BORDER SECURITY
CBP Aims to Prevent
High-Risk Travelers
from Boarding U.S.-
Bound Flights, but
Needs to Evaluate
Program Performance
Report to Congressional Requesters
January 2017
GAO-17-216
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-17-216, a report to
congressional requesters
January 2017
BORDER SECURITY
CBP Aims to Prevent High
-Risk Travelers
from
Boarding U.S.
-Bound Flights, But Needs to
Evaluate
Program Performance
What GAO Found
The Department of Homeland Security’s (DHS) U.S. Customs and Border
Protection (CBP) analyzes traveler data and threat information to identify high-
risk travelers before they board U.S.-bound flights. CBP’s National Targeting
Center (NTC), the primary entity responsible for these analyses, conducts
traveler data matching which assesses whether travelers are high-risk by
matching their information against U.S. government databases and lists, and
rules-based targeting, which enables CBP to identify unknown high-risk
individuals. CBP operates multiple predeparture programs that use the results of
NTC’s analyses to help identify and interdict high-risk travelers before they board
U.S.-bound flights. CBP officers inspect all U.S. bound travelers on precleared
flights at the 15 Preclearance locations and, if deemed inadmissible, a traveler
will not be permitted to board the aircraft. CBP also operates nine Immigration
Advisory Program (IAP) and two Joint Security Program (JSP) locations as well
as three Regional Carrier Liaison Groups (RCLG) that allow CBP to work with
foreign government and air carrier officials to identify and interdict high-risk
travelers. Through these programs, CBP may recommend that air carriers not
permit such travelers to board U.S.-bound flights.
CBP data show that it identified and interdicted over 22,000 high-risk air travelers
in fiscal year 2015 through its predeparture programs. CBP officers at
Preclearance locations determined that 10,648 of the approximately 16 million air
travelers seeking admission to the United States through such locations were
inadmissible. Similarly, CBP, through its IAP, JSP, and RCLG locations, made
11,589 no-board recommendations to air carriers for the approximately 88 million
air travelers bound for the United States from such locations. While CBP’s
predeparture programs have helped identify and interdict high-risk travelers,
CBP has not fully evaluated the overall effectiveness of these programs using
performance measures and baselines. CBP tracks some data, such as the
number of travelers deemed inadmissible, but has not set baselines to determine
if predeparture programs are achieving goals, consistent with best practices for
performance measurement. By developing and implementing a system of
performance measures and baselines, CBP would be better positioned to assess
if the programs are achieving their goals.
CBP plans to expand its predeparture programs where possible, though several
factors limit its ability to expand to all priority locations. In May 2015—after
soliciting interest among foreign airport authorities and scoring interested airports
using risk and other factors—CBP stated it would begin Preclearance expansion
negotiations with 10 priority airports in 9 countries. As of November 2016, CBP
had not completed the process required to begin operations in any locations
prioritized for expansion, but had reached agreement with one location at which
Preclearance operations could begin as early as 2019. According to senior CBP
officials, Preclearance expansions are lengthy and complex processes because
host governments and airports must be willing to allow for a Preclearance
location, and CBP’s Preclearance expansion strategy relies on partnering with
airports that are willing to pay for the majority of operational costs.
Why GAO Did This Study
DHS seeks to identify and interdict
international air travelers who are
potential security threats to the United
States, such as foreign fighters and
potential terrorists, human traffickers,
and otherwise inadmissible persons, at
the earliest possible point in time. In
fiscal year 2015, CBP processed more
than 104 million U.S.-bound air
travelers. CBP operates various
predeparture programs domestically
and overseas that are designed to
identify and interdict high-risk travelers
before they board U.S.-bound flights.
GAO was asked to review CBP’s
predeparture programs. This report
addresses (1) how CBP identifies high-
risk travelers before they board U.S.-
bound flights; (2) the results of CBP’s
predeparture programs and the extent
to which CBP has measures to assess
program performance; and (3) how
CBP plans to expand its predeparture
programs. GAO reviewed CBP policies
and procedures and fiscal year 2015
data across these programs. GAO also
visited nine foreign and one domestic
airport, selected based on location and
traveler volume, among other factors.
Information from these visits was not
generalizable but provided valuable
insights into program operations.
What GAO Recommends
GAO recommends that CBP develop
and implement a system of
performance measures and baselines
to evaluate the effectiveness of its
predeparture programs and assess
whether the programs are achieving
their stated goals. CBP concurred with
the recommendation and identified
planned actions to address the
recommendation.
For more information, contact Rebecca
Gambler at (202) 512
-8777 or
.
Page i GAO-17-216 Border Security
Letter 1
Background 6
CBP Analyzes Traveler Data and Threat Information to Identify
High-Risk Travelers before They Board U.S.-Bound Flights 9
CBP’s Air Predeparture Programs Interdict High-Risk Air
Travelers, but CBP Has Not Fully Assessed the Programs’
Performance 14
CBP Plans to Expand its Predeparture Programs, but Several
Factors Limit Its Ability to Expand to All Priority Locations 26
Conclusions 35
Recommendation for Executive Action 35
Agency Comments and Our Evaluation 36
Appendix I Comments from the Department of Homeland Security 39
Appendix II GAO Contact and Staff Acknowledgments 41
Figures
Figure 1: U.S. Customs and Border Protection’s (CBP) Air
Predeparture Program Locations 7
Figure 2: Actions Taken by U.S. Customs and Border Protection’s
(CBP) Predeparture Programs to Interdict High-Risk
U.S.-Bound Air Travelers Throughout the Travel Process
a
12
Figure 3: Total Traveler Volume and Inadmissibility Decisions for
U.S. Customs and Border Protection (CBP)
Preclearance, Fiscal Year 2015 16
Figure 4: Total U.S.-Bound Traveler Volume and No-Board
Recommendations for U.S. Customs and Border
Protection (CBP) Immigration Advisory Program (IAP)
and Joint Security Program (JSP), Fiscal Year 2015 18
Figure 5: Total U.S.-Bound Traveler Volume and No-Board
Recommendations for U.S. Customs and Border
Protection (CBP) Regional Carrier Liaison Group
(RCLG), Fiscal Year 2015 20
Figure 6: U.S. Customs and Border Protection’s (CBP)
Predeparture Programs’ Contributions to U.S.
Government Information Gathering Efforts 23
Contents
Page ii GAO-17-216 Border Security
Abbreviations
CBP U.S. Customs and Border Protection
DHS Department of Homeland Security
GPRA Government Performance and Result Act
IAP Immigration Advisory Program
JSP Joint Security Program
NTC National Targeting Center
OFO Office of Field Operations
POE Port of Entry
RCLG Regional Carrier Liaison Group
TSA Transportation Security Administration
TSDB Terrorist Screening Database
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Page 1 GAO-17-216 Border Security
441 G St. N.W.
Washington, DC 20548
January 24, 2017
Congressional Requesters
The Department of Homeland Security (DHS) seeks to identify and
interdict international air travelers who are potential security threats to the
United States at the earliest possible point in the travel lifecycle to make
the nation’s physical borders the last, not the first, line of defense. DHS’s
U.S. Customs and Border Protection (CBP) is the federal agency with
primary responsibility for securing U.S. borders and processes all
travelers on U.S.-bound flights.
1
In fiscal year 2015, CBP processed more
than 104 million U.S.-bound air travelers. CBP’s efforts start before air
travelers enter a foreign port of embarkation—including when an
individual applies for U.S. travel documents, or reserves, books, or
purchases an airline ticket—and continue during travel up until officers
from CBP’s Office of Field Operations (OFO) determine whether to admit
travelers into the United States at U.S. ports of entry (POE).
2
CBP
implements multiple air predeparture programs designed to interdict high-
risk individuals, such as foreign fighters and potential terrorists, human
traffickers, drug smugglers, and otherwise inadmissible persons, before
they board U.S.-bound aircraft.
3
CBP officers assigned to these programs
query traveler data against government databases (referred to as vetting),
conduct in-person interviews of travelers at foreign airports (referred to as
1
See 6 U.S.C. § 211. For the purposes of this report, our scope focuses on CBP efforts
associated with air travel and does not include CBP’s efforts to process individuals who
are traveling to the United States via other means, such as pedestrians or vehicles at U.S.
land ports of entry or via commercial cruise ships.
2
OFO, which is headed by an Executive Assistant Commissioner and has nearly 28,000
employees, is responsible for providing border security while facilitating lawful trade and
travel at U.S. POEs. POEs are facilities that provide for the controlled entry into or
departure from the United States. Specifically, a POE is any officially designated location
(seaport, airport, or land border location) where CBP officers or employees are assigned
to clear travelers and merchandise, collect duties, and enforce customs laws, and where a
person may apply for admission into the United States pursuant to U.S. immigration law.
3
For the purposes of this report, the term “high-risk traveler” refers to any traveler who
may be inadmissible to the United States under the Immigration and Nationality Act, or
who may otherwise pose a threat to homeland or national security. See, e.g., 8 U.S.C. §
1182 (establishing grounds for inadmissibility). According to CBP, the predeparture
programs discussed in this report aim to interdict all high-risk travelers, but primarily focus
on national security concerns and preventing known or suspected terrorists or travelers
with connections to known or suspected terrorists from boarding flights destined for the
United States.
Letter
Page 2 GAO-17-216 Border Security
interviewing), and conduct full examinations of travelers and their
belongings at foreign airports to determine admissibility to the United
States (referred to as inspecting), as appropriate. U.S.-bound travelers
are vetted, interviewed, or inspected prior to boarding flights, although not
all U.S.-bound travelers undergo all three processes. In fiscal year 2015,
CBP data indicate that more than 8,100 known or suspected terrorists, or
individuals with connections to known or suspected terrorists, attempted
to apply for travel to the United States or board U.S.-bound flights. CBP
has plans underway to expand the presence of its predeparture programs
overseas.
Recent events have highlighted the increased threat of one group of high-
risk individuals, namely foreign fighters—individuals who leave home,
travel abroad to terrorist safe havens, and join or assist violent extremist
groups. In February 2016, the Director of National Intelligence reported
that more than 36,500 foreign fighters—including more than 6,600 from
Western countries—had traveled to Syria to train with, support, or join
extremist groups, such as the Islamic State in Iraq and Syria (ISIS).
4
Moreover, according to the Director of National Intelligence, the
November 2015 attacks in Paris, France, which killed 130 people, were
conducted, in part, by European foreign fighters returning from Syria.
Furthermore, airport and air travel security remains a pressing current
issue, as evidenced by the October 2015 bombing of a Russian airliner in
the Sinai, Egypt, which killed all 224 passengers onboard, as well as the
March 2016 airport attack in Brussels, Belgium, which killed 32 people.
You asked us to review CBP’s air predeparture programs and CBP’s
plans to expand them. This report addresses the following questions: (1)
How does CBP identify high-risk travelers before they board U.S.-bound
flights? (2) What have been the results of CBP’s air predeparture
programs, and to what extent does CBP have measures to assess the
programs’ performance? (3) How does CBP plan to expand its air
predeparture programs?
4
James R. Clapper, Director of National Intelligence, Worldwide Threat Assessment of
U.S. Intelligence Community, testimony before the Senate Select Committee on
Intelligence, 114th Cong., 2nd sess., February 9, 2016.
Page 3 GAO-17-216 Border Security
This report is a public version of a sensitive report that we issued in
September of 2016.
5
CBP deemed some of the information in that report
as sensitive security information and law enforcement sensitive, both of
which must be protected from public disclosure. Therefore, this report
omits sensitive information about CBP’s efforts to target and interdict
high-risk passengers prior to departing for the United States. Although the
information provided in this report is more limited in scope, it addresses
the same questions as the sensitive report. Also, the overall methodology
used for both reports is the same.
To determine how CBP identifies high-risk travelers before they board
U.S.-bound flights, we reviewed documentation related to CBP’s efforts to
identify high-risk travelers before they board U.S.-bound flights, such as
CBP’s 2015 predeparture targeting standard operating procedures and
guidance on targeting effort development and implementation. We also
reviewed applicable federal statutes, regulations, and DHS privacy
documents related to CBP’s predeparture targeting efforts. In addition, we
reviewed documentation on CBP’s processes for developing,
implementing, and reviewing its targeting efforts. We interviewed senior
CBP officials responsible for leading CBP’s targeting efforts at the
National Targeting Center (NTC) to better understand the process by
which NTC develops, implements, and oversees the targeting process
and observed the predeparture targeting process.
6
We also interviewed
and received documentation from DHS’s Office of General Counsel
regarding its oversight of CBP’s targeting and identification efforts.
To determine the results of CBP’s air predeparture programs, we
reviewed CBP documents, policies, and procedures regarding the
management and operations of CBP’s predeparture programs, including
standard operating procedures and strategic planning documents. We
also interviewed CBP headquarters officials responsible for managing
CBP’s predeparture programs. To evaluate the extent to which CBP has
measures in place to evaluate these programs’ performance, we
5
GAO, Border Security: CBP Aims to Prevent High-Risk Travelers from Boarding U.S.-
Bound Flights, but Needs to Evaluate Program Performance, GAO-16-646SU
(Washington, D.C.: Sept. 29, 2016).
6
CBP’s NTC leads all of CBP’s predeparture targeting and vetting efforts. NTC is a 24/7
operations entity responsible for providing advance information and research about high-
risk travelers and cargo and facilitating coordination between law enforcement and
intelligence agencies in support of CBP’s anti-terrorism mission and efforts to keep high-
risk individuals and cargo from boarding U.S.-bound flights.
Page 4 GAO-17-216 Border Security
assessed CBP’s efforts to measure and track program performance
against requirements for performance measurement in the Government
Performance and Results Act of 1993 (GPRA)
7
and the GPRA
Modernization Act of 2010,
8
as well as best practices on performance
management
9
and best practices on program evaluation.
10
Moreover, we
gathered fiscal year 2015 data—the most recent complete data
available—on the results of CBP’s predeparture programs. Due to
technology updates related to CBP’s efforts to collect data on
predeparture program vetting, interviewing, and inspection, we used fiscal
year 2015 data.
11
We also collected and analyzed available CBP data
from fiscal year 2015 on the number of travelers matched to the Terrorist
Screening Database (TSDB) and its subset No Fly List, as well as
previously unknown individuals identified by CBP as high-risk.
12
We
assessed the reliability of these data by, for example, reviewing
documentation from and meeting with relevant CBP officials responsible
for processing and handling the data, as well as by reviewing the data for
inconsistencies. We found that these data were sufficiently reliable to
provide descriptive information on the result of CBP’s identification and
targeting efforts and for presenting descriptive statistics on CBP’s efforts
to prevent high-risk individuals from traveling to the United States.
7
See generally Pub. L. No. 103-62, 107 Stat. 285 (1993). GPRA was enacted to help
resolve the long-standing management problems that undermined the federal
government’s efficiency and effectiveness and provide greater accountability for results.
8
See generally Pub. L. No. 111-352, 124 Stat. 3866 (2011) (updating GPRA).
9
GAO, Managing For Results: Enhancing Agency Use of Performance Information for
Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005). The best
practices outlined in GAO-05-927 were developed through literature review, interviews
with performance information experts, and group discussions with federal program
managers, among other things.
10
GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January
2012). The best practices outlined in GAO-12-208G are based on GAO studies, policy
documents, and program evaluation literature. To ensure the guide’s competence and
usefulness, drafts were reviewed by selected GAO, federal and state agency evaluators,
and evaluation authors and practitioners from professional consulting firms.
11
Due to the switch from multiple data collection systems for each predeparture program
to one data collection system, which CBP implemented in fiscal year 2015, we elected to
use fiscal year 2015 data to ensure that all of the data is comparable across programs.
12
The Terrorist Screening Database (TSDB) is the U.S. government’s consolidated
terrorist watchlist. The No Fly List is a subset of the TSDB that identifies individuals
prohibited from boarding flights to, from, within, or overflying the United States.
Page 5 GAO-17-216 Border Security
We also conducted site visits at nine foreign airports and one domestic
airport from May 2015 through September 2015 to observe the specific
techniques used by CBP officers to prevent high-risk individuals from
boarding U.S.-bound flights.
13
To help ensure that our site visits included
observations across all of CBP’s predeparture programs within our scope
and across geographic regions, we selected these locations based on
factors such as program type; geographic location; and CBP data on
overall traveler volume and numbers of high-risk travelers, among other
things. Moreover, during the site visits at foreign locations, we met with
CBP, Department of State, and other U.S. government officials;
representatives from host country government agencies; airport authority
representatives; and airline representatives to discuss and observe how
CBP implements the predeparture programs. Our visits to these locations
do not provide a representative sample of these programs, but provide
illustrative examples and insight into the processes and daily operations
of these programs. We also met with and received documentation from
CBP predeparture officials located in the three U.S. POEs that coordinate
with airlines at foreign airports to prevent individuals who may pose a
security threat, have fraudulent documents, or are otherwise likely to be
inadmissible from boarding flights to the United States.
To determine how CBP plans to expand its air predeparture programs, we
reviewed and analyzed CBP documentation, including guidance for
prospective applicant airports, cost estimates for potential expansion
locations, and CBP’s expansion evaluation report and supporting
materials. We also analyzed CBP’s January 2016 predeparture “white
paper,” which outlines CBP’s goals for its programs and discusses its
strategy for expanding these programs and capabilities. We also
reviewed relevant laws concerning expansion, particularly those related to
funding and CBP staffing requirements. We interviewed a non-
generalizable sample of private sector representatives from air carrier
associations, airlines, and airport authorities regarding CBP’s planned
expansion of the predeparture programs. We selected these stakeholders
13
During our site visits, we traveled to nine foreign airports—Pierre Elliott Trudeau
International Airport in Montreal, Canada; Lester B. Pearson International Airport in
Toronto, Canada; Abu Dhabi International Airport in Abu Dhabi, United Arab Emirates;
Doha Hamad International Airport in Doha, Qatar; Heathrow Airport in London, England;
Charles de Gaulle International Airport in Paris, France; Adolfo Suarez Madrid—Barajas
International Airport in Madrid, Spain; Tocumen International Airport in Panama City,
Panama; and Benito Juarez International Airport in Mexico City, Mexico. We also traveled
to one domestic airport—John Fitzgerald Kennedy International Airport in New York City,
New York.
Page 6 GAO-17-216 Border Security
through analysis of Department of Transportation data on air carrier
volume, consultation with airline industry representatives, and input from
an internal GAO expert on the airline industry. The information we
obtained from our private sector interviews cannot be generalized, but
offers insight into the role and participation of private sector stakeholders
into CBP’s expansion efforts. We interviewed CBP, Department of State,
Transportation Security Administration (TSA), and Department of
Transportation officials on predeparture expansion, including factors
affecting expansion, insights into the negotiation process, the different
roles of federal stakeholders involved in the process, and the status of
these efforts.
We conducted this performance audit from October 2016 to January 2017
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
According to CBP documentation, throughout the travel process, OFO’s
NTC analyzes traveler information and uses it to provide CBP officers at
CBP’s predeparture locations with relevant and timely information about
an individual.
14
According to CBP documentation, these efforts provide
CBP officers stationed overseas and within the United States the ability to
address risks or prevent the movement of identified threats toward the
United States at the earliest possible point in the travel process. CBP’s
predeparture programs use the results of NTC’s efforts to identify and
interdict high-risk individuals destined for the United States while they are
still overseas. Specifically, CBP operates three air predeparture programs
that are responsible for all U.S.-bound air travelers—Preclearance; the
Immigration Advisory Program (IAP) and Joint Security Program (JSP);
and the regional carrier liaison groups (RCLG). In fiscal year 2015, CBP’s
14
For the purposes of this report, the term travel process denotes the sequential steps that
an international traveler takes to travel to the United States and focuses specifically on the
points in time when travelers reserve and purchase airline tickets; check-in at the airport;
transit to the United States; and arrive at a U.S.-based (i.e. domestic) airport; it does not
focus on steps taken by the traveler before a ticket is reserved or purchased, such as
obtaining a requisite travel authorization.
Background
Page 7 GAO-17-216 Border Security
predeparture programs consisted of more than 670 CBP officers at 29
locations worldwide as outlined in figure 1 below.
Figure 1: U.S. Customs and Border Protection’s (CBP) Air Predeparture Program Locations
Preclearance. Preclearance locations operate at foreign airports and
serve as U.S. POEs. Preclearance operations began in 1952 in Toronto
to facilitate trade and travel between the United States and Canada. As of
April 2016, CBP operates 15 air Preclearance locations in six countries.
15
Through the Preclearance program, uniformed CBP officers at a foreign
airport exercise U.S. legal authorities to inspect travelers and luggage
and make admissibility determinations prior to an individual boarding a
plane to the United States.
16
According to CBP officials, an inspection at a
Preclearance location is the same inspection an individual would undergo
at a domestic POE, and officers conducting Preclearance inspections
exercise the same authority as officers at domestic POEs to approve or
deny admission into the United States.
17
As a result, travelers arriving at
15
See 19 C.F.R. § 101.5. CBP’s Preclearance location in Victoria, Canada, only processes
maritime travelers and, as a result, we did not include it in this report.
16
See 8 U.S.C. § 1103(a)(7); 19 U.S.C. § 1629. See also 8 C.F.R. §§ 235.1, 235.5; 19
C.F.R. §§ 148.22, 162.6, 162.8. See also Pub. L. No. 114-125, § 813, 130 Stat. 122, 217-
18 (2016) (authorizing the DHS secretary to establish and maintain CBP preclearance
operations in a foreign country).
17
Individuals denied admission to the United States at a Preclearance location are not
permitted to proceed beyond the point of inspection and, thus, are unable to board a flight
to the United States.
Page 8 GAO-17-216 Border Security
domestic air POEs from Preclearance locations do not have to be re-
inspected upon entry or if they are connecting to a domestic flight.
18
In
fiscal year 2015, CBP had about 600 staff located in Preclearance
facilities around the world.
Immigration Advisory Program (IAP) and Joint Security Program
(JSP). IAP and JSP operate at foreign airports. According to CBP
officials, under this program, unarmed, plain clothes CBP officers posted
at foreign airports partner with air carriers and host country government
officials to help prevent terrorists and other high-risk individuals from
boarding U.S.-bound flights by vetting and interviewing them before
travel.
19
According to CBP program documentation, CBP established IAP
in 2004 to prevent terrorists, high-risk, and improperly documented
travelers from boarding airlines destined to the United States. Building on
the IAP concept, CBP established JSP in 2009 to partner with host
country law enforcement officials to identify high-risk travelers. CBP
officers at IAP and JSP locations have the ability to question travelers and
review their travel documents. They are to act in an advisory manner to
the air carriers and host governments and do not have authority to deny
boarding to individuals on U.S.-bound flights or fully inspect travelers or
their belongings. IAP and JSP officers are authorized by CBP to make
recommendations to airlines as to whether to board or deny boarding
(known as a no-board recommendation) to selected travelers based on
their likely admissibility status upon arrival to the United States. The final
decision to board travelers, however, lies with the carriers.
Regional Carrier Liaison Groups (RCLG). RCLGs are located and
operate at domestic airports. CBP established RCLGs in 2006 to assist
air carriers with questions regarding U.S. admissibility requirements and
travel document authenticity. RCLGs are located in New York, Miami, and
Honolulu. According to CBP officials, RCLGs are responsible for
coordinating with air carriers on all actionable referrals from NTC on U.S.
bound travelers departing from an airport without an IAP, JSP, or
Preclearance presence. Each RCLG is assigned responsibility for
travelers departing out of a specific geographic location.
20
Similar to IAP
18
According to CBP officials, in accordance with CBP’s current preclearance agreements
and processes, CBP officers retain the authority to inspect these travelers and their
accompanying goods or baggage after arriving in the United States should further
inspection be warranted.
19
See 8 U.S.C. § 1225a(b).
20
RCLGs are not responsible for travelers departing from Preclearance locations.
Page 9 GAO-17-216 Border Security
and JSP, CBP officers in RCLGs also make no-board recommendations
as appropriate to air carriers. CBP officers at RCLGs do not have
authority to make admissibility determinations about U.S.-bound air
travelers, and the final decision to board or not board a traveler lies with
the carrier.
CBP electronically vets all travelers before they board U.S.-bound flights
and continues to do so until they land at a U.S. port of entry. Through
these vetting efforts, CBP seeks to identify high-risk travelers from the
millions of individuals who travel to the United States each year. CBP’s
vetting and targeting efforts are primarily conducted by NTC and entail (1)
traveler data matching and analysis, (2) rules-based targeting, and (3)
recurrent vetting.
CBP’s primary method of identifying high-risk individuals is through the
comparison of travelers’ information (such as name, date of birth, and
gender)
21
against records extracted from U.S. government databases,
21
According to CBP officials, information from both the Advance Passenger Information
System (APIS), which includes biographical information such as full name, date of birth,
gender, flight number, date of arrival and departure, citizenship, and passport/alien
registration card number, among others, and the Passenger Name Record (PNR), which
refers to reservation information contained in an air carrier’s electronic reservation system
and/or departure control system that sets forth the identity and travel plans of each
traveler or group of travelers included under the same reservation record, are utilized in
the targeting and vetting of individuals attempting to travel to the United States. See 49
U.S.C. § 44909; 19 C.F.R. §§ 122.49a, 122.49d. Air carriers must generally provide APIS
information not later than 30 minutes prior to securing the aircraft (i.e. departure), while
according to CBP officials, air carriers must provide PNR to CBP not later than 96 hours
prior to scheduled departure. NTC uses APIS information to positively confirm the identity
of high-risk travelers.
CBP Analyzes
Traveler Data and
Threat Information to
Identify High-Risk
Travelers before They
Board U.S.-Bound
Flights
CBP Has Processes in
Place to Identify High-Risk
Travelers before They
Board U.S.-Bound Flights
Traveler Data Matching and
Analysis
Page 10 GAO-17-216 Border Security
including the Terrorist Screening Database (TSDB)—the U.S.
government’s consolidated terrorist watch list.
22
Traveler data matching
focuses on identifying known high-risk individuals—that is, individuals
who may be inadmissible to the United States under U.S. immigration law
or who may otherwise pose a threat to homeland or national security.
According to senior NTC officials, CBP devotes significant resources to
traveler data matching and analysis. CBP’s primary tool for vetting and
targeting travelers is the Automated Targeting System (ATS), which is a
computer based-enforcement and support system that compares traveler
information against intelligence and law enforcement data to identify high-
risk travelers. Traveler data matching occurs throughout the travel
process and, upon a positive or possible match, CBP officers can select
these individuals for further vetting, interviewing, and inspection.
CBP’s rules-based targeting efforts seek to identify unknown high-risk
travelers—that is, travelers for whom U.S. government entities do not
have available derogatory information directly linking them to terrorist
activities or any other actions that would make them potentially
inadmissible to the United States but who may present a threat and thus
warrant additional scrutiny. According to NTC officials responsible for the
rules-based targeting program, unknown high-risk travelers pose the
greatest threat to the United States because their information is not
contained in lists of known high-risk individuals and are therefore more
difficult to detect. CBP identifies unknown high-risk individuals by
comparing their information against a set of targeting rules based on
intelligence, law enforcement, and other information. NTC officials stated
that these rules have identified potential foreign fighters or other high-risk
travelers. Within CBP, the NTC develops, modifies, and implements the
targeting rules in ATS. On the basis of our interviews and reviews of CBP
documentation, we found that when designing or implementing any new
22
Information in the TSDB comes from two sources: the National Counterterrorism Center,
which provides information on known or suspected international terrorists in the Terrorist
Identities Datamart Environment, and the Federal Bureau of Investigation, which provides
information about known or suspected domestic terrorists. For more information about the
TSDB and the process by which the U.S. government manages this watchlist, see GAO,
Terrorist Watchlist: Routinely Assessing Impacts of Agency Actions since the December
29, 2009, Attempted Attack Could Help Inform Future Efforts, GAO-12-476 (Washington,
D.C.: May 31, 2012). Databases and lists used include the Terrorist Screening Center’s
TSDB and its subset No Fly List, the Centers for Disease Control and Prevention’s Do Not
Board List (an infectious and contagious disease watchlist), the Federal Bureau of
Investigation’s National Crime Information Center, travelers with derogatory records in
TECS (CBP’s primary database for documenting traveler records and not an acronym),
the Department of State’s record of denied or revoked visas, and others.
Rules-Based Targeting
Page 11 GAO-17-216 Border Security
rules, NTC, in coordination with other partners at CBP, engages in a
multiple-step assessment and review process to ensure that the proposed
rule will meet its intended purpose and not impose an unjustifiable impact
on legitimate travelers. Rules-based targeting evaluates travelers during
the travel process and in some cases in advance of the travel process. If
a traveler is a rule “hit”, this individual can be selected for further vetting,
interviewing, and inspection.
23
CBP supports its traveler data matching and rules-based targeting efforts
through the use of recurrent vetting. NTC’s vetting, targeting, and traveler
data matching activities in ATS run 24 hours a day and seven days a
week and automatically scan through updated traveler information, when
available. This process, known as recurrent vetting, is to ensure that new
information that affects a traveler’s admissibility is identified in near real
time. Recurrent vetting occurs throughout the travel process and
continues until a traveler arrives at a domestic port of entry. For example,
after checking into a foreign airport, a traveler may have his or her U.S.
visa revoked for a security or immigration-related violation. Due to
recurrent vetting, CBP would be alerted to this through ATS and could
take action as appropriate.
Information on individuals who the NTC identifies through traveler data
matching or rules-based targeting, including recurrent vetting, is compiled
automatically through ATS into a daily high-priority list, or traveler referral
list. CBP officers at the NTC review the traveler referral list for accuracy
and to remove, if possible, any automatically generated matches
determined to not be potential high-risk individuals.
24
After this review,
CBP officers at the NTC use ATS to send the traveler referral list to
officers at each Preclearance, IAP, JSP, and RCLG location, as shown in
figure 2. According to CBP officials responsible for managing CBP’s
predeparture programs, these traveler referral lists represent their daily,
high-priority requirements. According to CBP officials, officers at each of
23
In general, when a traveler is identified through rules-based targeting, the traveler is
considered to have hit the rule.
24
Some travelers may be a “false positive” and match to high-risk individuals because they
have the same or similar name and personal information. Upon further review, such as by
viewing a picture of the traveler and comparing it with a picture of the high-risk individual,
CBP may be able to determine conclusively that the traveler is not the high-risk individual
in question. If this happens, CBP officers at the NTC can remove this individual from the
traveler referral list.
Recurrent Vetting
CBP Sends Lists of
Identified High-Risk
Travelers to Predeparture
Program Locations and
Coordinates Its Targeting
Efforts with TSA
Page 12 GAO-17-216 Border Security
these locations are required to assess each individual on the traveler
referral list and verify travel and identity documents, as appropriate. CBP
officers stationed overseas and at RCLGs communicate with the NTC
regarding the authenticity and completeness of traveler documents and
may send additional information to have the NTC verify that the
documents are legitimate.
Figure 2: Actions Taken by U.S. Customs and Border Protection’s (CBP) Predeparture Programs to Interdict High-Risk U.S.-
Bound Air Travelers Throughout the Travel Process
a
a
For the purposes of this report, the term travel process denotes the sequential steps that an
international traveler takes to travel to the United States and focuses specifically on the points in time
when travelers reserve and purchase airline tickets; check-in at the airport; transit to the United
States; and arrive at a U.S.-based (i.e., domestic) airport. It does not focus on steps taken by the
traveler before a ticket is reserved or purchased, such as obtaining a requisite travel authorization.
b
This figure generally represents the actions CBP officers take to interdict high-risk travelers who will
travel directly to the United States from a foreign last point of departure airport.
c
CBP’s NTC leads all of CBP’s predeparture targeting and vetting efforts. The NTC is a 24/7
operations entity within CBP’s Office of Field Operations responsible for providing advance
information and research about high-risk travelers and facilitating coordination between law
Page 13 GAO-17-216 Border Security
enforcement and intelligence agencies in support of CBP’s anti-terrorism mission and efforts to keep
high-risk travelers from boarding U.S.-bound flights.
d
For the purposes of this report, the term “high-risk traveler” refers to any traveler who may be
inadmissible to the United States under the Immigration and Nationality Act or who may otherwise
pose a threat to homeland or national security. See 8 U.S.C. § 1182 (establishing grounds for
inadmissibility). According to CBP, the predeparture programs discussed in this report aim to interdict
all high-risk travelers, but primarily focus on national security concerns and preventing known or
suspected terrorists or travelers with connections to known or suspected terrorists from boarding
flights destined for the United States.
e
CBP officers at air Preclearance locations conduct inspections of all U.S.-bound air travelers and
determine whether they are admissible into the United States, as if conducted at a domestic U.S. port
of entry.
f
If CBP determines that a traveler at an RCLG, IAP, or JSP location will likely be deemed inadmissible
upon arrival in the United States, CBP officers responsible for the location may recommend to the air
carrier that it not board the traveler. Air carriers, however, retain authority to board the traveler unless
the traveler has been identified by TSA as being on the No Fly List.
Additionally, NTC coordinates its traveler data matching and rules-based
targeting for international air travelers with TSA’s Secure Flight
Program.
25
In April 2014, NTC and TSA developed an electronic common
operating picture, which displays a master CBP and TSA traveler referral
list of high-risk travelers in both the NTC and TSA operations center.
According to CBP and TSA officials responsible for these programs, joint
display of high-risk traveler information permits both TSA and CBP to
identify and resolve discrepancies in vetting travelers, coordinate their
efforts, and functions as a security redundancy. In addition, NTC officials
stated that CBP and TSA’s coordination efforts have allowed them to
identify more high-risk travelers than they would have if they had been
working separately.
25
In response to requirements of the Intelligence Reform and Terrorism Prevention Act of
2004, and a recommendation of the National Commission on Terrorist Attacks upon the
United States (the 9/11 Commission), TSA developed and implemented Secure Flight in
order to assume from air carriers the function of matching traveler information against
watchlists maintained by the federal government. See 49 U.S.C. § 44903(j)(2)(C). After
initiating development of its prescreening system in 2004, TSA began implementing
Secure Flight in 2009, and completed transitioning foreign and domestic air carriers to the
program in November 2010. Secure Flight screens travelers on all domestic and
international flights to, from, and within the United States; certain flights overflying the
continental United States; and international point-to-point flights operated by U.S. aircraft
operators. See 73 Fed. Reg. 64,018 (Oct. 28, 2008).
Page 14 GAO-17-216 Border Security
According to officials from NTC and DHS’s Offices of General Counsel,
Privacy, and Civil Rights and Civil Liberties, CBP has internal and
external processes in place to ensure that its vetting and targeting
efforts—particularly the use of targeting rules—are relevant, manageable,
and in compliance with privacy requirements.
26
These officials reported
that CBP reviews the targeting rules on a periodic basis to assess
whether the rules remain relevant in light of evolving threats. In addition,
CBP also conducts constant rule maintenance and development as
needed in response to new or changing threats. According to CBP
documentation, DHS’s Offices of General Counsel, Privacy, and Civil
Rights and Civil Liberties also review the targeting rules on a periodic
basis to ensure that the rules do not excessively affect the traveling
public. According to NTC officials, to date there have been no
disagreements about the validity or utility of the rules between NTC and
the external review groups.
Through its predeparture programs—Preclearance, IAP and JSP, and
RCLGs—CBP identifies and interdicts high-risk travelers before they
board U.S.-bound flights. Specifically, CBP data indicate that CBP’s
predeparture programs identified and ultimately interdicted approximately
22,000 high-risk air travelers in fiscal year 2015.
26
See, e.g., 80 Fed. Reg. 13,407 (Mar. 13, 2015) (APIS System of Records Notice) and
77 Fed. Reg. 30,297 (May 22, 2012) (ATS System of Records Notice).
CBP Has Processes in
Place to Oversee and
Review Predeparture
Targeting Efforts
CBP’s Air
Predeparture
Programs Interdict
High-Risk Air
Travelers, but CBP
Has Not Fully
Assessed the
Programs’
Performance
CBP Identifies and
Interdicts High-Risk
Travelers before They
Board U.S.-Bound Flights
Page 15 GAO-17-216 Border Security
Preclearance. In fiscal year 2015, CBP officers at Preclearance locations
determined that 10,648 air travelers were inadmissible out of the
approximately 16 million air travelers seeking admission to the United
States through a Preclearance location (see fig. 3). In addition to requiring
that all travelers undergo a primary inspection, CBP officers in these
locations also referred almost 290,000 individuals for secondary
inspection.
27
Because all precleared travelers are inspected at a foreign
airport, CBP officials told us that Preclearance presents the best
opportunity to prevent high-risk individuals from boarding a flight to the
United States because the opportunity to conduct a secondary inspection
or interview could result in information linking a person to terrorism or a
crime that may render them inadmissible to the United States. CBP
officers at the three Preclearance locations we visited—Montreal and
Toronto, Canada, and Abu Dhabi, United Arab Emirates—noted that
being able to conduct an inspection on travelers has allowed them to
identify high-risk individuals. During our site visits to Preclearance
locations, CBP officers stated that they conduct their own targeting
activities, in addition to coordinated targeting activities with NTC.
27
Primary inspection refers to the procedure that CBP uses to conduct an initial inspection
of individuals seeking to enter the United States to determine if additional review or
scrutiny is needed to ensure compliance with U.S. law. Persons who need additional
scrutiny and persons selected as part of a random selection process are subjected to a
more detailed review called a secondary inspection. This involves, for example, a closer
inspection of travel documents and possessions, additional questioning by CBP officers,
and cross references through multiple law enforcement databases to verify the traveler’s
identity, background, purpose for entering the country, and other appropriate information.
Page 16 GAO-17-216 Border Security
Figure 3: Total Traveler Volume and Inadmissibility Decisions for U.S. Customs and Border Protection (CBP) Preclearance,
Fiscal Year 2015
IAP and JSP. CBP officers at IAP and JSP locations made 3,925 no-
board recommendations in fiscal year 2015 for the approximately 29
million air travelers bound for the United States from such locations (see
fig. 4). During this same time period, CBP data indicated 1,154 confirmed
encounters with individuals on the TSDB, including 106 on the No-Fly
List.
28
According to CBP officials, IAP and JSP officers receive the
majority of their daily targets from the NTC and they work closely with the
NTC to address high-risk targets and identify trends in high-risk travel.
28
A confirmed encounter refers to when a representative of the U.S. government (in this
case a CBP officer) comes in to contact, either through physical interviewing or inspection
or through electronic vetting, with an individual whose identity is confirmed as a match to a
record in the TSDB.
Page 17 GAO-17-216 Border Security
According to our observations and in-person discussions with IAP and
JSP officials, on a daily basis, IAP and JSP officers resolve NTC targets,
observe travelers, and issue no-board recommendations to carriers
regarding persons scheduled to travel on U.S.-bound flights who will likely
not be admitted into the United States upon arrival. IAP and JSP officers
also conduct their own targeting initiatives and have access to the host
airports’ sterile and boarding areas to question travelers and review their
travel documents.
29
According to CBP officials and IAP and JSP officers
(and supported by our in-person observations), air carriers almost always
follow IAP and JSP no-board recommendations.
29
The sterile area of an airport is, in general, the area beyond a security screening
checkpoint that provides travelers access to boarding aircraft and to which access is
generally controlled through the screening of persons and property. See, e.g., 49 C.F.R. §
1540.5.
Page 18 GAO-17-216 Border Security
Figure 4: Total U.S.-Bound Traveler Volume and No-Board Recommendations for U.S. Customs and Border Protection (CBP)
Immigration Advisory Program (IAP) and Joint Security Program (JSP), Fiscal Year 2015
a
In issuing a no-board recommendation, an IAP or JSP officer is recommending that the air carrier not
transport a traveler because the individual will likely be deemed inadmissible upon arrival in the
United States.
Page 19 GAO-17-216 Border Security
RCLG. CBP officers working at the three RCLGs made 7,664 no-board
recommendations in fiscal year 2015 for the approximately 59 million
travelers bound for the United States from locations within the RCLGs’
spheres of responsibility (see fig. 5). During this time period, CBP data
indicate that RCLGs also reported 1,634 confirmed encounters with
individuals in the TSDB, including 119 on the No-Fly List. On the basis of
our site visit to the New York RCLG, as well as phone interviews with the
Miami, Florida, and Honolulu, Hawaii, RCLGs, we found that RCLG
officers regularly resolve NTC targets, respond to questions from air
carriers, conduct research on long-term targeting initiatives, and issue no-
board recommendations. According to CBP officials, in the event that
RCLGs issue a no-board recommendation, airlines generally follow it.
CBP officials from all three RCLGs could not recall any examples over the
last 5 years of an airline not following a no-board recommendation from
an RCLG location.
Page 20 GAO-17-216 Border Security
Figure 5: Total U.S.-Bound Traveler Volume and No-Board Recommendations for U.S. Customs and Border Protection (CBP)
Regional Carrier Liaison Group (RCLG), Fiscal Year 2015
a
A no-board recommendation issued by an RCLG to an air carrier recommends that the air carrier not
transport a traveler because the individual will likely be deemed inadmissible upon arrival in the
United States.
Page 21 GAO-17-216 Border Security
In addition to preventing high-risk or other inadmissible travelers from
boarding U.S.-bound flights, CBP’s predeparture programs have resulted
in other benefits by, for example, (1) assisting air carriers, (2) enhancing
coordination with host country law enforcement agencies, (3) gathering
additional information on travelers to improve U.S. targeting activities, or
(4) facilitating travel.
CBP’s predeparture programs provide regular assistance to air carriers
on relevant U.S. admissibility requirements and U.S. travel documents.
During our site visits, we observed that IAP and JSP officers regularly
interacted with air carriers, and provided a point of contact at foreign
airports for air carriers and airport security employees who may have
difficulties assessing the validity of travel documents or understanding
U.S. immigration requirements. For example, during our site visit to one
IAP location in Europe, officers reported keeping a separate telephone
line for air carriers to use when requesting assistance regarding
document validity. In addition, several airline representatives we spoke
with reported that CBP officers from IAP and JSP locations have provided
helpful training to staff.
30
Further, according to RCLG officials we spoke
with, the relationships that the RCLGs have established with air carriers
allows RCLG officers to provide them with early information on potential
traveler admissibility determinations, which ultimately help the air carrier
avoid the costs associated with transporting inadmissible travelers back
to their point of departure as well as fines that could be imposed.
31
According to CBP documentation, one of the key advantages of its
predeparture programs is the ability to improve coordination overseas
between CBP and host country law enforcement agencies. As part of
their daily duties, IAP and JSP officers are responsible for establishing
30
In accordance with section 124 of the Illegal Immigration Reform and Immigrant
Responsibility Act of 1996, CBP established the Carrier Liaison Program to provide
technical assistance to air carriers and security companies regarding the use of fraudulent
travel documents. See Pub. L. No. 104-208, div. C, § 124, 110 Stat. 3009, 3009-562
(1996); 8 U.S.C. § 1356(h)(2)(A)(iv). This program is responsible for training air carriers on
document validity. According to IAP and JSP training requirements, all IAP and JSP
officers are certified to provide this training.
31
See 8 U.S.C. § 1323 (authorizing CBP to impose a fine on air carriers who transport
passengers to the United States who do not have valid passports or unexpired visas).
Further, under the International Civil Aviation Organization’s International Standards and
Recommended Practices, air carriers are responsible for transporting inadmissible
passengers back to their point of departure, or to a location where the passenger may be
deemed admissible.
CBP’s Predeparture
Programs Provide
Additional Travel and
Security-Related Benefits
Assisting Air Carriers
Improving Coordination with
Host Country Law Enforcement
Agencies
Page 22 GAO-17-216 Border Security
positive working relationships with numerous foreign entities, including
airlines and their security organizations, foreign border control authorities,
and other law enforcement agencies. For example, during our site visits
to the two JSP locations, host government law enforcement and security
representatives emphasized that their coordination with and training from
CBP was invaluable, and that it allowed them to better identify and target
high-risk individuals. Host government officials told us that the expanded
targeting efforts in their countries due to CBP’s presence at JSP locations
also have a strong impact on regional security. Moreover, according to
CBP officials, information sharing through the JSP program has led to
enhanced coordination and targeting efforts to include taking action
against international drug, currency, and human smugglers, and known or
possible suspected terrorists. Similarly, during our site visits to three IAP
locations in Europe, foreign law enforcement officials we spoke with told
us that information sharing generally occurs informally between IAP
officers and host government officials rather than through formal channels
due to host country privacy concerns about formal information sharing
arrangements with other governments.
According to senior CBP officials, all of CBP’s predeparture programs
provide key information that helps to improve NTC’s targeting efforts and
also supports larger U.S. government information gathering efforts on
high-risk individuals and threats to the United States (see fig. 6). For
example, according to CBP data, in fiscal year 2015, CBP’s predeparture
programs allowed CBP to identify thousands of previously unknown high-
risk individuals and of these, CBP nominated more than 1,500 for
inclusion in the TSDB.
Gathering Information to
Improve NTC Targeting Efforts
Page 23 GAO-17-216 Border Security
Figure 6: U.S. Customs and Border Protection’s (CBP) Predeparture Programs’ Contributions to U.S. Government Information
Gathering Efforts
According to senior CBP officials, CBP officers stationed overseas in
Preclearance, IAP, or JSP locations have the opportunity to collect
information about travelers, their travel history, and any other pertinent
information while engaging with these individuals in conversation as part
of interviewing or inspecting them. Officials told us that the information
collected can be maintained and used for future targeting efforts if these
individuals travel to the United States again.
Air carrier and airport authority representatives, foreign government
officials, and CBP officials we interviewed reported that CBP predeparture
operations help to facilitate travel into the United States. For example,
CBP officials, as well as air carrier and airport authority representatives
told us that Preclearance operations ensure that all individuals aboard a
given plane have already been inspected and have been cleared for entry
into the United States. As a result, officials told us that this provides
airports with more domestic airport arrival gate options by allowing
international flights to arrive at domestic terminals that may not otherwise
be equipped to properly inspect international travelers. IAP and JSP also
provide travel facilitation benefits, according to IAP and JSP officers we
spoke with. For example, IAP and JSP officers assist U.S. citizens and
lawful permanent residents who have lost, stolen, or expired
Travel Facilitation
Page 24 GAO-17-216 Border Security
documentation. Although U.S. citizens and lawful permanent residents
can generally not be denied entry to the United States under U.S.
immigration law, air carriers will typically deny boarding to travelers
without proper documentation because the air carrier cannot verify
documentation and the legal status of the individual as admissible to the
United States. According to IAP and JSP officers, having a physical
presence at the airport enables them to reconcile an individual’s identity
by accessing CBP databases and recommending to the air carriers that
they board the traveler. Further, U.S. embassy officials we interviewed in
Europe stated that IAP officers routinely assist embassy staff in verifying
travelers’ identities and, because of their access to CBP databases, IAP
officers are able to facilitate travel for U.S. citizens and lawful permanent
residents even when the embassy is closed. For example, embassy
officials in Western Europe reported that IAP officers were instrumental in
facilitating the travel of the parents of the American students who
thwarted a terrorist attack on the Thalys train from Amsterdam to Paris in
July 2015. Not all of the families had the required travel documentation for
entry into France, and IAP officers worked with the Western European
government and air carriers to ensure their arrival and departure.
CBP has not evaluated the effectiveness of its predeparture programs as
a whole, including implementing a system of performance measures and
baselines to assess whether the programs are achieving their stated
goals. In a January 2016 white paper, CBP states that its strategic goal
for its predeparture programs is to achieve comprehensive and highest
level coverage at all high-risk air transit points to the United States with a
focus on using the programs to push the U.S. borders outward to
intercept and address potential threats at the earliest possible
opportunity. Other program-specific documentation that we reviewed
articulates similar, high-level predeparture program objectives, which are
primarily focused on enhancing national security, counterterrorism, and
travel facilitation. CBP has taken some initial steps to measure the
performance of its air predeparture programs by collecting data on
program activities. For example, CBP tracks a variety of data on the
activities across Preclearance, IAP, JSP, and RCLG locations, including
data on the numbers of travelers issued no-board recommendations or
deemed inadmissible; invalid travel documents seized; and No-Fly List
and TSDB encounters. According to CBP officials, on occasion, CBP has
used these data, among other inputs, to support adjustments to its
operations, including closing two IAP former locations where CBP
determined that high-risk traveler volume did not merit having a location.
On the basis of our analysis of CBP documentation and interviews with
CBP Has Not Evaluated
Overall Effectiveness of Air
Predeparture Programs
Page 25 GAO-17-216 Border Security
program officials, CBP has not assessed the performance of these
programs on a regular basis, in part because it has not established
baselines for these measures. Therefore, CBP does not have anything
against which to compare the data to determine whether the programs
are achieving stated goals. Solely tracking increases or decreases in
program data, such as traveler volume or the number of invalid travel
documents seized, does not allow CBP to fully evaluate its predeparture
programs as such changes in the data may not be an indicator of
program success or increased efficacy.
CBP officials told us that they have collected a large quantity of data and
statistics regarding the actions of their predeparture programs and have
done so since program inception for all programs. However, due to
changes in operational focus, technology updates, and the use of
separate data systems at predeparture program locations, CBP has not
collected consistent data across all of its predeparture programs. As a
result, CBP does not have baseline data on which to measure program
performance. However, CBP officials stated that they now have updated
and uniform data collection systems that are consistent across all
predeparture programs. As a result, CBP officials stated that they should
be able to identify performance baselines from fiscal year 2015 onward.
According to senior CBP officials, some of the results of CBP’s
predeparture programs are not easily measured. For example, some
benefits, such as coordination and information sharing with host
governments, are invaluable but difficult to measure. Officials also noted
that relying on data alone may not always present the most accurate
picture of the true impact of predeparture programs because changes to
the travel process or other factors may impact the predeparture programs
in ways that are not fully captured by the data. However, on the basis of
our analysis of CBP’s documentation, including official hearing
statements, and interviews with predeparture program officials, CBP uses
these data as indicators of the programs’ success.
According to GAO’s Program Evaluation Guide, which articulates best
practices for program evaluation, a program evaluation is a systematic
study using research methods to collect and analyze data to assess how
well a program is working and why.
32
Program evaluation is closely
related to performance measurement and analyzes performance
32
GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January
2012).
Page 26 GAO-17-216 Border Security
measures to assess the achievement of performance objectives or goals.
Evaluations answer specific questions about program performance and
may focus on assessing program operations or results. Evaluation can
play a key role in strategic planning and in program management,
providing feedback on both program design and execution. Moreover, in
accordance with GPRA, as updated by the GPRA Modernization Act of
2010, performance measurement is the ongoing monitoring and reporting
of program accomplishments, particularly towards pre-established goals,
and agencies are to establish performance measures to assess progress
towards goals.
33
Agencies can use performance measurement to make
various types of management decisions to improve programs and results,
such as developing strategies and allocating resources, and identify
problems and take corrective action.
34
Developing and implementing a
system of performance measures and baselines for each program would
help ensure that these programs are achieving their intended goals. By
using data from fiscal year 2015, for example, to develop initial baselines,
CBP could better measure program performance towards meeting stated
goals.
CBP has plans underway to expand its predeparture programs,
particularly Preclearance operations. According to CBP, Preclearance
expansion is a significant homeland security priority. CBP has reported
that it aims to preclear 33 percent of all U.S.-bound air travelers by 2024.
Accordingly, in September 2014, CBP invited foreign airport authorities
33
See generally Pub. L. No. 103-62, 107 Stat. 285 (1993) (GPRA) and Pub. L. No. 111-
352, 124 Stat. 3866 (2011) (updating GPRA); 31 U.S.C. § 1115.
34
GAO, Managing For Results: Enhancing Agency Use of Performance Information for
Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005).
CBP Plans to Expand
its Predeparture
Programs, but
Several Factors Limit
Its Ability to Expand
to All Priority
Locations
CBP Aims to Expand Its
Predeparture Programs to
Additional Overseas
Locations
Page 27 GAO-17-216 Border Security
interested in having the United States expand Preclearance operations to
their location to submit letters of interest. CBP received 25 letters of
interest from foreign airport authorities. Of the 25 airports, CBP selected
18 to rank, prioritize, and score for potential new air Preclearance
locations.
35
CBP, in conjunction with TSA and considering input from
Department of State, conducted technical site visits and evaluations of
these airports. In particular, CBP and TSA assessed these airports based
on a variety of factors related to national security, travel facilitation, and
feasibility of operations, among other things. In May 2015, DHS
announced plans to enter into formal negotiations to expand
Preclearance to 10 airports in 9 countries.
36
According to CBP
Preclearance officials, all 10 priority airports are valuable in supporting
CBP’s predeparture mission.
Opening a new Preclearance location requires the entry into force of an
international agreement between the United States and a foreign
government and requires the resolution of various diplomatic issues such
as the extent of the law enforcement capability of CBP officers within the
host country to include the carriage of service weapons, CBP officer
immunity or legal status within the host country, and other complex
issues. After reaching an agreement with the host country, expansion
timelines may change due to competitive pressures, facility readiness,
and other factors, according to CBP Preclearance officials. The Director
of Preclearance noted that, in accordance with the Trade Facilitation and
Trade Enforcement Act of 2015, CBP will provide any requisite
information and certifications to the appropriate Congressional
committees before entering an agreement into force with the government
35
CBP did not pursue Preclearance expansion with seven of the locations that submitted
letters of interest for a number of reasons, including lack of host country willingness and
ongoing diplomatic negotiations.
36
The 10 priority airports identified for potential expansion are: Amsterdam Airport
Schiphol, in the Netherlands; London Heathrow and Manchester Airports in the United
Kingdom; Istanbul Ataturk Airport in Turkey; Narita International Airport in Tokyo, Japan;
Madrid-Barajas Airport in Spain; Brussels Airport in Belgium; Stockholm Arlanda Airport in
Sweden; Oslo Airport in Norway; and Punta Cana Airport in the Dominican Republic. The
other 8 remaining airports were not identified as potential Preclearance locations for a
number of reasons, but CBP officials noted that these airports could submit new letters of
interest for consideration during the next expansion solicitation round.
Page 28 GAO-17-216 Border Security
of a foreign country to establish Preclearance operations.
37
In May 2016,
CBP again invited interested airport authorities to submit a letter of
interest to participate in the Preclearance program by August 1, 2016.
38
CBP officials told us that they also aim to expand IAP or JSP operations
to other airports where CBP has determined there is a potential threat to
the United States but Preclearance may not always be feasible.
According to CBP officials, host countries and airport authorities must
express interest in the program, coordinate with CBP so that CBP may
determine if airports are suitable for participating in the program, and host
countries must agree to bilateral arrangements before CBP will expand
the program.
37
Specifically, section 814 of the Trade Facilitation and Trade Enforcement Act of 2015,
enacted in February 2016, establishes three requirements pursuant to which the Secretary
of Homeland Security must provide to the Committee on Homeland Security and
Governmental Affairs, the Committee on Finance, the Committee on Commerce, Science
and Transportation, and the Committee on Appropriations of the Senate, and to the
Committee on Homeland Security, the Committee on Ways and Means, and the
Committee on Appropriations of the House of representatives, information and
certifications regarding the establishment of Preclearance operations either 60 or 45 days
before an agreement with the government of a foreign country to establish CBP
Preclearance operations enters into force. See Pub. L. No. 114-125, § 814(a)-(c), 130
Stat. 122, 218-19 (2016). Title VIII, subtitle B of the Act is referred to as the Preclearance
Authorization Act of 2015.
38
On November 4, 2016, the Secretary of Homeland Security announced the selection of
11 new foreign airports, located in nine countries, for possible Preclearance expansion.
The 11 airports identified for possible Preclearance locations are: El Dorado International
Airport (BOG) in Bogota, Colombia; Ministro Pistarini International Airport (EZE) in Buenos
Aires, Argentina; Edinburgh Airport (EDI) in Edinburgh, United Kingdom; Keflavik
International Airport (KEF) in Iceland; Mexico City International Airport (MEX) in Mexico
City, Mexico; Milan-Malpensa Airport (MXP) in Milan, Italy; Kansai International Airport
(KIX) in Osaka, Japan; Rio de Janeiro-Galeão International Airport (GIG) in Rio de
Janeiro, Brazil; Leonardo da Vinci-Fiumicino Airport (FCO) in Rome, Italy; São Paulo-
Guarulhos International Airport (GRU) in Sao Paulo, Brazil; and Princess Juliana
International Airport (SXM) in St. Maarten.
Page 29 GAO-17-216 Border Security
Because CBP depends on the willingness of host country governments
and airport authorities to establish overseas predeparture program
locations, there are challenges to expanding Preclearance, IAP, and JSP.
For example, not all of the airports that responded to CBP’s expansion
solicitation may be able to secure the necessary support of their
governments to enter into negotiations with the United States for
Preclearance operations. Multiple senior CBP Preclearance officials
stated that the willingness and readiness of the host government and
airport authority are key factors impacting the timeline of expansion. As a
result, CBP’s negotiation and planning efforts are furthest along with two
countries that currently have willing governments and airport authorities,
according to CBP officials.
39
However, CBP did not select these two
locations solely based on their score among the 10 priority locations that
CBP selected for potential expansion. CBP officials stated that expanding
to these locations does not preclude CBP from establishing Preclearance
operations at some of the other airports where the benefits to the United
States might be greater, as long as these other eight locations can meet
CBP’s requirements. According to CBP’s Preclearance evaluation report,
some high-priority airports that are interested in Preclearance may face
challenges in meeting such requirements. For example, airports that
provide service to the United States on multiple U.S. air carriers, such as
London Heathrow, will need to ensure that all U.S. carriers have access
to Preclearance services by, for example, reconfiguring terminals,
according to CBP Preclearance officials. Further, airport authorities and
39
On November 4, 2016, the Secretary of Homeland Security announced that the United
States and Sweden signed an agreement to implement Preclearance operations at
Stockholm Arlanda Airport. The agreement will be brought into force after the
Governments have completed all necessary internal procedures. According to the
Secretary of Homeland Security, Preclearance operations in Sweden may begin as early
as 2019. In addition, on December 1, 2016, the United States and the Dominican Republic
signed an agreement to implement Preclearance operations at the Punta Cana
International Airport. The agreement will be brought into force after the Governments have
completed all necessary internal procedures. Preclearance operations may begin at Punta
Cana International Airport as early as 2017.
Host Government and
Foreign Airport
Willingness, among Other
Factors, Affect CBP’s
Ability to Expand Air
Predeparture Programs to
Other High Priority
Locations
Page 30 GAO-17-216 Border Security
host country governments in many locations are not interested and do not
support establishing a CBP Preclearance operation.
40
Moreover, CBP plans to expand Preclearance to locations where airport
authorities agree to reimburse CBP for certain costs. For the first 14
Preclearance locations, CBP assumed all of the costs of Preclearance
operations—including officer pay, travel costs, and other operational
costs. Beginning with Abu Dhabi, CBP determined that its model for new
Preclearance locations would include a requirement for costs to be
shared with the host airport authority. CBP’s expenses for Preclearance
inspections in Abu Dhabi are reimbursed to about 85 percent of all
expenses.
41
According to CBP officials, under this model, CBP is able to
extend its borders without having to pay the full costs of operations.
Airport authority officials we spoke with in Canada stated that they valued
having CBP Preclearance operations at their facilities, but noted that high
up-front development and implementation costs could be potential
40
In addition, DHS’s annual appropriations acts in recent years have provided that none of
the funds made available to DHS may be used for new CBP air preclearance agreements
unless: (1) the Secretary of Homeland Security, in consultation with the Secretary of State,
has certified to Congress that air Preclearance operations at the airport provide a
homeland or national security benefit to the United States; (2) U.S. passenger air carriers
are not precluded from operating at existing preclearance locations; and (3) a U.S.
passenger air carrier is operating at all airports contemplated for establishment of new air
Preclearance operations. See, e.g., Pub. L. No. 114-113, div. F, § 553, 129 Stat. 2242,
2520 (2015).
41
Under its agreement with the United Arab Emirates (UAE), CBP is able to recoup all
costs associated with Preclearance operations to the greatest extent permitted by U.S.
law. Under federal law, CBP may only seek reimbursement for immigration pre-inspection
and agriculture preclearance services, such as inspecting travel documents and
agriculture items; it may not seek reimbursement for time spent conducting customs
activities such as collecting duties levied by the U.S. government. See 8 U.S.C. § 1356(i),
19 U.S.C. § 58c(e)(6)(B); see also 7 U.S.C. § 8311(a), (b) (authorizing the Secretary to
enter into reimbursable fee agreements for the preclearance of animals or articles for
movement into the United States at foreign locations), 6 U.S.C. § 231 (transferring this
agricultural authority, among others, from the Secretary of Agriculture to the Secretary of
Homeland Security). Moving forward, CBP officials stated that all countries wishing to be
considered for Preclearance should generally be willing to pay, to the maximum extent
allowable by U.S. law, for expenses incurred by CBP in the establishment and
maintenance of Preclearance services, including, but not limited to salaries, expenses,
and relocation costs of CBP Preclearance officers. See, e.g., Pub. L. No. 114-125, § 817,
130 Stat. at 220 (2016) (providing, among other things, that cost sharing agreements may
authorize payment to CBP for initial Preclearance operating costs, which include costs
incurred or expected to be incurred by CBP to establish or maintain Preclearance
operations and include hiring, training, and equipping new CBP officers who will be
stationed at domestic ports of entry to backfill officers to be stationed at an airport in a
foreign country, in advance of incurring the costs or on a reimbursable basis).
Page 31 GAO-17-216 Border Security
impediments for other airport authorities. Because of the cost-sharing
model CBP has implemented, not all airport authorities may be willing or
able to accept Preclearance operations in their facilities.
According to CBP officials and documentation, airport authorities’ and
host countries’ willingness to participate also affects CBP’s efforts to
expand IAP and JSP operations, particularly concerns related to
sovereignty, such as CBP officer presence in the country and airport.
These officials also raised concerns about airside access, such as access
to areas within the airport, freedom of movement, and ability to interview
travelers. These officials stated that JSP and IAP expansion efforts are
also impacted by officer safety and security concerns, particularly in
potential expansion locations in Central and South America as well as the
Middle East and Southeast Asia.
CBP is taking some steps to address staffing and funding needed for the
expansion of its predeparture programs, but because CBP’s efforts are
still in the early stages and negotiations with host governments about
planned expansion locations have not yet been finalized, it is too soon to
determine whether CBP’s efforts will fully address its needs.
According to CBP’s Assistant Commissioner for Human Resources
Management, staffing is one of the most prominent challenges the
agency faces. CBP data indicate that, as of February 2016, OFO was
more than 800 officers below its congressionally authorized staffing level,
which includes all POEs—OFO had 23,775 officer positions authorized
and 22,937 officers on-board. In addition, according to CBP hiring and
attrition data, as of February 2016, about one percent of initial applicants
for a CBP OFO officer qualify. This means that CBP needs approximately
78,000 new applicants in fiscal year 2016 to meet its current officer gap.
Further, in April 2016, CBP officials testified that OFO’s staffing model
estimates that the agency will need to hire an additional 2,107 officers
through fiscal year 2017 to account for growing volumes of trade and
CBP is Taking Some Steps
to Address Staffing and
Funding Needs as it
Seeks to Expand its
Predeparture Programs
Staffing
Page 32 GAO-17-216 Border Security
travel.
42
CBP’s stakeholders, including several air carriers and air carrier
associations we met with, also raised concerns about the impact of
expanding Preclearance operations on domestic POEs because CBP
plans to initially staff new locations with officers from domestic POEs.
CBP’s Office of Human Resources Management has taken several steps
to address the agency’s broader staffing gaps. In addition, in April 2016,
CBP officials testified that CBP has begun initiatives aimed at decreasing
the amount of time it takes for an applicant to complete the hiring
process, increased the number of recruiting events, and coordinated with
the Department of Defense to recruit qualified veterans and individuals
separating from military service. Further, senior Preclearance officials
stated that when staffing Preclearance locations for start-up operations,
CBP selects temporary duty staff from various ports so as not to deplete
the capacity of any one domestic POE. IAP and JSP also use temporary
duty staff from multiple POEs for start-up and to augment core staff
during seasonal peak travel. Further, a senior Preclearance official stated
that new Preclearance locations will not be operational until sometime in
fiscal year 2017 at the earliest and that, similar to the process in Abu
Dhabi, CBP will initially staff a new operation with a smaller number of
temporary duty officers and then gradually increase the number of
permanent staff at these locations. Moreover, according to a CBP budget
official, since the costs of new Preclearance positions will be mostly
reimbursed by the foreign airport authorities, CBP will be able to backfill
positions at domestic POEs that were vacated as a result of moving staff
to Preclearance locations.
In addition, CBP has reported that implementing additional Preclearance
locations will reduce wait times at domestic air POEs and lead to more
42
Keeping Pace with Trade, Travel, and Security: How Does CBP Prioritize and Improve
Staffing and Infrastructure: Hearing before the Subcommittee on Border and Maritime
Security, House Committee on Homeland Security, April 19, 2016 (Joint CBP statement of
Eugene Schied: Assistant Commissioner, Office of Administration; Linda Jacksta,
Assistant Commissioner, Office of Human Resources Management; and John Wagner:
Deputy Assistant Commissioner, Office of Field Operations). According to CBP data, the
staffing shortfall is primarily at land POEs, as airport locations are staffed at 99 percent of
the authorized levels, as of April 2016.
Page 33 GAO-17-216 Border Security
efficient inspections.
43
Specifically, CBP’s 2016 white paper notes that
Preclearance operations will reduce wait times at some of the busiest air
POEs in the United States. In addition, CBP officials also stated that
Preclearance operations have led to increased airport traveler processing
capacity. However, according to CBP officials responsible for data
collection and analysis across OFO programs, CBP does not have
generalizable data or analyses on the effect of Preclearance expansion
on domestic wait times, so they could not provide us with data to
corroborate this statement. Further, according to CBP officials and an
airline official we met with, reductions in wait times may be short-term
because airlines and airports may add new international routes in place of
precleared flights. On the basis of our review of CBP documentation, we
could not determine the extent to which there is a causal relationship
between Preclearance operations and long-term, reduced wait times at
domestic POEs. As of May 2016, CBP officials stated that they are in the
process of surveying all U.S. airports to gain insights on the full extent of
the impact of Preclearance operations, particularly traveler wait times and
processing capacity.
CBP has also taken steps to model anticipated Preclearance, IAP, and
JSP expansion staffing needs. However, CBP’s estimates are preliminary
and senior officials noted that CBP will be in a better position to determine
staffing needs once CBP is further along in the negotiation process with
host governments. According to CBP officials, the total staff required for
each new predeparture location depends on the negotiated CBP
presence at each location, which has not been finalized.
44
As a result, it is
too early in CBP’s efforts to accurately estimate staffing needs of
expanding CBP’s air predeparture programs, and to determine if CBP’S
current and planned actions will address staffing needs.
43
In a July 2015 report to Congress, CBP reported that a precleared Boeing 777 from Abu
Dhabi arriving at Chicago O’Hare Airport in the middle of peak traffic reduces the number
of travelers in queues for inspection at O’Hare at that time by almost 20 percent. In
addition, DHS’s Congressional Budget Justification for Fiscal Year 2017 states that
preclearing a single, daily flight (Boeing 777) from Abu Dhabi to JFK Airport, reduced JFK
terminal wait times by an average of 13.7 minutes (for a 2-hour period) and as a result,
travelers processed at JFK will wait 188,000 fewer hours over the course of a year.
44
For example, CBP officials explained that the number of officers stationed at each
Preclearance location depends on multiple factors, including the number of flights the
airport authority wants precleared and the number of shifts that will meet airport authority
requirements for total precleared flights.
Page 34 GAO-17-216 Border Security
CBP has taken some steps to identify and address funding needs for the
expansion of its predeparture programs, though it is too soon for us to
determine if these actions will fully address CBP’s funding needs. As
previously mentioned, CBP plans to expand Preclearance to locations
where airport authorities agree to reimburse CBP for certain costs.
Specifically, CBP intends to require the host airport authority to reimburse
CBP for all of the agricultural and immigration inspection-related costs
associated with Preclearance operations. Further, CBP officials stated
that new Preclearance locations will generally be expected to provide the
facilities and equipment necessary for Preclearance operations.
45
Moreover, Preclearance officials stated that they are planning to use
authority provided to CBP under the Trade Facilitation and Trade
Enforcement Act of 2015, enacted in February 2016, to collect
Preclearance payments for start-up costs in advance of opening new
Preclearance facilities, and to collect reimbursement in advance of
incurring the costs for the provision of certain activities, such as
immigration or agricultural inspection activities.
46
By using these two
strategies, Preclearance officials stated that they should be able to secure
airport authority funding for almost all activities associated with the
planning and operations of future Preclearance locations. Although CBP
prefers that the airport authority pay the majority of Preclearance costs,
CBP officials stated that its expansion decisions are not solely driven by
the costs CBP would have to incur to set up and maintain a Preclearance
location. These officials stated that CBP would still consider expanding
Preclearance to a desirable location even if the country or airport
authority did not support the reimbursement model; however, CBP’s
current expansion plans and white paper strategy indicate that they are
primarily pursuing the reimbursement model. In contrast to Preclearance,
CBP officials stated that CBP will continue to fund all of the costs
45
CBP officials estimate that CBP will be reimbursed for approximately 85 percent of total
costs for any planned expansion locations; however, this percentage could potentially
fluctuate depending on the nature of travel out of Preclearance locations. CBP will not
request that the host airport authorities reimburse all costs because, among other things,
as explained earlier, CBP is not authorized under federal law to seek reimbursement for
costs associated with customs activities.
46
The Trade Facilitation and Trade Enforcement Act of 2015 provides that CBP may
collect payment for initial Preclearance operation costs in advance of incurring the costs.
See Pub. L. No. 114-125, § 817, 130 Stat. at 220. The Act further provides that
reimbursement for the provision of immigration inspection services, as well as the
preclearance of animals or articles, may be collected in advance, among other things. See
Pub. L. No. 114-125, § 118, 130 Stat. at 222 (amending 8 U.S.C. § 1356(i) and 7 U.S.C. §
8311(b)).
Funding
Page 35 GAO-17-216 Border Security
associated with additional JSP and IAP locations. Officials told us that
CBP has developed cost estimates for several potential JSP locations.
Further, CBP has taken steps to model anticipated Preclearance and IAP
and JSP expansion costs. CBP has incorporated Preclearance staffing
estimates into a cost model, which includes costs for salaries, benefits,
relocation, and office space. According to CBP budget officials, the total
cost incurred by CBP depends on the total number of officers stationed at
each location, which has not been finalized. Similarly, funding required for
IAP and JSP locations is also dependent on the number of staff at each
location. As a result, it is too early in CBP’s efforts to accurately estimate
the cost of expanding CBP’s predeparture programs, and to determine if
CBP’S current and planned actions will address funding needs.
Through its predeparture programs, CBP seeks to prevent high-risk
individuals from boarding U.S.-bound flights—a key aspect of the
agency’s mission to secure the U.S. border. In support of this mission,
CBP has implemented a layered security approach aimed at identifying
and preventing the travel to the United States of such individuals as early
in the travel process as possible. CBP’s approach uses information from
across the government and leverages CBP officer’s physical presence at
predeparture program locations around the world. As a result of CBP’s
efforts to vet, interview, and inspect travelers, CBP interdicts thousands of
high-risk travelers each year. Moreover, CBP’s predeparture programs
have provided additional benefits that improve global safety and security
and facilitate lawful travel. However, CBP has not evaluated the
effectiveness of its predeparture programs as a whole, including using a
system of performance measures and baselines by which to assess
whether the programs are achieving their stated goals. By developing and
implementing a system of performance measures and baselines to
evaluate the effectiveness of its predeparture programs, CBP will be
better positioned to measure predeparture program performance and to
determine what these data indicate about whether the programs are
achieving their stated goals.
To better ensure the effectiveness of CBP’s predeparture programs, we
recommend that the Commissioner of U.S. Customs and Border
Protection develop and implement a system of performance measures
and baselines to evaluate the effectiveness of CBP’s predeparture
programs and assess whether the programs are achieving their stated
goals.
Conclusions
Recommendation for
Executive Action
Page 36 GAO-17-216 Border Security
We provided a draft of this report to the Departments of Homeland
Security, State, and Transportation for their review and comment. The
Department of Transportation indicated that it did not have any comments
on the draft report via e-mail. The Department of State provided technical
comments via e-mail, which we incorporated as appropriate. DHS
provided written comments, which are noted below and reproduced in full
in appendix I, and technical comments, which we incorporated as
appropriate.
DHS concurred with our recommendation and described the actions it
plans to take in response. Specifically, DHS stated that it plans to create
a working group to develop and implement a system of performance
measures and establish baselines to evaluate the effectiveness of CBP’s
predeparture programs and to assess whether the programs are
achieving their stated goals. If implemented effectively, these planned
actions should address the intent of our recommendation.
If you or your staff have any questions about this report, please contact
me at (202) 512-8777 or g[email protected]. Key contributors to this
report are listed in appendix II.
Rebecca Gambler
Director, Homeland Security and Justice
Agency Comments
and Our Evaluation
Page 37 GAO-17-216 Border Security
List of Requesters
The Honorable Michael T. McCaul
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Martha McSally
House of Representatives
The Honorable Filemon Vela
House of Representatives
The Honorable Peter T. King
House of Representatives
The Honorable Brian Higgins
House of Representatives
The Honorable John Ratcliffe
House of Representatives
The Honorable Cedric L. Richmond
House of Representatives
The Honorable Daniel M. Donovan, Jr.
House of Representatives
The Honorable Donald M. Payne, Jr.
House of Representatives
The Honorable Scott Perry
House of Representatives
The Honorable Bonnie Watson Coleman
House of Representatives
The Honorable John M. Katko
House of Representatives
The Honorable Kathleen M. Rice
House of Representatives
Page 38 GAO-17-216 Border Security
The Honorable Susan Brooks
House of Representatives
The Honorable Jeff Duncan
House of Representatives
The Honorable Richard Hudson
House of Representatives
The Honorable William R. Keating
House of Representatives
The Honorable James R. Langevin
House of Representatives
The Honorable Sheila Jackson Lee
House of Representatives
The Honorable Patrick Meehan
House of Representatives
The Honorable Norma J. Torres
House of Representatives
Appendix I: Comments from the Department of
Homeland Security
Page 39 GAO-17-216 Border Security
Appendix I: Comments from the Department
of Homeland Security
Appendix I: Comments from the Department of
Homeland Security
Page 40 GAO-17-216 Border Security
Appendix II: GAO Contact and Staff
Acknowledgments
Page 41 GAO-17-216 Border Security
Rebecca Gambler, (202) 512-8777 or GamblerR@gao.gov.
In addition to the contact named above, Kathryn Bernet (Assistant
Director), Chuck Bausell, Jose Cardenas, Eric Hauswirth, Paul Hobart,
Susan Hsu, Richard Hung, Benjamin Licht, Thomas Lombardi, Sara
Margraf, Michael Silver, and Martin Wilson made key contributions to this
report.
Appendix II: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(101179)
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