Department of the Treasury: Information on the Office of Enforcement's
Operations (Letter Report, 03/02/2001, GAO/GAO-01-305).

This report discusses GAO's review of the Department of the Treasury's
Office of Enforcement. Enforcement was created to provide oversight,
policy guidance, and support to Treasury's enforcement bureaus. GAO
found that no comprehensive source provided guidance to either the
Enforcement staff or to the bureaus on the circumstances under which
bureaus are required to interact with Enforcement. In addition,
established documentation did not exist for 12 of the 29 circumstances
under which the bureaus are required to interact with Enforcement, and
when it did exist, the documentation was generally broad in nature and
did not provide explicit information on one-half of the expected
interaction between the bureaus and Enforcement. About one-half of the
bureau officials that GAO interviewed said that they were not aware of
written requirements for their bureaus' interactions with Enforcement or
that they knew when to interact through such factors as their
professional responsibility, experience, judgment, or common sense. An
agency's internal control needs to be clearly documented and that
documentation should be readily available for examination. Without a
clearly defined and documented set of policies and procedures covering
operational and communications activities, Enforcement runs the risk of
not being able to perform its functions and meet its goals efficiently.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-305
     TITLE:  Department of the Treasury: Information on the Office of
	     Enforcement's Operations
      DATE:  03/02/2001
   SUBJECT:  Internal controls
	     Interagency relations
	     Law enforcement agencies
	     Policy evaluation
	     Financial management
	     Agency missions

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GAO-01-305

Report to Congressional Committees

United States General Accounting Office

GAO

March 2001 DEPARTMENT OF THE TREASURY Information on the Office of
Enforcement's Operations

Page i GAO- 01- 305 Office of Enforcement's Operations Letter 1

Appendix I Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles 33

Appendix II Funding That Enforcement Received in Addition to Its Basic
Annual Operating Funds 112

Appendix III Comments From the Department of the Treasury 114

Appendix IV GAO Contacts and Staff Acknowledgments 115

Tables

Table 1: Circumstances Under Which Bureaus Are Required to Interact With
Enforcement and the Corresponding Documentation 18 Table 2: Summaries of
Example Projects and Ongoing Efforts That

Enforcement Engaged in That Were Related to Its Oversight, Policy Guidance,
and Support Roles 24 Table 3: Factors Identified by Enforcement and Bureau
Officials as

Having Been a Barrier to Enforcement in Fulfilling Its Roles 29 Table 4:
Enforcement Projects and Ongoing Efforts Related to

Treasury's Missions and Strategic Goals That Are Supported by Enforcement
and the Law Enforcement Bureaus 34

Figures

Figure 1: Enforcement Organization Chart, as of September 2000 8 Figure 2:
Enforcement's Initial and Year- End Financial Plans for

and Actual Obligations of Its Annual Operating Funds, Fiscal Years 1994
Through 2000 14 Contents

Page ii GAO- 01- 305 Office of Enforcement's Operations

Figure 3: FTEs Authorized for and Used by Enforcement, Fiscal Years 1994
Through 2000 16

Abbreviations

ATF Bureau of Alcohol, Tobacco and Firearms DAS Deputy Assistant Secretary
DCI Data collection instrument DOJ Department of Justice EOAF Executive
Office of Asset Forfeiture FLETC Federal Law Enforcement Training Center
FinCEN Financial Crimes Enforcement Network FMD Financial Management
Division FTE Full time equivalent IRS/ CID Internal Revenue Service's
Criminal Investigation Division OF& A Office of Finance and Administration
OFAC Office of Foreign Assets Control OMB Office of Management and Budget
OPR Office of Professional Responsibility

Page 1 GAO- 01- 305 Office of Enforcement's Operations

March 2, 2001 The Honorable Ben Nighthorse Campbell Chairman The Honorable
Byron L. Dorgan Ranking Member Subcommittee on Treasury and General
Government Committee on Appropriations United States Senate

The Honorable Ernest J. Istook Chairman The Honorable Steny H. Hoyer Ranking
Minority Member Subcommittee on Treasury, Postal Service,

and General Government Committee on Appropriations House of Representatives

The conference report on the Treasury and General Government Appropriations
Act for fiscal year 2000 requires us to conduct a review of the Department
of the Treasury's Office of Enforcement (Enforcement). 1 Enforcement is to
provide oversight, policy guidance, and support to the Treasury enforcement
components 2 -that is, the Bureau of Alcohol, Tobacco and Firearms (ATF);
the U. S. Customs Service (Customs); the Executive Office of Asset
Forfeiture (EOAF); the Federal Law Enforcement Training Center (FLETC); the
Financial Crimes Enforcement Network (FinCEN); the Office of Foreign Assets
Control (OFAC); and the U. S. Secret Service. 3 Enforcement is headed by the
Under Secretary (Enforcement) whose staff includes an Assistant Secretary
and three Deputy Assistant Secretaries (DAS). In addition, officials of each
bureau select a liaison to serve as a central point of contact to
Enforcement on

1 H. R. Conf. Rep. No. 106- 319 at 58 (1999). 2 Additionally, Enforcement is
to provide policy guidance to the Internal Revenue Service's Criminal
Investigation Division- not oversight or supervision. 3 For the purposes of
this report, we will refer to these Treasury components as “law

enforcement bureaus” or “bureaus.”

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 305 Office of Enforcement's Operations

various matters, such as conveying information, collecting data, and
ensuring that bureaus are aware of all requests for information.

As discussed with staff from the Subcommittee on Treasury and General
Government, Senate Committee on Appropriations, and the Subcommittee on
Treasury, Postal Service, and General Government, House Committee on
Appropriations, we agreed to determine

? the resources (funding and full time equivalents (FTE)) 4 that were
available for Enforcement to perform its oversight, policy guidance, and
support roles for fiscal years 1994 to 2000; the resources Enforcement
obligated each year for fiscal years 1994 to 2000; and, when applicable, why
obligations differed from what was available;

? the circumstances, if any, under which the Treasury law enforcement
bureaus are required to interact with Enforcement instead of acting on their
own; whether the bureaus have complied with these requirements;
Enforcement's role in these interactions; and how Enforcement has
communicated its authority to the bureaus;

? what Enforcement has done to provide oversight, policy guidance, and
support to the law enforcement bureaus and examples of projects and ongoing
efforts (i. e., continuous projects with no fixed end date) that Enforcement
has undertaken related to each of these roles since October 1, 1998; and

? what factors, if any, have been barriers to Enforcement in fulfilling its
oversight, policy guidance, and support roles, according to Enforcement and
bureau officials, and what actions, if any, has Enforcement taken in
response to these factors.

We focused our work on those offices within Enforcement that are responsible
for providing oversight, policy guidance, and support to Treasury's law
enforcement bureaus. To gather information on these objectives, we
interviewed Enforcement and bureau officials, obtained and reviewed relevant
documentation, and developed and administered a data collection instrument
(DCI).

4 An FTE generally consists of one or more employed individuals who
collectively complete 2,080 work hours in a given year. Therefore, either
one full- time employee or two half- time employees equal one FTE.

Page 3 GAO- 01- 305 Office of Enforcement's Operations

The resources available to Enforcement to perform its basic operations,
including its oversight, policy guidance, and support roles, for fiscal
years 1994 through 2000, ranged from about $2.3 million in fiscal year 1996
to $5.2 million in fiscal year 2000. 5 From fiscal years 1994 to 2000, about
$28.3 million had initially been made available to Enforcement through
Treasury's Financial Management Division (FMD), and Enforcement obligated
about $25. 2 million of these funds. In 5 of the 7 fiscal years from 1994 to
2000, Enforcement obligated fewer funds than had initially been made
available through FMD. According to Enforcement and FMD officials, a
principal reason that Enforcement did not use all of the funds that were
initially available was because of hiring- related issues. In the remaining
2 fiscal years, Enforcement's obligations were greater than the amount of
funding initially made available by FMD due to both personnel and
nonpersonnel- related expenses, such as equipment purchases. For fiscal
years 1994 through 2000, the number of FTEs that Enforcement used ranged
from 23 in fiscal year 1995 to 51 in fiscal year 2000. 6

No comprehensive source provided guidance to either Enforcement staff or the
bureaus on the circumstances under which bureaus are required to interact
with Enforcement. At our request, Enforcement officials compiled a list of
those circumstances. The 29 circumstances that they identified included
personnel activities, such as awarding bonuses to senior managers; fiscal
activities, such as reviewing annual budget submissions; and a wide variety
of activities related to specific law enforcement programs of the bureaus,
such as making payments to informants. For 12 of the circumstances, no
established documentation existed (such as Enforcement policies, handbooks,
or operating manuals) that prescribed interaction requirements. For many of
the other 17 circumstances, documentation was generally broad in nature and
did not provide explicit guidance to the bureaus on such things as when and
how they were to interact with Enforcement. Enforcement may not be able to
perform its functions and meet its goals efficiently without strong internal
control, including a clearly defined and documented set of policies and
procedures describing the circumstances under which the bureaus are required
to interact with Enforcement.

5 These are the funds that Treasury's Financial Management Division allotted
to Enforcement from the departmental offices' salaries and expenses
appropriation for Enforcement's basic operations.

6 These figures do not include FTEs for staff for which Enforcement was
reimbursed or who were detailed to Enforcement. Results in Brief

Page 4 GAO- 01- 305 Office of Enforcement's Operations

About one- half of the bureau officials we interviewed said that they either
were not aware of written requirements for their bureaus' interactions with
Enforcement or that they knew when to interact through such factors as their
professional responsibility, experience, judgment, or common sense. Bureau
officials generally said that they interacted with Enforcement under the
circumstances that Enforcement officials identified and provided examples of
their compliance. Enforcement officials said that their roles in these
interactions were determined by factors such as the particular issue being
covered or the type of product being generated and its level of importance.
Enforcement officials identified various methods that the Office used to
establish authorities and communicate with the law enforcement bureaus. For
example, the liaisons representing Treasury's law enforcement bureaus were
to meet daily with the Under Secretary to discuss various topics, including
operational matters such as arrests and seizures.

Enforcement staff engaged in various projects and activities to fulfill
their oversight, policy guidance, and support roles. According to
Enforcement officials, these generally included projects, ongoing efforts,
and discrete functions on more limited efforts. For example, Enforcement has
an ongoing effort to reduce juvenile and youth violence, among other things,
that subsequently was adopted as a presidential initiative. Enforcement has
worked with ATF on this ongoing effort, which has included developing the
Youth Crime Gun Interdiction Initiative; drafting, reviewing, or commenting
on briefing papers and reports; and regularly briefing Department of Justice
(DOJ) officials, Office of Management and Budget (OMB) officials,
congressional staff, and others on plans, budgets, reports, and
appropriations requests. Both Enforcement and bureau officials also
emphasized the importance of Enforcement's advocacy role for the bureaus,
both within and outside of Treasury.

Enforcement and bureau officials identified several factors that they viewed
as having been barriers to Enforcement in fulfilling its oversight, policy
guidance, and support roles. The bureau liaisons tended to identify internal
factors as barriers, including administrative issues, such as Enforcement's
starting from scratch when making data requests from the bureaus and not
determining whether it already had the data being requested. Enforcement and
other bureau officials, however, focused more on external factors, such as
Enforcement's need for additional resources to analyze the bureaus' budgets
and strategic plans. Enforcement officials described actions they had taken
to address some of these barriers, but they noted that two issues prevented
Enforcement from

Page 5 GAO- 01- 305 Office of Enforcement's Operations

fully addressing these barriers- a lack of control over the barrier and a
lack of resources.

To improve the Office of Enforcement's internal control, we are recommending
that the Secretary of the Treasury direct the Under Secretary (Enforcement)
to strengthen internal control by establishing a policies and procedures
manual to ensure that the circumstances under which their bureaus are to
interact with Enforcement are clearly defined, documented, and readily
available for examination by bureau officials, among others. In commenting
on a draft of this report, the Acting Under Secretary (Enforcement) agreed
with our recommendation and said that Enforcement has initiated a project to
plan and develop a policies and procedures manual, which would include a
subsection containing specific direction and guidance to the liaisons.

Initially created in 1968, 7 the Office of Enforcement was then headed by an
Assistant Secretary of the Treasury. The Under Secretary (Enforcement)
position was created as a result of Treasury's fiscal year 1994
appropriation in which Congress directed that the Secretary of the Treasury
establish the Office of the Under Secretary (Enforcement) 8 to give
increased prominence to the law enforcement activities and responsibilities
of Treasury's law enforcement bureaus. In July 1994, the first Under
Secretary (Enforcement) was sworn in. The Under Secretary's staff includes
an Assistant Secretary and three Deputy Assistant Secretaries. The Under
Secretary reports to the Secretary of the Treasury through the Deputy
Secretary of the Treasury and is responsible for the following functions: 9

? coordinating all Treasury law enforcement matters, including the
formulation of policies for all Treasury enforcement activities;

? ensuring cooperation and proper levels of Treasury participation in law
enforcement matters with other federal departments and agencies;

7 According to an Enforcement official, the Office of the Assistant
Secretary for Enforcement, Tariff and Trade Affairs, and Operations was
established in 1968 and had the general configuration of the current Office
of Enforcement.

8 Treasury Department Appropriations Act, 1994, P. L. 103- 123, 107 stat.
1226, 1234 (1993). 9 These functions were outlined in a Treasury paper on
the organization and functions of the Office of the Under Secretary
(Enforcement). According to an Enforcement official, information similar to
this will be made part of Treasury's Internet Web site. Background

Page 6 GAO- 01- 305 Office of Enforcement's Operations

? directly overseeing the Assistant Secretary (Enforcement) and DAS
(Enforcement Policy); and, through the Assistant Secretary (Enforcement),
overseeing the DAS (Law Enforcement) and the DAS (Regulatory, Trade and
Tariff Enforcement);

? providing departmental oversight of Customs; the Secret Service; ATF; and
FLETC and, through the Assistant Secretary (Enforcement), monitoring the
activities of FinCEN, OFAC, and EOAF; and conducting policy guidance for the
Internal Revenue Service's Criminal Investigation Division (IRS/ CID);

? negotiating international agreements on behalf of the Secretary of the
Treasury to engage in joint law enforcement operations and for the exchange
of financial information and records useful to law enforcement; and

? supervising the Director of the Office of Finance and Administration (OF&
A).

Enforcement's performance goals, as described in its fiscal year 2000
performance plan, were to (1) develop and implement policies to facilitate
achievement of strategic goals in Treasury's enforcement mission 10 and (2)
provide effective oversight of law enforcement bureaus. 11 The fiscal year
2000 budget for the Treasury law enforcement bureaus, 12 as enacted, totaled
about $3.3 billion, with about 27,300 FTEs. 13

10 Treasury has four missions, according to its strategic plan for fiscal
years 1997 to 2002. They are (1) economic- to promote prosperous and stable
American and world economies, (2) financial- to manage the government's
finances, (3) law enforcement- to protect our financial systems and our
nation's leaders and foster a safe and drug- free America, and (4)
management- to continue to build a strong institution.

11 Under the Government Performance and Results Act of 1993 (P. L. 103- 62),
agencies are to prepare annual performance plans, which are to contain the
agencies' performance goals, among other things. In implementing this act,
Treasury has required that its bureaus and the departmental office develop
and submit annual performance plans to Congress.

12 These figures do not include funding or FTEs for IRS/ CID; EOAF, which
does not receive annual appropriated funding because it is a permanent
indefinite account; and OFAC, which does not have funds enacted directly to
it because it is an office within the departmental offices salaries and
expenses appropriation. Additionally, according to Treasury's Office of
Financial and Budget Execution, about $130 million of the Treasury
Forfeiture Funds' “super surplus funds” and about $75 million of
Interagency Crime and Drug Enforcement funds were available in fiscal year
2000 to reimburse the law enforcement bureaus for law enforcement
activities.

13 The FTE figure does not include reimbursable FTEs.

Page 7 GAO- 01- 305 Office of Enforcement's Operations

As of September 30, 2000, Enforcement had 42 staff on board, consisting of
24 mission- related and 18 mission- support staff. 14 In addition to these
staff, Enforcement also had on board six detailees and one employee for whom
Enforcement was reimbursed. Four of the five top Enforcement management
positions and one bureau head position are political positions that are
subject to turnover with a change in administration. Figure 1 shows an
Enforcement organization chart as of September 2000.

14 These were mission- related and mission- support staff paid by
Enforcement, and they generally fall within the unshaded and unshadowed
boxes in the Enforcement organization chart in figure 1.

Page 8 GAO- 01- 305 Office of Enforcement's Operations

Figure 1: Enforcement Organization Chart, as of September 2000

Page 9 GAO- 01- 305 Office of Enforcement's Operations

Source: GAO developed from Enforcement data and discussions with Enforcement
officials.

Page 10 GAO- 01- 305 Office of Enforcement's Operations

We focused our work on those offices within Enforcement that are responsible
for providing oversight, policy guidance, and support to Treasury's law
enforcement bureaus. These are the Offices of the Under Secretary
(Enforcement), the Assistant Secretary (Enforcement), the DAS (Enforcement
Policy), the DAS (Law Enforcement), the DAS (Regulatory, Tariff and Trade
Enforcement), and Finance and Administration.

To determine Enforcement's resource availability and obligations and, where
applicable, why obligations differed from what was available, we interviewed
and obtained documentation from Enforcement and FMD officials. The
documentation we obtained and reviewed included Enforcement's financial
plans and payroll runs and relevant portions of appropriations acts for
fiscal years 1994 through 2000. We selected fiscal year 1994 as the starting
point for these data because that was the year that the first Under
Secretary (Enforcement) was sworn in.

To determine the circumstances under which the law enforcement bureaus are
required to interact with Enforcement, versus acting on their own, we
interviewed Enforcement officials. Because there was no comprehensive source
that indicated when the bureaus are required to interact with Enforcement,
we asked Enforcement officials to compile a list of these circumstances and
to provide copies of the documentation that spelled out these requirements.
We reviewed these documents to determine the extent to which they described
the required interaction between Enforcement and the bureaus, such as when
and how the bureaus were to interact with Enforcement. To determine whether
the bureaus generally have complied with these requirements, the role
Enforcement is to play, and how Enforcement communicated its authority to
the bureaus, we interviewed Enforcement and bureau officials and obtained
and reviewed related documentation.

We also interviewed Enforcement and bureau officials to (1) determine what
Enforcement had done to provide oversight, policy guidance, and support to
the law enforcement bureaus and (2) identify what factors, if any, have been
viewed as barriers to Enforcement in performing its oversight, policy
guidance, and support roles, and what actions Enforcement had taken in
response to these factors. We summarized these factors and identified broad
categories into which they fell. We did not determine to what extent, if at
all, the barriers these officials cited have affected Enforcement's ability
to fulfill its roles.

Lastly, we developed and administered a DCI to Enforcement officials to
gather information on examples of projects in which Enforcement Scope and

Methodology

Page 11 GAO- 01- 305 Office of Enforcement's Operations

engaged from October 1, 1998, through June 30, 2000. 15 Enforcement did not
have an inventory of the projects or ongoing efforts related to its
oversight, policy guidance, and support roles. Therefore, we requested that
Enforcement officials identify and provide data on up to 5 projects or
ongoing efforts that were related to each of the 10 strategic goals that
either Enforcement or the bureaus it oversees supports. Because the projects
and ongoing efforts on which we obtained information are not a statistical
sample of all projects and ongoing efforts, the DCI responses may not be
representative of all projects or ongoing efforts that Enforcement engaged
in during this period. We received 49 completed DCIs. 16 We did not verify
the information provided in the DCIs. Appendix I provides (1) Treasury's
four missions and the strategic goals for which the Enforcement officials
were to complete the DCIs and (2) data on each of the projects or ongoing
efforts they described in their DCI responses.

The Enforcement officials we interviewed included the Under Secretary;
Assistant Secretary; the DAS (Enforcement Policy); the DAS (Law
Enforcement); the DAS (Regulatory, Tariff and Trade Enforcement); and the
Director, OF& A. The officials at each of the law enforcement bureaus that
we interviewed were (1) generally the bureau heads or deputy directors,
assistant directors, or deputy assistant directors and (2) the bureau
liaisons. 17 , 18 The bureau liaisons we interviewed were either the current
or most recent former liaisons. 19 Liaisons are individuals from the law
enforcement bureaus who perform a liaison function between their bureaus and
Enforcement. They serve as central points of contact for Enforcement by
conveying information and collecting data, among other things.

15 Enforcement officials were to select projects or ongoing efforts that
were in place as of October 1, 1998, or that began on or after October 1,
1998, and before July 1, 2000, including projects still under way when the
DCI was completed. This was a mutually agreed to time frame that was
designed to be long enough to allow Enforcement officials to select projects
and ongoing efforts that demonstrated the type of work Enforcement engaged
in to fulfill its roles.

16 The number of DCIs that Enforcement officials completed for each goal
ranged from 2 to 10. 17 Our reference to law enforcement bureau officials
includes those from IRS/ CID.

18 EOAF did not have a bureau liaison to Enforcement. 19 At the time of our
interviews, several of the bureau liaisons had been in their positions for 2
months or less. Because of these staffs' limited experiences in the liaison
positions, we spoke with the former liaisons.

Page 12 GAO- 01- 305 Office of Enforcement's Operations

We did our work in Washington, D. C., between April 2000 and February 2001
in accordance with generally accepted government auditing standards. We
provided a copy of our draft report to the Secretary of the Treasury. The
Acting Under Secretary (Enforcement) provided written comments on the draft
and agreed with our recommendation.

Enforcement's basic operations are funded through Treasury's annual
appropriation for departmental offices' salaries and expenses. Treasury
distributes (or allots) this annual appropriation among various programs and
offices, including Enforcement. For example, in fiscal year 2000, Congress
appropriated about $134 million for the departmental offices' salaries and
expenses appropriation. 20 Of this total, Treasury's FMD allotted about $5.2
million to Enforcement for its annual operations, including its oversight,
policy guidance, and support roles. 21

FMD allots these annual operating funds to Enforcement through a financial
plan. The initial financial plan indicates the amount of funds Enforcement
has available for the fiscal year. 22 The resources made available to
Enforcement through its initial financial plans for fiscal years 1994
through 2000 ranged from about $2.3 million in fiscal year 1996 to $5.2
million in fiscal year 2000. Throughout the fiscal year, FMD can increase or
decrease the financial plan for a variety of reasons, including the rate at
which Enforcement has obligated its funds during the fiscal year and funding
needs elsewhere in Treasury. For example, according to FMD officials, at the
Secretary's discretion, funds may be reallotted to support the Secretary's
priorities. For fiscal years 1994 through 2000, the percentage of funding
from the initial financial plan that Enforcement

20 Treasury Department Appropriations Act, 2000, P. L. 106- 58, 113 stat.
430 (1999). 21 In addition to these basic annual operating funds,
Enforcement has received other funding, according to Enforcement and FMD
officials. This funding consisted of (1) funds from the departmental
offices' salaries and expenses appropriation for special projects or
purposes; (2) multiyear or no- year (i. e., budget authority that remains
available for obligation for an indefinite period of time) funds that were
appropriated by Congress or transferred from other Treasury bureaus or
federal agencies to Treasury's departmental offices for Enforcement; and (3)
funds that Enforcement obligated out of its allotment from the departmental
offices' salaries and expenses appropriation and for which it was
reimbursed. For additional information, see appendix II.

22 The annual financial plan that FMD uses to allot funds to Enforcement is
broken out by

“object” classifications that include personnel (e. g.,
personnel compensation and benefits) and nonpersonnel classifications (e.
g., travel, equipment, and supplies and materials). The financial plan also
provides the number of authorized FTEs for Enforcement. Enforcement's

Resources

Page 13 GAO- 01- 305 Office of Enforcement's Operations

obligated ranged from about 74 percent (in fiscal year 1997) to about 124
percent (in fiscal year 1996). Cumulatively, from fiscal years 1994 to 2000,
about $28.3 million had initially been made available to Enforcement through
FMD, and Enforcement obligated about $25.2 million of these funds.

Figure 2 shows Enforcement's initial financial plan, year- end financial
plan, and actual obligations of its annual operating funds for fiscal years
1994 through 2000.

Page 14 GAO- 01- 305 Office of Enforcement's Operations

Figure 2: Enforcement's Initial and Year- End Financial Plans for and Actual
Obligations of Its Annual Operating Funds, Fiscal Years 1994 Through 2000

a These figures include funding for the Office of Professional
Responsibility (OPR), which was created within Enforcement pursuant to
congressional direction provided during the fiscal year 1997 appropriations
process. (See H. R. Conf. Rep. No. 104- 863 at 1139 (1996).) OPR funding for
fiscal years 1997 and 1998 was provided separately from the Treasury
departmental offices' salaries and expenses account. (See Treasury
Department Appropriations Act, 1997, P. L. 104- 208, 110 Stat. 3009, 3009-
315, (1996) and Treasury Department Appropriations Act, 1998, P. L. 105- 61,
111 Stat. 1272, 1273, (1997).) Congressional action, effective fiscal year
1999, moved the funding for OPR into the departmental offices' salaries and
expenses account, and FMD included this funding in Enforcement's financial
plans. (See H. R. Conf. Rep. No. 105- 825 at 1473 (1998).)

Source: GAO developed from Treasury's Financial Management Division data.

In 5 of the 7 fiscal years from 1994 to 2000, Enforcement obligated fewer
funds than it had available through its initial financial plan. In 3 of the
5 fiscal years- 1995, 1997, and 1998- Enforcement obligated about
threequarters of its available funds. In the remaining 2 fiscal years- 1999
and 2000- Enforcement obligated about 92 percent of its available funds.
Enforcement and FMD officials said that a principal reason that Enforcement
did not obligate all of its available funds was due to

Page 15 GAO- 01- 305 Office of Enforcement's Operations

Enforcement's not obligating all of the funds it had available for personnel
expenses. According to an Enforcement official, Enforcement had not always
hired staff quickly enough, which created a surplus of personnel funds and
ultimately led to FMD's reducing Enforcement's financial plan. Enforcement
officials cited a variety of issues they have faced relating to hiring
staff. These issues included a lengthy hiring process, including the
background and security investigations; difficulty in filling positions
because qualified people were in high demand; length of time it took to get
approval from the Office of Management to fill a position; Office of
Management's not approving the filling of a position; and Enforcement's
being slow in selecting candidates. Enforcement officials said that the
major reason for underobligating available funds in fiscal years 1997 and
1998 was that Enforcement experienced major impediments in staffing its
newly established Office of Professional Responsibility (OPR), which was
funded by Treasury's fiscal year 1997 appropriation. 23

In the remaining 2 of the 7 fiscal years (1994 and 1996), Enforcement's
obligations were greater than its initial financial plan. Both personnel and
nonpersonnel- related factors, such as equipment purchases, were the reasons
for Enforcement's obligating more that it had available through its initial
financial plan.

Figure 3 shows the number of FTEs authorized for Enforcement by the
Assistant Secretary for Management 24 and the number of FTEs that
Enforcement had used as of the end of each fiscal year. 25 For fiscal years
1994 through 2000, the number of FTEs that Enforcement was authorized ranged
from 31 in 1996 to 51 in 2000. The number of FTEs used ranged from 23 in
fiscal year 1995 to 51 in fiscal year 2000.

23 An OPR within the Office of the Under Secretary for Enforcement was
created pursuant to congressional direction provided during the fiscal year
1997 appropriations process. 24 The Assistant Secretary for Management is
the head of Treasury's Office of Management and is Treasury's Chief
Financial Officer. 25 These figures do not include FTEs for staff for which
Enforcement was reimbursed or who were detailed to Enforcement.

Page 16 GAO- 01- 305 Office of Enforcement's Operations

Figure 3: FTEs Authorized for and Used by Enforcement, Fiscal Years 1994
Through 2000

Note: These figures do not include FTEs for staff for which Enforcement was
reimbursed or who were detailed to Enforcement. a These figures include the
FTEs for OPR. OPR funding for fiscal years 1997 and 1998 was provided

separately from the Treasury departmental offices' salaries and expenses
account. Congressional action, effective fiscal year 1999, moved the funding
for OPR into the departmental offices' salaries and expenses account, and
FMD included the FTEs authorized through this funding in Enforcement's
financial plans.

Source: GAO developed from Treasury's Financial Management Division data.

No comprehensive source provided guidance to either Enforcement staff or the
bureaus on the circumstances under which bureaus are required to interact
with Enforcement. At our request, Enforcement officials compiled a list of
those circumstances. The 29 circumstances they identified included personnel
activities, such as awarding bonuses to senior managers; fiscal activities,
such as reviewing annual budget submissions; and a wide variety of
activities related to specific law enforcement programs of the bureaus, such
as making payments to informants. For 12 Law Enforcement

Bureaus' Interactions With Enforcement

Page 17 GAO- 01- 305 Office of Enforcement's Operations

of these circumstances, no established documentation existed that prescribed
interaction requirements. For many of the 17 other circumstances, the
documentation generally was broad in nature and did not provide explicit
guidance to the bureaus on such things as when and how they were to interact
with Enforcement.

About one- half of the bureau officials we interviewed said that they either
were not aware of written requirements for their bureaus' interactions with
Enforcement or that they knew when to interact through such factors as their
professional responsibility, experience, judgment, or common sense.
According to Enforcement officials, Enforcement's role in these interactions
depended on various factors, such as the particular issue or type of product
to be generated and its level of importance. According to Enforcement
officials, they used various methods, including Treasury orders and
directives and regular meetings with the bureau heads and liaisons, to
establish Enforcement's authority and to communicate policies, procedures,
and other information to the bureaus.

With regard to interacting with the bureaus, Enforcement did not adequately
meet the standards for internal control established by GAO. 26 Documentation
on the circumstances under which law enforcement bureaus are required to
interact with Enforcement was not readily available from Enforcement
officials. As a result, we asked Enforcement officials to compile a list of
these circumstances. We also asked for the corresponding documentation that
requires these interactions. The officials noted that Enforcement did not
have a policies and procedures manual, and that all of these requirements
may not be in writing. For example, they said that some requirements may be
informal and have become practice over time. The data that these officials
compiled are shown in table 1.

26 Standards for Internal Control in the Federal Government (GAO/ AIMD- 00-
21. 3. 1, Nov. 1999). Enforcement Did Not

Adequately Meet Internal Control Standards

Page 18 GAO- 01- 305 Office of Enforcement's Operations

Table 1: Circumstances Under Which Bureaus Are Required to Interact With
Enforcement and the Corresponding Documentation

Circumstances under which bureaus are required to interact with Enforcement
Documentation requiring the interaction

Weekly activity reports No established documentation exists Major rulings No
established documentation exists Significant bureau activities No
established documentation exists Designation of National Special Security
Events No established documentation exists a Certain Freedom of Information
Act appeals No established documentation exists- documentation created on a
case- bycase or yearly basis b Budget data requests from OMB No established
documentation exists- documentation created on a case- bycase or yearly
basis b Supplemental budget proposals No established documentation exists-
documentation created on a case- bycase or yearly basis b Positions for
inclusion in interdepartmental reports (e. g., International Narcotics
Controlled Strategy Report, Counterterrorism Plan)

No established documentation exists- documentation created on a case- bycase
or yearly basis b

Major memorandum of understanding No established documentation exists-
documentation created on a case- bycase or yearly basis b Performance
measures (i. e., development of measures and reports on performance) No
established documentation exists- documentation created on a case- bycase or
yearly basis b Annual budget submissions No established documentation
exists- documentation created on a case- bycase or yearly basis b Appeals c
No established documentation exists- requirements in 19 CFR vary on the

basis of the type of decision being appealed Performance appraisals of
senior managers 1999 memorandum from the Assistant Secretary for Management
to bureau

heads Bonuses for senior managers 1999 memorandum from the Assistant
Secretary for Management to bureau

heads Candidates to receive Secret Service protection 18 U. S. C. 3056
Payments to informants Secretary of the Treasury's Guidelines for Seized and
Forfeited Property

Acceptance of forfeited items Secretary of the Treasury's Guidelines for
Seized and Forfeited Property

Correspondence for departmental signature Treasury Executive Secretariat
Procedures Manual

Reports to be published Treasury Executive Secretariat Procedures Manual

Testimony, for review and clearance Treasury Directive 28- 02 and Treasury
Executive Secretariat Procedures Manual

Regulations to be published Treasury Directive 28- 01 and Treasury Executive
Secretariat Procedures Manual

Fleet management information Treasury Directives 74- 01 and 74- 06 Penalty
cases Treasury Directive 00- 58 Plans for agency reorganization Treasury
Directive 21- 01 Legislation, for review and clearance Treasury Directive
28- 02 Reports to Congress Treasury Directive 28- 02 Responses to questions
for the record Treasury Directive 28- 02 Major cases 1999 memorandum from
Enforcement Chief of Staff to bureau liaisons Acceptance of gifts 1999
memorandum from Under Secretary (Enforcement) to bureau liaisons

Page 19 GAO- 01- 305 Office of Enforcement's Operations

Note: When providing the documentation that indicates that the bureaus are
to interact with Enforcement, Enforcement officials identified two other
circumstances that were not on the original listing that they provided.
These circumstances were press releases and certain Privacy Act appeals.
Because these circumstances were not on the listing that we showed the
bureau officials, we did not include them in this table. a According to an
Enforcement official, a Treasury/ DOJ interagency working group is
developing

criteria and guidelines for designating National Special Security Events. b
Specific requirements have been developed and documented on a case- by- case
or yearly basis, according to Enforcement officials, but no established
documentation exists requiring interaction under this circumstance. c These
are appeals of Customs rulings.

Source: Enforcement officials and GAO analysis of documentation.

Twelve of the 29 circumstances under which the bureaus are to interact with
Enforcement lacked established documentation, as shown in table 1. According
to Enforcement officials, however, documentation is created on a case- by-
case or yearly basis in eight of these circumstances. For example, for major
memorandums of understanding, review procedures are established as each
memorandum is developed, according to Enforcement officials. In 11 of the 17
circumstances for which established documentation existed, the documentation
was generally broad in nature and did not provide explicit information on
the expected interaction between Enforcement and the bureaus. For example,
some of the documentation consisted of Treasurywide documents, such as
directives, that identified items that had to be cleared through the
appropriate departmental offices (e. g., Enforcement) before being
finalized. These documents were not specific to Enforcement and, therefore,
did not provide specific guidance to the law enforcement bureaus on such
things as the procedures that the bureaus should follow to clear items
through Enforcement, who the bureaus should contact in Enforcement, and the
necessary time frames for getting the clearances. The documentation for the
remaining six circumstances provided more specific guidance to the bureaus.

About one- half of the bureau officials we interviewed said that they either
were not aware of written requirements for their bureaus' interactions with
Enforcement or that they knew when to interact through such factors as their
professional responsibility, experience, judgment, or common sense. 27 Two
other liaisons said that they learned how to do their jobs by

27 One official reported also relying on input from their director to
determine when to interact with Enforcement.

Page 20 GAO- 01- 305 Office of Enforcement's Operations

shadowing or getting an orientation from their predecessors. One of these
two liaisons reported no receipt of documentation providing guidance, and
the other reported having a “learn as you go” experience.

GAO's standards for internal control state that an agency's internal control
needs to be clearly documented, and that the documentation should be readily
available for examination. Control activities include the policies,
procedures, techniques, and mechanisms that enforce management's directives
for meeting the agency's objectives. Furthermore, the standards say that,
for an agency to run and control its operations, it must have relevant,
reliable, and timely communications relating to internal and external
events. The standards also say that pertinent information should be
identified, captured, and distributed in a form and time frame that permits
people to perform their duties efficiently.

Enforcement needs to ensure that a clearly defined and documented set of
policies and procedures, covering such issues as the circumstances under
which the bureaus are to interact with Enforcement, are readily available
for examination by Enforcement and bureau officials. Such documentation
would help ensure that (1) these officials would know specifically when and
how the bureaus are to interact with Enforcement and (2) Enforcement will
receive relevant information in a timely manner. Lacking such information,
Enforcement may not be able to perform its functions and meet its goals
efficiently. Furthermore, as a part of a new administration, incoming
Enforcement officials may find the transition to their new roles less
cumbersome if clearly documented policies and procedures were available
regarding when and how bureaus are required to interact with Enforcement.

Page 21 GAO- 01- 305 Office of Enforcement's Operations

After reviewing the table 1 data on the circumstances under which the
bureaus are required to interact with Enforcement, bureau officials 28
generally concurred that their offices would interact with Enforcement in
these circumstances. 29 Bureau officials cited examples of when they have
complied with these requirements. For example, officials from FLETC stated
that Enforcement was actively involved in the development of FLETC's annual
budget submission. The director said that FLETC would develop the first
draft of the budget, and that Enforcement would review the draft for such
things as whether it supported Treasury's strategic plan. Similarly, an
official from the Secret Service said that the Service sends its strategic
and performance plans and its performance reports to Enforcement for review
and comment. Another Secret Service official provided, as an example, a
recent instance in which the bureau informed Enforcement of an inquiry the
bureau had received to provide Secret Service protection to an individual
involved in the recent presidential campaign.

Several bureau officials further explained that they communicated with
Enforcement on significant or major matters or events. These officials
provided us with definitions of what they considered to be significant or
major. Some examples that they provided to us related to issues that could
invoke inquiries from the media or the Under Secretary; issues that could
affect relationships with other bureaus or external stakeholders, such as
OMB; and departures from the bureaus' normal courses of action.

According to Enforcement officials, Enforcement's role in the circumstances
in which the bureaus are to interact with Enforcement was dependent on such
factors as the particular issue or type of product to be generated and its
level of importance. For example, for some written products that would be
incorporated into a report, Enforcement officials' role may be limited to
reading and editing the bureaus' products and forwarding them to the office
that is responsible for submitting the report. An area in which Enforcement
was heavily involved, according to

28 We did not review this list with officials in three interviews. An
Enforcement official noted that OFAC, which reports to the Assistant
Secretary (Enforcement), and EOAF, which reports to the DAS (Law
Enforcement), have more specific interaction requirements because these
offices are located within the Office of Enforcement.

29 Both Enforcement and bureau officials noted that not all of these
circumstances, such as payments to informants and major rulings, were
applicable to all of the bureaus. Bureau Officials Cited

Examples of How They Complied With Enforcement's Interaction Requirements

Enforcement's Role in Bureau Activities

Page 22 GAO- 01- 305 Office of Enforcement's Operations

Enforcement officials, was the bureaus' annual budget submissions.
Enforcement's involvement included reviewing the budgets to ensure that they
reflected Enforcement's priorities and advocating for the bureaus with
Treasury' Office of Management and OMB throughout the budget process.

According to Enforcement officials, Enforcement uses a variety of methods to
establish authorities and communicate policies, procedures, guidelines,
reporting requirements, and information to the bureaus. Methods that these
officials described to us as being used included the following:

? Bureau heads meetings: These meetings are to be held every other week
between the Under Secretary and senior Enforcement officials and bureau
heads.

? Individual bureau head meetings: These meetings are to be held every other
week between the Under Secretary and individual bureau heads. The Assistant
Secretary also is to hold regular one- on- one meetings with the Directors
of FinCEN and OFAC.

? Monthly case briefings: These meetings are to be held monthly by the Under
Secretary with bureau staff to get in- depth briefings on significant
investigations.

? Significant case briefings: In addition to the monthly case briefings, as
appropriate, bureaus are to brief the Under Secretary, Assistant Secretary,
and staff on significant or high- visibility cases.

? Weekly written reports to the Under Secretary: These reports are to
contain information on significant activities from bureau heads.

? Daily bureau liaisons meetings: Daily briefings by bureau liaisons to the
Under Secretary in which various topics, such as press- worthy issues,
arrests, seizures, and important events, are to be discussed.

? Informal staff- to- staff contacts: Daily interactions between Enforcement
and bureau staff during which issues affecting the bureaus are to be
discussed.

Other methods of communication identified by Enforcement officials included
Treasury orders and directives; ad hoc groups established to address budget,
operational, or other issues that require a more intense focus for a short
period of time; working groups established to address long- range or ongoing
issues, such as the Treasury Enforcement Council working groups; and
memorandums from Enforcement management or staff. Enforcement Officials

Identified Methods They Use to Communicate Authority and Policies to Bureaus

Page 23 GAO- 01- 305 Office of Enforcement's Operations

Some of these methods were initiated after ATF's 1993 raid of the Branch
Davidian Compound, in Waco, TX, according to congressional testimony by a
former Under Secretary (Enforcement) and a Treasury report reviewing the
raid. 30 These steps were taken, at least in part, to improve oversight and
formal and informal communication between the bureaus and Treasury,
according to the Under Secretary's testimony. The methods initiated or
reactivated at that time included (1) regular meetings between the Under
Secretary's office and the bureau heads and (2) the Treasury Enforcement
Council working groups. Additionally, the former Under Secretary stated that
he issued a directive in August 1993 requiring that Enforcement be informed
of any significant operational matters that affect any of the bureaus'
missions, including major, high- risk law enforcement operations.

Enforcement staff engaged in various activities to carry out Enforcement's
oversight, policy guidance, and support roles. These activities included
projects and ongoing efforts (i. e., continuous projects with no fixed end
date) that were related to a specific issue, according to Enforcement
officials. We collected data on these projects and ongoing efforts through a
DCI. Additionally, to fulfill its roles, Enforcement staff engaged in
discrete functions on more limited efforts. Another important role that
various Enforcement and bureau officials emphasized was Enforcement's
advocacy role for the bureaus, both within and outside of Treasury.

Enforcement officials completed 49 DCIs that described projects and ongoing
efforts undertaken by Enforcement from October 1, 1998, through June 30,
2000. Table 2 provides summary information from the DCIs on one project and
one ongoing effort for each of Enforcement's three roles. The responses for
each of the DCIs that Enforcement completed are provided in appendix I.

30 Federal Actions at Waco, Texas: Hearings before the Subcomm. on Crime of
the House Comm. on the Judiciary, 104th Cong. (1995) (Statement of Ronald K.
Noble, Under Secretary of the Treasury for Enforcement). Report of the
Department of the Treasury on the Bureau of Alcohol, Tobacco, and Firearms
Investigation of Vernon Wayne Howell also known as David Koresh, September
1993. Enforcement

Activities Intended to Fulfill the Oversight, Policy Guidance, and Support
Roles

Projects and Ongoing Efforts

Page 24 GAO- 01- 305 Office of Enforcement's Operations

Table 2: Summaries of Example Projects and Ongoing Efforts That Enforcement
Engaged in That Were Related to Its Oversight, Policy Guidance, and Support
Roles

Role and type of effort Summary of project or ongoing effort Oversight

Project Customs Service Internal Affairs Review: As a result of a statutory
requirement, Enforcement conducted an assessment of the vulnerabilities to
corruption and the effectiveness of Customs' Office of Internal Affairs.
Enforcement collected data and statistics from Customs on case investigative
files and internal policies and procedures, developed strategies to improve
Customs' procedures, and prepared briefing papers for Treasury officials on
the progress and findings of the review. This project began in March 1998
and ended in February 1999 with the submission to Congress of a formal
report of the review. Ongoing effort Training Group: Enforcement initiated
the Training Group to advise the Under Secretary on the overall

training programs and training initiatives in Treasury's law enforcement
bureaus. Enforcement conducted an assessment of firearms requirements for
Treasury law enforcement officers; drafted an assessment report; and briefed
the Under Secretary, senior bureau officials, Members of Congress, and local
law enforcement. This ongoing effort began in February 1998.

Policy guidance

Project Interagency Commission on Crime and Security in U. S. Seaports:
Enforcement took the lead in coordinating the establishment of the
Interagency Commission on Crime and Security in U. S. Seaports. Enforcement
gathered information on the cost of establishing the commission, prepared
briefing materials for the Secretary to explain the establishment of the
commission, and served on the commission. This project began in November
1998 and ended in October 2000. Ongoing effort Child Labor Advisory
Committee: Enforcement became involved in this effort because the child
labor issue

is broader than just a Customs issue and Enforcement is able to provide a
broader perspective. Enforcement chaired and oversaw the activities of this
advisory committee. Enforcement worked with Customs to revamp Customs'
regulations with regard to seizure of goods made with “slave
labor,” including child slave or indentured labor. Enforcement's
participation in the project included chairing and overseeing activities of
the advisory committee, reviewing draft text by Customs and other agencies
on child labor issues, and negotiating with officials of foreign country
agencies to enforce Child Labor Import Standards. This ongoing effort began
in January 1998.

Support

Project 2000 Campaign: A statutory requirement directs Enforcement to
coordinate requests for Secret Service protection from prospective major
presidential and vice presidential candidates. Enforcement coordinates all
requests for protection and makes recommendations to the Secretary of the
Treasury. Enforcement collects manpower data from the other bureaus that
support the Secret Service and plays a role in the campaign's budget
process. This project began in October 1999 and is anticipated to end in
March 2001. Ongoing effort Youth Crime Gun Interdiction Initiative and Anti-
Trafficking: Enforcement supported ATF in its efforts to

reduce juvenile and youth violence. Enforcement worked with ATF to develop
this initiative, drafted language on the initiative and illegal market
enforcement strategies for speeches presented by Treasury and White House
officials, and delivered annual testimony addressing the initiative. This
ongoing effort began in September 1995.

Source: GAO summary of DCIs completed by Enforcement officials.

According to the responses to our DCI, 18 of the 49 example projects and
ongoing efforts undertaken by Enforcement from October 1, 1998, through June
30, 2000, primarily supported Enforcement's oversight role; 19 supported
Enforcement's policy development and guidance role; and the remaining 12
related to Enforcement's support role. Twenty- three of the reported
activities related to ongoing efforts- that is, continuous projects with no
fixed end date. Of the 49 example projects and ongoing efforts,

Page 25 GAO- 01- 305 Office of Enforcement's Operations

Enforcement initiated 14 and 21 were initiated as a result of statutory
requirements, other congressional direction, a presidential initiative, or
other factors, such as a request by the Deputy Secretary of the Treasury to
initiate the project or effort. The remaining 14 projects and ongoing
efforts were initiated due to a combination of the two reasons- that is,
they were self- initiated and initiated due to statutory requirements, other
congressional direction, a presidential initiative, or other factors.

Enforcement's involvement in these projects and efforts was usually due to
multiple factors. Some frequently cited reasons why Enforcement became
involved included the following:

? Treasury was directed to participate by congressional direction or
presidential initiative.

? The effort involved high- visibility issues or major policy issues.

? The issue was broader than one bureau. Enforcement was able to provide a
broader perspective than a single bureau could provide.

? The effort required coordination with or outreach to multiple entities,
such as multiple Treasury bureaus and offices; federal departments or
agencies; state and local entities; foreign governments; and/ or private
sector organizations.

Almost all of Enforcement's projects and ongoing efforts involved other
federal departments or agencies. Most frequently identified were DOJ (30
DCIs), OMB (26 DCIs), the Federal Bureau of Investigation (22 DCIs), and the
Department of State (19 DCIs). Forty- one of the projects and ongoing
efforts involved Treasury offices other than Enforcement or the law
enforcement bureaus, such as the Office of General Counsel (29 DCIs), the
Office of Management (23 DCIs), and the Office of Legislative Affairs (12
DCIs).

Enforcement officials identified the various functions that Enforcement
staff performed on each project and ongoing effort. The following are the
functions that were identified most frequently (i. e., the function was
performed on at least 39 of the 49 projects or efforts).

? Briefing officials, such as the Secretary or Deputy Secretary of the
Treasury; Members of Congress or their staff; the Under Secretary or
Assistant Secretary (Enforcement); and staff from OMB and DOJ, including the
Attorney General.

? Collecting data from the Treasury law enforcement bureaus or other
entities associated with the particular project. For example, the Five- Year
Counterterrorism Plan project involved Enforcement's gathering,

Page 26 GAO- 01- 305 Office of Enforcement's Operations

reviewing, organizing, and providing information on the bureaus' current
counterterrorism activities and proposals for new programs.

? Coordinating with entities such as the Treasury law enforcement bureaus
and other federal departments and agencies, including DOJ, OMB, and the
Office of Personnel Management.

? Preparing background materials for, among others, senior Treasury
officials, including the Secretary or Deputy Secretary of the Treasury; the
Under Secretary or Assistant Secretary (Enforcement); and various committee
members, such as members of the money laundering strategy interagency group.

? Overseeing or monitoring such things as law enforcement bureaus' and other
entities' implementation of programs or action items. For example, on a
North American Free Trade Agreement Working Group project, Enforcement
oversaw the United States', Mexico's, and Canada's implementation of
regulations related to Customs.

? Developing or drafting programs, initiatives, and strategies. For example,
for the National Church Arson Task Force project, Enforcement worked in
coordination with ATF, DOJ, and others to develop guidelines and strategies
for federal law enforcement agencies' investigation of church arson
incidents.

In addition to the work that Enforcement staff performed on specific
projects or ongoing efforts, they may perform similar, discrete functions on
more limited efforts throughout the year, according to Enforcement
officials. These functions included the following:

? collecting data (e. g., from bureaus/ offices);

? preparing briefing or background materials;

? briefing officials;

? developing or drafting such things as reports, programs, initiatives,
strategies, policies, directives, standards, and regulations;

? overseeing or monitoring such things as programs, activities, and
operations;

? reviewing written products, such as drafts, testimonies, and plans, and
program results;

? developing or reviewing budget proposals or seeking funding;

? coordinating with other agencies, bureaus, or other entities or mediating
disputes;

? writing correspondence or speeches; and

? delivering speeches or testifying. Discrete Functions

Performed on More Limited Efforts

Page 27 GAO- 01- 305 Office of Enforcement's Operations

For example, one Enforcement official said that the Office of Policy
Development receives requests on a daily basis to provide Enforcement's
comments on draft or proposed legislation, testimonies, press releases, or
other material.

Several officials in Enforcement and the bureaus said that Enforcement has a
key role as an advocate for the bureaus, both within and outside of
Treasury. In particular, various officials cited the importance of
Enforcement's being an advocate for the bureaus' budgets before the
Secretary of the Treasury, Office of Management, and OMB.

During interviews, we asked Enforcement and bureau officials 31 for their
views on what, if anything, were barriers to Enforcement's fulfilling its
oversight, policy guidance, or support roles. 32 We interviewed 24
Enforcement and bureau officials, 17 of whom cited at least 1 factor that
they considered a barrier to Enforcement. We did not determine to what
extent, if at all, these cited barriers affected Enforcement's ability to
fulfill its roles, but rather, we summarized the testimonial information
provided to us by interviewees. In discussing the cited barriers with
Enforcement officials, they said they generally understood the views
presented even though they did not always concur with them. These officials
identified two issues that affected their ability to fully address the cited
barriers- lack of control over the barrier and lack of resources.

Enforcement and bureau officials cited a variety of factors as having been
barriers to Enforcement in fulfilling its roles. These factors tended to
fall into two categories- factors that related to Enforcement's internal
operations, such as a need for better internal communications, and factors
related to operations or resources outside of Enforcement's control. Lengthy
processes within Treasury and the need for more resources for oversight are
examples of barriers in the latter category. The liaisons tended to cite
internal factors, while Enforcement and other bureau officials tended to
identify external factors.

31 Due to time constraints, for one bureau, we covered this topic only with
the liaison. 32 In the course of discussing other issues during the
interviews, officials also identified factors that they saw as hindering
Enforcement. Enforcement and Bureau

Officials Noted the Importance of Enforcement's Advocacy Role

Officials' Views on Barriers to Enforcement in Fulfilling Its Roles

Page 28 GAO- 01- 305 Office of Enforcement's Operations

Table 3 shows our categorization of the factors identified by the officials.
With the exception of the factor concerning Enforcement's needing more
resources, none of the 24 other factors were cited by more than 3 officials.
The need for more resources was cited as a barrier by seven officials.

Page 29 GAO- 01- 305 Office of Enforcement's Operations

Table 3: Factors Identified by Enforcement and Bureau Officials as Having
Been a Barrier to Enforcement in Fulfilling Its Roles

Categorization of factors Factors Internal

Administrative Enforcement always starting from scratch- does not think
about data already have or who to request data from Poor communication
within Enforcement Enforcement is slow to move paper Lack of time Staff not
co- located with the Deputy Assistant Secretary who oversees them

Management and staff Political appointees pressing own agenda Too heavy a
reliance on detailees from the bureaus who have divided loyalties- that is,
to their bureaus and to Enforcement Enforcement's lack of desire to push or
be on the vanguard of issues Enforcement management tends to work on the
subjects that they know best- criminal law enforcement, not regulatory
enforcement Enforcement management lack of experience. For example, these
managers lack

budget and management backgrounds when appointed; therefore, they have long
learning curves

law enforcement background and experience Lack of continuity between
administrations and, therefore, downtime

Other Temporary circumstances (e. g., loss of a staff member)

External

Administrative issues Lengthy processes within Treasury Need more flexible
hiring and a quicker hiring process Getting positions authorized through the
Office of Management Enforcement needs more resources

for OF& A to analyze budgets and strategic plans

for oversight and/ or policy

to keep the Under Secretary and Assistant Secretary informed of issues Need
for additional support from other Treasury offices Need more effort from
Office of Legislative Affairs

Shortage of resources in Office of Public Affairs affects its ability to
support Enforcement Under Secretary's and/ or Enforcement's lack of status/
priority in Treasury Tough for some Treasury Secretaries to understand that
certain bureaus serve other departments and agencies and to provide
resources commensurate to that service

Insufficient/ Unclear authority to do job Lack of control over bureaus'
budgets, actual or perceived Under Secretary's or Deputy Assistant
Secretary's lack of line or chain of command authority over the bureaus;
cannot tell the bureaus what to do The role that the Under Secretary should
play and what the Under Secretary should do is murky

Page 30 GAO- 01- 305 Office of Enforcement's Operations

Categorization of factors Factors

Murky relationship between Under Secretary and bureaus Under Secretary
position does not seem to have the clout that the Attorney General has a
Enforcement seems to have no clout with Congress

Other Lack of interest in compliance measurement by non- Treasury agencies
and organizations (e. g., OMB and the Congress) a When discussing these
factors with Enforcement officials, they noted that the Attorney General

position is a cabinet- level position, whereas the Under Secretary position
is not. Source: Factors cited during interviews with Enforcement and bureau
officials. GAO developed the specific categories on the basis of these
factors.

Enforcement officials indicated that Enforcement had taken actions to try to
mitigate some of the barriers that were identified. For example, regarding
the view that the Under Secretary does not seem to have enough clout, an
Enforcement official said that each Under Secretary has tried to raise the
profile of the office and to reach out and develop relationships with his
counterparts in other departments. The official agreed that Treasury
processes can be lengthy, particularly the clearance processes. The official
said that Enforcement tries to identify the highest priority items and that
Enforcement staff ensure that others in Treasury understand the priority and
process the items as quickly as possible. Regarding the belief that there is
a lack of continuity between administrations, Enforcement officials noted
that Enforcement has increased the number of career staff in its office to
ensure that there are staff who have a historical knowledge of how
Enforcement works and what the bureaus do.

Enforcement officials provided us with other examples of Enforcement's
taking actions to mitigate some of the cited barriers. Related to the view
that Enforcement needs more effort from the Office of Legislative Affairs,
an Enforcement official said that in the past, Enforcement has detailed
bureau staff to the Office of Legislative Affairs and has offered to give
this office one of Enforcement's FTEs. Additionally, the official said that
Enforcement has invited the Office of Legislative Affairs staff to attend
the Enforcement staff meetings. Regarding Enforcement's lack of control over
bureaus' budgets, the official discussed Enforcement's advocacy efforts both
within Treasury and at OMB, which includes educating the Office of
Management on the bureaus' needs. Enforcement Officials

Identified Efforts to Address Cited Barriers

Page 31 GAO- 01- 305 Office of Enforcement's Operations

No comprehensive source provided guidance to either Enforcement staff or the
bureaus on the circumstances under which bureaus are required to interact
with Enforcement. In addition, established documentation did not exist for
12 of the 29 circumstances under which the bureaus are required to interact
with Enforcement, and when it did exist, the documentation was generally
broad in nature and did not provide explicit information on the expected
interaction between the bureaus and Enforcement. About one- half of the
bureau officials we interviewed said that they were not aware of written
requirements for their bureaus' interactions with Enforcement or that they
knew when to interact through such factors as their professional
responsibility, experience, judgment, or common sense.

An agency's internal control needs to be clearly documented and that
documentation should be readily available for examination. Without a clearly
defined and documented set of policies and procedures covering operational
and communications activities, Enforcement runs the risk of not being able
to perform its functions and meet its goals efficiently. Furthermore, since
a number of Enforcement and bureau positions are political appointments that
are subject to turnover with a change in administration, a clearly defined
and documented set of policies and procedures could smooth transitions.

We recommend that the Secretary of the Treasury direct the Under Secretary
(Enforcement) to strengthen internal control by developing a policies and
procedures manual to ensure that the policies and procedures on the
circumstances under which the bureaus are to interact with Enforcement are
clearly defined, documented, and readily available for examination by bureau
officials and others.

We requested comments on a draft of this report from the Secretary of the
Treasury. On February 22, 2001, the Acting Under Secretary (Enforcement)
provided written comments conveying Enforcement's agreement with our
recommendation. This letter is reproduced in appendix III. The Acting Under
Secretary stated that Enforcement has initiated a project to plan and
develop an Enforcement policies and procedures manual, and that Enforcement
is working with bureau personnel to ensure that the end product is a
meaningful document. He noted that the proposed manual would contain a
subsection with specific direction and guidance for the liaisons assigned to
Enforcement from each bureau. Conclusions

Recommendation for Executive Action

Agency Comments

Page 32 GAO- 01- 305 Office of Enforcement's Operations

We are providing copies of this report to the Honorable Paul H. O'Neill,
Secretary of the Treasury, and James F. Sloan, Acting Under Secretary
(Enforcement). We will also make copies available to others upon request.

The major contributors to this report are acknowledged in appendix IV. If
you or your staff have any questions concerning this report, please call
Weldon McPhail or me on (202) 512- 8777.

Laurie E. Ekstrand Director, Justice Issues

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 33 GAO- 01- 305 Office of Enforcement's Operations

To determine what projects or activities the Department of the Treasury's
Office of Enforcement had undertaken to provide oversight, policy guidance,
and support to law enforcement bureaus, we administered a data collection
instrument (DCI) to Enforcement officials. We asked these officials to
provide information on the projects and ongoing efforts (i. e., continuous
projects with no fixed end date) that Enforcement staff had engaged in to
carry out its responsibilities from October 1, 1998, to June 30, 2000. 1 We
specifically asked Enforcement officials to complete a DCI for up to five
projects or ongoing efforts that were related to each of the strategic goals
supported by either Enforcement or the bureaus it oversees. The DCI
responses may not be representative of all projects or ongoing efforts that
Enforcement engaged in during this period. The DCIs were completed between
October 2, 2000, and November 9, 2000, and the data are current as of the
date each DCI was completed and returned to GAO.

Table 4 shows (1) Treasury's 4 missions and the 10 strategic goals that
Enforcement and the bureaus support and (2) the 49 projects and ongoing
efforts that were reported in the DCIs. Enforcement officials identified and
completed between 2 and 10 DCIs for each of the strategic goals. The names
of the projects and ongoing efforts that the Enforcement officials provided
in the DCIs are listed in the last column of the table, and these officials'
detailed responses to the individual DCIs are shown after the table. We did
not make editorial changes to the officials' DCI responses.

1 Enforcement officials were to select projects or ongoing efforts that were
in place as of October 1, 1998, or that began on or after October 1, 1998,
and before July 1, 2000, including projects still under way when the DCI was
completed. Appendix I: Selected Projects and Ongoing

Efforts Relating to Enforcement's Oversight, Policy Guidance, and Support
Roles

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 34 GAO- 01- 305 Office of Enforcement's Operations

Table 4: Enforcement Projects and Ongoing Efforts Related to Treasury's
Missions and Strategic Goals That Are Supported by Enforcement and the Law
Enforcement Bureaus

Mission Strategic goal Project or ongoing effort

Promote domestic economic growth 1. Customs Automated Commercial

System/ Environment 2. Treasury Advisory Committee on the Commercial

Operations of the Customs Service (COAC) 3. International Trade Data System
Economic: Promote prosperous

and stable American and world economies

Maintain U. S. leadership on global economic issues 4. Stolen Cars/ Mexico

5. Child Labor Advisory Committee 6. G7 Customs Standardization Initiative
7. North American Free Trade Agreement (NAFTA)

Working Group on Rules of Origin Financial: Manage the government's finances
Collect revenue due to the federal

government 8. Alcohol Regulation 9. Interagency Commission on Crime and
Security in US

Seaports Combat financial crimes and money laundering 10. National Summit on
Identity Theft

11. Promotion of International Anti- Money Laundering Standards 12.
Identification of Non- Cooperative Countries and

Territories 13. National Money Laundering Strategy 14. Black Market Peso
Exchange Anti- Money Laundering

Working Group Reduce the trafficking, smuggling, and use of illicit drugs
15. General Counterdrug Intelligence Plan- Development

Phase 16. Report to Congress on Southwest Border 17. Annual Narcotics
Certification 18. General Counterdrug Intelligence Plan-

Implementation 19. Foreign Narcotics Kingpin Designation Act 20. US- Mexico
High Level Contact Group for Drug Control 21. Plan Colombia Fight violent
crime 22. National Church Arson Task Force

23. National Special Security Events 24. Five- Year Counterterrorism Plan
25. 2001 Terrorism Supplemental 26. Commerce in Firearms (CIF) Report and
Regulatory

Enforcement Project 27. National Criminal Instant Background Check System

(NICS) 28. Gun Show Report 29. Modified Assault Rifles Import Ban 30. YCGII
and Anti- trafficking 31. Firearms Legislation Law Enforcement: Protect our

financial systems and our nation's leaders, and foster a safe and drug- free
America

Protect our nation's leaders and visiting world leaders 32. 2000 Campaign

33. Secret Service- Agent Review 34. Secret Service- Uniformed Division
Review 35. International Monetary Fund (IMF) and the World

Bank Spring Ministerial Meeting

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 35 GAO- 01- 305 Office of Enforcement's Operations

Mission Strategic goal Project or ongoing effort

Provide high- quality training for law enforcement personnel 36. Training
Group

37. Map of the World (MTW) 38. International Law Enforcement Academies 39.
Federal Law Enforcement Training Center (FLETC)

Organizational Assessment and Implementation Improve management operations
40. Establishment of the Office of Professional

Responsibility (OPR) 41. Schedule B 42. Retirement Bubble 43. Pay
Demonstration Project 44. Senior Executive Service (SES) Review Management:
Continue to build

a strong institution Improve program performance 45. Customs Service
Internal Affairs Review

46. Iran Document Destruction Report 47. Assessment of US Customs Service
Passenger

Enforcement Targeting Program 48. Treasury/ Department of Justice (DOJ)
Parity Review 49. Selection of Law Enforcement Bureau Heads

Source: Department of the Treasury Strategic Plan for Fiscal Years 1997-
2002, September 30, 1997;

Department of the Treasury Program Performance Report, Fiscal Year 1999; and
Enforcement DCI responses.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 36 GAO- 01- 305 Office of Enforcement's Operations 1. Customs Automated
Commercial System/ Environment

Mission and goal supported Economic mission: Promote domestic economic
growth Primary responsibility Deputy Assistant Secretary (Regulatory, Trade
and Tariff Enforcement) (DAS (RT& T)) Primary role Support Purpose The
Automated Commercial Environment (ACE) is a new system intended to meet the

need of Customs to manage trade risks and modernize operations to keep pace
with the staggering growth of international trade, advancements in
automation, and the requirements of the Customs Modernization Act. ACE would
eventually replace, the Automated Commercial System (ACS), the existing
outdated and failing Customs import trade system. The purpose of this
project is to secure a reliable stream of funding from system users to
support replacement of the current obsolete system with ACE and to keep the
new system up to date. How project initiated Self- initiated Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (RT&
T), Customs Service, Office of Management

? Office of Management and Budget (OMB)

? Private sector Why Enforcement was involved OE oversaw this project to
search for funding solutions. The Customs Commissioner saw

his responsibility as identifying the need and technology for automation
enhancement rather than becoming involved in finding funding solutions.
Functions Enforcement performed ? Collected data on use of Customs automated
commercial system in order to evaluate

options for funding a new system with support from users.

? Options for funding a new automated system with user support were revised
at Treasury with no bureau involvement. All briefing materials were prepared
by Enforcement staff.

? Briefed OMB, Congressional staff, and Treasury officials.

? Developed strategies for informing and seeking approval of funding
proposals.

? Committee reports are prepared by committee members and submitted to
Congress.

? Long term monitoring of and involvement in Customs' use of automated
systems to process commercial transactions quickly and to maintain high
levels of compliance with trade laws.

? Reviewed all testimony and most correspondence with Congress on the
development of a new automated system.

? In addition to development of legislature proposals for funding ACE with
user support, reviewed all Customs budget submissions to assure that
Customs' case was stated most effectively.

? Coordinated with OMB on funding issues.

? Handled virtually all correspondence for Secretary on Customs automation
problems.

? Frequent speaker to trade groups in support of funding for Customs
automation. Project duration Start date: January 1997

No fixed end date Enforcement staffing level on the project 1 staff member
who spent 10 to less than 25 percent of his/ her time on the project.
Project results Trade groups have pinned their hopes on persuading Congress
to fund a new automated

system entirely out of appropriated funds. The appropriation for FY 2000 is
zero, the expected appropriation for FY 2001 is $130 million. But this is
$80 million less than requested in the President's budget and well below the
amount needed to complete ACE in a reasonable time frame. Consequently, the
trade community is increasingly willing to agree to provide direct funding
support through some user fees.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 37 GAO- 01- 305 Office of Enforcement's Operations 2. Treasury Advisory
Committee on the Commercial Operations of

the Customs Service (COAC)

Mission and goal supported Economic mission: Promote domestic economic
growth Primary responsibility Assistant Secretary (Enforcement) Primary role
Policy development and guidance Purpose To assure that there is an active
channel of communication between the Treasury and

businesses affected by Customs' operations. How project initiated Self-
initiated and statutory requirement: the Advisory Committee was initially
established

by legislation and subsequently continued by Treasury initiative. Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (RT& T), Customs Service, Office of
General Counsel

? None

? Private sector- twenty members of the Committee are from the private
sector Why Enforcement was involved The Chairman of the Senate Finance
Committee concluded that the Customs Service

was not responding to the private sector views, and established a Federal
advisory committee to be chaired by Treasury. Functions Enforcement
performed ? Information on Customs programs is collected in order to respond
to Committee

questions and comments.

? With assistance from Customs, briefings and background papers are prepared
for agenda items for each quarterly Committee meeting. Papers are presented
to all committee members as appropriate.

? Assistant Secretary (Enforcement) and occasionally other government
officials are briefed prior to meetings.

? Agenda for meetings are developed by Enforcement staff.

? Oversee activities of Advisory Committee.

? Review Committee reports to Congress, briefing papers, speeches prepared
for Treasury officials, and other information concerning activities of the
Committee.

? Depending on the issue, other agencies may have an interest in Committee
topics. When this occurs, OE often coordinates with those agencies. For
example, OE and the Committee were instrumental in resolving a dispute
between the private sector, Customs Service, and Census Bureau over the
design for a new automated export system.

? OE prepared speeches and remarks for Treasury officials on activities of
Committee. OE staff also drafted Assistant Secretary remarks for each
Committee meeting. The Secretary and Deputy Secretary have provided remarks,
prepared by OE staff, to the Committee.

? Assistant Secretary (Enforcement) and other Enforcement staff are invited
to speak at trade events held in conjunction with committee materials.

? OE performs staff work of Advisory Committee, including scheduling
arrangements for Committee meetings, preparing agenda, arranging for guest
speakers, preparing reports of meetings, etc. Project duration Start date:
September 1988; No fixed end date Enforcement staffing level on the project
5 or 6 staff members who spent 10 to less than 25 percent of their time on
the project. Project results The Advisory Committee has improved
communication among businesses, Customs, and

Treasury on Customs issues. Given the length of time the Committee has been
in existence, it is not practical to list all of its accomplishments.
Biennial reports are submitted to the Committee on Ways & Means, and the
Committee on Finance. These reports detail the activities of the Committee.
Among other things, the Advisory Committee has had a substantive role in
Customs' reorganization, on the design for the Automated Export System
(AES), and on Customs' policies and procedures for compliance assessment
audits.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 38 GAO- 01- 305 Office of Enforcement's Operations 3. International
Trade Data System

Mission and goal supported Economic mission: Promote domestic economic
growth Primary responsibility DAS (RT& T) Primary role Policy development
and guidance Purpose To create a coordinated, government wide system for the
collection, use, and

dissemination of information related to commerce across our national
borders. The system will include information about the cargoes, the
conveyances in which they are transported, and where applicable, the
personnel involved in the transportation of goods (to support enforcement of
immigration laws). The system will also be designed to accommodate the
eventual inclusion of data on certain aspects of non- goods trade. How
project initiated Presidential initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (RT&
T), Customs Service, Office of Management

? Department of Defense, Department of Transportation, Coast Guard, Drug
Enforcement Administration (DEA), Immigration and Naturalization Service
(INS), OMB, Department of Agriculture, Department of Commerce, Department of
the Interior, Department of Health and Human Services, USITC

? Private sector Why Enforcement was involved Customs attempted to lead an
interagency effort, but failed to win the support of the other

agencies involved. In early 1995, the other agencies communicated to the
Office of Management and Budget their disinclination to continue the project
under Customs leadership. In September of 1995, the leadership
responsibility was assigned to Treasury's Office of Enforcement in a
memorandum from the Vice President to all departments and agencies.
Functions Enforcement performed ? Prepared briefing materials to explain
purpose of project and briefings on the status of

design and implementation plans.

? Conducted briefings for Executive Office of the President, Treasury, and
other executive branch officials, and for members of Congress and staffs.

? Substantial amount of time spent in planning for ratification of
International Trade Data System (ITDS) by participating agencies and the
private sector, and for obtaining support from Congress.

? As chairman of interagency board, DAS, RT& T was responsible for
monitoring progress of ITDS project office toward achievement of goals set
by the board.

? Reviewed draft proposals for project design and implementation, as well as
briefing materials to seek broad support for project.

? Participated in preparation of annual budgets for ITDS project.

? ITDS is an interagency project with implications for almost 100 government
agencies that regulate international trade or collect statistics on
international trade. Considerable coordination was necessary among the
involved agencies.

? Required to negotiate with other agencies on ITDS design and
implementation plans.

? Prepared correspondence for members of Congress and private sector parties
who were seeking information about the ITDS; wrote speeches for DAS,
Regulatory Tariff & Trade to present to trade groups.

? Speeches to several trade groups between 1995 and August 1999. Project
duration Start date: September 1995

Anticipated end date: December 2001 Enforcement staffing level on the
project 2 staff members who spent 25 to less than 50 percent of their time
on the project. Project results The interagency ITDS Board successfully
completed the government- wide trade data

system project design architecture. The work on developing the prototype is
on- going; however, progress has been delayed by automation problems at the
Customs Service.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 39 GAO- 01- 305 Office of Enforcement's Operations 4. Stolen Cars/
Mexico

Mission and goal supported Economic mission: Maintain U. S. leadership on
global economic issues Primary responsibility DAS (RT& T) Primary role
Support Purpose Mexican officials contacted OE with their concerns about the
economic impact to the

legitimate market as the result of illegal vehicles from the United States
appearing in Mexico. Officials estimated that between 1/ 3 and 1/ 2 of all
automobiles imported into Mexico are imported illegally. The Mexican
government requested Treasury assistance in arranging for Mexican Customs to
be provided with NCIC data from the Federal Bureau of Investigation (FBI) on
U. S. stolen cars. Mexican Customs could then stop apparent violators and
forward the information to U. S. Customs for consideration of possible
enforcement action against smugglers. How project initiated Self- initiated
Parties involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (RT& T), Customs Service

? FBI

? State and/ or local government- Texas Department of Public Safety, private
sector- National Insurance Crime Bureau Why Enforcement was involved Mexican
government officials requested assistance from Treasury Enforcement to

coordinate with Customs and the FBI come to a solution to resolve problem.
Functions Enforcement performed ? Collected VINS for cars smuggled into
Mexico.

? Prepared background materials for Under Secretary on issue.

? Under Secretary briefed Secretary on Mexican government request for
assistance.

? Worked with the FBI, U. S. Customs, and Mexican Customs to develop
procedures for the transfer of FBI stolen car data to Mexican Customs in a
manner satisfactory to the FBI.

? Resolved differences between FBI and Customs as to procedure for
addressing problem. Also coordinated with Mexican Customs to analyzing
Mexican data on smuggled cars and with the Texas State Department of Public
Safety.

? Negotiated with Mexican government to obtain their concurrence with
Enforcement program proposals for addressing both stolen and smuggled cars.
Project duration Start date: April 1998

Anticipated end date: December 2000 Enforcement staffing level on the
project 1 staff member who spent less than 10 percent of his/ her time on
the project. Project results Results of program will be seen within next 90
days. Results will include data on cars

stolen in U. S. and stopped by Mexican customs, as well as penalty actions
against U. S. parties involved in smuggling cars into Mexico. OE efforts in
this project have had a positive influence on Treasury and Customs relations
with Mexican government officials and we expect future cooperation and
assistance from Mexico on a number of issues of concern to Treasury.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 40 GAO- 01- 305 Office of Enforcement's Operations 5. Child Labor
Advisory Committee

Mission and goal supported Economic mission: Maintain U. S. leadership on
global economic issues Primary responsibility Assistant Secretary
(Enforcement) Primary role Policy development and guidance Purpose
Treasury's Advisory Committee on International Child Labor Enforcement was
established

to promote the dialogue between the government and citizens, organizations,
firms, etc., concerned with the problem of goods manufactured with forced or
indentured child labor being imported into the United States, and to focus
attention on the issue of international child labor enforcement. How project
initiated Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (RT& T), Customs Service, Office of
General Counsel

? Department of State, Department of Labor, USTR, National Economic Council,
and Members of Congress

? Foreign governments, private sector- committee members include private
sector representatives Why Enforcement was involved At the Departmental
level, OE is able to bring to the issue a higher visibility both within the

Administration and with the private sector. This issue is broader than just
a Customs Service issue and OE is able to provide a broader perspective.
Working with the White House and Congress, OE was able to help Customs get
increased funding for its child labor enforcement efforts. Functions
Enforcement performed ? OE staff collected data/ material on potential
suspect imports from USCS as well as

other general data from private sector and other agencies.

? Prepare background material for senior Treasury officials and members of
the Advisory Committee.

? Brief senior Treasury, Congressional, and White House officials, as well
as member of the Advisory Committee on Administration, Treasury and Customs
child labor efforts and committee progress.

? Produced Child Labor “Red Flags” Advisory for the import
community and others with information on the issue of forced or indentured
child labor.

? Worked with Customs and counsel to revamp Customs regulations with regard
to seizure of goods made with ‘slave labor', including child slave or
indentured labor.

? Draft reports, advisories, and informational materials for senior
officials, business community, and concerned citizens.

? Chair and oversee activities of the Advisory Committee.

? Review draft testimony by Customs and other agencies on child labor
issues. Senior OE officials also reviewed red flag advisory drafted by OE
staff.

? Assisted with, reviewed and supported proposals for increased finding for
USCS Child Labor Enforcement efforts.

? Regular coordination and consultation with Labor, State, NEC, USTR and
congressional staff.

? Negotiate with officials of foreign country agencies to enforce Child
Labor Import standards.

? Prepared speeches for senior Treasury officials, including the Secretary
and Deputy Secretary, dealing with Child Labor.

? OE staff has participated in outreach efforts with business community.

? OE performs staff work of Advisory Committee, including scheduling
arrangements for Committee meetings, preparing agenda, arranging for guest
speakers, preparing reports of meetings, etc. Project duration Start date:
January 1998

No fixed end date

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 41 GAO- 01- 305 Office of Enforcement's Operations

Enforcement staffing level on the project 7 staff members who spent 10 to
less than 25 percent of their time on the project. Project results Since
this project began two years ago, there have been a number of successes:

- Production of Red Flag Advisory - Increased Child Labor Enforcement Budget
for Customs Service:

- $10,000,000 in President's budget for FY 2002 - $ 5,000,000 for FY 2000 -
$ 3,000,000 for FY 1999 - Increased attention to Child Labor Issues -
Enhanced USCS Child Labor Enforcement - Promoted understanding of opposing
positions between Industry and Advocates - Revamped Customs regulations with
regard to seizure and forfeiture of goods made with ‘slave labor',
including child slave or indentured labor.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 42 GAO- 01- 305 Office of Enforcement's Operations 6. G7 Customs
Standardization Initiative

Mission and goal supported Economic mission: Maintain U. S. leadership on
global economic issues Primary responsibility DAS (RT& T) Primary role
Policy development and guidance Purpose To simplify and standardize Customs
Service electronic reporting of data. How project initiated Self- initiated
Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (RT& T), Customs Service

? Department of Transportation, Department of Commerce, US Trade
Representative

? Foreign governments, private sector Why Enforcement was involved OE was
able to bring to this effort a broader perspective than Customs could by
itself and

OE is in a better position to coordinate and negotiate inter- Departmental
and multilateral issues. Functions Enforcement performed ? Collected
information on reporting data from Customs and other federal agencies.

? Prepared briefing materials for senior Treasury officials.

? Briefed senior Treasury officials, private sector, and USCS.

? Developed strategy for advancing this project with G7 country
participants.

? Coordinated proposed data requirements with Customs, Commerce,
Transportation, and USTR.

? Negotiated with other G7 countries as well as World Customs Organization
and European Commission.

? Prepared correspondence and communications with other Federal agencies and
with representatives of other G7 Countries.

? Delivered speeches to private sector organizations on new data
requirements. Project duration Start Date: March 1997

Anticipated end date: June 2001 Enforcement staffing level on the project 2
staff members who spent 25 to less than 50 percent of their time on the
project. Project results The G7 Standardization Initiative Project is still
underway. However, OE expects to

achieve standardized reporting requirements for electronic data and EDIFACT
Customs messages.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 43 GAO- 01- 305 Office of Enforcement's Operations 7. North American
Free Trade Agreement (NAFTA) Working

Group on Rules of Origin

Mission and goal supported Economic mission: Maintain U. S. leadership on
global economic issues Primary responsibility DAS (RT& T) Primary role
Policy development and guidance Purpose 1) Liberalize, simplify North
American Free Trade Agreement (NAFTA) Rules of Origin

2) Ensure smooth operation of NAFTA Rules of Origin and Customs Procedure
How project initiated Statutory requirement: NAFTA Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (RT& T), Customs Service, Office of
General Counsel

? Department of State, OMB, Department of Commerce, International Trade
Commission

? Foreign governments, private sector Why Enforcement was involved OE leads
Treasury's efforts with regard to NAFTA implementation, as this is an
extremely

high visibility issue that requires considerable coordination and
consultation with other Federal agencies and foreign governments. Functions
Enforcement performed ? Prepared briefing materials on NAFTA implementation
efforts.

? Briefed senior Treasury officials, members of Congress, and the private
sector on efforts.

? Developed regime for simplifying NAFTA rules of origin and Customs
procedures.

? Developed Treasury policies and subsequent regulations regarding
implementation of NAFTA.

? OE oversaw the United States, Mexican, and Canadian implementation of
NAFTA regulations related to Customs.

? OE reviewed draft policies, implementation strategies, and draft
regulations relating to NAFTA implementation.

? The Office coordinated with the Departments of Commerce and State, the
USTR, and other agencies with an interest in NAFTA implementation.

? Considerable consultations with Mexican and Canadian counterparts on NAFTA
implementation procedures. Project duration Start date: January 1998

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 10 to less than 25 percent of their time on the project. Project
results OE coordination efforts led to a simplification of NAFTA chartered
rules and rules of origin

and a liberalization of related rules. OE ensured the smooth implementation
of new rules, regulations, and customs procedures. OE officials also
developed successful working relationships with officials in other Federal
agencies, as well as Canada and Mexico, to resolve disputes and implement
NAFTA policies.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 44 GAO- 01- 305 Office of Enforcement's Operations 8. Alcohol
Regulation

Mission and goal supported Financial mission: Collect revenue due to the
federal government Primary responsibility DAS (RT& T) Primary role Oversight
Purpose Prompted by OE attention to public and judicial concerns, OE
initiated regular oversight of

the Bureau of Alcohol, Tobacco and Firearms (ATF) alcohol regulation
functions, with particular attention to business practices/ competition,
regulations, health- related labeling, and informative labeling. How project
initiated Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (RT& T), ATF, Customs Service,
Office of General Counsel

? Department of Justice, FTC

? Foreign governments, private sector Why Enforcement was involved OE is
able to provide a broader perspective, particularly on crosscutting issues
that

require outreach with private sector organizations and other Federal
agencies. Functions Enforcement performed ? Prepared background and briefing
materials on health labeling and other regulatory

issues.

? Briefed senior Treasury officials.

? OE developed revised policy and substantially drafted the amended
regulations for regulation of Business Practices/ Competition in the
beverage alcohol industry.

? Oversaw process for publication in the Federal Register and implementation
of new regulations by ATF.

? Coordinated with FTC and Justice in review of the business competitive
policy. Also, considerable consultation and negotiation with industry
representatives. Project duration Start date: February 1994

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 10 to less than 25 percent of their time on the project. Project
results ? Revised Competitive Policy/ Regulations

? Revised permissible Label Health Claims

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 45 GAO- 01- 305 Office of Enforcement's Operations 9. Interagency
Commission on Crime and Security in US Seaports

Mission and goal supported Financial mission: Collect revenue due to the
federal government Primary responsibility Assistant Secretary (Enforcement)
Primary role Policy development and guidance Purpose To develop and
facilitate an interagency commission to study crime and terrorism at our

nation's seaports, and to develop and implement recommendations to address
these problems. How project initiated Presidential initiative Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (Enforcement Policy), DAS (Law Enforcement), DAS (RT& T), ATF, Customs
Service, Secret Service, Counsel

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, FBI, INS, National Security
Council, OMB, Office of National Drug Control Policy (ONDCP), Department of
Commerce, Joint Chiefs, EPA, Department of Agriculture, Department of Labor,
CIA, Department of Health and Human Services, U. S. Congress

? State and/ or local governments, private sector Why Enforcement was
involved A Presidential Order directed the Departments of the Treasury,
Justice and

Transportation to develop and oversee a Commission on Crime and Security in
US Seaports. Treasury, through Enforcement, took the lead in coordinating
the establishment of the Commission. Functions Enforcement performed ?
Gathered information about the cost of establishing the Commission, staff
available to

support the Commission, the points of contact for the other lead agencies,
and identified possible Commission members. Briefings and public hearings
were held at numerous locations around the United States to obtain input
from affected groups.

? Briefing materials were prepared for the Secretary to explain the
establishment of the Commission, and later to obtain approval of the
Commission's final report. The Assistant Secretary, who was a member of the
Commission, received briefing materials in preparation for meetings of the
Commission, to analyze the Commission's proposed recommendations, and to
summarize the material in the final report.

? The Assistant Secretary and Under Secretary were briefed about the
proposal to establish the Commission, the proposed structure and
organization of the Commission and its staff, the progress of the
Commission, and the Final Report of the Commission. The Assistant Secretary
also participated in briefings for members of Congress on the work of the
Commission.

? Initiatives and recommendations were developed for the Assistant Secretary
to recommend to the Commission.

? Much of the work of the Commission was performed by its staff. Throughout
the oneyear operation of the Commission, Enforcement monitored the progress
and activities of the staff to ensure that the work remained on course. The
Assistant Secretary also attended all Commission meetings, since she served
as a member of the Commission.

? Numerous drafts of the report, as well as the Final Report of the
Commission were reviewed and edited.

? In leading the process of establishing the Committee, Enforcement had to
determine the costs to operate the Commission and find funding to cover
these costs. The recommendations contained in the Final Report have budget
implications. Treasury is currently working with OMB regarding funding for
these recommendations.

? The Office of Enforcement coordinated with the NSC regarding the
development and wording of the Presidential Order that established the
Commission, the press release announcing the Order, as well as the
subsequent clearance and announcement of the Commission's report. The
Commission was organized and established by representatives of the
Departments of Justice, Transportation, and the Treasury under the lead of
the Office of Enforcement. This involved numerous telephone calls, chairing

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 46 GAO- 01- 305 Office of Enforcement's Operations

many organizing sessions, harmonizing positions, and reaching consensus on
the membership, operation, procedures and plan of action of the Commission.
The Assistant Secretary served as a member of the Commission, which involved
reviewing numerous background documents, attending monthly meetings,
visiting three seaports for on- site briefings and meetings, participating
in public hearings, and coordinating with the other Commissioners to develop
the recommendations contained in the Commissions' Final Report.

? Findings and recommendations were negotiated by the members of the
Commission during Commission meetings.

? Letters were drafted from the three cabinet officials to the others
departments and agencies named in the Presidential Order to solicit their
participation in the Commission.

? Enforcement staff attended Commission meetings, coordinated comments from
all components of Enforcement and Treasury on the draft Commission Report,
coordinated transmission of the Report to the White House, and provided
information to Treasury Public Affairs and Legislative Affairs Offices.
Enforcement is currently considering implementation plan for the
recommendations contained in the report. Project duration Start date:
November 1998

End date: October 2000 Enforcement staffing level on the project 5 staff
members who spent less than 10 percent of their time on the project. Project
results The final report of the Commission was prepared, reviewed and
approved by the three

lead Departments, transmitted to the White House, and is now at OMB for
review and adoption of the Commission's recommendations. The recommendations
of the Commission will significantly improve the security of the nation's
seaports while also enhancing information and revenue collection
capabilities.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 47 GAO- 01- 305 Office of Enforcement's Operations 10. National Summit
on Identity Theft

Mission and goal supported Law enforcement mission: Combat financial crimes
and money laundering Primary responsibility DAS (Enforcement Policy) Primary
role Oversight Purpose Responding to a Presidential directive, organize an
interagency group to plan and

conduct the National Summit on Identity Theft. Thereafter, participate in
other agencies' workshops on prevention and victim assistance, and supervise
the Secret Service as it works with DOJ to conduct a workshop on law
enforcement responses to identity theft. How project initiated Presidential
initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), Finance and Administration, Financial Crimes
Enforcement Network (FinCEN), Internal Revenue Service's Criminal
Investigation Division (IRS/ CID), Secret Service, Office of Management,
Secretary, Deputy Secretary, Domestic Finance, Public Affairs, Office of
Comptroller of the Currency, General Counsel, Office of Information
Technology

? Department of Justice, FBI, OMB, Federal Trade Commission, Social Security
Administration, U. S. Postal Inspection Service, Federal Deposit Insurance
Corp., White House/ OMB, U. S. Sentencing Commission, Federal Reserve Board,
Office of Thrift Supervision

? State and/ or local governments, foreign governments, private sector Why
Enforcement was involved The President directed Treasury to organize the
Summit. The Secret Service is the

Treasury bureau most involved in the issue, given its mission of combating
financial crime. Enforcement took the lead role since the issues involved
more than the Secret Service's law enforcement perspective. Functions
Enforcement performed ? The Secret Service provided information on its
identity theft cases and programs.

? In addition to regular decision and information briefings for the Under
Secretary, staff developed memoranda for the Secretary and Deputy Secretary.

? Staff briefed Deputy Secretary Eizenstat, who ultimately was not able to
participate in the Summit.

? Enforcement coordinated the development of initiatives for the Summit,
including not only the announcement of Secret Service database programs and
cooperation with industry, but also pressuring the credit reporting bureaus
to change their ways of doing business. The credit bureaus issued a press
release on the eve of the Summit, promising to ease the process for identity
theft victims.

? Edit contractor's draft summary of Summit proceedings and publish on
Treasury web site.

? Enforcement worked with management to hire and interact with the
contractor selected to run the invitation process and space arrangements.

? Enforcement staff reviewed counsel's drafts of correspondence to the U. S.
Sentencing Commission, and Public Affairs' draft press releases and press
plans. Staff and counsel reviewed testimony and legislative proposals.

? Reviewed budget proposals developed by the Office of Management for
funding Summit.

? A large interagency group organized the Summit. Enforcement coordinated
all the logistics and hired the contractor to serve as a liaison with the
hotel and to handle invitations, and was in charge of one of five separate
panels. In three follow- on workshops scheduled for early FY 2001,
Enforcement is coordinating with other agencies, including Secret Service
who is planning one workshop as co- host with DOJ.

? Enforcement staff prepared invitation materials, agenda, and drafts of
remarks by the Secretary and Under Secretary for the Summit. Thereafter, we
drafted an interagency memorandum about the workshops.

? Under Secretary Johnson was a panelist at the Summit, and Assistant
Secretary

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Page 48 GAO- 01- 305 Office of Enforcement's Operations

Bresee introduced the Secretary before his opening remarks. Deputy Assistant
Medina hosted many of the Summit's sessions. Project duration Start date:
May 1998

Anticipated end date: November 2000 Enforcement staffing level on the
project 4 staff members who spent 25 to less than 50 percent of their time
on the project. In the

months leading up to the Summit, staff and the DAS (Enforcement Policy)
spent at least 75 percent of their time on the Summit. Project results ?
Successful National Summit on Identity Theft, involving over 300 attendees
over a day

and a half of sessions, receiving significant media coverage.

? Summit allowed sharing of public and private sector views, experiences,
ideas, and technological solutions leading to follow- on workshops.

? Proceedings available on web site, and in hard copy if requested.

? Follow on workshops to be held by FTC and SSA as announced in Federal
Register

? Supported changes to federal sentencing guidelines for identity theft
which will go into effect in November.

? Secret Service initiatives announced at Summit, including skimming and
check fraud databases, pilot project with Citicorp on e- commerce data
collection.

? Before the Summit, developed and coordinated Administration positions on
privacy vs. consumer convenience, emphasizing assistance to victims through
prevention and remediation after the crime occurs.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 49 GAO- 01- 305 Office of Enforcement's Operations 11. Promotion of
International Anti- Money Laundering Standards

Mission and goal supported Law enforcement mission: Combat financial crimes
and money laundering Primary responsibility Under Secretary (Enforcement)
Primary role Policy development and guidance Purpose The purpose of the
project is to work toward universal implementation of the 40

Recommendations of the Financial Action Task Force (FATF), including
maintaining active participation in the development, promotion, and
implementation of these standards; maintaining the United States' leadership
role in the FATF; furthering the establishment and development of FATF-
style regional bodies; and, providing assistance to jurisdictions seeking to
bring themselves into compliance. How project initiated Other a : In 1989,
the G- 7 Economic Summit established the FATF to develop anti- money

laundering standards and to promote worldwide implementation of those
standards. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (Enforcement Policy), DAS (Law
Enforcement), ATF, Customs Service, Executive Office of Asset Forfeiture
(EOAF), FinCEN, Federal Law Enforcement Training Center (FLETC), IRS/ CID,
Secret Service

? Department of Justice, Department of State, DEA, FBI, National Security
Council, ONDCP

? State and/ or local governments, foreign governments, private sector Why
Enforcement was involved This project involves major policy issues and
entails high level policy development

implications. Treasury's Office of Enforcement (OE) has the lead within the
U. S. government regarding anti- money laundering efforts; additionally, OE
heads the U. S. Delegation to the FATF, which is the international body
called upon by the G- 7 and G- 8 to take the lead in pursuing this
initiative on a global basis. Extensive interagency coordination is required
to reach consensus within the U. S. on the various issues involved and as to
what action should be taken with regard to each, as well as in determining
the nature and content of bilateral contacts to be made relative to these
issues. Functions Enforcement performed ? OE has collected data (and
continues to collect data) as required to accomplish the

objectives of this project. Data collection is coordinated with the
Departments of Justice and State, U. S. law enforcement and financial
institution regulatory agencies, other agencies, relevant international
organizations and bodies, and the foreign governments involved.

? OE prepares briefing materials for members of the U. S. interagency group
involved in this initiative, as well as for Secretary Summers and other
members of Treasury management, to facilitate the decision making process on
the various issues involved.

? Secretary Summers, Deputy Secretary Eizenstat, and others are briefed by
OE on the status and progress of this high priority initiative, as well as
on specific issues.

? OE devises programs, initiatives, and strategies as needed to accomplish
the goals of this project.

? Policies and standards are developed and drafted as required to accomplish
U. S. objectives relative to this project.

? OE drafts and prepares various reports and other submissions pursuant to
specific issues, taskings, and requirements to achieve the project goals.

? OE monitors the establishment, development and progress of the various
FATF- style regional bodies, as well as the work of the FATF itself.
Additionally, progress made by individual countries and governments around
the world is monitored in terms of the effectiveness of their anti- money
laundering regimes and the extent to which they meet international anti-
money laundering standards.

? Reports, statements, policy papers, legislation, regulations, guidelines,
and other relevant written products and documents are reviewed.

? Funding is sought to conduct assessments of the anti- money laundering
regimes of various governments, and to provide training and technical
assistance to aid governments in making necessary changes to bring them in
line with international anti-

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Page 50 GAO- 01- 305 Office of Enforcement's Operations

money laundering standards. Funding is also sought for contributions to the
FATF and the regional FATF- style bodies to enable them to continue their
work to accomplish the goals of this project.

? The interagency process is used to develop the U. S. position and make
decisions relative to issues, proposals, action plans, reports, and policies
to be advanced as a result of this initiative. OE has the lead in this
process.

? Within the FATF, the U. S. negotiates with other member governments to
determine policies and standards to be established and promoted, as well as
in development of the process and policies for taking forward this effort.
As Head of the U. S. Delegation to the FATF, OE takes the lead in conducting
these negotiations for the U. S. The U. S. has established and maintains a
leadership role within the FATF in formulating the policies of, and actions
taken by, the FATF. Further, extensive bilateral contact is conducted with
various jurisdictions (both FATF members and non- members) regarding
specific issues to obtain support, encourage action, assess deficiencies,
and/ or to provide assistance. Again, OE has the lead regarding these
contacts with respect to this initiative.

? OE prepares extensive correspondence relative to this project.
Correspondence is maintained with the FATF, member governments of the FATF,
the FATF- style regional bodies, members of the regional FATF- style bodies,
and non- member governments, as well as with the U. S. agencies and
departments involved in the interagency group participating in this
initiative. Speeches, talking points, press statements, and presentation
remarks are prepared for Secretary Summers, Deputy Secretary Eizenstat, and
others as needed relative to this project.

? The Head of the U. S. Delegation to the FATF and other members of the U.
S. delegation make substantial interventions during meetings of the FATF and
regional FATF- style bodies, as well as giving presentations at various
meetings, conferences, and other international events. In addition,
Secretary Summers, Deputy Secretary Eizenstat, the Under Secretary
(Enforcement), and others have testified relative to this initiative.
Project duration Start date: June 1989

No fixed end date Enforcement staffing level on the project 2 OE staff, plus
5 detailees from other agencies, 1 intern, and 1 administrative assistant

who spent 75 to 100 percent of their time on the project. Project results
Within the FATF, all 29 member governments now have comprehensive anti-
money

laundering legislation in place. Prior to the establishment of the FATF,
only a few governments in addition to the U. S. had established adequate
anti- money laundering regimes.

OE has taken a leadership role in the FATF and spearheaded efforts to work
with other governments to adopt anti- money laundering regimes. Largely due
in part to these efforts, over the past ten years, member and non- member
governments around the world have taken steps and continue to progress in
establishing effective anti- money laundering regimes consistent with the 40
recommendations of the FATF. Although substantial progress has been made, a
number of jurisdictions continue to fall short of the standards. Through the
work of the OE Money Laundering Task Force, efforts continue within this
project to effect universal implementation of the international anti- money
laundering standards. a Response categories included self- initiated,
statutory requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 51 GAO- 01- 305 Office of Enforcement's Operations 12. Identification
of Non- Cooperative Countries and Territories

Mission and goal supported Law enforcement mission: Combat financial crimes
and money laundering Primary responsibility Under Secretary (Enforcement)
Primary role Policy development and guidance Purpose The purpose of this
project is to identify jurisdictions that pose a money laundering threat

to the United States, support the efforts of the Financial Action Task Force
(FATF) to identify non- cooperative jurisdictions based on its 25 criteria,
take appropriate action with respect to identified financial crime havens,
and to prompt reforms by the identified jurisdictions to bring them into
compliance with international anti- money laundering standards. How project
initiated Self- initiated and other a : as a leader within the G- 7, the U.
S. Treasury Department, and

OE in particular with respect to money laundering policy, was critical to
formulating the initiative. OE continues to lead developments within
relevant multilateral fora. Initiated by G- 7 Finance Ministers at the
Birmingham Economic Summit to accelerate reforms in important financial
centers. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (Enforcement Policy), DAS (Law Enforcement), Customs Service, FinCEN,
IRS/ CID

? Department of Justice, Department of State, National Security Council,
ONDCP

? Foreign governments Why Enforcement was involved This project involves
major policy issues and entails high level policy development

implications. Treasury's Office of Enforcement (OE) has the lead within the
U. S. government regarding anti- money laundering efforts; additionally, OE
heads the U. S. Delegation to the FATF, which is the international body
called upon by the G- 7 and G- 8 to take the lead in pursuing this
initiative on a global basis. Extensive interagency coordination is required
to reach consensus within the U. S. on which jurisdictions should be
identified as problematic in this context and as to what action should be
taken with regard to each, as well as in determining the nature and content
of bilateral contacts to be made relative to this issue. Functions
Enforcement performed ? OE collected data (and continues to collect data) on
each jurisdiction reviewed or yet to

be reviewed to determine to what extent it meets the 25 criteria of the FATF
for identification as a non- cooperative. This data includes, but is not
limited to, laws, regulations, and practices of each jurisdiction relative
to its anti- money laundering regime, supervision/ regulation of its
financial services sector, and level of cooperation with foreign law
enforcement and financial regulatory entities. Data collection is
coordinated with the Departments of Justice and State, U. S. law enforcement
and financial institution regulatory agencies, relevant international
organizations and bodies, and the foreign governments involved.

? OE prepares briefing materials for members of the U. S. interagency group
involved in this initiative, as well as for Secretary Summers and other
members of Treasury management, to facilitate the decision making process on
the various issues involved.

? Secretary Summers and Deputy Secretary Eizenstat are briefed regularly by
OE on the status and progress of this high priority initiative.

? OE devises programs, initiatives, and strategies as needed to accomplish
the goals of this project.

? Advisories to U. S. financial institutions are drafted, cleared through
the interagency process, and issued on jurisdictions identified as non-
cooperative.

? Jurisdiction reports are prepared for submission to the FATF on
jurisdictions under review. These reports discuss in detail to what extent
each jurisdiction meets the FATF's 25 criteria and are the basis for
determining whether a jurisdiction is identified as non- cooperative.

? This project monitors progress made by identified non- cooperative
countries or territories (NCCTs) in addressing identified deficiencies in
their anti- money laundering

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Page 52 GAO- 01- 305 Office of Enforcement's Operations

regimes. It also monitors the actions taken by other jurisdictions under
review or previously reviewed to determine the current status of each
jurisdiction relative to the 25 FATF criteria.

? Reports, statements, legislation, regulations, guidelines, and other
relevant written products and documents are reviewed.

? The U. S. position is developed and decisions are made through the
interagency process relative to proposals, reports, advisories to be issued,
and policies to be advanced as a result of this initiative. OE has the lead
in this process.

? Within the FATF, the U. S. negotiates with other member governments to
determine which jurisdictions will be reviewed by the FATF, which
jurisdictions will be listed as non- cooperative, as well as in development
of the process and policies for taking forward this effort. As Head of the
U. S. Delegation to the FATF, OE takes the lead in conducting these
negotiations for the U. S. Further, extensive bilateral contact is conducted
with the various jurisdictions with regard to their laws, regulations, and
antimoney laundering regimes. Again, OE has the lead regarding these
contacts with respect to this initiative.

? OE prepares extensive correspondence relative to this project.
Correspondence is maintained with the FATF, member governments of the FATF,
the jurisdictions under review or previously listed, as well as the U. S.
agencies and departments involved in the interagency group participating in
this initiative. Speeches, talking points, press statements, and
presentation remarks are prepared for Secretary Summers, Deputy Secretary
Eizenstat, and others as needed relative to this project.

? The Head of the U. S. Delegation to the FATF has been invited to speak on
this initiative on various occasions and has given several presentations.
Secretary Summers and Deputy Secretary Eizenstat have also given speeches
and testified before the Congress on the subject. Project duration Start
date: June 1998

No fixed end date Enforcement staffing level on the project 2 OE staff plus
5 detailees from other agencies, 1 intern, and 1 administrative assistant

who spent 50 to less than 75 percent of their time on the project. Project
results In June 2000, the FATF published a list identifying 15 jurisdictions
as non- cooperative

based on its 25 criteria. The U. S. Treasury Department/ FinCEN issued
Advisories to U. S. financial institutions on all 15 NCCTs in July 2000. Not
only the listed NCCTs, but numerous other countries and territories have
taken considerable action to change their laws, regulations, and practices
to bring them in line with international anti- money laundering standards as
a direct result of this initiative. Jurisdictions have been and are
currently taking concrete steps to correct deficiencies in their systems in
an effort to be de- listed or to avoid being included on the NCCT list in
the future. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 53 GAO- 01- 305 Office of Enforcement's Operations 13. National Money
Laundering Strategy

Mission and goal supported Law enforcement mission: Combat financial crimes
and money laundering Primary responsibility Under Secretary (Enforcement)
Primary role Policy development and guidance Purpose The purpose of this
project is to outline a comprehensive, integrated approach to

combating money laundering, both domestically and globally; and, to provide
a clear, detailed plan for government action, which is updated annually. The
Strategy is organized around four broad goals: strengthening domestic
enforcement; enhancing the measures taken by banks and other financial
institutions; building stronger partnerships with state and local
governments; and bolstering international cooperation. How project initiated
Self- initiated and statutory requirement: the Office of Enforcement (OE)
worked with

Congressional staff on drafting the Money Laundering and Financial Crimes
Strategy Act of 1998, signed by the President in October 1998, which
requires the National Strategy. OE has taken the lead within Treasury and
the U. S. government in producing the Strategy and in preparing the five
annual reports called for by the Act. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (Enforcement Policy), DAS (Law
Enforcement), DAS (RT& T), Finance and Administration, ATF, Customs Service,
Executive Office of Asset Forfeiture (EOAF), FinCEN, FLETC, IRS/ CID, Office
of Foreign Assets Control (OFAC), Secret Service, Office of Management,
Comptroller of the Currency, Office of the Assistant Secretary for
International Affairs, Office of General Counsel, Office of Legislative
Affairs, Offices of the Secretary and the Deputy Secretary

? Department of Justice, Department of State, DEA, Executive Office for U.
S. Attorneys (EOUSA), FBI, National Security Council, OMB, ONDCP, Commodity
Futures Trading Commission, Federal Deposit Insurance Corporation, Federal
Reserve Board, National Credit Union Administration, Office of Thrift
Supervision, United States Postal Inspection Service, United States
Securities and Exchange Commission

? None Why Enforcement was involved This project involves major policy
issues and entails high level policy development

implications. Treasury's OE has the lead within the U. S. government
regarding antimoney laundering efforts; additionally, OE's broader
perspective was needed, such that no other individual bureau, agency, or
office could provide. Extensive interagency coordination is required to
develop the annual Strategy, which is cleared through OMB and issued jointly
by the Attorney General and the Secretary of the Treasury. Functions
Enforcement performed ? OE has collected data and continues to collect data
as required to accomplish the

objectives of this project. Data collection is coordinated with the
Departments of Justice and State, U. S. law enforcement and financial
institution regulatory agencies, and other offices within Treasury.

? OE prepares briefing materials for members of the U. S. interagency group
involved in this initiative, as well as for Secretary Summers, Deputy
Secretary Eizenstat, and other members of Treasury management, relative to
this initiative.

? During the drafting of the Act, OE staff briefed Congressional staff on OE
plans for implementation. Since the Act's passage, OE briefs Secretary
Summers, Deputy Secretary Eizenstat, Congressional staff, and others on the
status and progress of this high priority initiative, as well as on specific
issues.

? The purpose of the project is to produce annual national strategies,
including programs and initiatives to counter money laundering, both
domestically and globally. OE drafted two comprehensive National Money
Laundering Strategy documents that were issued within the past year; three
additional annual strategies are statutorily required to be produced.

? The Strategy calls for development and issuance of policies, directives,
standards, regulations. OE is involved in the process of accomplishing those
items and works

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Page 54 GAO- 01- 305 Office of Enforcement's Operations

directly with other agencies and departments involved in achieving the
Objectives and implementing the Action Items contained within the Strategy
concerning these issues.

? The Office of the Under Secretary oversees and OE staff participates in
drafting the annual National Money Laundering Strategy and other reports
relative to the Strategy.

? OE monitors progress by all agencies and departments involved in
implementation of the Objectives and Action Items contained within the
Strategy. OE maintains a spreadsheet that reflects the current status of
each Action Item. A significant number of Action Items are assigned to OE
officials for implementation.

? Drafts, reports, statements, legislation, and other written products are
reviewed.

? OE participated in and reviewed budget proposals for Treasury and the
bureaus to implement the Strategy.

? The interagency process is used to collect information needed to develop
the strategy; draft Strategies are reviewed and cleared through the
interagency process; the annual Strategies are issued jointly by Treasury
and Justice; and coordination continues into the implementation stage. OE
coordinates extensively with other departments, agencies, and offices, while
maintaining the lead throughout the entire process.

? Within the drafting and review process of the annual strategies, OE
negotiates with the other agencies involved regarding priority items and
specific Objectives and Action Items to accomplish Strategy goals. OE has
the lead in this process.

? OE prepares correspondence, speeches, talking points, press statements,
and presentation remarks for Secretary Summers, Deputy Secretary Eizenstat,
and others as needed relative to this project. Correspondence is maintained
with the U. S. agencies and departments involved in the interagency group
participating in this initiative.

? Secretary Summers, Deputy Secretary Eizenstat, Under Secretary
(Enforcement) Johnson, and others have testified relative to this
initiative. Project duration Start date: October 1998

Anticipated end date: 2003 Enforcement staffing level on the project 2 OE
staff, plus 5 detailees from other agencies, 1 intern, and 1 administrative
assistant

(Money Laundering Task Force) who spent 75 to 100 percent of their time on
the project. Project results Significant progress has been made. Two
comprehensive National Money Laundering

Strategies were issued within the past year and a number of Strategy
Objectives and Action Items have already been achieved. For example, in
implementing the Objective to

“Apply increasing pressure on jurisdictions where lax controls invite
money laundering” and the related Action Items, OE played a critical
role in action taken in June 2000 by the Financial Action Task Force (FATF)
when it published a list identifying 15 jurisdictions as non- cooperative
based on its 25 criteria. Further, the U. S. Treasury Department/ FinCEN
issued Advisories to U. S. financial institutions on all 15 non- cooperative
countries and territories (NCCTs) in July 2000. Not only the listed NCCTs,
but numerous other countries and territories have taken considerable action
to change their laws, regulations, and practices to bring them in line with
international anti- money laundering standards as a direct result of this
initiative. Jurisdictions have been and are currently taking concrete steps
to correct deficiencies in their systems in an effort to be de- listed or to
avoid being included on the NCCT list in the future.

The Act also required the designation of High Intensity Money Laundering and
Related Financial Crime Areas (HIFCAs) that concentrate law enforcement
efforts at the federal, state, and local levels to combat money laundering.
OE, through its support of the Money Laundering Task Force and interface
with FinCEN, helped monitor the implementation of the HIFCA program and the
process that designated four new HIFCAs in the 2000 Strategy. In addition,
the Act called for the establishment of a federal grant program, the
Financial Crime- Free Communities Support Program (C- FIC) to provide seed
capital for emerging state and local counter- money laundering efforts.
Treasury and Justice signed an MOU to govern the administration of the C-
FIC and solicit applications from eligible candidates. The goal for 2000 is
to award $2.5 million in C- FIC grant funds.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 55 GAO- 01- 305 Office of Enforcement's Operations 14. Black Market
Peso Exchange Anti- Money Laundering Working

Group

Mission and goal supported Law enforcement mission: Combat financial crimes
and money laundering Primary responsibility DAS (Enforcement Policy) Primary
role Policy development and guidance Purpose To achieve the goal of
dismantling the Black Market Peso Exchange money laundering

system, the Under Secretary for Enforcement created the BMPE Interagency
Working Group in 1998 to develop a comprehensive action plan to combine the
efforts of federal, state, local, and international law enforcement agencies
as well as the business and financial communities in understanding and
undermining the BMPE. The working group brings together, in a coordinated
effort, the tools of Treasury's and Justice's enforcement bureaus and the
regulatory agencies. This effort ensures that federal law enforcement uses
all its available resources in mounting a comprehensive attack against the
BMPE system as a whole. How project initiated Self- initiated Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (RT& T), ATF, Customs Service, FinCEN, IRS/ CID,
OFAC, Office of General Counsel

? Department of Justice, Department of State, DEA, FBI, Office of the
Comptroller of the Currency, National Drug Information Center, U. S. Postal
Service

? State and/ or local governments, foreign governments, private sector Why
Enforcement was involved The BMPE is considered by many money laundering
experts to be the largest money

laundering system in the Western Hemisphere. To effectively combat a system
of its magnitude requires an aggressive, integrated, and coordinated effort
involving federal, state, local, international law enforcement as well as
cooperation of the business community. The Office of Enforcement, with its
law enforcement resources and its direct ties to the business community, was
uniquely positioned to establish and lead this initiative. Functions
Enforcement performed ? OE staff collected trade data, law enforcement BMPE
case summaries, and other data

necessary to prepare briefings and testimony related to the BMPE.

? Briefing materials were prepared for meetings with officials and
background papers were prepared for use by the Attorney General, Deputy
Secretary of the Treasury, and foreign officials engaged in the attack on
the BMPE.

? Please briefly explain. Briefings were made to the Attorney General,
Deputy Secretary of the Treasury, and foreign officials. For example,
officials of Aruba, Colombia, Panama, and Venezuela are participating in a
working group with the U. S. to further combat BMPE in the Western
Hemisphere.

? The Working Group developed a BMPE Action Plan which included strategic
objectives to be met in coordinating the fight against the BMPE and ensuring
the cooperation of the business community. As part of its efforts, it has
also developed and established an international BMPE Working Group and a
domestic government/ industry outreach program that will lead to the
creation and adoption of an anti- money laundering compliance program and
best practices guidelines.

? Through the government/ industry outreach program, the Working Group is
facilitating the development of standards and best practices that will be
adopted by business and industry to combat the BMPE.

? As participants on the Working Group, OE staff draft input for Working
Group reports, proposals, standards, etc.

? The Under Secretary of Enforcement established and oversees the activities
of the Working Group, and OE staff participate as members of the Group.

? In addition to preparing written products associated with the efforts of
the Working

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Group, Office of Enforcement staff reviews reports, proposals, and
initiatives developed by the Working Group.

? The BMPE Working Group is a large interagency program with a number of
cross cutting initiatives. Among other things, Treasury Office of
Enforcement directs the efforts of the Working Group and serves as a
clearinghouse and coordinator for a number of those initiatives.

? The BMPE money laundering system is a global problem. Outreach programs
have been developed and implemented to engage the international community in
the attack on this system. In establishing these programs, members of the
Working Group, and OE staff, have on occasion had to meet and negotiate with
international law enforcement and government officials.

? A key component of the BMPE strategy is education of the national and
international business communities on the BMPE process and measures that can
be taken to avoid BMPE activity. To accomplish this objective, speeches have
been written to increase the awareness of the business community to this
money laundering system and steps that can be taken to avoid business
involvement in it.

? A key component of the BMPE strategy is education of the national and
international business communities on the BMPE process and measures that can
be taken to avoid BMPE activity. To accomplish this objective, the Under
Secretary of Enforcement has made a number of speeches to trade associations
to increase the awareness of its members to the BMPE. In addition,
advisories have been published by the U. S. Customs Service and the
Financial Crimes Enforcement Network.

? The Working Group has held seminars and workshops for the business
community to educate on the operations of the BMPE system and to provide
information on how to avoid becoming involved in the system. Project
duration Start date: February 1998

No fixed end date Enforcement staffing level on the project 3 staff members
who spent 25 to less than 50 percent of their time on the project. Project
results A BMPE Action Plan was developed and is being implemented by OE.
Some of the

results of the Working Group include: 1. An enhanced understanding of the
BMPE process by the federal, state, local, and

international law enforcement communities has resulted in improved
coordination and effectiveness of federal law enforcement BMPE
investigations, data collection, and information sharing. 2. The aggressive
and successful domestic outreach program has resulted in a

heightened awareness of the BMPE process and an increased level of
cooperation of the Business community in developing anti- money laundering
compliance programs. 3. Development and implementation of an international
Black Market Peso Exchange

Working Group to examine the BMPE on a global scale will lead to the
development of specific actions to be taken by member countries to attack
the BMPE money laundering system. 4. Mutual agreements and training programs
with international partners have resulted

in a dramatic improvement in the ability to detect and deter BMPE. 5. Both
FinCEN and Customs have issued Advisories alerting the financial community

and the trade community to the warning signs of BMPE activity.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
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Page 57 GAO- 01- 305 Office of Enforcement's Operations 15. General
Counterdrug Intelligence Plan- Development Phase

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility DAS (Enforcement
Policy) Primary role Policy development and guidance Purpose The General
Counterdrug Intelligence Plan (GCIP) is designed to enhance the Nation's

critical counterdrug intelligence structure to ensure counterdrug activities
of the law enforcement and intelligence communities are prepared for the new
century. The GCIP is intended to ensure that departmental policymakers,
intelligence systems, and law enforcement professionals are able to act in a
coordinated and efficient manner to curtail the activities of criminal drug
organizations. How project initiated Other a : the review that produced the
GCIP was commissioned by the Attorney General,

Director of Central Intelligence, Secretary of the Treasury, and Director of
ONDCP, and supported by the Secretaries of Defense, Transportation, and
State. This review was an extension of and expansion on recommendations made
by a White House Task Force that studied national counterdrug intelligence
in response to a requirement in the 1998 Treasury and General Government
Appropriations Act. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary, Assistant Secretary (Enforcement), DAS (Enforcement
Policy), DAS (Law Enforcement), DAS (RT& T), Customs Service, FinCEN, IRS/
CID, Office of General Counsel

? Department of Defense, Department of Justice, Department of State ,
Department of Transportation, Coast Guard, DEA, FBI, National Security
Council, ONDCP, Intelligence Community

? None Why Enforcement was involved As the GCIP was commissioned at the
Cabinet level, Departmental level participation was

necessary from the beginning of the project. The goal of the GCIP is
extremely broad, establishing an interagency architecture that supports
agents and intelligence analysts in the field; improves Federal, State, and
local relationships; promotes international cooperation; and responds to the
needs of Departmental policymakers as they formulate counterdrug policies
and resource decisions. Functions Enforcement performed ? Led Treasury
efforts to gather data from the various bureaus in support of interagency

review of counterdrug activities.

? Prepared numerous reports and background papers for the GCIP review team
on bureau missions, positions on issues, relationships among enforcement
agencies, foreign presence, sharing and disseminating information, etc. Also
prepared written briefings for Treasury officials on the status of GCIP
progress.

? Provided periodic briefings for Enforcement and bureau officials on the
status of GCIP plans, objectives, progress, etc.

? As a member of the interagency review team, developed plans and drafted
initiatives and strategies for GCIP action items.

? Drafted proposed standards for future law enforcement and intelligence
community action covering the gamut of GCIP topics, including information
technology, training, State and local relationships, foreign government
cooperation, national intelligence centers, and cross- jurisdictional
coordination.

? Drafted reports for use by the GCIP review team and drafted portions of
the final GCIP.

? Oversaw input by bureaus and, at the DAS level, oversaw progress of GCIP
review team.

? In addition to participating as a working member of the GCIP review team,
Treasury Enforcement served on the Deputy Assistant Secretary/ Assistant
Commissioner of Assistant Director- level Counterdrug Intelligence
Coordinating Group (CDICG) which reviewed and monitored objectives,
progress, and written product of the review team.

? As both a member of the GCIP review team and the CDICG, Enforcement
coordinated with 13 Federal agencies and departments to develop a consensus
on the GCIP

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 58 GAO- 01- 305 Office of Enforcement's Operations

findings and initiatives. Much negotiations to ensure that issues of
importance to Treasury law enforcement were included in the final plan.

? As a member of the GCIP review team, prepared correspondence on behalf of
team and the CDICG. Prepared remarks for Under Secretary to present at
formal interagency press roll- out of the GCIP.

? The Under Secretary delivered remarks at formal interagency press roll-
out of the GCIP. Project duration Start date: September 1997

End date: February 2000 Enforcement staffing level on the project 5 staff
members: spent 25 to less than 50 percent of their time on the project.
Project results The direct result of the project was the issuance of the
GCIP in February 2000, which

provided an integrated, strategically oriented counterdrug intelligence
framework to enhance future counterdrug operations. The framework included a
series of 73 concrete action items to achieve the plan and established a new
cooperative coordination mechanism consisting of agencies in the law
enforcement and intelligence communities. a Response categories included
self- initiated, statutory requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 59 GAO- 01- 305 Office of Enforcement's Operations 16. Report to
Congress on Southwest Border

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility DAS (Enforcement
Policy) Primary role Oversight Purpose In response to Congressional
directive in the 1999 Treasury- Postal Appropriation, working

with USCS, ONDCP, and DOJ to provide a report on efforts to improve
coordination among federal law enforcement agencies on the US Southwest
Border. How project initiated Other Congressional direction a : language in
the 1999 Treasury- Postal Appropriation Act

(Sec 629) directed the report. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), DAS (RT& T),
Customs Service, Leg Affairs, Office of General Counsel

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, EOUSA, FBI, INS, OMB, ONDCP

? None Why Enforcement was involved Congressional language directed that the
Secretary (in conjunction with the Attorney

General and the Director of ONDCP) submit the report. Since the substance of
Congressional concerns dealt with interdicting drugs, Enforcement was
tasked. Functions Enforcement performed ? Collect and organize data from
USCS, INS, and ONDCP.

? Prepare update briefings for Under Secretary, Secretary and Deputy
Secretary on project status.

? Brief Secretary, Deputy Secretary and Under Secretary on project status.

? The project consists of preparing a written report for submission to
Congress. Treasury (Enforcement) took responsibility as the principal
drafter of the report, ensuring coordination with the other agencies as
required.

? Review and incorporate (as appropriate) USCS and INS implementation plans
for the Border Coordination Initiative, DOJ and EOUSA submissions, and field
office strategy documents. Evaluate program results from BCI as provided in
monthly reports for inclusion in the report to Congress.

? The principal effort of this office since it developed the first draft of
the report has been to mediate disputes between various concerned parties
(INS, Border patrol, EOUSA, ODAG, HIDTA, ONDCP/ Supply Reduction, ONDCP/
State & Local, USCS), and to negotiate changes to text as requested by each.

? Prepare correspondence from Treasury officials to counterparts (Assistant
Secretary and Under Secretary level). Draft and coordinate within Treasury
and the interagency joint memoranda from the Secretary, the AG, and ONDCP
Director to Congressional leaders. Project duration Start date: February
1999

Anticipated end date: October 2000 Enforcement staffing level on the project
2 staff members who spent 25 to less than 50 percent of their time on the
project. Project results Unknown. The final interagency- approved draft of
the report was completed in May, 2000.

Secretary Summers and Attorney General Reno signed the transmittal to
Congress in June and August, 2000 respectively. a Response categories
included self- initiated, statutory requirement, other congressional
direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 60 GAO- 01- 305 Office of Enforcement's Operations 17. Annual Narcotics
Certification

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility DAS (Enforcement
Policy) Primary role Policy development and guidance Purpose The State
Department makes recommendations to the President as to whether he certifies

that the world's major drug- producing and transit countries are fully
cooperating in our antinarcotics trafficking efforts, or taking sufficient
steps on their own. Before making these recommendations, State leads an
interagency process to obtain consensus. The President announces his
decision by March 1 of each year. Following the process, State publishes the
International Narcotics Cooperation Strategy Report (INCSR) which provides
the background for the Presidential determinations. The INCSR includes
country reports not only on narcotics, but also on money laundering. The
text of the INCSR is reviewed in an interagency process, culminating in the
March 1 publication. Thereafter, the interagency players review demarches to
be sent to the countries, describing what factors will be evaluated in the
certification process for the following calendar year. How project initiated
Statutory requirement Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), ATF, Customs
Service, FinCEN, IRS/ CID, OASIA

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, FBI, National Security
Council, OMB, ONDCP, CIA, HHS

? Foreign governments Why Enforcement was involved Narcotics certification,
including the money laundering component, involves over- arching

government policy- making in an interagency context. OE is the best place to
coordinate all of the bureaus' input into that decision- making process.
Functions Enforcement performed ? Collect data on narcotics seizures, money
laundering, and foreign governments'

financial systems and cooperation with Treasury bureaus.

? Preparation for interagency certification meetings including information
described above.

? Prepare updates for Secretary and Deputy Secretary on certification
process; prepare decision memorandum for final certification
recommendations.

? Review demarches to foreign governments.

? Participate in interagency certification strategic decisions, recommend
Departmental concurrence in these decisions.

? Participate in drafting of annual INCSR.

? Review INCSR drafts, review certification demarche drafts.

? Participate in interagency certification decision process using Treasury
bureaus' input.

? Advocate Treasury's position as to specific countries' certification in
interagency process.

? Some years, Treasury has been required to testify before Congress as to
certification recommendations. Project duration Start date: 1987

No fixed end date Enforcement staffing level on the project 4 staff members
who spent 10 to less than 25 percent of their time on the project. Note:

While meetings are going on December- February, it's considerably more than
25 percent. Project results Treasury has contributed to the INCSR published
annually since 1987 by the State

Department. Treasury has contributed to the recommendations to the President
as to certification each year. Some years, Treasury has been required to
testify before Congress as to certification and the factors considered in
the recommendations.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 61 GAO- 01- 305 Office of Enforcement's Operations 18. General
Counterdrug Intelligence Plan- Implementation

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility DAS (Law
Enforcement) Primary role Oversight Purpose The purpose of the project is to
implement the 73 action items in the General Counterdrug

Intelligence Plan (GCIP). The GCIP is designed to enhance the Nation's
critical counterdrug intelligence structure to ensure counterdrug activities
of the law enforcement and intelligence communities are prepared for the new
century. The GCIP is intended to ensure that departmental policymakers,
intelligence systems, and law enforcement professionals are able to act in a
coordinated and efficient manner to curtail the activities of criminal drug
organizations. How project initiated Presidential Initiative: the GCIP has
been an Administration initiative that builds on the

National Drug Control Strategy. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (Law Enforcement), Finance and Administration, ATF, Customs Service,
FinCEN, FLETC, IRS/ CID, OFAC, Secret Service, Office of Management,
Treasury Legislative Affairs, General Counsel, Information Systems

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, FBI, National Security
Council, OMB, ONDCP, Intelligence Community

? State and/ or local governments, foreign governments Why Enforcement was
involved The GCIP is an Administration initiative. The goal of the GCIP is
extremely broad,

establishing an interagency architecture that supports agents and
intelligence analysts, in the field; improves Federal, State, and local
relationships; promotes international cooperation; and responds to the needs
of Departmental policymakers as they formulate counterdrug policies and
resource decisions. Functions Enforcement performed ? Gather data from
bureaus on existing and proposed efforts to implement GCIP action

item, including data on personnel, recruitment, training, information
technology, etc.

? Prepare background materials and briefing papers on the objectives of the
GCIP, and on funding for the Counterdrug Intelligence Secretariat (CDX). The
CDX is the staff arm of the Counterdrug Intelligence Coordinating Group
(CDICG), the interagency coordinating body overseeing the overall Federal
implementation of the GCIP.

? To date, briefings have been made to staff of various Congressional
committees and to the CDICG.

? Develop strategies for implementation of GCIP action items by Treasury
bureaus.

? Oversee implementation of GCIP action items by Treasury enforcement
bureaus.

? Prepared proposals seeking waiver of appropriations statutory language
prohibiting reprogramming of agency funds for interagency committees. Due to
the issuance of the GCIP so late in the fiscal year, no funding was included
in FY 2000 appropriations for the CDX activities. A waiver was required to
permit agencies to reprogram funds to the Department of Justice (which
provides administrative services for CDX) for FY 2000. Funding for future
years is included in ONDCP appropriations.

? Coordinate with Treasury enforcement bureaus, the CDX, and with other
CDICG members on implementation of GCIP action items.

? Certain GCIP action items relate to coordination with foreign governments
on counterdrug intelligence. Since formal operations under the GCIP were
initiated in February 2000, the CDICG and the CDX have already stepped in to
resolve a potentially serious problem relating to the sharing of U. S.
counterdrug alert information among foreign nation liaison officers
participating in the Joint Interagency Task Force (JIATF). Project duration
Start date: February 2000

No fixed end date Enforcement staffing level on the project 3 staff members
who spent 10 to less than 25 percent of their time on the project.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 62 GAO- 01- 305 Office of Enforcement's Operations

Project results The GCIP action items focus on six broad areas: a policy-
level coordination mechanism; coordination among the four national
intelligence centers; regional, state, and local coordination; foreign
coordination; intelligence analyst development and training; and information
technology. The policy- level coordinating mechanism- the CDICG- has been
established, and a relationship has been formed among the four national
intelligence centers. The agencies represented on the CDICG, as well as many
other Federal agencies, are working together to achieve progress in
implementing the action items addressing all the GCIP initiatives.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 63 GAO- 01- 305 Office of Enforcement's Operations 19. Foreign
Narcotics Kingpin Designation Act

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility Assistant
Secretary (Enforcement) Primary role Oversight Purpose To oversee the
development of Treasury's position and coordinate the Administration's

response to the Kingpin Act prior to its passage by the Congress in December
1999; and to monitor the implementation of the Kingpin Act by the Office of
Foreign Assets Control through the first Presidential designations in June
2000. OE will continue to monitor the Kingpin program implementation in the
future. How project initiated Self- initiated and statutory requirement: the
Assistant Secretary (Enforcement) took the

lead in developing Treasury's position and coordinating with other agencies
on the proposed Kingpin bill. Enforcement worked with OFAC on the process to
prepare, in coordination with other agencies, the first Presidential
designations of narcotics kingpins, as required by the legislation. Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), Finance and Administration, Customs Service, IRS/ CID,
OFAC, Office of International Affairs, Office of Legislative Affairs, Office
of General Counsel

? Department of Defense, Department of Justice, Department of State, DEA,
FBI, National Security Council, ONDCP, Intelligence Community

? None Why Enforcement was involved Enforcement took the lead because of the
policy- level decisions to be made and due to

the extensive coordination required, not only among offices within the
Treasury, but with agencies outside of Treasury. Functions Enforcement
performed ? Collected data on resources required by OFAC and other Treasury
bureaus to

implement the Kingpin Act and on the type of information that would be
needed by OFAC to develop designations.

? Prepared briefing materials and talking points for high- level Treasury
and other government officials on the Act provisions, procedures for
implementation, and impact of bill.

? Enforcement and OFAC briefed Treasury, Justice, ONDCP and State officials,
including embassy personnel.

? Worked with OFAC to develop implementation strategies in response to
changes as the legislation progressed in the Congress and for the final
Kingpin Act.

? In coordination with other Treasury offices, developed Treasury policy and
positions for the Secretary on the Kingpin Act.

? Monitored OFAC's coordination with other agencies in the development of
the first narcotics kingpin designations by the President under the new Act.

? Reviewed drafts of proposed legislation, briefing materials, and program
implementation plans.

? Worked with OFAC to develop proposals to seek funding for OFAC
implementation of the Kingpin Act through emergency supplementals and
through the FY 2001 appropriations request.

? The Assistant Secretary coordinated with Justice officials on plans and
procedures for Kingpin Act implementation.

? Enforcement and OFAC briefed Mexican officials and Mexican business
community on the Kingpin Act provisions. OE, working with OFAC, drafted
talking points on the Act's provisions for use by Administration officials
in meetings with foreign officials.

? Reviewed correspondence, testimony, and briefing materials responding to
inquiries and questions on the Kingpin Act. Project duration Start date:
February 1999

No fixed end date

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 64 GAO- 01- 305 Office of Enforcement's Operations

Enforcement staffing level on the project 4 staff members who spent 10 to
less than 25 percent of their time on the project. Project results On June
1, 2000, the President designated 12 narcotics kingpins from four countries

pursuant to the Foreign Narcotics Kingpin Designation Act. The designations
were jointly recommended to the President by the Departments of Treasury,
Justice, State, and Defense, and the CIA. The effect of the June 1
designations is to impose sanctions against the 12 kingpins that target
their financial and business operations. There will be additional
designations of narcotics kingpins and their front companies and individuals
at least yearly, as required by the Act. OE will continue to monitor the
future implementation efforts and required reports to Congress of this
highly visible program.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 65 GAO- 01- 305 Office of Enforcement's Operations 20. US- Mexico High
Level Contact Group for Drug Control

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility Under Secretary
(Enforcement) Primary role Policy development and guidance Purpose The HLCG
is the mechanism for coordinating bilateral policies and actions on the
entire

range of counterdrug issues, to include demand reduction, illicit drug
production and trafficking, law enforcement cooperation and training, anti-
money laundering efforts, attack on criminal organizations, anti- corruption
efforts, and anti- illegal firearms trafficking. The HLCG meets twice
annually in plenary, and its subordinate working groups meet more
frequently. The HLCG is chaired by the US ONDCP Director and the Mexican
Foreign Minister and Attorney General. Group membership includes
representatives from both nations' Finance, Justice, Defense, Health, and
Foreign ministries. US representatives are from NSC, DOJ, FBI, DEA, USMS,
INS, Treasury, USCS, ATF, IRS- CI, FinCEN, State- INL, State- WHA, US
Ambassador to Mexico, USCG, DOD, JCS, USIC, HHS, and SAMHSA. Treasury is
represented by the Under Secretary for Enforcement. HLCG has a number of
subordinate working groups. Treasury participates in the USG Mexico Core
Group at the Under Secretary level (approximately 6 times per year), in
bilateral Steering Committee at the Assistant Secretary level (approximately
4 times per year), and chairs bilateral technical working groups on money
laundering and firearms trafficking (approximately 2- 3 times per year for
each). How project initiated Presidential initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), ATF, Customs Service, FinCEN,
IRS/ CID, OASIA

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, FBI, INS, National Security
Council, CIA, HHS, USMS

? Foreign governments Why Enforcement was involved Departmental
participation was mandated by the Presidential directive. Enforcement, as

the lead for issues related to US counterdrug activities within Treasury,
coordinates Treasury and bureau participation in the HLCG process. Functions
Enforcement performed ? Collect investigative data, and information on
current counterdrug activities in the US

and Mexico.

? Prepare briefings for Under Secretary's and Assistant Secretary's use at
multiple Core Group and Steering Committee meetings. Prepare background,
briefing materials, and presentations for Under Secretary's use at HLCG
plenaries.

? Brief Secretary and Deputy Secretary on HLCG status and specific issues,
also brief Under Secretary in preparation for Core Group, Steering Committee
meetings.

? Develop USG proposals for bilateral actions against money laundering and
firearms trafficking. Draft those portions of the Binational Drug Strategy,
and coordinate within Treasury and the US interagency.

? Participate in drafting USG policy on cooperative efforts with Mexico (e.
g. The USMexico Alliance Against drugs signed by Presidents of both
countries, the BrownsvilleMerida agreements signed by Attorneys General of
both countries, and the bilateral Memorandum of Agreement on Cross Border
Monetary Instrument Reporting signed by Under Secretary for Enforcement and
his Mexican counterpart). Developed and coordinated within Treasury and the
US interagency performance measures of effectiveness for the Binational Drug
Strategy and negotiated with Mexican officials the final adopted version of
those measures.

? As US chair of the bilateral working groups on money laundering and
firearms trafficking, prepare periodic reports on the mission, goals, and
activities of the working groups for the Secretary as well as the HLCG
principals.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 66 GAO- 01- 305 Office of Enforcement's Operations

? HLCG is both bilateral and interagency. Treasury equities require
extensive interagency coordination to develop USG positions and action
plans, as well as negotiating positions and tactics for dealing with Mexican
counterparts.

? Prepare speeches and presentations for use at HLCG plenaries as well as at
bilateral Steering Committee and technical working group meetings.

? Make presentations to Cabinet level officials and media at HLCG plenary
sessions. Project duration Start date: March 1996

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 25 to less than 50 percent of their time on the project. At times

this has risen to as much as 80 to 100 percent. Project results Improved
coordination between the US and Mexico on counterdrug issues. Specific

accomplishments are detailed in the US- Mexico Alliance Against drugs signed
by Presidents of both countries, the Binational Drug Strategy and the
related performance measures. Among other things, specific areas of
increased cooperation enhanced under Treasury Enforcement's leadership
include:

? the bilateral Memorandum of Agreement on Cross Border Monetary Instrument
Reporting signed by Under Secretary for Enforcement and his Mexican
counterpart,

? adoption by Mexico of regulations implementing its anti- money laundering
law,

? U. S. assistance to Mexico through ATF on tracing firearms used in crimes
in Mexico,

? Mexico undertaking the required steps to join the Financial Action Task
Force (the leading international anti- money laundering organization),

? enhanced cooperation between Treasury law enforcement and the Government
of Mexico on money laundering and illegal firearms trafficking cases.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 67 GAO- 01- 305 Office of Enforcement's Operations 21. Plan Colombia

Mission and goal supported Law enforcement mission: Reduce the trafficking,
smuggling, and use of illicit drugs Primary responsibility DAS (Enforcement
Policy) Primary role Policy development and guidance Purpose Working with
bureaus, propose projects for assisting government of Colombia in its

counter- narcotics efforts. Following Congressional passage of supplemental
funding package for numerous program areas, refine bureau implementation
plans and negotiate funding from justice sector funds with DOJ and other
agencies. How project initiated Other a : Colombian President Pastrana
approached the USG and requested our

assistance with his $7. 5 billion Plan Colombia program. The Administration
proposed a package to support Mr. Pastrana, and the Congress ultimately
approved $1.3 billion in funding to assist Colombia and other regional
governments with counter- narcotics efforts including equipment and training
for Colombian military and law enforcement, eradication, and alternative
development. A Presidential Decision Directive laid out areas of
responsibility for agency involvement. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), Finance and
Administration, ATF, Customs Service, FinCEN, IRS/ CID, OFAC, Secret
Service, Office of Management, OASIA, Office of Technical Assistance

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, DEA, FBI, National Security
Council, OMB, ONDCP, CIA

? Foreign governments, IMF, World Bank, human rights NGO's Why Enforcement
was involved Enforcement coordinated the input of all the bureaus into the
Department's proposals

from the initial Administration package, and continuing through the current
negotiations with other agencies as to implementation plans. Functions
Enforcement performed ? Collect proposals, organize implementation planning
package for transmission to other

agencies, collect information on current activities in Colombia and
surrounding countries.

? Prepare briefings for multiple Deputies' Committee meetings at NSC, also
for Under Secretary's use at Executive Committee meetings, and for Secretary
and Deputy Secretary on project status.

? Brief Secretary on project status, also brief Deputy Secretary and Under
Secretary in preparation for Deputies Committee and Executive Committee
meetings on project.

? Develop complete package of proposals and implementation plans for
Department's Plan Colombia activities.

? Participate in drafting Presidential Decision Directive, implementation
plans for Congress, strategy documents outlining goals and plans.

? Once implementation begins, Enforcement staff will oversee and monitor
bureau projects, as well as coordinate them with other participants in
justice sector areas

? Review PDD, implementation plans, strategy documents, bureaus' proposals
and implementation plans.

? Entire project deals with seeking funding for assistance to Plan Colombia.

? Project is interagency, also represent Treasury interest in planning
process for particular sectors of project.

? Work within DOJ- led process to plan implementation of justice sector
programs. Project duration Start date: March 1999

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 25 to less than 50 percent of their time on the project. At

times, this has risen to as much as 80- 100 percent.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 68 GAO- 01- 305 Office of Enforcement's Operations

Project results The Colombia funding supplemental included $68 million for
Customs radar upgrades, $1 million for Customs' Americas Counter Smuggling
Initiative, involving outreach to business; $2 million for Customs police
training, $1 million for OASIA/ Office of Technical Assistance (OTA) for
banking supervision assistance, and $500k for OASIA/ OTA for tax revenue
enhancement. Treasury's bureaus and the Office of Enforcement have sought
$5.3 million in funding from several sources in a justice sector planning
process for other training and equipment for the government of Colombia. a
Response categories included self- initiated, statutory requirement, other
congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 69 GAO- 01- 305 Office of Enforcement's Operations 22. National Church
Arson Task Force

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Policy
development and guidance Purpose Implementation of President Clinton's
three- part strategy to combat the scourge of arsons

at our nation's houses of worship- particularly African American churches in
the South. How project initiated Other a : in response to the President's
directive to address the issue of church arsons, the

Departments of Treasury and Justice established the National Church Arson
Task Force. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), Finance and Administration, ATF, Office of General
Counsel, Office of Legislative Affairs, Office of Public Affairs

? Department of Justice, EOUSA, FBI, Department of Housing and Urban
Development, Federal Emergency Management Agency

? State and/ or local governments, private sector Why Enforcement was
involved The interagency National Church Arson Task Force is a Presidential
initiative. The

Assistant Secretary (Enforcement) was designated Co- chair of the Task
Force, and has continued in that capacity as Under Secretary (Enforcement).
Functions Enforcement performed ? ATF maintains data on incidents of church
arson. The Department of Justice maintains

data on prosecutions and convictions of the arsonists. In preparing reports,
testimony, speeches and other materials, Enforcement staff gather relevant
information from ATF and DOJ.

? Background and briefing materials have been prepared for high- level
Treasury and Justice officials, Task Force members and for the public on
Task Force efforts.

? Oral briefings have been presented to Treasury officials and to Task Force
members.

? In coordination with ATF, DOJ and others, developed guidelines and
strategies for investigation by Federal law enforcement agencies of church
arson incidents.

? Developed a list of best practices for interagency coordination.
Coordinated with ATF on the development of recommendations for the public on
preventing church arsons. Also, in coordination with ATF, DOJ and others,
developed operational protocols and guidelines for operations of Task Force.

? Prepare Task Force reports to the President. An interim report and four
annual reports have been submitted to the President since creation of the
Task Force.

? In coordination with the Department of Justice, monitor progress of ATF
investigations and DOJ prosecutions of church arsons.

? In conjunction with preparation of reports to the President and other
documentation, review ATF reports of arson investigation results.

? In 1996, additional funding was requested (and obtained) to support ATF
investigations of church arsons.

? Coordinate regularly with other agency members of the National Church
Arson Task Force.

? Prepare correspondence, draft speeches and testimony for then Assistant
Secretary (Enforcement) and now Under Secretary (Enforcement) on ATF efforts
and progress of Task Force.

? The Under Secretary (Enforcement) has delivered numerous speeches and
presented testimony on Task Force efforts and the highly successful ATF
investigation and of church arsons. The Chief of Staff (Enforcement) has
made presentations on the work of the Task Force at workshops sponsored by
the Department of Housing and Urban Development. Project duration Start
date: June 1996

No fixed end date Enforcement staffing level on the project 4 staff members
who spent less than 10 percent of their time on the project.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 70 GAO- 01- 305 Office of Enforcement's Operations

Project results Successful results of the National Church Arson Task Force
include: a decline in the number of reported church arsons; a rate of arrest
for church arsons that is more than double the national average for arsons
generally; an increased focus on fire prevention at churches; financial
support for rebuilding of houses of worship destroyed by arson; and
preparation and distribution of a threat assessment guide for churches. a
Response categories included self- initiated, statutory requirement, other
congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 71 GAO- 01- 305 Office of Enforcement's Operations 23. National Special
Security Events

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility DAS (Law Enforcement) Primary role Oversight Purpose
Presidential Decision Directive 62 requires the full protective and
consequence

management capabilities of the Federal Government to be made available if a
major event is designated a National Special Security Event. OE oversees
process under which events are proposed and designated, and oversees the
security provided for those events designated as NSSEs. How project
initiated Presidential initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), Finance and Administration,
ATF, Customs Service, IRS/ CID, Secret Service

? Department of Defense, Department of Justice, FBI, National Security
Council, Federal Emergency Management Administration

? State and/ or local governments Why Enforcement was involved OE provides
direction and leadership to the two Treasury bureaus mentioned in PDD- 62,

the Secret Service and the Customs Service. OE provides a broader
perspective on each bureau's assigned roles and assists in exploring
alternative funding for these events. Additionally, OE is aggressively
spearheading a more concrete understanding of the criteria and process for
the designation of an event to the NSSE level. Functions Enforcement
performed ? Collected data on specific events proposed and on proposed
security plans. Collected

informational data for resources and funding purposes. Data collected to
respond to Congressional and Executive inquiries.

? Prepare informational materials for the Secretary and his Staff within
Treasury as part of process to obtain approval to designate an event as an
NSSE.

? Briefings for Secretary and his Staff and the Attorney General. Briefings
for other officials directly affected by the event. (e. g. Mayors and Police
Chiefs in Los Angeles and Philadelphia for both National Political
Conventions).

? Draft initiatives to amend program processes for strengthening the
standards for the designations of NSSEs.

? Develop new standards and criteria for designating NSEEs.

? Extensive meetings and “table top” security exercises with the
bureaus and outside entities relating to NSSEs. Trips to event sites and
participation at the events to support the bureaus and to provide ongoing
reports to Treasury officials of event activities.

? Reviewed reports from the perspective bureaus and the Counter- Terrorism
and Security Group (CSG)

? Developed, reviewed budget proposals, proposed, and continued to seek and
explore alternative sources of funding for NSSEs through the Legislative and
Executive Branches.

? Coordinate and mediates among all respective parties on issues, including
air interdiction, funding proposals, and the actual designation of an event.
Problem solving with DOJ.

? Responding to correspondence from the National Security Council relating
to designation.

? Congressional testimony (appropriations) relating to NSSEs. Project
duration Start date: May 1998

No fixed end date Enforcement staffing level on the project 4 staff members
who spent 25 to less than 50 percent of their time on the project.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 72 GAO- 01- 305 Office of Enforcement's Operations

Project results The PDD was drafted and cleared with the White House and
ultimately approved. OE led effort to develop and implement processes for
designating events as NSSEs. OE has been able to achieve some limited
funding for events. The relationship of Treasury bureaus with state, local,
and Federal law enforcement has been strengthened as the result of the
cooperation exhibited in participating in the events. There were five NSSEs
designated in FY 2000. All were successfully completed. It is estimated that
about three events per year will be designated NSSEs in the future. The
Presidential Inauguration in 2001 and the 2002 Winter Olympics also were
designated as NSSEs.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 73 GAO- 01- 305 Office of Enforcement's Operations 24. Five- Year
Counterterrorism Plan

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility DAS (Law Enforcement) Primary role Oversight Purpose
To develop and implement a unified government- wide plan to combat
terrorism. How project initiated Other Congressional direction a : the FY
1998 Appropriations Bill required that the

Department of Justice lead an inter- agency process to develop a
comprehensive five- year counter- terrorism plan. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), Finance and Administration,
ATF, Customs Service, FinCEN, FLETC, IRS/ CID, OFAC, Secret Service, Office
of Management

? Department of Defense, Department of Justice, Department of State,
Department of Transportation, Coast Guard, EOUSA, FBI, INS, National
Security Council, OMB, CIA

? None Why Enforcement was involved The initial project was led by DOJ, so
it was appropriate that Treasury respond at the

Departmental level. Additionally, the Department could provide a broader,
more coordinated, and more comprehensive approach than the individual
bureaus. The implementation of the plan requires the oversight of the
Department. Functions Enforcement performed ? Information regarding the
current counter- terrorism activities of the bureaus, as well as

proposals for new programs was gathered, reviewed, organized, and provided
to DOJ.

? Prepared briefing materials for the Under Secretary, Secretary and other
senior officials.

? Briefed Congressional staff.

? Worded with bureaus to develop proposals to address emerging terrorist
threats.

? Held coordinating meeting to develop a unified Treasury position.
Organized representation on the various working groups that developed the
Plan.

? Reviewed and corrected all written submission, all draft versions of the
Plan, coordinated the clearance of the Plan through Treasury.

? Determined the cost of new initiatives identified in the Plan, proposed
funding for these initiatives as part of the budget process. Continue to
advocate for funding for these initiatives.

? Participated as the representative of the Department at senior level
meetings, coordinated closely with DOJ on the elements of the Plan,
vigorously defended the bureaus' initiatives and programs, mediated disputes
that arose.

? Drafted letters to senior DOJ officials to obtain representation in the
coordinating group, and regarding areas of disagreement with the draft Plan.

? Enforcement continues to coordinate the implementation of the Treasury
action items contained in the plan, and provide information for inclusion in
the yearly update of the Plan. Project duration Start date: Early 1998

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 75 to 100 percent of their time on the project for 8 months,

then 25 to 50 percent for about 3 months, and then about 10 percent. Project
results A comprehensive interagency Plan, which contained many of the ideas
and initiatives

proposed by Treasury and its bureaus, was developed and has been updated
each year. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 74 GAO- 01- 305 Office of Enforcement's Operations 25. 2001 Terrorism
Supplemental

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility DAS (Law Enforcement) Primary role Support Purpose To
strengthen our nation's counterterrorism efforts, OE requested funding for
additional

counterterrorism programs for the Treasury law enforcement bureaus and
offices. How project initiated Presidential initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (Law
Enforcement), Finance and Administration, ATF, Customs Service, FinCEN, IRS/
CID, OFAC, Secret Service, Office of Management, Office of Legislative
Affairs

? Department of Defense, Department of Justice, Department of State, FBI,
INS, National Security Council, OMB

? None Why Enforcement was involved In late March 2000, at the request of
OMB, Treasury was requested to submit proposals

for a possible counterterrorism supplemental. OE met with all Treasury law
enforcement bureaus to discuss, review and evaluate each bureaus
counterterrorism programs. Each bureau was requested to submit supplemental
funding requests to enhance these programs. OE coordinated these funding
requests with OMB. Functions Enforcement performed ? All bureaus submitted
supplemental funding requests to OE. OE collected and

“packaged” these requests for submission to OMB. At the request
of OMB, OE was required to prioritize these submissions.

? OE prepared voluminous briefing and background materials on Treasury- wide
counterterrorism programs.

? OE briefed Treasury officials and OMB officials on our counterterrorism
supplemental requests on a number of occasions. OE also briefed
Congressional appropriators on our request.

? In addition to our efforts to enhance existing bureau programs, OE
proposed a new Treasury terrorist asset tracking initiative. This new
initiative was applauded by OMB and efforts are underway to fund this new
program.

? The DAS (LE) and OF& A prepared extensive budget- related reports for
submission to OMB in conjunction with the supplemental appropriations
process.

? OE continues to monitor the progress of this counterterrorism initiative.

? Develop or review budget proposals, seek funding- as previously mentioned,
this project is specifically related to a supplemental funding request
pertaining to our counterterrorism efforts.

? At the request of OMB, OE submitted this proposal as a consolidated
Treasury counterterrorism request. Extensive coordination was required with
all bureaus. Each bureau was required to submit its draft counterterrorism
funding request to OE. After consultation with each bureau and an internal
OE review, a Treasury Counterterrorism supplemental funding request was
submitted to OMB approximately 4 weeks after this initiative began.

? Appropriate correspondence prepared for OMB regarding the supplemental
funding initiative. Project duration Start date: March 2000

Anticipated end date: October 2000 Enforcement staffing level on the project
9 staff members who spent 10 to less than 25 percent of their time on the
project. Project results A supplemental budget proposal was developed and
approved within Treasury and sent

to OMB. The Treasury proposal was approved by OMB and forwarded to Congress.
Funds for counterterrorism were included in the approved 2001 budget.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 75 GAO- 01- 305 Office of Enforcement's Operations 26. Commerce in
Firearms (CIF) Report and Regulatory

Enforcement Project

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Policy
development and guidance Purpose The purpose of this project is fourfold:
(1) to oversee the establishment of an ARF annual

report of firearms regulatory- related statistics (Commerce in Firearms)
usable by agency personnel, government personnel, Congress, and interested
experts, modeled on the Council of Economic Advisors annual report, which
includes an ongoing statistical series for the United States and topical
introductory essays by the agency, in order to centralize USG publication of
these statistics, inform the public of vital firearms- related statistics,
and make ATF's regulatory enforcement activities transparent to oversight
agencies and other interested parties; (2) to support, invigorate and focus
ATF's regulatory enforcement activities by providing a publicly understood,
rational basis for a firearms regulatory program, based on identifying
Federally licensed firearms dealers that were likely sources of crime guns,
to determine if they were violating federal firearms laws; (3) to ensure
that ATF would take appropriate regulatory and/ or criminal enforcement
action based on these findings (Feb. 4, 2000) and to require follow up
reporting to the Secretary on that regulatory enforcement program (Fall
2000), consisting of: conducting intensive inspections of the small
percentage of federal firearms licensees (FFLs) who (a) accounted for over
half of all crime guns traced to current dealers in 1999, (b) were
uncooperative with ATF trace requests in 1999, and to collect firearms
transaction records from uncooperative dealers and used gun records from
dealers who had 10 or more crime guns with time- to- crime of three years or
less traced to them in 1999 (An ancillary benefit of the program is the
improvement of ATF's ability to conduct comprehensive crime gun tracing of
used firearms used in crime by obtaining firearms transaction records of the
uncooperative and high- trace, short time- to- crime dealers); and (4) to
inform Congress and the public about the problem of corrupt Federal Firearms
Licensees. How project initiated Self- initiated and presidential
initiative: the project was self- initiated by the OE, then

announced by President Clinton as well as the Secretary of the Treasury.
Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), ATF,
General Counsel, Economic Policy DAS

? Department of Justice

? None Why Enforcement was involved OE conceived of the idea of an annual
compilation of vital ATF firearms statistics,

assisted in developing and drafting the first annual CIF report. OE worked
with ATF to develop the related regulatory enforcement program and required
follow up reporting to the Secretary, and participated in reviewing that
report and its findings. OE continues to be involved in assisting ATF to
establish an authoritative annual firearms statistical report, and in
drawing out the regulatory enforcement and other policy implications of the
data. OE brought in the Office of Economic Policy to assist in developing
and interpreting ATF statistical data on U. S. firearms entering commerce
and in coordinating with the Office of the Census. Functions Enforcement
performed ? OE worked with ATF, academic contractors, and the DOJ Bureau of
Justice Statistics

to develop and analyze the data underlying the initial regulatory
enforcement plan and in the CIF report itself, then received monthly status
reports from ATF, summarizing the number of inspections conducted and
various results to date, and reporting on the entry and use of firearms
records for comprehensive tracing purposes.

? OE prepared materials relating to the development of the report, the
regulatory enforcement program, and oversight of this project for the Under
Secretary's meetings with ATF's director, and for the White House.

? OE briefed White House officials, the Secretary, Deputy Secretary, and
Under

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 76 GAO- 01- 305 Office of Enforcement's Operations

Secretary at various points on the progress of the project.

? OE helped ATF design both the annual statistical report using the Council
of Economic Advisors annual report as a model, and the regulatory
enforcement program itself that drew from the data published in that report
as well as other investigative information.

? OE assisted ATF in developing the enforcement policy of focusing on high
crime indicator FFLs and making this policy a matter of public commitment
and knowledge, and supported the development of new regulations requiring
FFLs to conduct annual inventory and report guns lost in shipment and
collecting information on FFL transaction numbers.

? OE assisted in the design and drafting of the initial CIF Report , is
similarly involved in preparing the implementation report to the Secretary,
and is engaged with ATF in planning the 2001 Firearms Commerce report.

? OE's regulatory oversight responsibility prompted the request for the
invigorated regulatory enforcement program, and after this was announced, OE
received monthly reports on implementation of the focused inspection project
and of receipt and use of FFL records for crime gun tracing purposes. OE
also is involved in overseeing the final implementation report to the
Secretary, and in developing and analyzing enforcement and other policy
implications of the project. OE is involved in supporting and monitoring the
development of the 2001 Firearms Commerce report, together with the Office
of Economic Policy.

? OE was significantly involved in reviewing drafts of the report, related
memorandum, and regulations, has been involved in reviewing the monthly
reports and in preparing the final report. OE will also help prepare and
review guidelines for continuing a targeted inspection program and review
next years Firearms Commerce report.

? Based on the improved targeting and accountability of ATF's regulatory
enforcement resources, Treasury sought and won support for an additional 200
ATF firearms inspectors in FY2001, and based on the success and importance
of this project, OE will help ATF seek funding for addition inspection
resources for FY2002.

? OE sought and obtained the assistance of the authoritative Bureau of
Justice Statistics in designing and establishing ATF's annual compilation of
firearms statistics.

? Deputy Secretary, Secretary and President offered remarks in connection
with the initial CIF report. Project duration Start date: Fall 1999

No fixed end date Enforcement staffing level on the project 3 staff members
who spent less than 10 percent of their time on the project. Project results
As a result of OE's efforts, ATF published the first annual compilation of
U. S. firearms

statistics, provided a comprehensive explanation to the public of the role
of Federal firearms licensees in the supply of crime guns and conducted
intensive, focused inspections of approximately 1,012 licensed dealers;
identified more than 400 suspected firearms traffickers and nearly 300
prohibited purchasers, and referred 691 cases to special agents for further
investigation; conducted a demand letter initiative obtaining firearms
records from uncooperative dealers and 10- trace, short time- to- crime
dealers; resolved 75 percent (1, 336) of the unsuccessful crime gun traces
associated with the inspected licensees; identified 13, 271 missing
firearms; discovered 3,927 NICS criminal background check record keeping
errors; initiated license revocation proceedings for 20 FFLs; issued
proposed rules to require FFLs to conduct at least one physical inventory
each year and to report to ATF any firearms missing from their inventory,
and to require the shipper or sender to report losses of firearms that occur
in shipment; revised its license renewal form to verify the number of
transactions the FFL engaged in, in order to help determine whether the FFL
is engaged in the firearms business and qualifies for renewing the license;
and established policy guidelines for providing tracing data to importers
and manufacturers. This and other information on the project's results and
their policy implications will be provided in a final implementation report
to the Secretary, which is in the process of being prepared. Preparation of
the 2001 Firearms Commerce report is underway.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 77 GAO- 01- 305 Office of Enforcement's Operations 27. National
Criminal Instant Background Check System (NICS)

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility DAS (Law Enforcement) Primary role Oversight Purpose
To oversee ATF's implementation of the National Criminal Instant Background
Check

System (NICS). NICS is the system used to conduct background checks on
prospective firearms purchasers. If the FBI cannot complete a NICS check
within three days, a federal firearms licensee may release the firearm to
the purchaser. If the FBI subsequently determines the purchaser is
prohibited from purchasing a firearm (a “delayed denial”), ATF
is asked to retrieve the gun. A prior GAO review found a large ATF backlog
of delayed denials. How project initiated Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), ATF,
Office of General Counsel

? FBI

? None Why Enforcement was involved The Under Secretary wanted an
independent review of the ATF NICS operations. Functions Enforcement
performed ? Collected data from ATF on NICS denials and firearms retrievals
that were pending

and those completed.

? Briefed Under Secretary on status of ATF's NICS operations.

? Monitoring of all NICS operations, procedures followed by ATF, statistics
on denials and retrievals, resolution of problems in implementation.

? Encouraged ATF to find funding to create interface between NICS database
and ATF's general enforcement database (NFORCE). OF& A supported future
funding to achieve upgrades to ATF information systems.

? Discussions with FBI and ATF on NICS background check procedures and
regular meetings/ conference calls to discuss issues of interest to both ATF
and FBI. Project duration Start date: January 2000

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 10 to less than 25 percent of their time on the project. Project
results OE role identified problems hindering effective ATF implementation
of NICS and

recommended solutions. OE efforts helped ATF reduce its backlog of delayed
denial retrievals and recognize the need to create an interface between its
NICS database and NFORCE to meaningfully track retrievals. NICS tracking
data is now available at ATF.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 78 GAO- 01- 305 Office of Enforcement's Operations 28. Gun Show Report

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Policy
development and guidance Purpose Respond to a Presidential directive
concerning the need for background checks for all

guns sold at gun shows. How project initiated Presidential initiative
Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), Finance and
Administration, ATF, Office of General Counsel, Legislative Affairs

? Department of Justice, White House Domestic Policy Council

? State and/ or local governments, private sector Why Enforcement was
involved This was a White House policy initiative, carried out by OE, to
develop information, policy

analysis, and new firearms legislation, drawing on ATF information, legal
and enforcement knowledge, experience of the gun world, and firearms
expertise. Functions Enforcement performed ? OE collected extensive gun
show, gun crime, and enforcement related data with the

assistance of ATF in preparing both the Presidential directive itself and
the follow- up report (Gun Shows: Brady Checks and Crime Gun Traces).

? Extensive briefing and background materials were prepared for Treasury and
White House officials in connection with the directive, issuance of the
report, and announcement of the legislation resulting from the report.

? Extensive briefings of Treasury and White House officials in connection
with the directive, report, and legislation.

? Drafted legislation to require background checks at gun shows and
documentation permitting crime gun tracing.

? Gun Shows: Brady Checks and Crime Gun Traces, January 1999. Co- authored
with DOJ. ATF/ Treasury had the main pen, DOJ editorial role.

? Monitored report and legislation preparation.

? Reviewed drafts of report materials and report itself, as well as related
legislation, testimony, press information.

? Worked with ATF and OE budget office to develop budget estimates for
additional enforcement efforts.

? Gun show report co- authored with DOJ, ongoing discussions.

? Wrote routine correspondence and a number of speeches including references
to this report.

? Mentioned in various speeches and testimony by officials. Project duration
Start date: November 1998

End date: February 1999 Enforcement staffing level on the project 3 staff
members who spent 10 to less than 25 percent of their time on the project.
Project results ? Development of authoritative empirical information about
gun shows, for the benefit of

Congress, the media, and the public;

? New federal legislation on gun shows drafted and partially enacted
(pending in HouseSenate Conference);

? State legislative initiatives on gun shows in various stages;

? Heightened public understanding of the role of gun shows in supplying guns
to criminals and juveniles (as at Columbine) as reflected in the media and
local initiatives;

? Built public and Congressional support for revived gun show enforcement by
ATF (resulting in removal of internal ATF restrictions);

? Further developed public understanding of the role of the illegal market
generally in supplying guns to criminals and juveniles and the need for
corrective enforcement, legislative and regulatory actions.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 79 GAO- 01- 305 Office of Enforcement's Operations 29. Modified Assault
Rifles Import Ban

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Policy
development and guidance Purpose To determine the appropriateness of barring
so- called sporterized semi- automatic assault

rifles form importation and to take appropriate action. How project
initiated Self- initiated and presidential initiative: OE discussed the
possibility of an import ban on

sporterized rifles with the Domestic Policy Council, to follow up on the
1994 legislation (the assault weapons ban). This resulted in a Presidential
directive. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), ATF, Office of
Management, Office of General Counsel, Office of Legislative Affairs

? Department of Justice, OMB

? State and/ or local governments, private sector Why Enforcement was
involved This was a Presidential policy initiative to reexamine ATF
importation practice of applying

regulation to particular firearms. Functions Enforcement performed ?
Extensive data on sporterized assault weapons collected through survey made
a part

of the final report. OE and ATF worked closely together, with academic
experts, to prepare the report.

? Prepared briefing on directive, and progress and results of report.

? Treasury and White House officials briefed extensively.

? Report and its adoption by Secretarial memorandum constituted a new policy
application that resulted in regulatory action by ATF.

? Extensive report prepared in conjunction with ATF and General Counsel,
Department of Treasury Study on Sporting Suitability of Modified
Semiautomatic Assault Rifles, April 1998.

? Oversaw implementation of Administration initiative.

? Reviewed draft report materials, legislation needed to deal with after-
effects among importers.

? The report resulted in the need for legislation to compensate certain
firearms importers. Worked with Congress, OMB, and DOJ to provide
compensation.

? Worked closely with ATF to prepare report.

? Provided input for speeches by Secretary and White House officials.
Project duration Start date: August 1993

End date: December 1998 Enforcement staffing level on the project 2 staff
members who spent 10 to less than 25 percent of their time on the project.
Project results The final report produced by the project resulted in
regulatory action by ATF to ban the

importation of 29 types of assault weapons.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 80 GAO- 01- 305 Office of Enforcement's Operations 30. YCGII and Anti-
trafficking

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Support
Purpose (1) Focus ATF agent and inspector enforcement resources on reducing
juvenile and

youth violence at a time when juvenile homicides were spiking and public
concern was and remains high; (2) Expand use of crime gun tracing and trace
analysis (including mapping) to solve

gun crimes and reduce the illegal market in guns, especially those supplied
to criminals and juveniles; (3) Support ATF's development of and build
public support for an integrated firearms

enforcement policy and strategy that optimized ATF's expertise and authority
and did not rely exclusively on incarcerating individual violent offenders,
but also looked at illegal sources of guns fueling community violence and
“hot spots”; (4) Make ATF expertise and information more
available to State and local law

enforcement to strengthen enforcement of Federal, State and local gun laws;
(5) Expand law enforcement, media, and public understanding of the illegal
market in

guns -by teaching them to ask the question “where did the crime gun
come from?”- as a foundation for new regulation and laws that further
reduce illegal market access to guns; (6) Build public trust of ATF and
expand public and Congressional support for ATF's

firearms enforcement mission and an integrated firearms enforcement
strategy; (7) Integrate DOJ, including US Attorney, and OMB views of
firearms enforcement with

those of Treasury and ATF. How project initiated OE self- initiated the
project in September 1995, and it was adopted as a Presidential

initiative in Summer 1996. OMB also took significant budget action for FY 96
that required that ATF enforcement policy be re- focused away from a sole
focus on incarcerating individual violent offenders. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), Finance and Administration,
ATF, EOAF, Office of Management, Office of General Counsel, Office of
Legislative Affairs, Office of Inspector General

? Department of Justice, OMB, National Partnership for Reinventing
Government

? State and/ or local governments, law enforcement organizations, and
academic experts Why Enforcement was involved OE responded to President
Clinton's priority of reducing gun violence (as evidenced by

the Brady law and the Assault Weapons Ban) and the White House interest in
reducing youth violence generally, as evidenced by Mrs. Clinton's focus on
children. Since Treasury oversees ATF, we looked for a way to fulfill the
President's agenda within the appropriate scope of our authority. Thus, this
was an Administration initiative building on and drawing from ATF resources,
expertise, and ideas. YCGII is an example of a product of OE- ATF teamwork.
Functions Enforcement performed ? Numerous planning meetings involving data
collection in initial stages of project to

develop, explain and justify the initiative. Key data involved budget, FTE,
gun crime, and gun tracing information.

? Many volumes of briefing materials over the five- year period, for
principals, hearings, announcements, and media interviews. Three White House
events.

? Regularly briefed Treasury, OMB, DOJ, White House, Congressional staff and
principals in conjunction with plans, budgets, reports and appropriations
requests.

? OE and ATF worked together to draft this program, which began as an
initiative funded by the Treasury Asset Forfeiture Fund, and as the program
developed, new actions and strategies to further the project's objectives
enumerated above.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 81 GAO- 01- 305 Office of Enforcement's Operations

? Drafted or prepared three YCGII Crime Gun Trace Reports: 1997, 1999, 2000
(hereafter anticipated to be annual); YCGII Performance Report 1999 (by
request of Congressional appropriators); and, Following the Gun: Enforcing
Federal Laws Against Firearms Traffickers, June 2000 (indirectly related to
YCGII).

? Some monitoring of program implementation by DAS (Law Enforcement) and AS
(Enforcement) following computer crisis in connection with the 1999 Crime
Gun Trace Reports; similar type of oversight effort following 2000 IG
report.

? Most written products associated with this program, internal or external,
have been drafted, reviewed, or commented on by OE. These included briefing
papers, testimony, reports, and media background papers.

? Developed Administration/ ATF firearms enforcement initiatives from 1996
through FY 2001. Assisted in developing ATF annual budget proposals.
Responsible for major budget initiative, beyond that initially sought by the
agency, but developed with the assistance of bureau, OE, and Treasury budget
officers.

? Ongoing discussions and coordination with Justice, including cooperative
work with the Bureau of Justice Assistance, Bureau of Justice Statistics,
and National Institute of Justice. Plenty of disputes arose because this
was, from the perspective of DOJ, a bottom up initiative, that is, an
investigator initiative rather than a prosecutor initiative and also
involved State and locals, usually considered DOJ “turf.”

? Ongoing negotiations and compromise with DOJ (main DOJ and program/
funding agencies), OMB, and the Hill, all normal program development and
funding type of activities and disputes.

? Drafted language on YCGII and illegal market enforcement strategy for
speeches presented by Treasury and White House officials as well as routine
public correspondence.

? YCGII and illegal market enforcement strategy included in speeches by
Treasury and White House officials. OE also provided annual testimony that
addressed YCGII initiative. Project duration Start date: September 1995

No fixed end date Enforcement staffing level on the project 1 staff member
who spent 10 to less than 25 percent of his/ her time on the project. For

some weeks, full- time.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 82 GAO- 01- 305 Office of Enforcement's Operations

Project results Most significant results:

? Establishment of systematic field focus by ATF agents and inspectors on
illegal sources of guns, especially to young people, and use of field data
to expand information and feed it back into investigations and strategy,
resulting in strategically focused cases, and acceptance of broadened
enforcement strategy complementary to incarceration of individual violent
offenders;

? Major increase in crime gun tracing nationwide; improved investigative
methods at ATF such as deployment of online LEAD promoted through YCGII; and
establishment of new analytic unit at ATF, the Crime Gun Analysis Branch, to
analyze crime gun data for investigations, service ATF offices and State and
local law enforcement agencies, and provide public reporting;

? Annual YCGII Crime Gun Trace Reports now a major law enforcement tool and
tool for informing the public, on a city by city and national basis, of
crime gun trends. Unlike many crime reports, these provide not just numbers
as reported by localities, but analysis, that is, they take raw information
from States and localities, and return it with Federal value added, based on
information that only the Federal government has (in this case, results of
trace requests);

? Additional reports, e. g., Following the Gun, using research techniques
developed in YCGII, illuminate the illegal market in guns for policy and
political level, making public dialogue about new gun laws and enforcement
more informed;

? Achievement of the acceptance by law enforcement, the Congress, public,
and the media of the need to know where the crime gun comes from, especially
where juveniles get their guns, and the need for strong enforcement action
and preventive measures (like closing the gun show loophole) against illegal
suppliers of guns to criminals and juveniles and not just against criminals
and youth after they have used the guns;

? Significant prosecutor, public, media, OMB, and Congressional acceptance
of attacking the illegal market, reducing illegal diversion and possession
of firearms, and interdicting gun trafficking, with media now educated to
ask, “Where did the crime gun come from?”, much better public
understanding of how criminals and juveniles get guns;

? Improved coordination with DOJ on firearms issues, including new DOJ
investment in illegal market research (by NIJ) and improved joint
understanding of the need to balance prosecution of armed offenders with
prosecution of their illegal suppliers and focus on preventing illegal
diversion.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 83 GAO- 01- 305 Office of Enforcement's Operations 31. Firearms
Legislation

Mission and goal supported Law enforcement mission: Fight violent crime
Primary responsibility Under Secretary (Enforcement) Primary role Policy
development and guidance Purpose Presidential initiative to develop new
firearms legislation to improve firearms enforcement

and prevent firearms crimes. How project initiated Self- initiated and
presidential initiative: OE had developed firearms legislation proposals

with ATF over a two year period and violence reduction legislation with all
bureaus as a matter of normal legislative development. White House requested
list of initiatives in connection with the development of a second
“Crime bill.” In April 1999, President Clinton submitted
firearms legislation to Congress. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), Finance and
Administration, ATF, Office of General Counsel, Office of Legislative
Affairs

? Department of Justice, OMB, White House Domestic Policy Council

? Law enforcement organizations Why Enforcement was involved OE coordinated
Administration initiative to develop new firearms legislation. Also

coordinated Administration FY 2001 Firearms Enforcement (Budget) Initiative.
OE drew on ATF expertise and expressed enforcement needs. Functions
Enforcement performed ? Data collected from ATF to develop and support
legislative proposals and “section- bysection” analysis and
factual support for the proposals.

? Briefing materials prepared on the legislation.

? Briefed Treasury, DOJ, and White House officials on proposals and progress
of project.

? Legislative strategies developed for gun proposals and the funding
initiative for ATF.

? Helped draft White House report on early version of legislation.

? Continual review of legislative proposals and many descriptions of them
used on the Hill.

? Developed and reviewed budget proposal seeking funding for ATF.

? Coordinated with DOJ and White House to resolve a number of contested
provisions in legislation.

? Drafted input for numerous speeches for Treasury and White House
officials.

? OE provided testimony on firearms enforcement initiative funding request.
Project duration Start date: 1997

No fixed end date Enforcement staffing level on the project 2 staff members
who spent 10 to less than 25 percent of their time on the project. Project
results ? Major firearms legislation submitted to Congress.

? Significant portions of the legislation passed both chambers.

? Significant increase in public and media awareness of key proposals.

? Unprecedented funding increase of $93 million for gun enforcement achieved
for ATF in FY2001.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 84 GAO- 01- 305 Office of Enforcement's Operations 32. 2000 Campaign

Mission and goal supported Law enforcement mission: Protect our nation's
leaders and visiting world leaders Primary responsibility DAS (Law
Enforcement) Primary role Support Purpose On behalf of the Secretary, OE
coordinates requests for Secret Service protection from

prospective major presidential and vice presidential candidates. How project
initiated Statutory requirement Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (Law
Enforcement), Finance and Administration, ATF, Customs Service, IRS/ CID,
Secret Service, Office of Management, Office of General Counsel, Office of
Legislative Affairs

? OMB, Congressional Advisory Committee

? State and/ or local governments, private sector Why Enforcement was
involved By statute (18 USC 3056 (a) (7)), the Secretary of the Treasury has
the authority to

decide which candidates receive USSS protection and when the protection
begins. OE briefs the Advisory Committee which the Secretary is required by
statute to consult prior to authorizing protection. OE also coordinates all
requests for protection and makes recommendations to the Secretary. The USSS
could not play a role in this process because of the potential of a conflict
of interest. Functions Enforcement performed ? OE plays a critical role in
the campaign budget process. The USSS normally needs

extra funding to support a presidential campaign. These funds are not needed
annually. Some funds for equipment and services are needed two years prior
to the campaign due to procurement lead time requirements. The majority of
the funding is needed during the campaign year to support the costs directly
associated to the campaign. OE also collects manpower data from the other
bureaus who support the USSS during the campaign.

? Numerous briefing and background materials are required to brief high-
ranking Treasury officials, OMB and congressional appropriators.

? Brief officials- A number high level Treasury, OMB and Congressional
appropriators request briefings on this issue. The Advisory Committee which
the Secretary is required to consult, must receive an in- depth briefing on
the entire process. The Advisory Committee is made up of the Speaker of the
House, Minority Leader of the House, the Majority and Minority leaders in
the Senate plus one additional member selected by the committee.

? The Advisory Committee guidelines must be reviewed and adopted by the
Advisory Committee prior to the campaign. OE is responsible for reviewing
and updating the guidelines. These guidelines serve as a baseline for
approving requests for USSS protection by major presidential and vice
presidential candidates.

? Develop or draft policies, directives, standards, regulations- The
Advisory Committee guidelines are critical to evaluation process and making
decisions concerning to requests for USSS protection.

? The reporting requirements relating to the campaign are as follows:

? A letter from the Secretary to each member of the Advisory Committee
inviting them to participate in this process must be prepared.

? When a request for USSS protection from a candidate is received at DO, the
following memoranda/ correspondence are prepared:

? A memorandum from the Enforcement Policy Officer to the Under Secretary is
prepared.

? A memorandum from the Under Secretary to the Secretary is prepared.

? A letter from the Secretary to the candidate is prepared.

? If the request is authorized, a memorandum from the Secretary to the
Director- USSS is prepared.

? The Under Secretary (Enforcement) who has oversight of the USSS, oversees
the

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 85 GAO- 01- 305 Office of Enforcement's Operations

protective mission of the Secret Service.

? Review documents, such as assessments of eligibility of candidates for
protection and threat assessments of candidates. In addition to what has
previously been mentioned, numerous budget- related materials are reviewed
in conjunction with funding required to support the campaign.

? Review funding proposals by Secret Service and other bureaus who are
required to support protection of candidates.

? OE coordinates manpower requests with the other Treasury bureaus who are
directed to support the USSS during campaign years.

? As previously mentioned, letters are written to candidates who have
requested protection. In addition, letters are written to members of the
Advisory Committee.

? Due to the budgetary concerns pertaining to a presidential campaign and
the history of assassinations in this country, this is a high profile
project that requires testimony to OMB and Congressional appropriators.
Project duration Start date: October 1999

Anticipated end date: March 2001 Enforcement staffing level on the project 5
staff members who spent 25 to less than 50 percent of their time one the
project. Project results Project results in determinations of eligibility,
etc., for protection of candidates. Eligible

candidates receive comprehensive protective details provided throughout the
campaign.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 86 GAO- 01- 305 Office of Enforcement's Operations 33. Secret Service-
Agent Review

Mission and goal supported Law enforcement mission: Protect our nation's
leaders and visiting world leaders Primary responsibility Assistant
Secretary (Enforcement) Primary role Support Purpose To analyze the issues
and demands that were driving staffing problems in the Secret

Service, the Office of Enforcement established a Secret Service Working
Group on Workforce Retention and Workload Balancing, which was overseen by
an Executive Committee of Assistant Secretary (Enforcement), Assistant
Secretary (Management) and the Secret Service Director. The Office of
Management and Budget also participated in the working group. Secret Service
was having increasing difficulty retaining agents, due in part to
significant increases in the amount of travel and overtime. The purpose of
the Working Group was to examine staffing and other quality of life issues
facing the Secret Service agent population and develop recommendations to
address these issues. How project initiated Self- initiated: the project was
initiated by OE after Secret Service raised issues regarding

staffing levels and agent retention. OMB was supportive of a review as part
of any staffing increase request by Secret Service. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (Law Enforcement), Finance and Administration, Secret Service, Office
of Management, Treasury Counsel

? OMB

? None Why Enforcement was involved OE undertook this project in conjunction
with the Secret Service, Treasury's Office of

Management, and OMB. OE sought to support the Secret Service as it worked to
address staffing and quality of life issues in its agent population. OE
support was critical to Secret Service being successful in getting an
increased number of agent FTE. Functions Enforcement performed ? OE staff
collected data from Secret Service regarding staffing and quality of life
issues.

Data included- overtime, travel time, attrition, staffing, and other
relevant information.

? OE staff prepared memoranda for Treasury officials reporting the working
group's findings and recommendations.

? OE staff provided briefings to Treasury and OMB officials on the working
group's findings.

? OE staff developed recommendations for improving the quality of life of
agents in the Secret Service.

? OE staff drafted an action plan and a report on the working group's
findings and recommendations

? OE staff, in conjunction with other members of the Executive Committee,
monitored the work of the working group.

? OE staff reviewed the working groups Action Plan and draft working group
report (done by other OE staff).

? Working with other working group members, OE staff helped prepare a
proposal to increase Secret Service staffing, including the related budget
request.

? OE coordinated the proposed staffing increase and related budget request
with OMB. Project duration Start date: October 1999

End date: December 1999 Enforcement staffing level on the project 6 staff
members who spent 50 to less than 75 percent of their time on the project.
Project results As the result of the project, Secret Service is expected to
receive a significant increase in

agent FTE (approximately 228 new agents can be hired in FY 2000 and
approximately 454 new agents can be hired in FY 2001). Additionally, a
number of administrative and management changes were made to improve agent
quality of life.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 87 GAO- 01- 305 Office of Enforcement's Operations 34. Secret Service-
Uniformed Division Review

Mission and goal supported Law enforcement mission: Protect our nation's
leaders and visiting world leaders Primary responsibility Assistant
Secretary (Enforcement) Primary role Support Purpose The Secret Service's
mission has grown progressively more difficult and complex with

increasing demands on both its agent and uniformed workforce. In 1999 an
interagency working group reviewed staffing issues among the agent workforce
and developed recommendations designed to assist the Secret Service in
improving retention and enhancing worklife. As the result of the agent
review, Secret Service is expected to receive a significant increase in
agent FTE (approximately 228 new agents can be hired in FY 2000 and
approximately 454 new agents can be hired in FY 2001). Additionally, a
number of administrative and management changes were made to improve agent
quality of life. Given the success of the agent working group, an
interagency working group was convened to conduct a similar review of Secret
Service's Uniformed Division (UD). Attrition has become a significant issue
for the UD for a number of reasons, including a significant increase in the
amount overtime leading to cancelled days off and annual leave. How project
initiated Self- initiated: the project was initiated by OE after consulting
with Secret Service. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? DAS (Law Enforcement), Finance and Administration, Secret Service, Office
of Management, Treasury Counsel

? OMB

? None Why Enforcement was involved OE undertook this project in conjunction
with the Secret Service, Treasury's Office of

Management, and OMB. OE was able to provide a broader, third- party
perspective, and sought to support the Secret Service as it worked to
address staffing and quality of life issues in its Uniformed Division. OE's
involvement in a similar agent review was critical to getting the Secret
Service additional resources. OE and Secret Service have sought to duplicate
the success of the agent review. Functions Enforcement performed ? OE staff
collected data from Secret Service regarding pay, staffing levels,
attrition,

overtime, travel, and other information.

? OE staff have briefed other Treasury officials on the status of the
review.

? OE staff developed recommendations to improve quality of life for Secret
Service Uniformed Division Officers.

? OE staff took the lead in drafting the working group's Action Plan and is
the lead drafter of the report of the working group's findings and
recommendations.

? OE staff monitored the progress of the working group (which also included
other OE staff).

? OE staff reviewed the working group's Action Plan and is currently
reviewing the draft working group report (both of which was prepared by
other OE staff with help from other working group members).

? OE staff, in conjunction with staff from Treasury Management and Secret
Service, is developing a proposal to increase the number of uniformed
officers and the related budget request.

? OE is coordinating the working group's efforts with OMB. Project duration
Start date: June 2000

Anticipated end date: October 2000 Enforcement staffing level on the project
6 staff members who spent 25 to less than 50 percent of their time on the
project.

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Page 88 GAO- 01- 305 Office of Enforcement's Operations

Project results We anticipate that the working group will make a number of
recommendations to improve the quality of life and career development of
Uniformed Division Officers, including a significant increase in Officer
staffing. As the result of a similar review done for agents, Secret Service
is expected to receive a significant increase in agent FTE (approximately
228 new agents can be hired in FY 2000 and approximately 454 new agents can
be hired in FY 2001). Additionally, the agent review led to a number of
administrative and management changes to improve agent quality of life.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 89 GAO- 01- 305 Office of Enforcement's Operations 35. International
Monetary Fund (IMF) and the World Bank Spring

Ministerial Meeting

Mission and goal supported Law enforcement mission: Protect our nation's
leaders and visiting world leaders Primary responsibility Assistant
Secretary (Enforcement) Primary role Oversight Purpose The IMF/ World Bank
annual meeting was held in Washington, DC, from April 15 to 17,

2000, and hosted by the Department of the Treasury. OE's responsibility was
to maintain oversight of the security arrangements for the event. How
project initiated Self- initiated and other a : the initial request for
Secret Service protection of the event was

received in a letter dated January 18, 2000 from the IMF/ World Bank. OE
supported the request. The Treasury Secretary directed OE to provide close
oversight of operations. The adverse intelligence received by law
enforcement and the recent civil unrest experienced in Seattle, Washington,
during the World Trade Organization meetings brought increased attention to
this matter. The Secret Service had provided security for the Fall IMF/
World Bank meetings in previous years, however, this was the first year
where substantial protest activity was anticipated. As this event was hosted
by the Department of the Treasury and the Secretary (a Secret Service
protectee), OE was heavily involved in the decision to provide Secret
Service security for the event. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), DAS (RT& T), Finance and
Administration, Secret Service, Office of Management, Office of
International Affairs, Office of General Counsel, Office of Public Affairs,
Office of the Secretary and Deputy Secretary

? Department of Defense, Department of Justice, Department of State, FBI

? State and/ or local governments Why Enforcement was involved OE provided
direction and leadership to the Secret Service. Additionally, the OE played
a

major role in a liaison capacity between law enforcement and the IMF/ World
Bank and Treasury Management. In particular, OE arranged for a meeting
between the Secretary and the Mayor DC and the Chief of the Metropolitan
Police Department in order to discuss the security concerns in greater
detail. OE also worked with high level officials at the IMF/ World Bank, as
well as with the Attorney General to ensure our efforts were coordinated.
Functions Enforcement performed ? Collected data on event activities.
Informational data for resources and funding

purposes. Data collected to respond to Congressional and Executive
inquiries.

? Prepared informational materials and status briefings for the Secretary,
the Deputy Secretary, and their staffs.

? Briefings for Secretary and Treasury officials, and for other
organizations in and out of the Federal Government, directly affected by the
event. Also briefed the Attorney General and officials at the Justice
Department.

? Strengthened standards for aggressive oversight of cooperation between
Federal and local law enforcement.

? Drafted or prepared informational and briefing reports of actions as
events occurred throughout the period of the IMF/ World Bank meetings.

? Extensive meetings and “table top” security exercises with the
bureaus and outside entities relating to the event.

? Reviewed reports from the Secret Service, FBI and local law enforcement.

? OE oversaw the coordination among all law enforcement entities involved in
the preparations for this event.

? Wrote correspondence to IMF/ World Bank regarding the requested security
for the event. Project duration Start date: January 2000

End date: April 2000

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 90 GAO- 01- 305 Office of Enforcement's Operations

Enforcement staffing level on the project 5 staff members who spent 25 to
less than 50 percent of their time on the project. Project results Security
for the IMF/ World Bank Spring meetings was a complete success.
Relationships

between the Secret Service and state, local, and Federal law enforcement
have been strengthened because of the cooperation exhibited in preparation
for the event. In addition, the IMF/ World Bank meetings took place as
scheduled and were not disrupted due to the coordinated relationship of law
enforcement. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 91 GAO- 01- 305 Office of Enforcement's Operations 36. Training Group

Mission and goal supported Law enforcement mission: Provide high- quality
training for law enforcement personnel Primary responsibility DAS (Law
Enforcement) Primary role Oversight Purpose To advise the Office of the
Under Secretary (Enforcement) on the overall training

programs and training initiatives in the Treasury's law enforcement bureaus.
A group of training experts from the Treasury bureaus was developed. The
group, which meets approximately once per month, provides the Under
Secretary for Enforcement an assessment, both short term and long range, on
training implications for personnel within the Treasury law enforcement
bureaus; and ensures quality training is provided for all personnel, law
enforcement, professional, administrative, technical and support. One of the
projects on which the group has focused was the establishment of a firearms
requalification range in the Washington, DC area. How project initiated
Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), ATF, Customs
Service, FinCEN, FLETC, IRS/ CID, Secret Service

? Members of the Range/ Training Working Group: U. S. Park Police, U. S.
Capitol Police, and Metropolitan Police, District of Columbia

? State and/ or local governments Why Enforcement was involved The Under
Secretary wanted to ensure quality training was being provided for all

personnel: law enforcement, professional, administrative, technical and
support. The US wanted to monitor the International Law Enforcement Officer
training provided by the Treasury Bureaus, through ILEA, to ensure proper
utilization of resources. Overall, the objective was to ensure the quality,
cost effectiveness and timeliness of training, and to ensure the policy of
Best Practice as it relates to training programs is available and followed
by all Treasury law enforcement bureaus. Functions Enforcement performed ?
Conducted an assessment of the firearms requirements of Treasury law
enforcement

officers.

? Briefing materials were provided to the Under Secretary.

? Briefings were provided for the Under Secretary and senior officials of
the Treasury. bureaus, other Federal law enforcement bureaus, local law
enforcement, and members of Congress.

? Prepared an assessment report providing recommendations to the Under
Secretary.

? A firearms assessment report was prepared.

? The training provided by the law enforcement bureaus, both through FLETC
and through their own bureau training programs, is overseen and monitored.

? Reviewed FLETC submission to the Appropriations Committees on the need for
a consolidated firearms requalification training range in the greater
Washington, DC area.

? Work closely with Treasury and other law enforcement bureaus on the
development of projects, such as the firearms range in the Washington, DC
area. Project duration Start date: February 1998

No fixed end date Enforcement staffing level on the project 1 staff member
who spent 10 to less than 25 percent of his/ her time on the project.
Project results The training group has exchanged ideas and information on
training issues relevant to all

of the Treasury law enforcement bureaus to determine the feasibility of
establishing a consolidated training facilities for Treasury bureaus in the
Washington area. On one project, the firearms requalification range, the
group conducted a review and feasibility study. As a result of that study, a
site was located in the metropolitan area that is now being considered for
development.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 92 GAO- 01- 305 Office of Enforcement's Operations 37. Map of the World
(MTW)

Mission and goal supported Law enforcement mission: Provide high- quality
training for law enforcement personnel Primary responsibility DAS (Law
Enforcement) Primary role Oversight Purpose The Department of the Treasury's
Map of the World (MTW) is a collection of the

international criminal justice activities and enforcement priorities of all
Treasury enforcement agencies in all regions of the world. The ultimate
objective for MTW is to develop a plan to address international crime
through the administration of international justice assistance programs.
After Treasury's plan is complete, it will be consolidated with the
priorities of Justice, State, and AID to form a combined strategy for
providing international law enforcement assistance. How project initiated
Other a : the Department of Justice, through the Attorney General, provided
the Department

of the Treasury with a copy of its MTW. That report concludes, that the MTW
is a work in progress and that it will require periodic updates to ensure
that it reflects evolving international issues, and accurately expresses
current priorities of Justice. The Deputy Secretary of the Treasury asked
the Office of Enforcement to develop a complementary Treasury MTW plan and
to work with Justice and State to coordinate programs. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (Enforcement Policy), DAS (Law
Enforcement), DAS (RT& T), Finance and Administration, ATF, Customs Service,
EOAF, FinCEN, FLETC, IRS/ CID, OFAC, Secret Service, Office of Management,
Office of International Affairs

? Department of Justice, Department of State, DEA, FBI, Agency for
International Development (AID)

? None Why Enforcement was involved Office of Enforcement was able to bring
all interested parties to the table in order to share

information regarding training needs and priorities to form a Treasury MTW.
Such a universal approach that could only be provided by OE. Functions
Enforcement performed ? Each bureau provided information, by region, which
was reviewed and analyzed.

Meetings were held weekly to discuss the information and the goals of the
Treasury law enforcement bureaus.

? Briefing materials were prepared to advise the Under Secretary, the Deputy
Secretary, and other senior Treasury officials of the progress on MTW.

? OE provided status reports to the Deputy Secretary.

? OE, after collecting data from the Treasury bureaus, reviewed, prioritized
and drafted the strategies provided in the MTW.

? The Department of the Treasury will provide to the Departments of State
and Justice, its version of the MTW upon completion.

? Coordinated with Treasury bureaus and Justice on the development of
Treasury's MTW.

? When a program, strategy, or issues came into questions, OE would attempt
to resolve the issue with the interested parties. Normally, those parties
were the Treasury law enforcement bureaus. Project duration Start date:
October 1999

No fixed end date Enforcement staffing level on the project 5 staff members
who spent 25 to less than 50 percent of their time on the project.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 93 GAO- 01- 305 Office of Enforcement's Operations

Project results Treasury's Office of Enforcement coordinated and compiled
Treasury's MTW. Two principal areas are addressed by the MTW: 1. MTW
recommends specific training, institution building, and technical assistance

activities which, Treasury components believe, should be emphasized as part
of the budget cycle. 2. MTW represents a comprehensive statement of
Treasury's international perspectives

believed to serve as a cornerstone on which Treasury is to build an
institutional mechanism for policy level discussions and collaborative
efforts. The MTW is a work in progress that will require periodic updates to
ensure that it reflects evolving international issues, and accurately
expresses current priorities. Further, MTW will also be used to provide
information that will enable the Department of Treasury and participating
agencies to collaborate in planning the international training and
assistance programs. The MTW is organized by geographic region. Each
regional section:

- provides an overview that briefly assesses the prominent criminal
activities and justice systems that affect U. S. interests; - identifies key
countries believed to be representative of the most serious crime challenges
throughout the region and which warrant immediate action; - outlines
multilateral organizations and initiatives; - describes Treasury components'
overseas presence and their current activities; and - identifies the
principal challenges and goals of strategic planning. a Response categories
included self- initiated, statutory requirement, other congressional
direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 94 GAO- 01- 305 Office of Enforcement's Operations 38. International
Law Enforcement Academies

Mission and goal supported Law enforcement mission: Provide high- quality
training for law enforcement personnel Primary responsibility DAS (Law
Enforcement) Primary role Oversight Purpose The International Law
Enforcement Academies (ILEA) are a cooperative effort among the

Departments of State, Justice and Treasury. Treasury Enforcement is directly
involved in the development and activities of two ILEAs and participates in
two other ILEAs. To accomplish overall coordination of the ILEAs, a Policy
Board was established that is comprised of members from each Department and
appointed by the Secretary of State, the Attorney General and the Secretary
of the Treasury. The mission of these academies has been to support emerging
democracies, help protect U. S. interests through international cooperation
and to promote social, political and economic stability by combating crime.
ILEAs also encourage strong partnerships among regional countries, to
address common problems associated with criminal activities. How project
initiated Presidential initiative Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (Law
Enforcement), ATF, Customs Service, FinCEN, FLETC, IRS/ CID, Secret Service

? Department of Justice, Department of State, DEA, FBI

? Foreign governments Why Enforcement was involved The International Law
Enforcement Academies (ILEA) are a cooperative effort between

the Departments of State, Justice and Treasury. By ILEA Charter, the Under
Secretary for Enforcement is a member of a Policy Board, comprised of
members from each Department appointed by the Secretary of State, the
Attorney General and the Secretary of the Treasury that guides all ILEAs. As
such, the Under Secretary brings the overall Treasury view to the Board not
just individual Treasury law enforcement bureaus views. Functions
Enforcement performed ? Collect data on training that should be conducted in
each ILEA region.

? Provide to the bureaus suggested agenda for upcoming Policy Board meetings
and then prepares the Treasury position taking into consideration all the
bureaus concerns. Provides to the Treasury law enforcement bureaus guidance
from the Policy Board.

? Developed concept of Policy Board and leadership at ILEAs. Identifies
sites and propose final selected locations for ILEAs. Develops proposals for
training courses.

? After consultation with the Departments of State and Justice, provides
policies and directives on the operations and activities of the ILEAs to all
Treasury law enforcement bureaus.

? Oversees and monitors the operation of all ILEAs as a member of the Policy
Board. Directly oversees FLETC operations at ILEAs. Supervises Treasury
employees detailed to the ILEAs.

? Reviews budget, policy, operations and ILEA program results.

? Obtains funding and FTE for Treasury to participate as Director or Deputy
Director of ILEAs. Develops MOUs with State Department to obtain funding for
ILEA operations.

? Participates in steering group that discusses working- level issues
related to the ILEAs. Coordinates positions with Treasury bureaus and
consults with Justice and State regarding all ILEA issues.

? As a member of the Policy Board, identifies area of concern for Federal
law enforcement, determines the need for a new ILEA, and if approved,
provides a team to negotiate with the host government on the establishment
of an ILEA in the region. Enforcement participates on all negotiation teams.

? Responds to inquiries from members of congress, international community
and law enforcement. Project duration Start date: February 1998

No fixed end date

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 95 GAO- 01- 305 Office of Enforcement's Operations

Enforcement staffing level on the project 4 staff members who spent 25 to
less than 50 percent of their time on the project. Project results The
United States has undertaken several initiatives to address the challenges
of

international crime. One of the most important is the establishment of
regional law enforcement academies to train foreign law enforcement and
criminal justice personnel. The mission of these academies is to support
emerging democracies, help protect U. S. interests through international
cooperation and promote social, political and economic stability by
combating crime. ILEAs also encourage strong partnerships among regional
countries to address common problems associated with criminal activities.

The success of the ILEA Budapest led President Clinton, at the San Jose,
Costa Rica Summit in May of 1997, to announce that an ILEA for Latin America
would be established in that region. To deliver on the commitment made by
the President, and as a matter of policy and process, courses were conducted
in both Panama and Costa Rica during 1998 and 1999. The Policy Board is
currently working on establishing a Western Hemisphere ILEA in Costa Rica.
Further, the ILEA Policy Board, after an initial assessment of four
countries, has decided to establish an ILEA for Southern Africa in Botswana.
Negotiations (MOUs) with the Government of Botswana (GOB) were conducted in
Gaborone, Botswana from February 14 through February 18, 2000. The
negotiating team consisted of representatives from the Departments of
Justice, State and the Treasury. The MOU between USG and GOB should be
signed at the end of September 2000.

The ILEA philosophy and intent is to encourage nations in a particular
region to develop institutions, support the concepts of regional
participation, and share financial and programmatic responsibilities for law
enforcement training.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 96 GAO- 01- 305 Office of Enforcement's Operations 39. Federal Law
Enforcement Training Center (FLETC)

Organizational Assessment and Implementation

Mission and goal supported Law enforcement mission: Provide high- quality
training for law enforcement personnel Primary responsibility DAS (Law
Enforcement)- when former DAS became Assistant Secretary (Enforcement)

project moved with her Primary role Oversight Purpose OE became aware of a
number of issues at FLETC that raised concerns, including a lack

of diversity in the FLETC workforce and employee complaints regarding a
wide- range of EEO and management issues. OE staff made a number of trips to
FLETC and met with managers and employees. During these visits, employees
repeatedly raised EEO and management issues. Additionally, OE received a
number of written complaints from FLETC employees regarding FLETC management
and EEO matters. To address these issues, OE contracted the performance of
an “Organizational Assessment of the Federal Law Enforcement Training
Center” (“ Organizational Assessment”) focusing on human
resources, including EEO and sexual harassment, management practices, and
environmental, health and safety. The purpose was to review these areas,
identify issues, and make recommendations for improvement. How project
initiated Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), Finance
and Administration, EOAF, FLETC, Office of Management, Treasury Counsel

? Department of Justice, OMB, Members of FLETC's Board of Directors (in
addition to OE, members are: Department of Justice, Department of Interior,
GSA, OPM, OMB, and the House of Representatives Sergeant at Arms) were
briefed on the project, as well as Congressional staff

? None Why Enforcement was involved The review was done as part of OE's
oversight responsibility, it was done by an outside

management consultant, and included a review of FLETC senior management. As
noted above, one of the factors that lead to the review was a number of
employee complaints regarding EEO and FLETC management. Because of the
nature of the review, FLETC was not in a position to do the review itself.
Functions Enforcement performed ? OE staff worked to ensure that the
contractor received all materials it requested from

FLETC.

? OE staff prepared memoranda for Treasury officials on the status and
results of the review and implementation of the recommendations.

? OE staff participated in briefings for Treasury officials regarding the
status and results of the review and implementation of the recommendations.
OE staff also briefed members of FLETC's board of directors and
Congressional staff.

? OE staff worked with FLETC and other Treasury offices to develop a plan to
implement the Assessment's recommendations and then helped FLETC implement
the recommendations.

? OE staff oversaw the work being done by the contractor on the report,
including weekly conference calls and periodic briefings. OE staff also
reviewed status reports and draft reports. Additionally, to ensure
implementation of report recommendations, OE formed an implementation
working group chaired initially by the DAS (Law Enforcement) and then by the
Assistant Secretary (when the former DAS became A/ S). Other OE staff also
supported the working group.

? OE staff reviewed status reports and drafts of the final report by the
contractor. OE staff also reviewed status reports on implementation from
FLETC.

? OE staff worked w/ IRS procurement and the Executive Office of Asset
Forfeiture to fund the contract for the Organizational Assessment.

? OE staff briefed other FLETC stakeholders on the Organizational
Assessment. OE staff also prepared letters for members of Congress on the
report.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 97 GAO- 01- 305 Office of Enforcement's Operations

? OE staff prepared letters for members of Congress on the Assessment and
implementation. Project duration Start date: July 1997

End date: April 2000 Enforcement staffing level on the project 5 staff
members who spent 10 to less than 25 percent of their time on the project.
Project results The former Director of FLETC retired after receiving a copy
of the draft report and

discussing it with the former Under Secretary. Working with OE, the new
Director has implemented a wide range of initiatives and improvements
relating to the areas covered by the Assessment, including strengthening its
EEO system and its environmental controls. OE staff have made repeated site
visits to FLETC facilities and have interviewed employees and participating
organizations. These interviews indicate a significant improvement in morale
of employees and increased satisfaction of participating organizations.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 98 GAO- 01- 305 Office of Enforcement's Operations 40. Establishment of
the Office of Professional Responsibility

(OPR)

Mission and goal supported Management mission: Improve management operations
Primary responsibility Under Secretary (Enforcement) Primary role Oversight
Purpose To establish an Office within Enforcement to provide advice to the
Under Secretary and

oversee operational issues relating both to the individual law enforcement
bureaus and offices, and to cross- cutting jurisdictional areas, such as
training, equal opportunity and personnel practices, internal affairs, and
inspection. How project initiated Self- initiated and other Congressional
direction a : in Fiscal Year 1997 Appropriations Bill,

Congress directed the establishment of the Office of Professional
responsibility. Then Under Secretary Kelly was also exploring the options
for expanding Enforcement staff to permit more in- depth assessment of the
bureaus' activities. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), DAS (Law
Enforcement), Finance and Administration, ATF, Customs Service, FLETC,
Secret Service, Office of Management, Legislative Affairs

? OMB, OPM

? None Why Enforcement was involved This was inherently an Office of
Enforcement function. However, the Bureaus were

consulted regarding the mission and composition of the office. Functions
Enforcement performed ? OE staff collected information to prepare position
descriptions and determine

appropriate grade levels for the new employees.

? Numerous briefings were prepared to explain the need for the office,
outline the proposal, present options, and identify the necessary staffing
level.

? Officials within Treasury, OMB, OPM and Congress received briefings.

? A plan, organizational chart, position descriptions, and vacancy
announcements were developed.

? Congress was provided with information regarding Enforcement's progress in
establishing OPR.

? The progress of obtaining all the necessary approvals for the office,
staff, funding and space were monitored to ensure that they were moving
forward as expeditiously as possible.

? The cost of staffing, office space, equipment, travel and expenses, etc
was calculated and funding was sought within the Department, at OMB, and
from Congress.

? Enforcement coordinated with the Office of the Inspector General to ensure
that there was no duplication in the missions of the two offices.

? It was necessary to negotiate with Management and OMB to obtain approval
for the establishment of the office.

? Letters to members of Congress, OPM, OMB were drafted, reviewed and
approved.

? Progress on the establishment of OPR and accomplishments of OPR have been
reported to Congress each year in Appropriations testimony. Project duration
Start date: October 1996

Anticipated end date: when funding is available Enforcement staffing level
on the project 4 staff members who spent less than 10 percent of their time
on the project.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 99 GAO- 01- 305 Office of Enforcement's Operations

Project results OPR was established and the first staff members hired in
early 1998. Since that time, additional staff members have been recruited,
brought on board and integrated into the office. While OE has not been
allowed to staff the office as it would have liked due to funding
constraints, it has been able to assemble a staff with specific bureau
expertise, as well expertise in subject matter areas that cross bureau
jurisdictional lines. Numerous efforts have been made, or are underway, by
the OPR staff to support and enhance operations of the Treasury bureaus.
Examples include the assessment of the vulnerabilities to corruption and
effectiveness of the Customs Service Office of Internal Affairs; Treasury/
Justice funding parity review; assessment of the Customs passenger
processing enforcement targeting program; efforts to obtain a firearms
requalification range to serve law enforcement in the Washington, DC area;
implementation of the Fairness in Law Enforcement Executive order; oversight
of ATF's implementation of the National Criminal Instant Background Check
System; review of OFAC document destruction; Secret Service agent Review;
Secret Service Uniform Division review; and Treasury's Map of the World
international law enforcement training plan. a Response categories included
self- initiated, statutory requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 100 GAO- 01- 305 Office of Enforcement's Operations 41. Schedule B

Mission and goal supported Management mission: Improve management operations
Primary responsibility Finance and Administration Primary role Support
Purpose Schedule B authority equipped our bureaus with recruitment and
hiring tools similar to

other major federal law agencies; and thereby enabled us to hire the
brightest and most skilled. How project initiated Self- initiated Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), Finance
and Administration, ATF, Customs Service, FLETC, IRS/ CID, Secret Service,
Office of Management

? OMB, OPM

? None Why Enforcement was involved This project affected several bureaus
and required direction at a higher level. Once the

Office of the Under Secretary (Enforcement) made this need a high priority,
he led/ held numerous senior level meetings with OPM Director LaChance, OMB,
etc. He even engaged White House staff. Functions Enforcement performed ?
Personnel data was collected from each law enforcement bureau regarding
race,

national origin, grade, gender, etc.

? Briefing and background memoranda prepared for written briefings and oral
presentations.

? Briefings were held for Treasury and bureau policy officials and for OPM
and OMB officials.

? Strategy and program for achieving Schedule B Authority developed by the
Office of Enforcement. Program developed for implementing once authority
obtained.

? The Offices of Enforcement and Management worked closely to draft an
Executive order for the President to sign granting the Schedule B Authority.

? Enforcement coordinated and oversaw the entire project to gain hiring
relief through Schedule B Authority. Project impetus was assisted by such
Congressionally mandated studies as the earlier Hay Group Report that also
looked at hiring difficulties for the Treasury law enforcement bureaus.
Enforcement's role in leading all these efforts was a benefit and helped
achieve Schedule B Authority.

? Written products reviewed included memoranda, draft testimony, and the
draft Executive order.

? Enforcement coordinated with OPM, OMB, and the enforcement bureaus as they
all had equities or jurisdiction in the granting of Schedule B Authority.

? Negotiated with OPM and OMB.

? Draft testimony prepared for Under Secretary to address the Schedule B
Authority issue.

? This issue was part of the testimony of Office of the Under Secretary
(Enforcement) regarding FY00 and FY01 Appropriations. Project duration Start
date: Summer 1998

End date: Summer 2000 OE staffing level on the project 1 staff member who
spent 10 to less than 25 percent of his/ her time on the project. From

start to finish at least 4 to 6 months on a full- time basis.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 101 GAO- 01- 305 Office of Enforcement's Operations

Project results This project was a clear winner. Treasury Enforcement now
has direct hiring authority. The Office of Enforcement's role in
coordinating all of the recent hiring, recruitment, and retention studies
for law enforcement bureaus has helped to propel the movement to achieve
Schedule B Authority. Among the anticipated benefits of the new hiring
authority are: (1) maximum flexibility to target recruiting on much- needed
skill sets; (2) greater ability to achieve diversity goals: (3) increased
ability to focus on the large number of intangible skills and personal
characteristics needed for successful law enforcement performance; and (4)
faster and more efficient processes to search out and hire the best
candidates for special agent positions.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 102 GAO- 01- 305 Office of Enforcement's Operations 42. Retirement
Bubble

Mission and goal supported Management mission: Improve management operations
Primary responsibility Finance and Administration Primary role Support
Purpose Treasury was concerned that its enforcement bureaus were going to
lose 50% of its

agents over a five- year period, due to retirement. As mandated in House
Report 105- 592, Treasury was instructed to analyze the impact of
potentially large numbers of criminal investigator retirements that would
occur over the next several years. Enforcement designed and chaired a
working group to formulate a solid statement of work and, in turn, let and
managed the contract to study the issue. How project initiated Self-
initiated and other Congressional direction a : the Office of Enforcement
had

recognized a disproportionate number of retirements occurring and the
potential for significant more numbers in a short period. In House Report
105- 592, Congress also recognized the potential problem and mandated a
review. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary, Assistant Secretary (Enforcement), ATF, Customs Service,
FLETC, IRS/ CID, Secret Service, Office of Management

? OMB, OPM

? Private sector- contractor HuMMRO Why Enforcement was involved The Office
of Enforcement was able to provide a broader perspective on a problem that

had an impact on all the Treasury enforcement bureaus. At the same time,
Congress required Treasury to conduct an analysis. Functions Enforcement
performed ? The Office of Enforcement captured data from OPM and the
Department's database for

the preliminary assessments.

? Briefing materials were prepared on the work plan and final report to
Congress.

? The Under Secretary and enforcement bureau heads were briefed on the
progress and final report prepared by the group.

? Recommendations and strategy for addressing the problem were outlined in
the final report.

? Reports of progress were prepared and group produced final report.

? The Office of Enforcement chaired the working group, managed the contract,
and oversaw progress of the effort.

? The final report to Congress and numerous memoranda were among written
products reviewed.

? Enforcement coordinated with OPM, OMB, Treasury law enforcement bureaus,
and the Office of Management to complete the project.

? Testimony was drafted by Enforcement staff.

? The Under Secretary presented testimony at appropriations hearings.
Project duration Start date: Fall 1998

End date: Spring 1999 Enforcement staffing level on the project 3 staff
members who spent less than 10 percent of their time on the project. Project
results The final report objectively quantified Treasury enforcement bureau
critical resource

needs to address the large number of agents approaching retirement. Both
parties on the Appropriations Subcommittee expressed concern about our
needs. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 103 GAO- 01- 305 Office of Enforcement's Operations 43. Pay
Demonstration Project

Mission and goal supported Management mission: Improve management operations
Primary responsibility Finance and Administration Primary role Support
Purpose The purpose of the project is to establish an innovative performance
pay plan

Demonstration Project for Treasury's law enforcement scientific and
technical personnel that will improve the recruitment, retention,
development, and performance of employees in critical occupations. How
project initiated Self- initiated and other a : the FBI had earlier received
Congressional authorization to

conduct a demonstration project. When Treasury Enforcement learned of the
FBI authorization, it requested similar authorization for Treasury. On
November 26, 1997, the President signed the Commerce, Justice and State
Appropriation Bill (Public Law 105119) which authorized Treasury to conduct
a three- year personnel management demonstration project. This was a new
statutory authorization, not a requirement. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), Finance
and Administration, ATF, Customs Service, Secret Service, Office of
Management

? OMB, OPM

? Private sector- contractors Booz Allen and Hummro- Mercer Why Enforcement
was involved The Office of Enforcement was able to provide a broader
perspective as well as oversight

largely because the three major enforcement bureaus were involved.
Enforcement established the Demonstration Project Working Group and the
contract for the project was executed by the Office of Enforcement.
Functions Enforcement performed ? The Demonstration Project Working Group
collected data from the bureaus on job

series and number of employees in each category that would participate in
the project. The Working Group analyzed and provided data to the contractor
for all participants in the demonstration and control groups, including data
on organization, work location, background data (race, gender, veteran
status, handicapped status).

? Briefing memoranda were prepared for the Under Secretary and bureau
personnel.

? The Demonstration Project Working Group conducted briefings for OMB, OPM,
the Under Secretary (Enforcement), bureau heads, personnel officers, the
National Treasury Employee Union, and bureau employees.

? An operating plan was developed and submitted to Congress. Treasury also
prepared an implementation plan and a training plan.

? The Treasury Working Group developed operating procedures, charters for
the Treasury Personnel Policy Review Board and Bureau Advisory Board
overseeing the Working Group and the project, and governing bylaws.

? Reports prepared for Congress included an Operating Plan, and Evaluation
Report (required by legislation), and a Baseline Report that summarizes the
status of ATF and Secret Service prior to the demonstration project.

? Treasury provides oversight of the Demonstration Project Working Group.

? Written products prepared and reviewed include the Operating Plan,
Evaluation Plan, Baseline Report, and operating procedures for ATF.

? Budget projections/ estimates were submitted for the first year of
operation and for five outyears.

? Treasury Enforcement coordinated with OPM, OMB, and the law enforcement
bureaus.

? The Under Secretary issued a press release and additional news articles
were prepared with ATF management officials announcing the demonstration
project. The Under Secretary also sent out an explanatory memorandum to the
Treasury bureaus on the demonstration project.

? Press interviews and Congressional testimony addressed the demonstration
project.

? Treasury Enforcement established an on- site Demonstration Project Working
Group to manage the demonstration project and oversight boards to monitor
progress.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 104 GAO- 01- 305 Office of Enforcement's Operations

Project duration Start date: October 1998 Anticipated end date: October 2001
Enforcement staffing level on the project 6 staff members who spent 75 to
100 percent of their time on the project. Project results The expectations
for the demonstration project are to enhance the bureaus' abilities to

improve the recruitment, retention, development, and performance of
employees in critical law enforcement occupations. The demonstration project
is still underway and an evaluation report is due to Congress late in the
Spring 2001. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 105 GAO- 01- 305 Office of Enforcement's Operations 44. Senior
Executive Service (SES) Review

Mission and goal supported Management mission: Improve management operations
Primary responsibility Finance and Administration Primary role Support
Purpose To ensure that Treasury enforcement bureaus are on a competitive
level (regarding

career development) with other major Federal law enforcement entities
(regarding SES allocation). How project initiated Other Congressional
direction and other a : the House Conference Report 106- 319 that

accompanied the Treasury Appropriations bill directed the Treasury to review
and report on the apparent disparity in SES allocations for law enforcement
components at Treasury and Justice. A review was also requested by OMB/ OPM
to ‘justify' Treasury's request for additional SES positions. Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), Finance
and Administration, ATF, Customs Service, EOAF, FinCEN, FLETC, IRS/ CID,
OFAC, Secret Service, Office of Management

? Department of Justice, OMB, OPM

? Private sector Why Enforcement was involved Treasury was directed to
conduct the review. Also, the Office of Enforcement was able to

provide a broader perspective, especially because this effort involved all
of the law enforcement bureaus. Functions Enforcement performed ? Data was
collected on the total numbers of FTE and SES positions for each of the

Treasury law enforcement bureaus and offices, as well as for comparable
agencies such as FBI, DEA, INS, US Marshals Service, and Bureau of Prisons.

? Briefing memoranda prepared on extent of problem for Treasury bureaus and
comparison ratios among other agencies.

? Senior Treasury and Enforcement bureau, and office officials were briefed
on the review, as well as OPM and OMB officials.

? Criteria and an SES allocation formulation were drafted by Enforcement in
conjunction with the Office of Management.

? The Office of Enforcement negotiates revisions and critical points with
Management, OMB and OPM as the project develops.

? Criteria and allocation model for SES and proposal to senior policy
officials reviewed by the Office of Enforcement.

? Significant coordination was necessary among the Office of Enforcement and
the Office of Management, OMB and OPM.

? Talking points and Congressional testimony were prepared.

? This issue was addressed in the Office of Undersecretary of Enforcement's
testimony regarding FY00 and FY01 Appropriations Project duration Start
date: June 1999

Anticipated end date: Spring 2001 Enforcement staffing level on the project
3 staff members who spent less than 10 percent of their time on the project.
From start to

finish at least 4 to 6 months on a full- time basis. Project results There
have been several Congressionally directed reviews of Treasury enforcement's

SES allocation. Each study has given our appropriators sufficient concern to
direct further in- depth reviews. This purpose of the current review is not
to acquire more SES for the Enforcement bureaus, but to develop a new, more
equitable basis for SES allocation at Enforcement bureaus and offices that
seeks to ensure parity with other law enforcement agencies in the Federal
government. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 106 GAO- 01- 305 Office of Enforcement's Operations 45. Customs Service
Internal Affairs Review

Mission and goal supported Management mission: Improve program performance
Primary responsibility DAS (Law Enforcement) Primary role Oversight Purpose
To conduct an assessment of the vulnerabilities to corruption and of the
effectiveness of

the Customs Service Office of Internal Affairs. How project initiated
Statutory requirement: the Treasury and General Government Appropriations
Act, FY 98,

directed the Under Secretary (Enforcement) to conduct a comprehensive review
of the potential vulnerability of the Customs Service to corruption and to
examine the efficacy of the Customs Office of Internal Affairs. Although
mandated by statute, the former Under Secretary had earlier expressed to
Treasury appropriators that one of his reasons for proposing the
establishment of OPR was to conduct just such an assessment. Parties
involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (Law
Enforcement), Customs Service, General Counsel

? Department of Justice, FBI, INS

? State and/ or local governments, private sector Why Enforcement was
involved The Under Secretary (Enforcement) was directed by Treasury
appropriators to conduct

the assessment. Further, the review was performed in an oversight capacity
and was not a self inspection. Functions Enforcement performed ? Collected
data and statistics from Customs on case investigative files and internal

policies and procedures.

? Prepared briefing papers to Treasury officials on the progress and
findings of the review.

? Regularly provided oral briefing for Treasury officials. Provided oral
briefings for staff of various Congressional committees, including the
Senate Finance Committee, the Narcotics Caucus, and Appropriations
Committees of both houses.

? Developed strategies for future consideration to improve Customs
procedures.

? Developed recommendations in the final report to amend existing Customs
policies, directives, and standards.

? The final report was published in February 1999. This report was submitted
to the Congress and issued publicly.

? OE continues to oversee implementation of the report recommendations.

? There were several Congressional hearings following issuance of the
report. OE reviewed testimony prepared for those hearings.

? OE reviews Customs budget proposal to ensure they are adequate to
implement the report's recommendations.

? Prepared written testimony and responses to Congressional correspondence
concerning the report.

? Delivered oral testimony before Congressional committees on the report's
findings and recommendations. The OPR staffer who was the principal drafter
of the report testified at two of those hearings. Project duration Start
date: March 1998

End date: February 1999 Enforcement staffing level on the project 6 staff
members who spent 50 to less than 75 percent of their time on the project.
Project results After an extensive study, a comprehensive report was issued
of the assessment. Every

recommendation in the final report was adopted and is being implemented by
the Customs Service.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 107 GAO- 01- 305 Office of Enforcement's Operations 46. Iran Document
Destruction Report

Mission and goal supported Management mission: Improve program performance
Primary responsibility Assistant Secretary (Enforcement) Primary role
Oversight Purpose Review of circumstances surrounding the destruction of
certain Iran files at OFAC that

may have been responsive to a subpoena received by the Treasury Department.
How project initiated Self- initiated and other a :The project was initiated
jointly by the General Counsel and the

Assistant Secretary (Enforcement) and conducted by staff of both offices.
Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Assistant Secretary (Enforcement), DAS (Law Enforcement), OFAC, Office of
General Counsel

? Department of Justice

? None Why Enforcement was involved OE felt that it was important to
formally record the circumstances surrounding the

document destruction in the event that the matter arose sometime in the
future. Further, since it was decided to provide the report to the U. S.
District Court judge, it was also important that the Court understand that
the review was performed by employees outside of OFAC. Functions Enforcement
performed ? Data on the type and number of documents destroyed and
information on records

retention and destruction procedures were collected from OFAC. In addition,
many OFAC employees were interviewed by the review team.

? The Deputy General Counsel and the Assistant Secretary (Enforcement) were
briefed on the status of the review as it progressed.

? A final report was prepared on findings of the review into circumstances
surrounding destruction by OFAC of certain Iran documents. That report was
also filed in U. S. District Court on July 25, 2000.

? The review looked at existing OFAC policies and procedures for records
destruction, determined what process was followed in this particular
document destruction event, and described what documents were destroyed.

? As this was a joint project, OE coordinated closely with the Office of
General Counsel. OFAC also cooperated fully in the review. Project duration
Start date: June 2000

End date: July 2000 Enforcement staffing level on the project 1staff member
who spent 75 to less than 100 percent of his/ her time on the project.
Project results The report produced for the Assistant Secretary
(Enforcement) and the General Counsel

found that the document destruction was inadvertent and occurred in the
context of a major office- wide renovation. Personnel involved were not
aware of the subpoena or did not have it in mind at the time (subpoena had
been pending for two years awaiting further action). The report was
submitted to the court who subsequently found that the Department did not
act in bad faith in destroying some of the documents that may be covered by
the subpoena and commended the Department in taking quick action to remedy
the situation. a Response categories included self- initiated, statutory
requirement, other congressional direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 108 GAO- 01- 305 Office of Enforcement's Operations 47. Assessment of
the US Customs Service Passenger Enforcement

Targeting Program

Mission and goal supported Management mission: Improve program performance
Primary responsibility DAS (Law Enforcement) Primary role Oversight Purpose
The former Under Secretary for Enforcement tasked the Office of Professional

Responsibility (OPR) with assessing the passenger enforcement targeting
program and reviewing the Customs Inspector training to ensure that the
targeting program did not discriminate on the basis of race, color, national
origin, ethnicity, religion or gender. In addition, OPR assessed the Customs
Service automated advance passenger targeting system to ensure that advance
targeting is not impermissibly based on nationality, racial, ethnicity,
religious or gender characteristics. The assessment continued into the
current Under Secretary for Enforcement's tenure. How project initiated
Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS (Law
Enforcement), Customs Service, FLETC, Office of General Counsel

? None

? None Why Enforcement was involved The former Under Secretary for
Enforcement received several allegations that Customs

Service Inspectors were targeting minorities for more intrusive personal
searches at several airports of entry. In addition, there was extensive
Congressional interest and media coverage on the Customs Service alleged
activities. Functions Enforcement performed ? OPR's review methodology
included on- site interviews with personnel at the Port of

Miami, the Customs Academy in Glynco, Georgia, inspectors assigned to the
Analytical Unit and Rover Teams, and with Customs Passenger Service
Representatives. OPR did a comprehensive review of documentation and
Passenger Processing Policies. Also, OPR conducted site visits to Miami,
Florida and Glynco, Georgia.

? During the course of the assessment, the OPR review team prepared briefing
papers, statistical charts to be used in briefings with the Under Secretary
for Enforcement, the Assistant Secretary for Enforcement and the Deputy
Assistant Secretary for Law Enforcement.

? During the course of the assessment, the OPR review held briefings with
the Under Secretary for Enforcement, the Assistant Secretary for Enforcement
and the Deputy Assistant Secretary for Law Enforcement to inform them on the
progress on the review.

? As a result of the OPR's assessment, the U. S. Customs Service enhanced
its communication with passengers by establishing a Customer Satisfaction
Unit and displaying passenger notification signs in the airports of entry.

? OPR issued a report that was transmitted from the Under Secretary to the
Commissioner of Customs. The report recommended that the U. S. Customs
Service increase its standards in the area of professionalism.

? OPR prepared a Report of Findings and Conclusions, and Recommendations for
the Under Secretary for Enforcement and the Commissioner, United States
Customs Service. The Customs Commissioner embraced, adopted and enhanced the
Office of Enforcement's recommendations.

? OE monitored the implementation of the recommendations.

? OPR reviewed the Customs Commissioner's Congressional testimony on this
issue, as well as other reports prepared by Customs.

? Due to the increased media coverage and Congressional interest on racial
profiling, OPR prepared correspondence on its assessment and report. Project
duration Start date: May 1998

End date: June 1999

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 109 GAO- 01- 305 Office of Enforcement's Operations

Enforcement staffing level on the project 5 staff members who spent 25 to
less than 50 percent of their time on the project. Project results The
Office of Enforcement's, OPR issued a report on the Assessment of the United

States Customs Service Passenger Enforcement Targeting to the Under
Secretary (Enforcement). The Under Secretary (Enforcement) issued a copy of
the report to the Commissioner, U. S. Customs Service and advised the
Commissioner to provide the Office of the Under Secretary with Customs
course of action to the implementation of the recommendations that were set
forth in the report. The Customs Commissioner has made the following
changes: Established two committees, one internal and one external, to
review the procedures used in personal searches. The committees were tasked
to review the criteria used to identify passengers for further inspections.
Mandated that all Customs Inspectors receive extensive training on
interpersonal communications, cultural interaction, confrontation
management, personal search policy, and passenger enforcement selectivity.
Established a Customer Satisfaction Unit (CSU) to receive and process
complaints by passengers. The CSU ensures that complaints are correctly
addressed and that passengers receive appropriate feedback. Also, the CSU
provides current information to senior management and analyzes trends within
the complaint system. Established a National Public Education Program that
informs the traveling public of the authority and responsibilities of
inspectors employed by the Customs Service which may result in a passenger
being subjected to a personal search.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 110 GAO- 01- 305 Office of Enforcement's Operations 48. Treasury/
Department of Justice (DOJ) Parity Review

Mission and goal supported Management mission: Improve program performance
Primary responsibility DAS (Law Enforcement) Primary role Support Purpose To
present to OMB a comparative review of the parity in law enforcement funding

between the Department of the Treasury and the Department of Justice. The
review addressed certain programmatic and budgetary similarities and
differences between the two departments, and stressed the need for a
consistent approach to be instituted by OMB for annualizing Federal law
enforcement programs. How project initiated Self- initiated and other a :
OMB informed Treasury that it was planning a review of

Treasury/ Justice law enforcement funding and expressed interest in
Treasury's views concerning the parity issue. In addition to presenting its
views on the subject, the Office of Enforcement initiated a more
comprehensive comparative review to present to OMB that highlighted specific
Treasury bureau programs of significance that have not been equitably
funded. Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), Assistant Secretary (Enforcement), DAS
(Enforcement Policy), DAS (Law Enforcement), DAS (RT& T), Finance and
Administration, ATF, Customs Service, EOAF, FinCEN, FLETC, IRS/ CID, Secret
Service, Office of Management

? OMB

? None Why Enforcement was involved Due to the fact that the review of
program funding covered programs in all Treasury law

enforcement bureaus, OE was in a better position to coordinate input from
all bureaus, provide a broader perspective of the issue, and provide support
of bureau funding at the Under Secretary level. Functions Enforcement
performed ? The Office of the Under Secretary collected data from all
Treasury law enforcement

bureaus and offices on past, existing, and necessary funding for significant
programs, resources, equipment, and technology.

? Report reviewing Treasury law enforcement program funding prepared and
sent under signature of Under Secretary to OMB.

? Reviewed past and existing funding for Treasury law enforcement programs
and compared to funding for similar programs at DOJ.

? Enforcement coordinated with all bureaus to develop a position to best
support Treasury law enforcement programs. Project duration Start date: May
1999

End date: July 1999 Enforcement staffing level on the project 5 staff
members who spent 25 to less than 50 percent of their time on the project.
Project results Enforcement provided a review of parity in law enforcement
funding between Justice and

Treasury, including illustrations of funding variations for specific
programs. Enforcement recommended to OMB that a balanced and uniform
approach be applied to funding all law enforcement programs. This approach
would reflect similarities across agencies and the close coordination among
law enforcement entities. The review stressed the increasing complexity of
crime today and the reality that no single law enforcement agency has all
the skills and authority to most effectively fight complicated criminal
schemes. While OMB did not embrace the recommendations in the review, it
agreed that all relevant agencies should participate in the formulation of
law enforcement initiatives. OMB appreciated the input from Enforcement to
its decision- making process and hoped to work closely with Treasury on
specific proposals in future budget submissions. a Response categories
included self- initiated, statutory requirement, other congressional
direction,

presidential initiative, and other.

Appendix I: Selected Projects and Ongoing Efforts Relating to Enforcement's
Oversight, Policy Guidance, and Support Roles

Page 111 GAO- 01- 305 Office of Enforcement's Operations 49. Selection of
Law Enforcement Bureau Heads

Mission and goal supported Management mission: Improve program performance
Primary responsibility Assistant Secretary (Enforcement) Primary role
Oversight Purpose As openings occurred, the Office of Enforcement identified
candidates, interviewed, and

made recommendations for selection to the Secretary for Directors and Deputy
Directors of Secret Service (twice), FLETC, Customs, ATF, FinCEN and the
Executive Office for Asset Forfeiture. Additionally, although he does not
report directly to the Under Secretary, the Chief of the Criminal
Investigation Division of the IRS was interviewed prior to his selection.
How project initiated Self- initiated Parties involved

? Treasury

? Other federal departments or agencies

? Other

? Under Secretary (Enforcement), DAS (Enforcement Policy), DAS (Law
Enforcement), DAS (RT& T), Office of Management, Offices of the Secretary
and Deputy Secretary

? None

? None Why Enforcement was involved The law enforcement bureaus report to
the Under Secretary. Therefore, it was the

responsibility of the Office of Enforcement to oversee the selection process
of the bureau heads and make a recommendation to the Secretary as to who
should be selected. Functions Enforcement performed ? Information regarding
appropriate candidates and their qualifications was obtained.

? Briefing materials and interview questions were prepared in preparation
for the candidate interviews.

? After finalists were identified, the Secretary and Deputy Secretary were
briefed and met with the candidates. Once a selection was made, OE officials
notified appropriate Congressional staff and Members of Congress, as well as
officials in the interagency law enforcement community.

? Information regarding the candidates qualifications were reviewed and
analyzed.

? Interview schedules were developed, the timing of candidate interviews was
coordinated with the various bureaus, and reference checks were conducted on
the applicants. In addition, OE sought out potential candidates by speaking
to officials at the Justice Department, state and local law enforcement, and
the private sector.

? Letters to all candidates were prepared to announce the final selection.

? Extensive effort was involved in identifying, recruiting, interviewing and
selecting the best possible candidates. Project duration Start date: 1996

End date: March 2000. There are currently no bureau head openings.
Enforcement staffing level on the project 7 staff members who spent 10 to
less than 25 percent of their time on the project. Project results Eight
excellent candidates were selected to lead the Treasury law enforcement
bureaus:

two Secret Service Directors, ATF Director, ATF Deputy Director, Customs
Commissioner, FLETC Director, FinCEN Director, Asset Forfeiture Director.
Their selection has resulted in significant change and improvement at all of
the bureaus. In addition, the thorough and extensive selection process was
viewed by the candidates, as well as by Treasury officials, as a fair yet
challenging process designed to pick the best possible candidate for the
position.

Appendix II: Funding That Enforcement Received in Addition to Its Basic
Annual Operating Funds

Page 112 GAO- 01- 305 Office of Enforcement's Operations

Enforcement's basic operations are funded through Treasury's annual
appropriation for departmental offices' salaries and expenses. Treasury's
Financial Management Division (FMD) distributes (or allots) this annual
appropriation among various programs and offices, including Enforcement. For
example, in fiscal year 2000, Congress appropriated about $134 million for
the departmental offices' salaries and expenses appropriation. 1 Of this
total, Treasury's FMD allotted about $5.2 million to Enforcement for its
annual operations, including its oversight, policy guidance, and support
roles. Information on the funds FMD allotted to Enforcement for fiscal years
1994 through 2000 has been previously shown in the letter (see fig. 2).

In addition to these basic annual operating funds, Enforcement has received
other funding, according to Enforcement and FMD officials. (These funds are
not included in fig. 2.) This funding consisted of the following:

? Funds from the departmental offices' salaries and expenses appropriation
for special projects or purposes. Approximately $3.2 million were allotted
to Enforcement for fiscal years 1994 through 2000, of which about 61 percent
was to be passed through Enforcement to other Treasury accounts. The
remaining 39 percent was available to and fully obligated by Enforcement.
This included funds to perform a study of ATF's 1993 raid of the Branch
Davidian Compound, in Waco, TX.

? Multiyear or no- year funds that were appropriated by Congress or
transferred from other Treasury bureaus or federal agencies to Treasury's
departmental offices for Enforcement for fiscal years 1994 through 2000.
These totaled to about $267 million of which about 98.3 percent was to be
passed through Enforcement to other Treasury accounts. The remaining 1.7
percent (or $4.6 million) was available to Enforcement for its operations. 2
As of September 30, 2000, Enforcement had obligated about 72 percent (or
about $3.3 million) of the multiyear or no- year funds available for its
operations.

? Funds that Enforcement obligated out of its allotment from the
departmental offices' salaries and expenses appropriation and for which it
was reimbursed. For fiscal years 1994 through 2000, Enforcement had

1 Treasury Department Appropriations Act, 2000, P. L. 106- 58, 113 stat. 430
(1999). 2 An Enforcement official noted that use of a portion of these funds
was restricted by law to oversight of the implementation of the Violent
Crime Control and Law Enforcement Act of 1994, P. L. 103- 322, 108 Stat.
1796 (1994). Appendix II: Funding That Enforcement

Received in Addition to Its Basic Annual Operating Funds

Appendix II: Funding That Enforcement Received in Addition to Its Basic
Annual Operating Funds

Page 113 GAO- 01- 305 Office of Enforcement's Operations

obligated about $1.0 million of reimbursable funds. This included funds to
perform a study of the White House security.

Appendix III: Comments From the Department of the Treasury

Page 114 GAO- 01- 305 Office of Enforcement's Operations

Appendix III: Comments From the Department of the Treasury

Appendix IV: GAO Contacts and Staff Acknowledgments

Page 115 GAO- 01- 305 Office of Enforcement's Operations

Laurie Ekstrand, (202) 512- 8777 Weldon McPhail, (202) 512- 8777

In addition to those named above, Mary Lane Renninger, Nettie Y. Mahone,
David P. Alexander, Michael J. Curro, Geoffrey R. Hamilton, and Charlotte A.
Moore made key contributions to this report. Appendix IV: GAO Contacts and
Staff

Acknowledgments GAO Contacts Acknowledgments

(182094)

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