This is the accessible text file for GAO report number GAO-08-538
entitled 'Supply Chain Security: CBP Works with International Entities
to Promote Global Customs Security Standards and Initiatives, but
Challenges Remain' which was released on August 18, 2008.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
August 2008:
Supply Chain Security:
CBP Works with International Entities to Promote Global Customs
Security Standards and Initiatives, but Challenges Remain:
International Supply Chain Security:
GAO-08-538:
GAO Highlights:
Highlights of GAO-08-538, a report to congressional requesters.
Why GAO Did This Study:
Oceangoing cargo containers play a vital role in global trade but can
also pose a risk of terrorist exploitation. U.S. Customs and Border
Protection (CBP), part of the Department of Homeland Security (DHS),
oversees security of the supply chain—the flow of goods from
manufacturer to retailer. CBP anticipates that adoption of uniform,
international customs security standards could eventually lead to a
system of mutual recognition whereby the customs security-related
practices and programs taken by one customs administration are
recognized and accepted by another administration. In response to
congressional requesters, GAO determined (1) actions CBP has taken to
develop and implement international supply chain security standards,
(2) actions CBP has taken with international partners to achieve mutual
recognition of customs security practices, and (3) issues CBP and
foreign customs administrations anticipate in implementing 100 percent
scanning of U.S.-bound container cargo. To conduct its work, GAO
analyzed CBP documents on supply chain security programs and
international cooperation initiatives and met with CBP officials and
foreign customs officials from various trading partner nations. Also,
GAO drew upon its related reports and testimony on supply chain
security issued earlier this year—GAO-08-187 (Jan. 25), GAO-08-240
(Apr. 25), and GAO-08-533T (June 12). DHS provided technical comments
on a draft of this report, which GAO incorporated where appropriate.
What GAO Found:
To develop and implement international supply chain security standards,
CBP has taken a lead role in working with foreign customs
administrations and the World Customs Organization (WCO). Through the
Container Security Initiative (CSI), CBP places staff at foreign
seaports to work with host nation customs officials to identify high-
risk container cargo bound for the United States, and through the
Customs-Trade Partnership Against Terrorism (C-TPAT), CBP forms
voluntary partnerships to enhance security measures with international
businesses involved in oceangoing trade with the United States. In
collaboration with 11 other members of the WCO, CBP developed the
Framework of Standards to Secure and Facilitate Global Trade (SAFE
Framework), which is based in part on the core concepts of the CSI and
C-TPAT programs and provides standards for collaboration among customs
administrations and entities participating in the supply chain. The
SAFE Framework was adopted by the 173 WCO member customs
administrations in June 2005; and as of July 2008 154 had signed
letters of intent to implement the standards.
CBP has actively engaged with international partners to define and
achieve mutual recognition of customs security practices. Broadly, for
example, CBP contributed to development of the SAFE Framework, which
calls for a system of mutual recognition. More specifically, in June
2007, CBP signed a mutual recognition arrangement with New Zealand—the
first such arrangement in the world—to recognize each other’s customs-
to-business partnership programs. Furthermore, in June of this year,
CBP signed mutual recognition agreements with Jordan and Canada. By
early 2009, CBP anticipates obtaining a mutual recognition agreement
with the European Commission, which represents the 27 member nations of
the European Union.
CBP actively engages in the implementation of international customs
security standards, however recent law, such as The Implementing
Recommendations of the 9/11 Commission Act of 2007 (9/11 Act) requiring
that 100 percent of U.S.-bound container cargo be scanned at foreign
seaports—using a nonintrusive inspection process involving equipment
such as X-rays and radiation detection equipment—may affect worldwide
adoption of international supply chain security standards. CBP and some
foreign partners have stated that unless additional resources are made
available, 100 percent scanning could not be met. Given limited
resources, CBP and European custom administration officials said that
100 percent scanning may provide a lower level of security if customs
officers are diverted from focusing on high-risk container cargo. Under
the current risk-management system, for example, the scanned images of
high-risk containers are to be reviewed in a very detailed manner.
However, according to WCO and industry officials, if all containers are
to be scanned, the reviews may not be as thorough. Further, a European
customs administration reported that 100 percent scanning could have a
negative impact on the flow of commerce and also would affect trade
with developing countries disproportionately.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-538]. For more
information, contact Stephen Caldwell at (202) 512-9610 or
CaldwellS@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
CBP and Foreign Customs Administrations Have Jointly Developed Global
Customs Security Standards and Initiatives and Work Cooperatively to
Implement These Standards Worldwide:
CBP Is Working with Foreign Customs Administrations to Develop
International Standards for Customs-to-Customs Relationships and for
Customs-to-Business Partnership Programs:
CBP and International Partners Are Working to Achieve Mutual
Recognition of Customs Security Practices:
While Working to Internationalize Customs Security Standards, CBP and
International Partners Report Challenges in Balancing These Efforts
with Other Legal Requirements:
Concluding Observations:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: World Customs Organization SAFE Framework of Standards:
Appendix III: CBP's Collaborative Efforts to Enhance Container
Security:
Appendix IV: The Secure Freight Initiative:
Appendix V: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Major U.S. Initiatives to Secure Oceangoing Containers:
Table 2: U.S.-EU Joint Customs Cooperation Committee Action Plan as of
June 2008:
Table 3: WCO SAFE Framework--Standards for the Customs-to-Customs
Pillar:
Table 4: WCO SAFE Framework--Standards for the Customs-to-Business
Pillar:
Table 5: CBP's Collaborative Efforts to Enhance Container Security:
Table 6: Information on the Six Foreign Seaports Participating in the
SFI Pilot Program:
Figures:
Figure 1: Overview of Key Participants Involved in Shipping Containers
in the International Supply Chain:
Figure 2: CSI Targeting and Examination Activities:
Figure 3: Timeline of Major U.S. and International Events to Facilitate
Supply Chain Security:
Figure 4: World Map Indicating the 154 WCO Member Countries That Have
Signed Letters of Intent to Implement the WCO SAFE Framework:
Figure 5: The Twin Pillars of Customs-to-Customs Network Arrangements
and Customs-to-Business Partnership Programs Based on the Four Core
Principles of the WCO SAFE Framework of Standards:
Figure 6: Two Forms of Mutual Recognition:
Abbreviations:
9/11 Act: Implementing Recommendations of the 9/11 Commission Act:
AEO: Authorized Economic Operator:
APEC: Asia-Pacific Economic Cooperation:
ATS: Automated Targeting System:
C-TPAT: Customs-Trade Partnership Against Terrorism:
CBP: Customs and Border Protection:
CSI: Container Security Initiative:
DHS: Department of Homeland Security:
DOE: Department of Energy:
EU: European Union:
JCCC: Joint Customs Cooperation Committee:
NTC-C: National Targeting Center--Cargo:
SAFE Port Act: Security and Accountability for Every Port Act:
SAFE Framework: WCO Framework of Standards to Secure and Facilitate
Global Trade:
SFI: Secure Freight Initiative:
WCO: World Customs Organization:
WMD: weapons of mass destruction:
United States Government Accountability Office:
Washington, DC 20548:
August 15, 2008:
Congressional Requesters:
Concerns about the ability of both the federal government and U.S.
companies participating in international maritime commerce to identify
and prevent weapons of mass destruction (WMD) from being smuggled
inside cargo containers bound for the United States have heightened
since the terrorist attacks of 2001. Oceangoing cargo containers play a
vital role in the movement of cargo between global trading partners,
and more than 700 foreign seaports ship cargo to the United States. In
fact, 11 million oceangoing cargo containers arrived at U.S. seaports
in fiscal year 2007--meaning roughly 30,000 oceangoing containers
arrived each day that year. Balancing security concerns with the need
to facilitate the free flow of commerce remains an ongoing challenge
for the public and private sectors alike.
In the federal government, U.S. Customs and Border Protection (CBP),
part of the Department of Homeland Security (DHS), is responsible for
overseeing oceangoing container security and reducing the
vulnerabilities associated with the supply chain--the flow of goods
from manufacturers to retailers. As CBP performs this mission, it
maintains two overarching and sometimes conflicting goals--increasing
security while facilitating legitimate trade and travel. To address
these goals, CBP has developed a layered risk-management approach to
cargo security.[Footnote 1] This approach includes analyzing trade data
received in advance of cargo being shipped to facilitate risk-based
decisions for the identification of high-risk cargo. Also, as part of
this risk-management approach, CBP operates two voluntary security
programs. The first is the Container Security Initiative (CSI), a
customs-to-customs program that places CBP officers in foreign seaports
to use intelligence and risk assessment information to determine
whether U.S.-bound shipments are at risk of containing WMD or other
terrorist contraband--a process referred to as targeting.[Footnote 2]
The second is the Customs-Trade Partnership Against Terrorism (C-TPAT),
a customs-to-business partnership program that provides benefits to
supply chain companies that comply with pre-determined security
measures.[Footnote 3] In addition, to better protect international
trade against the threat of terrorism, CBP promotes a set of
international customs security standards similar to the CSI and C-TPAT
programs, which as of June 2008, 154 countries have pledged to adopt.
To develop and promote the implementation of these international
standards for supply chain security, CBP works through the World
Customs Organization (WCO)--an intergovernmental organization
representing the customs administrations of 173 countries, which aims
to enhance the effectiveness and efficiency of customs administrations.
CBP and the WCO anticipate that widespread adoption of uniform,
international customs security standards eventually could lead to the
development of a system of mutual recognition whereby the security-
related practices and programs taken by the customs administration of
one country are recognized and accepted by the administration of
another. According to CBP, a system of mutual recognition could lead to
greater efficiency in providing security by, for example, reducing
redundant examinations of container cargo and avoiding the unnecessary
burden of addressing different sets of requirements as a shipment moves
through the supply chain in different countries, thereby facilitating
international trade.
To further address container security concerns, Congress passed, and
the President signed, the Security and Accountability for Every (SAFE)
Port Act in 2006, which includes provisions that codified the CSI and C-
TPAT programs, both of which had been CBP initiatives but not
previously required by law.[Footnote 4] The act also included
requirements for CBP to consider factors such as cargo volume when
designating seaports as CSI participants and required CBP to test the
feasibility of scanning 100 percent of U.S.-bound container cargo in
foreign seaports. To fulfill these and other requirements of the act,
CBP developed the Secure Freight Initiative (SFI) and the SFI pilot
program.[Footnote 5] In August 2007, the Implementing Recommendations
of the 9/11 Commission Act of 2007 (9/11 Act) was enacted, requiring,
among other things, that foreign seaports scan 100 percent of U.S.-
bound container cargo by 2012, with possible exemptions for individual
seaports,[Footnote 6] replacing the similar provision in the SAFE Port
Act that did not have a deadline for full implementation of the
scanning requirement.[Footnote 7]
In response to your request, we assessed CBP's efforts related to
international customs security standards. Specifically, this report
addresses the following questions:
* What actions has CBP taken to develop and implement international
supply chain security standards?
* What actions has CBP taken with international partners to achieve
mutual recognition of customs security practices?
* What issues do CBP and foreign customs administrations working to
internationalize customs security standards anticipate in implementing
100 percent scanning of U.S.-bound container cargo?
To address these objectives, we reviewed available CBP documentation,
such as reports pertaining to the CSI, C-TPAT, and SFI programs, and
international agreements related to CBP's work in the international
trade community. In addition, we met with CBP officials in Washington,
D.C., who have program responsibilities for international affairs and
trade. Also, to discuss multilateral and bilateral efforts to promote
supply chain security, we met with representatives from the European
Commission and the WCO, as well as with customs officials from the
Americas, Asia, and Europe at the 2007 WCO World Customs Forum and
CBP's 2007 CSI Global Targeters Conference.[Footnote 8] We also spoke
with representatives of industry groups, including CBP's Departmental
Advisory Committee on Commercial Operations and the Federation of
European Private Port Operators.[Footnote 9] We spoke with officials of
foreign customs administrations during our visits to 6 of the 58
seaports that participate in the CSI program.[Footnote 10] We selected
the six CSI seaports--located in the countries of Belgium, Canada,
France, Honduras, South Korea, and United Arab Emirates--based on
geographic and strategic significance, container volume shipped to the
United States from the seaports, and when the seaports began conducting
CSI operations. The results from our visits to seaports provided
examples of CBP and host government operations but cannot be
generalized beyond the seaports visited because we did not use
statistical sampling techniques in selecting the seaports. Similarly,
while the perspectives of foreign officials we spoke to cannot be
generalized across the wider population of countries, they provided us
examples of how CBP interacts with foreign customs administration
officials at overseas seaports. Additionally, we reviewed CBP and WCO
documents on international initiatives for enhancing supply chain
security. We conducted this performance audit in conjunction with
concurrent reviews of the CSI and C-TPAT programs from May 2006 through
July 2008 in accordance with generally accepted government auditing
standards.[Footnote 11] 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. A
detailed discussion of our scope and methodology is contained in
appendix I.
Results in Brief:
CBP has taken a lead role in working with members of the international
customs community--including foreign customs administrations in the WCO
and relevant private industry groups--to develop and implement
international supply chain security standards. CBP, along with 11 other
members of the WCO, developed the Framework of Standards to Secure and
Facilitate Global Trade (commonly referred to as the SAFE Framework)
that was adopted in June 2005 by the 173 member customs administrations
of the WCO. The SAFE Framework--which is based on CBP's CSI and C-TPAT
programs--provides guidance to WCO member customs administrations on
(1) customs-to-customs practices that assist in securing the
international supply chain against terrorism and other forms of
transnational crimes and (2) the development of customs-to-business
partnership programs such as the C-TPAT program. Working with
international partners, CBP has assisted in the international
implementation of the SAFE Framework by participating in a capacity-
building program that provides technical assistance and training to the
customs administrations of developing countries. In addition to working
through the WCO to promote international customs security standards,
CBP's CSI and C-TPAT programs have influenced the development of
similar programs in other countries because their programs provide
models for how to implement the security standards in the SAFE
Framework.
CBP has worked with the international customs community to achieve a
system of mutual recognition--an arrangement whereby the actions or
decisions taken by one customs administration are recognized and
accepted by another administration--by, among other things, adopting
and implementing the SAFE Framework that calls for a system of mutual
recognition, and by developing an action plan for the achievement of
mutual recognition of customs-to-business partnership programs. The
WCO's SAFE Framework calls for the establishment of two types of mutual
recognition--mutual recognition of customs controls and mutual
recognition of customs-to-business partnership programs. According to
CBP, although not easily or quickly attained, achieving mutual
recognition offers the potential benefit of providing CBP an exit
strategy for the CSI program in some countries. Generally, while
accepting the WCO definition of mutual recognition, CBP focuses its
efforts by offering guidance on and a process for achieving mutual
recognition of customs-to-business partnership programs--referred to as
Authorized Economic Operator (AEO) programs. According to officials
from CBP and foreign customs administrations, a system of mutual
recognition will be a catalyst for further implementation of AEO
programs. To work toward a system of mutual recognition of customs-to-
business partnership programs, CBP engages in activities with other
countries. For example, in June 2007, CBP signed a mutual recognition
arrangement with New Zealand--the first such arrangement in the world-
-to recognize each other's customs-to-business partnership programs and
later signed mutual recognition agreements with Jordan and Canada in
June 2008. Further, CBP and the European Commission have agreed to
establish mutual recognition of customs-to-business partnership
programs by early 2009.
CBP actively engages in the development and implementation of
international customs security standards; however it may face issues in
worldwide adoption of these standards because of the statutory
requirement to scan 100 percent of U.S.-bound container cargo. While
the pilot program is still underway and its full impacts are still
unknown, international partners have expressed to DHS and Congress that
100 percent scanning runs counter to--and could adversely impact the
implementation of--international customs security standards such as the
SAFE Framework. Officials from the European Commission and CBP stated
that unless additional resources are made available, 100 percent
scanning could not be met. And as we testified in June 2008, it is
unclear who will pay for additional resources--including increased
staff, equipment, and infrastructure--needed to implement the statutory
requirement to scan 100 percent of U.S.-bound container cargo at
foreign seaports. Given these resource issues, officials from CBP and
European customs administrations stated that scanning all cargo bound
for the United States may actually provide a lower level of security.
The officials explained that 100 percent scanning could result in
diluting the current focus on high-risk containers. Under the current
risk-management system, customs officers are to base their reviews on
the perceived risk posed by the cargo and, thus, are to review the
scanned images of high-risk containers in a very thorough and detailed
manner. However, according to CBP and WCO officials, if the scanned
images of all containers must be reviewed, the reviews may not be as
thorough because customs officers could lose focus due to the sheer
volume of work. If images are not properly or thoroughly analyzed, a
degradation of security could result. Further, a European customs
administration official reported that 100 percent scanning could have a
negative impact on the flow of international commerce. The official
also added that the 100 percent scanning requirement would
disproportionately affect trade with developing countries.
In commenting on a draft copy of this report, DHS provided technical
clarifications, which we incorporated where appropriate.
Background:
Vulnerabilities of Containers in the International Supply Chain:
Seaports are critical gateways for the movement of commerce through the
international supply chain. The facilities, vessels, and infrastructure
within seaports, and the cargo passing through them, all have
vulnerabilities that terrorists could exploit. The containers carrying
goods that are shipped in oceangoing vessels are of particular concern
because they can be filled overseas at many different locations and are
transported through complex logistics networks before reaching U.S.
seaports.
In addition, transporting a shipping container from its international
point of origin to its final destination involves many different
participants and many points of transfer. The material in a container
can be affected not only by the manufacturer or supplier of the
material being shipped but also by carriers who are responsible for
getting the material to a seaport and by personnel who load containers
onto the ships. Others who interact with the cargo or have access to
the records of the goods being shipped include exporters who make
arrangements for shipping and loading, freight consolidators who
package disparate cargo into containers, and forwarders who manage and
process the information about what is being loaded onto the ship.
Figure 1 illustrates many of the key participants and points of
transfer involved from the time that a container is loaded for shipping
to its arrival at the destination seaport and ultimately the importer.
Figure 1: Overview of Key Participants Involved in Shipping Containers
in the International Supply Chain:
This figure is an overview of the key participants involved in shipping
containers in the International supply chain.
Export Side:
Exporter;
Freight coordinator;
Inland carrier (e.g. truck, rail);
Freight forwarder.
Import Side:
Customs broker;
Customs inspectors;
Terminal operator;
Inland carrier (e.g. truck, rail);
Importer.
[See PDF for image]
Source: GAO, DHS.
[End of figure]
Several studies of maritime security conducted by federal, academic,
nonprofit, and business organizations have concluded that the movement
of oceangoing cargo in containers is vulnerable to some form of
terrorist action. Every time responsibility for cargo in containers
changes hands along the supply chain there is the potential for a
security breach; thus, vulnerabilities exist that terrorists could take
advantage of by, for example, placing a WMD into a container for
shipment to the United States or elsewhere. While there have been no
known incidents of containers being used to transport WMDs, criminals
have exploited containers for other illegal purposes, such as smuggling
weapons, people, and illicit substances. Finally, while CBP has noted
that the likelihood of terrorists smuggling WMDs into the United States
in cargo containers is low, the nation's vulnerability to this activity
and the consequences of such an attack are potentially high. For
example, in 2002, Booz Allen Hamilton sponsored a simulated scenario in
which the detonation of weapons smuggled in cargo containers shut down
all U.S. seaports for 12 days. The results of the simulation estimated
that the seaport closures could result in a loss of $58 billion in
revenue to the U.S. economy along with significant disruptions to the
movement of trade.
The U.S. Government Is Engaged in Efforts to Secure Containers in the
International Supply Chain:
The federal government has taken many steps to secure the supply chain,
including the cargo in oceangoing containers destined for the United
States. While CBP officials at domestic seaports continue efforts to
identify and examine high-risk imports arriving in containers, CBP's
post-9/11 strategy also involves focusing security efforts beyond U.S.
borders to target and examine high-risk cargo before it enters U.S.
seaports. As discussed earlier in this report, CBP's strategy is based
on a layered approach of related initiatives that attempt to focus
resources on potentially risky cargo shipped in containers while
allowing other containers carrying cargo to proceed without unduly
disrupting commerce into the United States. While the Department of
Energy (DOE) has led U.S. efforts to detect radiation in cargo
containers originating at foreign seaports, CBP has initiated five
initiatives addressing container security. A brief description of each
is shown in table 1.
Table 1: Major U.S. Initiatives to Secure Oceangoing Containers:
Initiative and year introduced: Automated Targeting System (ATS), 1999;
Department: DHS;
Description: ATS is a complex mathematical model that uses weighted
rules to assign a risk score to arriving cargo shipments based on
shipping information. ATS helps CBP identify and prevent potential
terrorists and terrorist weapons from entering the United States. CBP
uses this computerized decision support tool to review documentation,
including electronic cargo manifest[A] information submitted by the
ocean carriers on all arriving shipments, and entry data (more detailed
information about the cargo) submitted by brokers to develop risk
scores that help identify containers for additional examination.
Initiative and year introduced: 24-hour Rule, 2002;
Department: DHS;
Description: CBP generally requires ocean carriers to electronically
transmit cargo manifests and entry data to CBP's Automated Manifest
System--a system designed to control imported merchandise from the time
a carrier's cargo manifest is submitted to CBP until the cargo is
properly entered and released by CBP--24 hours before the U.S.-bound
cargo is loaded onto a vessel at a foreign seaport. Carriers and
importers are to provide information to CBP that is used by ATS in
deriving risk scores. The cargo manifest information is submitted by
ocean carriers on all arriving cargo shipments, and entry data are
submitted by brokers.
Initiative and year introduced: Container Security Initiative (CSI),
2002;
Department: DHS;
Description: CBP, through the CSI program, places staff at
participating foreign seaports to work with host country customs
officials to identify and examine high-risk cargo to be shipped in
containers for WMD before they are shipped to the United States. CBP
officials identify the high-risk containers and request that their
foreign counterparts examine the contents of the containers.
Initiative and year introduced: Customs-Trade Partnership Against
Terrorism (C-TPAT), 2001;
Department: DHS;
Description: CBP develops voluntary partnerships with members of the
international trade community comprised of importers; customs brokers;
forwarders; air, sea, and land carriers; and contract logistics
providers. Private companies agree to improve the security of their
supply chains in return for various benefits, such as a reduced
likelihood that their containers will be examined. As of May 2008,
there were over 8,400 C- TPAT members from the international trade
community that had various roles in the supply chain.
Initiative and year introduced: Megaports Initiative, 2003;
Department: DOE;
Description: DOE installs radiation detection equipment at key foreign
seaports, enabling foreign government personnel to use radiation
detection equipment to screen shipping containers entering and leaving
these seaports, regardless of the containers' destination, for nuclear
and other radioactive material that could be used against the United
States and its allies.
Initiative and year introduced: Secure Freight Initiative, 2007;
Department: DHS, DOE;
Description: Pilot program at six selected CSI seaports to scan 100
percent of U.S.-bound container cargo for nuclear and radiological
materials overseas using integrated examination systems that couple
nonintrusive inspection equipment and radiation detection equipment.
Source: GAO summary of information obtained from DHS and DOE.
[A] Cargo manifests are prepared by the ocean carrier and are composed
of bills of lading for each shipment of cargo loaded on a vessel to
describe the contents of the shipments. The bill of lading can include
a variety of other information, such as the manufacturer of the cargo
and the name of the shipping line.
[End of table]
One of CBP's major efforts to address container security is CSI--a 6-
year-old program that aims to identify and examine U.S.-bound cargo
that is considered to pose a high risk of concealing WMDs or other
terrorist contraband by reviewing advanced cargo information sent by
ocean cargo carriers. As part of the program, CBP officers, usually
stationed at foreign seaports throughout Europe, Asia, the Middle East,
the Americas, or elsewhere, seek to identify high-risk U.S.-bound
container cargo. CBP and host government officials share the role of
assessing the risk of U.S.-bound container cargo leaving the seaports
of the countries participating in CSI. Among other tasks, CBP officers
at the 58 CSI seaports are responsible for identifying high-risk cargo
shipped in containers, whereas host government customs officials
examine the high-risk cargo--when requested by CBP--by scanning
containers that hold the cargo using various types of nonintrusive
inspection equipment, such as large-scale X-ray machines, or by
physically searching the containers' contents before departure to the
United States. Figure 2 describes the activities carried out by CBP
officers and host government customs officials to target and examine
high-risk container cargo at CSI seaports.
Figure 2: CSI Targeting and Examination Activities:
This figure is a combination of text and photographs showing CSI
targeting and examination activities.
Targeting high-risk container shipments.
CBP uses ATS to electronically review data about U.S.-bound shipments
to produce a risk score, a process CBP refers to as screening. CBP
officers review the ATS risk scores and may consider additional
information or collaborate with host government officials to identify
high-risk shipments with a nexus to terrorism—a process referred to as
targeting.CBP officials make a final determination about which
containers are high risk and will be referred to host government
customs officials for examination.
Photo: CBP official conducting targeting activities.
Examining high-risk container shipments. CBP officials request that
host government officials examine containers with high-risk shipments
to detect WMD or other items with a nexus to terrorism. Examining a
container involves using nonintrusive inspection equip-ment, radiation
detection equipment, or both to scan the container’s contents.
Typically, the radiation detection equipment is used, then large scale
nonintrusive inspection equipment, to scan the container’s contents.
The results of the scan will influence whether or not CBP requests that
the host government conduct a physical search, during which a container
is opened and its contents are removed for review.
Photo: Container scanned with non-intrusive imaging x-ray equipment at
a CSI port.
[See PDF for image]
Source: GAO and CBP.
[End of figure]
Another of CBP's major efforts to address container security is through
the C-TPAT program. Initiated in November 2001, C-TPAT aims to secure
the flow of goods bound for the United States by developing a voluntary
antiterrorism partnership with stakeholders of the international trade
community, which is comprised of importers; customs brokers;
forwarders; air, sea, and land carriers; and contract logistic
providers. C-TPAT members commit to improving the security of the
supply chain, which may include, for example, the use of employee
identification systems for access control purposes. The members also
agree to provide CBP with information on their specific security
measures and allow CBP to validate or verify, among other things, that
their security measures meet or exceed the agency's minimum security
requirements. The purpose of this latter step, referred to as
validation, is to help CBP ensure that the security measures outlined
in a member's security profile are actually in place and are effective.
In return, C-TPAT members are entitled to various benefits--chief among
them, a reduced likelihood of having their cargo inspected.
As part of its mission and strategic plan, CBP also seeks to promote
the security of oceangoing containers by having its officers work
closely with other stakeholders, including international customs trade
organizations and host governments (where seaports participating in the
CSI program are located). CBP's former Commissioner has stated that a
key goal of this outreach effort is to promote an international
framework of customs security standards that multiple countries can
agree upon. Such a framework is intended by the United States and other
parties to help institute consistent, reliable customs security
standards and practices. Figure 3 shows a timeline for the various U.S.
security initiatives addressing container cargo security.
Figure 3: Timeline of Major U.S. and International Events to Facilitate
Supply Chain Security:
This figure is a timeline of major U.S. and international events to
facilitate supply chain security.
International: June 1999: Revised Kyoto Convention[A];
United States: September 2001: 9/11 Terrorist attack;
United States: November 2001: C-TRAT (U.S. AEO program) established;
United States: January 2002: CSI program began;
International: June 2005: WCO adopted the SAFE Framework of Standards;
International: January 2006: WCO began capacity building programs;
International: March 2006: Japan's AEO program becomes operational;
United States: October 2006: SAFE Port Act passed;
International: May 2007: Singapore's AEO program becomes operational;
International: June 2007: United States and New Zealand establish
Mutual Recognition of their AEO programs;
United States: August 2007: 9/11 Act required 100% scanning by 2012;
United States: October 2007: Intitiation of Secure Freight Initiative
pilot program;
International: January 2008: EU’s AEO program becomes operational;
United States: June 2008: CBP releases report on SFI pilot program;
International: January 2009: Mutual recognition between United States
and EU AEO programs.
[See PDF for image]
Source: GAO analysis.
[A] The Revised Kyoto Convention is an international customs agreement
signed by 55 countries, including the United States. Signatories pledge
to use risk management to identify high-risk container cargo.
[End of figure]
CBP and Foreign Customs Administrations Have Jointly Developed Global
Customs Security Standards and Initiatives and Work Cooperatively to
Implement These Standards Worldwide:
Working through the WCO and in cooperation with the international
customs community, CBP has taken a lead role in the development of
international standards in customs security practices and in customs-
to-business partnership programs. This effort led to the adoption of
the WCO SAFE Framework, which establishes standards for collaboration
between the customs administrations of different countries as well as
between customs administrations and businesses. CBP has also assisted
in the implementation of the SAFE Framework to promote international
customs security standards, such as through capacity-building efforts
that provide technical assistance and training to developing countries
wanting to implement the SAFE Framework.
CBP Is Working with Foreign Customs Administrations to Develop
International Standards for Customs-to-Customs Relationships and for
Customs-to-Business Partnership Programs:
CBP has taken a lead role in working with foreign customs
administrations on approaches to standardizing supply chain security
worldwide. In 2004, CBP, along with 11 other member customs
administrations of the WCO, formed the High Level Strategic Group to
develop international standards for customs security
practices.[Footnote 12] The group developed the WCO Framework of
Standards to Secure and Facilitate Global Trade (commonly referred to
as the SAFE Framework), the core concepts of which are based on
components in CBP's CSI and C-TPAT programs. Further, CBP's CSI and C-
TPAT programs have provided a model for developing global customs
security standards, as countries adopt a framework that embodies the
core principles of these programs.
The CSI and C-TPAT strategic plans call for promoting an international
framework of customs security standards using the core elements of the
U.S. cargo security strategy.[Footnote 13] As CBP has recognized in
security matters the United States is not self-contained, either in its
problems or its solutions. The growing interdependence of countries
requires policy makers to recognize the need to work in partnerships
across international boundaries to achieve vital national goals.
Further, the WCO has acknowledged that customs security enforcement,
particularly with the threat of terrorism, cannot be done in isolation
and requires international cooperation. To that end, CBP has taken a
lead role in working with foreign customs administrations, through the
WCO, to establish the framework of international standards designed to
enhance the security of the global supply chain while facilitating
international trade. In June 2005, the 173 member customs
administrations of the WCO adopted the SAFE Framework. Further, as of
June 2008, 154 WCO member countries, including the United States, had
signed letters of intent for implementing the SAFE Framework[Footnote
14] (see fig. 4).
Figure 4: World Map Indicating the 154 WCO Member Countries That Have
Signed Letters of Intent to Implement the WCO SAFE Framework:
This figure is a world map indicating the 154 WCO member countries that
have signed letters of intent to implement the WCO SAFE Framework.
[See PDF for image]
Source: GAO (map art), WCO (data)
[End of figure]
The SAFE Framework establishes the standards for collaboration between
the customs administrations of different countries (known as the
customs-to-customs pillar) as well as between customs administrations
and the businesses participating in commercial trade activities through
various supply chains (known as the customs-to-business pillar). These
standards provide guidance on what WCO member customs administrations
must do at a minimum to both secure the international supply chain and
facilitate trade. As seen in figure 5, the twin pillars of the customs-
to-customs standards and the customs-to-business standards are based
upon four core principles and underpin the SAFE Framework.
Figure 5: The Twin Pillars of Customs-to-Customs Network Arrangements
and Customs-to-Business Partnership Programs Based on the Four Core
Principles of the WCO SAFE Framework of Standards:
This figure is an illustration showing the twin pillars of customs-to-
customs network arrangements and customs-to-business partnership
programs based on the four core principles of the WCO SAFE framework of
standards.
[See PDF for image]
Source: GAO representation of WCO data and Art Explosion images.
Note: Appendix II describes the 11 standards of the customs-to-customs
pillar and the 6 standards of the customs-to-business pillar.
[End of figure]
The standards and principles of the SAFE Framework are similar to those
of the CSI and C-TPAT programs. For example, just as in the CSI
program, the standards in the customs-to-customs pillar state that
members should use a risk-management system to target and identify
potentially high-risk cargo. Under these standards, members should also
require advanced electronic information on container shipments to
determine the risk posed by cargo. Further, member customs
administrations should provide for joint targeting and screening, the
use of standardized sets of targeting criteria, and compatible
communication and information-exchange mechanisms. The customs-to-
business pillar of the SAFE Framework incorporates the concept of the
Authorized Economic Operator (AEO) and provides technical guidance for
customs administrations to develop an AEO program that offers
incentives to supply chain companies that comply with predetermined
minimum security standards.[Footnote 15] In the United States, C-TPAT
is the designated AEO program (and businesses participating in the
program are Authorized Economic Operators). Just as in the C-TPAT
program, the WCO customs-to-business pillar provides that the customs
administration should, with representatives from the trade community,
design a validation process for the respective AEO program that offers
incentives to participating businesses. Further, the technical guidance
for AEO programs states that participating businesses should develop
mechanisms for the education and training of personnel regarding
security practices. In essence, the SAFE Framework internationalizes
the core principles of the CSI and C-TPAT programs.
According to the WCO, SAFE Framework stakeholders receive benefits from
incorporating the core principles of the framework and implementing the
standards. CBP officials stated that widespread implementation of the
SAFE Framework benefits global container cargo security by shifting the
focus of international customs administrations from primarily revenue
collection to include enhanced security. Further, the SAFE Framework
strengthens cooperation between customs administrations to improve
their capability to detect high-risk cargo. Additionally, widespread
implementation of the SAFE Framework could potentially help prevent
port shopping by terrorists or smugglers who look for seaports with
more lax or nonexistent security standards. According to CBP and WCO
officials, implementation of the SAFE Framework could benefit WCO
member countries by enhancing security, speeding up operations,
increasing revenue collection, and improving integrity programs for
ensuring that customs administrations are free of corruption. The
officials also noted that the SAFE Framework could lead to
implementation of CSI-like customs security practices at non-CSI
foreign seaports and enhance customs administration reform and
modernization, which could improve the ability to detect high-risk
cargo for antiterrorist security purposes. According to the WCO, the
broad implementation of the standards also could allow companies to
avoid the unnecessary burden of addressing different sets of
requirements as a shipment moves through the supply chain logistics in
different countries. Moreover, as we have previously reported, creating
common standards facilitates collaboration between entities.[Footnote
16]
Multiple Initiatives Are Under Way to Implement Elements of the SAFE
Framework and to Promote Global Customs Security Standards:
Working with the WCO and other international partners, CBP has taken
several steps to support implementation of the SAFE Framework and to
promote a customs environment that focuses on security. To help
implement the SAFE Framework, CBP, along with the customs
administrations of other countries, participates in a capacity-building
program, known as the Columbus Program, which is coordinated through
the WCO and fosters customs administration modernization in developing
countries. Capacity-building activities consist of technical assistance
and training, which lead to the establishment of infrastructure and
procedures that are consistent with the objectives of the SAFE
Framework standards. Capacity building consists of three phases: needs
assessment, implementation, and monitoring. The first phase (needs
assessment) provides an evaluation of a developing country's current
capacity and existing gaps that would prevent it from implementing the
SAFE Framework. The second phase (implementation) involves support from
the assisting country to put into action recommendations derived from
the needs assessment. Finally, the third phase involves monitoring the
modernization practices put in place in phase two. According to the
WCO, as of April 2008, 111 countries were participating in the capacity-
building program. As of July 2008, 104 of these countries had completed
the first phase, 65 had moved into the second phase, and one was in the
third phase. To carry out capacity- building activities, the WCO relies
on contributions from individual donor countries like the United
States. As a participating customs administration, CBP has provided
training and assistance to 10 countries in the capacity-building
program by developing customs regimes in these countries that
incorporate the core elements of U.S. supply chain security programs,
and thus the SAFE Framework. CBP has provided border enforcement
training, integrity awareness training, and an advisory program.
Additionally, CBP works with Asia-Pacific Economic Cooperation (APEC)
member countries to help implement the WCO SAFE Framework through
APEC's Framework for Secure Trade, which, according to CBP, is
substantially identical to the WCO SAFE Framework.[Footnote 17] The
APEC Framework enables member countries to advocate the implementation
of the WCO SAFE Framework in non-WCO customs administrations, such as
Taiwan.
In addition to working collaboratively with the international community
to develop and implement the SAFE Framework, CBP has influenced the
development of customs security practices in other countries through
its own cargo security strategy. According to European customs
administration officials we spoke to, the CSI program is beneficial
because it provides a model for how to incorporate elements of the SAFE
Framework, including targeting and the use of advance information, into
their own customs practices. For example, the European Union recently
amended its customs code to incorporate programs similar to CSI and C-
TPAT.[Footnote 18] To further promote international supply chain
security, since 2004, CBP has held an annual CSI global conference to
share information on challenges met and best practices for customs
operations. For example, in the August 2007 conference, two sessions
specifically focused on challenges encountered with capacity building
and on best practices for CSI seaport operations. Additionally, the
conference provided a forum for senior-level customs officials from all
CSI countries to establish working relationships with one another and
discuss future policy actions.
Just as the CSI program has influenced the ability of foreign customs
administrations to target and examine high-risk containers in other
countries, the C-TPAT program has helped influence the development of
AEO programs. According to CBP officials as well as customs officials
from Europe, Asia and Africa, operation of the C-TPAT program has
provided a guide on how these programs should be operated. According to
data from the WCO, about 70 countries have begun developing their own
national AEO programs, which is essential to implementation of the SAFE
Framework. Canada, Japan, Jordan, New Zealand, and Singapore have
operational AEO programs in place. Other countries, such as Australia
and some European Union nations will soon have operational systems in
place. Further, through the WCO capacity-building program, several
countries in the developing world have begun work on AEO pilots. For
example, the East African Community--a regional intergovernmental
organization made up of Burundi, Kenya, Rwanda, Tanzania, and Uganda--
has started a program based on the SAFE Framework, which used the C-
TPAT program as a model. Similarly, the Southern African Customs Union-
-made up of Botswana, Lesotho, Namibia, South Africa, and Swaziland--
has also begun work on developing a pilot AEO program. Panama and
Paraguay are considering AEO pilots as well.
CBP and International Partners Are Working to Achieve Mutual
Recognition of Customs Security Practices:
The SAFE Framework calls for a system of mutual recognition, and CBP
has developed action plans and pilot programs to help develop mutual
recognition relationships with other countries. There are two types of
mutual recognition--first, the arrangement whereby the actions or
decisions taken by one customs administration are recognized and
accepted another administration and, second, an arrangement whereby the
two nations' AEO programs are mutually recognized by the respective
customs administrations.[Footnote 19] CBP and other international
customs officials see mutual recognition as providing an exit strategy
for the CSI program (which includes reassigning or repatriating CBP
officers stationed abroad) in some countries, as well as being a driver
for further implementation of AEO programs. Finally, CBP engages in
activities to assist in the development of a system of mutual
recognition, such as pilot programs, and in June 2007, CBP signed a
mutual recognition arrangement with New Zealand--the first ever such
arrangement in the world--to recognize each other's customs-to-business
partnership programs.
CBP and International Organizations Have Defined Different Types of
Mutual Recognition:
CBP has worked with the international customs community to develop and
implement the SAFE Framework, a set of international customs standards
that calls for a system of mutual recognition, which the CBP and the
WCO define as the arrangement whereby the actions or decisions taken by
the customs administration of one country are recognized and accepted
by the administration of another. Further, according to the WCO, for a
system of mutual recognition to work, there must be an agreed-upon
common set of standards that are applied in a uniform manner so that a
level of confidence is possible between different customs
administrations. The WCO distinguishes between mutual recognition of
customs controls and mutual recognition of AEO programs, as described
below and illustrated in figure 6.
* Mutual recognition of customs controls is achieved when, for example,
the customs administrations of two countries have confidence in each
other's procedures for targeting and inspecting cargo shipped in
containers. According to the WCO, such mutual recognition could be
achieved through joint targeting and screening, the use of standardized
sets of criteria for identifying high-risk cargo for inspection, and
compatible communication and information-exchange mechanisms.
* Mutual recognition of AEO programs occurs when customs
administrations agree to recognize one another's AEO programs and
security features and to provide comparable benefits to members of the
respective programs.
Figure 6: Two Forms of Mutual Recognition:
This figure is an illustration of two forms of mutual recognition.
[See PDF for image]
Source: GAO analysis and Art Explosion images.
[End of figure]
The SAFE Framework states that members should work with each other to
develop mechanisms for mutual recognition of customs controls and of
AEO programs.
While CBP officials stated that the agency accepts the WCO definition
of mutual recognition, CBP focuses its efforts and offers a process for
achieving mutual recognition of AEO programs. CBP does not offer
specific guidance on how to achieve mutual recognition of customs
controls because officials believe that mutual recognition of AEO
programs, such as the United States' C-TPAT program and New Zealand's
AEO program, called the Secure Export Scheme, implies mutual
recognition of customs controls. This is because, when obtaining
information on a foreign country's AEO program, CBP officials also
review the targeting and customs practices of that country. Therefore,
according to CBP, there is no need for additional guidance or efforts
with regard to mutual recognition of customs controls. However, an
official from the WCO Private Sector Consultative Group (consisting of
trade community partners from diverse industry and transport sectors)
stated that there needs to be more clarity between the two types of
mutual recognition and the benefits associated with each. CBP and WCO
officials have stated that achieving mutual recognition of customs
controls presents a challenge to customs administrations and may not be
easily or quickly attained. According to those officials, this is
because full recognition and adoption of the SAFE Framework does not by
itself provide countries with confidence in each other's customs
security practices and thus mutual recognition.
CBP and International Officials See Mutual Recognition as an Exit
Strategy for the CSI Program in Some Countries and a Catalyst for
Implementation of AEO Programs:
CBP and European customs officials we spoke with see the benefit of
mutual recognition as providing an exit strategy for the CSI program in
some countries and being a catalyst for further implementation of AEO
programs. CBP officials have stated that it was never the intention of
the agency to keep CBP officers in foreign seaports under the CSI
program indefinitely, but that a certain level of trust about the
security practices of the customs administration of a foreign country
and a common set of standards (i.e., mutual recognition) would be
needed before CBP personnel at CSI seaports could be shifted to areas
of greater need.
While the CSI program constitutes an effort to implement the SAFE
Framework, it differs from the SAFE Framework in that it is a
reciprocal program. The SAFE Framework calls for a system of mutual
recognition between the customs administrations of two countries,
whereas CSI requires CBP officers to be placed in foreign ports, and in
return for accepting the CSI program in a foreign country, the United
States offers host countries the opportunity to place their customs
officers in U.S. seaports to target oceangoing, containerized cargo
being exported to their countries. However, when partner countries do
not place their customs officers in a U.S. seaport, the CSI program
focuses on identifying high-risk U.S.-bound containers at the CSI
seaports (i.e., U.S. imports) and not on those containers outbound from
the United States to foreign countries (i.e., U.S. exports).
Alternatively, under a system of mutual recognition, in which
comparable risk management principles are used, joint activities such
as identifying cargo for inspection and cooperation between customs
administrations would not require the placement of customs officials in
foreign seaports. Further, the SAFE Framework requires that all
countries inspect outbound high-risk containers at the request of the
importing country if such a request is deemed to be reasonable. While
the CSI program offers participating countries the ability to station
their customs officials in U.S. seaports, 2 of the 33 countries
participating in CSI--Canada and Japan--had decided to do so as of July
2008. Thus, the program primarily benefits U.S. security. European
customs administration officials we spoke to stated that if all
countries practiced reciprocity, as envisioned in the CSI program, each
seaport would have numerous customs officials present from different
countries, which is an inefficient use of resources. Alternatively,
they said that implementation of a system of mutual recognition whereby
customs officials in the United States have confidence that the customs
controls and AEO programs of another country provided an acceptable
level of security would be a more efficient use of limited resources.
CBP and customs officials we spoke to from Asia, Europe, and the South
Pacific support mutual recognition of AEO programs. The WCO and
industry representatives have stated that mutual recognition is an
important benefit of AEO programs and will be the driving force behind
further implementation of such programs internationally. Further, these
officials stated that, in the absence of mutual recognition, there is
little incentive for private companies to join AEO programs and,
therefore, countries may not adopt this risk-management approach.
Conversely, mutual-recognition systems provide some assurance that
joining an AEO program could provide benefits across countries.
According to CBP and the WCO, mutual recognition of AEO programs could
reduce the need for multiple assessments of private sector supply chain
firms by the customs administrations of different countries and could
generate benefits for both industry and government--benefits that
include faster clearances, reduced examinations, and rapid business
resumption in the aftermath of a terrorist event.
CBP Has Engaged in Activities to Achieve Mutual Recognition with
International Partners:
CBP has been working to promote the SAFE Framework and engaging in
pilot programs with foreign governments to harmonize customs efforts
and to facilitate progress towards mutual recognition. For example, CBP
is working with the European Commission--the executive arm of the EU--
to standardize customs practices across countries to be consistent with
the SAFE Framework. CBP and the European Commission's Taxation and
Customs Union Directorate, working through the Joint Customs
Cooperation Committee, developed a 10-point action plan to further
harmonize the customs efforts of the United States and the European
Union.[Footnote 20] This action plan includes the establishment of
common data elements to be used for risk determination and a mechanism
for the exchange of information, both of which are suggested by the
SAFE Framework to assist in the development of mutual recognition of
customs controls. The action plan also calls for a pilot to compare the
United States' C-TPAT program with the European Union's AEO program for
the purpose of achieving mutual recognition between the respective
programs.[Footnote 21] Based on the 10-point action plan, CBP and the
European Commission are also conducting a CSI pilot involving low-
volume European seaports, known as the feeder port pilot
program.[Footnote 22] Under the pilot, local customs officials at the
feeder ports work with CBP officers located at CSI seaports to assess
the risk and jointly determine whether the U.S.-bound container cargo
originating in these feeder ports should receive further scrutiny.
Local customs officials at the feeder seaports then inspect those U.S.-
bound containers determined to be high risk before they are loaded on
vessels at the feeder port. According to EU officials, the aim of
coordinating on the efforts included in the 10-point action plan is to
reduce the number of requirements that differ between European
countries and the United States. Once these efforts are finalized, the
EU intends to expand the projects to include other international
partners. Table 2 describes elements of the 10-point action plan.
Table 2: U.S.-EU Joint Customs Cooperation Committee Action Plan as of
June 2008:
Action item and description: Conduct a transshipment pilot program -
Pilot program to test security of and accuracy of information on
transshipped cargo containers between the United States and the EU.[A];
Status: Completed in 2006.
Action item and description: Develop a joint risk rules set -
Establishment of U.S.-EU joint rules set for container security to
allow for shared identification of security threats;
Status: Ongoing. CBP and the EU completed the draft rules set in 2006.
Beginning in April 2008, EU Officers were stationed at the National
Targeting Center-Cargo and have refined this draft rules set. The
updated rules set is currently being programmed within CBP's Automated
Targeting System-International for testing.
Action item and description: Establish minimum control standards -
Establishment of control standards for the handling of high-risk
containers suspected of containing terrorist-related materials;
Status: Completed. Minimum control standards jointly agreed to under
the JCCC.
Action item and description: Develop a common list of advanced cargo
data elements - Creation of a common list of cargo data elements that
should be submitted in advance;
Status: Completed in 2007.
Action item and description: Exchange information - Establishment of an
exchange of information between the United States and the EU using the
EU's secure Web site;
Status: Completed 2007. CBP and the EU continue to exchange information
through various mechanisms in accordance with the U.S.-EU Customs
Mutual Assistance Agreement.
Action item and description: Conduct mutual recognition pilot of C-TPAT
and EU AEO programs - Explore the feasibility of establishing mutual
recognition between United States and EU customs-to-business
partnership programs (C-TPAT and Authorized Economic Operator);
Status: A joint U.S./EU roadmap towards mutual recognition was adopted
on March 6, 2008. CBP and the European Commission will work to
implement the roadmap and achieve mutual recognition of C-TPAT and the
EU AEO in 2009.
Action item and description: Conduct a CSI feeder port pilot[B] - Pilot
program to expand the reach of CSI by identifying the risk level of
containers in feeder seaports at neighboring CSI seaports and having
the examination, if needed, take place at the feeder port;
Status: A 6-month pilot project was conducted at the Port of Szczecin,
Poland, from March 2007 to September 2007. An evaluation of the pilot
has been completed. In April 2008 the 6-month pilot commenced in the
port of Aarhus, Denmark. A pilot with Salerno, Italy, is to begin in
July 2008 and will also run for 6 months. Once all three pilots have
been completed, further analysis will be conducted.
Action item and description: Conduct a joint threat assessment - The
assessment summarizes the historical uses of weapons of mass effect as
well as the present threat of such weapons to supply chain
security.[C];
Status: The joint threat assessment has been completed, although the
United States and EU have agreed to an annual update. The update for
2008 was drafted and agreed to at the JCCC meeting in March 2008.
Action item and description: Station EU liaison officers at CBP's
National Targeting Center-Cargo in Herndon, Va. - Is to provide for the
stationing of EU Liaison officers at the National Targeting Center-
Cargo to serve as point of contact with the EU and study centralized
targeting operations.[D];
Status: In order to provide an opportunity to gain an understanding of
the work environment at the National Targeting Center-Cargo, EU customs
officials were stationed at the center in April 2008. The first two (of
a total of six) EU Officers were stationed at the NTC-C on April 14,
2008. The Officers have been working with CBP subject matter experts
and rules developers to finalize and test the joint rules set as well
as participating in various exchanges on topics of mutual interest. The
next set of two representatives will deploy to the NTC-C on July 14,
2008.
Action item and description: Explore research and development Issues -
Continuously explores areas for cooperation in the research and
development field;
Status: CBP and EU have agreed to keep one another abreast of ongoing
research and development efforts and are exploring possible areas for
cooperation.
Source: U.S. Customs and Border Protection and European Commission's
Taxation and Customs Union Directorate.
[A] Transshipment cargo containers are those that are unloaded from one
ship to a seaport for a short period of time before being loaded onto
another ship.
[B] The JCCC Action Plan originally called this action item "Minimum
Requirement for Container Security Initiative." It later evolved into
the feeder port pilot program.
[C] Weapons of mass effect are weapons capable of inflicting grave
destructive, psychological, and/or economic damage. These include
chemical, biological, nuclear, radiological, or explosive weapons.
[D] The mission of the National Targeting Center-Cargo is to support
CBP's cargo targeting operations. According to CBP, the center was
established in response to the need for proactive targeting aimed at
preventing acts of terror and to seize, deter, and disrupt terrorists
and implements of terror.
[End of table]
European Commission officials we spoke with stated that activities
undertaken with CBP under the action plan are for the purpose of
harmonizing customs efforts and facilitating progress toward achieving
mutual recognition of customs controls. For example, the feeder port
project is seen as a step toward mutual recognition as containers are
examined at the feeder port with no CBP officers present. According to
officials from the European Commission and other European customs
officials, with the establishment of these common security practices, a
state of mutual recognition of customs controls between the European
Union and the United States would exist, and there would no longer be a
need to have CBP personnel stationed at European seaports as part of
the CSI program. However, both European Commission and CBP officials
stated that several hurdles exist before personnel could be removed
from these seaports, such as verification of inspection and targeting
programs and activities.
In addition to the European Union, CBP has been pursuing mutual
recognition of AEO programs with those countries that have developed
programs. For example, in June 2007, CBP entered into its first mutual
recognition arrangement--that is, CBP and the New Zealand Customs
Service mutually recognized each other's respective customs-to-
business partnership program. Under the arrangement, CBP recognizes
members of New Zealand's AEO program (the Secure Export Scheme) and
provides benefits to New Zealand companies validated by the Secure
Export Scheme similar to those of C-TPAT members and vice versa.
According to a senior New Zealand customs official, requirements for
membership and validation in the nation's Secure Export Scheme program
have been adapted from the United States' C-TPAT program. CBP later
signed mutual recognition arrangements with Jordan and Canada in June
2008. Further, CBP and the European Commission have agreed to establish
mutual recognition of customs-to-business partnership programs by early
2009. The specific details of how the participating countries' customs
administrations plan to implement the mutual recognition arrangement--
such as what benefits, if any, should be allotted to members of other
countries' AEO programs--are in the process of being worked out.
Finally, CBP is also negotiating with Japan and Singapore to establish
mutual recognition arrangements with the industry partnership programs
of those countries.
To that end, CBP has developed an approach to achieving mutual
recognition of AEO programs with international partners. Prior to
pursuing mutual recognition, these partners must have (1) submitted a
letter of intent to the WCO to implement the SAFE Framework, (2)
developed their own AEO program to enhance security, and (3) shown a
willingness to commit to a four-phase mutual recognition process. The
four phases are:
* phase 1: an evaluation process that includes a comparison of both
nations' programs to determine the similarities, differences, gaps, and
challenges;
* phase 2: an operational planning and testing phase to determine the
specific approach to how mutual recognition will be achieved, including
the development of a pilot program;
* phase 3: conducting the pilot that was developed in phase two; and:
* phase 4: declaration of mutual recognition.
Appendix III provides an overview of CBP's collaborative efforts to
enhance container security.
While Working to Internationalize Customs Security Standards, CBP and
International Partners Report Challenges in Balancing These Efforts
with Other Legal Requirements:
CBP has been actively engaged in the development and implementation of
international customs security standards; however, recent laws
requiring 100 percent scanning of U.S.-bound container cargo at foreign
seaports may affect worldwide adoption of these standards. As required
by the SAFE Port Act, CBP is currently testing the feasibility of 100
percent scanning in a pilot program; and, while CBP has not yet
completed the pilot program, the 9/11 Act requires 100 percent scanning
of all U.S.-bound container cargo by 2012, with possible extensions for
individual seaports where specified conditions could hinder
implementation. CBP and international partners also report facing
challenges in implementing a 100 percent scanning requirement while
also maintaining their risk-management security approach.
Recent Law to Improve Maritime Security Imposes New Requirements to
Scan 100 Percent of U.S.-Bound Container Cargo:
The SAFE Port Act of 2006 requires DHS to test the feasibility of 100
percent scanning of U.S.-bound containers. To fulfill this requirement,
in December 2006, CBP and DOE jointly announced the formation of the
Secure Freight Initiative. This initiative included the SFI pilot
program, which became operational in October 2007. For more details on
SFI, see appendix IV. While the SFI pilot project is still under way,
the 9/11 Act was enacted. The act requires by 2012 100 percent scanning
of all U.S.-bound container cargo using nonintrusive inspection
equipment, including imaging equipment, which may use X-rays or gamma
rays to create images of the containers' contents and radiation
detection equipment at foreign seaports. The act also (1) specifies
conditions for potential extensions beyond 2012 if a seaport cannot
meet that deadline,[Footnote 23] (2) requires DHS to develop
technological and operational standards for scanning systems used to
conduct 100 percent scanning at foreign seaports, and (3) requires DHS
to ensure that actions taken under these provisions of the act do not
violate international trade obligations and are consistent with the WCO
SAFE framework or other international obligations of the United States.
These provisions of the 9/11 Act replace requirements of the SAFE Port
Act that called for 100 percent scanning of container cargo before its
arrival in the United States. While the SAFE Port Act stated that this
should be done as soon as possible, the 9/11 Act specifies a deadline
of 2012. According to senior CBP officials, requiring 100 percent
scanning before having the results of the SFI pilot compromises the
credibility of the agency with its international partners because those
countries that agreed to partner with CBP on the SFI pilot did so with
the understanding that the findings would drive further discussions
regarding a logical path forward.
While we have not yet fully reviewed the implementation of the 100
percent scanning requirement, we have a number of preliminary
observations based on visits to foreign seaports and on discussions
with officials from CBP, foreign customs administrations, and trade
organizations regarding potential challenges CBP and others may face in
implementing this requirement. We also testified in June 2008 on
challenges associated with implementing the 100 percent scanning
requirement.[Footnote 24]
CBP and International Partners Report Facing Challenges in Balancing
the 100 Percent Scanning Requirement with Current International Risk-
Management Security Practices, and Concerns Remain regarding the Impact
on Resources, Trade, and Security:
CBP may have difficulty implementing a 100 percent scanning requirement
while also maintaining a risk-management security approach that it has
developed with many international partners. Currently, under the CSI
program, CBP uses automated targeting tools to identify containers that
pose a risk for terrorism for further examination before being placed
on vessels bound for the United States. As we have previously reported,
risk management reduces of the risk of possible terrorist attack to the
nation by allocating resources to those areas of greatest risk and is
an approach accepted throughout the federal government.[Footnote 25]
Further, international partners have expressed to DHS and Congress that
100 percent scanning runs counter to the SAFE Framework, which is based
on risk-management principles. WCO officials are concerned that 100
percent scanning could have an adverse impact on several of the
organization's core instruments, which include not only the SAFE
Framework but also the Revised Kyoto Convention--an international
customs agreement to which the European Commission, the United States,
and 52 other nations, have acceded.[Footnote 26] Moreover, CBP and WCO
officials stated that some countries are reluctant to implement AEO
programs since they believe such programs would not be necessary with
100 percent scanning. Industry officials also stated that some
companies are reluctant to join AEO programs since one of the main
benefits of membership, a reduced likelihood of examination, would no
longer apply with 100 percent scanning.
CBP's international partners have raised concerns about the impact on
resources, security, and the flow of commerce should the 100 percent
scanning requirement take effect. As we testified in June 2008,
additional resources--including increased staff, equipment, and
infrastructure--would be necessary for implementing 100 percent
scanning of U.S.-bound container cargo at foreign seaports, and it is
unclear who would be responsible for the costs. Given this situation,
officials from the European Commission and CBP stated that unless
additional resources are made available, 100 percent scanning could not
be accomplished. According to officials from CBP, WCO, and the European
Commission, 100 percent scanning may actually provide a lower level of
security than the current method of targeting and examination using
risk-management methods. Officials from CBP and the European Commission
stated that the risk-management approach directs resources to where
they are most needed, whereas scanning 100 percent of containers is
inefficient because it directs too many resources to one activity--
scanning--and diminishes the focus on those container shipments that
pose the highest risk. According to a senior WCO official, under the
current risk-management system, customs officers review the scanned
images of high-risk containers in a very thorough and detailed manner.
However, if the officers must review scanned images of all containers,
the reviews may not be as thorough because the officers could lose
focus due to the sheer volume of work. If more officers are not
assigned, scanned images may not be properly or thoroughly analyzed,
leading to a degradation of security. Further, a European customs
administration official reported that 100 percent scanning could have a
negative impact on the flow of international commerce, which under the
9/11 Act may be grounds for granting a 2-year, renewable extension to
the 100 percent scanning requirement at individual seaports. The
official also added that the 100 percent scanning requirement would
disproportionately affect trade with developing countries.
Concluding Observations:
In large part because of the collaborative international efforts in
which CBP has taken a lead role, the global customs environment for
ensuring supply chain security is significantly transforming. CBP is
working in the international community actively and conscientiously to
promote the adoption and implementation of global security standards
for customs controls and for the adoption of AEO programs. Further, CBP
has promoted a vision of mutual recognition whereby countries can have
confidence in their respective customs security practices. To date, CBP
has made substantial progress in working with foreign governments to
develop and implement security practices based on components of CBP's
CSI and C-TPAT programs. These efforts potentially point to an exit
strategy for the CSI program in some countries and the generally more
efficient use of all countries' resources through cooperative
international relationships from the public and private sectors.
The transformation of customs security strategies from inward-looking
programs to outward-looking and internationally cooperative
relationships is in its early stages. While CBP has made progress
developing global security initiatives, the agency faces challenges
that may make it difficult to promote widespread adoption of a system
of internationally accepted customs security standards and mutual
recognition. In particular, significant challenges are posed by
prospective implementation of the statutory provision that calls for
100 percent scanning of U.S.-bound container cargo at foreign seaports.
Because of cost and logistical concerns, this provision may dissuade
foreign governments and businesses from participating in risk-
management security initiatives such as the CSI or C-TPAT programs as
well as discourage other nations from developing their own AEO
programs.
Agency Comments:
We provided a draft of this report to the Department of Homeland
Security and the Department of State for review and comment. The
Department of Homeland Security provided technical comments, which we
incorporated in this report where appropriate. The Department of State
did not provide comments.
We are sending copies of this report to appropriate congressional
committees, the Secretary of Homeland Security, and the Secretary of
State. This report will also be available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-9610 or caldwells@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. Key contributors to this report are
listed in appendix V.
Signed by:
Stephen L. Caldwell:
Director, Homeland Security and Justice Issues:
List of Requesters:
The Honorable Daniel K. Inouye:
Chairman:
Committee on Commerce, Science, and Transportation:
United States Senate:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Carl Levin:
Chairman:
The Honorable Norm Coleman:
Ranking Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable John D. Dingell:
Chairman:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Ted Stevens:
United States Senate:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Objectives:
In response to a request from the Chairman and Vice Chairman, Senate
Committee on Commerce, Science, and Transportation; the Chairman and
Ranking Member, Senate Committee on Homeland Security and Governmental
Affairs; the Chairman and Ranking Member, Permanent Subcommittee on
Investigations of the Senate Committee on Homeland Security and
Governmental Affairs; and the Chairman, House Committee on Energy and
Commerce, we reviewed U.S. Customs and Border Protection's (CBP)
programs--the Container Security Initiative (CSI) program and the
Customs-Trade Partnership Against Terrorism (C-TPAT) program--and CBP's
efforts to promote international supply chain security standards. For
this report, our review focused on the following questions regarding
CBP's efforts to promote and implement an international framework of
standards for supply chain security:
* What actions has CBP taken to develop and implement international
supply chain security standards?
* What actions has CBP taken with international partners to achieve
mutual recognition of customs security practices?
* What issues do CBP and foreign customs administrations working to
internationalize customs security standards anticipate in implementing
100 percent scanning of U.S.-bound container cargo?
Scope and Methodology:
In reviewing CBP's CSI program, C-TPAT program, and international
initiatives in supply chain security, we are releasing three reports--
one on the CSI program issued in January 2008, one on the C-TPAT
program issued in April 2008, and this report on CBP's international
supply chain security initiatives. [Footnote 27] We conducted this
performance audit in conjunction with concurrent reviews of the CSI and
C-TPAT programs from May 2006 to July 2008. To determine what actions
CBP has taken and its role in developing and implementing international
supply chain security standards, we met with officials at CBP's Office
of International Affairs and Trade Relations and the Office of Field
Operations to discuss the issues within the scope of this review. We
reviewed the strategic plans of the CSI and C-TPAT programs. We also
reviewed CBP documents related to its participation in capacity-
building efforts. Further, we attended CBP's 2007 CSI Global Targeters
Conference that took place in Arlington, Virginia, from August 28 to
30, 2007. The conference brought together, among others, foreign
customs officials from participating CSI countries and CBP officials
stationed at CSI seaports and from headquarters and provided a forum
for sharing challenges met and best practices for CSI country
participants. At the conference, we gathered information and spoke with
officials involved in many aspects of the international customs arena.
To determine CBP's role in the development of the World Customs
Organization's (WCO) SAFE Framework of Standards to Secure and
Facilitate Global Trade (more commonly referred to as the SAFE
Framework), we reviewed the meeting minutes and reports from the WCO's
High Level Strategic Group, the group tasked with developing the
principles and standards of the SAFE Framework. These meeting notes
helped us determine CBP's participation in the development of these
standards. We also reviewed the SAFE Framework itself. Additionally, we
spoke with WCO officials in Brussels. We reviewed WCO documents related
to capacity-building efforts and progress towards implementation of the
SAFE Framework.
We also visited 6 of the 58 CSI seaports. CSI seaports operate in 33
countries, and we selected these six CSI seaports based on geographic
and strategic significance, container volume to the United States from
the seaports, when the seaports began conducting CSI operations, and
whether the seaport was involved in CBP's Secure Freight Initiative.
The results from our visits to seaports provided examples of CBP and
host government operations but cannot be generalized beyond the
seaports visited because we did not use statistical sampling techniques
in selecting the seaports.
We also spoke with the European and Asian customs officials in foreign
embassies in Washington, D.C. Further, we spoke with foreign customs
officers stationed at the Port of Long Beach, California, as part of
the reciprocal agreement of the CSI program. While the perspectives of
foreign officials we spoke to cannot be generalized across the wider
population of countries, they provided us an overall understanding of
how CBP interacts with foreign customs officials at overseas seaports.
To determine CBP's role in implementing the SAFE Framework in the Asian-
Pacific region, we reviewed meeting reports from the Asia-Pacific
Economic Cooperation's Subcommittee on Customs Procedures.
Regarding the second and third questions--that is, CBP's efforts in
achieving mutual recognition of customs practices and business
partnership programs and the challenges CBP faces as it moves forward
with its international supply chain security initiatives--we spoke with
the European Union's European Commission officials in the United States
and with the European Commission's Taxation and Customs Union
Directorate and the Transportation and Energy Directorate, both located
in Brussels, Belgium. We reviewed meeting notes and reports from the
U.S.-EU Joint Customs Cooperation Committee and official agreements
between the United States and the EU. We also spoke with officials from
the customs administration of New Zealand, the first country with which
the United States has a mutual recognition arrangement, and reviewed
the official arrangement between the two countries. We further reviewed
official documents from CBP and the WCO regarding mutual recognition.
We attended the WCO World Customs Forum 2007, an international
conference on the SAFE Framework that took place at WCO headquarters in
Brussels, Belgium, on December 11 and 12, 2007. The forum provided a
critical implementation review of the SAFE Framework, including the
development of customs-to-business partnership programs, mutual
recognition efforts, and obstacles preventing widespread implementation
of international standards and programs. It also brought together
recognized experts in global trade, supply chain security,
international trade law, and customs procedures. We also spoke with
members of industry organizations including CBP's Departmental Advisory
Committee on Commercial Operations and the Federation of European
Private Port Operators.[Footnote 28] Additionally, we spoke with the
private terminal operators at the six CSI seaports we visited as well
as with officials from the port authorities. At the CSI seaports, we
interviewed host government officials and observed conditions at the
seaports regarding the scanning of containers. Finally, we reviewed
recent U.S. legislation dealing with maritime security, in particular
the Security and Accountability for Every Port Act of 2006 and the
Implementing Recommendations of the 9/11 Commission Act of 2007.
We conducted this performance audit from May 2006 through July 2008 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.
[End of section]
Appendix II: World Customs Organization SAFE Framework of Standards:
The World Customs Organization Framework of Standards to Secure and
Facilitate Global Trade (SAFE Framework) is built on the twin pillars
of the customs-to-customs network arrangements and the customs-to-
business partnerships. Table 3 describes the 11 standards that govern
the interaction between the customs administrations of different
countries in the customs-to-customs pillar, and table 4 describes the 6
standards that govern the interactions between a customs administration
and the businesses participating in commercial trade activities through
various supply chains in the customs-to-business pillar.
Table 3: WCO SAFE Framework--Standards for the Customs-to-Customs
Pillar:
Standard: 1;
Title: Integrated Supply Chain Management;
Description: The Customs administration should follow integrated
customs controls procedures as outlined in the WCO Customs Guidelines
on Integrated Supply Chain Management.
Standard: 2;
Title: Cargo Inspection Authority;
Description: The customs administration should have the authority to
inspect cargo originating, exiting, transiting (including remaining on
board), or being transshipped through a country.
Standard: 3;
Title: Modern Technology Inspection Equipment;
Description: Nonintrusive inspection equipment and radiation detection
equipment should be available and used for conducting inspections,
where available and in accordance with risk assessment. This equipment
is necessary to inspect high-risk containers or cargo quickly, without
disrupting the flow of legitimate trade.
Standard: 4;
Title: Risk-Management Systems;
Description: The customs administration should establish a risk-
management system to identify potentially high-risk shipments and
automate that system. The system should include a mechanism for
validating threat assessments and targeting decisions and identifying
best practices.
Standard: 5;
Title: High-Risk Cargo or Container;
Description: High- risk cargo and container shipments are those for
which there is inadequate information to deem shipments as low risk,
that tactical intelligence indicates as high risk, or that a risk-
scoring assessment methodology based on security-related data elements
identifies the shipment as high risk.
Standard: 6;
Title: Advance Electronic Information;
Description: The customs administration should require advance
electronic information on cargo and container shipments in time for
adequate risk assessment to take place.
Standard: 7;
Title: Targeting and Communication;
Description: The customs administration should provide for joint
targeting and screening, the use of standardized sets of targeting
criteria, and compatible communication and/or information exchange
mechanisms;
these elements will assist in the future development of a system of
mutual recognition of controls.
Standard: 8;
Title: Performance Measures;
Description: The customs administration should maintain statistical
reports that contain performance measures including, but not limited
to, the number of shipments reviewed, the subset of high-risk
shipments, examinations of high-risk shipments conducted, examinations
of high-risk shipments by nonintrusive inspection technology,
examinations of high-risk shipments by nonintrusive inspection and
physical means, examinations of high-risk shipments by physical means
only, and customs clearance times and positive and negative results.
Those reports should be consolidated by the WCO.
Standard: 9;
Title: Security Assessments;
Description: The customs administration should work with other
competent authorities to conduct security assessments involving the
movement of goods in the international supply chain and commit to
resolving identified gaps expeditiously.
Standard: 10;
Title: Employee Integrity;
Description: The customs administration and other competent authorities
should be encouraged to require programs to prevent lapses in employee
integrity and to identify and combat breaches in integrity.
Standard: 11;
Title: Outbound Security Inspections;
Description: The customs administration should conduct outbound
security inspection of high-risk containers and cargo at the reasonable
request of the importing country.
[End of table]
Source: World Customs Organization.
Table 4: WCO SAFE Framework--Standards for the Customs-to-Business
Pillar:
Standard: 1;
Title: Partnership;
Description: Authorized Economic Operators involved in the
international trade supply chain will engage in a self-assessment
process measured against pre-determined security standards and best
practices to ensure that their internal policies and procedures provide
adequate safeguards against the compromise of their shipments and
containers until they are released from customs controls at
destination.
Standard: 2;
Title: Security;
Description: Authorized Economic Operators will incorporate pre-
determined security best practices into their existing business
practices.
Standard: 3;
Title: Authorization;
Description: The customs administration, together with representatives
from the trade community, will design validation processes or quality
accreditation procedures that offer incentives to businesses through
their status as Authorized Economic Operators.
Standard: 4;
Title: Technology;
Description: All parties will maintain cargo and container integrity by
facilitating the use of modern technology.
Standard: 5;
Title: Communication;
Description: The customs administration will regularly update customs-
business partnership programs to promote minimum security standards and
supply chain security best practices.
Standard: 6;
Title: Facilitation;
Description: The customs administration will work co-operatively with
Authorized Economic Operators to maximize security and facilitation of
the international trade supply chain originating in or moving through
the administration's customs territory.
Source: World Customs Organization.
[End of table]
[End of section]
Appendix III: CBP's Collaborative Efforts to Enhance Container
Security:
CBP has collaborated with several partners or working groups to enhance
international container security. Some of these partners or groups
include the World Customs Organization (WCO), the Asia-Pacific Economic
Cooperation (APEC), member countries and the customs administrations of
the European Union, the New Zealand Customs Service, and the Canada
Border Services Agency. Table 5 describes some of the collaborative
work done by CBP.
Table 5: CBP's Collaborative Efforts to Enhance Container Security:
Partner or working group: WCO High Level Strategic Group;
Purpose of working group: Prepare a framework for security and
facilitation of the global supply chain;
Provide high-level guidance on implementation and development issues;
Status of working group efforts as of June 2007 Update: * Formulated,
adopted, and began implementation of the WCO Framework of Standards to
Secure and Facilitate Global Trade (SAFE Framework);
* Began work on capacity building;
* Sunset in June 2007.
Partner or working group: WCO SAFE Working Group;
Purpose of working group: Monitor, maintain, and develop the WCO
Framework;
Status of working group efforts as of June 2007 Update: * Established
June 2007 by WCO Council;
* The first meeting concluded in October 2007 (Brussels, Belgium) and
the second meeting was held April 22 to 23, 2008. The primary focus of
this meeting was the security filing requirements and refining the SAFE
Working Group Operations. CBP also provided an Update on the status of
the 100% scanning law and SFI pilot projects.
Partner or working group: U.S.-EU Joint Customs Cooperation Committee
(JCCC);
Purpose of working group: The U.S.-EU JCCC was established under the
Customs Cooperation and Mutual Assistance in Customs Matters agreement
signed May 28, 1997, to collaborate on customs issues;
Status of working group efforts as of June 2007 Update: * Under the
April 22, 2004, agreement to intensify and broaden the existing Customs
Cooperation and Mutual Assistance in Customs Matters agreement, the
JCCC was assigned oversight of a working-level expert group on
container security and supply chain security issues. See status of
working group below under U.S.-EU JCCC Steering Committee.
Partner or working group: U.S.-EU JCCC Steering Committee;
Purpose of working group: Was established to carry out the following
U.S.-EU JCCC initiatives;
* Establishment of CSI Minimum Requirements/CSI Feeder Port Pilot;
* Establishment of Minimum Control Standards for the inspection of high-
risk cargo;
* Establishment of a Joint Threat Assessment;
* Creation of a Joint Risk Rules Set;
* Creation of one Common List of Data Elements;
* Transshipment Pilot to test security of and accuracy of information
on transshipped cargo between the U.S. and the EU;
* Exchange of Information;
* Stationing of EU Liaison Officers at the National Targeting Center-
Cargo (NTC-C) in Herndon, Va;
* Mutual Recognition of trade partnership programs;
* Research and development Issues;
Status of working group efforts as of June 2007 Update: * CSI Minimum
Requirements/Feeder Port Pilot - Minimum Requirements jointly agreed to
under the JCCC/CSI Feeder Port Pilot - Feeder Port Pilots currently
underway in 3 locations: Szczecin, Poland (complete);
Aarhus, Denmark (operational);
and Salerno, Italy (set to begin July 2008);
* Minimum Control Standards - Action completed - minimum control
standards jointly agreed to under the JCCC;
* Joint Threat Assessment - Remains an ongoing action under the sharing
of information and will be shared, as deemed appropriate, with the WCO.
The Update for 2008 was drafted and agreed to at the JCCC meeting in
March 2008. The United States and EU have agreed to an annual Update;
* Joint Risk Rules - Set of rules drafted in 2006. They have been
further developed and are currently being programmed and tested under
the EU Liaison Officers action item;
* Common List of Data Elements - Action Completed;
* Transshipment Pilot - Action completed;
* Exchange of Information - The U.S. and the EU continue to exchange
information under the auspices of the U.S.-EU Customs Mutual Assistance
Agreement;
* EU Liaison Officers - The first two (of six total) EU Officers have
been stationed at the NTC-C;
* Mutual Recognition - Agreement of a road map toward mutual
recognition between the United States and EU completed in March 2008;
* R&D - Continuously exploring areas for cooperation in the R&D field.
Partner or working group: Asia-Pacific Economic Cooperation (APEC) Sub-
Committee on Customs Procedures;
Purpose of working group: To assist APEC member economies in adopting
the APEC Framework for Secure Trade leading to the implementation of
international standards for securing and facilitating the global supply
chain;
Status of working group efforts as of June 2007 Update:
* As of April 2008, CBP had completed the last component of a three
part seminar begun in July 2007-- "Essential Legal Authorities,"
"Establishment of Industry Partnership Programs," and "Supply Chain
Security Specialist Training," which was directed at supply chain
specialists who would be directly involved in the operation of the
program;
* As APEC member economies move toward implementing AEO programs, CBP
will continue to work with all economies to develop a methodology for
mutual recognition of AEOs authorized by other member economies to
avoid inconsistent, redundant and duplicative requirements and audits
for AEOs;
* CBP is actively engaged as the chair of the Collective Action Plan
Evaluation Working Group.
Partner or working group: CBP - New Zealand Customs Service Mutual
Recognition Arrangement;
Purpose of working group: To further secure the supply chain between
CBP and the New Zealand Customs Service;
Status of working group efforts as of June 2007 Update: * In June 2007,
CBP and the New Zealand Customs Service signed a Mutual Recognition
Arrangement that recognizes the extension of comparable benefits among
members of CBP’s Customs-Trade Partnership Against Terrorism and the
New Zealand Customs Service’s Secure Export Scheme. The United States
has discussed the benefits of a mutual recognition agreement with New
Zealand. These include reduced inspections and the ability to
reallocate customs resources in a more efficient fashion.
Partner or working group: CBP-Japan Customs & Tariff Bureau ("CTB")
Mutual Recognition Arrangement Negotiations;
Purpose of working group: To further secure the supply chain between
CBP and the Japan Customs and Tariff Bureau;
Status of working group efforts as of June 2007 Update: * CBP and JCTB
have completed the first phase of Mutual Recognition Arrangement
negotiations, which was the successful completion of a comparative
analysis between the two customs administrations’ programs. As of July
2008, CBP and JCTB are currently planning joint validations of Japanese
companies. CBP and JCTB look to sign an MRA by the end of the calendar
year.
Partner or working group: CBP - Jordan Mutual Recognition Arrangement;
Purpose of working group: To further secure the supply chain between
CBP and The Jordanian Customs Department;
Status of working group efforts as of June 2007 Update: * In June 2008,
CBP and the Jordan Customs Department signed a mutual recognition
arrangement that recognizes the extension of comparable benefits
between members of C- TPAT and Jordan's Golden List Program. It is the
first mutual recognition arrangement signed with a Middle Eastern
nation.
Partner or working group: CBP - Canada Border Services Agency
Partnership;
Purpose of working group: To further secure the supply chain between
CBP and Canada Border Services Agency;
Status of working group efforts as of June 2007 Update: * In June 2008,
CBP and the Canada Border Services Agency signed a mutual recognition
arrangement that recognizes the extension of comparable benefits
between members of C-TPAT and Canada's Partnership in Protection
program.
Source: GAO presentation of information gathered from CBP.
[End of table]
[End of section]
Appendix IV: The Secure Freight Initiative:
To improve maritime container security, the SAFE Port Act was enacted
in October 2006 and requires, among other things, that CBP conduct a
pilot program to determine the feasibility of scanning 100 percent of
U.S.-bound containers. It also specifies that the pilot should test
integrated scanning systems that combine the use of radiation portal
monitors and nonintrusive inspection equipment, building upon CSI and
the Megaports Initiative. To fulfill this and other requirements of the
SAFE Port Act, CBP and DOE jointly announced the formation of the
Secure Freight Initiative (SFI) in December 2006.
The goal of SFI is to build upon existing port security measures by
enhancing the U.S. government's ability to scan containers for nuclear
and radiological materials overseas and better assess the risk of U.S.-
bound containers. According to CBP officials, SFI is to be rolled out
in three phases. The initial phase is the International Container
Security project--commonly known as the SFI pilot program. The SFI
pilot program tests the feasibility of 100 percent scanning of U.S.-
bound container cargo at six overseas seaports meant to represent a
diverse array of trade processing capacities with varying container
traffic contents and flows. The SFI pilot program involves the
deployment of advanced cargo scanning capabilities and an integrated
examination system to participating overseas ports. The advanced cargo
scanning equipment--NII and radiation detection equipment--produce data
to indicate the presence of illicit nuclear and radiological material
in containers. The integrated examination system then uses software to
make this information available to CBP for analysis. According to CBP,
it will review the scan data at the foreign seaport or at CBP's
National Targeting Center-Cargo (NTC-C) in the United States.[Footnote
29] If the scanning equipment indicates a potential concern, both CSI
and host government customs officials are to simultaneously receive an
alert and the specific container is to be further inspected before it
continues on to the United States.
Table 6 lists the seaports participating in the SFI pilot program. As
shown in the table, three SFI seaports are to scan 100 percent of U.S.-
bound container cargo that passes through those seaports, while the
other three seaports are to deploy scanning equipment in a more limited
capacity.
Table 6: Information on the Six Foreign Seaports Participating in the
SFI Pilot Program:
SFI port: Qasim, Pakistan;
Deployment level when pilot operational: Full[C];
Testing date[A]: March 31, 2007;
Operational date[B]: October 12, 2007;
Volume of U.S.-bound containers, fiscal year 2007: 7,295.
SFI port: Puerto Cortez, Honduras;
Deployment level when pilot operational: Full[C];
Testing date[A]: April 2, 2007;
Operational date[B]: October 12, 2007;
Volume of U.S.-bound containers, fiscal year 2007: 75,800.
SFI port: Southampton, UK;
Deployment level when pilot operational: Full[C];
Testing date[A]: August 23, 2007;
Operational date[B]: October 12, 2007;
Volume of U.S.-bound containers, fiscal year 2007: 25,627.
SFI port: Hong Kong;
Deployment level when pilot operational: Limited[D];
Testing date[A]: November 19, 2007;
Operational date[B]: January 11, 2008;
Volume of U.S.-bound containers, fiscal year 2007: 795,138.
SFI port: Busan, South Korea;
Deployment level when pilot operational: Limited[D];
Testing date[A]: June 8, 2008;
Operational date[B]: September 2008 (projected);
Volume of U.S.-bound containers, fiscal year 2007: 645,467.
SFI port: Salalah, Oman;
Deployment level when pilot operational: Limited[D];
Testing date[A]: August 2008 (projected);
Operational date[B]: September 2008 (projected);
Volume of U.S.-bound containers, fiscal year 2007: 45,997.
Source: U.S. Customs and Border Protection.
[A] Testing date is defined as the date when the scanning systems are
in place and operational testing begins.
[B] Operational date is defined as the date when the SFI scanning data
are transmitted successfully to the local central alarm station and to
the CBP network in the United States.
[C] Fully operational seaports are to scan 100 percent of U.S.-bound
container cargo under the SFI pilot program.
[D] Limited operation seaports are to scan less than 100 percent of
U.S.-bound container cargo. For these seaports, CBP plans to conduct
SFI operations at a reduced level, typically limited to one terminal in
the port, such as Gamman Terminal in Busan.
[End of table]
Phase two of SFI is the implementation of a requirement that importers
and cargo carriers provide certain additional information about the
cargo they are transporting to the United States prior to loading at
the foreign port. The additional information will allow CBP to better
target high-risk cargo. In general, this security filing--also called
"10+2"--requires importers to provide data elements that further
identify the entities involved in the supply chain and their locations
as well as a more precise identification of the items shipped to the
United States. CBP worked with its Departmental Advisory Committee on
Commercial Operations and the trade community to identify the specific
data elements to be required, which resulted in the 10+2 additional
data elements required. CBP published a notice for proposed rulemaking
in the Federal Register on the 10+2 security filing in January 2008,
and the regulations underwent a public comment period until March 2008.
This phase is currently in the development stage.
As required by the SAFE Port Act, CBP issued a report in June 2008 on
the lessons learned from the SFI pilot program and the need and
feasibility of expanding the 100 percent scanning system to other CSI
seaports, among other things.[Footnote 30] Every 6 months after the
issuance of this report, CBP is to report on the status of full-scale
deployment of the integrated scanning systems at foreign seaports to
scan 100 percent of U.S.-bound cargo.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Stephen L. Caldwell, (202) 512-9610 or caldwells@gao.gov:
Acknowledgments:
In addition to the contact named above, Christine A. Fossett and Danny
R. Burton, Assistant Directors, and Robert Rivas, Analyst-in-Charge,
managed this assignment.
Stephanie Fain, Valerie Kasindi, Matthew Lee, and Leslie Sarapu made
significant contributions to the work.
Stanley Kostyla assisted with design and methodology.
Frances Cook provided legal support.
Sally Williamson provided assistance in report preparation.
Pille Anvelt and Avy Ashery developed the report's graphics.
[End of section]
Related GAO Products:
Supply Chain Security: Challenges to Scanning 100 Percent of U.S.-Bound
Cargo Containers. GAO-08-533T. Washington, D.C.: June 12, 2008.
Supply Chain Security: Examinations of High-Risk Cargo at Foreign
Seaports Have Increased, but Improved Data Collection and Performance
Measures Are Needed. GAO-08-187. Washington, D.C.: January 25, 2008.
Maritime Security: The SAFE Port Act: Status and Implementation One
Year Later. GAO-08-126T. Washington, D.C.: October 30, 2007.
Maritime Security: One Year Later: A Progress Report on the SAFE Port
Act. GAO-08-171T. Washington, D.C.: October 16, 2007.
Maritime Security: The SAFE Port Act and Efforts to Secure Our Nation's
Seaports. GAO-08-86T. Washington, D.C.: October 4, 2007.
Combating Nuclear Smuggling: Additional Actions Needed to Ensure
Adequate Testing of Next Generation Radiation Detection Equipment. GAO-
07-1247T. Washington, D.C.: September 18, 2007.
Maritime Security: Observations on Selected Aspects of the SAFE Port
Act. GAO-07-754T. April 26, 2007.
Customs Revenue: Customs and Border Protection Needs to Improve
Workforce Planning and Accountability. GAO-07-529. Washington, D.C.:
April 12, 2007.
Cargo Container Inspections: Preliminary Observations on the Status of
Efforts to Improve the Automated Targeting System. GAO-06-591T.
Washington, D.C.: March 30, 2006.
Combating Nuclear Smuggling: Efforts to Deploy Radiation Detection
Equipment in the United States and in Other Countries. GAO-05-840T.
Washington, D.C.: June 21, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment
Requirements Would Improve Overseas Targeting and Inspection Efforts.
GAO-05-557. Washington, D.C.: April 26, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved. GAO-05-
466T. Washington, D.C.: May 26, 2005.
Maritime Security: Enhancements Made, but Implementation and
Sustainability Remain Key Challenges. GAO-05-448T. Washington, D.C.:
May 17, 2005.
Cargo Security: Partnership Program Grants Importers Reduced Scrutiny
with Limited Assurance of Improved Security. GAO-05-404. Washington,
D.C.: March 11, 2005.
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in
Installing Radiation Detection Equipment at Highest Priority Foreign
Seaports. GAO-05-375. Washington, D.C.: March 31, 2005.
Homeland Security: Process for Reporting Lessons Learned from Seaport
Exercises Needs Further Attention. GAO-05-170. Washington, D.C.:
January 14, 2005.
Port Security: Better Planning Needed to Develop and Operate Maritime
Worker Identification Card Program. GAO-05-106. Washington, D.C.:
December 10, 2004.
Maritime Security: Substantial Work Remains to Translate New Planning
Requirements into Effective Port Security. GAO-04-838. Washington,
D.C.: June 30, 2004.
Homeland Security: Summary of Challenges Faced in Targeting Oceangoing
Cargo Containers for Inspection. GAO-04-557T. Washington, D.C.: March
31, 2004.
Container Security: Expansion of Key Customs Programs Will Require
Greater Attention to Critical Success Factors. GAO-03-770. Washington,
D.C.: July 25, 2003.
[End of section]
Footnotes:
[1] Risk management is a strategy called for by federal law and
presidential directive and is meant to help policy makers and program
officials most effectively mitigate risk while allocating limited
resources under conditions of uncertainty. Risk management allows for
reduction of risk against possible terrorist attack to the nation by
allocating resources to those areas of highest risk and is an approach
that has been accepted throughout the federal government.
[2] For more information on the CSI program, see GAO, Supply Chain
Security: Examinations of High-Risk Cargo at Foreign Seaports Have
Increased, but Improved Data Collection and Performance Measures Are
Needed, GAO-08-187 (Washington, D.C.: Jan. 25, 2008).
[3] For more information on the C-TPAT program, see GAO, Supply Chain
Security: U.S. Customs and Border Protection Has Enhanced Its
Partnership with Import Trade Sectors, but Challenges Remain in
Verifying Security Practices, GAO-08-240 (Washington, D.C.: Apr. 25,
2008).
[4] Pub. L. No. 109-347, 120 Stat. 1884.
[5] The SFI pilot program tests the feasibility of 100 percent scanning
at a select number of foreign seaports involved in the CSI program. See
appendix V for more information on SFI and its pilot program.
[6] The 9/11 Act includes possible exceptions for seaports for which
DHS certifies that specified conditions exist. Among others, these
conditions are: (1) adequate scanning equipment is not available or
cannot be integrated with existing systems, (2) a port does not have
the physical characteristics to install the equipment, or (3) use of
the equipment will significantly impact trade capacity and the flow of
cargo.
[7] Pub. L. No. 110-53, § 1701(a), 121 Stat. 266, 489-90 (2007)
(amending 6 U.S.C. § 982(b)).
[8] The European Commission is the European Union's (EU) policy making
and executive engine. The commission is composed of 27 commissioners,
one from each member state. Among its many powers, the commission
proposes legislation for approval by the EU Council and European
Parliament in matters relating to economic integration, ensures that EU
laws are applied and upheld throughout the EU, implements the budget,
and represents the European Community in international trade
negotiations. The EU is composed of 27 independent sovereign countries
which are known as member states: Austria, Belgium, Bulgaria, Cyprus,
the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece,
Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the
Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain,
Sweden, and the United Kingdom.
[9] CBP's Departmental Advisory Committee on Commercial Operations was
originally established by the Omnibus Budget Reconciliation Act of
1987, and its purpose is to advise the Secretaries of the Department of
the Treasury and the DHS on the commercial operations of CBP and
related DHS and Treasury functions. The Federation of European Private
Port Operators is a private industry organization representing the
interests of about 800 private port operators in Europe.
[10] The 58 CSI seaports are located in 33 different countries.
[11] See GAO-08-187 and GAO-08-240.
[12] The members of the High Level Strategic Group are the United
States, Canada, Finland, Germany, Ghana, Hungary, India, Japan, Jordan,
Senegal, South Africa, and the European Commission.
[13] The core elements of CBP's cargo security strategy include risk-
based targeting, advance information requirements (such as the 24-Hour
Rule), CSI, and C-TPAT. See table 1 for more details.
[14] The WCO updated the SAFE Framework in June 2007.
[15] Authorized Economic Operators include, for example, manufacturers,
importers, exporters, brokers, carriers, consolidators, intermediaries,
ports, airports, terminal operators, integrated operators, warehouses,
and distributors. Incentives for businesses participating in AEO
programs are defined and offered by the individual member states. Some
incentives could include (but are not limited to) expedited cargo
release, access of information of value to AEO participants, special
measures relating to periods of trade disruption or elevated threat
levels, and first consideration for participation in any new cargo
processing programs.
[16] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, GAO-06-15
(Washington, D.C.: Oct. 21, 2005).
[17] APEC's purpose is to facilitate growth, trade, cooperation, and
investment in the Asia-Pacific region. The APEC member countries are
Australia, Brunei Darussalam, Canada, Chile, People's Republic of
China, Hong Kong-China, Indonesia, Japan, Republic of Korea, Malaysia,
Mexico, New Zealand, Papua New Guinea, Peru, the Republic of the
Philippines, the Russian Federation, Singapore, Taiwan (Chinese
Taipei), Thailand, United States of America, and Viet Nam.
[18] The Community Customs Code codifies European Community customs
law. In May 2005, the European Parliament and the Council of the
European Union adopted a regulation to amend the Community Customs
Code. This amendment introduced measures that include (1) the use of a
risk-management framework that is to be fully computerized by 2009, (2)
the development of an Authorized Economic Operator program that entered
into force on January 1, 2008, and (3) the mandatory requirement of
advance electronic information on goods brought into or out of the
European Union by July 1, 2009.
[19] Customs controls are the measures applied by the customs
administration to ensure compliance with customs law. According to the
revised Kyoto Convention (a WCO instrument), all goods that enter or
leave a customs territory are subject to customs controls, and a
customs administration should use risk management in the control of
those goods exiting or entering the country. Therefore, all risk-
management activities in customs, such as targeting and inspecting
cargo, are considered customs controls.
[20] The U.S.-EU Joint Customs Cooperation Committee is co-chaired by
the CBP Commissioner and the Director General of the European
Commission's Taxation and Customs Union Directorate and is responsible
for overseeing all joint customs initiatives between CBP and the
European Commission.
[21] The European Union's AEO program became operational on January 1,
2008.
[22] A feeder port is a port that ships cargo to a larger transit
seaport.
[23] The act allows for a 2-year extension and an option for renewal of
the extension for 2-year increments thereafter if foreign ports can
demonstrate that at least two of the following conditions exist: (1)
scanning equipment is not available for purchase and installation; (2)
scanning systems do not have a sufficiently low false alarm rate; (3)
scanning systems cannot be purchased, deployed, or operated at ports
overseas, for example, if a port does not have the physical
characteristics to install such a system; (4) scanning systems cannot
be integrated into existing systems; (5) the use of such a scanning
system would significantly impact trade flows; and (6) scanning systems
do not adequately provide an automated notification of questionable or
high-risk cargo as a trigger for further inspection by appropriately
trained personnel.
[24] GAO, Supply Chain Security: Challenges to Scanning 100 Percent of
U.S.-Bound Cargo Containers, GAO-08-533T (Washington, D.C.: June 12,
2008).
[25] GAO-08-533T.
[26] Signatories of the Revised Kyoto Convention pledge to use risk
management principles in customs controls.
[27] See GAO, Supply Chain Security: Examinations of High-Risk Cargo at
Foreign Seaports Have Increased, but Improved Data Collection and
Performance Measures Are Needed, GAO-08-187 (Washington, D.C.: Jan. 25,
2008), and Supply Chain Security: U.S. Customs and Border Protection
Has Enhanced Its Partnership with Import Trade Sectors, but Challenges
Remain in Verifying Security Practices, GAO-08-240 (Washington, D.C.:
Apr. 25, 2008). Also, see GAO, Supply Chain Security: Challenges to
Scanning 100 Percent of U.S.-Bound Cargo Containers, GAO-08-533T
(Washington, D.C.: June 12, 2008).
[28] CBP's Departmental Advisory Committee on Commercial Operations was
established by the Omnibus Budget Reconciliation Act of 1987 to advise
the Secretaries of the Department of the Treasury and the DHS on the
commercial operations of CBP and related DHS and Treasury functions.
The Federation of European Private Port Operators is a private industry
organization representing the interests of about 800 private port
operators in Europe.
[29] According to CBP, the National Targeting Center (NTC) was
established in response to the need for proactive targeting aimed at
preventing acts of terror and to seize, deter, and disrupt terrorists
and implements of terror. NTC originally combined both passenger and
cargo targeting in one facility. It was later divided into NTCC and the
National Targeting Center-Passenger. For purposes of this report, we
use NTCC in our references since its mission is to support CBP cargo-
targeting operations.
[30] 6 U.S.C. § 981(d). The DHS Appropriations Act for fiscal year
2007, enacted shortly before the SAFE Port Act, also required a pilot
program to test 100 percent scanning at three ports, and established
similar, but not identical, requirements for the program. For example,
the report to Congress on lessons learned is to include a plan and
schedule to expand the scanning system developed under the pilot to
other CSI ports rather than an assessment of the need and feasibility
of such an expansion.
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. Government Accountability Office:
441 G Street NW, Room LM:
Washington, D.C. 20548:
To order by Phone:
Voice: (202) 512-6000:
TDD: (202) 512-2537:
Fax: (202) 512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548: