Combating Terrorism: How Five Foreign Countries Are Organized to Combat
Terrorism (Letter Report, 04/07/2000, GAO/NSIAD-00-85).

Pursuant to a congressional request, GAO reviewed five foreign
countries' efforts to combat terrorism, focusing on: (1) how other
governments are organized to combat terrorism; and (2) how they allocate
their resources to combat terrorism.

GAO noted that: (1) the countries generally have the majority of
organizations used to combat terrorism under one lead government
ministry; (2) however, because many other ministries are also involved,
the countries have created interagency coordination bodies to coordinate
both within and across ministries; (3) for example, while many countries
generally have their intelligence and law enforcement organizations
under their ministries of interior or equivalent, they also need to
coordinate with their ministries of foreign affairs, defense, and health
or emergency services; (4) the countries have clearly designated who is
in charge during a terrorist incident--typically their national or local
police; (5) the countries have national policies that emphasize
prevention of terrorism; (6) to achieve their policies, the countries
use a variety of strategies, including intelligence collection, police
presence, and various security measures such as physical barriers at the
entrances to public buildings; (7) these countries primarily use their
general criminal laws (e.g., those for murder or arson) to prosecute
terrorists; (8) the countries also have special terrorism-related laws
that allow for special investigations or prosecution mechanisms and
increased penalties; (9) the countries' executive branches provide the
primary oversight of organizations involved in combating terrorism; (10)
this oversight involves reviewing the programs and resources for
effectiveness, efficiency, and legality; (11) the five countries GAO
examined also had similarities in how they allocate resources to combat
terrorism; (12) officials in the ministries involved said they make
resource allocations based upon the likelihood of threats taking place,
as determined by intelligence assessments; (13) while the officials GAO
met with discussed resource levels in general, none of the five
countries tracked overall spending on programs to combat terrorism; (14)
such spending was imbedded in other accounts for broad organizational or
functional areas such as law enforcement, intelligence, and defense;
(15) officials in all countries told GAO that because of limited
resources, they made funding decisions for programs to combat terrorism
based on the likelihood of terrorist activity actually taking place, not
the countries' overall vulnerability to terrorist attack; and (16) the
officials said their countries maximize their existing capabilities to
address a wide array of threats, including emerging threats, before they
create new capabilities or programs.

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

 REPORTNUM:  NSIAD-00-85
     TITLE:  Combating Terrorism: How Five Foreign Countries Are
	     Organized to Combat Terrorism
      DATE:  04/07/2000
   SUBJECT:  Emergency preparedness
	     Interagency relations
	     Terrorism
	     Crime prevention
	     Foreign governments
	     Domestic intelligence
	     Facility security
	     Law enforcement
IDENTIFIER:  Canada
	     France
	     Germany
	     Israel
	     United Kingdom

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GAO/NSIAD-00-85

Appendix I: Security-Related Policy Development and Incident
Leadership in Canada, France, Germany, Israel, and the United
Kingdom

16

Appendix II: Principal Law Enforcement and Intelligence
Organizations in Canada, France, Germany, Israel, and the United Kingdom

18

Appendix III: Principal Terrorism Laws, Definitions, and Other Legal
Information in Canada, France, Germany, Israel, and the United
Kingdom

20

Appendix IV: Security-Related Oversight Organizations and Functions
in Canada, France, Germany, Israel, and the United Kingdom

22

Appendix V: GAO Contacts and Staff Acknowledgments

24

25

National Security and
International Affairs Division

B-284585

April 7, 2000

Congressional Requestors

In fiscal year 1999, the federal government spent about $10 billion to
combat terrorism. Over 40 federal departments, agencies, and bureaus have a
role in combating terrorism. The amount of spending and the large number of
agencies involved have prompted some Members of Congress to question who is
in charge of U.S. efforts to combat terrorism, how the federal government is
organized to prevent and respond to terrorism on U.S. soil, and how
resources are being allocated.

Based on these concerns, and recognizing that other countries have had more
experience dealing with terrorist attacks within their borders, you asked us
to provide information on (1) how other governments are organized to combat
terrorism and (2) how they allocate their resources to combat terrorism. We
selected Canada, France, Germany, Israel, and the United Kingdom for the
focus of our work.1

Over the years, we have found problems with efforts to combat terrorism in
the United States. For example, we reported in 1999 that the overall command
(i.e., who is in charge) at a terrorist incident was not clearly designated
or agreed to among federal, state, and local governments.2 In 1998, we
reported that some federal resources to combat terrorism were being
increased without a clear link to likely threats and that programs were
being developed based on vulnerabilities, not likely terrorist attacks.3 We
also reported in 1999 that these programs potentially duplicated

existing federal emergency response capabilities.4 A list of related GAO
products appears at the end of this report.

The information in this report describes similarities we found in how the
five countries we examined are organized and how they allocate resources to
combat terrorism. The appendixes provide more details on each individual
country. Since our objectives were to describe the efforts of these other
countries, we did not compare or contrast this information with how the
United States is organized to combat terrorism and we are not making any
recommendations.

The five countries we examined have similarities in how they are organized
to combat terrorism.

ï¿½ The countries generally have the majority of organizations used to combat
terrorism under one lead government ministry. However, because many other
ministries are also involved, the countries have created interagency
coordination bodies to coordinate both within and across ministries. For
example, while many countries generally have their intelligence and law
enforcement organizations under their ministries of interior or equivalent,
they also need to coordinate with their ministries of foreign affairs,
defense, and health or emergency services.

ï¿½ The countries have clearly designated who is in charge during a terrorist
incident--typically their national or local police.

ï¿½ The countries have national policies that emphasize prevention of
terrorism. To achieve their policies, the countries use a variety of
strategies, including intelligence collection, police presence, and various
security measures such as physical barriers at the entrances to public
buildings.

ï¿½ These countries primarily use their general criminal laws (e.g., those for
murder or arson) to prosecute terrorists. The countries also have special
terrorism-related laws that allow for special investigations or prosecution
mechanisms and increased penalties.

ï¿½ The countries' executive branches provide the primary oversight of
organizations involved in combating terrorism. This oversight involves
reviewing the programs and resources for effectiveness, efficiency, and
legality.

The five countries we examined also had similarities in how they allocate
resources to combat terrorism. Officials in the ministries involved said
they make resource allocations based upon the likelihood of threats taking
place, as determined by intelligence assessments. While the officials we met
with discussed resource levels in general, none of the five countries
tracked overall spending on programs to combat terrorism. Such spending was
imbedded in other accounts for broad organizational or functional areas such
as law enforcement, intelligence, and defense. Officials in all countries
told us that because of limited resources, they made funding decisions for
programs to combat terrorism based on the likelihood of terrorist activity
actually taking place, not the countries' overall vulnerability to terrorist
attack. They said their countries maximize their existing capabilities to
address a wide array of threats, including emerging threats, before they
create new capabilities or programs.

All five countries we visited have parliamentary style governments with
various ministries that provide an array of government services. For
example, a ministry of the interior may provide national law enforcement and
intelligence services. In a parliamentary style of government, the executive
branch has the dominant role in the development of policy and strategy.
Members of the legislative branch generally make up the cabinet, which under
the prime minister or the chancellor leads the executive branch of
government.5 The prime minister or the chancellor also leads the majority
political party, and because of party discipline, the majority party in the
legislature does not provide an independent role and the minority party does
not have much of a role in policy development.6

Some of the countries we visited have strong central governments, while
others have strong regional or state governments. For example, Canada with
its provinces and Germany with its states represent countries that have
relatively strong regional governments compared to France, Israel, and the
United Kingdom that have relatively strong central governments. To some
extent, the division of power between the central and regional governments
determines how these countries organize their efforts to combat terrorism.
For example, in some countries the national police play a key role, while in
other countries the regional or local police play a key role.

Officials in Canada, France, and Germany told us that the current threat
from terrorism in their countries is low. According to a 1998 Department of
State report on global terrorism, terrorism in Europe has declined, in part,
because of the increased vigilance by security forces and the recognition by
some terrorist groups that long-standing political and ethnic controversies
should be addressed by negotiations. For example, the remnants of Germany's
Red Army Faction, once among the world's deadliest, announced the
dissolution of their organization. In Israel, officials indicated that the
level of terrorism fluctuates with the peace process--terrorism typically
increases when the peace process is working, as those opposed to the peace
process try to derail it through violence. In the United Kingdom, officials
said that terrorism related to Northern Ireland continues to take place and
poses a real threat depending, in part, on developments in the peace
process. They added that although activity is at historically low levels,
the threat remains and is linked to developments in the peace process.
Officials from all five countries cited the threat of terrorists using
chemical, biological, radiological, and nuclear weapons as particularly
unlikely.

Oversight Are Similar

The five countries we examined have similarities in how they are organized
to combat terrorism. Specifically, each country places the majority of
resources for combating terrorism under one ministry, but each recognizes
that it must coordinate its efforts to develop national policy on combating
terrorism so it has interagency coordination bodies. Each country also has
clearly designated leadership at the scene of terrorist incidents. The five
countries have policies and strategies that emphasize the prevention of
terrorism using resources such as intelligence collection, police presence,
and security measures. In addition, each country uses its general criminal
laws (e.g., those for murder or arson) to prosecute terrorists. The
countries also have special terrorism-related laws that allow for special
investigation or prosecution mechanisms, and increased penalties. In each of
the five countries, the executive branch provides the primary oversight of
organizations involved in combating terrorism.

In four countries, most of the resources to combat terrorism--law
enforcement and intelligence services--are centralized under a lead agency,
generally the countries' ministry of interior or equivalent.7 For example,
the French Ministry of Interior includes the National Police and the two
domestic intelligence agencies that have a primary role in combating
terrorism. However, officials from all the countries said they view
counterterrorism as an intergovernmental effort that requires coordination
among law enforcement, intelligence, and other parts of the government that
may be involved in combating terrorism, including foreign affairs, the
military, and health and emergency services. Since they view combating
terrorism as an interagency effort, officials in each country identified the
prime minister or the chancellor as the one person in charge of combating
terrorism. Below that level, the effort to combat terrorism requires an
interagency body to formulate policy, coordinate activities, and provide
recommendations to the prime minister or the chancellor. In Israel, for
example, there is an interagency body called the Bureau for Counterterrorism
that coordinates activities and provides advice to the prime minister
regarding terrorism matters. Appendix I shows the interior ministries or
equivalent that lead efforts to combat terrorism and the interagency bodies
that provide coordination and advice on terrorism issues to the prime
minister or the chancellor.

All five countries have clearly designated who is to be in charge during a
terrorist incident. For example, in the United Kingdom, the local Chief
Constable (i.e., chief of police) has overall control of all aspects of
handling a terrorist incident. For Israel, the National Police are in
command within Israel, and the military are in command in the occupied
territories. Appendix I provides details on who is designated to command at
terrorist incidents for the rest of the countries.

Incident leadership is reinforced through written agreements and contingency
plans or other agreements. For example, in Canada, the Royal Canadian
Mounted Police has written agreements with major municipal police
departments on who leads the incident response. The French government has
written interagency contingency plans with command and control details for
such terrorist situations as a heightened threat, aircraft hijacking, ship
hijacking, or a chemical attack. Officials in the five countries stated that
they use the agreements or plans as the basis of their exercises to practice
their response, which further reinforces who leads at the incident site.
Clear incident command is also strengthened because the incident commander
controls all response elements, including police, fire, medical, and other
emergency services. Thus, there is one commander for police activities
(e.g., assaults, arrest, and gathering evidence) as well as other emergency
activities (e.g., evacuation, search and rescue, medical treatment, and
decontamination). Officials in the United Kingdom cited the importance of
having one person--the Chief Constable--in charge of the entire response.
Officials in the other four countries made similar comments on the need for
clear and unified leadership for the whole range of activities in a response
to a terrorist attack.

Each country had developed policies to combat terrorism through their
experience with various terrorist groups. The five countries' national
policies to combat terrorism, which were not always written, emphasized
prevention. Canadian officials were the only ones to provide us with their
written policies on terrorism. Officials in the other countries told us they
had no written policies. To implement their national policies, these
countries had strategies that included intelligence collection, police
presence, and other deterrent measures.

For example, the strategies in all five countries include domestic
intelligence, and each has at least one security intelligence organization
that gathers intelligence on domestic terrorist activities. Officials we
spoke with said that an effective intelligence capability is essential for
preventing acts of terrorism in their countries. In general, the role of
their domestic security intelligence organizations is to prevent acts of
terrorism by gathering information through a variety of sources and methods;
assessing the threats to security; and monitoring and sometimes disrupting
the activities of certain groups considered to be a threat within the
country.

All of the countries' domestic intelligence organizations are separate from
their law enforcement organizations. In Canada, France, and the United
Kingdom, these organizations are under a single ministry. In Germany there
are parallel federal and state intelligence and law enforcement
organizations, and both are under their respective ministries of the
interior. In Israel, the intelligence organizations report directly to the
prime minister, and the national police are under the Ministry of Public
Security. Cooperation between both law enforcement and intelligence
organizations was cited by officials in all five countries as important, in
part, because the domestic intelligence organizations do not have powers of
arrest. Law enforcement organizations become involved in combating terrorism
when information from the intelligence services indicates that criminal
activity has occurred, or is likely to occur, or when their own criminal
intelligence sources indicate such. Appendix II shows the principal law
enforcement and intelligence organizations of the countries we visited.

In addition to a strong intelligence capability, we found that the
countries' strategies included using a visible police presence to prevent
acts of terrorism. For example, in France, when there is a specific
terrorist threat, law enforcement increases its public presence in a visible
show of force. Likewise, the German Federal Border Police can provide
additional manpower to supplement state police at events such as political
demonstrations. In Israel, the National Police, as well as military
personnel, is present at various locations throughout the metropolitan areas
to respond to incidents as needed.

As part of their prevention strategies, the five countries use a variety of
other techniques to deter terrorist attacks. For example, all five countries
use physical barriers in certain critical areas and government buildings to
deter direct attacks. Other techniques are as follows. In Israel,
individuals and their belongings are often physically searched by police,
defense personnel, or security contractors and pass through metal detectors
before entering such places as shopping centers, airports, and local
attractions. In the United Kingdom, police use video cameras to monitor
daily events and watch for suspicious activity in London. In France, persons
entering government buildings typically walk through metal detectors.

All five countries use their general criminal laws to prosecute offenses
committed during a terrorist act, such as the crimes of murder, arson,
kidnapping, and hijacking. According to Canadian officials, treating
terrorism as ordinary crime removes the political element and thereby
dilutes the effectiveness of the terrorist act. The countries have also
enacted a variety of special laws that relate to terrorism that may include
a statutory definition or description of terrorism, or may invoke special
investigation or prosecution procedures, or provide for increased penalties.
Under French law, certain criminal offenses are considered terrorism when
the acts are intentionally linked to an individual or group whose purpose is
to cause a serious disruption of public order through intimidation or
terror. Penalties may be increased if a criminal offense is related to such
terrorism. France also has special judicial procedures to address terrorism
such as special courts and prosecutors. Germany's criminal code has a
special prohibition against the formation and support of a terrorist
association. In addition to its general criminal laws, Israel has two
principal laws that govern terrorism that contain a number of criminal
offenses such as supporting terrorist organizations. The United Kingdom has
two principal terrorism laws that designate a number of criminal offenses
relating to membership in and support of terrorist organizations.
Appendix III provides additional information on the terrorism-related laws
in the five countries.

Oversight reviews of programs and resources for effectiveness, efficiency,
and legality are primarily the responsibility of those ministers in the
executive branch that have a role in combating terrorism. Officials told us
that in their parliamentary style of government, ministers are accountable
for oversight and that this function is embedded in the ministers'
responsibilities. They generally viewed oversight as an ongoing routine
function of agency management, not an independent or separate review
function. For example, in France, the Minister of the Interior, through
their daily activities, reviews or oversees the activities of those
resources within the Ministry.

The legislatures in these countries do not hold oversight hearings or write
reports that evaluate programs to combat terrorism. In these parliamentary
style governments, the legislative branches do not provide ongoing
independent oversight of efforts to combat terrorism. While the five
countries do conduct some legislative review of national security activities
(e.g., through designated legislative committees), these reviews generally
have not focused on activities to combat terrorism. At times, some members
of the legislative branch are included in standing or ad hoc executive
oversight bodies. In Canada and Israel, independent reviews of activities to
combat terrorism are done by their national audit agencies. Appendix IV
summarizes oversight organizations and functions in the five countries we
visited.

Officials in the ministries involved in combating terrorism within the five
countries we visited said they made resource allocations based upon the
likelihood of threats taking place, as determined by intelligence
assessments. While the officials we met with discussed resource levels in
general, none of the five countries tracked overall spending on programs to
combat terrorism. Such spending was imbedded in other accounts for broad
organizational or functional areas such as law enforcement, intelligence,
and defense. Due to resource constraints, they said their countries maximize
their existing capabilities to address a wide array of threats, including
emerging threats, before they create new capabilities or programs.

The five countries we reviewed receive terrorist threat information from
their civilian and military intelligence services and foreign sources. Using
various means, each of the countries' intelligence services continuously
assess these threats to determine which ones could result in terrorist
activity and require countermeasures, which ones may be less likely to occur
but may emerge later, and which ones are unlikely to occur. Officials in all
countries told us that because of limited resources, they made funding
decisions for programs to combat terrorism based on the likelihood of
terrorist activity actually taking place, not the countries' overall
vulnerability to terrorist attack. For example, each of the countries may be
vulnerable to a chemical, biological, radiological, or nuclear attack by
terrorists, but officials believe that such attacks are unlikely to occur in
the near future for a variety of reasons, including the current difficulty
in producing and delivering these types of weapons. Furthermore, officials
in one country told us that the effects of these types of weapons would
alienate the population from the political aim of the terrorist groups and
therefore did not view this type of attack as likely. Officials we spoke
with believed that conventional bombs and other traditional means, such as
hijacking, are more likely to occur.

Threats

For less likely but emerging threats, officials in the five countries told
us that they generally try to maximize their existing capabilities for
responding to such threats, rather than create new programs or capabilities.
For example, the same capabilities used to respond to a fire, industrial
explosion, or chemical spill would be used for a terrorist incident
involving chemical, biological, radiological, or nuclear weapons. In
addition, officials in each country said additional capabilities from
neighboring states, provinces, cities, or national governments could be used
by local authorities if the situation exceeded their capabilities. For
example, Germany plans to rely on existing capabilities within the states
rather than develop new federal capabilities. Likewise, Israel has not
developed new capabilities, but it has a nationwide program that provides
gas masks and training to its citizens for defense against chemical or
biological attack in wartime that officials said has use for terrorist
attacks. The countries generally did not have major training programs in
place to train emergency response personnel for chemical, biological,
radiological, or nuclear attacks. However, the United Kingdom has a limited
program to train selected police officials as incident commanders and is
considering a training program for response personnel in selected locations.
Also, Canada has launched a policy initiative to develop a strategy to
strengthen national counterterrorism response capability, particularly the
ability to respond to chemical, biological, radiological, and nuclear
terrorist attacks. Only France has created new capabilities to respond to
chemical, biological, radiological, and nuclear terrorist attacks.

We provided a draft of this report to officials from all five countries for
their review and comment. All of the officials provided us with oral
comments indicating they agreed with the report's overall content and our
description of their countries' efforts. Officials from Canada and the
United Kingdom also provided written comments of a technical nature, and we
incorporated their changes where appropriate.

We examined how Canada, France, Germany, Israel, and the United Kingdom were
organized to combat terrorism. In selecting these countries, we considered
the historic level of terrorism and related activities within their borders,
the type of government, and our ability to conduct work in the countries. We
also consulted with officials from the U.S. State Department's Office of the
Coordinator for Counter Terrorism and other experts in the field of
terrorism inside and outside the federal government about which countries we
should examine. Based on our criteria and these consultations, we selected
Canada, France, Germany, Israel, and the United Kingdom.

Our scope was limited by two factors. First, we did not have audit authority
in the five countries; thus, we relied on the cooperation of foreign
officials. While we had numerous meetings with officials in the five
countries, we usually did not have access to many of their internal
documents, classified plans, or policy evaluations. Second, we were in each
country for a relatively short time, ranging from 1 to 2 weeks. As a result
of these limitations, we sought to describe how each country organized its
programs to combat terrorism, not to evaluate the operations or the
effectiveness of those programs. For our review of terrorism-related laws,
we relied on officials to identify appropriate statutes and did not do our
own comprehensive research or analysis of the countries' laws.

Because of the limitations we faced in reviewing foreign countries' policies
and programs, we asked the foreign officials to comment on the accuracy of
our work. After we conducted our overseas visits, we wrote summaries
documenting our observations and conclusions and sent them to the officials
for their verification, review, and comment. All of the officials provided
written comments, and we made changes to our summaries as appropriate. We
then used these summaries as the basis for drafting this report.

Our overall methodology consisted of reviewing applicable documents and
interviewing a broad array of national-level government officials whose
organizations had a significant role in combating terrorism. Where possible,
we met with regional and local government officials in the countries we
visited. We also met with contacts outside the government to provide us with
different perspectives on the countries' efforts to combat terrorism. For
example, we met with experts from academia, research organizations, the
media, and other nongovernmental organizations. For our specific objectives,
we interviewed officials at the level of government most able to provide us
information on our topics.

To describe how the five governments were organized to combat terrorism,
including oversight of terrorism programs, we met with officials from the
prime minister's or chancellor's office; legislative committee members with
responsibility regarding counter terrorism programs; and officials within
the ministries of interior, justice, defense, and other ministries that had
a role in combating terrorism. We also met with officials that have direct
responsibility for responding to and managing a terrorist incident. These
included officials who represented the countries' national police,
intelligence, military, and emergency medical organizations. To describe
oversight of terrorism programs, we met with members of legislative
committees, and national audit organizations and officials of inspector
general offices where they were present.

To describe how the countries allocate their resources to combat terrorism,
we met with many of the same officials above and focused our discussions on
how they analyzed threats and allocated resources for these programs.

We conducted our review from May 1999 through January 2000 in accordance
with generally accepted government auditing standards.

As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution of this report until
30 days after its issue date. At that time, we will send copies to
appropriate congressional committees and the federal agencies that combat
terrorism. We will also make copies available to other interested parties
upon request.

If you have any questions about this report, please contact me or Ray
Decker, Acting Associate Director for National Security Preparedness Issues,
at (202) 512-5140. Other major contributors to this report are listed in
appendix V.

Norman J. Rabkin
Director, National Security Preparedness Issues

List of Congressional Requesters

The Honorable Ted Stevens
Chairman
The Honorable Robert Byrd
Ranking Member
Committee on Appropriations
United States Senate

The Honorable Christopher S. Bond
Chairman
The Honorable Barbara Mikulski
Ranking Member
Subcommittee on Veterans Affairs, Housing and
Urban Development and Independent Agencies
Committee on Appropriations
United States Senate

The Honorable Ike Skelton
Ranking Member
Committee on Armed Services
House of Representatives

The Honorable Christopher Shays
Chairman
Subcommittee on National Security, Veterans
Affairs, and International Relations
Committee on Government Reform
House of Representatives

Security-Related Policy Development and Incident Leadership in Canada,
France, Germany, Israel, and the United Kingdom

Continued from Previous Page

                Canada         France            Germany              Israel                 United Kingdom
                               Interministerial
                               Liaison Committee
                               Against Terrorism

                               (Comitï¿½
                               Interministï¿½riel
                Privy Council  de Lutte
                Office is the  Anti-Terroriste)
                office that    is a high level   Coordinator for
                provides       committee that    Intelligence
                advice to the  develops policy                                               Official Committee
                prime minister and includes the  (Koordinierung der   Bureau for             on Terrorism
                and the        Prime Minister    Nachrichtendienste   Counterterrorism makes coordinates
                cabinet on     and Ministers of  des Bundes) is a     recommendations on     interagency
                terrorism      Interior,         direct advisor to    terrorism policy and   counter-terrorism
                issues. The    Defense, Justice, the Chancellor and   works with agencies    policy development
                                                 develops a general   involved in combating
 Interagency    Privy Council  and Foreign       policy framework and terrorism to formulate with input from
 policy         Office obtains Affairs.          coordinates state    recommendations. The   the organizations
 coordination   input from the                   issues. The Federal  Bureau includes        directly involved
 body           Solicitor      Anti-Terrorism    Ministry of the      representatives from   in combating
                General's      Coordination Unit                                             terrorism (Home
                Office for                       Interior includes    all agencies involved  Office, Foreign
                national       (Unitï¿½ de         police,              in combating terrorism and Commonwealth
                policy and the Coordination de   intelligence, and    and reports directly toOffice, and
                Ministry of    la Lutte          border police, and   the Prime Minister.    Association of
                Foreign        Anti-Terroriste)  provides federal                            Chief of Police
                Affairs for    is a working      policy for combating                        Officers).
                international  level             terrorism.
                policy.        coordination
                               group that
                               includes agencies
                               from the
                               Ministries of
                               Interior and
                               Defense that
                               coordinate
                               operations.
                Solicitor
                General is the
                ministry that                    State-level
                includes the   Ministry of       Ministries of        Ministry of Internal
                intelligence   Interior          Interiors            Security includes
                and law        (Ministï¿½re de                          resources to combat    Home Office is
                enforcement    L'Intï¿½rieur)      (Staatsministerium   terrorism--the Nationalequivalent to an
                resources for  hosts the         des Innern) includes Police and the Border  Interior Ministry
                combating      interagency       police,              Guard.                 and manages
                               Anti-Terrorism
 Organization   terrorism.     Coordination      intelligence, and                           domestic terrorism
 with primary   Within this    Unit. This        emergency            Ministry of Defense    programs. It has
 responsibility ministry the   ministry includes preparedness. Each   provides law           purview over law
 for combating  Canadian       the National      state ministry of    enforcement in the     enforcement,
 terrorism      Security       Police, the       interior is          occupied territories   domestic
                Intelligence                     represented in a     and the Home Front     intelligence, and
                Service        Central           Council of Interior  Command−a commandemergency
                provides the   Headquarters for  Ministers that       within the             management.
                overall threat Surveillance of   addresses a variety  military−provides
                assessment for the Territory,    of intelligence, law civil assistance
                Canada and the and the General   enforcement, and     management through out
                Royal Canadian Intelligence      emergency            Israel.
                Mounted Police Central Service.  preparedness issues.
                provides law
                enforcement.

                Canada         France            Germany              Israel                 United Kingdom
                Royal Canadian
                Mounted Police
                is Canada's
                national                         Federal police would
                police force.                    take command over
                Canada also                      the terrorist
                has municipal                    incident upon        National Police or
                police in                        direction of the     Military are in charge
                larger cities.                   federal prosecutor,  of a terrorist incidentLocal Chief
                The Mounted                      or at the request of in Israel, depending onConstable is the
                Police and                       the state. The       the location of the    official in charge
                municipal      Prï¿½fet is a       federal criminal     incident. In the       at the incident
                police forces  regional          police               occupied territories,  and decides
                                                 (Bundeskriminalamt)
 Leadership     have           political         are under the        the military responds  whether to bring
 during an      memorandums of appointee who     federal ministry of  to and remains in      in other support
 incident       understanding  supervises police interior. First      charge of a terrorist  as needed. The
                describing how and emergency                          incident. In the rest  entire government
                law            activities at a   responders would be  of Israel, the Nationalworks to support
                enforcement    terrorist scene.  the state police     Police respond to an   the police at the
                will be                          (Lï¿½ndeskriminalamt)  incident and remain in scene.
                coordinated                      under the state's    charge throughout the
                and who will                     interior ministry.   incident.
                be in charge.                    State police would
                The Royal                        provide support to
                Canadian                         their federal
                Mounted Police                   counterparts.
                are under the
                Ministry of
                the Solicitor
                General.

Note: For overseas terrorist incidents involving its citizens, the Ministry
of Foreign Affairs or equivalent in each country typically provides input to
the interagency coordination body on terrorism policy.

Source: Our interviews with selected officials and review of documents from
each country.

Principal Law Enforcement and Intelligence Organizations in Canada, France,
Germany, Israel, and the United Kingdom

Continued from Previous Page

               Canada          France           Germany                      Israel            United Kingdom
               Royal Canadian
               Mounted Police
               is the national National Police
               police force
               that has        (Direction
               primary         Gï¿½nï¿½rale de la
               responsibility  Police
               for prevention, Nationale) is
               protection, and the lead         Federal Criminal Police
               investigation   civilian         (Bundeskriminalamt) is       Israeli National
               of offenses     national police  responsible for protection   Police is the
               that constitute force that has   and investigation of acts of principal civilian
               a threat to the jurisdiction in  terrorism and extremism and  police force and  County Police
               security of     large urban      is under the Ministry of the is under the      Forces. Each
               Canada. They    areas. It is     Interior.                    Ministry of Publiccounty or group
               also serve as   divided into                                  Security.         of counties has
               provincial and  specialized      State Criminal Police                          a police force
               municipal       directorates for (Lï¿½ndeskriminalamt) is       Border Guard is   led by a chief
               police in many  such functions   responsible for criminal     the National      constable. The
               areas across    as border        investigations within the    Police's principalMetropolitan
 Law           Canada and are  security and     states and may assist the    mobile task force,Police Service
 Enforcement   under the       protection of    federal police during        focuses on        in London has
 Organizations Ministry of the dignitaries and  terrorism cases. Under the   internal security,the
               Solicitor       is under the     states' ministries of        and has a special Anti-Terrorist
               General.        Ministry of the  interior.                    antiterrorist     Branch, which
                               Interior.                                     unit.             the chief
               Two provinces                    Federal Border Guard                           constables of
               and most        National         (Bundesgrenzschutz) provides Israeli Defense   other police
               municipalities  Gendarmerie      security at the borders,     Force provides lawforces can call
               have their own                   transportation sites, and    enforcement in theon for
               police forces.  (Direction       other federal areas. It      occupied          assistance.
               Many have       Gï¿½nï¿½rale de la   assists state police when    territories.
               agreements with Gendarmerie      large forces are needed and
               the Royal       Nationale) is    is under the Ministry of the
               Canadian        responsible for  Interior.
               Mounted Police  law enforcement
               to facilitate   in small towns
               cooperation     and rural areas
               during          and is under the
               terrorist       Ministry of
               incidents.      Defense.

               Canada          France           Germany                      Israel            United Kingdom
                               Central
                               Headquarters for

                               Surveillance of
                               the Territory

               Canadian        (Direction de la
               Security        Surveillance du
               Intelligence    Territoire) is                                                  British
               Service is      responsible for                                                 Security
               responsible for intelligence     The Federal Office for the                     Service gathers
               collection,     regarding        Protection of the                              intelligence
               analyses,       internal threats Constitution (Bundesamt fï¿½r  Israeli Security  internally to
               production, and from external    Verfassungsschutz) collects  Agency is         investigate and
               dissemination   sources and is   and analyzes intelligence    responsible for   disrupt
               of security     under the        relating to politically      internal          terrorist
               intelligence on Ministry of the  motivated extremism,         intelligence      activity,
               terrorism. It   Interior,        including terrorism, and     collection and    provide advice
                                                coordinates with its state
 Domestic      participates in Director of the  counter-parts. Under the     analyses,         to the
 Intelligence  information     National Police. Ministry of the Interior.    counterespionage, government on
 Organizations sharing with                                                  and the preventiondomestic
               allied          General                                       of terrorist acts.security
               countries but   Intelligence     State Offices for the        It reports        matters, and
               does not        Central Service  Protection of the            directly to the   issue threat
               independently                    Constitution (Landesï¿½mter    Prime Minister andassessments. It
               conduct         (Direction       fï¿½r Verfassungsschutz) have  is formerly the   reports
               operations      Centrale des     similar roles but are        General Security  directly to the
               abroad and is   Renseignenments  independent of the federal   Service.          Home Office
               under the       Gï¿½nï¿½raux) is     government and are under the                   and/or the
               Ministry of the responsible for  states' ministries of                          Prime Minister
               Solicitor       intelligence     interior.                                      and is also
               General.        regarding                                                       known as MI-5.
                               internal threats
                               from internal
                               sources and is
                               under the
                               Ministry of the
                               Interior,
                               Director of the
                               National Police.
               Department of
               National        General
               Defense         Headquarters for
               established     Security
               intelligence    Overseas                                                        Secret
               response teams  (Direction                                    Mossad is Israel'sIntelligence
               to produce      Gï¿½nï¿½rale de la                                primary foreign   Service is
               intelligence    Sï¿½curitï¿½                                      intelligence      Britain's lead
               for supporting  Exterieure) is                                service and       foreign
               senior          responsible for  German Intelligence Service  reports directly  intelligence
               officials,      intelligence     (Bundesnnachrichte-ndienst)  to the prime      service. Under
               planners, and   gathering abroad is responsible for the       minister.         the Foreign and
               the             and is under the investigation of threats                       Commonwealth
                               Ministry of      from abroad.
 Other         Department's    Defense.                                      Ministry of       Office it
 Intelligence  hostage rescue                   Military Intelligence        Defense has a     reports
 Organizations unit.           Central          Service (Militï¿½rischer       section that      directly to the
                                                                             focuses on        Prime Minister
               Communications  Headquarters     Abschirmdienst) focuses on   military          and is also
               Security        Military         intelligence matters that    intelligence and  known as MI-6.
               Establishment   Intelligence     are relevant to military     works with the
               gathers         (Direction       affairs and is under the     Mossad and the    Government
               intelligence    Reseignments     Ministry of Defense.         Israeli Security  Communications
               through         Militaire)                                    Agency to prepare Headquarters
               electronic      collects and                                  the annual threat collects
               means and is    analyzes                                      assessment.       communications
               responsible for military                                                        intelligence.
               protecting      intelligence and
               information     is under the
               technology      Ministry of
               infrastructure. Defense.

Source: Our interviews with selected officials and review of documents from
each country.

Principal Terrorism Laws, Definitions, and Other Legal Information in
Canada, France, Germany, Israel, and the United Kingdom

Continued from Previous Page

                   Canada           France             Germany        Israel          United Kingdom
                                                                                      Prevention of
                   Security                                                           Terrorism
                   Offenses Act     Chapters I and II                 Defense and     (Temporary
                                                                      Emergency Act
 Principal         (1984) and       of title II        Section 129(a) (1945) and the  Provisions) Act
 terrorism-related Canadian         (Terrorism) of the of the                         of 1989 and the
 laws              Security         Penal Code and the                Prevention of   Northern
                   Intelligence     Code of Criminal   Criminal Code                  Ireland
                   Service Act      Procedure                         Terrorism       (Emergency
                   (1984)                                             Ordinance (1948)Provisions) Act
                                                                                      of 1998
                                                                      Neither law
                   Canadian                                           specifically
                   Security                                           defines
                   Intelligence     The Penal Code                    terrorism, but
                   Service Act does ties               German law     the Prevention
                   not explicitly   terrorist-related  does not       of Terrorism
                   define terrorism acts, defined as   define         Ordinance
                   but applies to   "an act by an      terrorism, but contains
                   "threats to the  individual or      a working      criminal        Both acts
                   security of      group that uses    definition     prohibitions    define
                   Canada." Such    intimidation or    provided by    regarding a     terrorism as
                   threats include  terror to disrupt  German         person's        "the use of
                   "activities      public order," to  government     activities and  violence for
                                    the Code's general officials
 Definition or     within or        criminal offenses. states that    association withpolitical ends
 description of    relating to                         terrorism is   a "terrorist    [including] any
 terrorism         Canada directed  Officials told us  the permanent  organiza-tion." use of violence
                   toward or in                                       Such an         for the purpose
                   support of the   that although this fight for      organization is of putting the
                   threat or use of definition does    political      defined as a    public, or any
                   acts of serious  not mention        goals and      "body of personssection of the
                   violence against political          change of the  resorting in itspublic in
                   persons or       motivation, an act political      activities to   fear."
                   property for the would not be       system through acts of violence
                   purpose of       labeled an act of  assaults       calculated to
                   achieving a      terrorism unless   against        cause death or
                   political        it was linked to   persons and    injury to a
                   objective within some political     property.      person or to
                   Canada or        motive or cause.                  threats of such
                   foreign state."                                    acts of
                                                                      violence."

                   Canada           France             Germany        Israel          United Kingdom
                                                       Section 129(a)
                                                       prohibits the
                                                       formation or
                                                       support of an
                                                       association
                                                       whose
                                                       objectives or                  The Northern
                                                       activities are                 Ireland
                                                       directed       The Defense and (Emergency
                                                       toward         Emergency Act, aProvisions) Act
                                                       committing     holdover from   of 1996, only
                                                       murder,        the British     applies to
                                                       genocide, or   Mandate of      Northern
                   Under the                           certain other  Palestine, is   Ireland. The
                   Security                            criminal acts  used primarily  Prevention of
                   Offenses Act,    The maximum        against        in the occupied Terrorism
                   the federal      allowable criminal personal       territories for (Temporary
                   government,      sentences are      liberty or     administrative  Provisions) Act
                   rather than a    increased when     endangering    enforcement     of 1989,
                   provincial or    certain criminal   the public.    purposes such asapplies to the
                   territorial      offenses, such as  Convicted      seizure of      United Kingdom
                   government,      violent conduct,   persons can be property. The   in general.
                   prosecutes       hijacking, or the  barred from    Prevention of
                   criminal         use of explosives, holding public Terrorism       Both acts
                   offenses that    are linked to      office and     Ordinance,      contain a
                   constitute a     terrorism. France  acquiring      developed duringnumber of
                                    has a special                     the origin of   comparable
 Other legal       threat to the    national court to  rights from    the State of    criminal
 information       security of      address acts of    public         Israel, containsoffenses
                   Canada, or if                       elections.
                   the victim of    terrorism under                   both judicial   relating to
                   the offense is   the Justice        While most     and             membership,
                   an               Ministry, which    violations of  administrative  participation
                   internationally  also permits this  the criminal   provisions, as  in, and support
                   protected        special            code are       well as criminalof proscribed
                   person. The      independent        prosecuted by  prohibitions    organizations.
                   specific         section to         the states,    against
                   offenses,        investigate,       the national   membership and  Subject to
                   however, are     prosecute, and     govern- ment   support of a    Parliamentary
                   still prosecuted adjudicate cases   can direct the terrorist group.agreement,
                   under Canada's   associated with    overall                        these temporary
                   federal criminal terrorism.         investigation  According to    laws will be
                   laws.                               and determine  Israeli         replaced later
                                                       if the state   officials, they this year by
                                                       or federal     are studying    one permanent
                                                       police will    ways to update  law that would
                                                       conduct the    and strengthen  apply
                                                       investigation  their terrorism throughout the
                                                       when           laws.           country and to
                                                       violations of                  all forms of
                                                       section 129(a)                 terrorism.
                                                       are suspected
                                                       or when the
                                                       crime has
                                                       national
                                                       consequences.

Note: This table is based upon laws that country officials identified as
their key statutes related to terrorism. It is not based upon a
comprehensive review of statues in the countries.

Source: Our interviews with country officials and review of legal documents
they provided.

Security-Related Oversight Organizations and Functions in Canada, France,
Germany, Israel, and the United Kingdom

Continued from Previous Page

 Level of
 review or  Canada             France            Germany                 Israel        United Kingdom
 oversight
                                                                                       The Cabinet
                                                                                       Office reviews
                                                                                       national security
                                                                                       issues for the
            Privy Council                                                              Prime Minister.
            Office monitors                                              National      The Home
            and coordinates                                              Security      Secretary is
            activities related                                           Council,      responsible for
            to security and                                              formed in     the British
            intelligence.      Interministerial                          1999, providesSecurity Service.
            Within the Privy   Liaison Committee                         broad review  The Foreign and
            Council Office is  Against Terrorism Office of the           of security   Commonwealth
            the Security and   (Comitï¿½           Chancellor, Coordinator issues.       Secretary is
            Intelligence       Interministï¿½riel  for Intelligence,                     responsible for
                               de Lutte                                  Israel's      the Secret
 Executive  Coordinator that   Anti-Terroriste)  provides executive      Security      Intelligence
            monitors such                        oversight for national
            activities on a    consists of       issues.                 Cabinet also  Service and the
            day-to-day basis.  high-level                                provides      Government
            Canada also has    officials                                 executive     Communications
            interdepartmental  involved in                               review and    Headquarters.
            committees,        combating                                 consists of   Other executive
            including the      terrorism.                                the principle committees are
            Interdepartmental                                            ministers who the Permanent
            Committee on                                                 have a role inSecretaries'
            Security and                                                 combating     Committee on the
            Intelligence.                                                terrorism.    Intelligence
                                                                                       Services and the
                                                                                       Ministerial
                                                                                       Committee on
                                                                                       Intelligence
                                                                                       Services.
            The Special Senate
            Committee on                                                               Senior
            Security and                                                               parliamentarians
            Intelligence                                                               sit on the
            reviewed                                                                   Intelligence and
            counterterrorism                                                           Security
            in 1998;                                                                   Committee.
            additional reviews                                                         Parliamentarians
            are done on an ad                    The Parliament has a    Subcommittee  also served as
            hoc basis. For                       standing committee on   on            Commissioners for
            intelligence and   Commissions are   Internal Affairs that   Intelligence  the British
                                                 monitors the police and is part of theSecurity Service
 Legislativepolice protection  formed if         the intelligence        standing      and the Secret
            issues Canada has  problems are
            the Security       found.            services' compliance to committee on  Intelligence
            Intelligence                         the law (usually in     Foreign       Service to review
            Review Committee,                    response to a specific  Affairs and   law enforcement
            the Royal Canadian                   incident).              Defense.      and intelligence
            Mounted Police                                                             activities. There
            Public Complaints                                                          is also a
            Commission, and                                                            parliamentary
            the Royal Canadian                                                         tribunal to
            Mounted Police                                                             investigate
            External Review                                                            public
            Committee.                                                                 complaints.
 Level of
 review or  Canada             France            Germany                 Israel        United Kingdom
 oversight
            Auditor General,
            Canada's
            independent                                                  State
            government audit   The Court of                              Comptroller's
            organization,      Accounts (Cour    The Federal Court of    Office has    The National
            reported on        des Comptes), is  Audit                   broad         Audit Office, the
            counterterrorism   France's          (Bundesrechnung-shof),  authority and United Kingdom's
            activities in 1996 independent       Germany's federal       can choose itsnational
 Other      with a follow-up   government audit  auditor conducts fiscal agenda. Issuedgovernment audit
            report in 1998.    organization, but audits, and each        a report on   organization has
            Canada also has an it has not        government department's Israel's      not focused on
            inspector general  focused on        internal inspectors     overlapping   counterterrorism
            only for           counterterrorism  monitor compliance with intelligence  issues.
            intelligence       issues.           internal regulations.   activities in
            issues that                                                  1999.
            reports to the
            Solicitor General.

Note: In all the countries, their judicial systems served a final oversight
function over the legality of executive branch activities in criminal
prosecutions.

Source: Our interviews with country officials and review of documents from
each country.

GAO Contacts and Staff Acknowledgments

Stephen L. Caldwell (202) 512-9610

In addition to the name above, Colin L. Chambers, Davi M. D'Agostino,
Kathleen Joyce, Paul Rades, Lorelei St. James, Karen Thompson, and Raymond
J. Wyrsch made key contributions to this report.

Related GAO Products

Combating Terrorism: Need to Eliminate Duplicate Federal Weapons of Mass
Destruction Training (GAO/NSIAD-00-64, Mar. 21, 2000).

Combating Terrorism: Chemical and Biological Medical Supplies Are Poorly
Managed (GAO/HEHS/AIMD-00-36, Oct. 29, 1999).

Combating Terrorism: Observations on the Threat of Chemical and Biological
Terrorism (GAO/T-NSIAD-00-50, Oct. 20, 1999).

Critical Infrastructure Protection: Fundamental Improvements Needed to
Assure Security of Federal Operations (GAO/T-AIMD-00-7, Oct. 6,1999).

Critical Infrastructure Protection: Comprehensive Strategy Can Draw on Year
2000 Experiences (GAO/AIMD-00-1, Oct. 1, 1999).

Information Security: The Proposed Computer Security Enhancement Act of 1999
(GAO/T-AIMD-99-302, Sept. 30, 1999).

Combating Terrorism: Need for Comprehensive Threat and Risk Assessments of
Chemical and Biological Attack (GAO/NSIAD-99-163,
Sept. 7, 1999).

Combating Terrorism: Analysis of Federal Counterterrorist Exercises
(GAO/NSIAD-99-157BR, June 25, 1999).

Combating Terrorism: Observations on Growth in Federal Programs
(GAO/T-NSIAD-99-181, June 9, 1999).

Combating Terrorism: Analysis of Potential Emergency Response Equipment and
Sustainment Costs (GAO/NSIAD-99-151, June 9, 1999).

Combating Terrorism: Use of National Guard Response Teams Is Unclear
(GAO/NSIAD-99-110, May 21, 1999).

Combating Terrorism: Issues to Be Resolved to Improve Counterterrorist
Operations (GAO/NSIAD-99-135, May 13, 1999).

Combating Terrorism: Observations on Biological Terrorism and Public Health
Initiatives (GAO/T-NSIAD-99-112, Mar. 16, 1999).

Combating Terrorism: Observations on Federal Spending to Combat Terrorism
(GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).

Combating Terrorism: Opportunities to Improve Domestic Preparedness Program
Focus and Efficiency (GAO/NSIAD-99-3, Nov. 12, 1998).

Combating Terrorism: Observations on the Nunn-Lugar-Domenici Domestic
Preparedness Program (GAO/T-NSIAD-99-16, Oct. 2, 1998).

Combating Terrorism: Observations on Crosscutting Issues
(GAO/T-NSIAD-98-164, Apr. 23, 1998).

Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and
Target Program Investments (GAO/NSIAD-98-74, Apr. 9, 1998).

Combating Terrorism: Spending on Governmentwide Programs Requires Better
Management and Coordination (GAO/NSIAD-98-39, Dec. 1, 1997).

Combating Terrorism: Federal Agencies' Efforts to Implement National Policy
and Strategy (GAO/NSIAD-97-254, Sept. 26, 1997).

(702009)

  

1. We selected these five countries based on terrorism-related activities
within their borders, the type of government, and our ability to conduct
work in these countries. For more details on our selection criteria, and how
we conducted our work, see our scope and methodology section.

2. Combating Terrorism: Issues to Be Resolved to Improve Counterterrorism
Operations (GAO/NSIAD-99-135, May 13, 1999).

3. Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and
Target Program Investments (GAO/NSIAD-98-74, Apr. 9, 1998).

4. Combating Terrorism: Observations on Federal Spending to Combat Terrorism
(GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).

5. For the purposes of this report, we use the term "executive branch" to
refer to those ministries, departments, or organizations that perform
executive-type functions. The term "legislative branch" refers to those
bodies of elected representatives that enact laws such as the Parliaments in
Canada and the United Kingdom, the National Assembly and Senate in France,
the Bundestag and Bundesrat in Germany, and the Knesset in Israel.

6. While minority parties generally do not have a large role in policy
development, they could have a large role in a coalition government where
they form a coalition and align with a larger party.

7. In Israel, the National Police are under one ministry; however, the main
domestic and international intelligence services are not in the same
ministry as the National Police and report directly to the prime minister.
*** End of document. ***