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Report to the Honorable Tom Harkin, U.S. Senate:

United States General Accounting Office:

GAO:

July 2003:

Foreign Military Sales:

Improved Air Force Controls Could Prevent Unauthorized Shipments of 
Classified and Controlled Spare Parts to Foreign Countries:

GAO-03-664:

GAO Highlights:

Highlights of GAO-03-664, a report to the Honorable Tom Harkin, U.S. 
Senate 

Why GAO Did This Study:

From 1990 through 2001, the Department of Defense delivered over $138 
billion in services and defense articles—including classified and 
controlled parts—to foreign governments through its foreign military 
sales programs. Classified spare parts are restricted for national 
security reasons, while controlled parts contain technology that the 
military does not want to release. GAO was asked to review the Air 
Force’s internal controls aimed at preventing countries from 
requisitioning and receiving classified or controlled spare parts that 
they are ineligible to receive. 

What GAO Found:

The Air Force’s internal controls for its foreign military sales 
program using blanket orders are not adequate, placing classified and 
controlled spare parts at risk of being shipped to countries not 
authorized to receive them. 

* The Air Force’s system has erroneously approved foreign country 
requisitions for classified and controlled spare parts based on 
incorrect federal supply classes. The system approves items for 
shipment based in part on an item’s federal supply class—not the 
item’s entire national stock number, which is a combination of the 
supply class number and a part number unique to the item. GAO found 
that because that system was not properly programmed, it erroneously 
approved 35 of 123 selected requisitions reviewed, because countries 
used unrestricted supply class numbers. For example, one country 
ordered a controlled outline sequencer used on various aircraft by 
using a supply class that was unrestricted, but incorrect for the part 
it requisitioned. Because supply class 1680 was not restricted and the 
system did not verify that 1680 was the correct supply class for 
national item identification number 010539320, the system approved the 
requisition. Had the system validated the entire 13-digit national 
stock number, it would have found that the number was incorrect and 
would not have approved the requisition. In addition, the Air Force 
has no written policies or procedures in place for recovering items 
that have been shipped in error.

* The Air Force has not validated modifications to the Security 
Assistance Management Information System that restrict parts available 
to foreign countries and has not tested the system since 1998 to 
ensure that it is working properly. Because modifications were not 
validated, the Air Force did not detect improperly made modifications 
to the system, and foreign countries were able to requisition and 
obtain controlled spare parts that, at the time, the Air Force was 
trying to restrict. GAO identified 18 instances in which countries 
requisitioned and received a controlled part for which they were not 
eligible because programmers had entered the restrictions in the wrong 
area of the system. Although Air Force officials subsequently told us 
that the part was improperly restricted, this example nevertheless 
demonstrates the need to validate system changes.

* Air Force command country managers did not always document reasons 
for overriding the recommendations of the system or the foreign 
military sales case manager. For 19 of the 123 requisitions GAO 
reviewed, command country managers overrode the system recommendations 
and shipped classified and controlled spare parts without documenting 
the reasons for overriding the system. For example, a command country 
manager overrode the system and shipped four classified target-
detecting devices without documenting the reasons for overriding the 
system.

What GAO Recommends:

To improve internal controls, GAO recommends modifying the Security 
Assistance Management Information System so that it validates country 
requisitions based on the requisitioned item’s national stock number, 
establishing policies for recovering classified or controlled parts 
that are shipped erroneously, establishing policies for validating 
modifications made to the system, periodically testing the system’s 
logic, and establishing a policy to document decisions to override the 
system.

The department fully concurred with four recommendations and partially 
with our recommendation to periodically test the system’s logic, 
citing a program being implemented that will test system 
modifications. However, we do not believe this program will address 
system logic flaws.

www.gao.gov/cgi-bin/getrpt?GAO-03-664.

To view the full report, including the scope and methodology, click on 
the link above. For more information, contact William M. Solis, (202) 
512-8365, solisw@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Internal Controls over Foreign Military Sales Are Not Adequate:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Scope and Methodology:

Appendix I: Comments from the Department of Defense:

Figures:

Figure 1: The Foreign Military Sales Process for Air Force Classified 
and Controlled Spare Parts:

Figure 2: Example of a National Stock Number Showing Federal Supply 
Class and National Item Identification Number:

Figure 3: Example of How a Restricted Item Was Requisitioned and 
Shipped:

United States General Accounting Office:

Washington, DC 20548:

July 29, 2003:

The Honorable Tom Harkin 
United States Senate:

Dear Senator Harkin:

From 1990 through 2001, the Department of Defense (DOD) delivered over 
$138 billion in services and defense articles--including classified and 
controlled spare parts[Footnote 1]--to foreign governments through the 
foreign military sales programs administered by the military services. 
The management of classified and controlled spare parts is critical 
given their potential to be used against U.S. interests if the parts 
should fall into the hands of countries or terrorist organizations that 
are ineligible to receive them.

You asked us to review the adequacy of key internal control activities 
aimed at preventing countries from requisitioning and receiving 
classified spare parts that they are ineligible to receive. Internal 
control activities include the policies, procedures, and processes that 
are essential for the proper stewardship of and accountability for 
government resources and for achieving effective and efficient program 
results. In our review, the key internal control activities we reviewed 
were in the areas of:

* restricting access to classified and controlled spare parts to 
countries that are eligible to receive them,

* validating restrictions loaded into the Air Force's Security 
Assistance Management Information System[Footnote 2] and testing the 
system's logic, and:

* maintaining proper documentation for overriding system restrictions.

We focused our efforts on the Air Force because it sold 53 million 
items, valued at over $1.7 billion, to foreign countries during fiscal 
years 2001 and 2002. The 53 million items included 1.4 million spare 
parts, valued at $299 million, that were classified or controlled spare 
parts. We plan to address Army and Navy policies, processes, and 
procedures relating to these sales in separate reviews.

To accomplish our review, we concentrated our efforts on classified and 
controlled spare parts that foreign countries requisitioned from the 
Air Force under blanket order cases,[Footnote 3] which define a 
country's eligibility to requisition spare parts. We obtained records 
from the Air Force Security Assistance Center on all classified and 
controlled spare parts that were purchased under blanket orders and, 
according to Air Force records, were shipped to foreign countries for 
the period October 1, 1997, through July 31, 2002. A preliminary test 
of 72,057 requisitions, valued at $679.5 million, identified 525 
requisitions, valued at $9.7 million, that appeared to violate Security 
Assistance Management Information System restrictions. We obtained 
satisfactory explanations from Air Force Security Assistance Center 
officials for all except 200 of the requisitions, valued at $ 5.6 
million. We reviewed 123 of these requisitions,[Footnote 4] valued at 
over $4.4 million, to determine the reasons classified and controlled 
items were released for shipment. Further details are in the Scope and 
Methodology section of this report.

Results in Brief:

The Air Force's internal controls for its foreign military sales 
program using blanket orders are not adequate, placing classified and 
controlled spare parts at risk of being shipped to countries not 
authorized to receive them. The internal control inadequacies we 
identified are as follows:

* Foreign country requisitions for classified and controlled spare 
parts were erroneously approved by the Air Force's Security Assistance 
Management Information System based on an incorrect federal supply 
class.[Footnote 5] The Security Assistance Management Information 
System approves items for shipment based in part on an item's federal 
supply class--not the item's entire national stock number. Thus, a 
country can obtain restricted spare parts by using an incorrect, but 
unrestricted, supply class with an item's correct national item 
identification number. We found that because the Security Assistance 
Management Information System was not properly programmed, it 
erroneously validated 35 of the 123 selected requisitions we reviewed 
because although countries used incorrect supply classes for the 
requisitioned items, they used unrestricted supply class numbers. For 
example, one country ordered a controlled outline sequencer used on 
various aircraft by using a supply class that was incorrect, but 
unrestricted, for the part it requisitioned. After the system validated 
the erroneous federal supply class, the item manager[Footnote 6] 
changed the supply class so that it was consistent with the 
requisitioned part, and the restricted part was shipped. Although Air 
Force Security Assistance Center officials were able to describe the 
actions they would take to recover a classified or controlled item that 
was erroneously shipped, neither the Air Force nor the center had 
written policies or procedures in place for recovering the items that 
had been shipped in error.

* The Air Force has not validated modifications to the Security 
Assistance Management Information System that restrict the parts that 
countries can requisition and has not tested the system since 1998 to 
ensure that it is working properly. GAO, Office of Management and 
Budget, and DOD internal control standards require that systems such as 
the Air Force's be periodically validated and tested to ensure that 
they are working as intended. Because modifications were not validated, 
the Air Force did not detect improperly made modifications to the 
system, and foreign countries were able to requisition and obtain 
controlled spare parts that, at the time, the Air Force was trying to 
restrict. For example, Air Force programmers were instructed to enter 
restrictions into the information system that would prevent countries 
from using blanket orders to requisition controlled bushings.[Footnote 
7] Of the 123 cases we reviewed, we found 18 instances in which 
countries requisitioned and received controlled bushings because 
managers had entered the restrictions in the wrong area of the system. 
Although Air Force officials subsequently told us that the bushings had 
been improperly restricted, this example demonstrates the need to 
verify that system modifications are made correctly. Because the 
system's logic has not been tested since 1998, the Air Force cannot be 
assured that the system accurately reviews current requisitions for 
compliance with restrictions.

* Command country managers did not always document reasons for 
overriding Security Assistance Management Information System or foreign 
military sales case manager[Footnote 8] recommendations in case files. 
For 19 of the 123 requisitions we reviewed, command country managers 
overrode the system recommendations and shipped classified and 
controlled spare parts without documenting the reasons for overriding 
the system. For example, a command country manager overrode the system 
and shipped four classified target-detecting devices without 
documenting the reasons for overriding the system. In another example, 
a command country manager authorized the shipment of a controlled 
communications security part that the system and the foreign military 
sales case manager had indicated should not be shipped. The case file 
contained no documentation explaining why the spare part was 
nevertheless shipped.

We are recommending that the Secretary of Defense instruct the 
Secretary of the Air Force to require responsible officials to (1) 
modify the Security Assistance Management Information System so that it 
validates country requisitions based on the requisitioned item's entire 
national stock number, (2) establish policies and procedures for 
recovering classified or controlled items that are erroneously shipped, 
(3) verify restriction changes made to the system to ensure that the 
changes were properly made, (4) periodically test the system's logic 
for restricting requisitions to ensure that it is working correctly, 
and (5) establish a policy for command country managers to document the 
basis for their decisions to override the system or recommendations 
made by foreign military sales case managers.

In commenting on a draft of this report, DOD fully concurred with four 
of our recommendations and cited corrective actions that had been taken 
or were planned. However, with regard to our recommendation to 
periodically test the system to ensure that its logic for restricting 
requisitions is working correctly, the department partially concurred, 
stating that a program is being implemented to test new and old 
modifications placed in the system to ensure that they are accurate. We 
believe that just testing the accuracy of the modification will not 
ensure that the system's logic for restricting requisitions is 
operating correctly. We therefore continue to believe that the system's 
logic for restricting requisitions should be periodically tested to 
ensure that it is working correctly. Otherwise, classified and 
controlled spare parts that are requisitioned may continue to be 
erroneously released.

Background:

The transfer of defense items to friendly nations and allies is an 
integral component in both U.S. national security and foreign policy. 
The U.S. government authorizes the sale or transfer of military 
equipment, including spare parts, to foreign nations either through 
government-to-government agreements or through direct sales from U.S. 
manufacturers. The Arms Export Control Act[Footnote 9] and Foreign 
Assistance Act of 1961,[Footnote 10] as amended, authorize the DOD 
foreign military sales program.

The Department of State sets the overall policy concerning which 
countries are eligible to participate in the foreign military sales 
program. DOD, through the military services, enters into foreign 
military sales agreements with individual countries. The Air Force 
Security Assistance Center, which is an activity of the Air Force 
Materiel Command, is responsible for the administration of the Air 
Force's foreign military sales program.

The center's responsibilities start with the initial negotiation of the 
foreign military sale and end with the delivery of parts and completion 
of all financial aspects of the agreements. The center uses an 
automated management information system, the Security Assistance 
Management Information System, to support its management of the program 
with accurate and timely information. For blanket order cases, the 
system uses criteria such as an item's national item identification 
number, a federal supply class, or a federal supply group[Footnote 11] 
to restrict the parts available to foreign military sales customers. 
Once the system has verified a country's eligibility and approved a 
requisition, the requisition is sent to a supply center to be filled 
and shipped. The overall foreign military sales process, as it applies 
to the Air Force, is shown in figure 1.

Figure 1: The Foreign Military Sales Process for Air Force Classified 
and Controlled Spare Parts:

[See PDF for image]

[End of figure]

This report addresses the portion of the process relating to the Air 
Force's approval or disapproval of foreign countries' requisitions for 
classified and controlled spare parts under blanket order 
cases.[Footnote 12] Blanket orders are for a specific dollar value and 
generally cover classes of parts that a country may need rather than a 
specific item within a class. Under blanket orders, the Air Force 
restricts classes of items, such as munitions and nuclear spare parts, 
from being requisitioned.

Internal Controls over Foreign Military Sales Are Not Adequate:

The Air Force's internal controls for foreign military sales using 
blanket orders are not adequate to prevent countries from ordering and 
receiving classified and controlled spare parts that they are not 
eligible to receive. We found that (1) controls based on supply class 
restrictions were ineffective and resulted in erroneously approved 
requisitions for shipment, and that written policies for recovering the 
erroneously shipped items did not exist; (2) the Air Force did not 
validate modifications to its Security Assistance Management 
Information System related to blanket orders or test the system's logic 
for restricting requisitions, and (3) command country managers did not 
always document reasons for overriding either the Security Assistance 
Management Information System or foreign military sales case manager 
recommendations not to ship classified spare parts. As a result of 
these inadequate internal controls, classified and controlled spare 
parts were shipped to countries not authorized to receive them. The Air 
Force Security Assistance Center has taken or plans to take actions to 
correct these issues.

Use of the Federal Supply Class Resulted in Erroneously Approved 
Requisitions:

Foreign country requisitions for classified and controlled spare parts 
were erroneously validated, as a result of an incorrect federal supply 
class, by the Air Force's Security Assistance Management Information 
System. The Air Force attempts to prevent countries from obtaining 
classified and controlled spare parts by restricting them from 
receiving spare parts that belong to selected federal supply classes. 
Included in the national stock number is a four-digit federal supply 
class (see fig. 2), which may be shared by thousands of items. The 
national stock number also contains a nine-digit national item 
identification number that is unique for each item in the supply 
system. A country can obtain a classified or controlled spare part by 
using an incorrect, but unrestricted, supply class with an item's 
correct national item identification number.

Figure 2: Example of a National Stock Number Showing Federal Supply 
Class and National Item Identification Number:

[See PDF for image]

[End of figure]

We found that because the Security Assistance Management Information 
System was not properly programmed, it erroneously validated 35 blanket 
order requisitions (of the 123 in our review), even though an incorrect 
supply class number was used, because the countries used supply classes 
that were not restricted. For example, in one case, the Air Force 
restricted countries from requisitioning parts belonging to the 1377 
federal supply class (cartridge-and propellant-actuated devices and 
components) on blanket orders. The restriction included an outline 
sequencer (national stock number -1377010539320) used on ejection seats 
for various aircraft. The country ordered the sequencer using national 
stock number 1680010539320. Because supply class 1680 (miscellaneous 
aircraft accessories and components) was not restricted and the 
Security Assistance Management Information System did not verify that 
1680 was the correct supply class for national item identification 
number 010539320, the system approved the requisition. Had the system 
validated the entire 13-digit national stock number, it would have 
found that the number was incorrect and would not have approved the 
requisition. Subsequently, the item manager recognized that 1680 was 
not the correct federal supply class and corrected the supply class to 
1377 before the part was shipped. This example is summarized in figure 
3. Air Force officials were unaware of this situation until our review 
identified the problem.

Figure 3: Example of How a Restricted Item Was Requisitioned and 
Shipped:

[See PDF for image]

[End of figure]

In another case, involving the restricted 1377 federal supply class, a 
country ordered a restricted battery power supply for the F-16 aircraft 
using national stock number 6130013123511. Because supply class 6130 
(nonrotating electrical converters) was not restricted and the Security 
Assistance Management Information System did not verify the entire 13-
digit national stock number, the requisition was approved. The Air 
Force shipped the restricted battery power supply to the country. 
Neither the Air Force nor the center had written policies or procedures 
in place for recovering the items erroneously shipped. Without these 
types of policies and procedures, the Air Force cannot be assured that 
appropriate steps will be taken to recover the parts. Air Force 
Security Assistance Center officials agreed that the supply class 
restrictions alone were ineffective and could be bypassed by use of 
inaccurate supply class information.

Failure to Validate the System Could Allow Unauthorized Shipments of 
Classified Spare Parts:

The Air Force has not validated modifications to the Security 
Assistance Management Information System that restrict parts that 
countries can requisition, and has not tested the system's logic for 
restricting requisitions since 1998 to ensure that it is working 
properly. As a result, modifications that were not properly made went 
undetected, and foreign countries were able to requisition and obtain 
controlled spare parts that the Air Force was trying to restrict.

For example, the Air Force instructed programmers to modify a table of 
restrictions in the Security Assistance Management Information System 
to prevent certain countries from using blanket orders to requisition 
controlled bushings in the 5365 supply class. Although Air Force 
Security Assistance Center officials subsequently told us that the 
bushings had been improperly restricted, we found that, for 18 of the 
123 requisitions we reviewed, countries had ordered and received the 
bushings, because the Security Assistance Management Information System 
was incorrectly programmed and did not identify the requisitions as 
requiring a review by command country managers. After we brought the 
transactions to the attention of Air Force Security Assistance Center 
officials, they investigated and found that programmers had entered the 
restrictions in the wrong area of the system. Because the Air Force had 
not validated that system modifications were properly made, the system 
had approved the requisitions. Although the Air Force later determined 
that the bushings should not have been restricted, this example 
nevertheless demonstrates the need to validate system changes.

The Air Force does not periodically test the Security Assistance 
Management Information System to ensure that it accurately reviews 
requisitions for compliance with restrictions. For example, when the 
system is working correctly, it will identify restrictions relating to 
parts, such as ammunition or nuclear spare parts, and will disapprove 
requisitions from countries that are ineligible to order these parts. 
Air Force Security Assistance Command officials said that the system 
had not been tested since 1998 to ensure that it accurately reviews 
requisitions for compliance with restrictions. When we tested the 
system's ability to restrict items based on their federal supply class, 
we found that the system did not always perform as intended. As 
discussed earlier, the system did not perform as intended because 
countries could requisition and obtain classified and controlled spare 
parts using an incorrect, but unrestricted, federal supply class with 
an item's correct national item identification number.

In the Federal Information System Controls Audit Manual,[Footnote 13] 
which lists internal control activities for information systems, one of 
the control activities listed involves the testing of new and revised 
software to ensure that it is working correctly. In addition, 
management of federal information resources[Footnote 14] rules require 
agencies to establish information system management oversight 
mechanisms that provide for periodic reviews to determine how mission 
requirements might have changed and whether the information system 
continues to fulfill ongoing and anticipated mission requirements. 
Further, DOD's ADP Internal Control Guideline[Footnote 15]at the time 
stated that periodic reviews of systems should be conducted to 
determine if they operate as intended.

According to Air Force Security Assistance Center officials, there have 
been few changes to the table of restrictions in the system. However, 
they did agree that existing changes need to be validated and were 
working to accomplish this. Based on our observations, the Air Force's 
failure to validate modifications and test model logic is in part due 
to an unquestioning confidence in the Security Assistance Management 
Information System's ability to correctly restrict the requisitioning 
of classified and controlled spare parts.

Documentation for Overriding System and Item Manager Recommendations Is 
Inadequate:

Command country managers did not always document reasons for overriding 
Security Assistance Management Information System or foreign military 
sales case manager recommendations not to ship classified spare parts. 
According to the Standards for Internal Control in the Federal 
Government,[Footnote 16] all transactions and other significant events 
need to be clearly documented. The standards state that such 
documentation should be properly managed and maintained and should be 
readily available for examination.

Of the 123 requisitions we reviewed, the Security Assistance Management 
Information System identified 36 requisitions for command country 
manager review. For 19 of the requisitions, command country managers 
overrode the system recommendations and shipped classified and 
controlled spare parts without documenting the reasons for overriding 
the system. For example, the command country manager overrode the 
system and shipped four classified target-detecting devices, but the 
case file did not contain any documentation explaining why the command 
country manager did so, and managers we queried could not provide an 
explanation for the override. Similarly, a command country manager 
authorized the shipment of a controlled communications security part 
that the Security Assistance Management Information System and foreign 
military sales case manager recommended not be shipped. The case file 
contained no documentation explaining why the spare part was shipped. 
According to Air Force officials, there were no written policies or 
procedures for documenting decisions to override the system or foreign 
military sales case manager recommendations. The Air Force Security 
Assistance Center plans to issue guidance to command country managers 
to document system bypass authorizations.

Conclusions:

The Air Force has not established nor does it maintain effective 
internal controls over foreign military sales sold under blanket 
orders. Specifically, internal controls involving use of the federal 
supply class to restrict requisitions, the modification of tables 
restricting the access to classified and controlled spare parts in the 
Air Force's system, testing of the system, and documentation of system 
overrides were inadequate. Without adequate internal controls, 
classified and controlled spare parts may be released to countries that 
are ineligible to receive them, thereby providing military technology 
to countries that might use it against U.S. national interests. 
Further, without written policies detailing the steps to be taken when 
the Air Force becomes aware of an erroneous shipment, the Air Force's 
ability to recover erroneously shipped classified or controlled parts 
is lessened.

Recommendations for Executive Action:

To improve internal controls over the Air Force's foreign military 
sales program and to minimize countries' abilities to obtain classified 
or controlled spare parts under blanket orders for which they are not 
eligible,

we are recommending that the Secretary of Defense instruct the 
Secretary of the Air Force to require the appropriate officials to take 
the following steps:

* Modify the Security Assistance Management Information System so that 
it validates country requisitions based on the requisitioned item's 
complete national stock number.

* Establish policies and procedures for recovering classified or 
controlled items that are erroneously shipped.

* Establish polices and procedures for validating modifications made to 
the Security Assistance Management Information System to ensure that 
the changes were properly made.

* Periodically test the Security Assistance Management Information 
System to ensure that the system's logic for restricting requisitions 
is working correctly.

* Establish a policy for command country managers to document the basis 
for their decisions to override Security Assistance Management 
Information System or foreign military sales case manager 
recommendations.

Agency Comments and Our Evaluation:

In commenting on a draft of this report, DOD fully concurred with four 
of our recommendations and cited corrective actions that had been taken 
or were planned, and it partially concurred with another 
recommendation. Specifically, with regard to our recommendation to 
modify the Security Assistance Management Information System to 
validate country requisitions based on the requisitioned item's 
national stock number, the department said that it has had a change in 
place since January 2003 to validate requisitions based on an item's 
national stock number. We believe that the department's change is 
responsive to findings that we brought to the Air Force's attention in 
December 2002. However, because our audit work was completed when the 
Air Force brought this change to our attention, we did not have an 
opportunity to validate the change. The department also stated that the 
Air Force (1) will write a policy memorandum on procedures for 
recovering classified or controlled items that are erroneously shipped, 
(2) will issue a policy memorandum directing that all modifications to 
the system be validated in accordance with existing policies and 
procedures, and (3) has issued a policy memorandum specifying those 
staff who can input transactions for overriding restrictions and 
requiring that waiver approvals for using the bypasses be documented.

With regard to our recommendation to periodically test the system to 
ensure that its logic for restricting requisitions is working 
correctly, DOD partially concurred. The department said that a program 
is being implemented to test new modifications placed in the system and 
that the testing of old modifications would be an ongoing effort. 
Testing the modifications placed in the system will ensure that they 
were made correctly. However, just testing the modifications will not 
ensure that the system is correctly applying its logic to the 
modifications in order to restrict requisitions for items that 
countries are not eligible to receive. For example, testing 
modifications may not identify logic problems, such as the one we 
identified involving the approval of requisitions based on an item's 
federal supply class. Thus, we continue to believe that the system's 
logic for restricting requisitions should be periodically tested to 
ensure that it is working correctly. Otherwise, classified and 
controlled spare parts that are requisitioned may continue to be 
erroneously released.

DOD's comments appear in appendix I.

Scope and Methodology:

To determine the adequacy of the Department of the Air Force's key 
internal control activities aimed at preventing countries from 
requisitioning and receiving classified and controlled spare parts that 
they are ineligible to receive, we held discussions with officials from 
the Under Secretary of Defense (Policy Support) International Security 
Program Directorate; Deputy Under Secretary of the Air Force 
(International Affairs); and the Air Force Materiel Command's Security 
Assistance Center, Dayton, Ohio. We discussed the officials' roles and 
responsibilities, the criteria and guidance they used in performing 
their duties, and the controls used to restrict countries from 
receiving parts that they are not eligible to requisition. At the Air 
Force Security Assistance Center and Air Logistics Centers at Warner 
Robins Air Force Base, Macon, Georgia, and Tinker Air Force Base, 
Oklahoma City, Oklahoma, we interviewed military and civilian officials 
to obtain an overview of the requisitioning and approval processes 
applicable to classified and controlled spare parts.

To test the adequacy of the internal controls, we obtained records from 
the Air Force Security Assistance Center on all classified and 
controlled spare parts that were purchased under blanket orders and 
approved for shipment to foreign countries for the period October 1, 
1997, through July 31, 2002. We limited our study to blanket orders 
because defined orders and Cooperative Logistics Supply Support 
Agreements specified the parts that countries were entitled to 
requisition by national stock number. In contrast, only Security 
Assistance Management Information System restrictions limited the parts 
that countries were entitled to order under blanket orders. The records 
covered 444 blanket orders that resulted in 72,057 requisitions for 
classified and controlled spare parts. Specifically, we took the 
following steps:

* We tested the Security Assistance Management Information System by 
applying the system's restrictions that applied to classified and 
controlled spare parts that were shipped under blanket orders, and 
identified 525 requisitions that appeared to violate the restrictions. 
We obtained satisfactory explanations from the Air Force Security 
Assistance Command for all except 200 of the requisitions, which were 
shipped despite restrictions.

* We reviewed case files for 123 requisitions,[Footnote 17] including 
87 requisitions for which the Security Assistance Management 
Information System had approved the shipment of classified and 
controlled spare parts without referring the requisitions to command 
country managers to determine if the requisitions should be approved. 
We followed up on these requisitions by consulting with command country 
managers.

* The case files that we reviewed included 36 requisitions that the 
Security Assistance Management Information System had referred to 
command country managers for review to determine if they had documented 
their decisions to override the system's decisions. We followed up on 
these reviews through discussions with command country managers.

We conducted our review from May 2002 through May 2003 in accordance 
with generally accepted government auditing standards.

As arranged with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from the date of this letter. At that time, we will send copies of this 
report to the Secretary of Defense; the Secretary of the Air Force; the 
Director, Office of Management and Budget; and interested congressional 
committees. We will also make copies available to others upon request. 
In addition, the report will be available at no charge on the GAO Web 
site at http://www.gao.gov.

Please contact me on (202) 512-8365, if you or your staff have any 
questions concerning this report. Key contributors to this report were 
Lawson (Rick) Gist, Jr.; Jennifer Thomas; Arthur James, Jr.; Lou 
Modliszewski; Susan Woodward; John Lee; and Kristy Lehmann.

Sincerely yours,

William M. Solis, Director 
Defense Capabilities and Management:

Signed by William M. Solis: 

[End of section]

Appendix I: Comments from the Department of Defense:

DEFENSE SECURITY COOPERATION AGENCY:

WASHINGTON, DC 20301-2800:

JUL 11 2003:

In reply refer to: I-03/007485:

Mr. William M. Solis, Director Defense Capabilities and Management U.S. 
General Accounting Office:

441 G Street, N.W. Washington, D.C. 20548:

Dear Mr. Solis:

This is the Department of Defense (DoD) response to the GAO Draft 
report, "Foreign Military Sales: Improved Air Force Controls Could 
Prevent Unauthorized Shipments of Classified and Controlled Spare Parts 
to Foreign Countries" dated May 23, 2003 (GAO Code 350223/GAO-03-664).

The Department reviewed the draft report and concurs in principle with 
the recommendation that the Secretary of Defense instruct the Secretary 
of the Air Force to require the appropriate officials to take 
corrective measures that ensure adequate controls are in place to 
prevent future unauthorized shipments of classified and/or controlled 
spare parts to foreign countries.

Comments addressing each of the five GAO draft report recommendations 
are included in the enclosure. We also provided the GAO with technical 
comments regarding the draft report under separate cover.

The Department appreciates the opportunity to comment on the draft 
report. My point of contact on this matter is Ms. Kathy Robinson. She 
may be contacted by email: kathy.robinson@dsca.tnil or by telephone at 
(703) 601-4368.

Sincerely,

TOME H. WALTERS, JR. LIEUTENANT GENERAL, USAF DIRECTOR:

Signed by TOME H. WALTERS, JR.: 

Attachment As stated:

GAO DRAFT REPORT - DATED MAY 23, 2003 GAO CODE 350223/GAO-03-664:

"FOREIGN MILITARY SALES: IMPROVED AIR FORCE CONTROLS COULD PREVENT 
UNAUTHORIZED SHIPMENTS OF CLASSIFIED AND CONTROLLED SPARE PARTS TO 
FOREIGN COUNTRIES":

DEPARTMENT OF DEFENSE COMMENTS TO THE GAO RECOMMENDATIONS:

RECOMMENDATION 1: The GAO recommended that the Secretary of Defense 
instruct the Secretary of the Air Force to require that the appropriate 
officials modify the Security Assistance Management Information System 
(SAMIS) so that it validates country requisitions based on the 
requisitioned item's complete national stock number. (p. 15/GAO Draft 
Report):

DOD RESPONSE Concur. A change has been in place since 29 Jan 03 whereby 
there is a check for supply class updates prior to requisition 
screening against edits in SAMIS table 105. It was tested in accordance 
with SAMIS procedures (SAMIS 01 10-3). This system modification 
accomplishes validation of country requisitions based on the 
requisitioned item's national stock number. The final audit report 
should reflect that AFSAC has accomplished this change and that the 
requirement for modifying the system is no longer an issue. In 
addition, the new Case Execution Management Information System (CEMIS) 
being developed by DSCA and the Military Departments has built in 
numerous requisition validation edits that will reject unauthorized 
orders from further processing, and thus preclude these types of 
occurrences in the future. Anticipate CEMIS will be ready for initial 
deployment in FY 07 timeframe.

RECOMMENDATION 2: The GAO recommended that the Secretary of Defense 
instruct the Secretary of the Air Force to require that the appropriate 
officials establish policies and procedures for recovering classified 
or controlled items that are erroneously shipped. (p. 15/GAO Draft 
Report):

DOD RESPONSE: Concur. Recovery of a classified or controlled item that 
was erroneously released and shipped to an unauthorized customer should 
be on an exception basis that is to apply when benefits to national 
security exceed financial and other costs of recovery. The AF can 
request the Purchaser submit a Supply Discrepancy Report for a 
misdirected shipment (per DLAI 4140.55, enclosure 7) for the item and 
then have the established processes for item return and customer 
reimbursement apply. If the customer refuses to return the item, then 
the possibility of seeking DSCA suspension of the customer's FMS 
program may be considered. SAF/IAPX will write a policy memorandum and 
coordinate with DSCA and the legal offices as required. Estimated 
completion date is 15 July 2003.

RECOMMENDATION 3: The GAO recommended that the Secretary of Defense 
instruct the Secretary of the Air Force to require that the appropriate 
officials establish policies and procedures for validating 
modifications made to the Security Assistance Management Information 
System to ensure that the changes were properly made. (p. 15/GAO Draft 
Report):

DOD RESPONSE: Concur. There have been few, if any, policy directives 
that have generated modifications to SAMIS table 105 (which was the 
focus of the audit) in recent years. There is a lack of narrative 
documentation for edits in the table and some of the existing edits 
need to be validated and necessary narrative entries made. This is an 
ongoing effort and testing will be done if changes are required. 
Policies and procedures are in place for all modifications to SAMIS 
(per 01 10-1 - SAMIS Programming Requirements Processing and Input, and 
01 10-3 - SAMIS Testing Procedures). Narrative rationale will be 
required for new entries to Table 105. The AFSAC Security Assistance 
Policy Office will be sending a policy memorandum directing applicable 
process owners and Offices of Primary Responsibility to adhere to this 
requirement. The estimated completion date for the policy memorandum is 
15 July 2003.

RECOMMENDATION 4: The GAO recommended that the Secretary of Defense 
instruct the Secretary of the Air Force to periodically test the 
Security Assistance Management Information System to ensure that the 
system's logic for restricting requisitions is working correctly. (p. 
15/GAO Draft Report):

DOD RESPONSE: Partially Concur. To help prevent unauthorized release of 
classified and controlled spare parts to foreign countries, testing for 
SAMIS table 105 will take place. The testing will occur when 1) there 
are changes to the SAMIS requisition logic, 2) there is a change in the 
system logic of SAMIS table 105 itself, and 3) there are modifications 
to SAMIS table 105 as a consequence of on-going verification of SAMIS 
table 105 entries. Prevention of unauthorized asset releases is 
accomplished via the SAMIS table 105 edits in conjunction with proper 
control of the transactions that allow these edits to be bypassed. 
Until recently, access to bypass transactions was only partially 
restricted. We have since established bypass oversight control whereby 
only designated process owners may input bypasses, and only upon 
obtaining waiver approval. Guidance for mandatory formal releasability 
reviews of bypass candidate items is expected to be signed out by 31 
July 03. A change is in place now is to check the Federal Stock Class 
of a requisition for currency prior to screening against the edits in 
SAMIS table 105 (the logic for this has been tested), and it is updated 
prior to the screening if necessary. A program that will verify 
accuracy of all new entries in SAMIS Table 105 is estimated to be 
operational by 14 July 03.

RECOMMENDATION 5: The GAO recommended that the Secretary of Defense 
instruct the Secretary of the Air Force to require that the appropriate 
officials establish a policy for command country managers to document 
the basis for their decisions to override Security Assistance 
Management Information System or foreign military sales case manager 
recommendations. (p. 15/GAO Draft Report):

DOD RESPONSE: Concur. AFSACAA policy memorandum written 13 May 03 
restricts who can input bypass transactions for over-riding edit 
restrictions in SAMIS Table 105 and 
requires that waiver approvals for using the bypasses be documented 
both electronically in SAMIS requisition narratives, and as hard copy 
(by the waiver request initiator) in the case files. The final audit 
report should reflect that AFSAC has accomplished this change and that 
establishing documentation policy is no longer an issue.

[End of section]

FOOTNOTES

[1] Classified spare parts are restricted for national security 
reasons; controlled parts are not classified but contain military 
technology/applications or are controlled cryptographic parts.

[2] The Security Assistance Management Information System is the Air 
Force's information system used to verify that countries are eligible 
to requisition and receive spare parts.

[3] Hereafter referred to as blanket orders.

[4] We initially reviewed 2 requisitions involving controlled 
communications security items and subsequently added 119 controlled and 
2 confidential requisitions to the review.

[5] The federal supply classification is a 4-digit number that 
designates a general commodity grouping, such as communications 
security equipment and components. Each part within a supply class has 
a unique 9-digit number--called the national item identification 
number--that differentiates each individual item in the department's 
inventory system. Together, the two numbers form a 13-digit national 
stock number.

[6] Item managers at the Air Force's air logistics centers are 
responsible for managing items in the Air Force's supply system. 

[7] A bushing is cylindrical metal sleeve used to reduce friction.

[8] Command country managers and foreign military sales case managers 
at the Air Force Security Assistance Center are respectively 
responsible for managing the sale of items to countries and for 
monitoring a particular type of case, such as a blanket order.

[9] Public Law 90-629.

[10] Public Law 87-195.

[11] The first two digits of the federal supply class are called a 
supply group and include several similar federal supply classes.

[12] Under the foreign military sales program, the Air Force also uses 
defined order cases (which cover specific items and quantities) and 
Cooperative Logistics Supply Support Agreements (which allow foreign 
countries to become partners in the military service's logistics 
system). The service purchases items for use of the foreign governments 
and monitors the foreign governments' demand for those items to ensure 
that an adequate level of support is available.

[13] U.S. General Accounting Office, Federal Information System 
Controls Audit Manual, GAO/AIMD-12.19.6 (Washington, D.C.: Jan. 1999). 

[14] Office of Management and Budget, Management of Federal Information 
Resources (Washington, D.C.: Nov. 2000).

[15] Department of Defense, ADP Internal Control Guideline (July 1988).

[16] U.S. General Accounting Office, Standards for Internal Control in 
the Federal Government, GAO/AIMD-00.21.3.1 (Washington, D.C.: Nov. 
1999).

[17] We initially reviewed 2 requisitions involving controlled 
communications security items and subsequently selected 121 additional 
requisitions to review. We selected requisitions from Bahrain, Egypt, 
Greece, Israel, Italy, Jordan, Morocco, Saudi Arabia, South Korea, 
Taiwan, Thailand, Tunisia, and Turkey and for specific types of 
equipment. Two of the requisitions were for confidential items; the 
remaining 121 requisitions were for controlled items.

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