The Naval Postgraduate School & The U.S. Department of Homeland Security

Praise, Problems, and Proposals: Audit Results of the FBI-Managed Terrorist Watchlist 

The Audit of the Federal Bureau of Investigation's Management of Terrorist Watchlist Nominations audit report of March 2014 reviews the impact of the December 25, 2009, failed terrorist attack (commonly known as the Underwear Bomber) and effectiveness of FBI initiatives implemented between 2009 and 2012 and intended to "ensure accuracy, timeliness, and completeness of the FBI's watchlisting practices."

This report finds that the Terrorist Screening Center (TSC) actions following the failed terrorist attack of December 25, 2009 "were not covered by the then-existing watchlist protocol and procedures. Despite [the] shortcomings in the protocol and other technical and procedural issues, […] TSC responded commendably to the attempted terrorist attack." In respect to the individual responsible for the failed December 25 attack, "the federal government possessed all of the information necessary to place the subject on the consolidated terrorist watchlist and prevent him from flying to the United States." Even though this information was readily available, not all databases were searched, leading to a failure to identify, correlate, and decipher all pieces of information. This resulted in TSC being unaware of the individual or his involvement in any actions related to him until after the attack had occurred.

Following the incident, TSC received directions "to include individuals on the [terrorist] watchlist for whom the U.S. government did not possess sufficient information to support inclusion on the watchlist based on pre-existing criteria, but that government officials believed necessary." These inclusions were found to be inadequately documented.

Previous auditors' recommendations have been implemented and make the FBI watchlist more complete, accurate, and current. However, the FBI has unnecessarily restricted terrorism information sharing with the National Counterterrorism Center (NCTC) which results in a hindered ability to manage watchlist nominations.

In summation, the TSC and FBI both have been advised to ensure proper documentation of actions and watchlist persons and to properly divulge information to sister agencies or organizations when the need arises. The recommendations provided in the audit report are meant to increase the efficiency and efficacy of the watchlist when identifying suspects and preventing terrorist acts.