OFFICE OF THE INSPECTOR GENERAL, AUDIT DIVISION
ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO CLOSE REPORT

Recommendation #1:  Promulgate general policy related to nominations to the consolidated terrorist watchlist and the sharing of information among DOJ components that might result in such a nomination, potentially including identifying nomination thresholds and information sharing criteria, and requiring formalization of watchlist nomination and related information sharing activities.

FBI Response:  FBI Concurs:  In collaboration with the Terrorist Screening Center and NCTC, develop uniform standards and protocols for watchlisting.

Recommendation #2:  Modify its written policy to require field office SSAs to review the nomination form for sufficient and accurate information prior to submission of the nomination form to FBI headquarters.

FBI Response:  FBI Concurs:  TREX will draft an Electronic Communication (EC) with updated watchlisting policies and will highlight the roles and responsibilities of field office SSAs. The EC will require that SSAs sign off on all FD-930s before the forms are submitted to TREX. The FBI will have the EC finalized in March 2008.

Recommendation #3:   Determine whether its watchlist processes for both its international terrorist and domestic terrorist nominations could be streamlined to reduce the number of times watchlist information must be manually entered.

FBI Response:  FBI Concurs:  TREX is currently working with NCTC and TSC to streamline the process. The TSC now enters all DT nominations . For FBI IT nominations, like it is for the rest of the watchlisting community, data will be entered into TIDE by NCTC-TIG for export to the TSDB, where it will in turn be exported to VGTOF and the other support systems. An EC describing the new process and outlining the responsibilities of TREX/TSC will be drafted by April 2008.

Recommendation #4:  Improve the policies concerning non-investigative subjects that the FBI nominates to the consolidated terrorist watchlist, including adding a requirement for the modification and removal of non-investigative subjects from the watchlist.

FBI Response:  FBI Concurs:  TREX will work with ITOS I/II, TSC and NCTC to ensure that all non-investigative subjects are nominated, modified, and removed from watchlisting in a consistent manner. An EC will be drafted highlighting the new policy and will be disseminated to all field offices and to Legal Attaché offices in March 2008.

Recommendation #5:  Ensure that all appropriate individuals, including JTTF personnel and veteran FBI agents, receive adequate training related to the FBI’s watchlist nominations process.

FBI Response:  FBI Concurs:  TREX has provided watchlisting training at the annual NJTTF Conference. Further, TREX is currently scheduled to provide training to 18 New Agents Trainee (NAT) classes in FY2008. TREX will also coordinate with NJTTF Unit to develop training curriculum at various regional JTTF conferences. The FBI believes there will be significant progress by May 2008.

Recommendation #6:  Ensure the correct sourcing of watchlist records involving information shared by their agencies and clarify responsibility for keeping these records accurate and up-to-date.

FBI Response:  This is a joint FBI/DEA/USNCB Action Item.
FBI Concurs:  TREX will work with NJTTF, DEA, and USNCB points of contact to develop a Memorandum of Understanding that will clearly outline each agency’s responsibilities for keeping accurate records. The FBI believes there will be significant progress by April 2008.

Recommendation #7:  Reach agreement on sharing terrorism information for use in the consolidated terrorist watchlist, to include what activities would result in terrorism information sharing. Further, ATF should ensure that ATF personnel are trained in how to identify such activities.

FBI Response:  This is a joint FBI/ATF Action Item
FBI Concurs:   TREX will work with NJTTF and ATF points of contact to develop an MOU that will clearly outline how terrorism information for use in the consolidated terrorist watchlist should be used. The FBI believes there will be significant progress by April 2008.