Seized Property Program Strategic Plan
Message from the Deputy Commissioner
U.S. Customs and Border Protection (CBP), an agency within the Department of Homeland Security (DHS), is responsible for managing and securing our Nation’s borders both at and between the ports of entry while facilitating legal trade and travel. To protect America from harm, CBP must detect and remove the goods and people that present a potential risk to security from the legitimate annual flow of over 25 million cargo containers, 100 million conveyances, and 400 million people. As a direct result of CBP’s successful enforcement of United States security and trade laws, America’s frontline removes over 7,000 pounds of narcotics, $180,000 in illicit currency, and $650,000 worth of fraudulent commercial merchandise daily that otherwise would have gained unlawful entry into the United States. The seizure and forfeiture of property terminates and deters threats to national and economic security.
CBP’s Seized Property (SP) Program is the agency-wide program that supports CBP’s law enforcement operations and preserves the deterrent effect of seizures through the secure and effective management of seized and forfeited property. The SP Program supports the components of CBP’s law enforcement offices that are directly responsible for controlling SP and components of CBP’s offices dedicated to supporting law enforcement’s SP activities. CBP also provides substantial SP management and security to other law enforcement agencies, including Immigration and Customs Enforcement (ICE) and other agencies contributing to the Department of Treasury’s U.S. Treasury Forfeiture Fund (TFF). CBP’s SP Program generates substantial revenue for TFF through the sale of forfeited property. The Treasury Executive Office for Asset Forfeiture (TEOAF), in turn, disburses TFF funds to support the law enforcement activities of CBP and other TFF member agencies.
The SP Program is a vital program that is large, growing, and centered on the mission. Therefore, to best direct this program, a coordinated effort of key business partners was initiated to develop a strategic plan. The strategic direction of CBP’s Seized Property Program 2009 – 2013 Strategic Plan is to provide a secure SP process to CBP’s law enforcement offices that alleviates the administrative burden of seizures and promotes performance and financial clarity. This plan presents a vision for the SP Program for the secure and effective management of seized property; characterized by unquestioned SP integrity, assured due process of law, enhanced national security capacity, a maximized self-sufficient financial state, and continuous operational improvement.
We will realize this strategic direction and vision by achieving three goals:
▪ Enhance the Public Trust and Safeguard Investigations – Support legal proceedings with absolute process and chain of custody integrity and robust oversight and quality assurance.
▪ Expand Enforcement Capacity through Proficient SP Program Support – Enhance the agency’s ability to protect America through the provision of highly efficient program administration, harmonized agency-wide efforts, and effective program and financial management.
▪ Increase Funding of SP Enforcement Operations – Achieve an optimal financial state and capitalize on the SP Program's unique revenue and funding opportunities.
The Seized Property Program Strategic Plan is aligned with DHS and CBP strategic direction and complements the Securing America’s Borders at Ports of Entry, Secure Border Initiative, and Resource Allocation strategic plans. We will continue to coordinate and work in close, seamless cooperation across CBP and with other U.S. Government agencies to best support national security and law enforcement.
Jayson P. Ahern
Acting Commissioner, U.S. Customs and Border Protection
Table of Contents
Executive Summary 1
CBP’s Seized Property Program 5
Mission and Vision 8
Goals and Objectives 9
Strategies and Actions 13
Appendix 21
Executive Summary
U.S. Customs and Border Protection (CBP) is America’s frontline, protecting the Nation from threats to our security and preventing terrorists and terrorist weapons from entering the United States. At ports of entry (POEs), the Office of Field Operations (OFO) secures the flow of people and goods into and out of the country, while facilitating legitimate travel and trade. Between POEs, the Office of Border Patrol (OBP) maintains border security over 7,500 expansive miles of land border. The Office of CBP Air and Marine (CBP A&M) uses its integrated air and marine fleets to detect, sort, intercept, track, and apprehend criminals at and beyond the U.S. border.
In fulfilling the agency’s mission, CBP’s law enforcement personnel must regularly exclude illegal or harmful property and illegal immigrants from entry into the United States. Seizure is an effective method of exclusion to terminate the threat posed to America and deter further attempts at unlawful activity. Each day, CBP Officers and Border Patrol Agents, with assistance from CBP Air and Marine (CBP A&M) Interdiction Agents, seize property such as narcotics and prohibited firearms, unsafe food and fraudulent consumer products, and undeclared currency. CBP may also take custody of any conveyance or other property used to attempt circumvention of U.S. laws. Additionally, CBP controls other merchandise on which duties, taxes, and fees are not paid or property that remains unclaimed at POEs, called General Order (GO) merchandise.
To support CBP’s law enforcement operations and preserve the deterrent effect of seizures, CBP must fulfill its compliance responsibility to maintain stringent controls over property that is excluded from entry by CBP when enforcing security, immigration, and customs laws. Operationally, this entails the careful recordation, timely transport, and efficient storage, sale, and disposal of seized property (SP), all while maintaining the security of SP during its lifecycle in CBP’s custody. CBP manages a massive volume of SP annually across OBP, OFO, CBP A&M, and other Government agencies, with an Fiscal Year (FY) 2007 value of approximately $1.4 billion. Securing and managing SP and processing cases are important administrative activities that must be conducted to further enhance the law enforcement benefits that accrue from enforcement seizures.
The agency’s SP Program supports offices that execute these vital tasks for the agency. The SP Program secures and accounts for SP and provides proficient program and administrative support to CBP’s frontline law enforcement personnel. Program members include the components of CBP’s offices dedicated to supporting law enforcement’s SP activities, including OFO’s Fines Penalties and Forfeitures (FP&F) Division, OBP’s Asset Forfeiture Program, the Office of Finance’s (OF) Seized and Forfeited Property Division (SFPD), and representatives from CBP A&M’s budget and operations offices. The Program is not led by any one office, but instead exists as a forum and collaborative framework for organizations that execute similar and often complementary SP functions. The Program supports communication to solve common problems. CBP’s SP Program promotes integration, when feasible and practical, while fostering the development of individual areas of expertise.
The scope and volume of CBP’s SP activities have increased significantly since former components of the U.S. Customs Service, the Border Patrol, and the Immigration Inspector section of the Immigration and Naturalization Service (INS) were combined into CBP as part of the Department of Homeland Security (DHS) in 2003. Additionally, increases in frontline personnel and their effectiveness have produced heightened levels of law enforcement actions, including seizures. Further, due to the agency’s unique position at the border, CBP provides other law enforcement agencies with valuable enforcement operations support, SP handling, secure storage, as well as regulatory and legal expertise.
Controlling harmful, illegal, or otherwise inadmissible property throughout the SP lifecycle is a challenging duty as seizure volumes continue to rise across our expansive country. In this complex environment, the SP Program must secure SP and support geographically disbursed enforcement operations, while operating world-class business practices that minimize security vulnerabilities and maximize efficiency. Examples of key business challenges faced by CBP’s SP Program are: relieving the administrative burden of seizures on frontline enforcement resources, capturing opportunities to minimize inventory costs, and addressing contractor performance issues through strengthened security controls.
To confront these challenges with confidence, CBP has defined the SP Program’s vision:
The intent of the Seized Property Program Strategic Plan is to define a roadmap that guides the organization to fulfill this vision, support CBP’s law enforcement offices engaged in SP activities, and accomplish shared CBP and Treasury aspirations. The development of such a roadmap is not intended to formulate priorities contrary to CBP’s priorities or encroach on the authorities of CBP’s offices.
The strategic direction of CBP’s SP Program is to provide a secure SP process to CBP’s law enforcement offices that alleviates the administrative burden of seizures and promotes performance and financial clarity. Additionally, CBP’s SP Program is dedicated to improving, wherever practical, the consistency and unification of its SP process across the agency to deter non-compliance and increase confidence in the SP Program. Program members are charged with maintaining the public’s trust by executing a process that affords due process and treats seizures and SP with the urgency they deserve as a critical function of CBP’s mission. When this strategic direction is sustained by a strong program support infrastructure, CBP’s SP Program will be brought to the foreground as an effective enabler of national and economic security.
Seized Property Program Strategic Plan aligns with existing plans and provides additional detail regarding high-level program objectives. The execution of this plan will best support CBP’s law enforcement personnel to secure America, maintain the integrity of SP, and capitalize on the SP Program’s unique revenue and funding opportunities. The plan presents three goals:
1. Enhance the Public Trust and Safeguard Investigations
2. Expand Enforcement Capacity through Proficient SP Program Support
3. Increase Funding of SP Enforcement Operations
The SP Program offices, including OBP, OFO, CBP A&M, and OF, are committed to coordinating to achieve these goals, thereby improving overall SP Program effectiveness and expanding Program benefits to all key business partners.
Figure 1 illustrates the strategic framework for CBP’s SP Program Strategic Plan. The mission statement defines the scope of responsibility and the vision describes the desired end-state for the SP Program. The goals reflect the high-level results needed to meet the vision and the objectives establish specific, measurable targets. Strategies serve as the “how to” for this strategic plan, providing concrete actions to achieve the objectives. The core capabilities represent the professional skills, assets, and alliances that the SP Program must succeed at daily to provide proficient support to the agency.
Figure 1 Strategic Framework – SP Program Strategic Plan
CBP’s Seized Property Program
1 Purpose of the SP Program
The SP Program is the agency-wide program that supports CBP’s law enforcement operations through the secure and effective management of SP. Securing and managing SP and processing seizure cases are important administrative activities that must be conducted properly to further enhance the law enforcement benefits that accrue from seizures, including deterrence of future illegal activity and funding of law enforcement operations from the proceeds of illegal activity. The Program’s members are dedicated to delivering a high-quality SP process to the agency’s frontline that promotes CBP’s law enforcement power and maintains SP integrity, while capitalizing on the SP Program’s unique funding and efficiency opportunities.
SP Program members include CBP offices that, as a result of executing their unique border security missions, seize property at the border, control SP while under CBP’s custody, or provide program and administrative support to law enforcement’s SP activities (see Appendix A for a detailed description of Program member roles and key business partners). Program members do not report to the SP Program but instead contribute together to CBP’s overall success with its critical SP duties. Because these offices engage in similar and complementary activities and share priorities, CBP has defined an agency-wide Program that crosses organizational lines to best support the execution of the SP process and to cohesively confront current challenges. The SP Program increases communication and coordination across member offices to achieve greater financial and performance clarity into CBP’s SP operations and to unify agency-wide processes, where suitable. The advancement of this Program as a more formal entity within CBP does not preclude CBP’s offices (or “Program members”) from exercising individual authorities.
Recognizing that ownership over enforcement operations resides with respective CBP offices, and that any operational changes must be approved through designated chains of command, the SP Program is committed to evaluating the agency’s SP activities to verify compliance and improve efficiency. This SP Program Strategic Plan is the cornerstone of the SP Program’s improvement efforts and guides CBP’s SP Integrated Program Team (IPT). The IPT coordinates the SP Program’s improvement efforts by convening Program members and business partners, including the Office of International Trade (OT), TEOAF, and Immigration and Customs Enforcement (ICE), to address priority challenges and shape strategic initiatives. The IPT fosters a consensus-based approach to implementing improvement options by seeking input from across Program members and business partners on SP administrative matters. The Program and IPT will also report to the SP Governance Board comprised of senior level individuals from across the agency to resolve high-level policy, resource, and process concerns.
2 Roles and Responsibilities within the SP Program
|CBP Organization |Overall Organization Role Description |Role Description in Context of Seized Property |
|CBP Enforcement |OFO secures the flow of goods and people into and out of the |Initiate seized property process through enforcement|
|Offices |country while facilitating legitimate trade and travel at U.S. |actions and perform property handling and case |
| |Ports of Entry (POEs). |processing. |
| |OBP secures and maintains operational control over U.S. borders |OFO’s Fines, Penalties, and Forfeitures (FP&F) |
| |between POEs, preventing the entry of terrorists and terrorist |Division represents OFO in the SP Program. |
| |weapons into the United States. |OBP’s Asset Forfeiture Program represents OBP in the|
| |CBP A&M uses integrated air and marine forces to detect and |SP Program. |
| |prevent the unlawful movement of people, illegal drugs, and other|CBP A&M’s Budget and Program Management personnel |
| |contraband toward or across U.S. borders. |represent CBP A&M in the SP Program. |
|OF |Responsible for financial management and accountability, |Perform fiduciary responsibilities and business |
| |including accounting, budget, financial systems, procurement and |functions, including contract management, GO |
| |acquisition, facilities and engineering, asset management, |program, budget, and facilities. |
| |investment management, and oversight of all financial operations |SFPD represents OF in the SP Program and is CBP’s |
| |within CBP. |liaison to TEOAF. |
|Business Partner |Overall Organization Role Description |Role Description in Context of Seized Property |
|Treasury |Serve the American people and strengthen national security by |Collect revenue and disburse funds to member |
| |managing the U.S. Government’s finances effectively, promoting |agencies by managing the TFF and administer the |
| |economic growth and stability, and ensuring the safety, |national seized property storage contract. |
| |soundness, and security of U.S. and international financial | |
| |systems. | |
|ICE |Protect America and uphold public safety by identifying criminal |Formulate cases against people who attempt to enter |
| |activities and eliminating vulnerabilities that pose a threat to |unlawful goods and seize money or materials that |
| |our nation’s borders, as well as enforcing economic, |support criminal activities. |
| |transportation and infrastructure security. | |
|OT |Direct the national trade policy and program functions of CBP and|Develop trade policies and enforcement priorities |
| |provide uniformity and clarity for the development of CBP’s |that result in seizures and analyze trade violations|
| |national strategy to facilitate legitimate trade |and trends to report on CBP outcomes. |
Benefits of the SP Program
CBP’s SP Program strives to contribute maximum benefits to its Program members and business partners within a complex operating environment. Figure 2 summarizes the key benefits to each group.
Figure 2 SP Program Benefits
Mission and Vision
CBP’s mission statement, describing its scope of responsibility for handling seized and forfeited property and supporting CBP’s enforcement operations, is:
The vision describes the desired end-state for CBP’s SP Program. The successful combination of these elements creates a well-functioning program and, more broadly, a more effective law enforcement and SP community.
Goals and Objectives
CBP’s SP Program Strategic Plan has three goals, each with corresponding objectives:
This plan focuses on results-driven goals to support law enforcement with a trusted SP process that complements CBP’s security mission. Each strategic goal is described below, along with the accompanying objectives that establish specific, measurable targets.
1 Goal 1: Enhance the Public Trust and Safeguard Investigations
In support of national and economic security, CBP must remove threats posed by harmful or illegal property. However, the risk to America does not end with the detention of property at the border. To earn the public trust, CBP must remain committed to safeguarding SP throughout its lifecycle under the SP Program’s control and effectively administer forfeiture cases. To maximize the deterrent effect of seizures and forfeitures as effective enforcement actions, the SP Program must establish an unquestioned chain of custody that enables effective case investigation and prosecution. To uphold the desired consequences to offenders, the SP Program will strengthen quality controls for SP inventory throughout its lifecycle and improve its contractor oversight capabilities. These actions will allow the SP Program to manage and execute a secure SP handling process that supports the strategic use of asset forfeiture to secure America and deter criminal enterprises.
1 Objective 1.1 Maintain absolute process and chain of custody integrity.
A secure process, a complete chain of custody record, and assurance of due process establishes trust in the SP handling process and enables CBP to maintain the integrity of case investigations. Improved tracking of SP from initial seizure to final disposition is most important to achieving this objective, particularly while SP is in the custody of contractors and subcontractors. The Program must develop rigorous inventory controls and partner with committed contractors that employ best practice inventory management and tracking techniques to improve process clarity. Additionally, the SP Program should enhance business partner knowledge of compliance requirements, define expectations of business partners, and develop a mutual understanding of partner roles and responsibilities along the chain of custody. Collaboration with business partners is crucial for setting uniform, effective policies that foster a secure and trusted SP handling process. Finally, CBP needs to update its IT system for seizure case processing to ensure that data is more useable for tracking SP and sharing case information with legal authorities.
2 Objective 1.2 Manage compliance requirements and mitigate risks with enhanced process and contract oversight.
To establish confidence in the SP process, effectively administer forfeiture cases, and best support investigations, CBP must demonstrate the operational effectiveness of its process controls and an ability to manage compliance considerations. This must include full accountability for and complete knowledge of contractor-performed activities. The Program must establish formal quality assurance plans and equip its personnel with the knowledge and tools needed to oversee contracted transportation and storage facilities, such as Contracting Officer’s Technical Representative (COTR) skills and performance management. Dedicated Program resources will increase their understanding of contract compliance terms, conduct regular reviews for fulfillment of these terms and other regulatory and compliance requirements, and develop plans to address identified violations. Specifically, the SP Program must address the risks inherent in subcontracted services and labor because security vulnerabilities currently exist.
2 Goal 2: Expand Enforcement Capacity through Proficient SP Program Support
The second goal focuses on developing SP Program support to enhance the organization’s ability to secure the border and enforce laws. To allow frontline personnel to focus efforts on enforcement actions, the SP Program must take SP, in both its physical and administrative forms, into custody quickly after initial seizure and provide centralized program, contract, and financial management. The Program will provide data analysis and reports to business partners and field managers that include actionable assessments of Program needs. Such dedicated Program support will operate as a world class business focused on finding innovative solutions to traditional operational and business problems. The Program will continue to build and put in place plans to maintain a highly effective workforce armed with the skills and tools needed to best provide such support. SFPD will remain responsive to the operational needs of business partners, act as CBP’s Treasury liaison, and increase TEOAF’s confidence in CBP. The Program will seek to better account for reimbursable costs and increase TFF funding opportunities to continually improve CBP’s financial position. CBP will actively pursue the elimination of appropriated funds diverted to SP administration and management. Critical to the achievement of this goal is increased coordination of CBP’s SP Program offices.
1 Objective 2.1 Minimize the field’s administrative workload to enable frontline personnel to focus on enforcement actions.
SP Program members will work together to identify opportunities to expedite the transfer of SP administrative duties away from the border. Although any operational changes require approval from CBP enforcement offices, coordinated efforts to identify potential efficiencies and maximize border effectiveness benefit the agency as a whole. By enabling law enforcement personnel to focus their effort on frontline needs instead of SP administration, OBP Agents, CBP Officers, CBP A&M Interdiction Agents, and other field personnel can devote their highly specialized skills to detecting threats to America, inspecting cargo, and making determinations to seize. Where possible, non-law enforcement CBP personnel must then be used to process and handle SP after initial seizure according to their expertise of the one-CBP SP process. To accomplish this objective, the SP Program offices must efficiently allocate their respective skill sets and define and execute agency-wide procedures that minimize the time SP spends at the border under frontline custody. Working with partners to evaluate the impact of current regulations and policy on frontline personnel will help accelerate the process, contain costs, and free up valuable enforcement resources while maintaining process integrity.
2 Objective 2.2 Maximize financial and performance effectiveness through improved program governance and detailed analysis.
To effectively support CBP’s enforcement operations, the SP Program must ensure that its governance bodies have access to data and analyses needed to make sound decisions regarding SP management. To this end, the SP Program must dedicate resources to contract and budget administration and to ongoing analyses of finances and performance. A consolidated set of cost and performance data from all Program offices will provide governance bodies and key business partners with greater insight into baseline Program costs, trends, and business problems. SFPD will support this effort by administering defined aspects of the SP Program like a business, forecasting budget requirements and proactively identifying performance issues that may lead to non-compliance or cost overruns. Also, SFPD must act as a conduit for the agency’s SP priorities by seeking continued guidance from enforcement personnel. SFPD must provide information to business partners, such as TEOAF, to raise the profile of the SP Program, illustrate its value, and increase confidence in its results. To achieve this objective, the SP Program, especially SFPD, must enhance the analytical skills of its workforce. Analysts must work with business partners to understand and substantiate needs and identify opportunities for process improvement based on field operational insights. The perceived rigidity of regulations and policy must not be viewed as immovable barriers to positive change; the SP Program members must work together to develop options and effectively communicate the benefits of proposed solutions. The successful achievement of this objective depends on the commitment of CBP offices to improving the end-to-end SP process, recognizing the interrelationships between decisions made at each phase and their impact on cost and performance.
3 Goal 3: Increase Funding of SP Enforcement Operations
In addition to strengthening CBP’s capacity for law enforcement, the SP Program is uniquely positioned to provide increased funding for enforcement operations. The Program must better leverage TFF to minimize the need for appropriated funds to support SP activities, thereby fulfilling SP funding needs through TFF reimbursements as much as possible and conserving public funds. Additionally, CBP must capitalize on the opportunities provided by TEOAF to fund agency-wide enforcement priorities. Through improved tracking of the SP Program’s costs and needs, as well as revealing value provided to business partners, CBP will be able to better obtain TFF allocations to support its mission requirements. The most important element necessary for CBP to achieve increased funding is to establish clear Program priorities.
Further, the SP Program will optimize its contribution to TFF. To do so, CBP must minimize operating costs (while maintaining requisite legal and compliance requirements) and maximize revenue from the forfeiture of assets. This will be accomplished through the execution of an efficient, standard SP handling process, proactive analysis of financial data, and by seeking innovative ways to grow revenues from the sale of forfeited assets. CBP’s effort will increase the size of TFF for all member agencies. Close cooperation between CBP’s enforcement offices, TEOAF, and CBP’s Treasury liaison will lead to a mutual understanding of partner priorities and activities.
1 Objective 3.1 Achieve an optimal financial state through TFF reimbursement and funding of enforcement priorities.
CBP must increase deserved funding of vital SP enforcement operations through improved budget and supplemental requests to TEOAF. The Program must first define the total cost of the SP Program by documenting the resources expended on SP activities and improve its budget formulation process. An agency-wide effort to capture complete and accurate cost information is needed. Cost data must be defined for the end-to-end process, from management time spent on program strategy through supplies used to transport SP in the field and including resources expanded in support of other agencies’ efforts. For example, CBP A&M tracks hours flown in support of enforcement operations that result in logged seizures; the total cost of this support in FY 2007 was $4 million, yet the reimbursable components of this cost were not defined or requested. The Program must develop a comprehensive understanding of all the mandatory expenses eligible for TFF disbursements and disseminate this information to CBP’s offices. In addition, CBP and its Treasury liaison must be able to provide clear and strong business cases of funding priorities to TEOAF.
2 Objective 3.2 Optimize revenue contributions to TFF to disrupt and dismantle criminal enterprises.
As steward of the TFF, TEOAF is dedicated to funding law enforcement activities that proficiently use allocated resources to deter and dismantle criminal enterprises. Treasury desires to increase funding of SP activities and will be more likely to do so when CBP demonstrates a unified Program with clear priorities and its commitment to executing a cost efficient and compliant process. The agency must reduce the average time SP remains in inventory and minimize contractor costs while upholding the regulations provided by the Seized Asset Management Enforcement Procedures (SAMEPH), Civil Asset Forfeiture Reform Act (CAFRA), Title 19, and other applicable regulations. In particular, there are opportunities for revenue growth and cost cutting of General Order (GO) merchandise storage and sale. Additionally, CBP will explore opportunities to achieve economies of scale in storage, transport, sale, and destruction of SP by consolidating with SP community members and other Government agencies. Communication across the SP community is critical to the successful achievement of this objective, which will result in increased funding for CBP’s Program activities and the SP community as a whole.
Strategies and Actions
The goals and objectives are accomplished through concrete strategies and actions, which serve as the tangible “how-to” for this strategic plan.
4 Goal 1: Enhance the Public Trust and Safeguard Investigations
1 Objective 1.1 Maintain absolute process and chain of custody integrity.
Strategies
Identify risks and develop security controls that ensure traceability throughout the chain of custody and accountability of business partners.
▪ Convene field law enforcement and other stakeholders to better understand enforcement priorities and determine operational changes needed to improve security and SP integrity.
▪ Conduct detailed business process analysis of the SP process and review standard operating procedures, including risk and vulnerability assessments at each process step.
▪ Identify the composition of SP in inventory and segment by unique characteristics and compliance requirements (including segmentation by size, value, security concerns, and length of time expected to remain in inventory).
▪ Define operational requirements, including the skill sets needed to execute them, for each inventory segment as it moves through the SP lifecycle based on identified vulnerabilities.
▪ Identify mitigation plans and responsibilities for process exceptions when security and compliance concerns arise.
▪ Develop alternatives to reduce reliance on higher risk subcontracted facilities, services, and labor (e.g., acquire additional storage space adjacent or nearby to existing contractor operated facilities (COF)).
Design a user-friendly, enabling, and enterprise-wide IT system for inventory management and case processing that provides a clear view of the chain of custody.
▪ Define user requirements, linked to the business process and operational and compliance needs, for an agency-wide inventory management and case processing IT system.
▪ Develop a business case for an agency-wide IT system for inventory management and case processing capabilities that leverages unique portals for users (e.g. a FP&F and AF Office portal focused on resources for case processing).
▪ Coordinate with Office of Information Technology (OIT) to provide a channel for Seized Asset and Case Tracking System (SEACATS) update requests while the new system is designed and built (e.g., direct link between SEACATS and contactor databases and provision of codes and system functions necessary for tracking).
▪ Develop quality assurance mechanisms for data collection and case information updates, including revision history, e-signatures, and time stamps.
▪ Develop differentiated stakeholder portals and standard automated reports relevant to information and processing needs (including investigators, legal counsel, and contract partners).
▪ Develop contractor access to SEACATS, based on read and write restricted profiles, to increase the timeliness of data updates and expedite processing, and stop faxing and routing consignments through the contractor’s clearinghouse in Alexandria, Virginia.
▪ Develop automated real-time tracking capabilities during transport and storage, such as bar coding and Radio Frequency Identification Device (RFID), and deploy based on assessed security risks.
Share information on the SP process and operational requirements to increase the effectiveness of controls.
▪ Communicate updated and standard SAMPEH procedures to all Program stakeholders and codify expectations for stakeholders and resource types.
▪ Refine training for field, CBP headquarters, and contracting personnel on the implementation of the updated SAMEPH, including its purpose, use, and benefits.
▪ Establish regular channels of communication between SP Program stakeholders to ensure priorities and responsibilities are understood at each stage of the SP lifecycle.
▪ Sponsor regular sessions focused on developing a comprehensive view of the process, from field execution through financial management, to reduce security risks.
2 Objective 1.2 Manage compliance requirements and mitigate risks with enhanced process and contract oversight.
Strategies
Refine the oversight capabilities of the SP Program.
▪ Outline the criteria, accountability, structure, and procedure for oversight of process and contractor compliance.
▪ Define an inventory accountability strategy that includes regular and unannounced reviews for contracted facilities and subcontracted service providers based on volume, value, and security requirements of SP handled and prior performance issues.
▪ Develop mitigation action plans for adverse incidents and risks found during oversight activities and reviews, and define cross-functional improvement teams to monitor and track implementation.
▪ Develop a tool to track issues and develop automated analysis and reporting capabilities to create visibility into performance.
▪ Coordinate efforts with TEOAF’s oversight team to avoid duplication of oversight efforts.
▪ Define clear channels for feedback on contractor performance or other procedural concerns that leverage the insight of resources in the field.
Apply SP process expertise and best practices to mitigate compliance and performance risks.
▪ Define CBP’s unique requirements for shared contract use and proactively provide input on proposed contract modifications to better support law enforcement needs.
▪ Conduct regular cost forecasts to obtain better estimates and avoid cost-overruns.
▪ Develop key performance indicators to generate insight into compliance, standard process execution, and contractor performance (such as inventory and invoice accuracy and length of time from disposition to action taken).
▪ Complete quarterly oversights of SP contracts and reward or penalize contractors based on performance.
▪ Dedicate resources to evaluate and revise current contract terms to include strengthened mechanisms for deterring noncompliance and incentives that affirmatively influence contractor behavior.
▪ Develop procedures and responsibility for monitoring of SEACATS data, including increased frequency of reconciliations with PRISM and ENFORCE.
▪ Conduct regular oversight of contractor disposal of SP (with a SPS or other qualified CBP resource) to ensure full execution of the proper disposition order.
▪ Train SP Program resources in best practice inventory management and quality assurance techniques, increase number of certified COTRs, and attend conferences to remain abreast of private sector innovation.
▪ Direct contractors to collect all SP Program costs and invoices according to CBP’s requirements (e.g., capture pre-seizure costs in CBP’s seven identified subcategories).
5 Goal 2: Expand Enforcement Capacity through Proficient SP Program Support
1 Objective 2.1 Minimize the field’s administrative workload to enable frontline personnel to focus on enforcement actions.
Strategies
Expedite the transfer of SP administrative duties away from law enforcement personnel.
▪ Identify tasks that do not require specialized enforcement skill sets (including requesting appraisal of merchandise, inputting the seizure case file, and counting and re-counting inventory).
▪ Determine what skills are needed for the identified tasks, map to job classifications, and hire personnel such as CBP Technicians or contractors to absorb administrative duties.
▪ Reduce the points of contact required to arrange for contractor services to minimize inventory time under law enforcement personnel custody.
▪ Evaluate the historical order and time frames of pre-seizure activities, including appraisal, counting, and data entry, to perform tasks concurrently and expedite lawful detention and seizure.
▪ Develop a standard process for handling personal effects seized with vehicles and other conveyances.
Ease the administrative burden of seizure workload that must remain with law enforcement personnel.
▪ Investigate a centralized “dispatch” model in port offices to provide dedicated support to field CBP Officers, OBP Agents, and CBP A&M Agents for seizure information recordation and develop a user-friendly, web-based seizure data entry portal.
▪ Reduce the data entry requirements of law enforcement personnel to the legal minimum.
▪ Codify legal requirements of seizures, evaluate operational and regulatory requirements, and initiate policy and regulatory changes to alleviate the burden, as necessary.
▪ Continue to train field personnel through conferences and classes on what is required for legal case sufficiency and deploy differentiated seizure procedures by merchandise type based on the regulatory security requirements or expected case needs.
▪ Evaluate the benefits of reducing the types of activities requiring COTR involvement.
▪ Investigate opportunities to minimize the amount of time spent in transit between the locations involved in SP processing, including dedicating resources with seizure expertise to high-volume areas.
2 Objective 2.2 Maximize financial and performance effectiveness through improved program governance and detailed analysis.
Strategies
Establish advisory bodies with accountability to oversee the SP Program’s priorities and process issues.
▪ Establish a Governance Board to ensure the integration and alignment of mission area needs and to resolve high-level policy, resource, and SPIPT process concerns.
▪ Hold standing meetings of the Seized Property Integrated Program Team (SP IPT) to address priority financial and management problems and review the results of ongoing Working Group analysis to determine mutually beneficial courses of action for the agency.
▪ Refer OFO operational issues and Treasury contractor concerns to the FP&F advisory board for mitigation and resolution and implement a similar structure and process for OBP and CBP A&M.
▪ Implement the agreement signed by the Acting Commissioner in January 2006 that details SFPD’s responsibilities for administration, including financial analysis, budget consolidation, contract analysis, and single point of contact to Treasury (see Appendix A for detailed responsibilities).
▪ Create a process for defining and regularly updating the agency’s SP priorities and for identifying CBP-wide priorities that intersect with TFF priorities, which will be represented to TEOAF.
Institute business metrics that help guide the SP Program’s ongoing strategic direction.
▪ Develop Program performance measures and SFPD performance measures to avoid cost overruns and compliance concerns, including compliance levels, financial health, contracting costs, outreach effectiveness, and measures of efficiency.
▪ Regularly disseminate information to stakeholders on the financial state of the SP Program, including clear documentation of TFF requests, funds allocated to date, and funding allocation decisions.
▪ Train CBP’s enforcement offices on the functioning of the Forfeiture Fund, including its budget process, priorities, and expected funding to increase participation in seeking reimbursements and special enforcement funds.
▪ Determine where cost-leaks occur (e.g., TFF disbursement opportunities that go unexplored) and continue to ensure that assets and funds turned over to other agencies are recorded.
▪ Communicate with TFF members to understand best practice forfeiture program management techniques and infuse relevant practices into CBP’s Program management structure.
Build the analytical capabilities needed to remain responsive to the operational needs of the SP Program.
▪ Identify the skills needed to effectively carry out defined SP Program Analyst activities and baseline current skills against identified needs.
▪ Identify resource and skill gaps, enhance the analytical skills of the existing workforce, and develop comprehensive succession plans to acquire qualified SP resources.
▪ Implement cross-training to support knowledge management activities and career growth and engage all CBP offices and business partners in training development.
▪ Determine ongoing analytical needs and dedicate analysts to examining priority issues, including cost efficiencies and revenue growth opportunities.
▪ Use trend analysis to prepare the SP Program for anticipated future changes in SP Program workload (e.g., forecast where contraband, aliens, and GO merchandise will likely be seized to improve resource allocation and planning decisions).
6 Goal 3: Increase Funding of SP Enforcement Operations
1 Objective 3.1 Achieve an optimal financial state through TFF reimbursement and funding of enforcement priorities.
Strategies
Develop a comprehensive understanding of TEOAF’s disbursement requirements and funding priorities of the SP community.
▪ Define the cost categories that can be funded through mandatory reimbursements, Super Surplus funds, and the Secretary’s Enforcement Fund.
▪ Define the information needed by the Treasury liaison to secure reimbursable funding and create forms that enable enforcement offices to easily provide this information.
▪ Develop standard justification sheets that provide the supporting information and documentation needed for more complex funding requests, including how the request ties in to overall agency and Program priorities.
▪ Prepare one CBP TEOAF funding request for the annual and supplemental budget submissions that provides consistent and equitable opportunities for enforcement offices to seek funds.
▪ Host conferences with other TFF member agencies to share best practices, enforcement priorities, and funding successes.
Capture the agency-wide cost of the SP Program.
▪ Incorporate the TFF budget formulation into the regular CBP budget process.
▪ Continue to review the operations of OFO, OBP, and CBP A&M to identify the activities that play a key role in the SP Program and segment Program activities into cost categories that represent opportunities for TFF disbursement.
▪ Develop a method to regularly, completely, and easily track the costs and time spent on SP Program activities (to include FP&F and AFO reimbursement potential for time spent on forfeitures) and forecast these costs to understand future budgetary needs.
▪ Capture the cost of Program activities that support other U.S. law enforcement agencies and the opportunity cost of lost disbursements overall.
▪ Inventory all facilities, equipment, and personnel paid for by the Forfeiture Fund and demonstrate that TFF funded full time employees are dedicated solely to SP Program activities to better justify funding requests and improve TEOAF’s confidence in CBP’s SP Program.
Provide Treasury with strong business cases for disbursements and articulate the SP Program’s priorities.
▪ Develop a shared process across the agency that formulate and present strong cases for TFF funding requests that cite the need for funding, detail plans for expenditures, and project impact or contribution to the SP community and process integrity.
▪ Create an annual list of integrated Program priorities and demonstrate how funding requests fit in to the broad picture of agency needs.
▪ Develop an enhanced annual report to Treasury, including progress on improvement initiatives and strategic plan implementation, volume and value of property managed, support of other law enforcement agencies, and the value of the SP Program to stakeholders.
▪ Involve high ranking officials, such as the Commissioner and Assistant Commissioners, funding requests from TEOAF to ensure alignment with top-level CBP enforcement priorities.
▪ Identify in-progress special operations and established agency priorities that support SP.
2 Objective 3.2 Optimize revenue contributions to TFF to disrupt and dismantle criminal enterprises.
Explore opportunities to increase revenues derived from forfeited assets.
▪ Review commodity segments and define an optimal disposition mechanism for each type, including an analysis of the sale of forfeited assets in lieu of disposal or destruction (e.g., sell paper and wearing apparel to recyclers).
▪ Investigate GO merchandise process improvements and analyze financial data to ensure compliance by warehousemen and carriers, generate additional revenue, and reduce costs.
▪ Examine the effectiveness of equitable asset sharing and ensure that full reverse asset sharing occurs in all CBP offices, (including an analysis of vehicles, boats, and planes interdicted with support of CBP, stored and secured by CBP, but remitted to other agencies).
▪ Examine and update memoranda of understanding (MOUs) with other law enforcement agencies, apply MOUs consistently across the agency, and cross-train agents in the use of Title 19 and Title 8 to assist CBP in recouping revenue.
▪ Investigate the expansion of the Southern Border vehicle contract in geographic scope and vehicle value.
▪ In light of a new DHS ruling, work with Rulings and Regulations (R&R) to conduct a thorough legal and cost/benefit analysis of the Federal law that allows for the immediate disposal or sale to dismantlers of vehicles where storage costs are projected to exceed proceeds.
▪ Coordinate commodity teams and rights holders to explore methods for altering forfeited Intellectual Property Rights (IPT) infringing merchandise to make it legal for sale or donation to service organizations.
Explore opportunities to decrease SP Program costs that are within CBP’s control.
▪ Analyze build versus rent opportunities for acquiring additional seized property management facilities, including vaults and storage facilities, to ensure storage availability and reduce geographically duplicate infrastructure.
▪ Analyze pre-seizure activity costs and inspection findings and determine thresholds for what inspections should be ordered.
▪ Explore opportunities to contain costs by leveraging economies of scale in storage, destruction, transportation, and advertising across CBP and with other law enforcement agencies.
▪ Develop an optimized transportation network model to verify the efficiency of the current system.
▪ Set procedures that maximize the use of CBP’s Government-Owned, Contractor-Operated (GOCO) facility by bringing cars from the surrounding area to offset storage costs.
▪ Investigate opportunities to leverage agricultural disposal best practices (e.g. the use of the prohibited items policy) to the broader CBP SP process.
Expedite the release of SP from storage.
▪ Establish target timeframes for issuing final dispositions based on commodity/seizure type.
▪ Coordinate with investigative, counsel, and other legal entities to reduce the average length of storage time and volume required for seized goods involved in cases, where possible (e.g. certain cases where retained samples would be sufficient to fulfill case needs).
▪ Monitor vehicles and other inventory in storage and distribute regular, actionable reports to field offices on forfeited property requiring disposition orders.
▪ Issue contractors blanket disposition orders electronically to ensure that property with disposition orders is included in the next scheduled sale and investigate increasing the frequency of sales to reduce lag time.
▪ Investigate the benefits of holding more frequent or online auctions of forfeited property.
▪ Develop incentives for contractors to more quickly dispose of inventory after final disposition.
Appendix
Appendix A: Detailed Program Member Roles and Key Business Partners i
Appendix C: Program Challenges vii
Appendix D: Seized Property Program Core Capabilities xi
Appendix E: Benefits of the Strategic Plan xiv
Appendix F: Looking to the Future xv
Appendix G: Glossary of Terms xvi
Appendix H: Strategic Goals Crosswalks xvii
Appendix A: Detailed Program Member Roles and Key Business Partners
1 CBP Enforcement Offices
CBP’s law enforcement officers stationed at and between the POEs are the agency’s frontline. This frontline is composed of the three border-facing offices of OFO, OBP, and CBP A&M:
OFO is responsible for CBP operations at all U.S. land, air, and sea ports. As such, OFO personnel require skills on the legal, commercial entry side and on the illegal, security assessment side. OFO’s SP activities are often focused on counterfeit merchandise or otherwise inadmissible goods.
OBP is responsible for CBP operations along the vast U.S. border, between the POEs. OBP Agents operate in remote locations that are far from CBP offices. OBP’s SP activities are often focused on drugs and vehicles seized in along the border.
CBP A&M is responsible for providing integrated air and marine capabilities to OBP, OFO, and other law enforcement agencies. CBP A&M’s efforts are primarily focused on providing the air and marine coverage necessary to interdict illegal drugs and immigrants. As such, CBP A&M is often involved in the seizure of sea vessels.
OFO, OBP, and CBP A&M initiate the SP process through direct enforcement actions (e.g., inspection), as well as supporting activities (e.g., air coverage), that result in the seizure of inadmissible property or persons. OFO’s Officers, OBP’s Agents, and CBP A&M Interdiction Agents target and intercept high-risk goods and illegal immigrants at the border. CBP’s frontline personnel are trained in the laws and regulations that result in the seizure of violative and otherwise prohibited property, and they enforce these laws objectively across all entrants and for all types of seizures.
After SP is removed from the flow of trade and travel, OFO and OBP are then responsible for SP handling and case processing at the field operational level. OFO’s Seized Property Specialists (SPS), who are CBP Officers dedicated to SP activities, are charged as the physical custodians of this property, and some OBP Agents and CBP Officers are cross-trained in SP handling as well. SPS’ are the critical link between CBP leadership and warehouse and vault security and contractor operations. In addition, OFO’s Fines, Penalties, and Forfeiture Officers (FP&F) and OBP’s Asset Forfeiture Officers (AFO) use their regulatory, legal, and investigative expertise to process SP cases to completion and FP&F and AF Paralegals provide assistance with this casework.
With respect to the budget and financial functions, OFO, OBP, and CBP A&M develop budget requests and justifications based on their assessment of their operational needs. Each office determines the budget needs of its HQ and field office components and then compiles field level requests into one office-wide request. These offices are also responsible for identifying their procurement (e.g., vehicles) and facility (e.g., vaults) needs.
The SP Program supports CBP’s enforcement offices by providing a coordinated approach to confronting shared problems and helping to optimize Program funding. This enables enforcement personnel to concentrate their efforts on the border security mission. Through its SP Integrated Program Team (IPT) and other improvement initiatives, the SP Program will continue to explore opportunities to increase the benefits of the SP Program to CBP’s enforcement offices, including increased funding and an efficient budget process. The IPT ensures that all offices with SP duties retain individual authorities while working together to solve common problems.
2 Office of Finance
OF has fiduciary responsibility for all of CBP. In January 2006, the Acting Commissioner charged OF with consolidating and centralizing the financial and business functions of CBP’s SP Program. Examples of key services provided by OF to the enforcement offices in the SP Program are procurement, facilities, and budget. OF’s SFPD provides financial management and cost analysis, specific to the SP function, to enforcement offices. SFPD’s administrative duties include contract management, investment review preparation, budget administration, infrastructure matters, financial reporting, and budget analysis. SFPD also serves as CBP’s liaison to TEOAF and secures reimbursement of Program execution costs from the Treasury Forfeiture Fund (TFF). OF / SFPD takes an active role in promoting financial responsibility, designing and delivering procedures for financial / administrative taskings (e.g., inventory), and performing issue analysis of business functions, but does not lead the SP Program and does not task CBP’s enforcement offices to perform enforcement duties.
In executing these duties, SFPD works closely with other CBP offices and Treasury. From its headquarters in Indianapolis, Indiana, SFPD maintains close relationships with Procurement, the National Finance Center (NFC), and Chief Counsel. To secure reimbursement of SP Program expenses from TFF, SFPD coordinates with the budget divisions of each Program office to capture the reimbursable costs of SP activities across the agency. SFPD then prepares and submits the agency’s consolidated budget request to TEOAF. The Treasury Liaison, along with subject matter experts from across CBP, advocates for funding of CBP priorities. In addition, SFPD and the Liaison encourage CBP offices to seek necessary resources for enforcement priorities from the Super Surplus and Secretary’s Enforcement Fund accounts (components of the TFF). To do so, SFPD will continue to work with the enforcement offices to identify opportunities for funding of special operations that accomplish shared CBP and Treasury goals and help deliver sound justifications.
Since its creation on October 1, 2006, SFPD has supported CBP’s enforcement offices with increased financial transparency, provided opportunities for storage cost reductions, and strengthened business case justifications. These efforts have secured increased funding from TEOAF. Between FY 2006 and FY 2008, reimbursable funding authority from TEOAF increased from approximately $17 million to approximately $26 million. In addition, CBP’s Super Surplus allocations from TEOAF have increased from approximately $2 million in FY 2006 to approximately $7 million in FY 2008.
2 SP Program Key Business Partners
The successful execution of the complex SP process demands highly synchronized actions of CBP’s SP Program members with a variety of internal and external business partners. Together, these business partners are charged with securing and accounting for SP and must manage the millions of dollars of revenue generated from the sale of forfeited assets to secure America’s border and disrupt criminal enterprises. The key business partners involved with the execution and management of this process are CBP’s Policy and Business Management Offices, the Department of the Treasury, other law enforcement agencies, U.S. Citizens, and Congress.
1 CBP Policy and Business Management Offices
Other CBP Offices, including the Office of Chief Counsel, the Office of Information Technology, the Office of International Trade, and additional components of the Office of Finance are connected to the SP Program.
Office of Chief Counsel – This office provides legal advice to, and legal representation of, CBP offices. CBP’s attorneys review proposed actions to ensure compliance, prepare and review formal legal opinions and responses, and evaluate proposed programs, policies, and procedures. In addition, Chief Counsel aggressively supports CBP and ICE forfeiture activities by preparing complaint and litigation reports for judicial forfeiture cases. Additionally, Chief Counsel encourages the U.S. Attorney General’s Office to prosecute prioritized CBP-initiated cases (particularly IPR infringements). The SP Program supports legal efforts by providing reliable information and by maintaining the integrity of SP throughout its lifecycle to support prosecution. If attorneys do not have access to complete and accurate information from the seizing officer, or if chain of custody is compromised, any criminal or civil proceeding could be greatly jeopardized.
Office of Information Technology (OIT) – OIT is responsible for implementation and maintenance of information technology across the agency. The SP Program relies on OIT to provide ongoing support for SEACATS and Enforce. These systems enable the agency to capture seizure and case processing data throughout SP’s lifecycle with CBP and allow Program business partners to access vital information. The Program works closely with OIT to convey system needs and enhance the SP Program’s IT infrastructure.
Office of Finance (OF) – OF administers a broad range of financial management activities for the agency and the SP Program benefits from its budgeting, procurement, and audit oversight support in particular. In addition to housing the SFPD, OF’s Asset Management (AM) division, National Finance Center (NFC), and Financial Services Division (FSD) provides financial and logistical support to the SP Program.
Office of Trade (OT) – OT provides national strategic direction to facilitate legitimate trade while protecting the American economy from unfair trade practices and illicit commercial enterprises. The field execution of trade policies, priorities, and customs laws often result in seizures, especially for intellectual property rights and health, safety, and agriculture concerns. The Program is subsequently responsible for processing cases, capturing seizure data, and securely storing SP. This support preserves seizures and forfeitures as effective enforcement tools used to uphold U.S. trade laws. In addition, OT’s Office of Regulations and Rulings (R&R) evaluate whether internal controls are adequate to prevent violations and assess and quantify trade violations (including seizures). In the future, the SP Program will increase communication to best understand OT’s strategic direction and develop forward-thinking plans to provide uniform, and efficient seizure and forfeiture services. Similarly, the SP Program will coordinate with such CBP offices as Intelligence, Anti-Terrorism, Policy & Planning, and the Secure Border Initiative to understand strategic intent and plan how to best support priorities.
2 U.S. Department of the Treasury
The U.S. Department of the Treasury is a critical business partner to CBP and the SP Program. Through its TFF, Treasury collects and manages revenue from five DHS and various Treasury law enforcement agencies working in the SP community. SP Program revenues totaled $257 million in FY 2006 with an approximately $56 million contribution from CBP. Subsequently, TEOAF, which aims to affirmatively influence the consistent and strategic use of asset forfeiture by law enforcement agencies, returns substantial funds to its member agencies to reimburse expenses associated with executing SP activities and to fund additional law enforcement actions. As one of the member agencies of TFF, CBP contributed approximately $45 million and received approximately $35 million in total funding from TEOAF in FY 2007. In addition, CBP is the primary user of a national seized property contract administered by Treasury. This contract cost TFF approximately $36 million in FY 2006, and this cost does not include additional expense incurred by CBP for use of this contract.
There are strong similarities between CBP and TFF strategic goals. First, the seizure of counterfeit currency helps to secure financial markets within the United States and throughout the world. Second, CBP deters illegal smuggling of contraband and terrorists into the United States and concentrates on illegal immigration enforcement. Finally, CBP is committed to instituting state-of-the-art technology at U.S. borders to improve national security and deter and disrupt criminal enterprises.
CBP’s SP Program has greatly increased annual contributions to the TFF due to a rise in seizures from the increased effectiveness of CBP’s enforcement personnel and also from well-executed revenue growth strategies and process efficiencies driven by SFPD. The SP Program will provide increasingly justified, precise, and clearly prioritized budget requests. CBP will continue to demonstrate efficiency in the use of vital TFF funds to maximize mutual benefits in the intersection of DHS and TFF imperatives. Additionally, CBP’s SP Program will continue to improve communication, define Program priorities in the context of the agency’s strategic direction, and develop a unified, process-oriented view to increase confidence in the SP Program.
3 Other Law Enforcement Agencies
CBP’s SP Program partners with other law enforcement agencies in the SP community. These agencies contribute to either TFF or the Department of Justice’s Asset Forfeiture Fund (AFF) or are components of state and local law enforcement. Due to CBP’s unique role at and between POEs, the SP Program initiates many seizure and forfeiture cases for these agencies and provides storage and information post-seizure during case processing. CBP endeavors to identify opportunities for consolidated transportation, warehousing, and selling of SP with partner law enforcement agencies. In addition, CBP will establish formal channels of communication among partners to share best practices, operational needs, and priorities.
Immigration and Customs Enforcement (ICE) – ICE, also a TFF member, is a partner and primary beneficiary of CBP’s SP Program. ICE is DHS’s primary investigative arm that targets and formulates cases against people who attempt to enter unlawful goods into the United States and seizes money and materials that support terrorism or other criminal activities. CBP’s SP Program provides ICE with pre-seizure operational support that includes air and marine assistance, a transparent chain of custody, effective security controls, and quality case information to support investigations. In fact, CBP’s FP&F Officers processed $139 million worth of seized property on behalf of ICE in FY 2006, and CBP remains a committed partner to ICE to better support prosecution efforts. CBP additionally seeks to better define the support resource requirements and to optimize asset sharing of tangible and real property proceeds resulting from joint efforts of the agencies.
In addition to its Federal Government business partners, the SP Program partners with state and local law enforcement agencies. This partnership provides local agencies with external funding through reimbursement of costs incurred and equitable asset sharing. Equitable asset sharing provides a portion of the revenue from the sale of any forfeited property to the agency involved in the case.
4 U.S. Citizens and Congress
The ultimate stakeholders to which CBP and the SP Program are accountable are U.S. citizens and Congress, who rely on CBP to enforce security and trade laws at the border, including the exclusion of harmful and inadmissible property. The SP Program blocks entry of such property into the United States marketplace after initial seizure and maintains secure custody throughout the process. The Program also conserves public funds by providing vital revenue to TFF that minimizes the amount of tax revenue required for effective enforcement by member agencies. By increasing the integrity of the SP process, strengthening partnerships and communication, and increasing revenue contributions to TFF, CBP’s SP Program ensures that the use of asset forfeiture is effective in protecting America.
Appendix B: Seized Property Process
Figure 3 Seized Property Process
Appendix C: Program Challenges
To best provide benefits to its business partners, the SP Program must address its top improvement challenges over the next four years and also capitalize on the SP Program's unique revenue and funding opportunities. This section presents the top environmental, business, and internal Program support challenges addressed by this strategic plan.
3 Environmental Challenges
Seizure volume and frequency continue to rise with the accelerated flow of goods and people across international borders and as advanced law enforcement capabilities enable CBP’s frontline to identify more violations. Due to these factors, the demand for the SP Program’s services has never been higher. On a typical day, more than 1.1 million passengers and pedestrians, 70,000 cargo containers, 300,000 privately owned vehicles, and 80,000 shipments of goods are processed at the nation’s borders. Additionally, CBP’s SP Program breadth of SP responsibilities increased with the DHS merger of 2003.
These considerations have increased the number of line items of SP managed, which is the primary measure of core workload, by nearly 65 percent since 2003. In FY 2007, CBP handled approximately 230,000 lines of SP totaling $1.4 billion. Each line processed represents a commodity type and not the physical volume of seized property handled (for example, one line item could represent 600 pallets of SP). This figure also does not include currency or monetary instruments valued at $71 million or prohibited items with $0 fair market value seized in FY 2007. In addition, CBP seizes illegal narcotics that are ultimately destroyed by CBP or another Federal agency. In FY 2006, CBP processed approximately 470,000 Kilograms of illegal narcotics that were retained and destroyed by CBP.
Heightened business partner expectations and emerging priorities also directly impact CBP’s SP responsibilities. National enforcement priorities, such as protecting intellectual property rights and ensuring health and safety, have resulted in increased SP workload. In addition, American citizens demand safety from harmful goods and security threats, and U.S. industry expects protection from unfair trade practices and illegally imported goods. Finally, Congressional interest has increased the visibility of border security and the use of strong deterrents such as seizures and forfeitures to safeguard American citizens and industry. In the face of these environmental challenges, the SP Program must remain responsive by preparing to meet the current and expected growth in workload. If the SP Program does not take steps to adapt to this environment, the deterrent effect of asset seizure and forfeiture on border security is weakened.
4 Business Challenges
Within this environment of rising volumes and increased SP responsibilities, the SP Program must address specific business challenges that are barriers to achieving its vision.
1 Skill Set Alignment
Aligning specialized skill sets to minimize frontline administrative burden and achieve maximum enforcement impact.
Currently, highly skilled law enforcement personnel are performing certain SP administrative tasks. This reduces the amount of time strained border resources spend on mission-critical duties. The administrative burden on law enforcement personnel results from high data entry and casework requirements, particularly while processing seizures for forfeiture. Cases may be opened and/or expanded to result in additional seizures and prosecutions. Also, the current allocation of CBP Officer, OBP Agent, and CBP A&M Interdiction Agent time does not efficiently deploy specialized skill sets. Due to a delay in the transition of SP administrative tasks to non-law enforcement personnel, Officers and Agents are not able to fully utilize their expert law enforcement capabilities to detect and remove threats to national security.
Although law enforcement officer skills may be needed during case processing (e.g., to investigate criminal activity or to issue a warrant), CBP should utilize non-law enforcement personnel to administer the remaining tasks, including regulatory, legal, and other paperwork requirements of SP. FP&F, Asset Forfeiture Officers, Seized Property Specialists, and FP&F and AF Paralegals are best positioned to most efficiently alleviate the administrative burden on frontline law enforcers. Program members must review the allocation of SP responsibilities and determine the most appropriate division of labor for their office, while being mindful not to duplicate efforts across the agency. Without a more appropriate skill set alignment, CBP risks an underutilization of enforcement personnel capacity.
2 Cost Containment
Capturing the full cost of the SP Program and predicting and controlling cost overruns.
The Program faces specific fiscal challenges, including: high storage costs, diversion of CBP appropriated funds to cover SP Program operating costs, and recovering allowable reimbursable expenses from TFF. Time lags between final disposition orders and actual disposals lengthen the time of SP in inventory, contributing to cost overruns. The agency expends significant effort in support of other agencies but may not sufficiently track time or costs or seek reimbursement (including for reverse / equitable asset sharing) to recoup these expenses. Revenue leaks out of the SP Program due to such unaccounted costs and due to the transition of SP revenue opportunities to other agencies after CBP has provided operational support or SP handling and secure storage. The SP Program lacks a consolidated record of the costs of SP activities across all CBP offices and therefore cannot seek the appropriate reimbursement of mandatory expenses from TEOAF. Further, without clarity into CBP’s operations and finances TEOAF is unable to confidently disburse TFF funds. Thus, CBP continues to use appropriated funds to cover Program shortfalls.
3 SP Security and Contractor Performance
Establishing trust in CBP’s SP process by addressing contractor performance issues and strengthening security controls.
The SP Program experiences difficulties with SP security, primarily due to contractor and sub-contractor performance issues, which puts it at risk for noncompliance and unexpected cost overruns. For CBP’s two main storage and transport contracts, there is concern about the SP Program’s ability to influence contractor behavior to effectively administer security regulations and controls. This concern stems from the following identified issues:
In the past, security breaches at contractor and sub-contractor operated facilities have adversely impacted law enforcement’s ability to administer a secure SP process.
CBP is currently unable to provide detailed tracking of property as it moves through the SP lifecycle under CBP and contractor custody, particularly while in transit.
Official chain of custody information remains paper-based and system limitations compound tracking problems.
CBP has experienced cost overruns with both the VSE and RRE contracts that CBP did not anticipate, in part due to poor cost estimates, e.g. for pre-seizure activities.
Contractors are not fully utilizing modern inventory management principles and fail to fulfill contractual terms such as judicious data entry, timely disposition of property, and accurate invoice submission.
Oversight has been irregular, responsibility for addressing contractor performance issues is not always clear, and follow-up on proposed corrective action is limited.
Although Program members have addressed specific issues as they arise, CBP has been unable to influence systemic corrective behavior due to limited resource availability and the continued full and regular payments of contractors despite performance issues. Without confidence in the security and accurate accounting of SP, CBP’s case investigation and prosecution may be jeopardized and the deterrent effect of seizures may be diminished. In addition, security breaches could lead to lessened public trust, potential lawsuits against the agency, and harm CBP and Treasury’s internal control ratings.
5 Internal Program Support Challenges
To keep pace with environmental and business challenges and achieve the SP Program’s vision, the following internal Program support challenges must be addressed.
1 SP Program Structure
Further unifying the SP Program to coordinate top-level priorities and field level requirements and execution.
The SP Program should capture opportunities for increased management effectiveness and administrative efficiency by building a supportive central program management infrastructure. Currently, the execution of certain SP handling procedures varies by geography and office. Non-standard processes, unless necessary to meet organization needs or mission requirements, generate uncertainties in the agency’s chain of custody control that is critical to investigations and, subsequently, can impact CBP’s deterrent effect. Variation in SP handling procedures across the agency results from narrow communication channels and leads to uncertainty in financial management and performance measurement.
2 Data Management
Providing analytical services driven by high-quality data, enabling tools, and a responsive information technology (IT) infrastructure.
CBP’s SP and case processing system burdens rather than enables employees. The user requirements of CBP’s personnel and the single SP process are no longer met by SEACATS. The Program currently experiences SP data quality concerns due to inadequate data entry quality and timeliness control and an irregular link between field and contractor databases. Such IT problems impact the SP Program’s ability to accurately track SP or effectively monitor seizure trends and costs.
3 Human Capital
Building the skills required to fully support the agency with SP process expertise, analysis, partnership development, and financial oversight.
The agency faces an aging workforce and risks losing depth of SP expertise without comprehensive succession plans. CBP must build an enabled workforce capable of meeting growth in the SP Program’s traditional services as well as demand for new analytical and financial and performance management services. Currently, CBP needs to build vital skill sets, including oversight and quality assurance capabilities, partnership management, and IT system and database query knowledge. In addition, personnel involved in SP would benefit from additional training on CBP’s SP activities beyond their individual role in the process. The SP Program requires a strong, agency-wide effort to strengthen these skills and fill resource gaps to mitigate the risks described above. For example, the SP Program experiences case processing delays due to a shortage of FP&F and AF Officers and FP&F and AF Paralegals, whose main responsibilities include fulfilling legal requirements, such as seizure notification and issuing disposition orders. When processing is delayed, SP remains in storage longer and accrues unnecessary costs.
Appendix D: Seized Property Program Core Capabilities
The close relationship of many of the strategies and actions described reveals the critical need for common core capabilities across the SP Program. The Program must focus on the internal development and application of these capabilities, which represent the professional skills, assets, and alliances in which the SP Program’s personnel must succeed daily to maintain a secure SP process, earn the public trust, and deliver proficient SP Program support to CBP’s law enforcement operations. The core capabilities are:
A vision for each of the core capabilities required for success is presented below to provide insight into the envisioned end-state for SP operations. Each of the four core capabilities draws strength from and reinforces the others. The strategies build toward the following future state of Program support and SP operations, illustrated by Figure 7.1.
Figure 4 SP Program Strategy in Action
4 Proficient Contract and Process Oversight Vision
The SP Program has developed a workforce that is able to ensure contractor and process compliance. Program personnel are knowledgeable of the internal and external controls needed throughout the SP process, can effectively administer contract terms, and form beneficial contractor relationships. Program personnel, who interact with contractors both administratively and in the field, are skilled in COTR matters and understand how process controls and contract terms are operationalized. The workforce has at its disposal the tools, policies, and other means of enforcement necessary to address poor performance and fix systemic process vulnerabilities. The SFPD and the SP Program’s law enforcement offices are called on to contribute both SP process and contract administration expertise during procurement. By presenting an accurate picture of the agency’s security and performance needs, the SP Program shapes the statement of work to best ensure compliance through strengthened controls at contractor operated facilities. Contracts integrate strong incentives that influence contractor behavior in a mutually beneficial way while ensuring compliance. Quality assurance plans are fully executed and methods are in place to review all aspects of contractor procedures, from invoicing through physical transportation. All contractors have established direct links to CBP’s system of record and are well integrated into processes so the SP Program can easily monitor performance and be confident in the process integrity. CBP has developed its personnel to have strong financial acumen, enabling them to prevent cost overruns associated with poor performance.
5 Expert Inventory Management Vision
CBP understands private and public sector best practices in inventory management and is relentless in its pursuit to implement them. CBP personnel located in contractor operated facilities enhance the security of SP in inventory, have deep inventory management skills, and can quickly address issues with contractor performance as they arise on-site. The Program continually analyzes operations to determine areas for improvement, especially in capacity planning, data maintenance, automated tracking, transportation network optimization, and differentiated treatments of property depending on commodity. The Program contributes fresh ideas that help Government agencies ensure compliance with property management regulations in an increasingly business-like operating environment. Further, the agency educates contractors on applicable best practices and their benefits and demands the use of such techniques. CBP hosts regular SP community events that encourage knowledge sharing across the Government and provide training and sessions on hot topics in inventory and warehouse management.
6 Effective Partnership and Communication Vision
The Program establishes and maintains close relationships with a variety of members of the SP community, such as other law enforcement offices and agencies, contractors, warehousemen, Treasury, investigative and intelligence agencies, shippers, and brokers. Together, these business partners are better able to strengthen law enforcement and improve process integrity than they would have been able to alone. Formal and informal channels of communication thrive as Program partners recognize the benefits of a holistic process-view and the drawbacks of overly narrow communication channels that restrict information sharing. More deeply, CBP has built a partnership capability that continually enriches collaboration through trusted information sharing and delivers outreach and training to further mutual understanding and improvement of the SP process. Partnerships continually expand and adapt to changing operational needs, regulations, and the business environment. Finally, SP Program members and key business partners understand each other’s respective priorities and coordinate to achieve mutual goals.
7 Insightful Analysis and Information Management Vision
The Program is critical to CBP’s efforts to address its most pressing challenges through proactive identification and mitigation of potential SP operational and business problems. The SP IPT, comprised of CBP’s law enforcement and business management offices and key business partners, effectively addresses the agency’s priority financial and process issues through evaluations of key business problems and the sharing of information across the agency and external business partners. Their efforts results in efficiency of operations, strengthened Program governance, and optimally supported law enforcement operations. In addition, the SFPD is the primary driver of useful, ongoing analysis and produces both regular and ad hoc reports that yield insights for policymakers, administrators, and field managers alike. Their financial acumen ensures a cost efficient process and increased reimbursement of SP Program activities through coordination with CBP’s enforcement offices. Quality data for analysis is readily available to all personnel through user friendly tools and employee web portals. Extracting knowledge from the data through queries and system reports is not overly burdensome and does not require extensive training. The data is organized in way that it is possible to understand trends and identify problem areas. Information disseminated to update priorities and develop plans is timely, relevant, and actionable.
Appendix E: Benefits of the Strategic Plan
CBP and SP Program business partners will accrue significant benefits from the successful implementation of this strategic plan. In addition to specific improvements in operational and management effectiveness, the following high value benefits are expected:
6 Increased National Security
Through the implementation of CBP’s SP Program strategic plan, seizures are preserved as an effective enforcement tool with a substantial deterrent effect. This is carefully balanced with the utmost needs for due process and to maintain the public trust. ICE and other investigative and intelligence agencies can confidently proceed with case investigations and prosecution due to the elevated integrity of the SP chain of custody. Additionally, cases will be better substantiated through the provision of high quality information from the SP Program. Implementation of this plan will also maximize the agency’s capacity to enforce security, customs, and immigration laws. By shifting the administrative workload of SP processing away from frontline enforcement personnel, this plan will lead to an undivided focus on the CBP mission.
7 Conservation of Public Funds
A unique characteristic of the SP Program is its ability to generate revenue and, in effect, turn non-compliance into a weapon against non-compliers. By optimizing its revenue contribution to the TFF, CBP is promoting Government-wide SP Program financial self-sufficiency as much as possible. These efforts will not compromise the ultimate law enforcement purpose of the SP Program and the more efficient administration and optimized sale of forfeited assets will ensure that CBP remains an essential partner and source of revenue for the U.S. Treasury. Additionally, through the improved financial and performance management of CBP’s SP Program provided for in this plan, appropriate disbursements for SP activities will be secured from the TFF, thereby minimizing the diversion of CBP funds appropriated to national security.
8 Increased SP Community Coordination
CBP’s SP Program strategic plan includes key considerations on improving communication and coordination across business partners. This includes the broader SP community of Federal, State, and Local law enforcement agencies. A primary contribution to all business partners is integrity of the seizure process that builds increasing levels of trust. Enhanced trust and consistency across the law enforcement community develop through heightened coordination will enhance the security of the U.S. border and dismantles criminal enterprises. Greater overall effectiveness in both enforcement and SP process integrity and discovery of opportunities for cost synergies will likely result from community meetings, and more regular contact, lead by CBP’s SP Program.
Appendix F: Looking to the Future
The SP Program is vital to protecting economic and national security by blocking entry of violative property into the United States. To meet the SP Program vision and preserve asset seizure and forfeiture as effective enforcement and deterrence tools, CBP must focus on implementing this strategic plan.
9 Forward Progress
CBP already has a number of successful programs and initiatives planned and underway to improve the SP Program. With implementation of this strategic plan, the SP Program will strengthen the foundation laid by these efforts to achieve its mission and goals.
One Face to Treasury – Attendance and increased management attention at TEOAF meetings has resulted in the TFF reimbursable authority funding allocations to CBP to rise from approximately $17 million in FY 2006 to $27 million in FY 2007, and finally, to $39 million in FY 2008. The Treasury liaison has secured increases funding of vital resources for enforcement priorities by increasing Treasury’s awareness of the SP Program’s goals and operations.
Seized Property Integrated Program Team (SP IPT) – The SP IPT is comprised of senior-level SP Program members who work together to improve the governance and efficiency of the SP Program. The IPT assigns small teams, or Working Groups, to identify the underlying causes of priority financial and process issues. These teams then provide recommendations on ways to improve SP processes, policies, and governance. These efforts aim to best support CBP’s law enforcement efforts while balancing the need for a financially sound Program. The group held its first meeting on February 5, 2008, and this meeting was successful in identifying the IPT’s priority initiatives for the next year, Working Group leads, crafting the IPT Charter, and refining the IPT process to accomplish the group’s shared objectives.
RRE Southern Border Vehicle Contract – The Program executed a strategy to sell vehicles valued at $2,500 to dismantlers for profit instead of destroying them at a cost to CBP. This innovation generated $4 million in revenue and eliminated $25 million in cost from the SP Program’s budget between FY 2006 and FY 2007. Due to security concerns at RRE primary and subcontracted facilities and continued cost overruns, the SP IPT established a working group to evaluate CBP and RRE’s processes and interaction to improve security and efficiency.
VSE National Contract – CBP consolidated its national inventory from 17 warehouses to three contractor operated facilities (COFs) in areas of high seizure volume, including Riverside, California, Dayton, New Jersey, and Miami, Florida. Through partnership with CBP and Treasury, VSE has enhanced internal and external controls and has agreed to transfer the contents of weak subcontracted facilities to central COFs.
Conferences – In May 2007 and March 2008, CBP held its first and second FP&F Conferences. These conferences facilitated dialogue across the field, including sharing of best-practices and discussion of common challenges. In June 2008, CBP held a third conference that was focused on SP financial management and rules and regulations. The SP Program will continue to explore opportunities for additional conferences with additional SP professionals, including SPS, AFO, and FP&F and AF Paralegal positions.
Appendix G: Glossary of Terms
Acronym Description
CBP A&M Office of CBP Air and Marine
AFF Department of Justice’s Asset Forfeiture Fund
AFO Asset Forfeiture Officers
ATF Bureau of Alcohol, Tobacco, and Firearms
CBP U.S. Customs and Border Protections
COTR Contracting Officer’s Technical Representative
DEA Drug Enforcement Agency
DHS Department of Homeland Security
DOJ-CI Department of Justice, Criminal Investigation Division
FBI Federal Bureau of Investigations
FP&F Fines, Penalties, and Forfeiture Officers
FSD Financial Services Division
GO General Order merchandise
ICE Immigration and Customs Enforcement
INS Immigration and Naturalization Service
IRS Internal Revenue Service
MOU Memorandum of Understanding
NFC National Finance Center
OBP Office of the Border Patrol
OF Office of Finance
OFO Office of Field Operations
OIT Office of Information Technology
OT Office of International Trade
POEs Ports of Entry
R&R Office of Regulations and Rulings
RAP Resource Allocation Plan
RRE Rod Robertson Enterprises
SAMEPH Seized Asset Management Enforcement Procedures Handbook
SAPOE Securing America’s Ports of Entry, OFO Strategic Plan
SBI Secure Border Initiative, OBP Strategic Plan
SEACATS Seized Asset and Case Tracking System
SFPD Seized and Forfeited Property Division
SP Seized property
SP IPT Seized Property Integrated Program Team
SP Program CBP’s Seized Property Program
SPS Seized Property Specialists
TEOAF Treasury Executive Office for Asset Forfeiture
TFF Treasury Forfeiture Fund
Appendix H: Strategic Goals Crosswalks
The following crosswalks identify areas in which goals and objectives of SP Program’s plan complement and supplement the agency’s other strategic plans.
| |CBP Strategic Goals and Objectives |
| | |
|SP Program / CBP Strategic Goals Crosswalk | |
| | |
| |Goal 1: Preventing Terrorism At Ports of Entry |
| |1.1: Improve the |1.2: Improve |1.3: Strengthen the |1.4: Push the |
| |collection, use, |identification and |CBP defense-in-depth|nation’s zone of |
| |analysis, and |targeting of |approach through the|security beyond |
| |dissemination of |potential terrorists|use of |physical U.S. |
| |intelligence to |and terrorist |state-of-the-art |borders through |
| |target, identify, |weapons, through |detection and sensor|partnerships and |
| |and prevent |risk management and |technology, |extended border |
| |potential terrorists|automated advanced |resources, and |initiatives to deter|
| |and terrorist |and enhanced |training. |and combat the |
| |weapons from |information. | |threat of terrorism.|
| |entering the United | | | |
| |States. | | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations| |
|1.1: Maintain absolute process and chain of custody |( | | |( |
|integrity. | | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | |( |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through| | |( | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | |( | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |CBP Strategic Goals and Objectives |
| | |
|SP Program / CBP Strategic Goals Crosswalk | |
| | |
| |Goal 2: Preventing Terrorism Between Ports of Entry |
| |2.1: Enhance the |2.2: Maximize border|2.3: Expand |2.4: Develop a more |
| |intelligence |security, along the |specialized teams |flexible, |
| |program, and improve|northern, southern, |and rapid-response |well-trained, |
| |intelligence-driven |and coastal borders,|capabilities to |nationally directed |
| |operations. |through an |enhance control of |program and address |
| | |appropriate balance |the borders, with |central |
| | |of personnel, |expansion to |infrastructure, |
| | |equipment, |problematic areas as|facility and |
| | |technology, |identified through |technology needs. |
| | |communications |continuing threat | |
| | |capabilities, and |assessments. | |
| | |tactical | | |
| | |infrastructure. | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | | |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | |( | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through | |( | |( |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | |( |( | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |CBP Strategic Goals and Objectives |
|SP Program / CBP Strategic Goals Crosswalk | |
| | |
| | |
| |Goal 3: Unifying as One Border Agency |
| |3.1: Create a |3.2: Develop and|3.3: Establish a|3.4: Leverage |3.5: Realign the|
| |shared law |implement |unified primary |the expertise, |Office of CBP |
| |enforcement |policy, |inspection |capabilities, |Air and Marine |
| |culture |management, |process for |and legal |to improve the |
| |throughout the |operations, |passenger |authorities of |overall |
| |agency to secure|infrastructure, |processing at |CBP officers to |operational |
| |the homeland. |and training |all ports of |establish |effectiveness |
| | |initiatives to |entry into the |antiterrorism |and efficiencies|
| | |integrate |United States |secondary |of CBP air and |
| | |analysis and |and fully |inspections. |marine assets. |
| | |targeting units.|integrate | | |
| | | |analysis and | | |
| | | |targeting units.| | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| | | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | | | |
|enhanced process and contract oversight. | | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable |( | | | | |
|frontline personnel to focus on enforcement actions. | | | | | |
|2.2: Maximize financial and performance effectiveness through |( | | | | |
|improved program governance and detailed analysis. | | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | | |
|dismantle criminal enterprises. | | | | | |
| |CBP Strategic Goals and Objectives |
|SP Program / CBP Strategic Goals Crosswalk | |
| | |
| |Goal 4: Facilitating Legitimate Trade and Travel |
| |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| |
|2.1: Minimize the field’s administrative workload to enable | |
|frontline personnel to focus on enforcement actions. | |
|3.1: Achieve an optimal financial state through TFF | |
|reimbursement and funding of enforcement priorities. | |
| |Goal 5: Protecting America and Its Citizens |
| |5.1: Capitalize |5.2: |5.3: Cooperate |5.4: Reduce the |5.5: Provide |
| |on the use of |Deploy…technolog|with other |importation of |support to |
| |information and |ies …to |agencies, |all prohibited |protect events |
| |intelligence to |pre-screen and |foreign |or illegal drugs|and key assets |
| |identify and |identify |governments, and|and other |of national |
| |target the CBP |smugglers and |industry |materials that |interest, and |
| |enforcement |smuggled |partners to |are harmful to |mitigate the |
| |response |merchandise to |administer and |the public or |risks of |
| |to...illegal |increase |enforce the laws|may damage the |terrorism and |
| |activities. |interdiction and|of the United |American |other threats to|
| | |apprehension |States. |economy. |critical |
| | |effectiveness. | | |government |
| | | | | |operations. |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.|( | |( |( | |
|1.2: Manage compliance requirements and mitigate risks with |( | | | | |
|enhanced process and contract oversight. | | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | | | |
|frontline personnel to focus on enforcement actions. | | | | | |
|2.2: Maximize financial and performance effectiveness through | | | | | |
|improved program governance and detailed analysis. | | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | |( |( | |
|dismantle criminal enterprises. | | | | | |
| |CBP Strategic Goals and Objectives |
| | |
|SP Program / CBP Strategic Goals Crosswalk | |
| | |
| |Goal 6: Modernizing and Managing |
| |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| |
|2.1: Minimize the field’s administrative workload to enable | |
|frontline personnel to focus on enforcement actions. | |
| |Goal 1: Gain Effective Control of the Borders |
| |1.1: DHS will employ the |1.2: DHS ended the practice|1.3: DHS will anticipate, |
| |right mix of personnel, |of “catch and release,” |detect, respond to, |
| |technology, infrastructure,|whereby illegal aliens from|disrupt, dismantle, and |
| |and response capabilities |countries other than Mexico|prosecute potential |
| |to gain effective control |arrested at the border were|terrorist and criminal |
| |of the land and maritime |often granted routine |organizations involved in |
| |border. |parole pending immigration |the illegal cross-border |
| | |hearings. |movement of people, goods, |
| | | |contraband, narcotics, and |
| | | |money to ensure homeland |
| | | |security and public safety.|
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | |( |
|1.2: Manage compliance requirements and mitigate risks with | | |( |
|enhanced process and contract oversight. | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable |( | | |
|frontline personnel to focus on enforcement actions. | | | |
|2.2: Maximize financial and performance effectiveness through |( | | |
|improved program governance and detailed analysis. | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | | |
|reimbursement and funding of enforcement priorities. | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | |( |
|dismantle criminal enterprises. | | | |
| |Secure Border Initiative |
| |Strategic Goals and Objectives |
|SP Program / OBP Goals Crosswalk | |
| | |
| |Goal 2: Strengthen Interior Enforcement and Compliance |Goal 3: TWP |
| |2.1: DHS will |2.2: DHS will |2.3: DHS will |3.1: DHS will |
| |investigate and |identify, apprehend,|provide tools to |advocate passage of a|
| |penalize employers |and expeditiously |foster compliance |Temporary Worker |
| |who systematically |remove the criminal |with immigration and|Program (TWP) as part|
| |employ or exploit |alien and fugitive |customs laws. |of comprehensive |
| |aliens unauthorized |population. | |immigration reform. |
| |to work, and | | | |
| |increase the | | | |
| |capability to | | | |
| |detect, deter, and | | | |
| |eliminate the abuse | | | |
| |of the immigration | | | |
| |process. | | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| | |( | |
|1.2: Manage compliance requirements and mitigate risks with | | |( | |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through | | | | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | | | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |Securing America’s Ports Of Entry |
|SP Program / OFO Strategic Goals Crosswalk |Strategic Goals and Objectives |
| | |
| | |
| |Goal 1: Advance Knowledge |Goal 2: Effective Inspections |
| |1.1: Increase |1.2: Implement a |2.1: Screen |2.2: Maintain |2.3: Improve |
| |scope and accuracy|highly effective |all people, |flexible, agile,|recording and |
| |of the information|risk management |goods, and |and streamlined |use of border |
| |gathered on |process by |conveyances |inspection |crossings, |
| |people, goods, and|performing |crossing the |processes. |inspection, and |
| |conveyances ahead |advance analysis |border at | |enforcement |
| |of arrival at the |…to identify |the POE. | |results. |
| |border. |potential threats| | | |
| | |prior to their | | | |
| | |arrival and to | | | |
| | |enable screening | | | |
| | |prioritization. | | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations| |
|1.1: Maintain absolute process and chain of custody | | | | |( |
|integrity. | | | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | | | |
|enhanced process and contract oversight. | | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | |( |( | |
|frontline personnel to focus on enforcement actions. | | | | | |
|2.2: Maximize financial and performance effectiveness through| | | | |( |
|improved program governance and detailed analysis. | | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | | | | |
|reimbursement and funding of enforcement priorities. | | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | | |
|dismantle criminal enterprises. | | | | | |
| |Securing America’s Ports Of Entry |
| |Strategic Goals and Objectives |
|SP Program / OFO Goals Crosswalk | |
| | |
| |Goal 3: Focused Security |Goal 4: Secure Environment |
| |3.1: Increase |3.2: Equip the ports|4.1: Secure POE |4.2: Improve |
| |situational |with specialized |facilities enabling |physical security |
| |awareness to improve|enforcement |CBP to effectively |controls at ports of|
| |border security at |capabilities to |perform its mission.|entry. |
| |the |promote | | |
| |ports of entry. |national resilience.| | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | |( |( |
|1.2: Manage compliance requirements and mitigate risks with | | |( |( |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable |( | | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through | | | | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | |( | | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |OFO Strategic Goals and Objectives |
| | |
|SP Program / OFO Goals Crosswalk | |
| | |
| |Goal 5: Successful Implementation |
| |5.1: Expand and enhance |5.2: Maintain a workforce |5.3: Capitalize on |
| |information-sharing |highly effective at |emerging technologies in |
| |partnerships to improve |carrying out CBP’s POE |order to plan and manage a |
| |intelligence development |border security mission and|cohesive technology |
| |and field operations. |strategic goals. |portfolio that best |
| | | |supports analysis and |
| | | |decision- making by CBP |
| | | |personnel. |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | |( |
|1.2: Manage compliance requirements and mitigate risks with | | | |
|enhanced process and contract oversight. | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | |
|frontline personnel to focus on enforcement actions. | | | |
|2.2: Maximize financial and performance effectiveness through |( |( | |
|improved program governance and detailed analysis. | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | |( | |
|reimbursement and funding of enforcement priorities. | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | |
|dismantle criminal enterprises. | | | |
| |OF Strategic Goals and Objectives |
| | |
|SP Program / OF Strategic Goals Crosswalk | |
| | |
| |Goal 1: Improve internal and external communication and customer service to create |
| |a more customer-focused culture |
| |1.1: Develop and |1.2: Train OF |1.3: Implement a |1.4: Continually |
| |implement an |personnel and |customer service |measure, monitor, |
| |internal and |customers on OF and |strategy and |and improve |
| |external |CBP mission, |process. |communication |
| |communication |functions, and | |strategy and |
| |strategy to improve |services. | |customer |
| |communication with | | |satisfaction. |
| |customers and | | | |
| |co-workers. | | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | | | |
|1.2: Manage compliance requirements and mitigate risks with |( |( | |( |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | |( | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through |( |( | | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF |( |( |( |( |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and |( | | |( |
|dismantle criminal enterprises. | | | | |
| |OF Strategic Goals and Objectives |
| | |
|SP Program / OF Strategic Goals Crosswalk | |
| | |
| |Goal 2: Improve organizational efficiency by providing documented, repeatable, and |
| |integrated business processes and a framework for continual process improvement and|
| |training |
| |2.1: Develop an |2.2: Develop a |2.3: Research and |2.4: Implement a |
| |integrated |quality management |implement industry |measurement program |
| |organizational |system to |best practices to |to define targets |
| |business process |continually monitor |improve |for performance and |
| |framework with |process |organizational |understand the value|
| |documented OF |effectiveness and |design, process |of improvements |
| |policies, processes,|identify and track |efficiency, and |implemented. |
| |procedures, and |process improvements|performance. | |
| |tools. |to closure. | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | |( | |
|1.2: Manage compliance requirements and mitigate risks with |( |( |( |( |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | |( | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through |( |( |( |( |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF |( |( | |( |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and |( |( |( |( |
|dismantle criminal enterprises. | | | | |
| |OF Strategic Goals and Objectives |
| | |
|SP Program / OF Strategic Goals Crosswalk | |
| | |
| |Goal 3: Implement human capital initiatives within OF to enhance employee |
| |retention, provide employees with needed skills, and streamline the hiring process |
| |3.1: Develop a |3.2: Improve OF |3.3: Implement a |3.4: Implement a |
| |process, based on |employee development|hiring strategy |succession |
| |core and technical |and retention by |using a variety of |management strategy |
| |competencies, to |providing training, |recruitment methods,|in OF that |
| |identify and assess |coaching, and |considering current |facilitates the |
| |employees’ work |performance feedback|and future needs and|development of a |
| |skills enabling OF |and facilitate |providing for |pool of candidates |
| |to effectively |personal ownership |quality |for leadership |
| |recruit, select, |of career growth. |decision-making and |positions. |
| |deploy, and develop | |speedy processing, | |
| |staff. | |to efficiently fill | |
| | | |open OF positions. | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.| | | | |
|1.2: Manage compliance requirements and mitigate risks with | |( | | |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through | |( | | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | | | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |OF Strategic Goals and Objectives |
| | |
|SP Program / OF Strategic Goals Crosswalk | |
| | |
| |Goal 4: Enhance integration of financial and other automated systems |
| |4.1: Enhance financial and other |4.2: Improve the proficiency of system |
| |automated systems to improve integration |users to ensure OF staff and customers |
| |and utilization of automated reporting |perform their duties and responsibilities|
| |and analysis capabilities. |effectively. |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity.|( | |
|1.2: Manage compliance requirements and mitigate risks with | |( |
|enhanced process and contract oversight. | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | |( |
|frontline personnel to focus on enforcement actions. | | |
|2.2: Maximize financial and performance effectiveness through |( | |
|improved program governance and detailed analysis. | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF |( | |
|reimbursement and funding of enforcement priorities. | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | |
|dismantle criminal enterprises. | | |
| |CBP Air and Marine National Strategic Plan |
| | |
|SP Program / CBP A&M Strategic Goals Crosswalk | |
| | |
| |Goal 1: Complete the Unification and Integration of CBP A&M |
| |1.1: Finalize and |1.2: Align |1.3: Standardize |1.4: Support and |
| |implement a single |successful practices|safety and training.|consolidate aircraft|
| |operational |and standards for | |and marine vessel |
| |structure. |field-level | |maintenance. |
| | |operations. | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard | |
|Investigations | |
|1.1: Maintain absolute process and chain of custody | | | | |
|integrity. | | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | | |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | |( | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness | | | | |
|through improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | | | | |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |CBP Air and Marine National Strategic Plan |
| | |
|SP Program / CBP A&M Strategic Goals Crosswalk | |
| |Goal 2: Maximize Border Security by Expanding and Improving Patrols and |
| |Surveillance along the Borders to Detect, Deter, and Prevent Illegal Entry |
| |2.1: Realign and |2.2: Align assets |2.3: Improve and |2.4: Realign and |
| |establish |to mission |expand mission |expand personnel |
| |strategically |requirements. |capabilities to meet|resources. |
| |located Air and | |the threat. | |
| |Marine sites. | | | |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | | | |
|1.2: Manage compliance requirements and mitigate risks with | | | | |
|enhanced process and contract oversight. | | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | |( | | |
|frontline personnel to focus on enforcement actions. | | | | |
|2.2: Maximize financial and performance effectiveness through | | | | |
|improved program governance and detailed analysis. | | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF | |( |( |( |
|reimbursement and funding of enforcement priorities. | | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | | |
|dismantle criminal enterprises. | | | | |
| |CBP Air and Marine National Strategic Plan |
| | |
|SP Program / CBP A&M Strategic Goals Crosswalk | |
| |Goal 3: Supporting Traditional Missions and Ensuring Fleet Safety |
| |3.1: Increase assets and |3.2: Fleet Safety and |3.3: Acquisitions, |
| |hours for interdiction and|Service Life Extension |supportability, and |
| |ICE support. |Program (SLEP). |performance enhancements. |
|SP Program Strategic Goals and Objectives |
|Goal 1: Enhance the Public Trust and Safeguard Investigations | |
|1.1: Maintain absolute process and chain of custody integrity. | | | |
|1.2: Manage compliance requirements and mitigate risks with |( | | |
|enhanced process and contract oversight. | | | |
|Goal 2: Expand Enforcement Capacity through Proficient SP | |
|Program Support | |
|2.1: Minimize the field’s administrative workload to enable | | | |
|frontline personnel to focus on enforcement actions. | | | |
|2.2: Maximize financial and performance effectiveness through | | | |
|improved program governance and detailed analysis. | | | |
|Goal 3: Increase Funding of SP Enforcement Operations | |
|3.1: Achieve an optimal financial state through TFF |( | | |
|reimbursement and funding of enforcement priorities. | | | |
|3.2: Optimize revenue contributions to TFF to disrupt and | | | |
|dismantle criminal enterprises. | | | |
-----------------------
U.S. Customs and Border Protection’s
Seized Property Program
Strategic Plan
FY 2009 - 2013
U.S. Department of Homeland Security
CBP seizes over:
▪ 7,388 pounds of narcotics in 98 seizures
▪ $187,176 in undeclared or illicit currency
▪ $652,603 worth of fraudulent commercial merchandise
▪ 41 vehicles between ports of entry
▪ 4,296 prohibited meat or plant materials
▪
On a typical day at and between U.S. Ports of Entry
Secure and effective management of seized and forfeited property, where:
▪ The integrity of seized and forfeited assets from the border through disposition is unquestioned and any process exceptions are predicted and approved.
▪ The consistent and strategic use of asset forfeiture enhances the security of the U.S. border and dismantles criminal enterprises while assuring due process of the law.
▪ CBP is an essential partner and source of revenue for the U.S. Treasury through achievement of economies of scale, efficient operations, and the optimized sale of forfeited assets.
▪ CBP’s SP Program is as financially self-sufficient as possible, minimizing the appropriated funds required to maintain operations through a strong SP Program support infrastructure.
▪ Continuous innovation facilitates continuous operational improvement, enabling the Treasury Executive Office for Asset Forfeiture (TEOAF) to allocate funds vital to CBP’s operations and enforcement programs.
To secure and account for seized and forfeited property, maintain the integrity of all investigations, and enhance funding to Treasury and CBP operations.
▪
Secure and effective management of seized and forfeited property, where:
▪ The integrity of seized and forfeited assets from the border through disposition is unquestioned and any process exceptions are predicted and approved.
▪ The consistent and strategic use of asset forfeiture enhances the security of the U.S. border and dismantles criminal enterprises while assuring due process of the law.
▪ CBP is an essential partner and source of revenue for the U.S. Treasury through achievement of economies of scale, efficient operations, and the optimized sale of forfeited assets.
▪ CBP’s SP Program is as financially self-sufficient as possible, minimizing the appropriated funds required to maintain operations through a strong SP Program support infrastructure.
▪ Continuous innovation facilitates continuous operational improvement, enabling TEOAF to allocate funds vital to CBP’s operations and enforcement programs.
Goal 3: Increase Funding of SP Enforcement Operations
Goal 1: Enhance the Public Trust and Safeguard Investigations
Achieve an optimal financial state and capitalize on the SP Program's unique revenue and funding opportunities.
Enhance the agency’s ability to protect America with highly efficient administration, harmonized agency-wide efforts, and effective program and financial management.
Support legal proceedings with a trusted handling of property, a secure chain of custody, and robust oversight and quality assurance.
▪
Goal 2: Expand Enforcement Capacity through Proficient SP Program Support
Objectives
1.1 – Maintain absolute process and chain of custody integrity.
1.2 – Manage compliance requirements and mitigate risks with enhanced process and contract oversight
Objectives
2.1 – Minimize the field’s administrative workload to enable frontline personnel to focus on enforcement actions.
2.2 – Maximize financial and performance effectiveness through improved program governance and detailed analysis.
Objectives
3.1 – Achieve an optimal financial state through TFF reimbursement and funding of enforcement priorities.
3.2 – Optimize revenue contributions to TFF to disrupt and dismantle criminal enterprises.
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1 CBP’s SP Program Contracts
CBP’s SP Program uses two primary contracts to manage seized property, including for the transport, storage, and sale or destruction of SP.
The VSE Corporation holds Treasury’s national general property and vehicle contract, which serves CBP and other law enforcement agencies in the SP community. This contract is owned and administered by Treasury and went into effect in January, 2007; in its first year of operation, the VSE contract cost approximately $37 million. The consolidation of 17 warehouses to VSE’s three national warehouses highlighted a variety of internal control weaknesses, such as missing goods and untimely updates of systems of record. In addition, physical security vulnerabilities were identified at certain facilities. Program members and Treasury actively engaged the contractor to strengthen internal and external controls and started to assess contractor performance on a quarterly basis. In addition, full-time CBP personnel are stationed in contractor operated facilities (COFs) to help ensure contractor compliance and enhance the security of the facilities.
The Rod Robertson Enterprises (RRE) Contract handles seized vehicles valued at less than $10,000 in the four Southwestern Border states. This contract, which is owned by CBP and administered by the SFPD, launched on October 1, 2006, and it cost CBP $8 million during FY 2007. RRE auctions forfeited vehicles valued between $2,500 and $10,000 on CBP’s behalf and sells vehicles valued at less than $2,500 to dismantlers for a profit instead of paying for destruction. In the first year of employing this technique, the SP Program produced $12 million in revenue and eliminated $25 million in destruction costs. RRE has repeatedly submitted inaccurate and untimely invoices and there are several security concerns at RRE primary and subcontracted facilities. Program members will continue to work closely with the contractor to ensure that all financial requirements are met and security regulations and controls are upheld in all RRE facilities.
▪ Proficient Contract and Process Oversight
▪ Expert Inventory Management
▪ Effective Partnership and Communication
▪ Insightful Analysis and Information Management
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