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entitled 'Justice Department: Better Management Oversight and Internal 
Controls Needed to Ensure Accuracy of Terrorism-Related Statistics' 
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Report to the Honorable Dan Burton, House of Representatives:



United States General Accounting Office:



GAO:



January 2003:



JUSTICE DEPARTMENT:



Better Management Oversight and Internal Controls Needed to Ensure 

Accuracy of Terrorism-Related Statistics:



Management Oversight and Internal Controls:



GAO-03-266:



GAO Highlights:



Highlights of GAO-03-266, a report to the Honorable Dan Burton, House 

Committee on Government Reform.



JUSTICE DEPARTMENT

Better Management Oversight and Internal Controls Needed to Ensure 

Accuracy of Terrorism-Related Conviction Statistics.



Why GAO Did This Study:



In accordance with the Government Performance and Results Act of 1993, 

the Department of Justice (DOJ) provides the Congress and the public 

with an annual performance report. These reports serve as an important 

measure of DOJ’s progress related to its strategic goals and 
objectives, 

including statistics on its efforts to investigate and prosecute 

terrorist 

acts. A December 2001 news article alleged that DOJ had inflated 

terrorism 

statistics in its Fiscal Year 2000 Performance Report. We were asked 

to 

review the accuracy of DOJ’s terrorism-related conviction statistics. 

Among 

other objectives, in this report we (1) identify how DOJ develops its 

terrorism-

related conviction statistics and (2) assess whether DOJ has sufficient 

management oversight and internal controls in place to ensure the 

accuracy of 

terrorism-related statistics included in its annual performance 

reports.



What GAO Found:



Beginning in fiscal year 2001, DOJ switched from using the FBI’s 

terrorism-related 

conviction statistics to using those of the Executive Office of 

U.S. Attorneys (EOUSA) 

for its annual performance report. This change was in response to 

concerns raised 

by a newspaper article’s allegation that DOJ had inflated terrorism 

statistics in 

its Fiscal Year 2000 Performance Report. It was also part of an 

effort to report 

conviction statistics that would be less likely to be misinterpreted, 

according to 

DOJ officials. The FBI historically classified more convictions than 

EOUSA as 

terrorism-related because it used a different classification system 

and included 

convictions obtained in international, federal, and state courts. 

EOUSA only included 

federal convictions. Our review of a sample of cases investigated 

and classified by 

the FBI as terrorism-related, including U.S. Attorney Office (USAO) 

cases covered by 

the article, found documentation to support the terrorism-related 

classifications for 

these cases. As for the accuracy and reliability of EOUSA’s 

terrorism-related statistics 

included in its annual performance reports, we found that DOJ does 

not have sufficient 

management oversight and internal controls in place, as required by 

federal internal 

control standards, to ensure the accuracy and reliability of its 

terrorism-related conviction 

statistics. At least 132 of the 288 USAO cases (about 46 percent) 

were misclassified as 

resulting in terrorism-related convictions in fiscal year 2002. 

Without the implementation 

of adequate management oversight and internal controls to ensure 

accurate and reliable 

terrorism-related conviction data, DOJ’s and the Congress’s 

ability to accurately assess 

terrorism-related performance outcomes of the U.S. criminal justice 

system will be limited.



A Review of EOUSA Fiscal Year 2002 Terrorism-Related Convictions 

Revealed That at Least 46 

Percent Were Misclassified.



[See PDF for Image]

[End of Figure]



What GAO Recommends:



To improve the accuracy and reliability of terrorism-related 

conviction statistics in DOJ’s 

annual performance reports, we recommend that the Attorney General, 

in accordance with federal 

internal control standards, implement a formal system to oversee 

and validate the accuracy of 

case classification and conviction data entered in EOUSA’s case 

tracking system. DOJ agreed to 

implement this recommendation.



To view the full report, including the scope

and methodology, click on the link above.

For more information, contact Laurie Ekstrand, (202) 512-8777, or 

ekstrandl@gao.gov.



Contents:



Letter:



Scope and Methodology:



Background:



Results in Brief:



FBI and EOUSA Classification Criteria Differ:



Number of Reported FBI and EOUSA Terrorism-Related Convictions Differs:



DOJ Used the FBI’s Terrorism-Related Statistics in Its 2000 Performance 

Report but Has Since Switched to Reporting EOUSA Statistics:



FBI Case Files Contained Documentation to Support Terrorism-Related 

Classifications:



Several Factors Contributed to Recent Increases in EOUSA’s Number of 

Terrorism-Related Convictions:



DOJ Lacks Internal Controls to Ensure Reliability of EOUSA Terrorism-

Related Statistics:



Conclusions:



Recommendation for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: Summaries of Selected Statutory Terrorism

Definitions:



Appendix II: Summary of Case Files GAO Reviewed:



Appendix III: GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Staff Acknowledgments:



Tables:



Table 1: Total Number of Terrorism-Related Convictions for the FBI and 

EOUSA:



Table 2: Misclassification of Fiscal Year 2002 Terrorism-Related 

Convictions Reported by Various USAOs:



Figure:



Figure 1: Difference in the Number of FBI and EOUSA Terrorism-Related 

Convictions for Fiscal Years 1997 through 2002:



Abbreviations:



DOJ Department of Justice

EOUSA Executive Office for United States Attorneys

FBI Federal Bureau of Investigation

LIONS Legal Information On-line System

TRAC Transactional Records Access Clearinghouse

USAO United States Attorneys Office:



United States General Accounting Office:



Washington, DC 20548:



January 17, 2003:



The Honorable Dan Burton

House of Representatives:



Dear Mr. Burton:



In accordance with the Government Performance and Results Act of 

1993,[Footnote 1] the Department of Justice (DOJ) provides the Congress 

and the public with an annual performance report. These annual 

performance reports serve as an important mechanism of accountability 

and measure of DOJ’s progress related to its strategic goals and 

objectives, including statistics on its efforts to investigate and 

prosecute terrorist acts. A December 2001 Philadelphia Inquirer article 

alleged that DOJ had inflated terrorism statistics in its Fiscal Year 

2000 Performance Report to the Congress by labeling cases as terrorism-

related that involved crimes not generally defined as terrorism. This 

article further alleged that DOJ had overstated the number of 

terrorism-related convictions in its annual reports, in part, to 

justify its budget request.



You asked us to examine how DOJ reports terrorism-related conviction 

statistics. On September 17, 2002, we briefed your office on the 

results of our review. This report summarizes and adds to the 

information presented during that briefing. Specifically, we are 

providing information on (1) the criteria DOJ’s Federal Bureau of 

Investigation (FBI) and Executive Office for United States Attorneys 

(EOUSA)[Footnote 2] used to classify cases and any resulting 

convictions as terrorism-related prior to fiscal year 2002; 

(2) what effect, if any, the use of different classification systems 

had on the number of convictions classified as terrorism-related prior 

to fiscal year 2002; (3) the basis for the number of terrorism-related 

convictions in DOJ’s Fiscal Year 2000 Performance Report; (4) whether 

FBI case files contained documentation to support its terrorism-related 

classifications; (5) the factors contributing to recent increases in 

terrorism-related conviction statistics reported by EOUSA; and (6) 

whether DOJ has sufficient management oversight and internal controls 

in place to ensure the accuracy and reliability of terrorism-related 

statistics included in its annual performance report.



Scope and Methodology:



To address our objectives, among other things, we interviewed DOJ’s 

Criminal Division, Justice Management Division, FBI, and EOUSA 

officials; reviewed FBI’s and EOUSA’s policies and guidance for 

classifying cases; researched terrorism definitions in the United 

States Code and Code of Federal Regulations; compared FBI and EOUSA 

conviction data for fiscal years 1997 through 2002; and reviewed 

conviction data included in DOJ’s Fiscal Years 2000 and 2001 

Performance Reports and similar data the 94 USAO districts had reported 

to EOUSA for fiscal year 2002.



Additionally, to determine whether documentation supported the FBI’s 

classification of certain cases as terrorism-related, we reviewed 

information in the FBI case files for 28 convictions. This included all 

19 convictions that the FBI had classified as terrorism-related for 

fiscal years 1999 and 2000 in three FBI field offices (Baltimore, 

Dallas, and Washington, D.C.).[Footnote 3] Additionally, concerning the 

18 USAO terrorism-related convictions investigated by the FBI that were 

covered by the scope of the Philadelphia Inquirer article, as requested 

by your staff, we reviewed documentation in the FBI case files for all 

9 convictions that were classified by the FBI as terrorism-related. We 

did not review investigative files for the remaining 9 convictions that 

were not classified by the FBI as terrorism-related convictions because 

these cases were classified under other categories (e.g., violent 

crime, National Infrastructure Protection and Computer Intrusions, 

foreign counterintelligence, and civil rights).



To determine the scope of USAO’s cases covered by the article, we 

compared and analyzed EOUSA, FBI, and Transactional Records Access 

Clearinghouse (TRAC) data,[Footnote 4] which the Philadelphia Inquirer 

had relied on. We did not review cases that the FBI did not classify as 

terrorism-related or cases that were investigated by other law 

enforcement agencies. We also did not attempt to review the 

appropriateness of the FBI’s investigative activities. Rather, we 

sought to determine whether documents in the case files detailing the 

investigative activities supported a terrorism-related classification 

based on the FBI’s classification system.



Because of concerns we had with the significant increase in the total 

number of USAO terrorism-related conviction statistics that resulted 

from EOUSA’s efforts late in fiscal year 2002 to have USAO districts 

retroactively identify cases relating to terrorism, we reviewed data 

detailing specific statutory charges in these cases. Discrepancies we 

found led to a request that EOUSA follow-up with all USAO districts 

reporting four or more domestic or international terrorism-related 

convictions to validate the accuracy of the districts’ reclassification 

efforts. The results of EOUSA’s follow-up with these districts raise 

concerns about the accuracy and reliability of EOUSA’s fiscal year 2002 

statistics included in this report.



We conducted our work at FBI headquarters and EOUSA in Washington, 

D.C., and at FBI field offices in Baltimore, Dallas, Philadelphia, and 

Washington, D.C., between February and December 2002 in accordance with 

generally accepted auditing standards.



Background:



Multiple federal agencies have a role in U.S. efforts to combat 

terrorism. The DOJ components primarily responsible for investigating 

and prosecuting terrorism-related cases are the FBI and the USAOs. The 

FBI is the lead federal agency responsible for investigating crimes for 

which it has primary or concurrent jurisdiction and which involve 

terrorist activities, or acts in preparation of terrorist activities, 

within the statutory jurisdiction of the United States.[Footnote 5] The 

USAOs prosecute federal criminal cases, including those related to 

terrorism.



There is no single, uniform definition of terrorism. Several federal 

statutes define terrorism in a variety of contexts. Appendix I provides 

examples of various statutory terrorism definitions. In addition to 

these statutory definitions, the FBI has a regulatory definition of 

terrorism, which refers to the “unlawful use of force and violence 

against persons or property to intimidate or coerce a government, the 

civilian population, or any segment thereof, in furtherance of 

political or social objectives.”[Footnote 6]



Although the FBI’s regulatory definition of terrorism relates to cases 

involving the unlawful use of force or violence, this same regulation 

designates the FBI as the lead federal agency for investigating both 

terrorist activities and acts in preparation of terrorist 

activities.[Footnote 7] Thus, the FBI may investigate cases that do not 

involve the use of force or violence that may be terrorism-related 

(e.g., cases involving money laundering or drug trafficking in support 

of a terrorist organization).



Results in Brief:



The FBI and EOUSA used different criteria to classify cases and 

resulting convictions as terrorism-related. The FBI classified a case 

as terrorism-related based on the overall violation being investigated; 

its classification criteria are contained in its Manual of 

Investigative Operations and Guidelines. USAOs, following EOUSA’s 

guidance in effect prior to fiscal year 2002, classified a case based 

on the statute under which an individual was indicted or convicted. The 

different classification criteria resulted in differences in how each 

entity ultimately classified a case. For example, if the FBI arrested 

an individual for money laundering and, as part of its investigation, 

gathered evidence that indicated that the defendant was laundering 

money for a terrorist group, it generally classified such a case and 

any resulting conviction as terrorism-related. On the other hand, if a 

USAO prosecuted the defendant and obtained a conviction solely on money 

laundering charges, it generally classified the conviction as a money 

laundering conviction and not as terrorism-related.



The total number of convictions classified by the FBI and USAOs as 

terrorism-related differed because each entity was using different 

classification criteria. In addition, because USAOs only prosecute 

federal cases, their classification system only includes federal 

convictions. In contrast, FBI’s classification system includes not only 

federal convictions, but also convictions in state, local, and 

international courts obtained with FBI investigative assistance.



As table 1 shows, the FBI and EOUSA have reported different terrorism-

related conviction numbers over the last 6 fiscal years.



Table 1: Total Number of Terrorism-Related Convictions for the FBI and 

EOUSAA:



Fiscal year: Component: FBI; Fiscal year: 1997: 124; Fiscal year: 1998: 

162; Fiscal year: 1999: 173; Fiscal year: 2000: 249; Fiscal year: 2001: 

225; Fiscal year: 2002: 373.



Fiscal year: Component: EOUSA; Fiscal year: 1997: 13; Fiscal year: 

1998: 44; Fiscal year: 1999: 59; Fiscal year: 2000: 30; Fiscal year: 

2001: 29; Fiscal year: 2002: 156[B].



[End of table]



Source: GAO-generated based on FBI and EOUSA data.



[A] FBI statistics include convictions resulting from terrorism-related 

hoaxes.



[B] As discussed in more detail later in this report, following 

September 11, 2001, EOUSA modified its case classification system and 

began tracking and including convictions resulting from criminal 

activity in support of terrorist activity or organizations and also 

began tracking and including terrorism-related hoaxes. However, during 

the course of our work, we found discrepancies that raise some concerns 

about the accuracy of EOUSA’s fiscal year 2002 figure.



In its Fiscal Year 2000 Performance Report, DOJ used the FBI’s 

terrorism-related investigation and conviction statistics to highlight 

its accomplishments. The FBI’s statistics were used because they 

reflect DOJ’s accomplishments beginning at the investigative stage 

through the prosecutive stage, according to DOJ officials. The 

Philadelphia Inquirer’s allegations that DOJ had misclassified certain 

terrorism-related convictions were based on how USAOs had classified 

certain cases versus how the FBI had classified these cases. Beginning 

with the Fiscal Year 2001 Performance Report, DOJ switched from using 

FBI’s statistics to using the statistics reported by EOUSA. This 

decision was made, according to DOJ officials, in response to concerns 

raised by the Philadelphia Inquirer article and because EOUSA 

conviction data was less likely to be misinterpreted.



Documentation existed in the FBI’s case files for the 28 convictions 

included in our review that the FBI had classified as terrorism-

related. Specifically, we found documentation to support all 19 

convictions that the FBI had classified as terrorism-related for fiscal 

years 1999 and 2000 in three FBI field offices. We also found 

documentation in the FBI case files for the 9 USAO convictions that 

fell within the scope of the Philadelphia Inquirer article that were 

classified by the FBI as terrorism-related.



EOUSA’s terrorism-related conviction data increased significantly, 

going from an average of 35 convictions per year for the previous 5 

years to about 160 in fiscal year 2002.[Footnote 8] EOUSA attributes 

the increase in its terrorism-related conviction statistics to (1) the 

Attorney General’s and President’s direction to make antiterrorism 

efforts a priority and heightened awareness, investigation, and 

prosecutorial efforts after September 11, 2001, and (2) the 

implementation of a new EOUSA classification system in fiscal year 

2002, intended to better capture terrorism-related efforts.



During the course of our engagement, we discovered that DOJ does not 

have sufficient management oversight and internal controls in place to 

ensure the accuracy and reliability of terrorism-related conviction 

statistics included in its annual performance reports. We found that 

DOJ lacks a formal system, as required by federal internal control 

standards, to verify the accuracy or oversee the reliability of case 

data entered in its Legal Information On-line System (LIONS)[Footnote 

9] by the various USAO districts and subsequently included in the 

annual performance reports. Specifically, the various USAO districts 

had originally classified 288 convictions as terrorism-related for 

fiscal year 2002. Our subsequent request that EOUSA follow up with 

selected USAO districts[Footnote 10] revealed that at least 132 of the 

288 convictions (about 46 percent) were misclassified as terrorism-

related. This misclassification occurred despite a semiannual effort by 

EOUSA requiring managers in the various USAO districts to certify the 

accuracy of case data. These 132 cases did not result in terrorism-

related convictions and were subsequently reclassified under other 

categories. EOUSA officials attribute these discrepancies to limited 

time afforded to the various USAOs to thoroughly reevaluate caseload 

and investigative data during their efforts to retroactively reclassify 

cases going back to the beginning of the fiscal year 2002.[Footnote 11]



The overall accuracy of the remaining 156 convictions is questionable 

because, at the time of our review, EOUSA had not validated the 

reliability of the terrorism-related conviction data for USAO districts 

that reported less than four domestic or international terrorism-

related convictions or convictions involving terrorism-related hoaxes 

or terrorist financing. Thus, we have concerns about the overall 

accuracy of EOUSA conviction statistics to be included in DOJ’s Fiscal 

Year 2002 Annual Performance Report and the sufficiency of management 

oversight and internal controls to validate the accuracy of terrorism-

related statistics reported by USAO districts. We are making a 

recommendation intended to better ensure the accuracy and reliability 

of EOUSA’s terrorism-related convictions.



We provided a draft of this report to the Attorney General and the 

Director of FBI for comment. DOJ and the FBI agreed with the report 

findings and DOJ agreed to implement our recommendation.



FBI and EOUSA Classification Criteria Differ:



Prior to fiscal year 2002, the FBI and EOUSA’s criteria for classifying 

cases and any resulting convictions differed. The FBI classified a case 

as terrorism-related based on the overall violation being investigated. 

USAOs, following EOUSA guidance, classified a case based on the charges 

in the indictment or the charges for which the defendant was convicted. 

For example, if the FBI arrested an individual for money laundering 

and, as part of its investigation, gathered evidence that indicated 

that the defendant was laundering money for a terrorist group, the FBI 

generally classified such a case as terrorism-related. On the other 

hand, if a USAO prosecuted the defendant and obtained a conviction 

solely on money laundering charges, USAO generally classified the 

conviction in the case as a money laundering conviction and not a 

terrorism conviction.



Although the FBI’s regulatory definition of terrorism refers to cases 

involving force and violence, as previously noted, this same regulation 

also designates the FBI as the lead agency responsible for 

investigating both terrorist activities, and acts in preparation of 

terrorist activities, within the statutory jurisdiction of the United 

States.[Footnote 12] Thus, a case need not involve force or violence to 

be classified by the FBI as terrorism-related. For example, the FBI may 

also classify nonviolent crimes (e.g., money laundering and fraud) as 

terrorism-related if they are undertaken to support terrorism-related 

activities. To capture and track the volume of its counterterrorism 

work, the FBI used the classification criteria contained in its Manual 

of Investigative Operations and Guidelines. The Manual, among other 

things, set forth multiple classification codes for domestic and 

international terrorism investigations and extensive guidance for 

agents and squad supervisors to determine the appropriate 

classification of an investigation.



As stated previously, at the time of the Philadelphia Inquirer’s 

allegation, EOUSA used a classification system that was based on the 

charges in an indictment or the charges for which a defendant were 

convicted. EOUSA’s classification guidelines are set forth in the Legal 

Information On-line System (LIONS) Users Manual. As outlined in the 

Manual, for an international terrorism classification, EOUSA used a 

representative (but not exhaustive) list of statutes that may relate to 

an international terrorist incident, (e.g., 18 U.S.C. 32 relating to 

destruction of aircraft or aircraft facilities and 18 U.S.C. 1203 

relating to hostage taking). For a domestic terrorism classification, 

the case must involve force or violence or the threat of force or 

violence undertaken by an individual or group seeking to further 

political or social goals.



EOUSA’s classification had no bearing on the FBI’s classification of a 

conviction resulting from a terrorism-related investigation, according 

to an FBI official. Occasionally, the FBI may reclassify a case when 

new facts become available that were not known at the time of the 

original classification.[Footnote 13]



Number of Reported FBI and EOUSA Terrorism-Related Convictions Differs:



The FBI’s number of reported terrorism-related convictions will differ 

from EOUSA’s because (1) the FBI and EOUSA had been using different 

criteria to classify terrorism-related cases and resulting convictions 

and (2) the FBI numbers include federal, state, local, or international 

court convictions resulting from its investigative efforts while 

EOUSA’s numbers include only federal court convictions. As shown in 

figure 1, the FBI has reported a different number of terrorism-related 

convictions than EOUSA over the past 6 fiscal years.



Figure 1: Difference in the Number of FBI and EOUSA Terrorism-Related 

Convictions for Fiscal Years 1997 through 2002:



[See PDF for image]



[End of figure]



[A] Number of convictions are as of September 30, 2002. FBI statistics 

include convictions resulting from terrorism-related hoaxes.



[B] As discussed in more detail later in this report, following 

September 11, 2001, EOUSA modified its case classification system and 

began tracking and including convictions resulting from criminal 

activity in support of terrorist activity or organizations and also 

began tracking and including terrorism-related hoaxes. However, during 

the course of our work, we found discrepancies that raise some concerns 

about the accuracy of EOUSA’s fiscal year 2002 figure.



DOJ Used the FBI’s Terrorism-Related Statistics in Its 2000 Performance 

Report but Has Since Switched to Reporting EOUSA Statistics:



In its Fiscal Year 2000 Performance Report provided to the Congress, 

DOJ used the FBI’s number of terrorism-related investigations and 

convictions. This report highlighted DOJ’s terrorism-related 

investigation and prosecution accomplishments. As noted earlier, DOJ 

used the FBI’s statistics because they track DOJ’s accomplishments 

beginning at the investigative stage through the prosecutive stage.



In response to concerns raised by the Philadelphia Inquirer article and 

to avoid any misinterpretation of DOJ’s statistics, beginning with the 

Fiscal Year 2001 Performance Report, DOJ switched from using the FBI’s 

statistics to using the statistics reported by EOUSA, according to DOJ 

officials. EOUSA’s statistics are intended to be representative of the 

cases prosecuted in federal courts that result in terrorism-related 

convictions and are less likely to be misinterpreted, according to DOJ 

officials. These statistics do not include cases for which the FBI had 

conducted a terrorism-related investigation that resulted in (1) a 

conviction in a state, local, or international court or (2) a federal 

conviction that was investigated by the FBI as terrorism-related but 

not classified by EOUSA as terrorism-related.



FBI Case Files Contained Documentation to Support Terrorism-Related 

Classifications:



We reviewed FBI investigative case files to ascertain whether 

documentation existed to support the FBI’s classification for 28 FBI 

terrorism-related convictions included in our review. We found 

documentation to support the FBI’s terrorism-related classifications 

for all 28 convictions. This included all of the convictions (19) that 

the FBI had classified as terrorism-related for fiscal years 1999 and 

2000 in three FBI field offices (Baltimore, Dallas, and Washington, 

D.C.) and 9 of the 18 USAO terrorism convictions covered by the scope 

of the Philadelphia Inquirer article that were investigated by the FBI.



Concerning the 18 USAO terrorism-related convictions investigated by 

the FBI that were covered by the scope of the Philadelphia Inquirer 

article, we found that the FBI had classified 9 of these cases as 

terrorism-related and had documentation in every case file to support 

these classifications. The FBI did not classify the remaining 9 

convictions as terrorism-related and as a result, we did not review 

those investigative case files. These cases were classified under other 

categories (e.g., violent crime, National Infrastructure Protection and 

Computer Intrusions, foreign counterintelligence, and civil rights). 

Appendix II provides a summary of the case files that we reviewed, 

including a description of the cases.



Several Factors Contributed to Recent Increases in EOUSA’s Number of 

Terrorism-Related Convictions:



As figure 1 shows, EOUSA’s number of terrorism-related convictions 

increased significantly in fiscal year 2002, going from an average of 

35 convictions per fiscal year for the previous 5 years to about 160 in 

fiscal year 2002. EOUSA attributed this increase to (1) the Attorney 

General’s and the President’s direction to make antiterrorism efforts a 

priority and heightened awareness, investigation, and prosecutorial 

efforts after September 11, 2001, and (2) the implementation of a new 

EOUSA classification system in fiscal year 2002, intended to better 

capture terrorism-related efforts.



On November 8, 2001, the Attorney General announced plans to prioritize 

the Justice Department and its components to focus on antiterrorism. 

The Attorney General noted that the attacks of September 11, 2001, had 

redefined the mission of DOJ. He described defending the nation and 

defending the citizens of America against terrorist attacks as the 

department’s first and overriding priority. On November 29, 2001, in a 

speech at a U.S. Attorney’s conference, the President said that 

terrorist violence on the home front must be prevented and defeated 

with vigilance, aggressive investigation, and certain punishment.



In December 2001, EOUSA issued new procedures for classifying cases as 

terrorism-related. Through these new procedures, EOUSA instructed all 

USAO district offices to immediately begin using terrorism-related 

program codes as the first code to identify and report on criminal and 

civil matters and cases arising out of terrorist attacks on the U.S. In 

addition, the policy memorandum added a new code to track terrorism-

related hoaxes that had not been previously tracked under the old 

classification system.[Footnote 14] In an August 7, 2002, policy memo, 

EOUSA added a new code to track terrorist financing,[Footnote 15] 

updated its guidance for classifying international and domestic 

terrorism cases,[Footnote 16] and provided additional procedures 

regarding how USAOs are to report terrorism-related cases.[Footnote 17] 

In addition, the August 7, 2002, policy memo, instructed the various 

USAOs to retroactively review the classification of cases opened or 

closed during fiscal year 2002 to ensure that all cases related to or 

involving terrorism-related activities were coded in LIONS and that the 

most appropriate terrorism-related or antiterrorism-related criminal 

program category code were used. This resulted in the reclassification 

of convictions in USAO cases.



The new policy introduced changes to EOUSA’s classification system. 

According to EOUSA officials, under the previous system cases were 

classified based on the lead charge for which a defendant was indicted 

or convicted. For example, if the lead conviction charge was money 

laundering, the primary classification of the case would have been 

classified as money laundering, even if terrorism-related purposes were 

also evident during the investigation. Under the new system, a case of 

this nature would result in the case being classified as a terrorism-

related conviction. The new case classification system accounts for 

evidence that the crime was committed for terrorism-related purposes, 

as does the FBI’s classification system.



DOJ Lacks Internal Controls to Ensure Reliability of EOUSA Terrorism-

Related Statistics:



Federal internal control standards require agencies to implement 

adequate controls over information processing. A variety of control 

activities may be used in information processing such as edit checks of 

data entered into information systems, reconciliation of summary 

information to verify data completeness, and management review of 

output reports.[Footnote 18] However, during the course of our 

engagement, we discovered that DOJ does not have sufficient management 

oversight and internal controls in place to ensure the accuracy and 

reliability of terrorism-related conviction statistics included in its 

annual performance reports.



We found that DOJ lacks a formal system, as required by federal 

internal control standards, to verify the accuracy or oversee the 

reliability of case data entered in LIONS by the various USAO districts 

and subsequently included in DOJ’s annual performance reports. 

Specifically, as table 2 shows, the various USAO districts originally 

classified 288 convictions as terrorism-related for fiscal year 2002. 

However, our subsequent request that EOUSA follow-up with all USAO 

districts reporting four or more domestic or international terrorism-

related convictions to validate the accuracy of the districts’ 

reclassification efforts revealed that at least 132 of the 288 (about 

46 percent) USAO convictions were misclassified. These 132 cases did 

not result in terrorism-related convictions. 127 of the 132 were 

subsequently reclassified as anti-terrorism-related 

convictions.[Footnote 19] The remaining 5 were reclassified as related 

to other types of crimes. These discrepancies occurred despite a 

semiannual effort by EOUSA requiring managers in the various USAO 

districts to certify the accuracy of case data.



Table 2: Misclassification of Fiscal Year 2002 Terrorism-Related 

Convictions Reported by Various USAOs:



Type of terrorism-related conviction: International terrorism; Number 

of USAO convictions originally reported as terrorism-related prior to 

EOUSA validation efforts: 174; Number of USAO terrorism-related 

convictions after EOUSA validation efforts[A]: 43; Percentage change: -

75%.



Type of terrorism-related conviction: Domestic terrorism; Number of 

USAO convictions originally reported as terrorism-related prior to 

EOUSA validation efforts: 92; Number of USAO terrorism-related 

convictions after EOUSA validation efforts[A]: 85; Percentage change: -

8%.



Type of terrorism-related conviction: Terrorism-related hoaxes; Number 

of USAO convictions originally reported as terrorism-related prior to 

EOUSA validation efforts: 22; Number of USAO terrorism-related 

convictions after EOUSA validation efforts[A]: 28; Percentage change: 

27%.



Type of terrorism-related conviction: Terrorist financing; Number of 

USAO convictions originally reported as terrorism-related prior to 

EOUSA validation efforts: 0; Number of USAO terrorism-related 

convictions after EOUSA validation efforts[A]: 0; Percentage change: 

0%.



Type of terrorism-related conviction: Total; Number of USAO convictions 

originally reported as terrorism-related prior to EOUSA validation 

efforts: 288; Number of USAO terrorism-related convictions after EOUSA 

validation efforts[A]: 156[B]; Percentage change: -46%.



[End of table]



Source: GAO generated based on EOUSA data.



[A] As previously noted, at our request, EOUSA followed-up with a 

sample of the USAO districts to validate the accuracy of their fiscal 

year 2002 terrorism-related convictions.



[B] The overall accuracy of the classification of these remaining cases 

is questionable because EOUSA’s validation efforts were limited to 

those USAO districts reporting four or more international or domestic 

terrorism-related convictions.



EOUSA officials attributed the discrepancies we found with the fiscal 

year 2002 statistics to limited time afforded the various USAOs to 

thoroughly reevaluate caseload and investigative data during their 

efforts to retroactively reclassify and identify convictions in closed 

terrorism-related cases dating back to the beginning of the fiscal 

year. Because EOUSA did not validate the accuracy of the terrorism-

related conviction data reported by the remaining USAO districts, we 

have some concerns about the overall accuracy of EOUSA conviction 

statistics to be included in DOJ’s Fiscal Year 2002 Annual Performance 

Report.



Conclusions:



Efforts on the part of EOUSA to implement new procedures to better 

ensure that DOJ prosecutors fully account for their efforts to combat 

terrorism-related activities are commendable. However, because the 

Congress and the American public rely on DOJ, in accordance with the 

Government Performance and Results Act, to provide annual performance 

data on the progress of its efforts to combat terrorism, it is equally 

important that the various USAOs accurately account for their efforts 

and not misclassify cases as terrorism-related that are not terrorism-

related. Without reliable terrorism-related conviction data, DOJ and 

the Congress’s ability to accurately assess terrorism-related 

performance outcomes of our criminal justice system and the results of 

efforts to combat terrorism will be limited. Discrepancies discovered 

in the accuracy of fiscal year 2002 terrorism-related conviction 

statistics that the USAO districts had initially provided to EOUSA 

raise concerns about the overall quality and reliability of EOUSA 

terrorism-related conviction statistics. In addition, these 

discrepancies identify the need for improvements in management 

oversight and internal controls to better ensure the accuracy of USAO 

terrorism-related performance data.



Recommendation for Executive Action:



To improve the accuracy and reliability of terrorism-related conviction 

statistics reported by DOJ in its annual performance reports, we 

recommend that the Attorney General, in accordance with federal 

internal control standards, implement a formal system to oversee and 

validate the accuracy of case classification and conviction data 

entered in LIONS by the various USAO districts. This system should 

entail edit checks of data entered into information systems, 

reconciliation of summary information to verify data completeness, and 

management review of output reports.



Agency Comments and Our Evaluation:



We provided copies of this report to the Attorney General and the 

Director of the FBI. DOJ and the FBI agreed with the report findings 

and DOJ agreed to implement our recommendation.



Unless you publicly announce the contents of this report earlier, we 

plan no further distribution until 30 days from the issuance date. At 

that time, we will send copies of this report to the Attorney General, 

the Director of the FBI, and other interested parties. We will also 

make copies available to others upon request. In addition, the report 

will be available at no charge on the GAO Web site at http://

www.gao.gov.



If you or your staff have any questions about this report, please 

contact Charles Michael Johnson or me at (202) 512-8777 or at 

johnsoncm@gao.gov or ekstrandl@gao.gov. Key contributors to this report 

are acknowledged in appendix III.



Sincerely yours,



Laurie E. Ekstrand

Director, Justice Issues:

Signed by Laurie E. Ekstrand:



[End of section]



Appendix I: Summaries of Selected Statutory Terrorism Definitions:



U.S. Code Citation: 8 U.S.C. 1182(a)(3)(B)(iii),(iv); Terrorism 

Definition: Generally defines ‘’terrorist activity’’ as an unlawful 

activity, undertaken with the intent to endanger the safety of one or 

more individuals or to cause substantial damage to property, which 

involves the hijacking or sabotaging of any conveyance; hostage-taking; 

violent attacks upon internationally protected persons; 

assassinations; the use of weapons or dangerous devices, including 

explosives, firearms, biological, chemical, or nuclear weapons; or a 

threat, attempt, or conspiracy to do any of the foregoing. The statute 

further defines the term “engage in terrorist activity”--conduct that 

can render an alien inadmissible to the United States. The term 

encompasses not only the commission of terrorist activities, but a 

broad range of conduct in support of terrorist activities, generally 

involving such things as preparation or planning; gathering information 

on potential targets; soliciting funds or members, or affording 

material support..



U.S. Code Citation: 18 U.S.C. 2331(1),(5); Terrorism Definition: 

Generally defines terrorism as unlawful acts that are dangerous to 

human life and that appear intended to intimidate or coerce a civilian 

population; to influence the policy of a government by intimidation or 

coercion; or to affect the conduct of a government by mass destruction, 

assassination, or kidnapping. Terrorism may be domestic or 

international under 18 U.S.C. 2331 depending on whether the crime 

occurred primarily outside or within the territorial jurisdiction of 

the United States, or whether the crime transcended national boundaries 

in certain respects defined by the statute.[A].



U.S. Code Citation: 18 U.S.C. 2332b(g)(5); Terrorism Definition: Lists 

numerous offenses in defining the term “Federal crime of terrorism” 

where the offense was calculated to influence or affect the conduct of 

government by intimidation or coercion or to retaliate against 

government conduct.[B].



U.S. Code Citation: 22 U.S.C. 2656f(d); Terrorism Definition: Defines 

“terrorism” for purposes of the State Department’s annual country 

reports as premeditated, politically motivated violence perpetrated 

against noncombatant targets by subnational groups or clandestine 

agents. Further defines “international terrorism” as terrorism 

involving citizens or the territory of more than one country..



U.S. Code Citation: 22 U.S.C. 2708(j); Terrorism Definition: Defines an 

“act of international terrorism” for purposes of the State Department’s 

rewards program as any act substantially contributing to the 

acquisition of unsafeguarded special nuclear material or any nuclear 

explosive device by individuals, groups, or non-nuclear weapon states, 

or any act that materially supports the conduct of international 

terrorism, including the counterfeiting of U.S. currency or the illegal 

use of other monetary instruments..



[End of table]



Source: GAO summary of U.S. Code provisions.



[A] The terrorism definitions at 18 U.S.C. 2331 are used for the 

Attorney General’s rewards program for information concerning terrorist 

acts. See 18 U.S.C. 3071(a), 3077(1). In addition, U.S. nationals 

injured by an act of international terrorism have a civil cause of 

action under 18 U.S.C. 2333.



[B] The Attorney General has primary investigative responsibility for 

“Federal crimes of terrorism.” 18 U.S.C. 2332b(f). In addition, the 

federal Sentencing Guidelines provide for a sentence enhancement if the 

offense involved, or was intended to promote, a federal crime of 

terrorism. U.S. Sentencing Guidelines Manual, Sec. 3A1.4 (2001).



[End of section]



Appendix II: Summary of Case Files GAO Reviewed:



The following table provides a summary of Federal Bureau of 

Investigation (FBI) field office case files we reviewed for 28 

convictions to determine whether documentation existed to support the 

FBI’s classification of these cases.



Table 3: 



FBI Field office: Baltimore, Md.; FBI case classification: Domestic 

terrorism; Type of case: State/local; Summary of case: The case 

involved a man who made repeated bomb threats against, among other 

things, a federal building and a courthouse in Maryland. During these 

telephoned threats, the defendant referred to himself as a “terrorist.” 

Note: Based on FBI guidance, all bomb threats in which a case is opened 

are classified as terrorism-related.; No. of defendants: 1; No. of 

convictions cited in case files: 1.



FBI case classification: FBI Field office: Domestic terrorism; Type of 

case: FBI Field office: State/local; Summary of case: FBI Field office: 

The case involved a man who was a self-proclaimed neo Nazi with a 

violent history. He was alleged to be stockpiling firearms and 

explosives at his home in preparation for starting his own militia 

group.; No. of defendants: FBI Field office: 1; No. of convictions 

cited in case files: FBI Field office: 2.



FBI case classification: FBI Field officeDallas, Tex.: Domestic 

terrorism; Type of case: FBI Field officeDallas, Tex.: State/local; 

Summary of case: FBI Field officeDallas, Tex.: The case involved a 

group of anti-military activists who broke into an Air National Guard 

facility and intentionally damaged U.S. Air Force aircraft in promotion 

of their antimilitary beliefs.; No. of defendants: FBI Field 

officeDallas, Tex.: 4; No. of convictions cited in case files: FBI 

Field officeDallas, Tex.: 4.



FBI Field office: Dallas, Tex.; FBI case classification: Domestic 

terrorism; Type of case: State/local; Summary of case: This case 

involved threats to bomb a public school in an attempt to stop an 

Scholastic Aptitude Test. This incident took place in May 1995, 1 month 

after the Oklahoma City bombing.; No. of defendants: 1; No. of 

convictions cited in case files: 1.



FBI case classification: FBI Field office: Domestic terrorism; Type of 

case: FBI Field office: Federal; Summary of case: FBI Field office: 

This case involved a paroled felon with a history of violent crime. 

While on parole, the defendant was arrested for possession of firearms 

and ammunition, as well as for conspiring to commit armed robbery to 

raise money for a suspected hate group.; No. of defendants: FBI Field 

office: 2; No. of convictions cited in case files: FBI Field office: 2.



FBI case classification: FBI Field office: Domestic terrorism; Type of 

case: FBI Field office: Federal; Summary of case: FBI Field office: 

This case involved a man who threatened to blow up a federal building 

by filling up his recreational vehicle with explosives and parking it 

in front of the federal building. His vehicle was found to contain no 

explosives.; No. of defendants: FBI Field office: 1; No. of convictions 

cited in case files: FBI Field office: 1.



FBI case classification: FBI Field office: Domestic terrorism; Type of 

case: FBI Field office: Federal; Summary of case: FBI Field office: The 

defendant in this case was found to have mailed a vial labeled as 

anthrax and to have placed another vial labeled as anthrax in a public 

area.; No. of defendants: FBI Field office: 1; No. of convictions cited 

in case files: FBI Field office: 2.



FBI case classification: FBI Field office: International terrorism; 

Type of case: FBI Field office: Federal; Summary of case: FBI Field 

office: This case involved a joint FBI and Immigration and 

Naturalization Service task force in which the defendant was arrested 

for harboring an illegal alien. During the investigation, the FBI 

uncovered evidence (i.e., telephone records and wire transfers) linking 

the defendant to a known associate of Usama bin Laden who was connected 

to the U.S. Embassy bombings in Kenya and Tanzania.; No. of defendants: 

FBI Field office: 1; No. of convictions cited in case files: FBI Field 

office: 1.



FBI case classification: FBI Field office: International terrorism; 

Type of case: FBI Field office: Federal; Summary of case: FBI Field 

office: This case involved a man who was deported from the United 

States in 1997 for counterfeiting, but who had returned to the United 

States and owned and operated convenience stores in Texas. The FBI 

investigated him for laundering money, using stolen and fraudulent 

credit cards, and shipping generators to a Middle Eastern country, in 

violation of a U.S. embargo.; No. of defendants: FBI Field office: 1; 

No. of convictions cited in case files: FBI Field office: 1.



FBI case classification: FBI Field officeWashington, D.C.: 

International terrorism; Type of case: FBI Field officeWashington, 

D.C.: Federal; Summary of case: FBI Field officeWashington, D.C.: The 

case involved two brothers who were arrested in a joint FBI/Bureau of 

Alcohol, Tobacco and Firearms operation in which the men were 

attempting to purchase automatic weapons and deal guns without a 

license. During the investigation, FBI agents learned that the men were 

originally from India and were associated with a violent Sikh faction.; 

No. of defendants: FBI Field officeWashington, D.C.: 2; No. of 

convictions cited in case files: FBI Field officeWashington, D.C.: 2.



FBI Field office: Washington, D.C.; FBI case classification: 

International terrorism; Type of case: Federal; Summary of case: This 

case involved a foreign national and his son who had attempted to enter 

an agreement with a Middle Eastern country to build an electrical power 

plant in violation of a U.S. embargo on doing business with this 

country. The State Department had designated this country as a sponsor 

of terrorism.; No. of defendants: 1; No. of convictions cited in case 

files: 1.



FBI case classification: FBI Field officeMiami, Fla.: Domestic 

terrorism; Type of case: FBI Field officeMiami, Fla.: State/local; 

Summary of case: FBI Field officeMiami, Fla.: In this case, a juvenile 

made a threat to bomb FBI headquarters in Washington, D.C.; No. of 

defendants: FBI Field officeMiami, Fla.: 1; No. of convictions cited in 

case files: FBI Field officeMiami, Fla.: 1.



FBI Field office: Miami, Fla.; FBI case classification: International 

terrorism; Type of case: Federal; Summary of case: Four defendants were 

investigated for purchasing and shipping dozens of weapons from various 

U.S. locations to the United Kingdom and Northern Ireland. The weapons 

were purchased at various gun shows, shops and from individual person. 

The defendants were citizens of the United Kingdom and the Republic of 

Ireland, and one of the defendants had claimed membership in the Irish 

Republican Army. Among other items found by investigators, was 

literature on the Irish Republican Army. The Anti-terrorist branch of 

New Scotland Yard opened this investigation and contacted the FBI.; No. 

of defendants: 4; No. of convictions cited in case files: 4.



FBI Field office: Philadelphia, Pa.; FBI case classification: Domestic 

terrorism; Type of case: Federal; Summary of case: This case involved a 

defendant that made bomb threats against a federal government facility 

in New Jersey. FBI agents found that the defendant had made a pipe 

bomb.; No. of defendants: 1; No. of convictions cited in case files: 1.



FBI case classification: FBI Field office: Domestic terrorism; Type of 

case: FBI Field office: Federal; Summary of case: FBI Field office: 

This case involved a man who made a biological bomb threat against a 

U.S. courthouse in Pennsylvania. A Joint Terrorism Task Force 

investigated this case.; No. of defendants: FBI Field office: 1; No. of 

convictions cited in case files: FBI Field office: 1.



FBI case classification: FBI Field officeSan Francisco, Calif.: 

Domestic terrorism; Type of case: FBI Field officeSan Francisco, 

Calif.: Federal; Summary of case: FBI Field officeSan Francisco, 

Calif.: This case involved a man who mailed letters including the 

words, “Anthrax, Anthrax, Anthrax” to his former place of employment.; 

No. of defendants: FBI Field officeSan Francisco, Calif.: 1; No. of 

convictions cited in case files: FBI Field officeSan Francisco, Calif.: 

1.



FBI Field office: San Francisco, Calif.; FBI case classification: 

Domestic terrorism; Type of case: Federal; Summary of case: This case 

involved a defendant who fired 20 shots to the Pacific Gas and Electric 

power substation in Redwood City. His actions eliminated power in the 

immediate area and caused over $500,000 in damage. The suspect was 

described as a possible terrorist member and to have protested the 

Oklahoma City trial.; No. of defendants: 1; No. of convictions cited in 

case files: 1.



FBI Field office: Seattle, Wash.; FBI case classification: Domestic 

terrorism; Type of case: Federal; Summary of case: This case involved a 

defendant who made death threats against a U.S. Magistrate Judge and 

two other individuals. The defendant belonged to a group that refers to 

themselves as Cypherfunks who advocate the overthrow of established 

governments via crypto-anarchy.; No. of defendants: 1; No. of 

convictions cited in case files: 1.



FBI Field office: Total; FBI case classification: [Empty]; Type of 

case: [Empty]; Summary of case: [Empty]; No. of defendants: 26; No. of 

convictions cited in case files: 28.



[End of table]



Source: GAO generated based on review of FBI investigative case files.



[End of section]



Appendix III: GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Laurie E. Ekstrand (202) 512-2758

Charles Michael Johnson (202) 512-7331:



Acknowledgments:



Chan My J. Battcher, Christopher Conrad, Christine F. Davis,

Michele Fejfar, Melissa Hinton, Anne E. Laffoon, and Kay Muse made key 

contributions to this report.



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FOOTNOTES



[1] P.L. 103-62 (Aug. 3, 1993).



[2] EOUSA is the executive office representing the 94 USAOs that 

prosecute federal cases. Among other things, EOUSA provides guidance, 

management direction, and oversight to USAOs, including policies and 

procedures for classifying cases.



[3] We selected these offices because they were located in regions near 

our assigned staff. Also, DOJ’s Fiscal Year 2000 Performance Report 

highlighted by the Philadelphia Inquirer article covered these fiscal 

years.



[4] TRAC is a data gathering, research and distribution organization 

associated with Syracuse University. Among other things, TRAC data 

include information about federal enforcement activities. We reviewed 

these data because the Philadelphia Inquirer used this information as 

part of its review.



[5] 28 C.F.R. 0.85(l).



[6] Id.



[7] Id.



[8] As previously noted, during the course of our work, we found 

discrepancies that raise some concerns about the accuracy of EOUSA’s 

fiscal year 2002 figure.



[9] LIONS is the automated case tracking system used by the various 

USAO districts and EOUSA to manage and track caseload data. It is also 

the system EOUSA relies on in deriving annual performance statistics 

for its fiscal year performance reports.



[10] At our request, EOUSA followed up with USAO districts reporting 

four or more domestic or international terrorism-related convictions to 

validate and test the accuracy of conviction data reported for fiscal 

year 2002.



[11] As discussed in more detail later in this report, EOUSA issued an 

August 7, 2002, memo instructing the various USAO districts to, among 

other things, retroactively ensure that all terrorism and antiterrorism 

matters were opened in LIONS and that they review all terrorism and 

antiterrorism matters and cases closed during fiscal year 2002 to 

ensure that the most appropriate terrorism-related or antiterrorism-

related criminal program category code(s) had been entered into LIONS.



[12] See 28 C.F.R. 0.85(l).



[13] The FBI’s Manual of Administrative Operations and Procedures 

outlines the procedures that FBI agents are to use when reclassifying a 

case, including obtaining Squad Supervisor and Assistant Special Agent 

in Charge approval. In addition, according to FBI officials, to ensure 

the accuracy and completeness of all case files, supervisory agents are 

required to complete a file review every 30 to 90 days. Additionally, 

FBI case files are subject to periodic reviews by the agency’s 

Inspection Division.



[14] EOUSA generally defines terrorism-related hoaxes as cases where 

someone knowingly and falsely reports information concerning conduct 

which if true would constitute a threatened or actual terrorist act.



[15] EOUSA generally defines terrorist financing to include federal 

criminal violations committed with the intention of providing material 

support to terrorists or concealing the provision of such support.



[16] Under the new classification policy, domestic and international 

terrorism cases involve violent or dangerous acts, including threats or 

conspiracies to engage in such acts, if the crime was undertaken with a 

terrorist motive; such crimes may include, but are not limited to, the 

list of “federal crimes of terrorism” in 18 U.S.C. 2332b(g)(5). The 

difference between the domestic and international terrorism 

classifications depends on whether the crime was transnational in 

nature, as discussed in the guidance.



[17] In the August 2002 policy memo, EOUSA also added seven 

antiterrorism codes to track any matter or case where the underlying 

purpose or object of the investigation is anti-terrorism, even where 

the offense is not obviously a federal crime of terrorism that would be 

coded under one of EOUSA’s terrorism-related classification codes. 

Anti-terrorism statistics are not included in the fiscal year 2002 

EOUSA terrorism-related convictions statistics included in this report.



[18] U.S. General Accounting Office, Standards for Internal Control in 

the Federal Government, GAO-00-21.3.1 (Washington, D.C.: Nov. 1999).



[19] EOUSA policy guidance described antiterrorism conviction cases as 

those resulting from efforts on the part of DOJ to prevent or disrupt a 

potential or actual terrorist threat even where the offense is not 

obviously a federal crime of terrorism that would be coded under one of 

EOUSA’s terrorism-related classification codes. For example, the 

conviction of a defendant arrested and subsequently convicted for 

identify fraud during a sweep of an airport, as part of a DOJ effort to 

prevent or disrupt terrorist activity, would be counted as an 

antiterrorism conviction.



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exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability 

of the federal government for the American people. GAO examines the use 

of public funds; evaluates federal programs and policies; and provides 

analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

integrity, and reliability.



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expanding archive of older products. The Web site features a search 

engine to help you locate documents using key words and phrases. You 

can print these documents in their entirety, including charts and other 

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20548: