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entitled 'Defense Exports: Reporting on Exported Articles and Services 
Needs to Be Improved' which was released on September 21, 2010. 

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Report to the Committee on Foreign Affairs, House of Representatives: 

United States Government Accountability Office: 
GAO: 

September 2010: 

Defense Exports: 

Reporting on Exported Articles and Services Needs to Be Improved: 

GAO-10-952: 

GAO Highlights: 

Highlights of GAO-10-952, a report to the Committee on Foreign 
Affairs, House of Representatives. 

Why GAO Did This Study: 

The U.S. government exports billions of dollars of defense articles 
and services annually to foreign entities, generally through direct 
commercial sales (DCS) from U.S. companies under licenses issued by 
the State Department (State) or through the Department of Defense 
(DOD) Foreign Military Sales (FMS) program. GAO has previously 
reported on weaknesses in the export control system. As requested, GAO 
(1) identified the magnitude and nature of defense articles and 
services exported and (2) assessed information currently reported on 
defense exports and any gaps and limitations in defense export data. 
To conduct this work, GAO analyzed export data from DOD for FMS and 
the Department of Commerce’s U.S. Census Bureau (Census) for DCS for 
2005 through 2009; reviewed relevant laws and regulations; assessed 
State and DOD reports on defense exports; reviewed agency data systems 
documentation; and interviewed officials from State, DOD, Homeland 
Security, and Census. 

What GAO Found: 

U.S. exports of defense articles—such as military aircraft, firearms, 
and explosives—ranged from about $19 billion to $22 billion annually 
in calendar years 2005 to 2009. Of these defense articles, about 60 
percent have been exported by companies to foreign entities through 
DCS licenses, while the remaining 40 percent were exported under the 
FMS program. Aircraft and related parts constitute the largest 
category of such exports—about 44 percent—followed by satellites, 
communications, and electronics equipment and their related parts. 
U.S. exports of defense articles were concentrated in a few countries: 
about half went to Japan, the United Kingdom, Israel, South Korea, 
Australia, Egypt, and the United Arab Emirates. Although no data are 
available on the export of defense services—such as technical 
assistance and training—provided through DCS, exports of defense 
services through FMS were stable, accounting for about one-third of 
the value of FMS exports. 

Figure: Exports of Defense Articles through Direct Commercial Sales 
and Foreign Military Sales, Calendar Years 2005 through 2009: 

[Refer to PDF for image: pie-chart] 

FMS: 40.6%: 
2005: $8.17 billion; 
2006: $8.43 billion; 
2007: $8.02 billion; 
2008: $7.38 billion; 
2009: $8.84 billion; 
Total: $40.85 billion. 

DCS: 59.4%; 
2005: $10.60 billion; 
2006: $11.71 billion; 
2007: $12.19 billion; 
2008: $12.05 billion; 
2009: $13.31 billion; 
Total: $59.86 billion. 

Source: GAO analysis of DOD and census data. 

Note: All values in billions adjusted to 2009 constant dollars and may 
not add to total due to rounding. 

[End of figure] 

Congress does not have a complete picture of defense exports under 
current reporting—including which method of export is used more often 
by individual countries or for certain types of items. State—which has 
overall responsibility for regulating defense exports—and DOD, report 
to Congress in response to various requirements. However, their annual 
reports on DCS and FMS exports have several information gaps and 
inconsistencies—in part, because of the differing purposes of the 
agencies’ data systems and different reporting methodologies. For 
example, State does not obtain data from U.S. companies on the export 
of defense services under DCS licenses, although it authorizes several 
billion dollars of such exports annually. State officials noted that 
they do not have an operational requirement to collect such 
information and doing so could be burdensome on exporters. Other 
limitations on defense export data include differences in agencies’ 
item and country categorizations and the inability to separate data on 
some permanent and temporary exports. Further, while State’s report is 
available on its Web site, DOD’s is not. These differences and 
limitations may inhibit congressional oversight and transparency into 
the entirety of U.S. defense exports. 

What GAO Recommends: 

GAO suggests that Congress consider whether it needs specific data on 
exported defense services and is recommending that State publicly 
report consolidated defense export data on DCS and FMS in a consistent 
manner. In the absence of additional direction and resources from 
Congress, State did not agree. GAO believes the recommendation remains 
valid. 

View [hyperlink, http://www.gao.gov/products/GAO-10-952] or key 
components. For more information, contact Belva M. Martin at (202) 512-
4841 or martinb@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

The Majority of U.S. Defense Articles Are Exported through Direct 
Commercial Sales, with About Half Going to Relatively Few Countries: 

Differences in Agencies' Reporting and Data Collection Limit 
Visibility of Defense Exports: 

Conclusions: 

Matter for Congressional Consideration: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of State: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Differences in Agencies' Reporting on Defense Exports: 

Figures: 

Figure 1: Exports of Defense Articles through DCS and FMS, Calendar 
Years 2005 through 2009: 

Figure 2: Value of Exports through FMS and DCS from Calendar Years 
2005 through 2009 by Type of Defense Articles: 

Figure 3: Top Seven Countries for Exports of Defense Articles, 
Calendar Years 2005 through 2009: 

Abbreviations: 

AES: Automated Export System: 

CBP: U.S. Customs and Border Protection: 

DCS: direct commercial sales: 

DDTC: Directorate of Defense Trade Controls: 

DOD: Department of Defense: 

DSCA: Defense Security Cooperation Agency: 

FMS: Foreign Military Sales: 

ITAR: International Traffic in Arms Regulations: 

USML: United States Munitions List: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 21, 2010: 

The Honorable Howard L. Berman: 
Chairman: 
The Honorable Ileana Ros-Lehtinen: 
Ranking Member: 
Committee on Foreign Affairs: 
House of Representatives: 

Each year, the U.S. government exports billions of dollars of defense 
articles and services, such as military aircraft and related parts, 
firearms, explosives, technical assistance, and training, that may 
include critical technologies. The government views the export of 
these articles and services as an integral part of safeguarding U.S. 
national security and furthering U.S. foreign policy objectives. Over 
the last decade, we have reported on weaknesses in the effectiveness 
and efficiency of government programs designed to protect critical 
technologies, which were largely attributable to poor coordination 
among multiple U.S. government agencies, complex interagency 
processes, and a lack of information sharing that together contributed 
to export enforcement challenges. These findings, along with others, 
prompted us to include the U.S. arms export control system as part of 
a high-risk area on ensuring the effective protection of technologies 
critical to U.S. national security interests since 2007.[Footnote 1] 

The Department of State (State) regulates defense exports for 
consistency with national security and foreign policy interests. 
Eligible foreign entities[Footnote 2] can obtain U.S. defense articles 
and services through the Department of Defense (DOD) Foreign Military 
Sales (FMS) program or through direct commercial sales (DCS) from U.S. 
defense companies under export licenses issued by State. 

To ensure that there is an accounting of what defense articles and 
services are actually exported from the United States, you asked us to 
provide information on the scope of U.S. defense exports. 
Specifically, we (1) identified the magnitude and nature of defense 
exports and (2) assessed information currently reported on these 
exports and limitations and any gaps in available defense export data. 

For the purpose of this report, we define "defense exports" as the 
permanent transfer--including shipment or delivery of defense articles 
or provision of defense services--to foreign entities either through 
DOD's FMS program[Footnote 3] or through license provided by State for 
a DCS export. We excluded temporary exports--which leave from and 
return to the United States without changing ownership--and articles 
shipped to U.S. government end users located in foreign countries. To 
identify information on the magnitude and nature of defense exports, 
we analyzed calendar years 2005 through 2009 data from DOD for FMS 
defense articles and services. We also analyzed data for the same 
period from the Department of Commerce's U.S. Census Bureau (Census)--
which maintains data on exports--for DCS of defense articles. 
Currently, no data are collected on the export of defense services 
through DCS. Although our analysis focuses on exports of defense 
articles, we obtained data from State on DCS licenses primarily to 
assess the reliability of Census data. This report does not include 
values for classified defense exports. However, we determined that 
excluding classified data would not materially affect our high-level 
analysis because the values of classified exports are small relative 
to the overall export totals. We assessed the reliability of defense 
export data by performing electronic testing, reviewing system 
documentation, comparing our data to published and other available 
information, and interviewing knowledgeable officials about data 
quality and reliability, and determined that the data were 
sufficiently reliable for the purpose of this review. For trend 
analysis--that is, changes in values over time--we adjusted for the 
effects of inflation by converting values to 2009 constant dollars. 

To compare export data through FMS and DCS, we analyzed the different 
item classification systems used by State, DOD, and Census and 
developed a common classification system enabling analysis of the 
values of defense articles by type of items. We also reviewed relevant 
laws and regulations regarding the export of defense articles and the 
requirements for reporting export information through Census's 
Automated Export System (AES). To identify information currently 
reported on defense exports, we obtained and analyzed the reports 
issued by State's Directorate of Defense Trade Controls (DDTC) and 
DOD's Defense Security Cooperation Agency (DSCA).[Footnote 4] To 
identify any limitations and gaps in the agencies' data collection and 
reporting, we reviewed data systems and related documentation at DDTC, 
DSCA, and Census. We also interviewed officials at these agencies and 
at the Department of Homeland Security's U.S. Customs and Border 
Protection (CBP) on their export data collection processes. 
Information on dual-use items--which can have both commercial and 
military uses and are regulated by the Department of Commerce under a 
separate control list--is outside the scope of this review. For more 
detailed information on our scope and methodology, see appendix I. 

We conducted this performance audit from February 2010 to September 
2010 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. 

Background: 

The Arms Export Control Act[Footnote 5] authorizes the President to 
control the export and import of defense articles and defense 
services. The statutory authority of the President to promulgate 
regulations with respect to exports of defense articles and defense 
services and designate those items to be considered defense articles 
and defense services[Footnote 6] for export control purposes has been 
delegated to the Secretary of State.[Footnote 7] State administers the 
arms export control system through requirements contained in the 
International Traffic in Arms Regulations (ITAR)[Footnote 8] and 
designates the articles and services deemed to be defense articles and 
defense services. These designations are made by State, with the 
concurrence of DOD, and constitute the United States Munitions List 
[Footnote 9] (USML), which comprises 21 major categories--for example 
Aircraft, Spacecraft, Military Electronics, and Guns and Armament--and 
more detailed subcategories. The ITAR also designates defense services 
subject to export controls, including furnishing assistance, technical 
data, or training to foreign entities. As defense exports are part of 
U.S. foreign policy, Congress requires reports to enable its 
oversight, including annual reports under the Foreign Assistance Act 
of 1961, as amended,[Footnote 10] Section 655 on defense exports, 
commonly referred to as Section 655 reports. 

U.S. defense articles and services generally can be exported to 
foreign entities in two ways--by FMS or DCS. Under FMS, the U.S. 
government procures defense articles and services on behalf of the 
foreign entity. Countries approved to participate in this program may 
obtain defense articles and services by paying with their own funds or 
with funds provided through U.S. government-sponsored assistance 
programs. While State has overall regulatory responsibility for the 
FMS program and approves the export of defense articles and services, 
DOD's DSCA directs the execution of the program, and the individual 
military departments implement the sale and export process. DOD bills 
foreign entities and tracks the export of articles and services 
through its financial systems. For FMS, an approved Letter of Offer 
and Acceptance authorizes the export. Under DCS, U.S. companies obtain 
permanent export licenses generally valid for 4 years[Footnote 11] 
from State's DDTC, which authorizes the export of defense articles and 
services directly to foreign entities. State also licenses defense 
articles for temporary export--when the article will be exported for a 
period of less than 4 years and will be returned to the United States 
without transfer of title. 

While most defense articles and services require a license for export, 
the ITAR contains numerous exemptions from licensing requirements that 
have defined conditions and limitations. For both FMS and DCS, the 
actual export of defense articles or services may occur years after 
the authorization--or may not take place at all. 

In addition to State and DOD, other U.S. government entities are 
involved with oversight of defense exports and management of export 
data. CBP oversees exports of defense articles leaving the country for 
compliance with export control laws and regulations and collects 
information on those exports through AES. AES is jointly managed and 
operated by CBP and Census, and the data it collects are used by State 
and other federal agencies. It is the central point through which 
export data required by multiple agencies are filed electronically to 
CBP. Foreign Trade Regulations[Footnote 12] and the ITAR require AES 
filings for all articles on the USML that are sent, taken, or 
transported out of the United States, and the exporter must provide 
either a license number or a citation of the license exemption. The 
data obtained through AES are maintained by Census's Foreign Trade 
Division and CBP for the purpose of developing merchandise trade 
statistics and enforcement of U.S. export control laws, but also are 
provided to State for reporting purposes. 

DCSA information on the FMS program identifies several considerations 
for foreign entities in choosing between FMS and DCS. Under FMS, DOD 
procures defense articles and services for the foreign entity under 
the same acquisition process used for its own military needs, and 
recipients may benefit from economies of scale achieved through 
combining FMS purchases with DOD's. In addition, DOD provides contract 
administration services that may not be available through the private 
sector. To recover its administration costs, DOD applies a surcharge 
to each FMS agreement that is a percentage of the value of each sale. 
Under DCS, foreign entities may have more direct involvement during 
contract negotiation with U.S. defense companies, may obtain firm-
fixed pricing, and may be better able to fulfill nonstandard 
requirements. However, according to State officials, some types of 
defense articles, such as certain types of missiles, can only be 
exported through FMS. 

In addition, DOD administers other programs through which defense 
articles can be exported to foreign governments. For example, the 
fiscal year 2006 National Defense Authorization Act[Footnote 13] 
provides funding authorities for DOD to jointly formulate and 
coordinate with State in the implementation of security assistance 
programs, which can include the export of U.S. defense articles and 
services. DOD also may export certain defense articles deemed "excess" 
to our national security needs to foreign governments or international 
organizations on a reduced or no-cost basis. 

The Majority of U.S. Defense Articles Are Exported through Direct 
Commercial Sales, with About Half Going to Relatively Few Countries: 

From calendar years 2005 through 2008, the value of U.S. exports of 
defense articles remained relatively stable, from about $19 billion 
and $20 billion,[Footnote 14] with an increase to about $22 billion in 
2009. Of the approximately $101 billion total in U.S. defense articles 
exported from 2005 through 2009, about 60 percent were exported 
through DCS, as shown in figure 1. This figure also shows that exports 
through DCS increased from $10.6 billion to $13.3 billion during this 
period--an increase of about 25 percent--while the value of FMS 
exports remained relatively stable. 

Figure 1: Exports of Defense Articles through DCS and FMS, Calendar 
Years 2005 through 2009: 

[Refer to PDF for image: pie-chart] 

FMS: 40.6%: 
2005: $8.17 billion; 
2006: $8.43 billion; 
2007: $8.02 billion; 
2008: $7.38 billion; 
2009: $8.84 billion; 
Total: $40.85 billion. 

DCS: 59.4%; 
2005: $10.60 billion; 
2006: $11.71 billion; 
2007: $12.19 billion; 
2008: $12.05 billion; 
2009: $13.31 billion; 
Total: $59.86 billion. 

Source: GAO analysis of DOD and census data. 

Note: All values are in billions and are adjusted to 2009 constant 
dollars. Values may not add to totals because of rounding. 

[End of figure] 

Although there are currently no data available on the export of 
defense services through DCS, we found that the value of defense 
services exported through FMS was also relatively stable over the last 
5 calendar years, ranging from about $3.8 billion to $4.2 billion 
annually from 2005 through 2009. Overall, services account for about 
one-third of the value of all FMS exports annually. 

Over the last 5 years, aircraft and their related parts and equipment 
accounted for about 44 percent of the value of all defense articles 
exported. The second largest category was satellites, communications, 
and electronics equipment and their related parts--accounting for 
about 20 percent of defense articles. We also found differences in the 
method of export for defense articles, with values for some types of 
articles higher through FMS versus DCS and vice versa. As shown in 
figure 2, of the approximately $26 billion in aircraft equipment and 
parts exported over the 5-year period, almost 66 percent (about $17.2 
billion) was exported through DCS. A much larger value of other 
equipment and parts; satellites, communications and electronics 
equipment, and related parts; and firearms were also exported through 
DCS. On the other hand, a larger value of missiles, ships, and their 
related parts were exported through FMS. For two categories--aircraft 
and vehicles, weapons, and their parts--export values were about 
evenly divided between DCS and FMS. 

Figure 2: Value of Exports through FMS and DCS from Calendar Years 
2005 through 2009 by Type of Defense Articles: 

[Refer to PDF for image: stacked vertical bar graph] 

Commodity: Aircraft Parts & Equipment; 	
DCS: $17.23 billion; 
FMS: $8.96 billion. 

Commodity: Satellites, Communications, Electronics Equipment & Parts; 
DCS: $114.77 billion; 
FMS: $4.58 billion. 

Commodity: Aircraft; 
DCS: $17.72 billion; 
FMS: $8.92 billion. 

Commodity: Vehicles, Weapons & Parts; 
DCS: $15.09 billion; 
FMS: $5.59 billion. 

Commodity: Other Equipment & Parts; 
DCS: $17.48 billion; 
FMS: $3.11 billion. 

Commodity: Missiles & Parts; 
DCS: $12.19 billion; 
FMS: $5.71 billion. 

Commodity: Ammunition, Explosives & Parts	
DCS: $12.11 billion; 
FMS: $1.38 billion. 

Commodity: Firearms; 
DCS: $10.98 billion; 
FMS: $0.16 billion. 

Commodity: Ships & Parts; 
DCS: $10.13 billion; 
FMS: $0.86 billion. 

Source: GAO analysis of DOD and Census data. 

Note: Values are not adjusted for inflation. 

[End of figure] 

Although defense articles and services are exported to hundreds of 
countries, we found that exports of defense articles were highly 
concentrated in a few countries. Over the past 5 years, the top three 
recipient countries--Japan, the United Kingdom, and Israel--accounted 
for almost one-third of the value of defense article exports. The top 
seven recipient countries, which include South Korea, Australia, 
Egypt, and the United Arab Emirates, accounted for about half of the 
value of all U.S. defense article exports.[Footnote 15] We also 
identified differences by the method of export through either FMS or 
DCS. In general, the value of FMS exports was higher for developing 
countries, while the value of DCS exports was higher for 
developed[Footnote 16] countries. State officials noted that 
developing countries may benefit from the FMS logistics, 
infrastructure, and other support that come with the FMS program. As 
shown in figure 3, of the $13 billion in defense articles that Japan 
imported, 85 percent ($11.15 billion) was exported through DCS. 
Similarly, of the $8.3 billion that the United Kingdom imported, 82 
percent (about $6.8 billion) was exported through DCS. On the other 
hand, Israel and Egypt import a higher value of their U.S. defense 
articles through the FMS program. Israel and Egypt receive annual U.S. 
security assistance funding[Footnote 17] that according to DOD and 
State officials, generally is used to purchase U.S. defense articles 
and services through the FMS program. FMS exports of defense services 
were also concentrated in a relatively few countries, with Saudi 
Arabia, Japan, and Egypt accounting for over one-third of the value 
over the last 5 years. 

Figure 3: Top Seven Countries for Exports of Defense Articles, 
Calendar Years 2005 through 2009: 

[Refer to PDF for image: illustrated world map] 

Country: United Kingdom; 
DCS: $6.84 billion; 
FMS: $1.48 billion. 

Country: Egypt; 
DCS: $0.41 billion; 
FMS: $3.66 billion. 

Country: Israel; 
DCS: $2.68 billion; 
FMS: $5.32 billion. 

Country: United Arab Emirates; 
DCS: $3.63 billion; 
FMS: $0.35 billion. 

Country: South Korea; 
DCS: $4.12 billion; 
FMS: $2.41 billion. 

Country: Japan; 
DCS: $11.15 billion; 
FMS: $1.99 billion. 

Country: Australia; 
DCS: $2.15 billion; 
FMS: $2.02 billion. 

Source: GAO analysis of DOD and Census data. 

Note: Values are in billions of dollars and are not adjusted for 
inflation. 

[End of figure] 

Differences in Agencies' Reporting and Data Collection Limit 
Visibility of Defense Exports: 

Although Congress requires reporting on various aspects of U.S. 
defense exports, State's and DOD's annual reports on "military 
assistance and military exports"--as required by Section 655 of the 
Foreign Assistance Act of 1961, as amended--do not provide a complete 
picture of the magnitude and nature of defense exports because the 
agencies use different reporting methodologies and have information 
inconsistencies and gaps--in part, because of the separate purposes of 
their data systems. Although the data we obtained and analyzed were 
sufficiently reliable to develop high-level, overall information on 
the magnitude and nature of defense exports, the differences in 
agencies' data--including the lack of information for defense services 
exported under DCS licenses, differences in agencies' item and country 
categorizations, and the inability to separate some permanent and 
temporary exports--hinder the ability to provide a comprehensive and 
transparent picture of defense exports. Current export reform 
discussions acknowledge that the proliferation of individual data 
systems make export licensing and enforcement more difficult; however, 
the FMS system has not been specifically cited in these proposals. 

Because defense exports are used for furthering U.S. foreign policy 
objectives, there are legislatively mandated reporting requirements to 
enable congressional oversight. State has overall responsibility to 
report on exports of defense articles and defense services. DOD also 
reports on defense exports under FMS and other programs. The most 
comprehensive reporting requirement is contained in Section 655 of the 
Foreign Assistance Act of 1961, as amended, which requires annual 
reporting of defense articles and services that were authorized and 
provided (exported)[Footnote 18] to each foreign country and 
international organization for the previous fiscal year under State 
export license or furnished under FMS, including those furnished with 
the financial assistance of the U.S. government.[Footnote 19] Also, 
for defense articles licensed for export by State, the act requires "a 
specification of those defense articles that were exported during the 
fiscal year covered by the report." There is not a parallel provision 
for a specification of defense services exported under licenses issued 
by State. In addition, the act requires that unclassified portions of 
the report be made public on the Internet through State. Although 
State publishes its Section 655 reports on its Web site, DOD's Section 
655 reports are not available either through DOD's or State's Web 
site. Other reporting requirements are focused on discrete aspects of 
defense exports and, as such, are not intended to provide a complete 
picture of such exports. For example, Section 36 of the Arms Export 
Control Act requires advance notifications to Congress for proposed 
sales based on certain dollar thresholds, as well as reports on 
defense exports sold. DOD also noted numerous additional reporting 
requirements for defense exports that occur under other programs, such 
as Excess Defense Articles and International Military Education and 
Training. 

While State and DOD each provide annual reports to Congress in 
response to the Section 655 requirement, we identified differences in 
the way each agency reports its data--in some cases based on differing 
interpretations of the same requirement--that lead to an incomplete 
overall picture of the magnitude and nature of such exports, as shown 
in table 1. 

Table 1: Differences in Agencies' Reporting on Defense Exports: 

State's Section 655 report: 
Authorized during the fiscal year: 
* Includes values for approved licenses for permanent exports of 
defense articles listed by country and USML category and subcategory; 
- These values include licenses to U.S. government end users located 
in foreign countries; 
* Includes values for approved licenses for export of defense services 
by country and USML category; 
Exported[A] during the fiscal year: 
* Began including export values from AES with the fiscal year 2008 
report, with no export values provided in prior reports; 
* Export values include permanent exports, temporary imports and 
exports, exports exempt from license requirements, and shipments to 
U.S. government end users in foreign countries; 
* Values are listed as a total by country but do not provide a 
specification of articles exported; 
* Values for defense services exported are not included because this 
information is not collected; 
Availability on the Internet:
* Report is available through State's Web site. 

DOD's Section 655 report: 
Authorized during the fiscal year: 
* Does not include values for approved authorizations; 
- DOD officials told us that they interpret the requirement to mean 
those articles exported in the fiscal year because exports must be 
authorized prior to export. They noted that authorizations meeting 
certain criteria are reported separately to Congress under other 
reporting requirements; 
Exported[A] during the fiscal year: 
* Includes values for exports of defense articles and services by 
country and category of items. However, some reported exports are not 
designated as defense articles and services under the USML (e.g., 
fuel, generators, forklifts, and construction); 
* Does not include values for export of defense articles and services 
funded by the U.S. government through non-FMS programs[B]; 
Availability on the Internet: 
* Report is not made available on the Internet through DOD's or 
State's Web sites. 

Source: GAO analysis of State's and DOD's Section 655 reports. 

[A] We use the term "exported" here, while the act uses both 
"provided" and "exported." 

[B] DSCA officials stated that prior to 2009, they were not receiving 
data on exports authorized by Sections 1206 and 1207 of the National 
Defense Authorization Act, but they are now receiving data on these 
exports. 

[End of table] 

The differences in reporting also occur because the data on defense 
exports are gathered and maintained by multiple government agencies 
for a variety of purposes using different data systems. State and DOD 
officials told us that information reported on defense exports is 
based on data that are contained in existing systems developed to 
satisfy the operational requirements of each organization and was not 
designed to integrate with other agencies' systems. For example, 
State's system was designed to manage the DCS licensing process, 
DSCA's system was developed to facilitate the management of the FMS 
program, and data collected in the AES system are maintained by Census 
primarily for generating trade statistics. Nonetheless, these systems 
are the principal sources of information on defense exports. In areas 
where these systems differ from each other, certain data fields need 
to be reconciled before data can be aggregated. Even with these 
adjustments, these and other system differences hinder the ability to 
perform a more detailed and in-depth analysis of defense exports. 

For example, one difference between State's and DOD's reporting is the 
lack of data on defense services exported under DCS licenses. 
According to State's reporting to Congress, for fiscal year 2005, it 
licensed[Footnote 20] over $27 billion in defense services. By fiscal 
year 2008, the most recent data available, the value of approved 
licenses for defense services almost tripled to over $71 billion. 
However, State does not report on the value of defense services 
exported under license authorizations because it does not have such 
information. This is in part because AES does not capture data on the 
export of services to foreign entities as it was developed to track 
information on the export of physical articles. Also, State officials 
noted that they have no operational requirement to have information on 
the value of exported defense services, and they do not require such 
information to be reported to State as it could create an additional 
burden on exporters. Further, these officials noted that they have not 
received feedback from congressional committees on the lack of such 
data in prior reports to Congress and therefore are not planning to 
obtain these data from exporters. In contrast, because DOD bills FMS 
customers for the export of defense services--including logistical 
support, repairs, training, and technical assistance--it tracks data 
on the value of services exported. As noted earlier in this report, 
defense services constitute about one-third of annual FMS exports. 

Further complicating efforts to combine and compare State and DOD data 
reported in the Section 655 reports is that agencies involved in the 
licensing, export, and collection of related data lack a unified item 
categorization scheme. According to agency officials, these item 
categorization schemes were developed for their specific purposes and 
were not designed to integrate with other agencies' data for reporting 
defense exports. In issuing DCS licenses, State uses the categories 
for defense articles and services enumerated on the USML and reports 
license values by USML categories and subcategories. However, when 
exporters file their export information through AES for these licensed 
exports, they include the USML category that provides a high-level 
categorization of articles (e.g., "Aircraft and Associated Equipment") 
but does not allow for the more detailed breakout of articles by 
subcategories, which State uses to report license values. Exporters 
also categorize articles according the Harmonized Tariff Schedule, 
based on the international "Harmonized System," which was developed 
for reporting merchandise trade statistics. The Harmonized System and 
USML are not directly comparable. For example, while the USML has a 
category for "tanks and military vehicles" separate from other 
categories for weapons, the Harmonized System has one combined 
category that includes both weapons and "weaponized" vehicles such as 
tanks and armored vehicles. As a result, a more detailed combined 
analysis of the types of military vehicles is not possible using 
existing category schemes. 

Under the FMS program, DOD reports export values based on information 
used to bill foreign entities using a unique item categorization 
system that also is not directly comparable to the USML. For example, 
the USML has separate categories for explosives, bombs, training 
equipment, and guidance equipment; DOD's single category for "bomb" 
includes items in all of those USML categories. Further, some of the 
articles and services exported through the FMS program, such as fuel 
and construction, are not controlled under the USML. However, since 
DOD bills foreign entities for these articles and services, they are 
included in DOD's reports along with defense articles and services. 
DOD officials noted that there is no requirement to report exports by 
USML categories. 

Defense export data comparisons also are limited because DOD, Census, 
and State define some countries and international organizations 
differently. For example, DOD's FMS data and State export license 
authorizations include exports to international organizations such as 
the United Nations. Exports documented through AES are coded for the 
country of destination and not for international organizations that 
may be located within those countries. Furthermore, each agency's 
system uses different codes for some countries, requiring manual 
analysis to enable combining and comparing of these data. For example, 
the code used for a country in one database may be used for a 
different country in another database, and some country names are 
different. These differences hamper efforts to make comparisons 
between the systems or to combine the databases to analyze like 
exports to countries and international organizations. 

Another difference between State's and DOD's Section 655 reports is 
State's inclusion of U.S. government end users in its data. While all 
exports under FMS are to foreign entities, State reports license 
authorization values for exports that are used by U.S. government 
agencies within the recipient country as well as articles exported for 
use by U.S. and allied forces operating on foreign soil. Because the 
values reported for exports of defense articles include these U.S. 
government end users, the value of such articles exported to foreign 
entities is overstated. 

In addition, obtaining precise data on DCS exports is further limited 
for certain types of exports where permanent and temporary exports are 
grouped together. For example, both temporary and permanent exports of 
classified items are identified under a single export license type. 
For 2005 through 2009, this license type included a total of about $7 
billion in exports, which can include temporary exports. In addition, 
the ITAR provides for a license exemption for some defense articles 
exported to Canada.[Footnote 21] However, the ITAR provides a single 
Canadian exemption that includes both permanent and temporary exports. 
As noted earlier, defense export data for Canada are likely 
understated since the data do not delineate permanent exports from 
temporary ones in the approximately $4.1 billion reported under this 
exemption from 2005 through 2009. 

DOD's reporting of total defense exports is also limited by the lack 
of data on exports of defense articles and services under certain U.S. 
government-funded programs. For example, until recently DSCA did not 
have access to centralized data on defense exports authorized under 
sections 1206 and 1207 of the National Defense Authorization Act for 
Fiscal Year 2006. Such exports are tracked separately from FMS cases-- 
generally by the appropriation that funded the export. In 2009, the 
DSCA system identified a cumulative total for these exports that 
included multiple years with no way to separate the data by the year 
of export. However, DSCA officials told us that they now receive 
monthly updates on these exports and are considering options for 
including these data in future reporting. Furthermore, officials at 
Census, CBP, and DOD told us that reporting through AES for FMS 
exports is not complete, although the U.S. Foreign Trade Regulations 
and the ITAR require AES filings for all USML items exported from the 
United States including those exported through FMS.[Footnote 22] DOD 
officials noted that while AES filing is required, not all DOD 
components fully comply. Census officials stated that they are 
providing outreach and training for DOD components to encourage 
compliance with this requirement. CBP officials noted that reporting 
of FMS exports through AES has improved over the years, and our 
analysis of AES data showed that the value of FMS exports reported in 
AES has increased from 2005 to 2009. 

Under the U.S. export control reform effort currently under way, the 
administration has noted that the myriad of U.S. government agencies 
involved in export controls continue to maintain separate information 
technology systems and databases that are not accessible or easily 
compatible with each other. According to a recent statement by the 
U.S. National Security Advisor,[Footnote 23] this proliferation of 
individual systems makes export licensing and enforcement more 
difficult. In our High-Risk Series, we found weaknesses in the 
effectiveness and efficiency of U.S. government programs that are 
related to the protection of technologies critical to national 
security interests, such as FMS and DCS, and recommended that these 
programs be reexamined to determine how they can collectively achieve 
their missions.[Footnote 24] The U.S. government is currently 
considering consolidating the current export control lists and 
adopting a single multiagency system for licensing with a single 
interface for exporters, ultimately leading to a single enterprisewide 
information technology system that can track an export from the filing 
of a license application until the item leaves a U.S. port. However, 
the administration has not announced plans on how defense articles and 
services authorized and exported under FMS and other government-to- 
government programs will be incorporated into a reformed U.S. export 
control system. 

Conclusions: 

A complete picture of defense exports--including which method of 
export is used more often by individual countries or for certain types 
of items--is not available under current reporting to Congress. 
Although State has overall responsibility to regulate the export of 
defense articles and services, it reports separately from DOD on some 
aspects of defense exports. Information from DOD and State cannot be 
readily combined to provide a complete picture of defense exports. 
Gaps and limitations in these data--including the lack of information 
on defense services exported under DCS, which could be substantial 
given the high dollar value of such services authorized by State--may 
inhibit congressional oversight and transparency into the entirety of 
U.S. defense exports. For example, Congress does not have complete 
data to determine whether specific U.S. foreign policy objectives are 
being furthered through the various export programs. While State has 
noted a potential burden for exporters if they were required to report 
on exports of defense services under DCS, there may be value to 
Congress in having such information, especially in light of the large 
and growing value of license authorizations for defense services. 

As U.S. export control reform efforts move beyond the initial phase of 
revising and consolidating control lists, it will be important to 
consider ways to standardize and integrate data across agencies to 
mitigate the gaps and limitations noted in this report. Recognizing 
that complete integration and standardization across agencies' data 
systems is a long-term effort that may require additional resources, 
State could improve overall reporting of defense exports under the 
constraints of current data systems by using a methodology similar to 
ours to enhance congressional oversight and transparency of such 
exports. Also, as policymakers develop and debate export control 
reform proposals, it is important to consider whether other programs 
related to the protection of technologies critical to U.S. national 
security, such as the FMS program, should be included in the reform 
efforts. 

Matter for Congressional Consideration: 

In order to obtain a more complete picture of defense exports, 
Congress should consider whether it needs specific data on exported 
defense services similar to what it currently receives on defense 
articles and, if so, request that State provide such data as 
appropriate. 

Recommendation for Executive Action: 

To improve transparency and consistency of reporting on defense 
exports required by the Foreign Assistance Act, we recommend that the 
Secretary of State direct the Directorate of Defense Trade Controls to 
coordinate with the Departments of Defense and Commerce to identify 
and obtain relevant defense export information under existing agency 
data systems and provide a consolidated report to Congress on DCS and 
FMS that: 

* specifies articles exported using a common category system; 

* separates U.S. government end users from foreign entities; 

* separates permanent and temporary exports; 

* incorporates all defense exports, including U.S. government-funded 
programs; and: 

* is made public through the Internet. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Departments of State, 
Homeland Security, and Defense and to Census under the Department of 
Commerce for their review and comment. Census and the Department of 
Homeland Security provided technical comments, which we incorporated 
as appropriate, and DOD did not comment on our draft. State provided 
written comments that are reprinted in appendix II. In commenting on 
the draft, State acknowledged the importance of maintaining and 
reporting to Congress and the public reliable data on U.S. defense 
exports through FMS and DCS, and notes that gaps and inconsistencies 
in current reporting are caused by differences in accounting by 
agencies for transfers of defense exports. However, State did not 
agree with our recommendation to report consolidated defense export 
data on FMS and DCS in a consistent manner. State reiterated that 
Congress has not requested any change to the substance of its current 
reporting, and State does not believe that the added resources 
necessary to change reporting formats are merited. However, based on 
our work and analysis of defense export data, we believe that 
congressional oversight and transparency into the entirety of U.S. 
defense exports could be improved with existing data and systems by 
utilizing more consistent reporting methodologies similar to those 
that we developed. State also noted that providing consolidated 
defense export data to Congress and the public was consistent with the 
goals of current export control reform efforts and encouraged Congress 
to provide criteria and the resources to develop appropriate 
information. We agree that ongoing export control reform efforts may 
provide opportunities to improve information and reporting, but 
recognizing that reforms may take years to implement, we believe that 
congressional oversight and transparency can be improved in the short 
term by implementing our recommendation. 

We are sending copies of this report to interested congressional 
committees, the Secretary of State, the Secretary of Defense, the 
Secretary of Commerce, and the Secretary of Homeland Security. This 
report also is available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

If you have questions about this report or need additional 
information, please contact me at (202) 512-4841 or martinb@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report are listed in appendix III. 

Signed by: 

Belva M. Martin: 
Acting Director: 
Acquisition and Sourcing Management: 

[End of section] 

Appendix I: Scope and Methodology: 

To identify information on the magnitude and nature of defense 
exports, we obtained data for calendar years 2005 through 2009 on 
direct commercial sales (DCS) from the U.S. Census Bureau's (Census) 
Automated Export System (AES) and on the Foreign Military Sales (FMS) 
program from the Department of Defense's (DOD) Defense Security 
Cooperation Agency (DSCA). For the purpose of this report, we defined 
"defense exports" as articles permanently exported under a Department 
of State (State) license to foreign end users. As such, we did not 
include temporary exports that return to the United States without 
transfer of ownership, shipments to U.S. government end users as 
identified in AES by the export information code, or articles exported 
under a license exemption. 

* For DCS, we obtained a data extract from Census for AES records for 
this time frame of electronic information filings designated with a 
State "license type," a required field for all exports covered by the 
United States Munitions List (USML). State has several different 
license types that generally identify the nature of the export or 
import, including permanent exports, temporary exports, temporary 
imports, agreements, articles exported with an exemption, or articles 
exported through the FMS program. For FMS data, although Foreign Trade 
Regulations and the International Traffic in Arms Regulations require 
AES filings for all articles on the USML, including those exported via 
FMS, we were told by both U.S. Customs and Border Protection (CBP) and 
Census officials that AES filings for DOD exports of FMS articles are 
not complete. Therefore, we could not use AES as a single data source 
for exports of defense articles. 

* For this reason, we obtained data from DSCA for FMS exports for the 
same time frame from DSCA's 1200 Delivery Subsystem. We did not 
include articles exported under Section 1206 or 1207 programs under 
the National Defense Authorization Act for Fiscal Year 2006. As noted, 
DSCA did not obtain export data on Section 1206 and 1207 exports until 
2009. We also did not include data on DOD's excess defense article 
program. 

* Although most of our analysis focuses on exports of defense 
articles, we obtained data from State on DCS licenses that were in 
effect during 2005 through 2009, primarily for the purpose of 
assessing the reliability of AES data for these exports. 

* For each of these three data sets, we also obtained the relevant 
reference tables and documentation from each agency. These reference 
tables translate the codes used in the databases--such as those for 
country name or commodity/item type--into their names or descriptions. 

* We also reviewed relevant laws and regulations regarding the export 
of defense articles and requirements for reporting export information 
through AES.[Footnote 25] 

In order to combine and compare information from FMS and AES on the 
types of articles exported, we analyzed the item categorization 
systems used by each system to identify areas of commonality. We 
determined that the broad categories used by DOD for grouping like 
items together could be adapted to accommodate the lowest level of 
detail identified between the two systems. This allowed us to develop 
relatively large categories, but precluded us from further refining 
the analysis by breaking these out into more detailed categories 
because some types of items were combined into one category in either 
of the two systems. 

To assess overall defense exports by country, we created a cross- 
reference table to enable us to relate the data for a specific country 
in one data set to information for that same country in the other data 
set. We also identified groupings of countries considered developed or 
developing according to the United Nations' definition. 

We did not include data on classified exports for either FMS or DCS. 
DOD officials stated that classified data on FMS exports could not be 
used in an unclassified report, even if aggregated with other data. We 
obtained and reviewed classified data for FMS and determined that 
excluding the FMS classified data from our analysis would not 
materially affect the high-level trend analysis and other information 
we discuss in this report. For classified DCS exports, temporary and 
permanent exports are grouped together in one license type in AES, 
with no way to separate permanent from temporary exports. 

For trend information across the 5-year time frame, we adjusted for 
the effects of inflation by converting values to 2009 dollars. We 
assessed the reliability of these data by performing electronic 
testing; reviewing system documentation, including system edits and 
validations; comparing our data to published or other available 
information; and interviewing knowledgeable officials about data 
quality and reliability. For the purposes of our analyses, we 
determined that the data were sufficiently reliable. 

To assess information reported on U.S. defense exports, we reviewed 
relevant reporting requirements and reviewed State and DOD reports to 
Congress on various portions of the export process, including 
notification of potential sales, authorizations, and exports. 
Specifically, we reviewed the reporting requirements in the Foreign 
Assistance Act of 1961, as amended, Section 655, on foreign military 
assistance that requires an annual report on both defense articles and 
services authorized and provided/exported to foreign countries and 
international organizations. We then analyzed and compared the 
relevant reports that State and DOD annually submit to Congress, 
identifying differences in reporting methodologies between the 
reports, and identified where such information is available to the 
public. We also interviewed agency officials at State's Directorate of 
Defense Trade Controls (DDTC) and DOD's DSCA responsible for 
generating these reports to obtain information on methodologies and 
definitions used in their respective reports. To identify limitations 
and gaps in available defense export data, we reviewed information and 
available system documentation for the data systems at DSCA, DDTC, and 
Census and interviewed knowledgeable officials at these agencies 
regarding data system purposes and functionality. We also interviewed 
officials at CBP who manage the AES interface with exporters. 

We conducted this performance audit from February 2010 to September 
2010 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of State: 

United States Department of State: 
Chief Financial Officer: 
Washington, D.C. 20520: 

September 14, 2010: 

Ms. Jacquelyn Williams-Bridgers: 
Managing Director: 
International Affairs and Trade: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548-0001: 

Dear Ms. Williams-Bridgers: 

We appreciate the opportunity to review your draft report,
"Defense Exports: Reporting on Exported Articles and Services to Be 
Improved," GAO Job Code 120862. 

The enclosed Department of State comments are provided for 
incorporation with this letter as an appendix to the final report. 

If you have any questions concerning this response, please contact 
Steven Rice, Deputy Director, Bureau of Political-Military Affairs at 
(202) 663-2803. 

Sincerely, 

Signed by: 

Barbara Retzlaff: 

cc: GAO — John Neumann: 
PM — Andrew J. Shapiro: 
State/OIG — Evelyn Klemstine: 

[End of letter] 

Department of State Comments on GAO Draft Report: 

Defense Exports: Reporting on Exported Articles and Services Needs to 
Be Improved (GAO-10-952, GAO Code 120862): 

Thank you for the opportunity to comment on your draft report entitled 
"Defense Exports: Reporting on Exported Articles and Services Needs to 
Be Improved." The Department of State recognizes the importance of 
maintaining and reporting to the Congress and public reliable data on 
United States defense exports through direct commercial sales or the 
Foreign Military Sales program. The draft report identifies gaps and 
inconsistencies in reports of this nature by the Executive Branch. 

However, the State Department notes that gaps and inconsistencies in
reporting are inherent in accounting for transfers of defense export 
across agencies. While Foreign Military sales may, for example, 
include items such as tanks and weaponry on the U.S. Munitions List 
under the jurisdiction of the Department of State, dual-use items 
under the licensing jurisdiction of Commerce will not be included in 
State reports. Likewise, the requirements of the Congress for 
reporting direct commercial sales and Foreign Military Sales are also 
different. 

The Department of State faithfully reports to Congress all data 
pertaining to exported articles and services that are within its 
jurisdiction to collect. To date, the Congress has expressed no desire 
to change the substance of our current reporting. The Department does 
not believe that devising additional reporting formats would merit the 
commitment or allocation of additional resources and therefore 
disagrees with the report's recommendations. 

Providing consolidated defense export data to Congress and the public 
is consistent with the goals of Export Control Reform and the 
Executive Branch task force evaluating proposals and recommendations 
associated with it. As decisions are made on Export Control Reform, 
the Department of State encourages the Congress to furnish criteria 
and resources to develop appropriate information technology platforms 
and reporting criteria of benefit to both the Congress and the public. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Belva M. Martin, (202) 512-4841 or martinb@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, John Neumann, Assistant 
Director; Marie Ahearn; Richard Brown; Sharron Candon; Julia Kennon; 
Roxanna Sun; Robert Swierczek; and Bradley Terry made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January 
2007). 

[2] Eligible foreign entities can include foreign governments, 
corporations, as well as international organizations, all of which are 
defined as foreign persons under 22 C.F.R. § 120.16. In addition, the 
Foreign Military Sales program is limited to eligible countries and 
international organizations. 22 U.S.C. § 2753, and Department of 
Defense, Security Assistance Management Manual, DOD 5105.38-M (Oct. 3, 
2003), C4.2. 

[3] We did not include articles exported under DOD's excess defense 
article program or articles and services exported under sections 1206 
and 1207 of the National Defense Authorization Act for Fiscal Year 
2006. Section 1206 authorized the President to direct the Secretary of 
Defense to build or support the capacity of foreign military forces to 
conduct counterterrorist operations or to support stability and 
military operations in which the United States is a participant. 
Section 1207 authorized the Secretary of Defense to transfer defense 
articles to the Secretary of State to facilitate the reconstruction, 
security, or stability assistance provided to a foreign country. 

[4] The information discussed in this report on the reporting 
requirements does not reflect our independent legal analysis or 
determination of the specific requirements. Rather, it is generally 
descriptive and reflects the differing interpretations, implementation 
of the requirements, or both by State and DOD. 

[5] 22 U.S.C. § 27 51 et seq. 

[6] 22 U.S.C. §§ 2778(a) and 2794(7). 

[7] Exec. Order No. 11,958, 42 Fed. Reg. 4,311 (1997). 

[8] 22 C.F.R. § 120 et seq. 

[9] 22 C.F.R. § 120.2; 22 C.F.R. Part 121. 

[10] 22 U.S.C. § 2415. 

[11] For the export of defense services, State authorizes technical 
assistance agreements, which State officials said are generally valid 
for 10 years. 

[12] 15 C.F.R. § 30.2. 

[13] National Defense Authorization Act for Fiscal Year 2006, Pub. L. 
No. 109-163 §§ 1206 and 1207 (2006). 

[14] In 2009 constant dollars. 

[15] Canada was the eighth largest recipient of U.S. defense articles 
at $3.6 billion exported under FMS and DCS. However, another $4.1 
billion of defense articles was exported to Canada under a license 
exemption, which can include both temporary and permanent exports that 
are not separately delineated in the AES data. Therefore, the value of 
Canada's permanent defense imports from the United States is likely 
understated. 

[16] As defined by the United Nations, Japan in Asia, Canada and the 
United States in northern America, Australia and New Zealand in 
Oceania, and Europe are considered "developed" regions or areas. All 
other regions are considered "developing." 

[17] For example, in fiscal year 2008, Israel and Egypt received about 
$2.4 billion and $1.3 billion, respectively, in Foreign Military 
Financing funds to improve their military capabilities. 

[18] Because authorizations are valid for several years, exports 
during a fiscal year may be based on authorizations from prior years. 

[19] 22 U.S.C. § 2415. 

[20] Services may be exported over the 10-year period covered by the 
license, and the value of services exported may be less than the 
authorized amounts. 

[21] 22 C.F.R. 126.5. 

[22] 30 C.F.R. § 30.2; 22 C.F.R. § 123.22. 

[23] "The Administration's Export Control Reform Plans," remarks by 
General James L. Jones, USMC (Ret), National Security Advisor, at the 
Senate Aerospace Caucus luncheon, June 30, 2010. 

[24] [hyperlink, http://www.gao.gov/products/GAO-07-310]. 

[25] As previously indicated, the information discussed in this report 
on the reporting requirements does not reflect our independent legal 
analysis or determination of the specific requirements. Rather, it is 
generally descriptive and reflects the differing interpretations, 
implementation of the requirements, or both by State and DOD. 

[End of section] 

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