and the Atlantic and Gulf Coast area. We then reviewed  guidance and memoranda issued by CBP and Coast Guard that detail  reporting and collection methods for the data, and challenges faced in  doing both. We interviewed headquarters and field officials about their  data collection and reporting methods and compared them with criteria in  Standards for Internal Control in the Federal Government, DHS policy  guidance for internal agency coordination and information sharing, and  the CBP and Coast Guard instructions for collecting and tracking data on  illegal seafarer entries. We assessed the reliability of these data by  reviewing CBP and Coast Guard data management practices for the data,  but found the data to be of undetermined reliability as discussed later in  this report. In addition, we reviewed statutes that apply to CBP and  Department of Justice authorities to issue and adjust civil monetary  penalties in cases involving illegal seafarer entries in violation of the INA,  and spoke with officials from both agencies about these authorities. We  reviewed the Federal Register to determine when the U.S. government last  adjusted the civil monetary penalties for cases involving seafarer-related  violations of the INA. We also reviewed CBP records of civil monetary  penalties assessed and collected for seafarer-related violations of the INA,  for fiscal years 2005 through 2009. We calculated what the difference in  these amounts would have been had the civil monetary penalties been  adjusted for inflation every 4 years, as required by law.
To answer the third question, we reviewed ILO documents and  interviewed officials from the ILO and relevant federal agencies, including  the State Department, CBP, Coast Guard, the Department of Labor  (Labor), and the Department of Transportation’s Maritime Administration  (DOT MARAD). We also developed and used a survey instrument to obtain  information from four foreign governments regarding views on ILO 185  and their practices for issuing identification or other credentials to  seafarers. We selected these countries based on two factors: (1) those that  are among the top 10 nations that supply seafarers on vessels transiting to  the United States and (2) a mix of nations that have ratified and not  ratified ILO 185. The results of our survey are not generalizable, but  provide perspectives from specific countries. Finally, we reviewed  documents and interviewed representatives from seven industry  organizations, including shipping companies and associations representing  ship owners and/or operators, and three labor organizations about issues  including their positions on ILO 185, standard practices for vetting and  hiring seafarers, and issues related to seafarer rights and access to shore  leave. In part, we selected these groups based on their involvement with  the ILO.
We conducted this performance audit from December 2009 through  December 2010 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.
subsections: section_title: Background
subsections: section_title: Number of Foreign Seafarer Arrivals in U.S. Seaports
paragraphs: Over $1.2 trillion dollars in merchandise of foreign trade is handled at U.S.  seaports each year, and according to DOT MARAD, U.S. ports accounted  for the second highest number of cargo vessel calls worldwide in 2009. In  addition, millions of individuals transit U.S. seaports annually on cruise  ships, making the cruise industry a source of major economic activity. For  example, direct spending for goods and services by the cruise lines and  their passengers in the United States was about $19.1 billion in 2008. The  global labor supply of seafarers who work on commercial vessels to  support these types of activities is estimated at 1.2 to 2 million individuals.  This figure encompasses individuals required for normal operation and  service on board commercial vessels, including hospitality-related  occupations on cruise ships such as food servers and entertainers.
Compared to the total number of arrivals at U.S. land and air ports of  entry, the number of foreign seafarers arriving in U.S. seaports is small.  For example, according to CBP data, foreign seafarer arrivals accounted  for almost 5 million of the approximately 27 million passenger and crew  arrivals recorded in U.S. seaports in fiscal year 2007. In contrast, for that  same year, CBP recorded 92 million passenger and crew arrivals on  international flights and 300 million passenger and pedestrian arrivals at  land border crossings.
According to CBP data, in fiscal year 2009, approximately 80 percent of  seafarers arriving by commercial vessel did so on board passenger vessels,  such as cruise ships with the remaining 20 percent arriving by cargo or  other vessel type. This is because individual cruise ship routes typically  account for regular, frequent arrivals, and cruise ships typically employ  hundreds of seafarers, while cargo ships often have just a few dozen  seafarers on board. As a result, the seaports receiving the largest  numbers of seafarers were generally those that had cruise vessel  operations. In fiscal year 2009, CBP reported 10 of the 132 U.S. seaports of  entry received 70 percent of foreign seafarer arrivals (see fig. 1 below).
section_title: Visa Requirements for Entry into the United States for Shore Leave
paragraphs: The State Department typically issues two types of non-immigrant visas to  foreign seafarers: C1/D or D. D visas are “crewmember” visas that allow a  seafarer to request a conditional permit to land in the United States only  if arriving by ship as an active seafarer. Under the C1 category of the  combined C1/D visa, seafarers are allowed to seek admission into the  United States at any port of entry—such as an airport—for the purpose of  transiting to ships for employment. If arriving by vessel in the capacity of  an active seafarer, the D category of the combined C1/D visa may be used  to request a conditional permit to land. Typically, these visas are valid for  multiple entries over a period of up to 5 years, and the maximum time  allowed in the United States for any single entry is 29 days. According to  CBP data, the vast majority of foreign seafarers who arrive in U.S.  seaports—over 95 percent in fiscal year 2009—possessed one of these  non-immigrant visas. By far, the C1/D visa is the most frequently issued  visa applied for and obtained by seafarers. Figure 2 below shows the share  of C1/D and D visas the State Department issued in fiscal year 2009.
section_title: Countries of Origin of Foreign Seafarers
paragraphs: As approximated by C1/D and D visa issuance, a few countries account for  large shares of the foreign seafarers who apply for non-immigrant visas to  enter the United States, with the Philippines supplying by far the most  seafarers, followed by India and the Russian Federation. Tables 1 and 2  below illustrate C1/D and D visa issuance data for fiscal year 2009.
section_title: Stakeholders Involved with Seafarer Security Issues
paragraphs: A number of domestic and international stakeholders are involved with  seafarer security issues. For example, among domestic stakeholders,  multiple DHS components share responsibilities for ensuring that aliens  for whom there may be national security or other concerns are not  admitted to the United States. Table 3 lists some of these organizations  and agencies and their roles related to seafarer security.
section_title: Legal and Regulatory Framework for Maritime Security Actions
paragraphs: International and national law and guidance govern maritime security, and  include provisions that apply to seafarers. At the international level, the  IMO, through its International Ship and Port Facility Security Code (ISPS)  and its Convention on Facilitation of International Maritime Traffic (FAL),  lays out the international framework designed to help ensure maritime  security and prevent unnecessary delays in maritime traffic. In addition,  national laws, regulations, and guidance also direct federal agencies and  vessel operators on a nationwide basis. For example, the INA as amended  requires that all aliens, including foreign seafarers, seeking admission to  the United States be inspected by immigration officers. It also requires  foreign seafarers, with certain exceptions, to obtain a conditional landing  permit to land temporarily in the United States. To grant a conditional  landing permit, CBP generally requires foreign seafarers to present a  passport or seaman’s book and a non-immigrant visa with a D  classification. Appendix I details key international and national laws,  conventions, or guidance pertaining to seafarer security.
section_title: Concerns with Seafarer Exploitation of Maritime Industry
paragraphs: According to Coast Guard National Maritime Intelligence Center officials  we met, to date there have been no terrorist attacks involving seafarers on  vessels transiting to U.S. ports and no definitive information to indicate  that extremists have entered the United States as seafarer non-immigrant  visa holders. Nevertheless, as we reported in 2007, security officials in the  U.S. government are concerned about the possibility of a future terrorist  attack in a U.S. port. Federal agencies have identified seafarer-related  risks involving either (1) extremists entering U.S. ports as seafarers and  their potential threat to vessels or port infrastructure; or (2) risks posed  generally by illegal immigration into the United States, in particular:    The State Department has reported that the exploitation of C1/D visas by  aliens is a national security concern because the visas could be used by  extremists to enter the United States. State Department and DHS reports  chronicle several cases where groups of seafarers have been able to obtain  valid visas through fraudulent means and successfully enter the United  States. These fraud cases generally involved C1/D applicants using what  were later determined to be fraudulent employment letters to obtain their  visas. Still, according to the State Department, the extent of fraud among  seafarer visa types—C1/D and D—is comparable with that encountered  with other non-immigrant visa types and does not constitute a substantial  problem.
As we reported in 2007, the Coast Guard has assessed the hypothetical  possibility that seafarers (or persons posing as seafarers) could conspire  to commandeer a vessel with the intent of using it as a weapon or  disrupting maritime commerce. However, vessel operator and industry  group assessments have found this to be an unlikely scenario in part due  to the vetting process shipping companies use when hiring, and  particularly for cargo or tanker vessels, the technical complexity required  for operating the vessels.
section_title: Federal Agencies Use a Layered Security Strategy to Identify and Address Foreign Seafarer Risks; Opportunities Exist for CBP to Enhance Inspection Methods
subsections: section_title: State Department Screens Seafarers Applying for Visas
paragraphs: The State Department’s visa adjudication process is the first layer of  security implemented by federal agencies to prevent terrorists, certain  criminals, or otherwise inadmissible aliens from gaining entry into the  United States. Aliens wishing to temporarily enter the United States—such  as foreign seafarers—fill out a visa application and make an appointment  for an interview at U.S. embassies or consulates abroad; pay a fee; and  submit photographs and 10-digit fingerprints. In turn, consular officers  review applications, interview applicants, screen applicant information  against federal databases, and review supporting documents to assess  whether the applicant is an intending immigrant, potential threat to  national security, or otherwise ineligible. Among other things, consular  officers check for previous visa refusals, immigration violations, criminal  histories, and terrorism concerns. If any such concerns arise, officers  conduct additional security checks by seeking input through an  interagency Security Advisory Opinion (SAO) (see fig. 3 for a description  of the visa adjudication process). Following these steps, the State  Department will either issue or refuse an applicant’s visa application.  Those applicants who are granted visas may then present the visa to CBP  officers to request admission into the United States when arriving at U.S.  ports (CBP’s process for admissibility screening is discussed later in this  report). In fiscal year 2009, the State Department reported that 265,512  applicants had applied for crew visas—C1/D and D. Of this number, the  State Department issued 229,527 (86 percent) and refused 35,985 (14  percent).
As we previously reported in 2007, the State Department has taken steps  to strengthen the security of the visa adjudication process since the  terrorist attacks of 9/11. For example, the State Department has  increased use of internal databases to track fraud cases and identify  trends, conducted an increased number of studies on visa adjudication  practices, and enhanced and expanded consular officer training courses  on fraud (see appendix II for a summary of selected actions the State  Department has taken since 9/11 to strengthen the adjudication process).  In addition, in 2007, following several cases in which seafarers obtained  visas fraudulently from overseas posts, the State Department issued  guidance suggesting additional steps that posts can take to identify fraud  among applicants for non-immigrant seafarer visas—particularly in  ensuring that the ship, visa applicant, and manning agency are bona fide  entities.
section_title: Within DHS, CBP and Coast Guard Conduct Advance-Screening, Inspections, and Enforcement Operations
subsections: section_title: Before Vessel’s Arrival, CBP and Coast Guard Screen Manifests and Assess Risks
paragraphs: Before a commercial vessel’s arrival, both CBP and Coast Guard are to  receive and screen advance information on commercial vessels scheduled  to arrive at U.S. ports. Vessel operators or agents are required to transmit  information to the Coast Guard’s National Vessel Movement Center,  including CBP-required advance passenger and crew information—known  as a manifest—and Coast Guard required Advanced Notice of Arrival  (ANOA). Multiple components screen this advance information to identify  national security-related or other concerns. Nationally, this includes  screening by CBP’s National Targeting Center-Passenger (NTC-P) and  Coast Guard’s Intelligence Coordination Center (ICC). Locally, CBP field  units at seaports of entry screen crew manifests against various  government databases and share the results with Coast Guard field units— known as Sectors. Appendix III provides a more detailed description of  this advance-screening process.
For all arriving commercial vessels, both CBP and Coast Guard policy  requires that field units prepare risk assessments based on the results of  advance-screening of vessel and seafarer information. CBP has the lead  role with respect to passengers and seafarer issues and provides the Coast  Guard with information on seafarers that raise initial security concerns.  According to the CBP commercial vessel entry and boarding policy, CBP’s  risk management approach begins with a collection of vessel information  obtained during advance-targeting and is followed by an analysis to  identify and address risk areas. CBP’s boarding policy identifies 19  different risk factors that field units are to consider for assessing risks  posed by the vessel or seafarers. Among those risk factors are whether the  vessel operator has had past instances of invalid or incorrect crew  manifest lists, whether the vessel has a history of seafarers unlawfully  landing in the United States, or whether the vessel is making its first  arrival at a U.S. seaport within the past year.
Additionally, for all arriving vessels, Coast Guard policy provides that field  units are to prepare risk assessments to identify those considered high  risk. For example, to quantify the risk factors Coast Guard uses a national  scoring tool to screen vessels against a variety of items. See figure 4 for a  description of the DHS process for screening, assessing risks, and  inspecting foreign seafarers. (Up to 72 hour prior to  vessel’ arrival) (Up to 48 hour prior to  vessel’ arrival)
section_title: At Port of Entry, CBP Officers Inspect all Seafarers with Coast Guard Support
paragraphs: CBP is the lead DHS agency responsible for inspecting all seafarers to  determine whether they are admissible into the United States. CBP  conducts these inspections to determine the nationality and identity, and  for non-U.S. citizens, the admissibility of each person wishing to enter the  United States and to verify that crew manifest information provided by a  vessel operator matches the advance information received prior to the  vessel’s arrival. For foreign seafarers, CBP’s seafarer inspection practices  focus on (1) review of identity and travel documentation; (2) a comparison  of the document to the seafarer to determine if he or she is in fact the true  bearer; and (3) interviews to determine admissibility and the potential  risks of the individual violating immigration laws. CBP officers rely on  interviews with the seafarer, their experience in observing and assessing  seafarer behavior, and verification of seafarer documents to determine  who is or is not admissible to the United States. CBP requires all arriving  seafarers to have either a passport or seaman’s book. While arriving  foreign seafarers are not required to hold a visa to enter a U.S. seaport on  a vessel, CBP requires all foreign seafarers to hold a valid visa to be  eligible for a conditional landing permit for shore leave. Appendix IV  provides additional information on CBP and Coast Guard boarding and  seafarer inspection activities.
section_title: CBP Seeks Additional Tools to Enhance Seafarer Admissibility Inspections
paragraphs: The procedures and tools CBP officers use to conduct admissibility  inspections vary to some extent based on whether the seafarer is arriving  on a cargo or cruise vessel. To manage the high number of both seafarers  and passengers, CBP generally conducts cruise vessel admissibility  inspections at dockside inspection facilities similar to those at airports. To  date, cruise line facilities at 15 seaports are equipped with U.S. Visitor and  Immigrant Status Indicator Technology (US-VISIT), which provides  biometric identification services to decision makers—in this case, CBP  officers.
CBP conducts almost all cargo vessel admissibility inspections on board  the vessel without the benefit of tools—such as mobile passport readers— for electronically verifying a seafarer’s identity or immigration status. In  this instance, CBP officers have to rely on information vetted before  boarding the vessel and their skill sets to identify fraud and grounds of  inadmissibility, both in reviewing documents and in interviewing  seafarers. CBP headquarters and officials from seven of eight CBP field  units we visited reported that having mobile or portable technology to  electronically verify the identity of seafarers would enhance their efforts  to identify fraudulent documents and confirm immigration status. Among  the capabilities sought by field officials from the seaport areas we visited  was having a portable device utilizing US-VISIT technology and providing  a real-time response for seafarers fingerprinted on board their vessel. Field  officials also reported seeking the ability to run background checks in the  field and the ability to machine read visas and passports.
DHS has recommended that DHS components electronically verify all  immigration status determinations. According to 2006 and 2008 guidance  issued by the DHS Screening Coordination Office (SCO), verification of  immigration status should not rely solely on verification of physical  security features present on a credential. The guidance states that  electronic verification provides greater security and should be conducted,  particularly where DHS owns the process. A CBP headquarters official  reported that the primary challenge in deploying mobile biometrics  readers or other tools for electronically verifying the identity of seafarers  is a lack of available connectivity to network communications in the  maritime environment. CBP headquarters reported the potential value  that such tools would provide CBP officers for conducting on board  seafarer inspections and that CBP had explored solutions in recent years.  For instance, a CBP headquarters official reported that some field units  had tried, generally without success, to use wireless laptops with access to  CBP data as a way to verify the identity of seafarers arriving at seaports on  board cargo vessels. Of the eight CBP field units we visited, three reported  efforts to use mobile technology as an electronic verification tool during  on board admissibility inspections. Of these three field offices, two  reported efforts to use laptops with connectivity to CBP databases as an  electronic verification tool, one of which reported some success while the  other reported abandoning the effort because of poor connectivity. The  third field office reported that it had participated in a DHS pilot in which  its officers were provided with hand-held biometric scanners to capture  fingerprints—the office reported the devices had provided value, but that  they were not aware of the status or results of the pilot.
In May 2009, DHS deemed as “high priority” the need for the department to  obtain hand-held mobile biometrics screening capabilities that can  effectively collect data samples from subjects in challenging operational  environments—such as those offshore and at seaports of entry. To address  this, in August 2009, DHS S&T issued a solicitation for research proposals  for developing a hand-held screening device. However, according to the  DHS S&T proposal, it is expected to take several years before this  technology can be made available for use by DHS agencies, such as CBP.  Moreover, DHS S&T officials reported that these proposals do not address  the connectivity challenges reported by CBP field officers.
DHS SCO has reported that given the inherent level of risk to security and  immigration or other fraud, visual verification alone of travel documents  poses significant concerns. In this way, by not having the ability to  electronically verify the documents, CBP’s methods for inspecting cargo  vessel crew offers less assurance that CBP is identifying fraud among  documents presented by the foreign seafarers seeking admission into the  United States. According to internal control standards, assessing risk  exposure is important to providing reasonable assurance that program  goals and objectives are met and determining options to address them.  CBP reported that its cargo vessel admissibility methods involve multiple  levels of screening to identify risks posed by seafarers. However, CBP  reported that it had not conducted an assessment of the risks associated  with not using electronic verification as part of its admissibility  inspections for cargo vessel seafarers. Consequently, conducting an  assessment to identify the risks of not meeting the DHS SCO  recommendations for electronically verifying documents as part of  immigration status determinations and identifying options for addressing  any identified risks and their costs, would be important until new tools  and technology become available.
section_title: DHS Faces Challenges in Ensuring Absconder and Deserter Records Are Accurate and Reliable and Has Not Adjusted Related Civil Monetary Penalties, as Required by Law
subsections: section_title: DHS Lacks Accurate and Reliable Data on Absconder and Deserter Incidents
paragraphs: CBP has primary responsibility for identifying and reporting absconder  and deserter incidents at U.S. seaports—both to Coast Guard and other  federal and local law enforcement stakeholders—and for tracking them in  CBP database systems. Meanwhile, the Coast Guard generally relies on  CBP’s reporting of these events for populating its own records of the  incidents, with Coast Guard Sectors receiving initial reports of the incident  and disseminating the information among various components within  Coast Guard. Figure 5 summarizes CBP and the Coast Guard’s processes  for identifying and reporting absconder and deserter incidents at U.S.  seaports.
CBP has reported continuing challenges with its seaport field units’  recording of absconder and deserter incidents in CBP database systems.  Since 2004, CBP has mandated that field units record all absconder and  deserter events and related information in its ENFORCE database, and  through 2007, CBP had issued several memoranda reminding field units to  do so. In 2007, CBP headquarters issued a memorandum to field units  reporting that its review of absconder and deserter cases found that CBP  field units at many seaports of entry had not been properly utilizing  ENFORCE to record these incidents.
CBP headquarters and field units we contacted provided us with data on  the number of absconder and deserter incidents identified at U.S. seaports  from fiscal years 2005 through 2009. The number of incidents reported by  CBP headquarters varied with those reported by seven of eight CBP field  units we contacted—with considerable variations at six of these seaports.
The following figure compares CBP headquarters and CBP field unit  absconder and deserter data we received:  According to 2007 guidance CBP headquarters issued to field units, it is  critical that CBP field officers properly enter cases of seafarer incidents  into the ENFORCE database in order to maintain data integrity and  develop meaningful analysis of trends and risks. Further, the guidance  notes that when adverse actions—such as seafarer absconder and deserter  incidents—are not properly recorded, these inaccurate statistics not only  impact targeting and analysis, but also inaccurately reflect workload with  regard to staffing justification and assumptions.
Officials from CBP headquarters and four field units we contacted  reported that they did not know why their absconder and deserter data  varied. A CBP headquarters official responsible for maintaining absconder  and deserter incident data reported that he had used the ENFORCE  database as headquarters’ source for the absconder and deserter data and  reported that field unit officials may have been inexperienced and not  known to use ENFORCE to access the data. In addition, CBP headquarters  reported that without comparing the methodology and data we were  provided by headquarters and field units, it could not conclude why the  data varied. Meanwhile, field officials from two of these field units told us  they believed the data they had provided were accurate. Overall, field  officials reported using various sources to collect the data. For example,  four field units reported they obtained their data from locally maintained  sources, including hard copy incident logs. In July 2010, a CBP  headquarters official responsible for managing the ENFORCE system for  CBP stated that the agency had faced continued challenges with ensuring  the accuracy of the data field officers had entered into ENFORCE  potentially as a result of difficulty field officers experienced in navigating  ENFORCE, and that CBP was working to improve the user interface of  ENFORCE so that it more effectively served the reporting needs of CBP  officers.
According to internal control standards, accurate reporting of transactions  and events are necessary to support management in making decisions.  Program managers need operational data to determine whether they are  meeting their agencies’ mission goals for effective and efficient use of  resources, while operating information is also needed to determine  whether the agency is achieving its compliance requirements under  various laws and regulations. To do this, internal control should generally  be designed to assure that ongoing monitoring occurs in the course of  normal operations. Procedures including regular comparisons and  reconciliations should be integrated into an agency’s activities.
CBP has reported the importance of accurately recording absconder and  deserter incidents to its targeting and analysis and workload staffing  justification and assumptions. However, CBP headquarters and field  officials were unable to fully explain why their respective records of these  incidents varied so considerably. Because of these variances, CBP’s data  are of undetermined reliability. Determining the reasons that absconder  and deserter data varies between headquarters and field units, and taking  any actions necessary to address them, could better position CBP to  provide reasonable assurance that its data are reliable, thereby facilitating  its targeting and analysis activities to help prevent illegal immigration at  seaports.
subsections: section_title: Coast Guard Concerned about Accuracy of Absconder and Deserter Data
paragraphs: At the national level, Coast Guard’s Intelligence Coordination Center (ICC)  maintains all Coast Guard reported asymmetric events involving vessels  arriving at U.S. seaports, including absconders and deserters, in a  classified database for use by Coast Guard leadership and field officials.  Regionally, Coast Guard has command structures responsible for Atlantic  and Pacific area operations, and each of these command structures has  intelligence coordination components—known as the Atlantic and Pacific  Area Maritime Intelligence Fusion Centers (MIFC-LANT and MIFC-PAC  respectively). Each of these fusion centers maintains its own database of  absconder and deserter incidents.
Coast Guard field practices for tracking absconder and deserter cases vary  by location, and Coast Guard ICC data on the number of absconders and  deserters differed from that reported by both MIFC-LANT and MIFC-PAC.  For example, for absconder and deserter incidents reported in the Coast  Guard’s Pacific Area during the period of fiscal years 2007 through 2009,  the ICC reported 86 total incidents, while MIFC-PAC reported 123. Similar  data variances occurred between ICC and MIFC-LANT. For example,  figure 7 shows that Coast Guard ICC and MIFC-LANT have reported  differing numbers of absconders and deserters at seaports in the Coast  Guard’s Atlantic Area during the period of fiscal years 2005 through 2009,  which includes seaports on the east and gulf coasts, and Puerto Rico.
Because the ICC and regional intelligence centers do not have a process in  place for comparing their absconder or deserter data on a systematic  basis, the Coast Guard is at risk of inconsistent or double counting by its  MIFCs and ICC. An official with the ICC’s Maritime Smuggling Branch,  which maintains this data, told us that Coast Guard leadership recognizes  this risk and is looking to establish business rules for coordinating this  information among its components. Moreover, according to several  intelligence assessments issued by MIFC-PAC in 2009 and 2010, the  sufficiency of reporting absconder and deserter events is a critical  intelligence gap as there is a substantial likelihood that some absconder  and deserter events were not reported through MIFC-PAC channels. In  these reports, MIFC-PAC questioned the accuracy of the absconder and  deserter reporting rates and the extent to which such incidents had gone  unreported.
According to internal control standards, accurate reporting of transactions  and events are necessary to support agency operations and internal  controls should generally be designed to assure that ongoing monitoring  occurs to help ensure such reporting. According to Coast Guard  intelligence assessments, thorough reporting of absconder and deserter  events is essential for asymmetric migration analysis and is a core input to  the Coast Guard’s vessel-targeting and threat-ranking programs. Thus,  studying the absconder and deserter reporting and tracking methods of its  components to examine their accuracy and thoroughness, including why  data reported by ICC for absconders and deserters would vary from that  reported by the two regional intelligence fusion centers, the Coast Guard  could be better positioned to analyze asymmetric migration trends and  implement vessel targeting and threat ranking programs.
section_title: CBP and Coast Guard Absconder and Deserter Records Differ
paragraphs: CBP and Coast Guard absconder and deserter records also varied  considerably between the two agencies—both at the national and local  seaport levels—with Coast Guard reporting far higher total absconder and  deserter incidents than CBP for fiscal years 2005 through 2009. For  example, nationwide, Coast Guard ICC reported 73 percent more  absconder incidents and almost double the number of deserter incidents  than CBP headquarters for this period. Moreover, in only one of these 5  years did CBP and Coast Guard report the same number of either  absconder or deserter incidents. Figure 8 details Coast Guard and CBP  headquarters absconder and deserter reporting for fiscal years 2005  through 2009.
Disparities also exist between absconder and deserter data reported by the  CBP and Coast Guard field units at seaports we contacted. For example,  CBP and Coast Guard field units at the eight seaports we visited provided  absconder and deserter data for those incidents that had occurred at their  seaport areas of responsibility between fiscal years 2005 through 2009.  Overall, Coast Guard and CBP field data of total absconder and deserter  events varied at six of seven seaports that provided comparable data. For  example, at one seaport, Coast Guard reported double the number of  absconders, but only about half as many deserters as did CBP. See  appendix V for port specific breakout of data.
Both CBP and Coast Guard headquarters reported that they did not know  why the two agencies’ records of absconder and deserter events differed.  The agencies reported that one factor may be that they have different  missions and purposes for using the data—with CBP reporting and  tracking the information as part of its immigration and law enforcement  mission, and Coast Guard doing so largely for intelligence reasons. For  example, as a result of their differing missions, Coast Guard’s ICC  indicated it did not share its information with CBP. Also, a Coast Guard  intelligence official reported that while Coast Guard’s reports of  absconders and deserters are largely based on information Coast Guard  Sectors receive in the field, other sources are used as well. However,  both agencies’ definition of absconders and deserters is similar, and  guidance is in place for CBP field units to report the information to Coast  Guard Sectors at seaports. Developing a systematic process for the two  agencies’ headquarters to share and reconcile their data could help resolve  inconsistencies in the difference between the Coast Guard and CBP data.
While CBP and Coast Guard have each identified reporting and tracking  absconder and deserter incidents as important for strategic and tactical  reasons, the two agencies have no systematic process for sharing their  absconder and deserter data to ensure they each are reporting an accurate  and reliable representation of actual events. As a result, although DHS has  identified illegal entry into the United States as a great concern, it is  unclear how reliable the department’s records of such events are for  determining the extent of the activity and informing its strategic and  tactical planning for addressing it.
According to an official with the Coast Guard’s ICC, the lack of  coordination on this data within DHS is a data accuracy issue. He further  noted that there is precedent for Coast Guard and other DHS agencies to  coordinate in tracking data that may provide both law enforcement and  intelligence value—which may benefit both agencies in their absconder  and deserter reporting. For example, Coast Guard participates in an  existing interagency forum for coordinating data related to narcotics  seizures made in the maritime domain. As part of the Consolidated  Counterdrug Database program (CCDB), Coast Guard officials meet on a  quarterly basis with ICE and Drug Enforcement Administration officials to  compare and discuss drug trafficking event records. The purpose of this  forum is to review, de-conflict, and validate drug interdiction records to  ensure that DHS has accurate data.
CBP and Coast Guard have each faced some challenges with respect to  reporting or tracking absconder and deserter events. While the two  agencies have varied missions and collection methods for tracking and  reporting the data, obtaining an understanding of these differences and the  challenges faced would better support DHS’s efforts to address them.  Moreover, sharing intelligence information among DHS components is one  of DHS’ highest priorities, and although DHS is comprised of multiple  components, it is nevertheless a single unified entity. Since 2007, DHS  policy to improve information sharing among DHS components has called  for all relevant information generated and received by individual entities  within DHS to be accessible to and shared between and among all other  DHS components. Establishing a systematic interagency process for  sharing and reconciling information on absconder and deserter incidents  consistent with internal control standards could better support each  agency’s efforts to prevent illegal immigration at U.S. seaports and  enhance homeland security.
section_title: Civil Monetary Penalties for Seafarer Incidents Have Not Been Adjusted as Required by Law
paragraphs: The INA requires all aliens, including foreign seafarers, seeking admission  to the United States to be inspected by immigration officers and prohibits  the landing of foreign seafarers, with certain exceptions, without a  conditional landing permit. It also places a responsibility on vessel  owners and agents, upon arrival to the United States, to provide  immigration officers with a list of aliens employed on a vessel and detain  foreign seafarers until they are inspected by an immigration officer, among  other things. CBP has responsibility for identifying and reporting  violations of these provisions and imposing civil monetary penalties to  those vessel owners or agents that it determines violated the provisions.  These penalties are intended to serve as a deterrent to future violations.  The following table identifies CBP enforcement authority and associated  civil monetary penalties.
CBP has not met legal requirements for adjusting these civil penalties for  inflation. In 1996, Congress amended the Federal Civil Penalties Inflation  Adjustment Act of 1990 to require agencies to issue regulations at least  every 4 years adjusting their covered penalties for inflation. The statute  (hereinafter referred to as the “Inflation Adjustment Act”) required  agencies with covered penalties to publish initial penalty adjustments in  the Federal Register in 1996, and to adjust their penalties for inflation at  least once every 4 years thereafter. However, our review of the Federal  Register for the years 1996 to 2010 found that civil monetary penalties for  the above violations had not been adjusted for inflation since calendar  year 1999. For fiscal years 2005 through 2009, CBP reported assessing civil  monetary penalties in 320 cases involving a total of 508 individual  seafarers. CBP reported assessing and collecting approximately $883,000  and about $435,000 respectively, in 2010 dollars. However, if the penalties  had been adjusted for inflation at least every 4 years as required under the  Inflation Adjustment Act, these amounts would have been $973,000 and  $470,000 respectively.
CBP and the Department of Justice (DOJ) share responsibility for issuing  regulations pertaining to these civil penalties. Officials from both  agencies acknowledged that they had not met requirements for adjusting  the above civil penalties under the Inflation Adjustment Act—with CBP  reporting that it was because doing so had not been a priority since DHS  was established, in 2003. As a result, the agencies did not take steps to  meet requirements of the Inflation Adjustment Act. DOJ officials reported  that while the two departments share responsibilities in issuing  regulations for these penalties, DHS was responsible for drafting and  initiating development of the regulation, as DHS is responsible for  enforcing the law and imposing the civil penalties. Officials from CBP’s  Fines Office reported first contacting DOJ in fall 2009 to discuss  development of a regulation to adjust the penalties for inflation. However,  neither DHS nor DOJ was able to provide a plan with timeframes for  issuing the regulation, as recommended by project management best  practices.
Because CBP has not raised its penalties in over a decade, it has not  exercised the full scope of its enforcement authority with respect to civil  monetary penalties. Developing a plan with timelines for issuing regulation  could better position CBP in assessing its progress to increase fines in  accordance with the law and in ultimately meeting the intent of the law.  Additionally, providing this plan to DHS leadership and Congress will  provide it with key information to help ensure CBP fulfills these regulatory  requirements.
section_title: ILO 185 Implementation Is Limited; the United States Has Not Ratified Convention Due to Visa Requirement Concern
subsections: section_title: As of January 2011, ILO 185 Is Not Widely Ratified or Implemented, and Key ILO Mechanisms to Promote Compliance Are Not in Place
paragraphs: International implementation of ILO 185 has been limited to date—since  its adoption in 2003 18 countries representing approximately 30 percent of  the global seafarer supply have ratified it, and of that number, only 4 have  been confirmed to issue ILO 185 seafarers’ identity documents (SIDs),  according to a senior ILO official and an ILO meeting document. Table 5  lists the ratifying nations and dates of ratification, and indicates nations  with confirmed ILO 185 issuance. In addition, other countries are  developing ILO 185 issuance capabilities or issuing the credentials on a  small scale. These countries include Canada, France, Malaysia, Nigeria,  and the Republic of Korea, according to the ILO.
To help ensure that the minimum requirements of the Convention are met  by ratifying nations, ILO 185 established a review mechanism and  mandates regular independent audits of countries’ issuance processes.  Nations that satisfactorily complete the review will be placed on an ILO  “List” of compliant countries that meet the minimum requirements for  their SID issuance processes; nations that do not pass the review risk their  credentials’ not being recognized by other nations. However, even though  18 countries have ratified the Convention—some as long ago as 6 years— no nations’ SID system or credentials have been independently evaluated  as prescribed in the Convention, and no “List” has been created. Figure 11  in appendix VI illustrates the review process ILO established, but has not  yet implemented, to promote compliance.
In addition to the “List” process that is specific to ILO 185, the ILO  Constitution sets reporting requirements for the implementation of all ILO  conventions. For example, countries must demonstrate progress to the  ILO in implementing conventions within set time periods after ratification,  with the first reports usually submitted within 2 years of ratification.  However, in the case of ILO 185, these implementation reporting deadlines  were extended. The ILO received the first reports on ILO 185  implementation from some, but not all, countries that were requested to  make submissions in 2010. According to a senior ILO official and ILO  documents, a major reason for the delay in establishing the “List” process  and the extension of regular ILO implementation reporting deadlines was  to give the United States and other critical port nations more time to  consider ratification. The ILO official noted that some of the ratifying  countries were hesitant to invest in developing or deploying new SID  systems if the credentials would not facilitate shore leave and transit in the  United States. The ILO also wanted U.S. officials to be included in the  review panels to create the first “List,” but the panels are only open to  ratifying members.
According to a senior ILO official and ILO documents, the “List”  mechanism was created to strengthen international assurances that  credentials will be issued in accordance with the Convention and is  expected to be implemented starting in 2011. In the meantime, however,  SIDs are being issued that have not undergone the full independent  evaluation and vetting process stipulated in the Convention. For example,  according to the ILO, one ratifying nation issued about 4,000 SIDs that  were later found to be non-compliant with the Convention. These  documents were recalled and reissued, but the newly issued SIDs were not  independently evaluated and thus lack assurances that minimum  requirements were met.
section_title: U.S. Voted to Adopt ILO 185, but Did Not Ratify Due to Visa Provisions
paragraphs: As of January 2011, the United States had not ratified ILO 185 largely due  to concerns over a provision for facilitating visa-free shore leave for  foreign seafarers arriving in U.S. seaports with ILO 185 credentials. After  9/11, maritime security concerns in general took on greater urgency, and  the United States submitted a set of proposals to the International  Maritime Organization (IMO) to address specific vulnerabilities, including  those related to seafarers’ identity documents. Among other things, the  United States called for more uniform standards, including document  security and biometrics, and a means by which member states could easily  verify the validity of documents presented at ports of entry on a 24-hour  basis. One such means of verification suggested by the United States was  an electronic database capable of linking biometric information and data  elements such as seafarer name, card number, and issuing authority to  specific credentials and individuals.
Responsibility for addressing these post 9/11 security concerns related to  seafarer credentials shifted from the IMO to the ILO because of the labor  organization’s long-standing administration of an earlier instrument on  seafarer credentials, Convention 108. In 2002, the ILO invoked a “fast- track” mechanism to revise ILO 108, and the resulting convention—ILO  185—was adopted almost unanimously by ILO members in 2003. Unlike  the earlier convention, ILO 185 requires countries to adopt certain  credential features and issuance processes, incorporates fingerprint  biometrics connected to national databases for verification purposes, and  establishes a review mechanism to monitor countries’ implementation.
The U.S. tripartite delegation of government, industry, and labor officials  was among those that voted to adopt ILO 185 in 2003, and had been active  in the drafting of the Convention, according to ILO and U.S. officials.  However, because the Convention retained provisions that called for visa- free shore leave and other transit privileges for holders of ILO 185 SIDs,  the United States has not ratified the Convention. The U.S. government  considers the State Department’s visa adjudication process to be an  important layer of border security to prevent terrorists, illegal immigrants,  and criminals from gaining entry. In a statement issued at the time the  Convention was adopted, the U.S. delegation affirmed its support for the  intent of the Convention, but said that ILO 185 SIDs would not be accepted  in lieu of visas for shore leave or transit—instead, according to the  statement, the United States would consider steps to facilitate the visa  application process for seafarers.
Former and current officials from DOT MARAD and the State Department  involved with the drafting and negotiation of the Convention told us that  the U.S. government had opposed the language that provides for visa-free  shore leave. Although the provision was ultimately kept, additional  language allowed for member countries that could not meet the  requirements for visa-free admission to instead provide arrangements that  were “substantially equivalent.” According to ILO and U.S. officials this  softening of the article was intended to give the United States and other  member nations a potential avenue to ratify the Convention without  eliminating its visa requirements. The Convention itself does not define  what mechanisms may qualify as “substantially equivalent” to visa-free  shore leave. However, in 2008 the ILO provided a “discussion paper” to  U.S. agencies that outlined ways to potentially satisfy the Convention and  also allow the U.S. to issue visas to seafarers. As of December 2010, the  United States had not yet fully considered these or other potential means  to meet the “substantial equivalence” clause, according to officials we  spoke with from two agencies.
subsections: section_title: U.S. Controls the Visa Process
paragraphs: Even if the Convention oversight mechanisms, such as the “List” process  are implemented, some officials from the U.S. agencies we spoke with  believed that foregoing the U.S.-controlled visa process based on the  possession of a SID alone would expose the United States to potential  deficiencies of other nations’ processes. Figure 9 below compares  elements of the current U.S. screening process to a notional scenario in  which an ILO 185 SID could be used in lieu of a visa for shore leave. Note,  however, that other scenarios are possible under the Convention,  including retaining the visa requirement, but these alternatives have not  yet been developed.
Although the Convention establishes numerous requirements for SID  issuance procedures, countries retain discretion over their processes. The  Convention requires that issuing authorities verify a SID applicant’s  identity, nationality or permanent residence, and occupation as a seafarer.
Issuing authorities must also verify “that the applicant does not constitute  a risk to security.” Although the Convention recommends some best  practices to achieve these results, such as vetting applicants against  security-related databases, the specifics of the security vetting process are  ultimately determined by the issuing state. Furthermore, as of January  2011, the ILO has not finalized arrangements for how and to what extent  information in the national seafarer databases will be accessed. As part of  the current visa adjudication process, the State Department collects  applicants’ biometric data and checks it against databases for potential  derogatory information. Even though similar biometric data would be  collected under the ILO 185 SID issuance process, it is not clear that U.S.  agencies could access the data for a similar database check, due to  different privacy protection laws in different countries, according to ILO  documents.
section_title: U.S. Agency Components’ Positions on ILO 185 Vary; Interagency Discussions Have Been Renewed
subsections: section_title: U.S. Agency Components’ Positions on ILO 185 Vary
paragraphs: Federal agencies involved had varied viewpoints on the implications of  ILO 185. Several agencies and agency components, including the DHS  Office of Policy, CBP, Coast Guard, and ICE within DHS; the State  Department; Labor; and DOT MARAD are involved to differing degrees  with ILO 185 policy issues. Officials representing seven agencies we spoke  with cited both benefits and drawbacks of the Convention, with all  agencies reporting that the visa-free shore leave provision had been the  most significant barrier to potential U.S. ratification. Agency positions are  summarized in table 6 below:  Differences in agency positions reflect to some extent their differing  missions. For example, in discussing ILO 185, Labor officials cited shore  leave as an important worker right critical to safety while DHS Office of  Policy representatives cited the potential security benefits of using  biometric data to verify identity. DOT MARAD officials, who serve the U.S.  merchant marine population, said that how the United States grants shore  leave to foreign seafarers could impact how U.S seafarers are granted  shore leave abroad. Even within the same agency, however, component  perspectives on ILO 185 varied. For example, while acknowledging the  difficulties associated with the visa-free shore leave provision, the Coast  Guard, a component of DHS, expressed support for ILO 185. In April 2009,  the Coast Guard issued a regulation that recognized ILO 185 seafarer  documents as one of six acceptable forms of identification for persons  arriving in U.S. waters from foreign ports. On the other hand, CBP, also a  component of DHS, reported that although the ILO 185 seafarer document  may provide identity information, it did not meet its requirements as a  travel or admissibility document, and was therefore not accepted for those  CBP purposes. CBP officials we interviewed at seaport field offices and in  headquarters also questioned some of the Convention’s security benefits— including those cited by Coast Guard officials. Finally, a CBP document  noted that the Convention does not provide for U.S. oversight or periodic  review of foreign SID issuance practices. The law enforcement interests of  the United States are not served, the document maintains, without  assurance that the guidelines in the Convention are adhered to.
section_title: Renewed Interagency Discussions on ILO 185
paragraphs: Officials from relevant U.S. agencies, joined sometimes by ILO and other  stakeholder representatives, met at least six times from 2005 through 2009  to discuss the Convention and related U.S. policy implications and options.  However, according to officials who represented at least three agencies at  these meetings, the discussions did not lead to any completed analysis or  review of the Convention, and in particular, no definitive resolution was  reached as to whether the United States should pursue “substantially  equivalent” options or if the Convention cannot be ratified. Officials from  four of the participating U.S. agencies said these meetings did not yield  more results because it was difficult to achieve consistent participation  and effort by all relevant agencies, given other demands and limited  resources. For example, officials from the DHS Office of Policy  acknowledged that ILO 185 fell under their purview at the departmental  level, but that the Convention has not been a priority for their office, and  that interagency involvement from the DHS departmental level has been  limited to date. In addition, the change in administration along with legal  delays in reestablishing a cabinet level committee on ILO issues (see  below) has also postponed interagency actions on ILO 185, according to  Labor officials.
On May 4, 2010, the Secretary of Labor convened the President’s  Committee on the International Labor Organization (PC/ILO) for the first  time since 2000. Appendix VII shows the current members of the PC/ILO  and its Tripartite Advisory Panel on International Labor Standards  (TAPILS), as well as the mechanism by which the committee transmits  recommendations to the president about ratification of ILO conventions.  At its May 2010 meeting, the PC/ILO members adopted a series of  conclusions that were forwarded to the President. One of these  conclusions urged the TAPILS, in conjunction with other relevant  agencies, to expedite its review of ILO 185 and where necessary find ways  to resolve concerns about U.S. compliance. DHS is not represented at the  cabinet level of this committee; however, officials from DHS, Coast Guard,  CBP, and other relevant agencies were invited to participate as members  of the TAPILS for the purpose of reviewing ILO 185.
Although earlier interagency discussions were convened by the agencies  themselves, the formation of the PC/ILO represents a more structured  undertaking to review ILO 185 and other ILO conventions for their  congruence with U.S. laws. As of December 2010, the TAPILS had  established a procedure to review ILO 185 provisions that included  creating a working group to develop potential approaches to the legal  issues stemming from Article 6 of the Convention. However, according to  one senior Labor official involved with the working group, there is no  established time frame for the group to complete its review or for the  larger committee to make a recommendation to the President. The  previous 7 TAPILS’ law and practice reviews typically took 2 to 3 years to  complete.
section_title: Industry and Labor Organizations Support ILO 185
paragraphs: In addition to U.S. government stakeholders, we spoke with  representatives from seven industry and labor organizations, including the  International Shipping Federation (ISF) and the International Transport  Workers’ Federation (ITF)—two organizations that represent industry and  labor in the ILO—about their perspectives on ILO 185 and other seafarer  issues. All of the groups generally supported the Convention, primarily  because of its visa-free shore leave provision, which they view as an  important seafarer right and also a safety and efficiency issue. For  example, due to the nature of the shipping industry, seafarers can spend  extended time periods aboard their vessels. Without adequate time away  from the vessel in the form of shore leave, mental and physical exhaustion  can adversely affect seafarers’ welfare and lead to more accidents,  according to labor and industry representatives. Representatives from five  groups also pointed out that seafarers do not always know in advance if  their vessels may call on U.S. ports and therefore may not possess U.S.  visas for shore leave. Furthermore, representatives from the industry and  labor organizations involved with drafting the Convention believed that  ILO 185 has potential to improve maritime security if more widely  implemented, particularly through its use of biometric identification and  national seafarer databases. However, some organizations cited the cost of  developing SID systems as a significant obstacle to ratification for some  countries, particularly if the United States does not recognize the ILO 185  SIDs for shore leave.
section_title: Key Seafarer Suppliers Support Convention
paragraphs: Officials from the four foreign governments we contacted—which  collectively account for almost 30 percent of the supply of seafarers  transiting to U.S. ports—reported that they support the Convention in  general. Of these four foreign governments, two have ratified the  Convention and two have not, although all issue specialized credentials to  their seafarers. The two non-ratifying countries reported that they are  considering ratification pending legal reviews. All four countries cited  greater facilitation of shore leave for seafarers as a benefit of the  Convention. This allowance, according to the countries, is an important  safety consideration and can also increase worker productivity. Officials  from these countries also cited the increased security features of cards,  more robust background checks of SID applicants, and potential access to  seafarer databases as benefits of the Convention.
The increased cost of new SID systems is especially important given the  relatively low number of countries that have ratified the Convention to  date. For example, one country that ratified the Convention reported to us  that it had not yet begun to issue the more secure SIDs because the  positions on ILO 185 in a number of important countries are still unknown.  If holding an ILO 185 SID does not afford seafarers any greater benefit  than an older credential, particularly while in significant port countries  like the United States, there is a disincentive for countries to spend funds  upgrading their systems, according to officials from this country. Although  we did not evaluate the quality of individual security features, the three  countries we contacted that had developed ILO 185 SIDs all reported  additional features compared with prior credentials.
section_title: Conclusions
paragraphs: Given the number of seafarers transiting U.S. ports each year and the  continued threats posed by terrorism to the United States, it is important  that seafarer risks are identified and actions are taken to ensure security  of vessels and port infrastructure, while preventing illegal immigration.  DHS guidance recommends components use both physical and electronic  methods for immigration inspections, but technology limitations have  reportedly been the primary challenge to implementing this guidance on  board cargo vessels. CBP has reported that electronic verification of  immigration status or travel documents is an important objective. While  this capability is unlikely to be available for several years, opportunities  exist for CBP action. By assessing the risks of relying on physical  inspection when conducting seafarer admissibility inspections on board  cargo vessels and identifying options to address these risks and their  costs, CBP could be in a better position to determine its course of action  for addressing these risks until the technology becomes available. In  addition, both CBP and Coast Guard have reported challenges with  respect to their reporting and tracking of the illegal entry events by  seafarers, known as absconders and deserters, and based on our overall  assessment, we found their data to be of undetermined reliability.  Moreover, Coast Guard and CBP records of these incidents vary  considerably, and consequently, DHS has no accurate and reliable  estimate to gauge the extent of the incidents. For each agency, (1)  conducting a study of reporting methods and challenges faced, including  why their records vary so considerably—within and among the agencies— and (2) moving forward, establishing a process for the two agencies to  regularly share and reconcile these records could better position DHS in  developing a stronger maritime security strategy. Finally, CBP has not  increased its civil monetary penalties for seafarer-related immigration  violations, as required by law, in over a decade. Civil monetary penalties  are an important element of regulatory enforcement and can lose their  ability to deter if unadjusted for inflation. While CBP and DOJ reported  taking steps to meet requirements for inflation adjustment, the agencies  have not developed a plan including timelines for issuing required  regulation. Providing a plan with timelines for when this regulation will be  issued could provide DHS leadership and Congress with key information  and help ensure CBP fulfills regulatory requirements.
section_title: Recommendations for Executive Action
paragraphs: To facilitate better agency understanding of the potential need and  feasibility of expanding electronic verification of seafarers, to improve  data collection and sharing, and to comply with the Inflation Adjustment  Act, we are making four recommendations.
We recommend that the Secretary of Homeland Security:    direct the Commissioner of CBP to assess the national-security and other  risks faced by CBP in the absence of technology to provide electronic  verification as part of CBP’s admissibility inspections for cargo vessel  seafarers and identify options for addressing these risks and their costs;    direct the Commandant of the Coast Guard and Commissioner of CBP to:    determine the reasons that absconder and deserter data varies between  headquarters and field units, and between the Coast Guard and CBP  and determine any actions necessary to address any variance; and  jointly establish an interagency process for sharing and reconciling  records of absconder and deserter incidents occurring at U.S. seaports.
We further recommend that the Secretary of Homeland Security and the  Attorney General of the United States develop a plan with timelines for  issuing regulations, as required by the Inflation Adjustment Act, to adjust  civil monetary penalties associated with violations of the Immigration and  Nationality Act involving foreign seafarers gaining illegal entry into the  United States and provide this plan to Congress.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the departments of State, Labor,  Transportation, Justice, and Homeland Security for their review and  comment. The State Department provided technical comments. Labor, in  an e-mail we received on December 15, 2010, also provided technical  comments as well as a general comment regarding the ILO 185  Convention. The Transportation Department did not provide comments on  the draft. DOJ did not provide official written comments on our report.  However, in an e-mail received December 9, 2010, the DOJ liaison stated  that DOJ concurred with the one recommendation we made to DOJ in the  report. DHS, in written comments received December 17, 2010, concurred  with all four of the recommendations in the report directed to DHS, and  identified actions taken, planned, or under way to implement the  recommendations. Written comments are summarized below and  reproduced in appendix VIII. DHS also provided technical comments that  we incorporated as appropriate.
Regarding our recommendation to assess the national-security and other  risks faced by CBP in the absence of technology to provide electronic  verification as part of its admissibility inspections for cargo vessel  seafarers and to identify options for addressing these risks and their costs,  DHS concurred. DHS stated that CBP will work in conjunction with the  DHS Screening Coordination Office to determine parameters to measure  and assess risks associated with the absence of technology for onboard  vessel inspection of seafarers.
Regarding our recommendation to (1) determine the reasons that  absconder and deserter data varies between headquarters and field units,  and between the Coast Guard and CBP and determine any actions  necessary to address them and (2) jointly establish an interagency process  for sharing and reconciling records of absconder and deserter incidents  occurring at U.S. seaports, DHS concurred. DHS stated that CBP and the  Coast Guard would begin to asses the appropriate offices within each  component involved in the review and to establish a working group to  evaluate the current reporting process within each component, and  between CBP and Coast Guard. Further, in its technical comments, DHS  noted that it was working to co-locate the Coast Guard’s ICC Coastwatch  and CBP’s National Targeting Center-Passenger and that this would help  to eliminate many of the absconder- and deserter-reporting  inconsistencies GAO identified between Coast Guard and CBP.
Regarding our recommendation that the Secretary of Homeland Security  and the Attorney General of the United States develop a plan with  timelines for issuing regulations, as required by the Inflation Adjustment  Act, to adjust civil monetary penalties associated with violations of the  Immigration and Nationality Act involving foreign seafarers gaining illegal  entry into the United States and provide this plan to Congress, both DHS  and DOJ concurred. DHS stated that it was currently working together  with DOJ to develop the regulations and hoped to issue final regulations in  2011. DOJ stated that it would report to Congress after GAO issued this  report. However, it remains important that the two departments develop a  plan with timelines for completing these actions and provide this  information to Congress.
Finally, while we made no recommendations regarding the status of the  ILO 185 Seafarers’ Identity Document Convention, DHS and Labor both  provided comments related to potential incongruence between the  Convention and existing U.S. law. DHS noted that CBP would object to  ratification of the ILO 185 Convention because of limitations of existing  laws for CBP enforcement. Also, in oral and technical comments provided,  Labor’s Director of the Office of International Relations within the Bureau  of International Labor Affairs suggested we note the May 2010  recommendation of the PC/ILO that urged TAPILS and all relevant U.S.  agencies to expedite its review of ILO 185 to find ways to resolve concerns  about U.S. compliance.
We are providing copies of this report to appropriate congressional  committees, to the Secretaries of State, Labor, Transportation, and  Homeland Security, to the Attorney General, and to other interested  parties. This report will also be available at no charge on the GAO Web site  at http://www.gao.gov.
If you or your staff has any questions concerning this report, please  contact me at (202) 512-7036 or by e-mail at jeszeckc@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. Key contributors to this report are  listed in appendix IX.
section_title: Appendix I: Key International and National Requirements and Guidance Applicable to Seafarer Security
paragraphs: Table 7 below lists select international and national laws, conventions or  guidance that govern various aspects of seafarer security.
section_title: Appendix II: Key State Department Actions Since 9/11 to Strengthen Visa Adjudication Process
paragraphs: Following the 9/11 terrorist attacks, the State Department sought to make  its visa adjudication process more robust. Table 8 below describes some of  the efforts initiated by the department in the areas of information/systems  management, training, and collaboration with U.S. Immigration and  Customs Enforcement (ICE).
section_title: Appendix III: DHS Advance-Targeting Process
paragraphs: CBP and Coast Guard each conduct advance-targeting of passenger and  crew information to identify potential threats.
Within CBP, the National Targeting Center-Passenger (NTC-P) screens  passenger and crew manifests against certain databases, such as records  from the Terrorist Screening Data Base (TSDB)—commonly referred to as  the terrorist watch list—and the Federal Bureau of Investigation’s National  Crime Information Center (NCIC) database, to determine their potential  risk to the United States. This screening process is designed to identify  individuals with potential terrorism links or criminal warrants and those  passengers and crew with potential immigration admissibility problems.  NTC-P uses an automated system—known as the Automated Targeting  System-Passenger (ATS-P)—to screen individuals against various data  sources.  If NTC-P identifies a potential match to a TSDB record during its  targeting, NTC-P refers the potential match to the FBI’s Terrorist  Screening Center (TSC) for further vetting and confirmation. The TSC will  make the final determination that the individual is a positive or negative  match to the terrorist watchlist record. According to CBP officials, the  number of terrorist-positive matches are extremely small in the maritime  environment compared to those transiting to air and land ports of entry in  large part due to the relatively smaller population of travelers arriving at  seaports.
Also at the national level, Coast Guard’s ICC performs central screening of  the Advance Notice of Arrival (ANOA) to identify potential ties to criminal  or terrorist activity. Should the ICC identify potential ties, it will  disseminate the results of its screening to the Coast Guard at the seaport  location where the vessel will be arriving—which will then be shared with  the local CBP field unit at that location.
At the local seaport level, CBP field units also conduct advance-targeting  of crew and passenger manifest information. CBP Passenger Analysis  Units (PAU) review arrival manifests using the ATS-P to identify  individuals who pose security risks and warrant additional inspection. The  screening process by NTC-P and the PAU identifies persons of interest  prior to the inspection and provides support to the CBP field officer to  determine if a seafarer can be authorized temporary landing privileges in  the United States. PAU officers interact with both the NTC-P and the local  Coast Guard Sector if they identify seafarers posing potential security  concerns. Coast Guard Sectors rely on the ICC and CBP for information  regarding any persons of interest and guidance on what actions to take  based on the nature of the concern.
CBP NTC-P officials reported that while NTC-P and local PAU’s generally  reviewed similar information, they played complementary roles in  identifying potential crewmember risks. For example, NTC-P has access to  more terrorist-screening resources than do most local PAU’s and the NTC- P is staffed with officials from other law enforcement agencies, such as  the FBI. Meanwhile, with local knowledge of seaport point of entry  activity, PAU’s conduct further screening with a focus on seafarer  immigration and law enforcement risks.
section_title: Appendix IV: CBP and Coast Guard Seafarer- Related Enforcement and Compliance Boardings and Inspections
subsections: section_title: Selected CBP Seafarer- Related Vessel Boardings and Inspections
paragraphs: Cargo Vessel Immigration Admissibility Boardings: To inspect seafarers  arriving on cargo vessels, CBP officers board the vessel, order the crew to  gather in a common area—typically the galley or crew lounge—and  conduct interviews with each seafarer. Since these inspections occur on  board the vessel in an un-automated environment, CBP officers have to  rely on information vetted before boarding the vessel and their skill sets to  identify fraud, both in documents and during interviews with seafarers.   CBP officials report that if a concern arises regarding the identity of a  crew being inspected on board a cargo vessel, CBP officers are equipped  with radios or cell phones to call back to the CBP PAU or NTC-P for  assistance.
Enforcement and Compliance Inspections: In addition to CBP’s  admissibility boardings, CBP boards commercial vessels to inspect crew  as part of compliance inspections or risk-based security operations. CBP  may conduct vessel boardings to address risks identified during advance-  targeting and ensure vessel operator compliance with immigration  regulations. Such boardings include reviewing security measures in place  by the vessel operator to ensure high-risk seafarers to not depart the  vessel.
section_title: Selected Coast Guard Seafarer-Related Boardings and Inspections
paragraphs: Coast Guard uses the results of its targeting assessments to guide the type  and extent of operations field units may conduct on arriving commercial  vessels. For example, based on intelligence, Coast Guard may conduct  armed security boardings to examine seafarer passports and visas and  ensure the crew list submitted via Advance Notice of Arrival (ANOA) is  accurate. It also conducts inspections of vessel crew as part of its  regulatory responsibility under the Maritime Transportation Security Act  (MTSA), International Ship and Port Facility (ISPS), and Port State  Control requirements of vessel operators. These include inspections of  crew identification and travel documents, and reviews of crew  certification and licensing documentation. From fiscal years 2006 through  2009, Coast Guard reported it had conducted approximately 17,000 MTSA  and 37,000 ISPS inspections of commercial vessels entering U.S. ports. Of  these inspections, Coast Guard reported finding approximately 5,000  security violations, which were generally related to access control of the  vessel.
section_title: Appendix V: Comparison of CBP and Coast Guard Field Unit Reports of Absconder and Deserter Incidents at Selected Seaports, Fiscal Years 2005 through 2009
paragraphs: We requested data from CBP field units and Coast Guard Sectors at eight  domestic seaports summarizing the number of absconder and deserter  incidents that the field units and sectors reported for fiscal years 2005  through 2009. At six of seven seaports that provided comparable data, CBP  and Coast Guard field units and sectors reported varying numbers of  incidents (see notes below describing our scope and methods of this  analysis). CBP and Coast Guard field units and sectors reported the same  number of incidents at only one seaport (Jacksonville). Below is a  summary of the field unit reported data.
section_title: Appendix VI: Summary of International Labor Organization’s Seafarers’ Identity Documents Convention (Revised), 2003 (ILO 185)
paragraphs: Appendix VI: S Orga Convention (Revised), 2003 (ILO 185)
The International Labor Organization’s Convention 185 (ILO 185)  establishes international standards for nationally issued seafarers’ identity  documents (SIDs). The Convention seeks to create a framework for  nations to issue more secure, standardized credentials to bona fide  seafarers, which, in turn, helps seafarers gain access to foreign territories  for shore leave and other professional travel, such as transiting from an  airport to meet a vessel in port.
subsections: section_title: ILO 185 Replaces an Earlier ILO Convention on Seafarers’ Identity Documents
paragraphs: ILO 185 is a revision of ILO 108, a 1958 convention that established a  structure for international recognition of national seafarers’ identity  documents. Ratified by a total of 64 countries that did not include the  United States, Convention 108 required ratifying countries to issue  seafarers’ identity documents or seafarer passports to applicants to  facilitate seafarer entry into foreign territories for shore leave or transit to  or from a vessel. Aside from basic requirements, such as mandating that  the documents list a seafarer’s full name and date of birth and contain a  photograph, ILO 108 did not specify how the documents should appear or  provide guidance on issuance processes. According to the ILO, identity  documents issued under ILO 108 varied greatly in appearance and most  did not contain security features. Moreover, according to a 2002 ILO  briefing paper, member states were often unaware of what each others’  ILO 108 documents looked like, if the documents were real or counterfeit,  and even whether the government in question had ratified the Convention.  Furthermore, the Convention permitted a ratifying nation to issue  documents to seafarers who were not citizens or permanent residents as  long as they worked on vessels registered in the country or in its territory.  This practice, according to an ILO official, resulted in some seafarers  obtaining valid identification credentials from multiple nations based on  their employment.
To a much greater extent than ILO 108, the revised ILO 185 Convention  sets minimum standards for how ratifying countries produce and issue  their seafarer identity documents, including the data they contain, security  features, and a fingerprint biometric. For example, ILO 185 requires SIDs  to comply with certain International Civil Aviation Organization (ICAO)  passport or other travel document specifications regarding materials used  and credential dimensions and placement of data. The Convention also  makes certain requirements for countries to maintain a national database  to track credential issuance, whose information must be accessible to  other ratifying nations, and calls for independent evaluations of SID  issuance processes and ILO certifications of compliance.
section_title: Proposed ILO “Listing” Process to Promote Convention Compliance
paragraphs: In accordance with Article 5 of the Convention, in 2005 the ILO developed  a specific process by which its Governing Body could approve a “List” of  ratifying nations that met minimum Convention requirements. In part due  to the limited number of ratifying nations to date, this process has not yet  been implemented, and as of January 2011, there is no list of compliant  countries.
section_title: Appendix VII: President’s Committee on the International Labor Organization (PC/ILO)
paragraphs: Appendix VII: President’s Committee on the  International Labor Organization (PC/ILO)
The President’s Committee on the International Labor Organization  (PC/ILO) is a federal advisory committee that, among other things,  evaluates ILO conventions and makes recommendations to the President  concerning potential U.S. ratification. The PC/ILO is chaired by the  Secretary of Labor and consists of other cabinet level representatives from  U.S. government as well as senior officials from labor and industry. Before  the full committee reports to the President, a committee subgroup, the  Tripartite Advisory Panel on International Labor Standards (TAPILS),  reviews selected conventions for conformity with U.S. law. The PC/ILO  was most recently convened in May 2010, and stated that a review of ILO  185 was a priority. Figure 12 below shows current PC/ILO membership  and the mechanism by which it makes its recommendations.
section_title: Appendix VIII: Comments from the Department of Homeland Security
section_title: Appendix IX: GAO Contacts and Staff Acknowledgments
paragraphs: Charles A. Jeszeck, (202) 512-7036 or jeszeckc@gao.gov.
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, David Bruno, Assistant Director,  and Jason Berman, Analyst-in-Charge, managed this assignment. Chloe  Brown and David Lutter made significant contributions to this report.  Charles Bausell, Kathryn Bernet, Namita Bhatia Sabharwal, Richard Hung,  and Stanley Kostyla assisted with design and methodology. Tracey King  provided legal support. Jessica Orr provided assistance in report  preparation.
section_title: Related GAO Products
paragraphs: Maritime Security: Ferry Security Measures Have Been Implemented,  but Evaluating Existing Studies Could Further Enhance Security.  GAO-11-207. Washington, D.C.: Dec. 3, 2010.
Maritime Security: Actions Needed to Assess and Update Plan and  Enhance Collaboration among Partners Involved in Countering Piracy  off the Horn of Africa. GAO-10-856. Washington, D.C.: Sep. 24, 2010.
Maritime Security: DHS Progress and Challenges in Key Areas of Port  Security. GAO-10-940T. Washington, D.C.: July 21, 2010.
Maritime Security: Varied Actions Taken to Enhance Cruise Ship  Security, but Some Concerns Remain. GAO-10-400. Washington, D.C.:  Apr. 9, 2010.
Supply Chain Security: Feasibility and Cost-Benefit Analysis Would  Assist DHS and Congress in Assessing and Implementing the  Requirement to Scan 100 Percent of U.S.-Bound Containers. GAO-10-12.  Washington, D.C.: Oct. 30, 2009.
Maritime Security: Vessel Tracking Systems Provide Key Information,  but the Need for Duplicate Data Should Be Reviewed. GAO-09-337.  Washington, D.C.: March 17, 2009.
Supply Chain Security: CBP Works with International Entities to  Promote Global Customs Security Standards and Initiatives, but  Challenges Remain. GAO-08-538. Washington, D.C.: August 15, 2008.
Maritime Security: National Strategy and Supporting Plans Were  Generally Well-Developed and Are Being Implemented. GAO-08-672.  Washington, D.C.: June 20, 2008.
Supply Chain Security: Challenges to Scanning 100 Percent of U.S.- Bound Cargo Containers. GAO-08-533T. Washington, D.C.: June 12, 2008.
Supply Chain Security: U.S. Customs and Border Protection Has  Enhanced Its Partnership with Import Trade Sectors, but Challenges  Remain in Verifying Security Practices. GAO-08-240. Washington, D.C.:  April 25, 2008.
Maritime Security: Coast Guard Inspections Identify and Correct  Facility Deficiencies, but More Analysis Needed of Program’s Staffing,  Practices, and Data. GAO-08-12. Washington, D.C.: February 14, 2008.
Supply Chain Security: Examinations of High-Risk Cargo at Foreign  Seaports Have Increased, but Improved Data Collection and Performance  Measures Are Needed. GAO-08-187. Washington, D.C.: January 25, 2008.
Maritime Security: Federal Efforts Needed to Address Challenges in  Preventing and Responding to Terrorist Attacks on Energy Commodity  Tankers. GAO-08-141. Washington, D.C.: December 10, 2007.
Maritime Security: The SAFE Port Act: Status and Implementation One  Year Later. GAO-08-126T. Washington, D.C.: October 30, 2007.
Combating Nuclear Smuggling: Additional Actions Needed to Ensure  Adequate Testing of Next Generation Radiation Detection Equipment.  GAO-07-1247T. Washington, D.C.: September 18, 2007.
Information on Port Security in the Caribbean Basin. GAO-07-804R.  Washington, D.C.: June 29, 2007.
Port Risk Management: Additional Federal Guidance Would Aid Ports in  Disaster Planning and Recovery. GAO-07-412. Washington, D.C.: March  28, 2007.
Maritime Security: Public Safety Consequences of a Terrorist Attack on  a Tanker Carrying Liquefied Natural Gas Need Clarification.  GAO-07-316. Washington, D.C.: February 22, 2007.
Coast Guard: Observations on the Preparation, Response, and Recovery  Missions Related to Hurricane Katrina. GAO-06-903. Washington, D.C.:  July 31, 2006.
Maritime Security: Information Sharing Efforts Are Improving.  GAO-06-933T. Washington, D.C.: July 10, 2006.
Cargo Container Inspections: Preliminary Observations on the Status of  Efforts to Improve the Automated Targeting System. GAO-06-591T.  Washington, D.C.: March 30, 2006.
Risk Management: Further Refinements Needed to Assess Risks and  Prioritize Protective Measures at Ports and Other Critical  Infrastructure. GAO-06-91. Washington, D.C.: December 15, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved.  GAO-05-466T. Washington, D.C.: May 26, 2005.
Maritime Security: Enhancements Made, But Implementation and  Sustainability Remain Key Challenges. GAO-05-448T. Washington, D.C.:  May 17, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment  Requirements Would Improve Overseas Targeting and Inspection  Efforts. GAO-05-557. Washington, D.C.: April 26, 2005.
Maritime Security: New Structures Have Improved Information  Sharing, but Security Clearance Processing Requires Further Attention.  GAO-05-394. Washington, D.C.: April 15, 2005.
Cargo Security: Partnership Program Grants Importers Reduced  Scrutiny with Limited Assurance of Improved Security. GAO-05-404.  Washington, D.C.: March 11, 2005.
Maritime Security: Better Planning Needed to Help Ensure an Effective  Port Security Assessment Program. GAO-04-1062. Washington, D.C.:  September 30, 2004.
Maritime Security: Partnering Could Reduce Federal Costs and  Facilitate Implementation of Automatic Vessel Identification System.  GAO-04-868. Washington, D.C.: July 23, 2004.
Maritime Security: Substantial Work Remains to Translate New  Planning Requirements into Effective Port Security. GAO-04-838.  Washington, D.C.: June 30, 2004.
Homeland Security: Summary of Challenges Faced in Targeting  Oceangoing Cargo Containers for Inspection. GAO-04-557T. Washington,  D.C.: March 31, 2004.
Homeland Security: Preliminary Observations on Efforts to Target  Security Inspections of Cargo Containers. GAO-04-325T. Washington,  D.C.: December 16, 2003.
Maritime Security: Progress Made in Implementing Maritime  Transportation Security Act, but Concerns Remain. GAO-03-1155T.  Washington, D.C.: September 9, 2003.
Combating Terrorism: Interagency Framework and Agency Programs to  Address the Overseas Threat. GAO-03-165. Washington, D.C.: May 23,  2003.
Nuclear Nonproliferation: U.S. Efforts to Combat Nuclear Smuggling.  GAO-02-989T. Washington, D.C.: July 30, 2002.
Coast Guard: Vessel Identification System Development Needs to Be  Reassessed. GAO-02-477. Washington, D.C.: May 24, 2002.