Combating Terrorism: How Five Foreign Countries Are Organized to Combat
Terrorism (Letter Report, 04/07/2000, GAO/NSIAD-00-85).
Pursuant to a congressional request, GAO reviewed five foreign
countries' efforts to combat terrorism, focusing on: (1) how other
governments are organized to combat terrorism; and (2) how they allocate
their resources to combat terrorism.
GAO noted that: (1) the countries generally have the majority of
organizations used to combat terrorism under one lead government
ministry; (2) however, because many other ministries are also involved,
the countries have created interagency coordination bodies to coordinate
both within and across ministries; (3) for example, while many countries
generally have their intelligence and law enforcement organizations
under their ministries of interior or equivalent, they also need to
coordinate with their ministries of foreign affairs, defense, and health
or emergency services; (4) the countries have clearly designated who is
in charge during a terrorist incident--typically their national or local
police; (5) the countries have national policies that emphasize
prevention of terrorism; (6) to achieve their policies, the countries
use a variety of strategies, including intelligence collection, police
presence, and various security measures such as physical barriers at the
entrances to public buildings; (7) these countries primarily use their
general criminal laws (e.g., those for murder or arson) to prosecute
terrorists; (8) the countries also have special terrorism-related laws
that allow for special investigations or prosecution mechanisms and
increased penalties; (9) the countries' executive branches provide the
primary oversight of organizations involved in combating terrorism; (10)
this oversight involves reviewing the programs and resources for
effectiveness, efficiency, and legality; (11) the five countries GAO
examined also had similarities in how they allocate resources to combat
terrorism; (12) officials in the ministries involved said they make
resource allocations based upon the likelihood of threats taking place,
as determined by intelligence assessments; (13) while the officials GAO
met with discussed resource levels in general, none of the five
countries tracked overall spending on programs to combat terrorism; (14)
such spending was imbedded in other accounts for broad organizational or
functional areas such as law enforcement, intelligence, and defense;
(15) officials in all countries told GAO that because of limited
resources, they made funding decisions for programs to combat terrorism
based on the likelihood of terrorist activity actually taking place, not
the countries' overall vulnerability to terrorist attack; and (16) the
officials said their countries maximize their existing capabilities to
address a wide array of threats, including emerging threats, before they
create new capabilities or programs.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-00-85
TITLE: Combating Terrorism: How Five Foreign Countries Are
Organized to Combat Terrorism
DATE: 04/07/2000
SUBJECT: Emergency preparedness
Interagency relations
Terrorism
Crime prevention
Foreign governments
Domestic intelligence
Facility security
Law enforcement
IDENTIFIER: Canada
France
Germany
Israel
United Kingdom
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GAO/NSIAD-00-85
Appendix I: Security-Related Policy Development and Incident
Leadership in Canada, France, Germany, Israel, and the United
Kingdom
16
Appendix II: Principal Law Enforcement and Intelligence
Organizations in Canada, France, Germany, Israel, and the United Kingdom
18
Appendix III: Principal Terrorism Laws, Definitions, and Other Legal
Information in Canada, France, Germany, Israel, and the United
Kingdom
20
Appendix IV: Security-Related Oversight Organizations and Functions
in Canada, France, Germany, Israel, and the United Kingdom
22
Appendix V: GAO Contacts and Staff Acknowledgments
24
25
National Security and
International Affairs Division
B-284585
April 7, 2000
Congressional Requestors
In fiscal year 1999, the federal government spent about $10 billion to
combat terrorism. Over 40 federal departments, agencies, and bureaus have a
role in combating terrorism. The amount of spending and the large number of
agencies involved have prompted some Members of Congress to question who is
in charge of U.S. efforts to combat terrorism, how the federal government is
organized to prevent and respond to terrorism on U.S. soil, and how
resources are being allocated.
Based on these concerns, and recognizing that other countries have had more
experience dealing with terrorist attacks within their borders, you asked us
to provide information on (1) how other governments are organized to combat
terrorism and (2) how they allocate their resources to combat terrorism. We
selected Canada, France, Germany, Israel, and the United Kingdom for the
focus of our work.1
Over the years, we have found problems with efforts to combat terrorism in
the United States. For example, we reported in 1999 that the overall command
(i.e., who is in charge) at a terrorist incident was not clearly designated
or agreed to among federal, state, and local governments.2 In 1998, we
reported that some federal resources to combat terrorism were being
increased without a clear link to likely threats and that programs were
being developed based on vulnerabilities, not likely terrorist attacks.3 We
also reported in 1999 that these programs potentially duplicated
existing federal emergency response capabilities.4 A list of related GAO
products appears at the end of this report.
The information in this report describes similarities we found in how the
five countries we examined are organized and how they allocate resources to
combat terrorism. The appendixes provide more details on each individual
country. Since our objectives were to describe the efforts of these other
countries, we did not compare or contrast this information with how the
United States is organized to combat terrorism and we are not making any
recommendations.
The five countries we examined have similarities in how they are organized
to combat terrorism.
· The countries generally have the majority of organizations used to combat
terrorism under one lead government ministry. However, because many other
ministries are also involved, the countries have created interagency
coordination bodies to coordinate both within and across ministries. For
example, while many countries generally have their intelligence and law
enforcement organizations under their ministries of interior or equivalent,
they also need to coordinate with their ministries of foreign affairs,
defense, and health or emergency services.
· The countries have clearly designated who is in charge during a terrorist
incident--typically their national or local police.
· The countries have national policies that emphasize prevention of
terrorism. To achieve their policies, the countries use a variety of
strategies, including intelligence collection, police presence, and various
security measures such as physical barriers at the entrances to public
buildings.
· These countries primarily use their general criminal laws (e.g., those for
murder or arson) to prosecute terrorists. The countries also have special
terrorism-related laws that allow for special investigations or prosecution
mechanisms and increased penalties.
· The countries' executive branches provide the primary oversight of
organizations involved in combating terrorism. This oversight involves
reviewing the programs and resources for effectiveness, efficiency, and
legality.
The five countries we examined also had similarities in how they allocate
resources to combat terrorism. Officials in the ministries involved said
they make resource allocations based upon the likelihood of threats taking
place, as determined by intelligence assessments. While the officials we met
with discussed resource levels in general, none of the five countries
tracked overall spending on programs to combat terrorism. Such spending was
imbedded in other accounts for broad organizational or functional areas such
as law enforcement, intelligence, and defense. Officials in all countries
told us that because of limited resources, they made funding decisions for
programs to combat terrorism based on the likelihood of terrorist activity
actually taking place, not the countries' overall vulnerability to terrorist
attack. They said their countries maximize their existing capabilities to
address a wide array of threats, including emerging threats, before they
create new capabilities or programs.
All five countries we visited have parliamentary style governments with
various ministries that provide an array of government services. For
example, a ministry of the interior may provide national law enforcement and
intelligence services. In a parliamentary style of government, the executive
branch has the dominant role in the development of policy and strategy.
Members of the legislative branch generally make up the cabinet, which under
the prime minister or the chancellor leads the executive branch of
government.5 The prime minister or the chancellor also leads the majority
political party, and because of party discipline, the majority party in the
legislature does not provide an independent role and the minority party does
not have much of a role in policy development.6
Some of the countries we visited have strong central governments, while
others have strong regional or state governments. For example, Canada with
its provinces and Germany with its states represent countries that have
relatively strong regional governments compared to France, Israel, and the
United Kingdom that have relatively strong central governments. To some
extent, the division of power between the central and regional governments
determines how these countries organize their efforts to combat terrorism.
For example, in some countries the national police play a key role, while in
other countries the regional or local police play a key role.
Officials in Canada, France, and Germany told us that the current threat
from terrorism in their countries is low. According to a 1998 Department of
State report on global terrorism, terrorism in Europe has declined, in part,
because of the increased vigilance by security forces and the recognition by
some terrorist groups that long-standing political and ethnic controversies
should be addressed by negotiations. For example, the remnants of Germany's
Red Army Faction, once among the world's deadliest, announced the
dissolution of their organization. In Israel, officials indicated that the
level of terrorism fluctuates with the peace process--terrorism typically
increases when the peace process is working, as those opposed to the peace
process try to derail it through violence. In the United Kingdom, officials
said that terrorism related to Northern Ireland continues to take place and
poses a real threat depending, in part, on developments in the peace
process. They added that although activity is at historically low levels,
the threat remains and is linked to developments in the peace process.
Officials from all five countries cited the threat of terrorists using
chemical, biological, radiological, and nuclear weapons as particularly
unlikely.
Oversight Are Similar
The five countries we examined have similarities in how they are organized
to combat terrorism. Specifically, each country places the majority of
resources for combating terrorism under one ministry, but each recognizes
that it must coordinate its efforts to develop national policy on combating
terrorism so it has interagency coordination bodies. Each country also has
clearly designated leadership at the scene of terrorist incidents. The five
countries have policies and strategies that emphasize the prevention of
terrorism using resources such as intelligence collection, police presence,
and security measures. In addition, each country uses its general criminal
laws (e.g., those for murder or arson) to prosecute terrorists. The
countries also have special terrorism-related laws that allow for special
investigation or prosecution mechanisms, and increased penalties. In each of
the five countries, the executive branch provides the primary oversight of
organizations involved in combating terrorism.
In four countries, most of the resources to combat terrorism--law
enforcement and intelligence services--are centralized under a lead agency,
generally the countries' ministry of interior or equivalent.7 For example,
the French Ministry of Interior includes the National Police and the two
domestic intelligence agencies that have a primary role in combating
terrorism. However, officials from all the countries said they view
counterterrorism as an intergovernmental effort that requires coordination
among law enforcement, intelligence, and other parts of the government that
may be involved in combating terrorism, including foreign affairs, the
military, and health and emergency services. Since they view combating
terrorism as an interagency effort, officials in each country identified the
prime minister or the chancellor as the one person in charge of combating
terrorism. Below that level, the effort to combat terrorism requires an
interagency body to formulate policy, coordinate activities, and provide
recommendations to the prime minister or the chancellor. In Israel, for
example, there is an interagency body called the Bureau for Counterterrorism
that coordinates activities and provides advice to the prime minister
regarding terrorism matters. Appendix I shows the interior ministries or
equivalent that lead efforts to combat terrorism and the interagency bodies
that provide coordination and advice on terrorism issues to the prime
minister or the chancellor.
All five countries have clearly designated who is to be in charge during a
terrorist incident. For example, in the United Kingdom, the local Chief
Constable (i.e., chief of police) has overall control of all aspects of
handling a terrorist incident. For Israel, the National Police are in
command within Israel, and the military are in command in the occupied
territories. Appendix I provides details on who is designated to command at
terrorist incidents for the rest of the countries.
Incident leadership is reinforced through written agreements and contingency
plans or other agreements. For example, in Canada, the Royal Canadian
Mounted Police has written agreements with major municipal police
departments on who leads the incident response. The French government has
written interagency contingency plans with command and control details for
such terrorist situations as a heightened threat, aircraft hijacking, ship
hijacking, or a chemical attack. Officials in the five countries stated that
they use the agreements or plans as the basis of their exercises to practice
their response, which further reinforces who leads at the incident site.
Clear incident command is also strengthened because the incident commander
controls all response elements, including police, fire, medical, and other
emergency services. Thus, there is one commander for police activities
(e.g., assaults, arrest, and gathering evidence) as well as other emergency
activities (e.g., evacuation, search and rescue, medical treatment, and
decontamination). Officials in the United Kingdom cited the importance of
having one person--the Chief Constable--in charge of the entire response.
Officials in the other four countries made similar comments on the need for
clear and unified leadership for the whole range of activities in a response
to a terrorist attack.
Each country had developed policies to combat terrorism through their
experience with various terrorist groups. The five countries' national
policies to combat terrorism, which were not always written, emphasized
prevention. Canadian officials were the only ones to provide us with their
written policies on terrorism. Officials in the other countries told us they
had no written policies. To implement their national policies, these
countries had strategies that included intelligence collection, police
presence, and other deterrent measures.
For example, the strategies in all five countries include domestic
intelligence, and each has at least one security intelligence organization
that gathers intelligence on domestic terrorist activities. Officials we
spoke with said that an effective intelligence capability is essential for
preventing acts of terrorism in their countries. In general, the role of
their domestic security intelligence organizations is to prevent acts of
terrorism by gathering information through a variety of sources and methods;
assessing the threats to security; and monitoring and sometimes disrupting
the activities of certain groups considered to be a threat within the
country.
All of the countries' domestic intelligence organizations are separate from
their law enforcement organizations. In Canada, France, and the United
Kingdom, these organizations are under a single ministry. In Germany there
are parallel federal and state intelligence and law enforcement
organizations, and both are under their respective ministries of the
interior. In Israel, the intelligence organizations report directly to the
prime minister, and the national police are under the Ministry of Public
Security. Cooperation between both law enforcement and intelligence
organizations was cited by officials in all five countries as important, in
part, because the domestic intelligence organizations do not have powers of
arrest. Law enforcement organizations become involved in combating terrorism
when information from the intelligence services indicates that criminal
activity has occurred, or is likely to occur, or when their own criminal
intelligence sources indicate such. Appendix II shows the principal law
enforcement and intelligence organizations of the countries we visited.
In addition to a strong intelligence capability, we found that the
countries' strategies included using a visible police presence to prevent
acts of terrorism. For example, in France, when there is a specific
terrorist threat, law enforcement increases its public presence in a visible
show of force. Likewise, the German Federal Border Police can provide
additional manpower to supplement state police at events such as political
demonstrations. In Israel, the National Police, as well as military
personnel, is present at various locations throughout the metropolitan areas
to respond to incidents as needed.
As part of their prevention strategies, the five countries use a variety of
other techniques to deter terrorist attacks. For example, all five countries
use physical barriers in certain critical areas and government buildings to
deter direct attacks. Other techniques are as follows. In Israel,
individuals and their belongings are often physically searched by police,
defense personnel, or security contractors and pass through metal detectors
before entering such places as shopping centers, airports, and local
attractions. In the United Kingdom, police use video cameras to monitor
daily events and watch for suspicious activity in London. In France, persons
entering government buildings typically walk through metal detectors.
All five countries use their general criminal laws to prosecute offenses
committed during a terrorist act, such as the crimes of murder, arson,
kidnapping, and hijacking. According to Canadian officials, treating
terrorism as ordinary crime removes the political element and thereby
dilutes the effectiveness of the terrorist act. The countries have also
enacted a variety of special laws that relate to terrorism that may include
a statutory definition or description of terrorism, or may invoke special
investigation or prosecution procedures, or provide for increased penalties.
Under French law, certain criminal offenses are considered terrorism when
the acts are intentionally linked to an individual or group whose purpose is
to cause a serious disruption of public order through intimidation or
terror. Penalties may be increased if a criminal offense is related to such
terrorism. France also has special judicial procedures to address terrorism
such as special courts and prosecutors. Germany's criminal code has a
special prohibition against the formation and support of a terrorist
association. In addition to its general criminal laws, Israel has two
principal laws that govern terrorism that contain a number of criminal
offenses such as supporting terrorist organizations. The United Kingdom has
two principal terrorism laws that designate a number of criminal offenses
relating to membership in and support of terrorist organizations.
Appendix III provides additional information on the terrorism-related laws
in the five countries.
Oversight reviews of programs and resources for effectiveness, efficiency,
and legality are primarily the responsibility of those ministers in the
executive branch that have a role in combating terrorism. Officials told us
that in their parliamentary style of government, ministers are accountable
for oversight and that this function is embedded in the ministers'
responsibilities. They generally viewed oversight as an ongoing routine
function of agency management, not an independent or separate review
function. For example, in France, the Minister of the Interior, through
their daily activities, reviews or oversees the activities of those
resources within the Ministry.
The legislatures in these countries do not hold oversight hearings or write
reports that evaluate programs to combat terrorism. In these parliamentary
style governments, the legislative branches do not provide ongoing
independent oversight of efforts to combat terrorism. While the five
countries do conduct some legislative review of national security activities
(e.g., through designated legislative committees), these reviews generally
have not focused on activities to combat terrorism. At times, some members
of the legislative branch are included in standing or ad hoc executive
oversight bodies. In Canada and Israel, independent reviews of activities to
combat terrorism are done by their national audit agencies. Appendix IV
summarizes oversight organizations and functions in the five countries we
visited.
Officials in the ministries involved in combating terrorism within the five
countries we visited said they made resource allocations based upon the
likelihood of threats taking place, as determined by intelligence
assessments. While the officials we met with discussed resource levels in
general, none of the five countries tracked overall spending on programs to
combat terrorism. Such spending was imbedded in other accounts for broad
organizational or functional areas such as law enforcement, intelligence,
and defense. Due to resource constraints, they said their countries maximize
their existing capabilities to address a wide array of threats, including
emerging threats, before they create new capabilities or programs.
The five countries we reviewed receive terrorist threat information from
their civilian and military intelligence services and foreign sources. Using
various means, each of the countries' intelligence services continuously
assess these threats to determine which ones could result in terrorist
activity and require countermeasures, which ones may be less likely to occur
but may emerge later, and which ones are unlikely to occur. Officials in all
countries told us that because of limited resources, they made funding
decisions for programs to combat terrorism based on the likelihood of
terrorist activity actually taking place, not the countries' overall
vulnerability to terrorist attack. For example, each of the countries may be
vulnerable to a chemical, biological, radiological, or nuclear attack by
terrorists, but officials believe that such attacks are unlikely to occur in
the near future for a variety of reasons, including the current difficulty
in producing and delivering these types of weapons. Furthermore, officials
in one country told us that the effects of these types of weapons would
alienate the population from the political aim of the terrorist groups and
therefore did not view this type of attack as likely. Officials we spoke
with believed that conventional bombs and other traditional means, such as
hijacking, are more likely to occur.
Threats
For less likely but emerging threats, officials in the five countries told
us that they generally try to maximize their existing capabilities for
responding to such threats, rather than create new programs or capabilities.
For example, the same capabilities used to respond to a fire, industrial
explosion, or chemical spill would be used for a terrorist incident
involving chemical, biological, radiological, or nuclear weapons. In
addition, officials in each country said additional capabilities from
neighboring states, provinces, cities, or national governments could be used
by local authorities if the situation exceeded their capabilities. For
example, Germany plans to rely on existing capabilities within the states
rather than develop new federal capabilities. Likewise, Israel has not
developed new capabilities, but it has a nationwide program that provides
gas masks and training to its citizens for defense against chemical or
biological attack in wartime that officials said has use for terrorist
attacks. The countries generally did not have major training programs in
place to train emergency response personnel for chemical, biological,
radiological, or nuclear attacks. However, the United Kingdom has a limited
program to train selected police officials as incident commanders and is
considering a training program for response personnel in selected locations.
Also, Canada has launched a policy initiative to develop a strategy to
strengthen national counterterrorism response capability, particularly the
ability to respond to chemical, biological, radiological, and nuclear
terrorist attacks. Only France has created new capabilities to respond to
chemical, biological, radiological, and nuclear terrorist attacks.
We provided a draft of this report to officials from all five countries for
their review and comment. All of the officials provided us with oral
comments indicating they agreed with the report's overall content and our
description of their countries' efforts. Officials from Canada and the
United Kingdom also provided written comments of a technical nature, and we
incorporated their changes where appropriate.
We examined how Canada, France, Germany, Israel, and the United Kingdom were
organized to combat terrorism. In selecting these countries, we considered
the historic level of terrorism and related activities within their borders,
the type of government, and our ability to conduct work in the countries. We
also consulted with officials from the U.S. State Department's Office of the
Coordinator for Counter Terrorism and other experts in the field of
terrorism inside and outside the federal government about which countries we
should examine. Based on our criteria and these consultations, we selected
Canada, France, Germany, Israel, and the United Kingdom.
Our scope was limited by two factors. First, we did not have audit authority
in the five countries; thus, we relied on the cooperation of foreign
officials. While we had numerous meetings with officials in the five
countries, we usually did not have access to many of their internal
documents, classified plans, or policy evaluations. Second, we were in each
country for a relatively short time, ranging from 1 to 2 weeks. As a result
of these limitations, we sought to describe how each country organized its
programs to combat terrorism, not to evaluate the operations or the
effectiveness of those programs. For our review of terrorism-related laws,
we relied on officials to identify appropriate statutes and did not do our
own comprehensive research or analysis of the countries' laws.
Because of the limitations we faced in reviewing foreign countries' policies
and programs, we asked the foreign officials to comment on the accuracy of
our work. After we conducted our overseas visits, we wrote summaries
documenting our observations and conclusions and sent them to the officials
for their verification, review, and comment. All of the officials provided
written comments, and we made changes to our summaries as appropriate. We
then used these summaries as the basis for drafting this report.
Our overall methodology consisted of reviewing applicable documents and
interviewing a broad array of national-level government officials whose
organizations had a significant role in combating terrorism. Where possible,
we met with regional and local government officials in the countries we
visited. We also met with contacts outside the government to provide us with
different perspectives on the countries' efforts to combat terrorism. For
example, we met with experts from academia, research organizations, the
media, and other nongovernmental organizations. For our specific objectives,
we interviewed officials at the level of government most able to provide us
information on our topics.
To describe how the five governments were organized to combat terrorism,
including oversight of terrorism programs, we met with officials from the
prime minister's or chancellor's office; legislative committee members with
responsibility regarding counter terrorism programs; and officials within
the ministries of interior, justice, defense, and other ministries that had
a role in combating terrorism. We also met with officials that have direct
responsibility for responding to and managing a terrorist incident. These
included officials who represented the countries' national police,
intelligence, military, and emergency medical organizations. To describe
oversight of terrorism programs, we met with members of legislative
committees, and national audit organizations and officials of inspector
general offices where they were present.
To describe how the countries allocate their resources to combat terrorism,
we met with many of the same officials above and focused our discussions on
how they analyzed threats and allocated resources for these programs.
We conducted our review from May 1999 through January 2000 in accordance
with generally accepted government auditing standards.
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution of this report until
30 days after its issue date. At that time, we will send copies to
appropriate congressional committees and the federal agencies that combat
terrorism. We will also make copies available to other interested parties
upon request.
If you have any questions about this report, please contact me or Ray
Decker, Acting Associate Director for National Security Preparedness Issues,
at (202) 512-5140. Other major contributors to this report are listed in
appendix V.
Norman J. Rabkin
Director, National Security Preparedness Issues
List of Congressional Requesters
The Honorable Ted Stevens
Chairman
The Honorable Robert Byrd
Ranking Member
Committee on Appropriations
United States Senate
The Honorable Christopher S. Bond
Chairman
The Honorable Barbara Mikulski
Ranking Member
Subcommittee on Veterans Affairs, Housing and
Urban Development and Independent Agencies
Committee on Appropriations
United States Senate
The Honorable Ike Skelton
Ranking Member
Committee on Armed Services
House of Representatives
The Honorable Christopher Shays
Chairman
Subcommittee on National Security, Veterans
Affairs, and International Relations
Committee on Government Reform
House of Representatives
Security-Related Policy Development and Incident Leadership in Canada,
France, Germany, Israel, and the United Kingdom
Continued from Previous Page
Canada France Germany Israel United Kingdom
Interministerial
Liaison Committee
Against Terrorism
(Comité
Interministériel
Privy Council de Lutte
Office is the Anti-Terroriste)
office that is a high level Coordinator for
provides committee that Intelligence
advice to the develops policy Official Committee
prime minister and includes the (Koordinierung der Bureau for on Terrorism
and the Prime Minister Nachrichtendienste Counterterrorism makes coordinates
cabinet on and Ministers of des Bundes) is a recommendations on interagency
terrorism Interior, direct advisor to terrorism policy and counter-terrorism
issues. The Defense, Justice, the Chancellor and works with agencies policy development
develops a general involved in combating
Interagency Privy Council and Foreign policy framework and terrorism to formulate with input from
policy Office obtains Affairs. coordinates state recommendations. The the organizations
coordination input from the issues. The Federal Bureau includes directly involved
body Solicitor Anti-Terrorism Ministry of the representatives from in combating
General's Coordination Unit terrorism (Home
Office for Interior includes all agencies involved Office, Foreign
national (Unité de police, in combating terrorism and Commonwealth
policy and the Coordination de intelligence, and and reports directly toOffice, and
Ministry of la Lutte border police, and the Prime Minister. Association of
Foreign Anti-Terroriste) provides federal Chief of Police
Affairs for is a working policy for combating Officers).
international level terrorism.
policy. coordination
group that
includes agencies
from the
Ministries of
Interior and
Defense that
coordinate
operations.
Solicitor
General is the
ministry that State-level
includes the Ministry of Ministries of Ministry of Internal
intelligence Interior Interiors Security includes
and law (Ministère de resources to combat Home Office is
enforcement L'Intérieur) (Staatsministerium terrorism--the Nationalequivalent to an
resources for hosts the des Innern) includes Police and the Border Interior Ministry
combating interagency police, Guard. and manages
Anti-Terrorism
Organization terrorism. Coordination intelligence, and domestic terrorism
with primary Within this Unit. This emergency Ministry of Defense programs. It has
responsibility ministry the ministry includes preparedness. Each provides law purview over law
for combating Canadian the National state ministry of enforcement in the enforcement,
terrorism Security Police, the interior is occupied territories domestic
Intelligence represented in a and the Home Front intelligence, and
Service Central Council of Interior Command−a commandemergency
provides the Headquarters for Ministers that within the management.
overall threat Surveillance of addresses a variety military−provides
assessment for the Territory, of intelligence, law civil assistance
Canada and the and the General enforcement, and management through out
Royal Canadian Intelligence emergency Israel.
Mounted Police Central Service. preparedness issues.
provides law
enforcement.
Canada France Germany Israel United Kingdom
Royal Canadian
Mounted Police
is Canada's
national Federal police would
police force. take command over
Canada also the terrorist
has municipal incident upon National Police or
police in direction of the Military are in charge
larger cities. federal prosecutor, of a terrorist incidentLocal Chief
The Mounted or at the request of in Israel, depending onConstable is the
Police and the state. The the location of the official in charge
municipal Préfet is a federal criminal incident. In the at the incident
police forces regional police occupied territories, and decides
(Bundeskriminalamt)
Leadership have political are under the the military responds whether to bring
during an memorandums of appointee who federal ministry of to and remains in in other support
incident understanding supervises police interior. First charge of a terrorist as needed. The
describing how and emergency incident. In the rest entire government
law activities at a responders would be of Israel, the Nationalworks to support
enforcement terrorist scene. the state police Police respond to an the police at the
will be (Ländeskriminalamt) incident and remain in scene.
coordinated under the state's charge throughout the
and who will interior ministry. incident.
be in charge. State police would
The Royal provide support to
Canadian their federal
Mounted Police counterparts.
are under the
Ministry of
the Solicitor
General.
Note: For overseas terrorist incidents involving its citizens, the Ministry
of Foreign Affairs or equivalent in each country typically provides input to
the interagency coordination body on terrorism policy.
Source: Our interviews with selected officials and review of documents from
each country.
Principal Law Enforcement and Intelligence Organizations in Canada, France,
Germany, Israel, and the United Kingdom
Continued from Previous Page
Canada France Germany Israel United Kingdom
Royal Canadian
Mounted Police
is the national National Police
police force
that has (Direction
primary Générale de la
responsibility Police
for prevention, Nationale) is
protection, and the lead Federal Criminal Police
investigation civilian (Bundeskriminalamt) is Israeli National
of offenses national police responsible for protection Police is the
that constitute force that has and investigation of acts of principal civilian
a threat to the jurisdiction in terrorism and extremism and police force and County Police
security of large urban is under the Ministry of the is under the Forces. Each
Canada. They areas. It is Interior. Ministry of Publiccounty or group
also serve as divided into Security. of counties has
provincial and specialized State Criminal Police a police force
municipal directorates for (Ländeskriminalamt) is Border Guard is led by a chief
police in many such functions responsible for criminal the National constable. The
areas across as border investigations within the Police's principalMetropolitan
Law Canada and are security and states and may assist the mobile task force,Police Service
Enforcement under the protection of federal police during focuses on in London has
Organizations Ministry of the dignitaries and terrorism cases. Under the internal security,the
Solicitor is under the states' ministries of and has a special Anti-Terrorist
General. Ministry of the interior. antiterrorist Branch, which
Interior. unit. the chief
Two provinces Federal Border Guard constables of
and most National (Bundesgrenzschutz) provides Israeli Defense other police
municipalities Gendarmerie security at the borders, Force provides lawforces can call
have their own transportation sites, and enforcement in theon for
police forces. (Direction other federal areas. It occupied assistance.
Many have Générale de la assists state police when territories.
agreements with Gendarmerie large forces are needed and
the Royal Nationale) is is under the Ministry of the
Canadian responsible for Interior.
Mounted Police law enforcement
to facilitate in small towns
cooperation and rural areas
during and is under the
terrorist Ministry of
incidents. Defense.
Canada France Germany Israel United Kingdom
Central
Headquarters for
Surveillance of
the Territory
Canadian (Direction de la
Security Surveillance du
Intelligence Territoire) is British
Service is responsible for Security
responsible for intelligence The Federal Office for the Service gathers
collection, regarding Protection of the intelligence
analyses, internal threats Constitution (Bundesamt für Israeli Security internally to
production, and from external Verfassungsschutz) collects Agency is investigate and
dissemination sources and is and analyzes intelligence responsible for disrupt
of security under the relating to politically internal terrorist
intelligence on Ministry of the motivated extremism, intelligence activity,
terrorism. It Interior, including terrorism, and collection and provide advice
coordinates with its state
Domestic participates in Director of the counter-parts. Under the analyses, to the
Intelligence information National Police. Ministry of the Interior. counterespionage, government on
Organizations sharing with and the preventiondomestic
allied General of terrorist acts.security
countries but Intelligence State Offices for the It reports matters, and
does not Central Service Protection of the directly to the issue threat
independently Constitution (Landesämter Prime Minister andassessments. It
conduct (Direction für Verfassungsschutz) have is formerly the reports
operations Centrale des similar roles but are General Security directly to the
abroad and is Renseignenments independent of the federal Service. Home Office
under the Généraux) is government and are under the and/or the
Ministry of the responsible for states' ministries of Prime Minister
Solicitor intelligence interior. and is also
General. regarding known as MI-5.
internal threats
from internal
sources and is
under the
Ministry of the
Interior,
Director of the
National Police.
Department of
National General
Defense Headquarters for
established Security
intelligence Overseas Secret
response teams (Direction Mossad is Israel'sIntelligence
to produce Générale de la primary foreign Service is
intelligence Sécurité intelligence Britain's lead
for supporting Exterieure) is service and foreign
senior responsible for German Intelligence Service reports directly intelligence
officials, intelligence (Bundesnnachrichte-ndienst) to the prime service. Under
planners, and gathering abroad is responsible for the minister. the Foreign and
the and is under the investigation of threats Commonwealth
Ministry of from abroad.
Other Department's Defense. Ministry of Office it
Intelligence hostage rescue Military Intelligence Defense has a reports
Organizations unit. Central Service (Militärischer section that directly to the
focuses on Prime Minister
Communications Headquarters Abschirmdienst) focuses on military and is also
Security Military intelligence matters that intelligence and known as MI-6.
Establishment Intelligence are relevant to military works with the
gathers (Direction affairs and is under the Mossad and the Government
intelligence Reseignments Ministry of Defense. Israeli Security Communications
through Militaire) Agency to prepare Headquarters
electronic collects and the annual threat collects
means and is analyzes assessment. communications
responsible for military intelligence.
protecting intelligence and
information is under the
technology Ministry of
infrastructure. Defense.
Source: Our interviews with selected officials and review of documents from
each country.
Principal Terrorism Laws, Definitions, and Other Legal Information in
Canada, France, Germany, Israel, and the United Kingdom
Continued from Previous Page
Canada France Germany Israel United Kingdom
Prevention of
Security Terrorism
Offenses Act Chapters I and II Defense and (Temporary
Emergency Act
Principal (1984) and of title II Section 129(a) (1945) and the Provisions) Act
terrorism-related Canadian (Terrorism) of the of the of 1989 and the
laws Security Penal Code and the Prevention of Northern
Intelligence Code of Criminal Criminal Code Ireland
Service Act Procedure Terrorism (Emergency
(1984) Ordinance (1948)Provisions) Act
of 1998
Neither law
Canadian specifically
Security defines
Intelligence The Penal Code terrorism, but
Service Act does ties German law the Prevention
not explicitly terrorist-related does not of Terrorism
define terrorism acts, defined as define Ordinance
but applies to "an act by an terrorism, but contains
"threats to the individual or a working criminal Both acts
security of group that uses definition prohibitions define
Canada." Such intimidation or provided by regarding a terrorism as
threats include terror to disrupt German person's "the use of
"activities public order," to government activities and violence for
the Code's general officials
Definition or within or criminal offenses. states that association withpolitical ends
description of relating to terrorism is a "terrorist [including] any
terrorism Canada directed Officials told us the permanent organiza-tion." use of violence
toward or in Such an for the purpose
support of the that although this fight for organization is of putting the
threat or use of definition does political defined as a public, or any
acts of serious not mention goals and "body of personssection of the
violence against political change of the resorting in itspublic in
persons or motivation, an act political activities to fear."
property for the would not be system through acts of violence
purpose of labeled an act of assaults calculated to
achieving a terrorism unless against cause death or
political it was linked to persons and injury to a
objective within some political property. person or to
Canada or motive or cause. threats of such
foreign state." acts of
violence."
Canada France Germany Israel United Kingdom
Section 129(a)
prohibits the
formation or
support of an
association
whose
objectives or The Northern
activities are Ireland
directed The Defense and (Emergency
toward Emergency Act, aProvisions) Act
committing holdover from of 1996, only
murder, the British applies to
genocide, or Mandate of Northern
Under the certain other Palestine, is Ireland. The
Security criminal acts used primarily Prevention of
Offenses Act, The maximum against in the occupied Terrorism
the federal allowable criminal personal territories for (Temporary
government, sentences are liberty or administrative Provisions) Act
rather than a increased when endangering enforcement of 1989,
provincial or certain criminal the public. purposes such asapplies to the
territorial offenses, such as Convicted seizure of United Kingdom
government, violent conduct, persons can be property. The in general.
prosecutes hijacking, or the barred from Prevention of
criminal use of explosives, holding public Terrorism Both acts
offenses that are linked to office and Ordinance, contain a
constitute a terrorism. France acquiring developed duringnumber of
has a special the origin of comparable
Other legal threat to the national court to rights from the State of criminal
information security of address acts of public Israel, containsoffenses
Canada, or if elections.
the victim of terrorism under both judicial relating to
the offense is the Justice While most and membership,
an Ministry, which violations of administrative participation
internationally also permits this the criminal provisions, as in, and support
protected special code are well as criminalof proscribed
person. The independent prosecuted by prohibitions organizations.
specific section to the states, against
offenses, investigate, the national membership and Subject to
however, are prosecute, and govern- ment support of a Parliamentary
still prosecuted adjudicate cases can direct the terrorist group.agreement,
under Canada's associated with overall these temporary
federal criminal terrorism. investigation According to laws will be
laws. and determine Israeli replaced later
if the state officials, they this year by
or federal are studying one permanent
police will ways to update law that would
conduct the and strengthen apply
investigation their terrorism throughout the
when laws. country and to
violations of all forms of
section 129(a) terrorism.
are suspected
or when the
crime has
national
consequences.
Note: This table is based upon laws that country officials identified as
their key statutes related to terrorism. It is not based upon a
comprehensive review of statues in the countries.
Source: Our interviews with country officials and review of legal documents
they provided.
Security-Related Oversight Organizations and Functions in Canada, France,
Germany, Israel, and the United Kingdom
Continued from Previous Page
Level of
review or Canada France Germany Israel United Kingdom
oversight
The Cabinet
Office reviews
national security
issues for the
Privy Council Prime Minister.
Office monitors National The Home
and coordinates Security Secretary is
activities related Council, responsible for
to security and formed in the British
intelligence. Interministerial 1999, providesSecurity Service.
Within the Privy Liaison Committee broad review The Foreign and
Council Office is Against Terrorism Office of the of security Commonwealth
the Security and (Comité Chancellor, Coordinator issues. Secretary is
Intelligence Interministériel for Intelligence, responsible for
de Lutte Israel's the Secret
Executive Coordinator that Anti-Terroriste) provides executive Security Intelligence
monitors such oversight for national
activities on a consists of issues. Cabinet also Service and the
day-to-day basis. high-level provides Government
Canada also has officials executive Communications
interdepartmental involved in review and Headquarters.
committees, combating consists of Other executive
including the terrorism. the principle committees are
Interdepartmental ministers who the Permanent
Committee on have a role inSecretaries'
Security and combating Committee on the
Intelligence. terrorism. Intelligence
Services and the
Ministerial
Committee on
Intelligence
Services.
The Special Senate
Committee on Senior
Security and parliamentarians
Intelligence sit on the
reviewed Intelligence and
counterterrorism Security
in 1998; Committee.
additional reviews Parliamentarians
are done on an ad The Parliament has a Subcommittee also served as
hoc basis. For standing committee on on Commissioners for
intelligence and Commissions are Internal Affairs that Intelligence the British
monitors the police and is part of theSecurity Service
Legislativepolice protection formed if the intelligence standing and the Secret
issues Canada has problems are
the Security found. services' compliance to committee on Intelligence
Intelligence the law (usually in Foreign Service to review
Review Committee, response to a specific Affairs and law enforcement
the Royal Canadian incident). Defense. and intelligence
Mounted Police activities. There
Public Complaints is also a
Commission, and parliamentary
the Royal Canadian tribunal to
Mounted Police investigate
External Review public
Committee. complaints.
Level of
review or Canada France Germany Israel United Kingdom
oversight
Auditor General,
Canada's
independent State
government audit The Court of Comptroller's
organization, Accounts (Cour The Federal Court of Office has The National
reported on des Comptes), is Audit broad Audit Office, the
counterterrorism France's (Bundesrechnung-shof), authority and United Kingdom's
activities in 1996 independent Germany's federal can choose itsnational
Other with a follow-up government audit auditor conducts fiscal agenda. Issuedgovernment audit
report in 1998. organization, but audits, and each a report on organization has
Canada also has an it has not government department's Israel's not focused on
inspector general focused on internal inspectors overlapping counterterrorism
only for counterterrorism monitor compliance with intelligence issues.
intelligence issues. internal regulations. activities in
issues that 1999.
reports to the
Solicitor General.
Note: In all the countries, their judicial systems served a final oversight
function over the legality of executive branch activities in criminal
prosecutions.
Source: Our interviews with country officials and review of documents from
each country.
GAO Contacts and Staff Acknowledgments
Stephen L. Caldwell (202) 512-9610
In addition to the name above, Colin L. Chambers, Davi M. D'Agostino,
Kathleen Joyce, Paul Rades, Lorelei St. James, Karen Thompson, and Raymond
J. Wyrsch made key contributions to this report.
Related GAO Products
Combating Terrorism: Need to Eliminate Duplicate Federal Weapons of Mass
Destruction Training (GAO/NSIAD-00-64, Mar. 21, 2000).
Combating Terrorism: Chemical and Biological Medical Supplies Are Poorly
Managed (GAO/HEHS/AIMD-00-36, Oct. 29, 1999).
Combating Terrorism: Observations on the Threat of Chemical and Biological
Terrorism (GAO/T-NSIAD-00-50, Oct. 20, 1999).
Critical Infrastructure Protection: Fundamental Improvements Needed to
Assure Security of Federal Operations (GAO/T-AIMD-00-7, Oct. 6,1999).
Critical Infrastructure Protection: Comprehensive Strategy Can Draw on Year
2000 Experiences (GAO/AIMD-00-1, Oct. 1, 1999).
Information Security: The Proposed Computer Security Enhancement Act of 1999
(GAO/T-AIMD-99-302, Sept. 30, 1999).
Combating Terrorism: Need for Comprehensive Threat and Risk Assessments of
Chemical and Biological Attack (GAO/NSIAD-99-163,
Sept. 7, 1999).
Combating Terrorism: Analysis of Federal Counterterrorist Exercises
(GAO/NSIAD-99-157BR, June 25, 1999).
Combating Terrorism: Observations on Growth in Federal Programs
(GAO/T-NSIAD-99-181, June 9, 1999).
Combating Terrorism: Analysis of Potential Emergency Response Equipment and
Sustainment Costs (GAO/NSIAD-99-151, June 9, 1999).
Combating Terrorism: Use of National Guard Response Teams Is Unclear
(GAO/NSIAD-99-110, May 21, 1999).
Combating Terrorism: Issues to Be Resolved to Improve Counterterrorist
Operations (GAO/NSIAD-99-135, May 13, 1999).
Combating Terrorism: Observations on Biological Terrorism and Public Health
Initiatives (GAO/T-NSIAD-99-112, Mar. 16, 1999).
Combating Terrorism: Observations on Federal Spending to Combat Terrorism
(GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).
Combating Terrorism: Opportunities to Improve Domestic Preparedness Program
Focus and Efficiency (GAO/NSIAD-99-3, Nov. 12, 1998).
Combating Terrorism: Observations on the Nunn-Lugar-Domenici Domestic
Preparedness Program (GAO/T-NSIAD-99-16, Oct. 2, 1998).
Combating Terrorism: Observations on Crosscutting Issues
(GAO/T-NSIAD-98-164, Apr. 23, 1998).
Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and
Target Program Investments (GAO/NSIAD-98-74, Apr. 9, 1998).
Combating Terrorism: Spending on Governmentwide Programs Requires Better
Management and Coordination (GAO/NSIAD-98-39, Dec. 1, 1997).
Combating Terrorism: Federal Agencies' Efforts to Implement National Policy
and Strategy (GAO/NSIAD-97-254, Sept. 26, 1997).
(702009)
1. We selected these five countries based on terrorism-related activities
within their borders, the type of government, and our ability to conduct
work in these countries. For more details on our selection criteria, and how
we conducted our work, see our scope and methodology section.
2. Combating Terrorism: Issues to Be Resolved to Improve Counterterrorism
Operations (GAO/NSIAD-99-135, May 13, 1999).
3. Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and
Target Program Investments (GAO/NSIAD-98-74, Apr. 9, 1998).
4. Combating Terrorism: Observations on Federal Spending to Combat Terrorism
(GAO/T-NSIAD/GGD-99-107, Mar. 11, 1999).
5. For the purposes of this report, we use the term "executive branch" to
refer to those ministries, departments, or organizations that perform
executive-type functions. The term "legislative branch" refers to those
bodies of elected representatives that enact laws such as the Parliaments in
Canada and the United Kingdom, the National Assembly and Senate in France,
the Bundestag and Bundesrat in Germany, and the Knesset in Israel.
6. While minority parties generally do not have a large role in policy
development, they could have a large role in a coalition government where
they form a coalition and align with a larger party.
7. In Israel, the National Police are under one ministry; however, the main
domestic and international intelligence services are not in the same
ministry as the National Police and report directly to the prime minister.
*** End of document. ***