Building Partner Capacity: U.S. Agencies Can Improve Monitoring of Counter-Firearms Trafficking Efforts in Belize, Guatemala, and Mexico
Released: 2016-02-02T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: Trafficking of illicit materials, including firearms, is widespread across Mexico's more than 700-mile southern border with Guatemala and Belize. Such trafficking presents a challenge for law enforcement in all three countries and for U.S. security interests. State and other U.S. agencies, such as ATF, have provided support to build the capacity of their counterparts in these three countries to address problems related to firearms trafficking. GAO was asked to review U.S. support to the governments of Belize, Guatemala, and Mexico to stem firearms trafficking across their shared border. This report examines, for these three countries, (1) the activities undertaken by U.S. agencies to build partner capacity to combat firearms trafficking and the extent to which they considered key factors in selecting the activities and (2) progress the United States has made in building such capacity. GAO analyzed program documentation and conducted interviews with U.S., Belizean, Guatemalan, and Mexican officials. To examine progress, GAO selected a nongeneralizable sample of eight key activities based on a number of factors, including whether the activity addressed firearms trafficking.

section_title: What GAO Found
paragraphs: U.S. agencies and their implementing partners have undertaken a number of capacity-building activities that support counter-firearms trafficking efforts in Belize, Guatemala, and Mexico. The figure below outlines examples of the areas of effort under which these activities fall. Selected, in part, based on partner country needs, these activities include efforts to provide support in using the Bureau of Alcohol, Tobacco, Firearms and Explosives' (ATF) web-based firearms tracing system (eTrace) and providing forensics training, including on ballistics. Some of these activities, such as firearms identification training, relate directly to firearms trafficking, while others broadly support antitrafficking or border security efforts for which stemming the trafficking of firearms is one of many goals. Presidential Policy Directive 23 highlights key factors, including partner country needs, absorptive capacity, sustainability, and other U.S. and other donor efforts, as important in planning security sector assistance. Agencies considered these factors in determining what activities to fund.

U.S. agencies and implementing partners have achieved many of their goals for eight key counter-firearms trafficking activities GAO reviewed, but could enhance their efforts to measure and report on progress. Agencies and implementers established performance measures and targets for five of these eight activities. Standards for Internal Control in the Federal Government states that managers should compare actual performance against expected results, highlighting the importance of such measures and targets. ATF tracks its activities but has not established performance targets for them, without which it is difficult to measure the success of its efforts. Two of the five activities GAO reviewed that established metrics and targets are ongoing and are meeting their goals, while three other activities were completed and met or partially met their goals, according to Department of State (State) and implementer reports. For activities it funds, State requires implementers to include a discussion of key challenges and strategies to address those challenges in quarterly reports. However, implementers' reports for activities GAO reviewed were inconsistent and did not always identify challenges or strategies for addressing them. Without this information, agencies risk not fully meeting their goals and may be unable to maximize the use of U.S. resources.

section_title: What GAO Recommends
paragraphs: GAO recommends that (1) ATF establish and document performance targets for its key counter-firearms trafficking activities in Belize, Guatemala, and Mexico, as appropriate, and (2) State work with other U.S. agencies and implementers to help ensure that progress reports identify key challenges and plans to address them. ATF and State agreed with these recommendations.

section_title: Letter
paragraphs: Trafficking of illicit materials, including firearms, is widespread across  Mexico’s more than 700-mile southern border with Guatemala and Belize.  This trafficking is closely linked to the activities of transnational criminal  organizations that are engaged in violent activities throughout the region.  For example, from 2007 to 2014, there were more than 70,000 homicides  related to criminal violence in Mexico. Similarly, fighting among criminal  organizations over contested trafficking routes in Central America has  fueled violence in Guatemala and Belize, which, according to the United  Nations Office on Drugs and Crime, had two of the highest homicide rates  in the world in 2012, the last year for which comprehensive data are  available. This violence, accompanying the flow of drugs throughout the  region, perpetuates the demand for firearms and presents a broader  challenge for law enforcement in all three countries, as well as for U.S.  security interests in the region.

U.S., Belizean, Guatemalan, and Mexican officials have all noted that  countering firearms trafficking is a priority for the region. The  governments of Belize, Guatemala, and Mexico have recognized the  need to improve the capacity of law enforcement organizations and other  criminal justice sector institutions to combat illegal firearms trafficking and  have initiated efforts to enhance their abilities to fight transnational  organized crime. The President of the United States has also  acknowledged the need to stem the flow of firearms to the region and has  committed U.S. support for these efforts. The Department of State  (State)—primarily through programs such as the Merida Initiative and the  Central America Regional Security Initiative (CARSI)—and other U.S.  agencies, such as the Bureau of Alcohol, Tobacco, Firearms and  Explosives (ATF) and U.S. Customs and Border Protection (CBP), have  provided support to build the capacity of their Belizean, Guatemalan, and  Mexican counterparts to address problems related to firearms trafficking.

You asked us to review U.S. support for the governments of Belize,  Guatemala, and Mexico to stem firearms trafficking across their shared  border. This report examines (1) the activities undertaken by U.S.  agencies to build partner capacity to combat firearms trafficking in Belize,  Guatemala, and Mexico and the extent to which they considered key  factors in selecting the activities and (2) the progress the United States  has made in building partner capacity in Belize, Guatemala, and Mexico  to combat firearms trafficking.

To address these objectives, we analyzed information from State, ATF,  CBP, the International Criminal Investigative Training Assistance Program  (ICITAP), and Immigration and Customs Enforcement (ICE), as well as  funding data for fiscal years 2010 through 2014 for programs that directly  or indirectly addressed firearms trafficking. We interviewed U.S. officials  and officials from the Organization of American States (OAS) in  Washington, D.C., and U.S. and Mexican officials in Mexico. Additionally,  we conducted interviews with Guatemalan and Belizean officials. We  compiled a list of activities that included combatting firearms trafficking as  at least one goal, but because other activities may also indirectly touch on  firearms trafficking, the list may not be comprehensive. To determine the  extent to which U.S. agencies considered key factors in selecting  capacity-building activities, we analyzed Presidential Policy Directive 23  (PPD 23), a directive on security sector assistance, and identified the key  factors it instructs agencies to consider when planning security sector  activities. We then analyzed agency documentation and interviewed U.S.  and foreign government officials to determine whether U.S. agencies that  conducted counter-firearms trafficking capacity-building activities  considered these factors.

To assess U.S. progress in building partner capacity in Belize,  Guatemala, and Mexico to combat firearms trafficking, we examined a  subset of capacity-building activities. Our review of these activities is not  generalizable to all activities conducted by U.S. agencies and their  implementing partners. Each of the eight key activities we reviewed (1)  included a specific component or objective that addresses firearms  trafficking, (2) had a substantial portion of funds directed to the activity, or  (3) was identified by U.S. and foreign officials as a key effort in building  partner capacity to combat firearms trafficking. We reviewed State and  implementing agency or organization progress reports that assessed  progress against the performance measures and targets set for each  activity. Based on interviews with knowledgeable agency officials and a  review of State’s relevant internal controls, we determined that data on  funding for these activities provided by State and ATF were sufficiently  reliable for the purposes of this report. For more information on our scope  and methodology, see appendix I.

We conducted this performance audit from February 2015 to January  2016 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
paragraphs: In Mexico, where, according to U.S. officials, the commercial sale or  purchase of a firearm is prohibited and strict controls limit citizens’ access  to firearms, illicitly trafficked firearms fuel drug trafficking violence, as we  reported in 2009. According to data from ATF’s web-based firearms  tracing system, eTrace, the majority of the guns seized and traced in  Mexico—about 70 percent from 2010 through 2014—have origins in the  United States.

As we also reported in 2009, the Mexican government initiated a new  national security strategy in 2006 to combat the growing power of criminal  organizations and curb their ability to operate with impunity in certain  areas of Mexico. The organizations countered government pressure with  increased violence against law enforcement entities and the  government’s efforts also appeared to result in increasing conflicts among  criminal organizations over lucrative drug trafficking routes. The United  Nations Office on Drugs and Crime has noted that the Mexican  government’s shift in strategy also affected trafficking routes in Central  America. As it became more hazardous for traffickers to ship drugs,  particularly cocaine, directly to Mexico via air and waterways, an  increasing share of the drug trade began to move overland through  Central America. Those routes entered Mexico through its shared  southern land border with Guatemala and, to a lesser extent, Belize.

According to the United Nations Office on Drugs and Crime, this change  in trafficking patterns resulted in increased competition for territorial  control among local organized crime groups. Over time, Mexican criminal  organizations also increasingly moved south into Central America to gain  control of trafficking routes. As a result, violence increased substantially in  countries throughout Central America. In recent years, the people of  Central America and Mexico have cited violent crime as one of the most  important issues facing their countries. Many of the criminal organizations  involved in the drug trade also traffic firearms across the region.

Although most of the firearms seized and traced in Mexico transited  across its northern border with the United States, firearms also travel in  both directions across Mexico’s southern border. It is difficult to ascertain  the volume of firearms trafficked across Mexico’s border with Guatemala  and Belize; however, according to the Mexican government, firearm  seizure rates in Mexico’s southern border states are low in comparison to  those of northern border states and the rest of the country. According to a  binational assessment conducted by U.S. and Mexican officials, many  Central American countries lack the capability to trace firearms  independently, which makes it difficult to determine the percentage of  weapons seized and traced in Mexico that have an origin in Central  America. Also, according to ATF officials, unlike Mexico, both Guatemala  and Belize allow for the commercial sale and purchase of firearms, so the  availability of legal firearms differs considerably across the three  countries. Guatemala and Belize are much smaller countries than Mexico,  and ATF data on seized and traced firearms indicate that the volume of  firearms seized and traced in these countries is also much smaller than  that in Mexico. For example, from 2010 to 2014, Mexico seized and  traced about 83,000 firearms, while Guatemala seized and traced about  7,000 firearms and Belize seized and traced about 300 firearms.

A number of U.S. agencies provide capacity-building assistance in the  three countries to help address concerns associated with firearms  trafficking, among other things.

State: State’s Bureau of International Narcotics and Law Enforcement  Affairs (INL) manages most of the funding for the Merida Initiative and  CARSI, the two primary initiatives through which the U.S. government  funds and manages activities to help address the problem of  increasing crime and violence in Mexico and Central America,  respectively. In cooperation with several other U.S. agencies, State is  also responsible for the overall implementation of these two initiatives.

State’s Bureau of Political-Military Affairs, Office of Weapons Removal  and Abatement (PM/WRA) works to reduce the harmful, worldwide  effects of at-risk, illicitly proliferated, and indiscriminately used  conventional weapons of war, including small arms and light  weapons. PM/WRA supports programs around the world that assist  governments in securing or destroying abandoned or stockpiled  munitions, with a goal of curbing illicit trafficking.

In most cases, State does not directly implement counter-firearms  activities but instead provides funding for other U.S. agencies or other  implementers, such as international organizations or  nongovernmental organizations, to implement the activities. As the  funding organization, State maintains responsibility for oversight of  these efforts.

Department of Justice: For over 45 years, ATF has implemented  efforts to combat arms trafficking within the United States and from  the United States to other countries as part of its mission under the  Gun Control Act. ATF is responsible for investigating criminal and  regulatory violations of federal firearms laws, among other  responsibilities. ATF traces U.S. and foreign manufactured firearms  for international, federal, state, and local law enforcement agencies, to  link a firearm recovered in a criminal investigation to its first retail  purchaser. It is the only entity within the U.S. government able to trace  firearms recovered from crimes in Mexico. ATF has four offices in  Mexico and an office in El Salvador that provides assistance  throughout Central America, including in Guatemala and Belize.  Through these offices, ATF provides an international liaison to support  ATF’s mission to interdict and prevent illegal firearms trafficking and  combat violent criminal gangs.

ICITAP works with foreign governments to develop professional and  transparent law enforcement institutions that protect human rights,  combat corruption, and reduce the threat of transnational crime and  terrorism. ICITAP provides a wide range of public safety development  expertise, including assistance in areas such as organizational  development, criminal investigations, and forensics.

Department of Homeland Security: CBP coordinates and supports  foreign initiatives, programs, and activities with its external partners  around the world. CBP strives to protect U.S. borders by  implementing programs and initiatives that promote antiterrorism,  global border security, nonproliferation, export controls, immigration,  and capacity building.

For over 30 years, ICE—and previously the U.S. Customs Service— has implemented efforts to enforce U.S. export laws. ICE agents and  other staff address a range of issues, including combating the illicit  smuggling of money, people, drugs, and firearms. ICE has offices in  Mexico and Guatemala whose missions are to support domestic  operations by coordinating investigations with foreign counterparts,  disrupt criminal efforts to smuggle people and materials into the  United States, and build international partnerships through outreach  and training.

section_title: U.S. Agencies Provide a Variety of Counter-Firearms Trafficking Capacity- Building Assistance and Considered Key Factors in Selecting Activities
subsections: section_title: U.S. Agencies Provide a Variety of Counter- Firearms Trafficking Capacity-Building Assistance in Belize, Guatemala, and Mexico
paragraphs: U.S. agencies and other implementing partners have undertaken a  number of capacity-building activities that directly or indirectly support  counter-firearms trafficking efforts in Belize, Guatemala, and Mexico.  Figure 1 outlines the areas of effort under which these activities fall.

As discussed below, these activities were selected based, in part, on the  needs of each country. Some of these activities relate directly to firearms  trafficking, such as ATF firearms identification training, while others  broadly support antitrafficking or border security efforts that include efforts  to stem the trafficking of firearms as one of many goals. For example,  State has provided nonintrusive inspection equipment to Mexico that can  be used to scan vehicles and containers for drugs or other contraband,  including firearms. These activities are largely funded by State and  implemented by other U.S. agencies or other implementing partners,  including international organizations or nongovernmental organizations.  The activities include the following:

Firearms training: ATF has an attaché in Mexico and a regional  attaché in El Salvador who supports activities throughout Central  America, including in Guatemala and Belize. Among their  responsibilities is managing a series of training courses for local  officials. In fiscal year 2014, ATF’s Mexico office managed 27 courses  that trained over 1,200 students. These training courses covered a  number of topics related to firearms and explosives and included 10  firearms identification courses. In the same year, ATF’s Central  America office managed 3 courses that trained nearly 200 students.  All 3 courses covered eTrace and 1 also covered investigative  techniques.

Provision and support of eTrace: ATF helps partner country  governments improve their use of the eTrace system. In 2009, ATF  launched a Spanish-language version of the system, which is used in  Guatemala and Mexico. Belizean officials use the English version of  eTrace. ATF officials work with host country officials to ensure that  they understand how to use the system and to encourage them to  input all crime weapons seized within the country into the system for  tracing.

Stockpile management: From 2010 through 2012, PM/WRA  provided a grant to the OAS to assist in the destruction of excess  firearms and ammunition in Guatemala. In 2012, PM/WRA also  provided funding for enhanced physical security of stockpile storage  facilities in Belize.

Firearms marking equipment and training: Under a PM/WRA  grant, from 2009 through 2014, the OAS implemented a program to  help facilitate the tracing process by distributing firearms marking  machines throughout Latin America and the Caribbean, including in  Guatemala and Belize. The program also included training on how to  use the equipment. The program provided five machines to  Guatemala and one machine to Belize, based on an assessment of  the needs of each country.

Forensic training and assistance: The United States initiated  several efforts to enhance the capacity of forensics labs, including  their ability to conduct ballistics work, in each of the three countries. In  Mexico, INL and ICITAP have provided support at the national and  state levels, through two separate programs, to help forensics labs  meet international standards. In Central America, INL supported a  regional program in forensics training. Additionally, INL officials noted  that INL has provided bilateral support to the forensics labs in both  Guatemala and Belize, including bringing a ballistics expert to Belize  for a yearlong detail in its forensics lab. According to INL officials,  INL intends to extend this detail by another year.

Additionally, the United States has supported the use of the Integrated  Ballistics Identification System (IBIS) in forensics labs in each country.  IBIS is designed to capture, file, and compare images of bullets and  cartridge casings. Investigators can use the system in examining  crime-related guns. INL has provided equipment, training, or both in  all three countries to initiate or enhance the use of IBIS and has  encouraged the countries to link their systems to those of neighboring  countries to enhance law enforcement capabilities throughout the  region.

Support for specialized units: In all three countries, INL and other  U.S. agencies have supported antitrafficking law enforcement units. In  Guatemala, ICE has supported the creation and sustainment of a  Transnational Criminal Investigative Unit—a unit of local law  enforcement officers who receive training and work closely with ICE  agents in investigating transnational crimes, including firearms  trafficking. With support from INL, ICE’s Mexico office also established  two Transnational Criminal Investigative Units in 2015, according to  U.S. officials. In Belize, INL and CBP have supported the creation and  sustainment of a mobile interdiction team that combats trafficking of  all illegal substances and materials, including firearms.

In Guatemala, INL and ATF have also provided support to the  Attorney General’s office, including to a firearms-specific group within  its organized crime unit. For example, Guatemalan officials noted that  ATF has provided technical guidance and expertise on firearms- related investigations. According to U.S. and Guatemalan officials,  INL and ATF have also provided training and equipment to support  the creation of a firearms and explosives unit within the Guatemalan  National Police.

Nonintrusive inspection equipment: In Mexico, INL has provided  nonintrusive inspection equipment and training at border ports of entry  and other strategic locations to allow the Mexican government to scan  and inspect passenger vehicles, cargo containers, and freight rail for  firearms, among other things. CBP has also provided training on the  use of this equipment.

Specialized canines: In Mexico, INL, in coordination with CBP, has  provided specialized canines with the ability to detect smuggled  firearms, among other things, and CBP has also provided training in  their use. In Guatemala, an INL official noted that INL has provided  support to a local canine training school that has outfitted government  units with canines capable of detecting firearms and drugs, among  other things.

A number of other U.S. efforts may touch on combatting firearms  trafficking without having this as an explicitly stated goal. For example,  Belizean officials noted that support provided by the U.S. Coast Guard  has helped them interdict firearms trafficked along the Caribbean coast.  Additionally, the United States has provided justice sector support in  Mexico that is intended to improve the judicial system’s ability to  prosecute crimes of all types, including those related to firearms  trafficking. Additionally, U.S. agencies, including CBP and ICE, provide  assistance to each of the countries to strengthen border security. These  efforts do not have a specific goal to counter firearms trafficking but  complement antitrafficking efforts, according to Department of Homeland  Security and State officials.

In total, U.S. agencies obligated about $191 million in fiscal years 2010  through 2014 to support these efforts, most of which went to activities that  were not specifically focused on countering firearms trafficking but  included it as one of many goals (see fig. 2). State’s INL provided the  majority—over 90 percent of total obligations reported by U.S. agencies— of this funding through the International Narcotics Control and Law  Enforcement appropriations account. Additionally, about 93 percent of the  total funding, or about $177 million, went to activities in Mexico. Most of  this—about $149 million—is attributable to two activities in Mexico that  are not specifically focused on countering firearms trafficking: (1) the  provision of nonintrusive inspection equipment and training and (2)  assistance to the Mexican federal and state forensic laboratories. In total,  U.S. agencies obligated about $23 million for activities that specifically  focused on countering firearms trafficking. This includes about $8 million  from INL to support activities in all three countries, nearly $14 million that  ATF provided in support of its activities in Mexico, and about $2 million  that PM/WRA provided for some of the efforts in Guatemala and Belize  through the Nonproliferation, Antiterrorism, Demining, and Related  Programs (NADR) appropriations account. About $7.5 million of the  overall total went to regional activities in Central America that included  other countries in addition to Guatemala and Belize.

section_title: U.S. Agencies Considered Key Factors in Selecting Counter-Firearms Trafficking Activities
paragraphs: Consistent with PPD 23, U.S. agencies considered key factors in  selecting counter-firearms trafficking activities. In PPD 23—a directive  governing U.S. security sector assistance, including firearms trafficking— the administration laid out policy guidelines for planning, implementing,  and monitoring security sector assistance. PPD 23 asserts that U.S.  agencies should consider several key factors in planning security sector  assistance, including partner country needs, absorptive capacity,  sustainability, and other donor and other U.S. efforts.
subsections: section_title: Partner Country Needs
paragraphs: U.S. counter-firearms trafficking capacity-building efforts in Belize,  Guatemala, and Mexico have largely focused on identified partner country  needs. We found that the issues of concern to the governments of Central  American countries, such as Guatemala and Belize, differ in some ways  from those of the government of Mexico, while other concerns exist in all  three countries. Guatemala, for example, like some other Central  American countries, has leftover stockpiles of weapons and ammunition  from past conflicts, resulting in more arms than are needed for military  and law enforcement purposes. Additionally, in both Guatemala and  Belize, some stockpiles are aging—and are, therefore, more volatile—or  are poorly secured. Firearms originating in or imported into Central  America have often lacked markings that allow law enforcement to trace  their origins. In all three countries, the ability to trace firearms has been a  concern. Countries did not have systems for tracking the source of  firearms and either lacked access to or did not regularly use ATF’s  eTrace system. Additionally, capacity gaps in investigating firearms- related crimes and the porous borders between Belize, Guatemala, and  Mexico have been concerns in all three countries.

U.S. agency activities have largely focused on these needs. For example,  agencies undertook stockpile management and firearms marking  activities in both Guatemala and Belize and have initiated efforts to  improve firearms tracing and investigations, as well as border security, in  all three countries. U.S. and foreign government officials noted that they  regularly meet to discuss how U.S. assistance can meet partner country  needs. In Mexico, U.S. and Mexican officials instituted a practice under  the current Mexican administration, through which all proposals for  Merida Initiative assistance are discussed in regular meetings with  representatives of a single office within the Mexican Interior Ministry. This  provides a single contact through which all Merida Initiative assistance is  coordinated and approved. In Guatemala and Belize, U.S. and host  country officials described a process in which they meet to discuss needs  on a regular basis.

section_title: Absorptive Capacity
paragraphs: Our analysis of State and implementing partner documents shows that  State and implementers considered absorptive capacity in selecting and  designing programs. For example, in choosing not to recommend one  proposal for a forensics program in Central America, INL noted that the  proposal focused too heavily on advanced technological approaches,  which may not be appropriately tailored to host country capabilities. In the  interagency agreement between INL and ICITAP for a forensics program  in Mexico, ICITAP said that it met with Mexican officials to discuss needs  and assess the existing capacity of Mexican state labs in designing the  program. Additionally, CBP noted that trainees for its nonintrusive  inspection equipment training program would be selected based on their  proficiency in using nonintrusive inspection equipment and on their work  performance and developed a series of courses to build this expertise  over time.

section_title: Sustainability
paragraphs: Our analysis of documents and interviews with agency officials shows  that agencies considered sustainability for counter-firearms trafficking  activities, with some officials noting that ensuring sustainability can be  challenging. Most of the interagency agreements we reviewed had a  section on sustainability, indicating that U.S. agencies and other  implementers considered how to create a sustainable program. In Mexico  and Guatemala, U.S. officials noted that it can be difficult to sustain  enhanced capacity because of regular turnover among host country  officials. However, in some cases, U.S. agencies incorporated efforts to  address this concern into their programs’ design. For example, in Mexico,  agencies have instituted train-the-trainer programs in which they train  host country officials who then train others within their organizations. The  goal of such programs is to establish a level of expertise among some  officials to help ensure long-term sustainability of U.S. training efforts.

The long-term sustainability of equipment has been a concern in the  firearms marking program in Central America. In particular, an OAS  official stated that the marking equipment provided in Central America  began requiring maintenance shortly into the program, but no funding had  been allocated by State for that purpose. PM/WRA officials noted,  however, that the memorandums of understanding established with  recipient countries noted that maintenance was the countries’  responsibility.

section_title: Other Donor and Other U.S. Efforts
paragraphs: Foreign officials said that the United States is often the only donor  supporting these types of counter-firearms trafficking efforts.  Nonetheless, State officials said that they meet with other donors to  ensure that efforts are not duplicative or conflicting. State also includes an  assessment of other donors’ efforts in some strategic planning documents  to ensure that planned U.S. efforts do not overlap with ongoing or  planned programs by other donors.

U.S. agencies indicated that they have generally considered other U.S.  efforts in their planning. According to U.S. officials, coordination among  U.S. government officials within each of the three countries is generally  good. They noted that U.S. agencies within each country meet regularly  and discuss ongoing activities to ensure that they are sharing information  and coordinating efforts. In one case, a lack of communication between  PM/WRA officials in Washington, D.C., and embassy officials in Belize  resulted in delays to a program’s implementation. In 2012, PM/WRA  provided $300,000 in obligated NADR funds to the U.S. Embassy in  Belize for stockpile management, but less than one-third of it was  expended by the embassy. State officials noted that embassy officials in  Belize were unaware of the remaining obligated but unexpended funds  until relevant officials informed them in spring 2015 that the funding  needed to be spent or deobligated. PM/WRA officials noted that it is  unusual for them to transfer funding directly to an embassy. They said  they typically would provide the funding directly to a contractor or other  implementing partner but provided it to the embassy in this case for the  sake of expedience. Once they were aware of the unexpended NADR  funds, embassy officials identified unmet needs for which these funds  could be used and submitted a proposal to PM/WRA to provide additional  security equipment to the Belizean government.

section_title: U.S. Agencies and Implementers Achieved Many of Their Goals for Counter-Firearms Trafficking Activities We Reviewed, but Efforts to Track and Report on Progress Are Inconsistent
subsections: section_title: Agencies Established Performance Measures and Targets for Most but Not All Key Counter- Firearms Trafficking Activities We Reviewed
paragraphs: U.S. agencies and other implementers established performance  measures and targets for five of eight key activities we reviewed that  assist in building capacity to combat firearms trafficking in Belize,  Guatemala, and Mexico. According to Standards for Internal Control in  the Federal Government, managers should compare actual performance  against planned or expected results and analyze significant differences.  In PPD 23 the administration also highlights the importance of monitoring  and evaluating security sector assistance efforts to make resource  allocation decisions. As we have previously reported, performance  measurement allows organizations to track progress in achieving their  goals and gives managers crucial information to identify gaps in program  performance and plan any needed improvements. Table 1 outlines eight  key counter-firearms trafficking activities in Belize, Guatemala, and  Mexico—within the broader areas of effort presented in figure 1—and  notes whether performance targets were established for each activity.

Agencies and other implementers that established performance metrics  and targets for these key activities did so as part of a broader  performance management framework. They articulated an overall  objective or goal for the activity and, to track progress toward these  objectives and goals, developed performance metrics and targets that  monitored specific actions that supported the objectives and goals.

All of the performance measures and targets agencies and other  implementers established for the key activities we reviewed were  assessable. State guidance on establishing performance metrics outlines  a variety of options for measuring success in various activities, such as  training courses and advising or mentoring. The types of performance  measures used for these activities varied in their degree of specificity. For  example, one of the performance measures for CBP’s activity to train  Mexican agency officials on the use of nonintrusive inspection equipment  is that trainees will demonstrate proficiency through an evaluation of  practical exercises. The firearms destruction activity in Guatemala,  managed by the OAS, identified specific numbers for the amounts of  expired or unstable ammunition and weapons the program intended to  destroy.

Some agencies established performance measures for some of the key  activities we reviewed but did not establish targets for them. As a result,  we were unable to assess whether these activities met their goals. For  example, although ATF tracks data on firearms-related training and  outcomes associated with eTrace in Belize, Guatemala, and Mexico, the  agency has not established performance targets for these activities,  making it difficult for ATF managers and other decision makers to  determine whether its counter-firearms trafficking efforts are successful.  ATF officials noted that measuring the overall success of capacity- building activities is difficult because the efforts rely on actions taken by  other governments. Additionally, they noted that the activities they  undertake may differ from year to year, depending on partner country  needs. State also did not initially establish measures and targets for its  physical security and stockpile management program in Belize, but has  since done so for the use of the program’s remaining funding. Additional  information about these activities follows.

Firearms training (ATF): For firearms-related training, ATF tracks the  number of training courses it manages in a fiscal year and the number  of students who participate. ATF produces weekly activity reports for  its efforts in Central America that recount law enforcement activities,  referrals, and training or proposed training, among other things. ATF  also collects student course evaluations and feedback provided by the  students to the instructors. However, ATF has not established targets  for these activities, such as the number or type of courses it plans to  hold in a year. Doing so could help ATF leverage the existing  feedback it collects, such as requests for longer courses or that ATF  offer a second, more in-depth course on a given topic. Targets could  also help to ensure that ATF is providing enough of the specific types  of courses that it and partner countries determine to be most  important for countering firearms trafficking activities. eTrace support and training (ATF): ATF tracks the number of  seized weapons traced through eTrace in each country, as well as the  number of eTrace training courses conducted. ATF also tracks  referrals that result from traces performed with eTrace. According to  ATF officials, referrals are firearms traces that lead to investigations in  the United States. In the past, ATF and State established targets for  expanding the use of Spanish-language eTrace in Mexico in country- wide strategic planning documents. However, ATF officials noted that  these targets were specific to the years following the rollout of  Spanish eTrace and are no longer used. ATF currently does not have  any targets related to the use of eTrace in Mexico or Central America.  State officials noted that without information against which it can  measure progress, it can be difficult to determine whether the  investment in promoting the use of eTrace in Central America is  worthwhile. ATF officials stated that it can be difficult to set targets for  eTrace referrals because it relies on host country officials inputting  these data. However, this does not preclude it from establishing other  targets related to eTrace, such as targets for expanding or  consistently using eTrace. Tracking data against performance targets  could potentially help ATF and State better understand the value of  these efforts.

Physical security and stockpile management (State): In 2012, in  response to a weapons pilferage incident, the Department of  Defense’s Defense Threat Reduction Agency reviewed the condition  of Belize’s munitions storage facilities and made a number of  equipment recommendations to bolster security. PM/WRA provided  $300,000 in obligated NADR funds to the U.S. Embassy in Belize to  implement these recommendations. As of September 2015, less than  one-third of the $300,000 award had been expended and not all  recommended equipment had been purchased. PM/WRA officials  stated that they typically require implementers to develop  performance measures and targets but could not provide evidence of  whether targets were developed in this case. Officials stated that  some of the funds were obligated but not expended because staff at  the embassy were unclear about the remaining availability of funds  following the initial procurement in 2012. The embassy developed a  plan for expending the remainder of the funds in summer 2015 to  avoid deobligation of the funds. The plan includes a clear target of  procuring and installing a new storage container at one Belizean  military site.

section_title: Two Ongoing Activities Are Meeting Their Goals, and Three Completed Activities Met or Partially Met Their Goals, According to Agency and Implementer Reports
paragraphs: As of the second quarter of fiscal year 2015, agency reports show that  implementing agencies and organizations of the five activities that  established performance targets had met or partially met their targets for  all measures. Two of these activities are ongoing and three have been  completed. Through interagency agreements or grant agreements,  State requires the implementers it funds to submit quarterly reports on the  progress of their activities. Our review of these assessments, as well as  assessments completed by State, indicates that the two ongoing activities  were meeting established goals for the firearms-related component of  their training as of the second quarter of fiscal year 2015, as shown in  table 2.

These activities are part of the U.S. government’s efforts to increase the  capacity of federal and state-level Mexican forensics laboratories, as  described below.

Forensic assistance to the Attorney General (ICITAP): ICITAP’s  2014 Interagency Agreement with INL outlines performance measures  for its assistance to the Forensic Laboratory of Mexico’s Procuraduría  General de la República, or Office of Attorney General (PGR). Each of  the components that make up the project has a number of  performance measures; however, we evaluated the firearms and tool  marks component because of its direct relationship with firearms  trafficking. As of the second quarter of fiscal year 2015, State  assessed that this component was on target. The overall objective  of the project is to achieve international accreditation for the PGR  forensic laboratory in five core disciplines, including ballistics. One of  the main goals for the firearms and tool marks component is  compliance with international standards for testing laboratories. As of  December 2015, according to ICITAP officials, ICITAP was preparing  for an accreditation audit and projected that this component would be  in compliance with international standards early in 2016. Initiated in  2010, the project made significant progress until the end of 2012,  according to ICITAP. The project was slowed from December 2012  until May 2014, following the change in the Mexican presidential  administration.

Forensic assistance to Mexican states (ICITAP): ICITAP initiated  this project providing assistance to Mexican states’ forensics  laboratories in June 2013. ICITAP’s 2014 Interagency Agreement with  INL outlines performance measures for this assistance. Each of the  components that make up the project has a number of performance  measures; however, we evaluated the firearms and tool marks  component because of its direct relationship with firearms trafficking.  State’s fiscal year 2015 second quarter and ICITAP’s fiscal year 2015  third quarter progress reports do not explicitly provide an assessment  of the firearms and tool marks component. However, State officials  noted that in their judgment, this project is meeting its goals for the  firearms and tool marks component. The overall objective of the  project is to enhance the capabilities of the forensic laboratory system  at the state level to adhere to international standards for testing  laboratories and use forensic-specific standards, where appropriate,  as the basis for development, resulting in up to 10 fully accredited  forensic laboratories—1 or 2 in each political region of the country.  The planned life of this project is 4 years, following which ICITAP  intends for all 32 state labs to have initiated the process to move  toward accreditation.

According to State’s and implementers’ progress reports, one of three  completed activities for which performance measures and targets had  been established fully met its goals. As shown in table 3, the OAS- managed firearms marking effort fully met its goals, and implementers  partially met established goals for the other two activities.

The progress made by agencies and implementers in achieving their  established goals for these activities is described below.

Nonintrusive inspection equipment training (CBP): CBP’s goals  for this activity were partially met. As of September 2014, State  assessed that this program was performing slightly below target.  Although the project was meeting most of its benchmarks and  timeline, it was unclear whether one of the project’s four performance  targets would be met—incorporating successfully trained personnel  into Mexico’s cadre of instructors. CBP’s 2013 Interagency Agreement  with INL outlines performance measures for technical assistance and  training on nonintrusive inspection equipment designed to interdict  contraband, including firearms. One initial target was to train a cadre  of 24 Mexican instructors; by the end of fiscal year 2014, CBP  certified 13 instructors who planned to train 400 Mexican officials in  the 2015 calendar year. State noted that the 13 instructors were well  qualified with extensive experience in border management. However,  as of the end of fiscal year 2014, it was unclear whether Mexican  agencies would incorporate the successfully trained participants into  their cadre of instructors. This project was initiated in April 2013 and  ended in December 2014.

Firearms marking (OAS): This OAS-managed regional project to  promote firearms marking in Latin America and the Caribbean  achieved all of its goals. The program was initiated in 2009 and  completed in 2014 and included the participation of Guatemala and  Belize. The goals of the project included creating a regional study of  firearms marking laws and practices, distributing at least one firearm  marking machine to every participating country, organizing a regional  workshop on firearms marking, and organizing a roundtable on  firearms marking. Guatemala was provided five marking machines— more than any other country in Central America—and Belize was  provided one machine. According to State officials, Guatemala was  provided more machines because of the high number of weapons in  that country. In June 2014, the OAS reported that it had met all of the  project’s goals.

Stockpile Destruction (OAS): An OAS-implemented stockpile  destruction program in Guatemala achieved one of its two goals.  Initiated in September 2010, the project’s goals were to destroy 250  tons of expired or unstable ammunition and 12,000 small arms/light  weapons belonging to the Ministry of Defense. By December 2011,  about 269 tons of ammunition had been destroyed, exceeding the  goal. In February 2012, the Guatemalan government announced its  plans to create two new military brigades to counter illegal drug  cartels, shifting the plans of the Ministry of Defense in relation to  stockpile destruction and rendering the second objective unattainable.  In total, 2,091 weapons were destroyed—representing 17 percent of  the goal of destroying 12,000 weapons.

section_title: Assessments of the Key Activities We Reviewed Did Not Consistently Identify Challenges to Meeting Program Goals or Strategies for Overcoming Them
paragraphs: State has a process for identifying and addressing challenges to  achieving program goals, but these efforts were not consistently  documented in implementing agency assessments of the key activities we  reviewed, as required. State’s agreements with implementing agencies  and organizations require that quarterly reports include a summary of any  critical issues or challenges and a plan of action in response to them.  According to State officials, an implementer may also communicate  significant challenges to the State official overseeing its activity via  conversations, meetings, and correspondence. For example, in Central  America, agencies meet weekly to discuss program activities, which may  include a discussion of any challenges. As a result, State officials noted  that implementers may not include challenges in quarterly reports if they  have been discussed in another venue. However, challenges and  potential solutions should also be articulated in quarterly reports,  according to State officials.

We found that implementers’ progress reports on the key counter- firearms trafficking activities we reviewed were inconsistent in identifying  key challenges or presenting strategies to address these challenges. For  example, a quarterly report for the OAS-managed firearms destruction  effort in Guatemala discussed a shift in host government priorities that  resulted in the delay of the destruction of firearms belonging to one  government agency. In response, implementing officials modified their  focus to instead destroy weapons managed by another branch of the  Guatemalan government. Although the goal was not fully satisfied, this  quarterly report comprehensively documented the challenge, the strategy  for resolving the challenge, and the final outcome.

In other cases, quarterly reports we reviewed did not identify challenges  or plans for addressing them. For example, ICITAP’s fiscal year 2015  third quarter report for its assistance to the PGR laboratories did not  discuss any challenges in delivering the assistance. Although State  assessed the firearms and tool marks component of this program as  meeting its targets, it also noted that other components of the program  were below target. However, the quarterly report did not discuss any  challenges or reasons why these components were not on target.  Additionally, a State assessment of the nonintrusive inspection equipment  training effort indicated that the biggest challenge to the program’s  success was securing support from host government agencies to  continue to allow the program’s trainees to train host country officials as a  group and to assess whether Mexican agencies would incorporate the  training into their internal curricula. CBP’s fiscal year 2014 fourth quarter  report mentioned a challenge associated with interagency  communication; however, it did not identify concerns about the host  country integrating the training into its curricula as a challenge.

According to State officials, agency quarterly reports are important for  understanding the progress of an activity toward meeting its goals. They  noted that including a discussion of challenges in quarterly reports helps  to ensure that all relevant stakeholders are aware of potential issues.  State officials noted that balancing resources across competing priorities  can be difficult and also said they use implementers’ quarterly progress  reports to inform resource allocation decisions. For example, if an activity  is not meeting its goals, State may look to end the program and allocate  resources to a different priority. Alternatively, if an activity is particularly  successful, State may look for opportunities to expand it. Without  information about challenges and plans for their resolution, State is  missing an opportunity to gain valuable knowledge that could help  facilitate future decision making about efforts to counter firearms  trafficking.

section_title: Conclusions
paragraphs: Building capacity to counter firearms trafficking is a priority for the U.S.  government and the governments of Belize, Guatemala, and Mexico. The  United States has worked well with partner countries to implement a  variety of capacity-building activities focused on partner country needs.  U.S. agencies have established performance metrics and targets for most  of the eight key counter-firearms trafficking efforts in Belize, Guatemala,  and Mexico that we reviewed, but ATF has not set targets by which it can  measure progress for its activities to provide firearms training and support  the use of eTrace. Without such targets, ATF management and other  decision makers may have difficulty evaluating the success of these  efforts and ensuring that they are focusing on the most pressing needs.  According to State’s and implementers’ reports, other U.S. agencies  funded by State have made progress toward key activities to counter  firearms trafficking, but they have not consistently reported on key  challenges to meeting their goals or on the strategies they intended to  use to address these challenges. Consistently identifying challenges and  mitigation strategies in quarterly progress reports ensures that all relevant  parties are aware of program risks and are able to make decisions with  full information. Without this information, implementers may not fully meet  their goals. Additionally, without this information, State, as the primary  funder of these activities, is limited in its ability to ensure that it is able to  maximize the use of U.S. resources.

section_title: Recommendations for Executive Action
paragraphs: We recommend the following two actions to enhance U.S. agencies’  performance monitoring of counter-firearms trafficking activities:

The Director of the Bureau of Alcohol, Tobacco, Firearms and  Explosives should establish and document performance targets for  the bureau’s key counter-firearms trafficking activities in Belize,  Guatemala, and Mexico, as appropriate.

The Secretary of State should work with other U.S. agencies and  implementers to help ensure that quarterly progress reports identify  key challenges and plans to address them.

section_title: Agency Comments
paragraphs: We provided a draft of this report to the Departments of State, Justice,  and Homeland Security and OAS for comment. In its written comments,  reproduced in appendix II, State generally concurred with our  recommendation and stated that it will work with other agencies to  implement it. The Department of Justice’s ATF provided its comments via  email and stated that it concurred with our recommendation and plans to  implement it. The Departments of Homeland Security and Justice also  provided technical comments that we incorporated, as appropriate. OAS  did not provide comments.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  appropriate congressional committees, the Secretary of State, the  Secretary of Homeland Security, the Attorney General of the United  States, the Director of the Bureau of Alcohol, Tobacco, Firearms and  Explosives, and the OAS Secretary General. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-6991 or farbj@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix III.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: In this report, we examined (1) the activities undertaken by U.S. agencies  to build partner capacity to combat firearms trafficking in Belize,  Guatemala, and Mexico and the extent to which they considered key  factors in selecting the activities and (2) the progress the United States  has made in building partner capacity in Belize, Guatemala, and Mexico  to combat firearms trafficking.

To determine what activities U.S. agencies have undertaken and the  extent to which U.S. agencies considered key factors in determining what  activities to undertake to build partner capacity to combat firearms  trafficking in Belize, Guatemala, and Mexico, we first identified U.S.  activities that either directly or indirectly addressed firearms trafficking.  We interviewed officials from the Departments of State (State), Justice,  and Homeland Security—and their component agencies, as  appropriate—and collected documentation on U.S. activities. We  compiled a list of relevant activities based on these interviews, interviews  with host country officials, and our review of documentation. We included  an activity in the scope of our review if it specifically included firearms  among the issues it was intended to address. Because other activities  may also indirectly touch on firearms trafficking, the list may not be  comprehensive.

To understand broader strategies underlying these activities, we reviewed  strategic planning documents specific to Belize, Guatemala, and Mexico,  including State’s Integrated Country Strategies, as well as several  interagency strategic and planning documents regarding U.S.  engagement with Central America, including the U.S. Strategy for  Engagement in Central America, the U.S. Strategy to Combat  Transnational Organized Crime, and the National Southwest Border  Counternarcotics Strategy. We collected funding data from State and the  Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and  Explosives (ATF) for these activities for fiscal years 2010 through 2014  and, based on interviews with knowledgeable agency officials and a  review of State’s relevant internal controls, determined that these data  were sufficiently reliable for our purposes.

We identified key factors for agencies to consider in Presidential Policy  Directive 23, a presidential directive covering security sector assistance,  including firearms trafficking. To determine whether agencies considered  these factors, we reviewed agency documentation and interviewed U.S.  and foreign officials. We interviewed U.S. officials and officials from the  Organization of American States in Washington, D.C., and U.S. and  Mexican officials in Mexico. Additionally, we conducted interviews with  U.S. and host country officials in Guatemala and Belize and with the ATF  Regional Attaché in San Salvador, who supports counter-firearms  trafficking efforts in both Guatemala and Belize.

To determine what progress the United States has made in building  partner capacity in Belize, Guatemala, and Mexico to combat firearms  trafficking, we identified eight key activities from the activities presented in  the first objective. Our review of these eight key activities is not  generalizable to all activities conducted by U.S. agencies and their  implementing partners. We defined an activity as a key activity if (1) the  activity had a specific component or objective to address firearms  trafficking, (2) a substantial portion of funding was directed to the activity,  or (3) U.S. or foreign officials identified the activity as a key effort to  building partner capacity to combat firearms trafficking.

For each key activity, we reviewed program documentation—including  grant agreements, interagency agreements (where applicable), and  progress reports—and interviewed agency officials to determine whether  the funding and implementing agencies had developed performance  measures and targets for the activity. If an agency had developed  performance measures and targets, we reviewed State’s and  implementers’ progress reports to determine whether the agency had met  its goals for the program. We reviewed ongoing efforts and completed  efforts separately since ongoing efforts would not be expected to have  met all of their goals prior to the program’s completion. For both ongoing  and completed efforts, we based our assessment of whether the activity  was on track for meeting its goals on agency and State progress reports.  We did not independently verify the data included in these reports. We  reviewed State’s interagency agreements and grant agreements with  implementing partners to determine what reporting requirements existed  for State-funded programs. We reviewed agency and other implementers’  quarterly reports to determine whether the reporting requirements were  met.

We conducted this performance audit from February 2015 to January  2016 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.

section_title: Appendix II: Comments from the U.S. Department of State

section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Juan Gobel (Assistant Director),  Kara Marshall, Qahira El’Amin, Julia Jebo Grant, Lynn Cothern, Charles  Michael Johnson, Jr., Ashley Alley, Oziel Trevino, and Justin Fisher made  key contributions to this report.


Question-summary annotations: questions: question: What activities have US agencies and their partners undertaken regarding counter-firearms efforts?
answer: U.S. agencies and their implementing partners have undertaken a number of capacity-building activities that support counter-firearms trafficking efforts in Belize, Guatemala, and Mexico.
child_questions: question: What do these activities uspport?
answer: Selected, in part, based on partner country needs, these activities include efforts to provide support in using the Bureau of Alcohol, Tobacco, Firearms and Explosives' (ATF) web-based firearms tracing system (eTrace) and providing forensics training, including on ballistics.

question: What are the points of focus of these activities?
answer: Some of these activities, such as firearms identification training, relate directly to firearms trafficking, while others broadly support antitrafficking or border security efforts for which stemming the trafficking of firearms is one of many goals.

question: What does Presidential Policy Directive 23 emphasize?
answer: Presidential Policy Directive 23 highlights key factors, including partner country needs, absorptive capacity, sustainability, and other U.S. and other donor efforts, as important in planning security sector assistance.

questions: question: What is the current state of the U.S.'s counter-firearms trafficking activities?
answer: U.S. agencies and implementing partners have achieved many of their goals for eight key counter-firearms trafficking activities GAO reviewed, but could enhance their efforts to measure and report on progress. Agencies and implementers established performance measures and targets for five of these eight activities.
child_questions: question: What is the status of the specific activities?
answer: Two of the five activities GAO reviewed that established metrics and targets are ongoing and are meeting their goals, while three other activities were completed and met or partially met their goals, according to Department of State (State) and implementer reports.

question: What do Standards for Internal Control in the Federal Government state?
answer: Standards for Internal Control in the Federal Government states that managers should compare actual performance against expected results, highlighting the importance of such measures and targets.
child_questions: question: To what extent does ATF track its success?
answer: ATF tracks its activities but has not established performance targets for them, without which it is difficult to measure the success of its efforts.

question: What does State require of implementers?
answer: For activities it funds, State requires implementers to include a discussion of key challenges and strategies to address those challenges in quarterly reports.
child_questions: question: To what extent did the implementers that GAO reviewed do this?
answer: However, implementers' reports for activities GAO reviewed were inconsistent and did not always identify challenges or strategies for addressing them.
child_questions: question: What is the possible effect of this gap?
answer: Without this information, agencies risk not fully meeting their goals and may be unable to maximize the use of U.S. resources.

questions: question: What is the current scale of illegal trafficking along Mexico's southern border?
answer: Trafficking of illicit materials, including firearms, is widespread across Mexico's more than 700-mile southern border with Guatemala and Belize. Such trafficking presents a challenge for law enforcement in all three countries and for U.S. security interests.
child_questions: question: What actions have State and ATF taken to deal with this problem?
answer: State and other U.S. agencies, such as ATF, have provided support to build the capacity of their counterparts in these three countries to address problems related to firearms trafficking.

question: What was GAO asked to do?
answer: GAO was asked to review U.S. support to the governments of Belize, Guatemala, and Mexico to stem firearms trafficking across their shared border.
child_questions: question: What does the GAO report examine?
answer: This report examines, for these three countries, (1) the activities undertaken by U.S. agencies to build partner capacity to combat firearms trafficking and the extent to which they considered key factors in selecting the activities and (2) progress the United States has made in building such capacity.
child_questions: question: What data did GAO collect?
answer: GAO analyzed program documentation and conducted interviews with U.S., Belizean, Guatemalan, and Mexican officials. To examine progress, GAO selected a nongeneralizable sample of eight key activities based on a number of factors, including whether the activity addressed firearms trafficking.