The Drug Enforcement Administration's International Operations (Redacted)

Audit Report 07-19
February 2007
Office of the Inspector General

Chapter 5: Administrative Functions

Our review included an evaluation of certain administrative functions for the DEA’s international operations in selected foreign offices, including an assessment of the DEA’s administration of its imprest funds and its practices and records related to security and firearms. We found deficiencies in these areas, which we believe were caused by weak management oversight and poor adherence to established rules and procedures.

Imprest Funds

Imprest funds are fixed or petty-cash funds held in the form of currency and coins that are advanced to designated cashiers, who in turn advance the funds to employees for mission-related expenses. Agencies use imprest funds to make a variety of payments to many types of recipients, including reimbursing employees for investigative expenses, for making small purchases and limited emergency non-investigative payments, [SENSITIVE INFORMATION REDACTED]. According to records at DEA headquarters, the total amount of imprest funds held by the DEA’s foreign offices amounts to $2,786,000.53 Additionally, the DEA offices in Thailand maintained imprest funds in Thailand’s national currency.54 Therefore, the total amount of imprest funds in the DEA foreign offices was approximately $3.18 million.

Eight of the 10 foreign offices we visited had imprest funds.55 We reviewed imprest funds for seven of these eight offices, which were accountable for nearly $1 million dollars.56 A breakdown for each office is shown in the following table:

DEA Imprest Fund Levels at Sites Reviewed

Ankara, Turkey

$ 65,000

Bangkok, Thailand57


Bogotá, Colombia


Cartagena, Colombia


Guadalajara, Mexico


Istanbul, Turkey


Mexico City, Mexico



$ 963,000

Source: Drug Enforcement Administration

In addition to its own imprest fund policies and procedures, the DEA must abide by imprest fund regulations established by the Department of Treasury (Treasury Department) and the State Department. These regulations include Chapter 8 of the DEA Financial Management and Policy Handbook, the Treasury Department’s Manual of Procedures and Instructions for Cashiers, as well as the State Department’s Financial Affairs Manual, Volume 4, and its Financial Management Procedures Handbook.

During our fieldwork, we interviewed imprest fund cashiers about their responsibilities, observed a count of the respective offices’ imprest fund, and tested a sample of transactions.

Imprest Fund Cash Counts

At seven DEA offices, we observed a cash count of the office’s imprest fund that was conducted by the principal cashier, alternate cashier, or acting supervisor who handled the funds and performed the actual count.58 All of the cash, expenditure documents, and reimbursement checks equaled the total authorized amount of the imprest fund allotted to each office, except for the DEA office in Bangkok.

While in Bangkok, we observed imprest fund cash counts on two separate occasions. On one occasion, the cashier discovered a $1 overage in the U.S. fund. On another occasion, the cashier found that the Thai Baht fund was short 24,000 Baht, an equivalent of $600 USD.59 As a result, we asked the cashier to review the imprest fund accounting ledgers and relevant documents to ensure that all transactions had been posted and that everything had been calculated correctly, and we invited the cashier’s immediate supervisor to count the funds. More than 2 hours later, after multiple viewings of the count conducted by the cashier and the cashier’s supervisor, the cashier found the missing Thai Baht outside the cash box within the safe that houses the imprest funds.

DEA Audits of Imprest Funds

DEA imprest funds are required to have quarterly unannounced audits and an annual audit of the primary and alternate imprest funds as well as an audit whenever a change in cashier duties occurs. These audits must be performed by individuals not associated with imprest fund activities, including supervisors of the imprest fund cashier. We tested the audits for FYs 2005 and 2006 for the locations we reviewed with imprest funds. We found that in Mexico City, Mexico, the DEA did not always conduct audits of the alternate imprest fund, and the DEA office in Bogotá, Colombia, omitted an audit of the primary imprest fund for one of the quarters we reviewed. Further, we found quarterly audits were occasionally performed by persons having supervisory responsibility over the imprest fund.

Imprest Fund Transactions Reviewed

We selected and reviewed a judgmental sample of FYs 2005 and 2006 imprest fund transactions at the seven foreign offices. We selected a sample of 233 transactions out of a universe of 3,266. We reviewed the supporting documentation to determine if the transactions were allowable, supported, properly classified, and accurately recorded. We also determined if imprest fund advances [SENSITIVE INFORMATION REDACTED] were cleared within authorized time limits. Finally, we determined if the imprest payments were made only to DEA employees (not others such as Foreign Service Nationals) as required by DEA’s Financial Management and Policy Handbook.

Based on our testing, we identified numerous discrepancies relating to a lack of supporting documentation, timeliness of clearing cash advances and returning flashroll monies, missing signatures, and funds issued to improper recipients.60 The following table displays for each location the number of transactions in our universe and testing sample, as well as the type and number of discrepancies noted during our testing.

DEA Foreign Imprest Fund Transactions Tested
Type and Number of Exceptions Found

Ankara Bangkok Bogotá Cartagena Guadalajara Istanbul Mexico City TOTALS

Transaction Universe









Transaction Sample









Insufficient supporting documentation









Receipts for advances not cleared timely









Missing signatures









Funds issued to improper recipients61









Flashroll not returned timely62


















Source: OIG analysis of DEA imprest funds’ transaction documentation

In our opinion, the weaknesses we identified occurred due to weak management oversight in the field and poor adherence to established protocols. The DEA has established policies and procedures that if adhered to should provide adequate controls over most imprest fund operations and sufficient documentation to support individual transactions. In addition, DEA headquarters has established a system of auditing DEA field office imprest funds and addressing identified deficiencies with the appropriate offices on a quarterly basis.

Operational Accounts

In locations without imprest funds, the DEA allows Special Agents to maintain reimbursable accounts called operational advances to be used for [SENSITIVE INFORMATION REDACTED] and for small, appropriate office expenses. The two DEA offices in Italy supplied each of three agents – one in Milan and two in Rome – with $3,000 operational advance accounts. According to the DEA Financial Management and Policy Handbook, agents must obtain approval from a supervisor before expending funds from an operational account. We selected a sample of 14 transactions in total from these three accounts. We found no evidence that the agents obtained the required authorization to incur the expense for 10 of the 14 transactions sampled.

Security Matters

The DEA foreign offices are physically located in U.S. Embassies, Consulates, or stand-alone locations. In these offices, the security of space, equipment, documentation, and intelligence is vitally important to the protection of the DEA’s personnel and operations. The DEA is responsible for abiding by all location-specific policies, including those promulgated by the State Department’s Chief of Mission. Within an Embassy or Consulate, the Regional Security Officer (RSO) administers and manages the U.S. diplomatic mission security programs that include protection of personnel, facilities, sensitive information, and U.S. citizens working or visiting the region.

We interviewed the RSO for each location we visited about the respective DEA office’s security practices. Additionally, we interviewed DEA employees assigned the collateral duty of “security officer” for DEA foreign offices in which we conducted fieldwork.64 While on-site, we also conducted observational walk-throughs of DEA work space, observed office and personnel security practices, reviewed secure safe and door combination-change records, and examined firearms storage practices. We identified certain deficient security practices in each of these areas.

Controlled Access Areas

The DEA offices we visited were either located entirely or partially in a controlled access area (CAA), or had access to a portion of CAA space. CAAs are specifically designated areas within a building where classified information may be handled, stored, discussed, or processed. DEA offices we visited in Mexico (Mexico City), Colombia (Bogotá and Cartagena), Thailand (Bangkok), and Turkey (Istanbul) were completely located in CAA space. Conversely, DEA offices in Italy (Milan and Rome), Mexico (Guadalajara and Mazatlán), and Turkey (Ankara) had a designated CAA within the office or in an area outside the office for working with classified information.

The State Department’s Foreign Affairs Manual states that the use of cellular phones is prohibited in CAA space. Our review noted no security violations regarding cellular phone usage in CAA space, except in the DEA offices in Mexico City, Mexico, and Bogotá, Colombia.

According to the RSO in Mexico City, on one occasion a security sweep identified 30 cellular phones in the DEA’s CAA space. The RSO also stated that DEA personnel were seen talking on cellular phones in the CAA on several other occasions. During our fieldwork in Mexico City, we observed several personnel who were in possession of their cellular phones within the CAA space, and in one instance we witnessed a DEA employee using a cellular phone in the CAA. In Bogotá, on at least one occasion we observed a DEA employee carrying a cellular phone within the office’s CAA.

We were told that the Deputy Chief of Mission spoke to the Mexico City Regional Director around May 2005 about the DEA’s increasing number of security violations identified during periodic RSO security checks. As a result, DEA management in Mexico City reminded all personnel of proper security procedures and implemented a nightly security checklist protocol for the office. This checklist was designed to verify that all documents and material were appropriately secured at the end of each day. The Deputy Chief of Mission and the RSO told us that the number of security violations decreased significantly following the implementation of the end-of-day security checklist.65

In the other offices we visited, the RSOs did not indicate concern over DEA CAA security, and we did not observe violations of security protocol.

Safe and Door Combination Locks

The DEA utilizes combination safes and door locks to guard its CAA areas that contain items such as sensitive documents, firearms, and imprest fund cash. The DOJ Security Program Operating Manual and the DEA Planning and Inspections Manual require that combinations be changed when the equipment is placed into initial use, whenever a person knowing the combination no longer requires access to it, and whenever a combination has been subject to possible compromise. The State Department’s Foreign Affairs Manual requires that the RSO change combinations at least every 12 months. In addition, good internal controls require that the DEA ensure that its space and information are properly secured, which includes assuring combinations are changed appropriately.

For 8 of the 10 DEA foreign offices in which we conducted fieldwork, we examined whether: (1) safe and door combinations were changed at least every 12 months, and (2) the DEA maintained an accurate inventory of the safes and secure door locks within its workspace, including current combinations.66 We also attempted to verify the DEA’s records against the RSO’s inventory records of door and safe combinations.

Our review at these DEA foreign offices revealed that the DEA was not adequately securing its offices in Mexico and Colombia because combinations were not tracked and changed as required. In Mexico City, the DEA provided an inventory showing the office maintained 78 safe and door combination locks. However, we conducted a count of combination locks with DEA personnel and found that there were only 54 combination locks in the DEA Mexico City office. Additionally, the DEA office in Cartagena, Colombia, provided an inventory list noting 20 safe and door combination locks were located within DEA space. However, our physical count revealed that two locks (on two separate safes) were missing from the inventory.

When records allowed us to test combination change dates, we identified a significant number of instances in which the DEA had not changed combinations in over 12 months. The following table details our testing and related findings in this area.

Number of Overdue Combination Changes
in DEA Foreign Offices

Location Over 12 Months
Since Combination
Last Changed















Mexico City












Source:   OIG analysis of Drug Enforcement Administration combination lock change practices

Our analysis of the Istanbul records showed that the combination to the lock on the DEA’s office entry door had not been changed since 2003. In our analysis of 52 combination change cards in Mexico City, we found that 42 of them had not been changed in over 12 months. The only centralized combination records available in Bogotá were maintained by the RSO, and our analysis of these records revealed that combinations had not been changed in the past year for 87 of 89 locks.

Although the State Department has the responsibility for changing the combinations of safes and door locks, the DEA must ensure the security of its space and information. Therefore, we believe the DEA should confirm that combinations are changed in accordance with all applicable regulations. To do so, DEA offices must have a reliable inventory of secure devices requiring combination changes. The DEA does not currently require such records. We recommend the DEA establish a policy for its foreign offices to maintain a complete and accurate record of its safe and door lock combinations, including the dates each combination was last changed.

Safe Security Observations

In the DEA offices in Mexico City and Bogotá, we observed DEA personnel leaving safes open and unattended. For instance, a DEA alternate imprest fund cashier in Mexico City kept $5,000 in imprest fund cash in a safe next to his desk, and we observed this safe open and unattended on two separate occasions. In the DEA Bogotá office, we viewed multiple safes unlocked with the drawers open while the responsible DEA personnel could not be located in the office area. Our discussions with DEA personnel and observations of safe contents indicated that safes contained sensitive information, and at times an agent’s weapon.

Although these safes were located in CAA space, we observed non-DEA personnel frequently entering the DEA office. We believe that DEA personnel in these offices need to be more diligent and follow security protocols more closely. Additionally, any safe holding weapons or imprest fund cash should be secured at all times when not in direct use.

Firearms Security, Safety, and Storage

The DEA Agents Manual states that all Special Agents assigned to DEA foreign offices should follow DEA policy unless modified by host-country or Chief of Mission policy. The manual further states that, when unattended, each firearm must be made safe and inoperable by one or more of the following methods: (1) remove and separate the source of ammunition, (2) install an issued gun safety lock, or (3) place the weapon in a commercially available lock box. We did not observe any exceptions to DEA or Chief of Mission policies for storage of weapons in our visits to [SENSITIVE INFORMATION REDACTED], but we did find minor violations in the other countries we visited.

For example, the Chief of Mission protocol for the U.S. Embassy in Bangkok, Thailand, stated that all weapons should be cleared using a proper clearing tube. However, we observed an agent clearing his weapon in a safe near his desk before presenting the firearm for our inspection.

Firearms Qualification

According to the DEA Agents Manual, all Special Agents (except those assigned to headquarters staff positions) must qualify semi-annually with their DEA‑issued handguns and any approved personally owned handguns they seek to have authorization to carry. In foreign offices, the DEA general firearms policy is modified, if necessary, to conform with the requirements of the host-country law or policy and Chief of Mission policy. DEA regulations further state that if there are no appropriate firearms facilities nearby, then the employee, when on official continental U.S. assignment (e.g., home leave or temporary duty assignment), should make arrangements to qualify at the nearest DEA office or at the DEA Training Academy facility in Quantico, Virginia.

Additionally, the DEA Agents Manual states that the original record of qualification should be maintained in a file within the office to which the agent is assigned. Primary firearms instructors are responsible for maintaining records of qualification in each agent’s file, which should follow the agent from post to post. Our initial review of DEA firearms files in foreign offices revealed that a number of files were not presently maintained in the respective DEA foreign office, as required. Additionally, several files available for review were incomplete while other files showed that many agents had not certified their weapons proficiency in over a year.

We also contacted the DEA Training Division and requested firearms qualification information for all agents assigned to a foreign office. The listing provided to us on February 3, 2006, contained information for 379 employees, including the dates each agent last qualified. We compared this list to our sample of field personnel and found that 10 of the 122 sampled employees were not on the list provided by the Training Division. As a result of the incomplete state of firearms records for DEA foreign personnel, we were unable to complete our testing in this area. Further, we identified the following three conditions related to weapons qualifications that pose serious liability risks to the DEA foreign offices.

DEA policy states that agents are exempt from firearms qualification requirements while stationed at a foreign post in the event host-country or U.S. Mission policies prevent compliance with the regulations, or if there is a lack of training facilities. However, the overall state of the firearms qualification for DEA personnel stationed in foreign offices, including the general poor documentation at the DEA Training Division and in the DEA foreign offices we visited, evidenced the lack of emphasis that the DEA placed on firearms proficiency for its personnel located overseas. The DEA informed us at the audit close-out meeting that it recognized a need for improvement in this area and planned to better enforce its policy requiring employees to qualify when on official or personal travel in the United States, including any approved home leave. However, we believe that this requirement still allows for the possibility of agents not certifying proficiency on a weapon issued in a foreign office if they are not required to travel to the United States on an operational matter and choose to spend their home leave outside the United States. We suggest the DEA explore other alternatives and develop procedures to address this policy gap. Also, we encourage the DEA to consider requiring agents to qualify on the same make and model of the weapon they will be issued by their foreign office before being allowed to report to their foreign post, especially for those agents reporting to a country that does not have a firearms testing facility compliant with DEA qualification standards.

Foreign Service Nationals

We noted in certain DEA offices that foreign service nationals (FSN) were allowed to carry weapons while on official duty for the DEA.68 The DEA offices in [SENSITIVE INFORMATION REDACTED] employed FSNs as Investigative Assistants. [SENSITIVE INFORMATION REDACTED].

An FSN [SENSITIVE INFORMATION REDACTED] informed us that he practiced firing his weapon at a local law enforcement firing range, but that the DEA did not test him for proficiency or maintain a qualification file for him. [SENSITIVE INFORMATION REDACTED], an FSN who carried a weapon while on duty with the DEA informed us that the agency tested his weapons proficiency, but did not maintain a record of his scores.

FSNs have been issued DEA-owned weapons and at least one has been carrying a weapon with the DEA’s tacit consent for more than 20 years. Allowing an FSN to carry a weapon without determining whether the individual is proficient could represent a significant liability for the agency. The DEA stated that it recognized the same vulnerability, which prompted the agency to develop a policy addressing FSNs carrying firearms during official DEA duty. The DEA promulgated this policy in July 2006, and we were provided this policy subsequent to our audit close-out meeting. Our review of the policy identified the same gap as identified in our review of the DEA firearms qualification policy for agents stationed in foreign countries. Specifically, the policy allows for an FSN stationed in a country without a DEA-approved firearms facility to be exempt from qualification standards.

Additionally, we followed up with the DEA regarding how the policy applied specifically to FSNs carrying personally owned firearms during official duty, as was the situation [SENSITIVE INFORMATION REDACTED]. The DEA responded that FSNs are prohibited from carrying personally owned firearms while on official DEA duty. Moreover, the DEA also stated that the intent of the policy was for firearms and ammunition to only be issued to FSNs on a day‑to‑day basis, unless the Regional Director specifically approves an exemption and allows the FSN to carry the DEA-issued weapon on a 24-hour basis. We believe the DEA should review its policy and ensure that this temporary authorization element and the prohibition of carrying personally owned firearms are addressed in the agency’s FSN firearms policy.

Administrative Cost Determinations

The State Department initiated the Interagency Consolidated Administrative Support Services (ICASS) program in October 1997 to provide and share the cost of common administrative support functions at U.S. government posts abroad. Examples of the services provided through ICASS are vehicle maintenance, travel services, mail and messenger services, information management, purchasing and contracting, non-residential security guard services, and building operations. Some services are mandatory and most are voluntary. Agencies, for the most part, are able to choose the services in which their office will participate.

For FY 2005, the ICASS Service Center reported that the DEA contributed approximately $17.5 million for ICASS administrative services. The following table shows the FY 2005 final ICASS costs for the DEA in the five countries that we visited.

Fiscal Year 2005 ICASS Costs for
DEA Offices in Countries Reviewed

Country ICASS Cost




$ 762,111








$ 4,000,955

Source: State Department ICASS Service Center

During our fieldwork, we discussed with DEA foreign office managers their use and consideration of ICASS and whether they thought it was the best method for procuring goods and services. In addition, DEA foreign office managers evaluated ICASS services in their annual review of administrative office needs. In some cases, the DEA determined that it was more cost effective to go outside ICASS for certain services. For instance, the DEA office in Bogotá, Colombia, does not participate in the Embassy’s motor pool because DEA management determined that it is more cost-effective to perform this function internally. Additionally, regional management in Rome, Italy, and Ankara, Turkey, informed us that they do not utilize ICASS for vehicle maintenance, as a better cost and quality of service can be obtained through local vendors.


During our review of DEA foreign offices, we found that the agency needed to improve certain aspects of its cash management, recordkeeping, and security. For instance, we found 165 deficiencies in our testing of 233 imprest fund transactions.69 Valued at over $3 million, the DEA’s foreign office imprest funds represent a significant amount of money that is at increased risk for loss if established procedures are not followed.

Additionally, DEA foreign offices in Mexico (Mexico City) and Colombia (Bogotá and Cartagena) could not provide complete and accurate records for safe and door combination-locks. We also observed DEA personnel in Mexico City talking on cellular phones within CAA space, a violation of U.S. Embassy security policy.

Of particular concern is that DEA Special Agents could arrive in foreign offices and be issued a weapon for which they had never qualified. In addition, our review of FSNs hired as Investigative Assistants revealed that the agency allowed FSNs to carry weapons but never certified their proficiency in firing the weapons. The DEA has recently promulgated policy addressing FSNs carrying firearms on official DEA duty, but we believe this policy needs refinement and clarification. Inadequate weapons certification for DEA employees, combined with generally poor evidence of weapons qualification practices for employees in foreign offices, present liabilities to the DEA and to the safety of its agents that we believe should be remedied.


We recommend that the Drug Enforcement Administration:

  1. Re-emphasize to DEA foreign managers and personnel that:

    1. audits of imprest funds should be performed and documented according to regulations, and

    2. it is important to maintain adequate supporting documentation, clear advances of funds in a timely manner or obtain and document extensions, count flashroll monies when returned to a cashier, ensure all required signatures are obtained, and limit payments to eligible recipients of imprest funds.

  2. Re-emphasize to agents with operational advances the importance of receiving authorization from a supervisor before expending funds from these accounts and retaining documentation of this approval for their records.

  3. Ensure all DEA personnel understand and adhere to proper security protocols in foreign offices by:

    1. reiterating to foreign offices the DEA and State Department policies on proper cell phone practices and the proper care of safes, and

    2. immediately changing safe and door combinations that have not been changed in the last 12 months and ensuring that all safe and door combinations are changed and recorded at least annually.

  4. Direct firearms coordinators to forward employee files for those who are no longer at post to their next post of duty or the Firearms Training Unit, and instruct foreign field offices to make current the firearms qualification files for their personnel and to provide notice to headquarters when completed.

  5. Revise the firearms qualification policy to address the situation where a DEA agent is located in a country without an available firearms testing facility that is compliant with DEA qualification standards and who does not officially or personally travel to the United States during a foreign post tenure.

  6. Determine why 10 of 122 sampled DEA Special Agents who were carrying firearms in foreign countries were not on the DEA Training Division’s centralized list of foreign DEA personnel certified to carry a weapon, and update the Training Division’s database accordingly.

  7. Refine its FSNs firearms policy, including:

    1. addressing the possibility of FSNs that are unable to certify weapons proficiency because there is no available firearms testing facility compliant with DEA qualification standards, and

    2. clarifying that FSNs are prohibited from carrying personal firearms during official DEA duty and that FSNs are to be issued weapons and ammunition on a day-to-day basis unless specifically authorized by the Regional Director to carry a DEA-issued firearm on a permanent basis.

  1. The DEA determines the dollar amount of each imprest fund in each office by reassessing annually the amount of investigative expenses used by an office.

  2. These funds valued at $394,000 are advanced by the State Department and are identified in the State Department’s general ledger.

  3. The Milan and Rome, Italy, offices did not have imprest funds.

  4. We were unable to fully review the imprest fund in Mazatlán, Mexico, because the imprest fund cashier was not in the office at the time of our fieldwork and DEA regulations prohibit other employees from accessing the fund in the absence of the designated cashier.

  5. We also found 2 deficiencies related to the untimely return of flashrolls, which were not included in our 233 transaction sample.

  6. A principal cashier is the primary cashier who has been designated and authorized to advance cash and carry out the cash operations, and who is personally liable for any loss or shortage of funds. An alternate cashier disburses funds during short absences of the primary cashier.

  7. The U.S. Dollar equivalent was calculated using the State Department’s constant exchange rate for this imprest fund of 40.00 Baht to the U.S. Dollar.

  8. A flashroll is a temporary advance issued to a Special Agent during the course of an investigation and used as “show money” to procure evidence.

  9. The DEA’s Financial Management and Policy Handbook states that imprest funds should only be issued to DEA employees. DEA headquarters personnel stated that FSNs were not considered eligible recipients of imprest fund cash. Following our audit close-out meeting the DEA stated that it was currently revising its policy to explicitly prohibit FSNs from receiving cash from the imprest fund. Our testing included the identification of imprest fund disbursements issued to non-DEA employees, including FSNs.

  10. In addition to the two incidents in Bangkok in which the flashroll was not returned timely, the cashier was not counting the currency upon return of the flashroll bags. The DEA’s Financial Management and Policy Handbook states that cashiers should verify the amount of cash in the flashroll when it is returned. Our transaction sample did not include any flashroll advances for the remaining offices. The transaction universe and transaction sample noted in the table do not include the flashroll transactions we tested in Bangkok.

  11. For some transactions tested we identified multiple deficiencies. Therefore, a single transaction may have more than one deficiency noted in the table.

  12. The DEA security officer is responsible for ensuring the DEA foreign office follows DEA security regulations, as well as Chief of Mission policies. The Chief of Mission is the title given to the principal U.S. government representative to a country, usually the U.S. Ambassador.

  13. However, our review of the completed checklists covering a 4‑week period revealed a weakness with the security checks. A primary purpose of the checklists was to document the final security review of the day after all employees had left for the night. We observed that some checklists clearly indicated that DEA personnel were still in the office when the checklist was being completed. Therefore, the individual performing the security sweep could not confirm that all safes and doors were locked and computers were turned off. DEA management in Mexico City agreed with our assessment and provided evidence that it instructed its staff immediately following our visit on the proper practices regarding security sweep duties.

  14. We did not conduct testing of safe and door lock inventories and combination change dates in Guadalajara and Mazatlán, Mexico.

  15. Two additional agents were stationed in Italy at the time of our fieldwork in April 2006. However, these individuals had recently arrived and had not yet received host-country approval to carry their weapons.

  16. The DEA stated that FSNs may carry firearms only if it complies with host nation law and only after being authorized by the host nation government.

  17. We also found 2 deficiencies related to the untimely return of flashrolls, which were not included in our 233 transaction sample.

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