Objectives

The primary objectives of this audit of the DEA’s international operations were to:

• review the DEA’s foreign office performance, including its efforts to track operational activity and its internal mechanisms for evaluating the performance of its foreign operations;

• examine the DEA’s involvement and management of international investigative activity;

• assess the DEA’s relationships with its law enforcement counterparts abroad, including its liaison associations and the exchange of information;

• analyze the DEA’s processes and controls over foreign administrative functions, including those related to security, firearms, property management, and fiscal matters; and

• review the training provided or coordinated by the DEA to its foreign counterparts and DEA personnel stationed abroad.

Scope and Methodology

We performed our audit in accordance with the Government Auditing Standards, and included such tests of the records and procedures that we considered necessary to accomplish the objectives of the audit. Generally, the scope of our review focused on the period between FY 2000 and July 2006, although our testing and inquiry extended beyond this period in certain instances. We performed testing of the DEA’s compliance with certain internal controls in the accomplishment of our audit objectives and include discussion on such in the finding and recommendation sections of our report. The objectives of our audit did not require that we perform testing of the DEA’s compliance with laws and regulations.

We conducted work at DEA headquarters and other U.S. government agency headquarters, and we judgmentally selected five countries in which the DEA operated to perform fieldwork at its foreign offices. Our methodology involved selecting locations that would provide a broad overall perspective of the DEA’s international operations, including diverse geographic location, jurisdiction, operational activity, and personnel composition. We visited the 10 DEA foreign offices (noted with boxed text) on the following map.

DEA Foreign Regions and Locations of OIG Fieldwork

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To accomplish our objectives we interviewed DEA personnel at its headquarters, foreign offices, and selected domestic field divisions. We also interviewed other U.S. government agency officials stationed in the United States and abroad, and met with law enforcement personnel from foreign government agencies who work with the DEA internationally. Additionally, we performed tests of administration of its imprest funds, management of its Sensitive Investigative Unit (SIU) Program, and adherence to security and firearms protocols. Our audit also involved the review of DEA documents, policies, and procedures, as well as analyses of empirical DEA data.

Interviews

Our review included interviews with officials from various U.S. and foreign government agencies. These discussions and the documents obtained during these interviews provided perspective on the DEA’s activity abroad. In total, we conducted interviews with 417 persons during this review.

Domestically, we met with 106 DEA officials at its headquarters in Arlington, Virginia; at the DEA Training Academy in Quantico, Virginia; the Special Operations Division in Chantilly, Virginia; and the El Paso Intelligence Center in El Paso, Texas. Our interviews included the Chief of Operations and chiefs for other DEA headquarters components, including the Office of International Programs, the Office of Enforcement Operations, and the Office of Management Operations, as well as numerous other managers and staff. We also interviewed 17 DEA personnel at the domestic field divisions in Chicago, Illinois; El Paso, Texas; and Washington, D.C. Our audit included interviews with 42 headquarters representatives from other U.S. government agencies. Appendix V contains a complete listing of the components with which we met during our review.

During our fieldwork at the 10 DEA foreign offices, we interviewed 114 DEA personnel. We also met with 107 representatives from other U.S. agencies stationed overseas, as well as 31 officials from foreign counterpart agencies with which the DEA works. The table in Appendix V lists the agencies contacted at each fieldwork location.

Data Analysis

We obtained and analyzed available DEA data related to its foreign operational activity. This included information from its systems that track activity on priority targets and investigative resource utilization. The information we obtained and reviewed covered the period of FY 2000 through July 14, 2006.⁷⁴

Testing

At the DEA foreign offices in which we conducted fieldwork, we performed tests related to the DEA’s SIU Program, its imprest funds, its security over space and information, and its practices for storing firearms and recording weapons proficiency qualifications.

SIU Program Testing – The DEA operated SIUs in three of the five countries in which we conducted fieldwork: Mexico, Colombia, and Thailand. In these countries, the DEA provided us with a listing of active SIU members. We judgmentally selected a sample of 106 SIU members: 32 in Mexico, 44 in Colombia, and 30 in Thailand. We attempted to verify dates of vetting procedures for each of the sample SIU members, including background checks, polygraph examinations, and urinalysis tests. As stated in the report, records of these security screening mechanisms were inadequate and impacted the comprehensiveness of our review.

Imprest Fund Testing – The DEA maintained imprest funds in 8 of the 10 foreign offices that we reviewed. We did not perform testing at one of these offices (Mazatlán, Mexico) because the imprest fund cashier was not present during our fieldwork in this location. The seven locations in which we did perform testing are noted in the table below. At these offices, we observed counts of imprest funds and alternate imprest funds.

Additionally, we selected a sample of transactions testing for compliance with applicable DEA, Treasury, and State Department guidelines for administering imprest funds in DEA foreign offices. We limited our testing to transactions occurring in FYs 2005 and 2006. Our methodology for selecting the sample for each fund tested included: (1) determining the total transaction universe for our testing period, and (2) generally selecting 10 percent, or a maximum of 50 transactions, of the total transactions for testing. One-half of our sample included the highest dollar transactions during our testing period and the remaining half was judgmentally selected from those transactions remaining. We selected additional transactions for testing where we deemed it appropriate.

Testing of DEA Imprest Funds⁷⁵

Location	Universe of Transactions	Sample Size
Ankara, Turkey	87	11
Bangkok, Thailand	694	50
Bogotá, Colombia	1,051	50
Cartagena, Colombia	939	58
Guadalajara, Mexico	189	29
Istanbul, Turkey	85	10
Mexico City, Mexico	221	25
Total	3,266	233

Source: OIG review and testing of imprest funds

Operational Accounts Testing – The DEA offices in Italy (Rome and Milan) did not maintain imprest funds. In its place, agents were authorized to use official reimbursable accounts, or operational advances. Three agents in Italy (one in Milan and two in Rome) had operational advances of $3,000 each. We reviewed the ledgers for these accounts and selected a sample of transactions for testing. In Rome, the universe consisted of a total of 34 transactions for both accounts. We selected 10 transactions for our testing, choosing the 5 highest dollar transactions, and judgmentally selecting the other 5. The operational advance in Milan had only four transactions and we tested all of them. We used the DEA’s Financial Management and Policy Handbook, Chapter 8, “Operational Advances” section for our testing criteria. Primarily, we tested transactions to verify proper use of funds, appropriate and timely authorization for expenditures, and accurate reimbursement.

Security Testing – In 8 of the 10 DEA foreign offices that we visited, we conducted testing of DEA’s compliance with established protocol for changing safe and door lock combinations. At each location, with DEA personnel, we conducted a physical count of the number of safe and door combination locks within DEA space. Where the availability of records allowed, we verified the DEA and State Department inventories of DEA safe and door combination locks that matched our physical count of such for each office, and we reviewed the last date of combination changes indicated on combination change forms.

Additionally, we conducted observational security sweeps of DEA CAAs, and noted exceptions to DEA and State Department security protocols.

74. Because we have no recommendations related to the results of our data analysis, we did not test the reliability of these information systems.

75. The total number of transactions includes FYs 2005 and 2006 primary cashier and alternate cashier imprest fund transactions.