United States Government Accountability Office

Report to Congressional Requesters

January 2016

FIREARMS
TRAFFICKING
U.S. Efforts to Combat
Firearms Trafficking to
Mexico Have
Improved, but Some
Collaboration
Challenges Remain

GAO-16-223

January 2016

FIREARMS TRAFFICKING

Highlights of GAO-16-223, a report to
congressional requesters

Why GAO Did This Study
Violent crimes committed by drug
trafficking organizations in Mexico
often involve firearms, and a 2009
GAO report found that many of these
firearms originated in the United
States. ATF and ICE have sought to
stem firearms trafficking from the
United States to Mexico.
GAO was asked to undertake a followup review to its 2009 report (GAO-09709) addressing these issues. This
report examines, among other things,
(1) the origin of firearms seized in
Mexico that have been traced by ATF,
(2) the extent to which collaboration
among U.S. agencies combating
firearms trafficking has improved, and
(3) the extent to which the National
Southwest Border Counternarcotics
Strategy measures progress by U.S.
agencies to stem firearms trafficking to
Mexico. To address these objectives,
GAO analyzed program information
and firearms tracing data from 2009 to
2014, and met with U.S. and Mexican
officials on both sides of the border.

What GAO Recommends
GAO recommends that the Secretary
of Homeland Security and the Attorney
General of the United States take
steps to formally monitor
implementation of the 2009 MOU
between ATF and ICE. GAO also
recommends that ONDCP establish
comprehensive indicators that more
accurately reflect progress made in
efforts to stem arms trafficking to
Mexico. The Departments of Homeland
Security and Justice, and ONDCP
agreed with GAO’s recommendations.

View GAO-16-223. For more information,
contact Jessica Farb at (202) 512-6991 or
farbj@gao.gov.

U.S. Efforts to Combat Firearms Trafficking to Mexico
Have Improved, but Some Collaboration Challenges
Remain

What GAO Found
According to data from the Department of Justice’s Bureau of Alcohol, Tobacco,
Firearms and Explosives (ATF), 73,684 firearms (about 70 percent) seized in
Mexico and traced from 2009 to 2014 originated in the United States. ATF data
also show that these firearms were most often purchased in Southwest border
states and that about half of them were long guns (rifles and shotguns).
According to Mexican government officials, high caliber rifles are the preferred
weapon used by drug trafficking organizations. According to ATF data, most
were purchased legally in gun shops and at gun shows in the United States, and
then trafficked illegally to Mexico. U.S. and Mexican law enforcement officials
also noted a new complicating factor in efforts to fight firearms trafficking is that
weapons parts are being transported to Mexico to be later assembled into
finished firearms, an activity that is much harder to track.
Origin of Firearms Seized in Mexico and Traced by ATF, 2009-2014

Note: These figures reflect firearms seized by Mexican authorities and traced by ATF, not all firearms seized in
Mexico.

In 2009, GAO reported duplicative initiatives, and jurisdictional conflicts between
ATF and the Department of Homeland Security’s Immigration and Customs
Enforcement (ICE). That year, in response to GAO’s recommendations on these
problems, ATF and ICE updated an interagency memorandum of understanding
(MOU) to improve collaboration. ATF and ICE have taken several steps since
then to improve coordination on efforts to combat firearms trafficking, such as
joint training exercises and conferences to ensure that agents are aware of the
MOU and its jurisdictional parameters and collaboration requirements. However,
GAO found that ATF and ICE do not regularly monitor the implementation of the
MOU. In the absence of a mechanism to monitor MOU implementation and
ensure that appropriate coordination is taking place between the two agencies,
GAO found that gaps in information sharing and misunderstandings related to
their roles and responsibilities persist.
The indicator used to track U.S. agencies’ efforts to stem firearms trafficking to
Mexico in the Office of National Drug Control Policy’s (ONDCP) National
Southwest Border Counternarcotics Strategy, by itself, does not adequately
measure progress. ONDCP tracks progress based on the number of arms seized
in Mexico and traced to the United States; however, this number does not reflect
the total volume of firearms trafficked from the United States, and it does not take
into account other key supporting agency actions and activities as measures.
United States Government Accountability Office

Contents

Letter

1
Background
Most Firearms Seized in Mexico That Are Traced by ATF Come
from the United States, and Most Are Purchased in Southwest
Border States
ATF and ICE Have Taken Steps to Improve Collaboration, but
Lack of Monitoring May Contribute to Coordination Challenges
U.S.-Mexico Collaboration on Firearms Trafficking Was Scaled
Back after 2012, but While Challenges Continue, Bilateral
Efforts Have Recently Been Gaining Momentum
The Current Weapons Chapter Indicator in the National Southwest
Border Counternarcotics Strategy Does Not Adequately
Measure the Progress of U.S. Agencies in Stemming Firearms
Trafficking to Mexico
Conclusions
Recommendations for Executive Action

3

29
32
32

Appendix I

Scope and Methodology

35

Appendix II

Comments from the Department of Homeland Security

38

Appendix III

GAO Contact and Staff Acknowledgments

40

8
20
25

Tables
Table 1: Key Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF) Efforts and Resources to Stem Firearms
Trafficking to Mexico
Table 2: Key Immigration and Customs Enforcement (ICE) Efforts
and Resources to Stem Firearms Trafficking to Mexico
Table 3: Supporting Actions and Activities in the Weapons
Chapter of Office of National Drug Control Policy’s
(ONDCP) 2013 National Southwest Border
Counternarcotics Strategy

Page i

6
7

31

GAO-16-223 Firearms Trafficking

Figures
Figure 1: Numbers of Firearms Seized in Mexico and Submitted
for Tracing, by U.S. and Non-U.S. Origin, 2009 to 2014
Figure 2: Examples of Long and Short Guns
Figure 3: Number and Type of Firearms Destined to Mexico
Seized in the United States by Immigration and Customs
Enforcement, 2009 to 2014
Figure 4: Number and Type of Firearms Seized in Mexico and
Submitted to the Bureau of Alcohol, Tobacco, Firearms
and Explosives for Tracing, 2009 to 2014
Figure 5: Top Source States for Firearms Seized in Mexico of U.S.
Origin and Numbers Seized, 2009-2014
Figure 6: Basic Firearm Components from Firearms Parts Kits
Figure 7: Comparison between a Receiver (Considered a Firearm)
and a Casting (Not Considered a Firearm)
Figure 8: A Flat with All of the Required Holes Drilled but That Has
Not Been Bent into Shape

9
11
12
13
15
17
18
19

Abbreviations
ATF
CBP
DHS
DOJ
DTO
FTE
ICE
INL
MOU
NTC
ONDCP
State
Strategy

Bureau of Alcohol, Tobacco, Firearms and Explosives
Customs and Border Protection
Department of Homeland Security
Department of Justice
drug trafficking organization
full-time equivalent
Immigration and Customs Enforcement
Bureau of International Narcotics and Law Enforcement
Affairs
memorandum of understanding
National Tracing Center
Office of National Drug Control Policy
Department of State
the National Southwest Border Counternarcotics Strategy

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without further permission from GAO. However, because this work may contain
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necessary if you wish to reproduce this material separately.

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GAO-16-223 Firearms Trafficking

Letter

441 G St. N.W.
Washington, DC 20548

January 11, 2016
The Honorable Eliot L. Engel
Ranking Member
Committee on Foreign Affairs
House of Representatives
The Honorable Jeff Duncan
Chairman
Subcommittee on the Western Hemisphere
Committee on Foreign Affairs
House of Representatives
Violence perpetrated by Mexican drug trafficking organizations (DTO)
continues to raise security concerns on both sides of the U.S.-Mexico
border. Mexican authorities consider firearms trafficking to be a major
factor in these organizations’ capacity to resist government efforts to
combat organized crime. Similarly, U.S. law enforcement agencies have
acknowledged the role firearms smuggling across the Southwest border
plays in fueling violent criminal activity in Mexico. As we reported in 2009,
trace data 1 on firearms seized from criminals in Mexico confirm that tens
of thousands of weapons seized in Mexico came from the U.S. side of the
border. 2 Over the past decade, U.S. and Mexican administrations have
recognized that addressing firearms trafficking requires bilateral attention,
and they have pledged to collaborate in their efforts to combat it.
You requested that we update our 2009 report and review U.S. efforts to
stem the flow of firearms trafficking into Mexico. In this report, we
examine (1) the origin of firearms seized in Mexico that have been traced
by the Department of Justice’s (DOJ) Bureau of Alcohol, Tobacco,
Firearms and Explosives (ATF); (2) the extent to which collaboration
among U.S. agencies combating firearms trafficking has improved; (3) the

1
Firearms tracing is the systematic tracking of the movement of a firearm recovered by
law enforcement officials from its first sale by the manufacturer or importer through the
distribution chain (wholesaler/retailer) to identify the first retail purchaser.
2

GAO, Firearms Trafficking: U.S. Efforts to Combat Arms Trafficking to Mexico Face
Planning and Coordination Challenges, GAO-09-709 (Washington, D.C.: June 18, 2009).

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GAO-16-223 Firearms Trafficking

status of coordination between U.S. agencies and their Mexican
counterparts combating firearms trafficking; and (4) the extent to which
the National Southwest Border Counternarcotics Strategy (Strategy)
measures progress by U.S. agencies to stem firearms trafficking to
Mexico.
To identify the number, source, and types of firearms trafficked to Mexico
that have been seized and traced, we relied primarily on ATF’s trace data
compiled by that agency’s National Tracing Center Firearms Tracing
System through eTrace. 3 We also reviewed the Department of Homeland
Security’s (DHS) Immigration and Customs Enforcement (ICE) data on
seizures of southbound firearms and cases involving firearms trafficking
to Mexico. To address collaboration among U.S. agencies, we reviewed
and analyzed documentation and reports on collaborative activities
among those agencies responsible for combating firearms. To obtain a
better understanding of the scope and progress of various U.S. agencies’
activities related to firearms trafficking, we met with officials from ATF,
ICE, DHS’s Customs and Border Protection (CBP), and the Department
of State (State). To examine the status of cooperation between U.S.
agencies and their Mexican counterparts, we met with U.S. and Mexican
officials to discuss their cooperative activities. To discuss cooperation by
U.S. and Mexican law enforcement officials to stem the flow of firearms
smuggling across the border, we met with U.S. and Mexican officials at
two major Southwest border locations—San Diego/Tijuana and El
Paso/Juarez. We traveled to Mexico City and Guadalajara, Mexico, to
meet with U.S. embassy and consulate officials responsible for
implementing programs to combat firearms trafficking and Mexican
government officials responsible for related activities. We also met with
the Office of National Drug Control Policy (ONDCP) to discuss the
Weapons Chapter of the Strategy. 4 We assessed the reliability of data
provided by various U.S. agencies by interviewing agency officials
knowledgeable about the data and reviewing related supporting
documentation about the data and the systems that produced them. We
determined that data were sufficiently reliable for the purpose of this

3

ATF has a paperless firearm trace submission system (eTrace) that is accessible through
the Internet, through which authorized users can submit, retrieve, query, and store
firearms trace information, as applicable.
4

The National Southwest Border Counternarcotics Strategy is issued on a biennial basis
by ONDCP consistent with requirements in the Office of National Drug Control Policy
Reauthorization Act of 2006, Pub. L. No. 109-469, § 1110, Dec. 29, 2006.

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GAO-16-223 Firearms Trafficking

report. Appendix I contains additional details about our scope and
methodology.
We conducted this performance audit from December 2014 to January
2016 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.

Background
U.S.-Mexico Collaboration
to Stem Firearms
Trafficking

For almost a decade, the government of Mexico has sought to combat the
growing power of criminal groups that initially emerged as DTOs in the
1980s and 1990s. This struggle became a national priority in 2006 when
then-President Felipe Calderón mobilized the Mexican military and law
enforcement agencies to disrupt DTO operations and target their
leadership structures. As the Congressional Research Service reported,
while these efforts have continued, under current President Enrique Peña
Nieto, who was elected in 2012, there has been a shift in emphasis
toward reducing criminal violence that threatens the security of civilians
and the business sector. 5 According to a RAND Corporation report,
besides trafficking billions of dollars’ worth of narcotics into the United
States annually, Mexican DTOs’ criminal activity now extends to other
areas, including human trafficking, kidnapping, money laundering,
extortion, bribery, racketeering, and weapons trafficking. 6
According to the Strategy DTOs require a constant supply of firearms and
ammunition to assert control over the territory where they operate,
eliminate rival criminals, enforce illicit business dealings, and resist
government operations. The Strategy indicates that firearms that criminal

5
Congressional Research Service, U.S.-Mexican Security Cooperation: The Mérida
Initiative and Beyond (Washington, D.C.: April 2014).
6
RAND Corporation, Mexico Is Not Colombia: Alternative Historical Analogies for
Responding to the Challenge of Violent Drug-Trafficking Organizations (Santa Monica,
Calif.: 2014).

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GAO-16-223 Firearms Trafficking

organizations acquire from the United States are primarily transported
overland into Mexico using the same routes and methods employed when
smuggling bulk cash south and drugs north across the U.S.-Mexico
border. The Strategy also notes that within the United States, DTOs or
their agents typically rely on “straw purchasers.” According to ATF, a
“straw purchase” occurs when a person who is a convicted felon (or
otherwise prohibited by federal law from purchasing a firearm) or who
wishes to remain anonymous, uses a third party, the straw purchaser, to
execute the paperwork necessary to purchase a firearm from a federally
licensed firearms dealer. The straw purchaser is a person who, but for
making false statements on the license application, would otherwise be
eligible under federal law to purchase a firearm and is therefore able to
pass the mandatory background check conducted by the federal firearms
licensee. 7 Although straw purchasers may legally purchase firearms for
their own possession and use, when they purchase firearms on behalf of
criminals or others, they violate federal law by making a false statement
to a federal firearms licensee on the required forms. 8 Firearm trafficking
organizations also frequently obtain firearms from unlicensed private
sellers in secondary markets, particularly at gun shows and flea markets
or through classified ads or private-party Internet postings, according to
ATF officials.
The surge in criminal activity by DTOs along the U.S.-Mexico border has
generated concern among policymakers that this violence is spilling over
into the United States. Since 2009, according to the National Drug Threat
Assessment—which is produced by the U.S. Department of Justice’s
National Drug Intelligence Center, Mexican-based DTOs have been
known to operate in more than a thousand cities in the United States.
7

U.S. federal law requires that a person file for and obtain a license from the U.S. Attorney
General before engaging “in the business of importing, manufacturing, or dealing in
firearms or importing or manufacturing ammunition” (18 U.S.C. § 923(a)). ATF lists nine
separate types of federal firearms licensees on its website: (1) dealers in firearms other
than destructive devices, (2) pawnbrokers in firearms other than destructive devices, (3)
collectors of curios and relics, (4) manufacturers of ammunition for firearms, (5)
manufacturers of firearms other than destructive devices, (6) importers of firearms other
than destructive devices, (7) dealers in destructive devices, (8) manufacturers of
destructive devices, and (9) importers of destructive devices.

8
A straw purchase violates 18 U.S.C. § 922(a)(6), which prohibits purchasers from
knowingly making false oral or written statements or furnishing false identification intended
to deceive licensed importers, manufacturers, or dealers as to the lawfulness of the sale.
Straw purchasers are subject to fines or imprisonment up to 5 years under 18 U.S.C. §
924(a)(1)(A).

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While the extent of violence seen in Mexico has not been reported in the
United States, law enforcement officials in two border cities we visited told
us that murders and other criminal activity on the U.S. side are often
linked to Mexican DTO activities.
The governments of the United States and Mexico have committed to
work together to stem the activities of these criminal organizations,
including illicit arms trafficking. From fiscal year 2008 to fiscal year 2015,
Congress appropriated about $2.5 billion in assistance for Mexico that
has been provided through the Mérida Initiative, including approximately
$194 million provided in the Consolidated and Further Continuing
Appropriations Act, 2015. For fiscal year 2016, the administration’s
budget request for the Mérida Initiative is $119 million, from various
accounts. 9 The Mérida Initiative is a bilateral security partnership between
the United States and Mexico to fight organized crime and build the
capacity of Mexico’s justice sector and law enforcement institutions to
uphold the rule of law. Among the many activities supported under the
Mérida Initiative, some assistance is provided to help combat firearms
trafficking, such as providing canines trained to detect weapons and
ammunition, and non-intrusive inspection equipment to detect the flow of
illicit goods, including firearms.

Principal U.S. Agencies
Involved in Combating
Firearms Trafficking

DOJ’s ATF and DHS’s ICE are the two primary agencies combating illicit
sales and trafficking of firearms across the Southwest border. ATF
combats firearms trafficking within the United States and from the United
States to other countries as part of its mission under the Gun Control Act
(see table 1). 10 ATF is responsible for investigating criminal and
regulatory violations of federal firearms laws, among other
responsibilities. In carrying out its responsibilities, ATF licenses and
regulates federal firearms licensees to ensure that they comply with
applicable laws and regulations. ATF also traces U.S. and foreign
manufactured firearms for international, federal, state, and local law
enforcement agencies to link a firearm recovered in a criminal

9

Mérida Initiative assistance is allocated from various appropriations accounts, including
International Narcotics Control and Law Enforcement; Economic Support Fund; Foreign
Military Financing; International Military Education and Training; Nonproliferation,
Antiterrorism, Demining, and Related Programs; Global Health and Child Survival; and
Development Assistance.
10

18 U.S.C. § 921 et seq.

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investigation to its first retail purchaser. This information can be used to
help link a suspect in the criminal investigation to a firearm or identify
potential traffickers. ATF is the only entity within the U.S. government with
the capacity to trace firearms seized in crimes in Mexico. The agency has
conducted investigations to identify and prosecute individuals involved in
firearms trafficking schemes and has provided training to Mexican law
enforcement officials on firearms identification and tracing techniques,
among other efforts.
Table 1: Key Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) Efforts and Resources to Stem Firearms Trafficking
to Mexico
Estimated funding expenditures
(fiscal years 2009-2014)

Key activities
•

•

Internationally, ATF works with other U.S.
agencies to investigate criminal and regulatory
violations of federal firearms laws. ATF has
primary jurisdiction over firearms and ammunition
imports and works with the Departments of
Homeland Security and State on illicit firearms
exports. ATF also provides training for foreign
counterparts on a variety of firearms topics, such
as weapons identification, and collaborates on
tracing firearms seized abroad.
Domestically, ATF identifies, investigates, and
arrests individuals and organizations that illegally
supply firearms to prohibited individuals. ATF
deters the diversion of firearms from lawful
commerce into the illegal market with
enforcement strategies and technology.

•

$55.1 million ($14.8 million for
operations within Mexico, and
over $40 million for certain
domestic operations and
operations along the U.S.Mexico border)

Personnel (fiscal year 2014)
•

•

•

A total of 423 agents, 157 industry
operations investigators, and 88
task force officers.
One agent, 4 intelligence research
specialists, and 2 investigative
analysts assigned to the El Paso
Intelligence Center.
4 agents assigned and 1 industry
operations investigator to the U.S.
Embassy and 6 special agents in
Monterrey, Tijuana, and Ciudad
Juarez.

Source: GAO analysis of ATF information. | GAO-16-223

Note: The figures in this table represent what ATF expends on various activities to stem firearms
trafficking in Mexico and throughout the Southwest region. According to ATF, this includes funding for
border field division offices in Dallas, Houston, Los Angeles, and Phoenix; support for the El Paso
Intelligence Center; and staff in Mexico. However, these figures do not fully reflect costs for the
agency’s domestic efforts to investigate Mexico-related cases.

ICE enforces U.S. export laws, and ICE agents and other staff address a
range of issues, including combating the illicit smuggling of money,
people, drugs, and firearms (see table 2). As the primary federal law
enforcement agency responsible for investigating international smuggling
operations and enforcing U.S. export laws, ICE’s Homeland Security
Investigations division targets the illegal movement of U.S.-origin
firearms, ammunition, and explosive weapons with the goal of preventing
the procurement of these items by DTOs and other transnational criminal
organizations. ICE’s investigative strategy includes the identification and

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prosecution of criminal networks and individuals responsible for the
acquisition and movement of firearms from the United States.
Table 2: Key Immigration and Customs Enforcement (ICE) Efforts and Resources to Stem Firearms Trafficking to Mexico
Estimated funding expenditures
(fiscal years 2009-2014)

Key activities

ICE, under certain legal authorities (specifically, the $94.8 million (expended for counterArms Export Control Act and International Traffic in firearms trafficking efforts related to
Arms Regulation), contributes to the U.S. effort to
Mexico)
stem firearms trafficking to Mexico by enforcing U.S.
export laws through some of its programs, including
its Counter Proliferation Investigations Program and
Border Enforcement Security Teams.

Personnel (fiscal year 2014)
ICE reports its personnel
contributions in terms of full-time
equivalent (FTE) hours. Thus, for
efforts to counter firearms and
ammunition trafficking ICE reports
that in fiscal year 2014 it expended
102,906 Mexico-related hours with
61 FTEs.

Source: GAO analysis of ICE information. | GAO-16-223

Other U.S. agencies that contribute to the effort to stem firearms
trafficking to Mexico include:
•

CBP. DHS’s CBP is charged with managing, securing, and controlling
the nation’s borders for both people and cargo entering and leaving
the United States. CBP’s outbound mission is to facilitate the
movement of legitimate cargo, while interdicting the illegal export of
weapons and other contraband out of the United States.

•

State. State’s Bureau of International Narcotics and Law Enforcement
Affairs (INL) advises the President, Secretary of State, and
government agencies on policies and programs to combat
international narcotics and crime. INL programs support State’s
strategic goals to reduce the entry of illegal drugs into the United
States and to minimize the impact of international crime on the United
States and its citizens. INL oversees funding provided to build the
capacity of Mexico to fight organized crime under the Mérida Initiative,
including funds to support efforts to combat firearms trafficking.

•

ONDCP. ONDCP is a White House component whose principal
purpose is to establish policies, priorities, and objectives for the
nation’s drug control program. It produces a number of publications,
including the Strategy—first issued in 2007. The Strategy is intended
to serve as an overarching guide for combating criminal activity along
the U.S.-Mexico border; since 2009 it has included a Weapons
Chapter in recognition of the threat posed by the smuggling of
firearms across the Southwest border. Given ATF’s and ICE’s roles in
combating firearms trafficking, these agencies share responsibility for
preparing the information presented in the Weapons Chapter of the

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Strategy. While ONDCP tracks progress by U.S. agencies in meeting
these objectives, it is not directly involved in planning or implementing
their activities.

Most Firearms Seized
in Mexico That Are
Traced by ATF Come
from the United
States, and Most Are
Purchased in
Southwest Border
States
Most Firearms Recovered
in Mexico That Are Traced
by ATF Come from the
United States

Data from ATF on firearms seized in Mexico and traced from calendar
year 2009 to 2014 indicate that the majority originated in the United
States. Because of the illicit nature of the trafficking, the exact number of
firearms trafficked from the United States into Mexico is unknown.
Similarly, ATF officials noted that since firearms seized in Mexico are not
always submitted for tracing the same year they were seized, or are not
submitted at all, it is not possible to develop data to track trends on
firearms seized. However, ATF uses the number of firearms seized and
traced as an indicator to estimate extent of illicit firearms trafficking. While
the government of Mexico collects data on the number of firearms its law
enforcement entities seize each year, our analysis and findings refer
exclusively to the universe of firearms seized in Mexico that were
submitted for tracing using eTrace. 11
According to ATF data, of the 104,850 firearms seized by Mexican
authorities and submitted for tracing from 2009 to 2014, there were
73,684, or 70 percent, found to have originated in the United States.
About 17 percent of the total, 17,544 firearms, were traced to a country

11

According to data provided by the government of Mexico, Mexican authorities seized
158,560 firearms from 2009 to 2014. However, we were unable to independently verify the
reliability of these data. Therefore, we did not compare figures provided by Mexican
authorities to ATF tracing data.

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other than the United States. 12 ATF could not determine the origin of
13,622 (13 percent) of these firearms because of incomplete
information. 13 See figure 1.
Figure 1: Numbers of Firearms Seized in Mexico and Submitted for Tracing, by U.S.
and Non-U.S. Origin, 2009 to 2014

Note: U.S. origin includes firearms manufactured in the United States or legally imported into the
United States. Non-U.S. origin refers to those firearms for which the trace request indicated a nonU.S. (foreign) manufacturer and for which there is no evidence that they were ever imported to the

12

According to ATF data, from 2009 to 2014, after the United States the top five countries
of origin of firearms seized in Mexico and traced were Spain (3,786), China (3,027), Italy
(2,186), Germany (1,522), and Romania (1,287).

13

In 2009, GAO reported data provided by ATF indicating that 87 percent of firearms
seized in Mexico and traced from 2004 to 2008 originated in the United States (see
GAO-09-709). ATF explained that data provided to GAO for the years 2004 to 2008 for
that report are not comparable to the data provided for this report because the agency has
established different parameters for analysis and reporting of the data for the period 2009
to 2014. Current ATF standards entail more extensive review of Mexican data submitted in
the eTrace system for completeness and accuracy. Additionally, more recent data on
traces are reported on a calendar year rather than a fiscal year basis.

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United States. Undetermined origin refers to those firearms for which the trace information was
unclear as to the manufacturer, country of origin, importer, or a combination of these.
a

Firearms may have been seized in prior years but submitted for tracing from 2009 to 2014.

From 2009 to 2011, numbers of firearms seized by Mexican authorities
and submitted for tracing fluctuated significantly, followed by a steady
decline after 2011. According to ATF officials, shifts in the number of guns
seized and traced do not necessarily reflect fluctuations in the volume of
firearms trafficked from the United States to Mexico from one year to the
next. ATF staff explained that there are several factors that have
influenced the year-to-year variance in the number of firearms traced
since 2009. For example, they explained that the high number of firearms
traced in 2009 reflects a single submission by the Mexican military to ATF
for tracing of a backlog of thousands of firearms. 14 Conversely, ATF
officials noted there was a lower number of firearms submitted for tracing
in 2010 because that is the year eTrace in Spanish was initially deployed
in Mexico, and Mexican law enforcement officials at the local, state, and
federal level had to be trained on using the system. In 2011, a much
higher number of firearms were traced as Mexican officials became
proficient in using the system. Finally, U.S. and Mexican officials suggest
the decline since 2011 may reflect a period of adjustment in cooperation
under the Peña Nieto administration. This included the centralization of
access to eTrace in Mexico’s Attorney General’s Office and retraction of
eTrace accounts from federal, state, and local law enforcement, which
resulted in fewer Mexican law enforcement officials able to trace firearms
using the system.

Long Guns Account for
about Half of All Firearms
Seized in Mexico and
Traced

According to Mexican law enforcement officials we interviewed, DTOs
prefer high caliber weapons with greater firepower, including high caliber
rifles or long guns, and military grade equipment. Officials explained that
the firearms of choice for drug traffickers are high caliber assault rifles,
such as AK type and AR 15 type, which are available for purchase in the
United States and which can be converted to fully automatic fire (i.e.,
converted into machine guns). Officials also noted that in recent years
they have seen DTOs acquire military equipment, such as .50 caliber
14
According to Mexican officials, Mexican law requires that all firearms seized in Mexico
must be stored by the Mexican military (Secretaría de Defensa Nacional—SEDENA).
Before the deployment of eTrace in Spanish in 2010, the Mexican military had
accumulated a sizable collection of seized firearms that were subsequently submitted for
tracing using ATF’s eTrace system.

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machine guns, rocket launchers, and grenade launchers. However, they
said that unlike firearms typically used by DTOs, which often can be
traced back to the United States, this type of equipment is known to often
be trafficked into Mexico from leftover Central American military
stockpiles from past conflicts. See figure 2 for examples of long and short
guns (also referred to as handguns).
Figure 2: Examples of Long and Short Guns

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According to data provided by ICE, the agency seized 5,951 firearms that
were destined for Mexico in the last 6 years. 15 Of firearms seized by ICE
from 2009 to 2014, 2,341, or 39 percent, were long guns—including rifles
and shotguns. During the same period, ICE seized 3,610 short guns—
including revolvers and pistols (see fig. 3).
Figure 3: Number and Type of Firearms Destined to Mexico Seized in the United
States by Immigration and Customs Enforcement, 2009 to 2014

Note: Pistols and revolvers are considered short guns. Rifles and shotguns are considered long guns.

According to data provided by ATF, almost half of all firearms seized in
Mexico and traced in the last 5 years were long guns. From 2009 through
2014, 49,566 long guns—rifles and shotguns—were seized and traced.
During that same period, 53,156 short guns—including revolvers and
pistols—were seized and traced. The data also show a substantial
decline in the number of long guns traced since 2011 (see fig. 4).
Mexican law enforcement officials said that in the last 2 years they often

15

According to ICE, this number includes seizures made that were enabled or assisted by
other DHS components.

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seized more handguns than rifles, but stated that the use of high caliber
rifles by cartels is still widespread.
Figure 4: Number and Type of Firearms Seized in Mexico and Submitted to the
Bureau of Alcohol, Tobacco, Firearms and Explosives for Tracing, 2009 to 2014

a

Firearms may have been seized in prior years but submitted for tracing from 2009 to 2014.

b

Pistols and revolvers are considered short guns. Rifles and shotguns are considered long guns.

According to ATF officials, steps the bureau has taken to combat firearms
trafficking to Mexico have made it more difficult for firearms traffickers to
acquire long guns. Specifically, they noted implementation of Demand
Letter 3, which requires licensed dealers and pawnbrokers in Arizona,
California, New Mexico, and Texas to report multiple sales of certain
rifles. 16 According to ATF, information from multiple sales reports on long
guns allows the bureau to identify indicators of suspicious or high-volume
purchasing by individuals, repetitive purchasing, and purchases by

16

Pursuant to 18 U.S.C. § 923(g)(5), ATF issued Demand Letter 3 to licensed dealers and
pawnbrokers in Arizona, California, New Mexico, and Texas, requiring them to submit
information to ATF concerning sales or other dispositions to an unlicensed purchaser,
within 5 business days, of two or more rifles that have semiautomatic action, a caliber
greater than .22, and the ability to accept a detachable magazine.

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associates, as well as geographical trends for such sales. ATF officials
reported that this information has helped them identify firearms traffickers
and others involved in a timelier manner, which on several occasions has
led to arrests and seizures of firearms intended for trafficking to Mexico.
From 2011 to 2014, 490 long guns that had been recorded as part of
multiple sales transactions under Demand Letter 3 were seized in crime
scenes—259 in the United States, 209 in Mexico, and 22 in undetermined
locations.

Most Firearms Seized in
Mexico and Traced to the
United States Were
Purchased in Southwest
Border States

Most of the firearms seized in Mexico that were traced and found to be of
U.S. origin from 2009 to 2014 came from U.S. Southwest border states.
While guns seized in Mexico of U.S. origin were traced to all of the 50
states, most came from Texas, California, and Arizona. As shown in
figure 5, of all firearms seized in Mexico that were traced and identified to
be of U.S. origin, about 41 percent came from Texas, 19 percent from
California, and 15 percent from Arizona. According to ATF, in fiscal year
2014, there were about 10,134 licensed dealers and pawnbrokers in the
four Southwest border states, many of them along the border. This
represents about 16 percent of the approximately 63,311 licensed dealers
and pawnbrokers nationwide. These licensed dealers and pawnbrokers
can operate in locations such as gun shops, pawn shops, their own
homes, or gun shows. 17

17

See discussion of gun shows in GAO-09-709.

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Figure 5: Top Source States for Firearms Seized in Mexico of U.S. Origin and Numbers Seized, 2009-2014

Note: Percentages in the pie chart do not add up 100 because of rounding. Actual number of firearms
purchased in selected states represented in parenthesis.

According to ATF officials, most firearms seized in Mexico and traced
back to the United States are purchased in the United States then
transferred illegally to Mexico. ATF has been able to determine the
original retail purchaser for about 45 percent of firearms seized in Mexico
and traced to the United States from 2009 to 2014. However, ATF was
unable to determine a purchaser for 53 percent, 18 because of factors such

18

According to ATF, the other 3 percent of firearms were traced to a purchaser in a foreign
country. Percentages do not add up to 100 because of rounding.

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as incomplete identifying data on trace request forms, altered serial
numbers, no response from the federal firearm licensee to ATF’s request
for trace information, 19 or incomplete or never received out-of-business
licensee records. 20

Trafficking in Firearms
Parts May Facilitate DTOs’
Acquisition of Firearms
and Complicates
Authorities’ Efforts to
Prevent Trafficking

ATF and Mexican government officials told us that a new complicating
factor in their efforts to fight firearms trafficking is the use of weapons
parts transported to Mexico to be later assembled into finished firearms.
According to documents provided by ATF, firearm parts include
unfinished receivers barrels, triggers and hammers, buttstocks, pistol
grips, pins, bolts, springs, and other items. Figure 6 shows some of these
firearms parts. None of these firearm parts are classified as firearms
under the Gun Control Act. 21 In general, U.S. federal laws and regulations
requiring manufacturers and importers of firearms to identify firearms with
a serial number do not apply to parts, unless otherwise specified by law. 22
Federal firearms licensees and other retailers are not required to report
on the acquisition and disposition of firearm parts as they must for
firearms. Furthermore, any individual in the United States may legally
acquire and possess certain firearm parts that are not otherwise
proscribed by law, including persons prohibited from possessing firearms
and ammunition, such as convicted felons.

19

Generally, 18 U.S.C. § 923 (g)(7) requires federal firearms licensees to respond
immediately to, and in no event later than 24 hours after, the receipt of a request by the
Attorney General for information contained in the records required to be kept.

20

In accordance with 18 U.S.C. § 923(g)(4), upon discontinuance of business by federal
firearms licensees, records shall be delivered within 30 days after the business
discontinuance to ATF.

21

Under the Gun Control Act, the term firearm means (1) any weapon, including a starter
gun, which will or is designed to or may readily be converted to expel a projectile by the
action of an explosive; (2) the frame or receiver of any such weapon; (3) any firearm
muffler or firearm silencer; or (4) any destructive device. The definition of firearm does not
include antique firearms. 18 U.S.C. § 922(a)(3).

22

Under the National Firearms Act, firearms include machine gun parts that are designed
and intended solely and exclusively for use in converting a weapon into a machine gun
and any combination of parts from which a machine gun can be assembled. See 26
U.S.C. § 5812(a); 5845(b). Additionally, the National Firearms Act defines firearms to
include silencers, which are subject to the requirement for manufacturers to identify them
with serial numbers. See 26 U.S.C. § 5845(a); 5842(a).

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Figure 6: Basic Firearm Components from Firearms Parts Kits

Firearms may be assembled by using parts kits that include all of the
components of a fully operable firearm minus the firearm receiver or
frame, which may be obtained separately. ATF officials explained that in
order to circumvent marking requirements on transactions involving
firearms and thus avoid tracing, criminals will sometimes use unfinished
receivers, such as “castings” or “flats,” rather than fully functional
receivers. A frame or receiver by itself is classified as a firearm by
definition under the Gun Control Act. The receiver is the part of the
firearm that houses the operating parts, typically the bolt or bolt carrier
group, the magazine well, and the trigger group. A casting is essentially a
piece of metal fabricated with the exterior features and contours of the
firearm receiver for which it is intended to substitute, but that without
further machining will not function as a firearm. Castings and flats are
commonly referred to as 80 percent receivers in marketing materials and
advertisements promoting their sale. The “80 percent” label is intended to
convey that the product has been cast or fabricated with most of the

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features of a finished, functional firearm receiver, but it will require further
machining to function as a firearm (see fig. 7).
Figure 7: Comparison between a Receiver (Considered a Firearm) and a Casting
(Not Considered a Firearm)

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A receiver flat is a piece of metal that has the same dimensions as a
receiver, but that has not been shaped into a firearm configuration. In this
form, it cannot accept any component parts, but with the proper
equipment it can be readily bent into shape and molded into a receiver
(see fig. 8).
Figure 8: A Flat with All of the Required Holes Drilled but That Has Not Been Bent
into Shape

According to documents provided by ATF, since kits, castings, and flats
are not classified as firearms, transfers of those items are not regulated
under the Gun Control Act or National Firearms Act. Although ICE
officials noted they are subject to export control laws, they have no serial
numbers and generally no markings; thus, firearms assembled with them
are untraceable. 23 In addition, receivers and firearms parts are small and
when transported separately may not be easily identified as items
intended for the production of firearms. They are also easy to conceal,
making it more challenging for customs authorities to detect illicit
shipments of such parts.

23

The Arms Export Control Act, as implemented through the International Traffic in Arms
Regulations, regulates the export of defense articles classified on the United States
Munitions List. Components, parts, accessories and attachments for certain firearms and
receivers are included as items on the U.S. Munitions List and are considered defense
articles that are subject to export control laws. See 22 C.F.R. § 121.1 & 120.45.

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According to ATF officials, there are no reliable data on the extent of
firearm parts trafficking from the United States into Mexico. They noted,
however, that recent seizures of firearms parts, firearms made with
unmarked parts, and equipment used to assemble or manufacture
firearms in Mexico suggest an emerging reliance by criminal
organizations on this source of weapons. For example, law enforcement
officials in Mexico described to us two high-profile cases in 2014 involving
illicit firearm parts assembly of this type. One was in Guadalajara, where
Jalisco state police seized hundreds of unfinished receivers and pieces of
sophisticated equipment being used to complete high caliber rifles. The
second was in Tijuana, where Baja California state police seized 25 rifles
in the process of assembly with firearm parts from the United States. 24

ATF and ICE Have
Taken Steps to
Improve
Collaboration, but
Lack of Monitoring
May Contribute to
Coordination
Challenges
ATF and ICE Have Taken
Steps to Improve
Collaboration, but Some
Challenges Remain

ATF and ICE have taken several steps to improve coordination on efforts
to combat firearms trafficking that we previously identified. 25 In 2009, we
reported instances of dysfunctional operations, duplicative initiatives, and
jurisdictional conflicts between ATF and ICE. 26 In response to our
recommendations on how to address these challenges, ATF and ICE
updated and signed an interagency collaboration memorandum of
understanding (MOU) in June 2009. In their revised MOU, the agencies
24

Mexican authorities indicated that they could not share more specific information on
these cases because they are part of ongoing federal investigations.

25

GAO-09-709.

26

GAO-09-709.

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committed to a shared goal of keeping the public safe by using the tools
given to both agencies and which are vital to the effective control of
domestic and international trafficking of firearms, ammunition, explosives,
weapons, and munitions. Specifically, the MOU set forth roles and
requirements for each agency with respect to (1) intelligence and
information sharing, (2) general investigative guidelines, (3) specific
investigative guidelines, (4) sources of information, and (5) conflict
resolution. This effort to improve coordination and optimize use of the
agencies’ expertise provided the basis to address the issues that had
hampered interagency collaboration prior to the MOU’s implementation.
ICE and ATF officials said that after the MOU was signed, they held joint
training exercises and conferences to ensure that agents had knowledge
of the MOU and its jurisdictional parameters and collaboration
requirements. Officials from each agency in headquarters, Mexico, and
border locations we visited indicated that personnel working on firearms
trafficking to Mexico were generally aware of the MOU’s key provisions
and collaborated on this basis. Agency officials also highlighted a more
recent joint interagency conference in September 2014, which sought to
provide participants with a common understanding of collaborative efforts
and respective areas of jurisdiction. Additionally, senior agency
headquarters officials asserted that there is extensive cooperation
between ATF and ICE, at the headquarters and field office levels. ATF
and ICE officials in border field offices we visited confirmed that they were
familiar with the MOU and that it provides them guidance on interagency
collaboration. Similarly, ATF and ICE officials in Mexico stated that since
they are co-located physically, they have a greater opportunity to work
together closely on firearms trafficking-related cases, and an ICE official
said that they rely on the MOU to help define their respective roles.
Nevertheless, we identified persistent challenges in information sharing
and some disagreement on the agencies’ respective roles in
investigations. For example, ATF and ICE disagree on the extent to which
trace data on firearms seized in Mexico collected through eTrace should
be shared to support ICE firearms trafficking investigations. According to
an ICE assistant deputy director, these firearms trace data from Mexico
are currently only shared on a limited basis with ICE. Several ICE officials
expressed an interest in obtaining access to these data and indicated that
this access would enhance their ability to identify methodologies used by
firearms traffickers and trends in criminal activity along the Southwest
border. ICE officials responsible for investigations said that trace data
should be shared in accordance to the MOU, which states “ATF shall
report to the appropriate ICE field office in a timely manner any

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intelligence received relating to the illegal exportation, attempted
exportation, or planned exportation of any item on the United States
Munitions List...” However, the MOU does not address how general
trafficking information, such as that submitted through eTrace by a third
law enforcement agency, may be shared.
ATF officials asserted that their agency shares trace data on firearms
seized in Mexico with ICE according to established agency polices, which
currently only allow ATF to provide non-case-specific information to other
agencies in aggregate form. With respect to the results of individual trace
requests, ATF officials explained that they are provided only to the law
enforcement agency that submits the trace information; generally, this
information is not shared with third parties, including other law
enforcement agencies. ATF would have to obtain authorization from the
third-party law enforcement agency that submitted the trace information to
share it with ICE. Thus, ATF cannot automatically share information with
ICE on firearm traces submitted by Mexican law enforcement agencies
without their authorization. ATF staff said these policies are set forth in
the agreements ATF signs with each law enforcement agency for the use
of eTrace. Officials from ATF and ICE said there are joint efforts under
way to find a mechanism to share this information.
Additionally, the 2009 MOU sets forth investigative guidelines to define
the roles and responsibilities of ATF and ICE pursuant to their respective
statutory authorities. For example, the MOU states that “the regulation
and inspection of the firearms industry is within the sole purview of ATF”
and that “all investigative activities at the port of entry, borders and their
functional equivalents must be coordinated through ICE.” Notwithstanding
these guidelines, we found some confusion among some agency officials
about the appropriate roles of their counterparts in conducting
investigations. For example, a senior ICE official responsible for
investigations questioned the involvement of ATF in firearms trafficking
investigations to Mexico, because, according to the official, ATF’s
jurisdiction focuses on combating domestic firearms violations. ICE
officials also expressed concerns that the involvement of ATF’s
international desk with Mexican agencies may create confusion among
Mexican government authorities over the roles that ICE and ATF play in
addressing firearms trafficking cases. However, an ICE assistant deputy
director explained that pursuant to the Arms Export Control Act, ICE has
primary jurisdiction over violations related to the international trafficking of
firearms, but many such trafficking investigations begin with domestic
criminal activities for which ATF has jurisdiction. Therefore, he stressed
that it is essential that the two agencies collaborate to leverage ICE’s

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international and ATF’s domestic legal authorities. He added that ATF’s
international operations also provide much-needed capacity building
regarding forensics and e-Trace activities in Mexico. However, ICE and
ATF must work to ensure that confusion is not created among Mexican
agencies regarding the responsibilities for the investigation of
international firearms trafficking by U.S. authorities.
ATF officials agree that their agency’s efforts to combat firearms
trafficking are concentrated in the United States, and that they recognize
the role of ICE in addressing transnational weapons trafficking. However,
some ATF officials said that it is incorrect to suggest that ICE has
exclusive jurisdiction with respect to illicit cross-border firearms trafficking
to Mexico. According to these officials, most investigations involving the
smuggling of firearms from the United States to Mexico implicate ATF
jurisdiction, because they typically involve the illegal acquisition of
firearms inside the United States. ATF’s jurisdiction extends to unlawful
acquisition of firearms by prohibited persons, straw purchasing, and other
unlawful transfers of firearms. ATF officials added that the bureau’s
statutory responsibility for tracing firearms includes the deployment of
eTrace to Mexican and other foreign law enforcement entities, and noted
that eTrace entries from Mexico can result in the opening of firearm
trafficking investigations focused on criminal activity in the United States.
ATF officials also acknowledge that because of the nature of firearms
trafficking to Mexico, many investigations involve overlapping jurisdiction
with respect to cross-border offenses squarely within ICE’s jurisdiction.
They also noted the critical role ATF plays in providing training and
capacity building on firearms and explosives identification and tracing for
Mexican law enforcement. During our fieldwork, Mexican law enforcement
agencies confirmed the benefits they derived from ATF capacity-building
efforts, and they said they regarded ATF as their lead U.S. counterpart in
investigating firearms trafficking. Thus, although ATF has established
productive cooperative relations with Mexican agencies, there may also
be some confusion in Mexico over ATF’s and ICE’s roles in combating
firearms trafficking, as expressed by some ICE officials.

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ATF and ICE Do Not
Consistently Monitor
Implementation of the
2009 MOU, Resulting in
Continued Coordination
Challenges

In prior work, we have identified several interagency mechanisms that
can be used to improve collaboration among agencies working on a
shared mission, such as information sharing, agency roles and
responsibilities, and oversight and monitoring. 27 We have also reported
that written interagency agreements, such as MOUs, are most effective
when they are regularly updated and monitored. We observed that when
implementation of such agreements is not regularly monitored, there is
sporadic and limited collaboration among agencies. We also have found
that agencies that create a means to monitor, evaluate, and report the
results of collaborative efforts can better identify areas for improvement.
Immediately after the MOU was updated in 2009, the agencies committed
to undertake efforts to ensure that its provisions would be implemented
accordingly. For example, at that time, ICE informed GAO that
headquarters had a process to obtain information from ICE field offices
every 60 days to identify coordination issues with ATF that could not be
resolved at the field level within the framework of the MOU. In such
situations, ICE headquarters would then work with the appropriate ATF
component to resolve the issue. ICE officials explained these initial
monitoring efforts were designed to ensure that the updated MOU was
being effectively followed as it introduced several provisions or guidelines
on how ATF and ICE should collaborate on firearms trafficking. However,
according to ICE officials, this process was only in place during the initial
implementation period of the MOU, and the effort was not sustained.
Currently, officials from both agencies acknowledged that there is no
specific mechanism in place to monitor implementation of the MOU.
However, each agency’s officials referred to different efforts that they said
provide an opportunity to monitor interagency collaboration under the
MOU. For example, a deputy assistant director for ICE stated that
coordination between ICE and ATF on firearms trafficking cases occurs at
the Export Enforcement Coordination Center as well as at the field level.
ICE’s Export Enforcement Coordination Center is intended to serve as the
primary forum within the federal government for executive departments

27

Other key features identified include policy development; program implementation; and
building organizational capacity, such as staffing and training. For additional information,
see GAO, Managing for Results: Key Considerations for Implementing Interagency
Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012), and Export
Promotion: Trade Agencies Should Enhance Collaboration with State and Local Partners,
GAO-14-393 (Washington, D.C.: May 21, 2014).

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and agencies to coordinate their export control enforcement efforts. The
Center seeks to maximize information sharing, consistent with national
security and applicable laws. Thus, it is likely that coordination challenges
between ICE and ATF on firearms trafficking could potentially be detected
at the Center. However, given the Center’s broader responsibility to
enhance export control enforcement efforts with multiple agencies, it is
not directly intended to monitor implementation of the MOU. Moreover,
coordination challenges related to the MOU persist even though the
Center has been in place for 5 years, indicating that this may not be an
effective means to monitor the MOU’s implementation.
Senior ATF officials said that although there is no formal arrangement to
regularly monitor implementation of the MOU, they consider joint
interagency training to be an effective approach to ensure that officials
from both agencies are familiar with the provisions of the MOU and are
working together effectively. However, only two such training exercises
have taken place—one in 2014 and another in September 2015. The
training is intended to acquaint officials from both agencies with how the
agencies coordinate firearms trafficking efforts, and as part of the training,
the MOU provisions are discussed, but these training exercises do not
constitute a mechanism for consistent monitoring of implementation of the
MOU. By not sustaining a monitoring process for the MOU, the agencies
have no assurance that its provisions are being implemented effectively,
and challenges we identified are continuing to persist without a process
for resolution.

U.S.-Mexico
Collaboration on
Firearms Trafficking
Was Scaled Back
after 2012, but While
Challenges Continue,
Bilateral Efforts Have
Recently Been
Gaining Momentum

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Bilateral Firearms
Trafficking Efforts Slowed
Following Mexican Moves
to Consolidate Law
Enforcement Collaboration

Mexican and U.S. officials described how upon coming to power in
December 2012, the current administration of Mexican President Enrique
Peña Nieto undertook a reevaluation of U.S.-Mexico law enforcement
collaboration, including efforts to combat firearms trafficking. 28 According
to some officials, the government of Mexico took steps to consolidate law
enforcement cooperative activities under an approach termed Ventanilla
Única—which translates to Single Window. Under Ventanilla Única,
Mexico’s Interior Ministry has become the primary entity through which
Mérida Initiative training and equipment are coordinated, including
capacity-building activities related to firearms trafficking. The government
of Mexico also established a single point of contact within Mexico’s Office
of the Attorney General to approve joint investigations with U.S.
counterparts. Additionally, Mexican officials explained that Mexican law
categorizes firearms trafficking as a federal crime and permits only
federal authorities to work on such cases. This has led to some notable
changes in the way U.S. and Mexican authorities work together on
firearms trafficking efforts.
One of these changes stemmed from the decision to centralize access to
ATF’s eTrace in the Mexican Attorney General’s Office. Consistent with
our prior recommendations, in 2010, ATF reached an agreement for
deployment of eTrace in Spanish in Mexico, with Mexican authorities.
According to ATF, this was a significant investment for which ATF
provided training to numerous officials from various Mexican federal,
state, and local law enforcement agencies on the use of eTrace, while
assigning accounts to allow them to access the system. However, by
2013 the Mexican government retracted access to many of these
accounts, effectively limiting eTrace in Mexico to certain authorized
officials in the office of Mexico’s Attorney General. Mexican officials
explained that the decision to consolidate access at the Attorney
General’s office was intended to provide the government of Mexico with
more effective control over the information associated with eTrace, and to
support a central repository of evidence related to federal crimes such as
trafficking of firearms. However, U.S. officials and some Mexican
authorities said that limiting access to eTrace to a single governmental
entity has restricted opportunities for bilateral collaboration. Some U.S.

28

U.S. law enforcement agencies conduct their work in Mexico in cooperation with
Government of Mexico counterparts under the Treaty of Cooperation Between the United
States of America and the United Mexican States for Mutual Legal Assistance. U.S.Mexico, S. Treaty Doc. No. 100-13 (1988).

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officials based in Mexico similarly noted that limiting access to eTrace
diminished tracing of total firearms seized by Mexican authorities.
Another significant change following the reassessment of bilateral
collaboration, which began in 2012, was the suspension of periodic
meetings of a working group known as GC Armas, which brought
together U.S. and Mexican officials from various agencies involved in
combating firearms trafficking. According to ATF officials, prior to 2013,
GC Armas held periodic meetings annually with the participation of
approximately 70 to 100 officials from both governments. These officials
shared useful information on firearms trafficking trends, trace data,
investigations, collaboration questions, and many other issues. ATF
officials said that oftentimes very productive cooperative efforts on
firearms trafficking began informally at GC Armas meetings and were
subsequently formalized. Mexican officials similarly characterized GC
Armas meetings as contributing in a fundamental manner to reaching
significant agreement between law enforcement in both countries on how
to combat firearms trafficking. They noted one such bilateral effort that
resulted in a comprehensive assessment of firearms and explosives
trafficking with recommendations for each country on sharing information
and cooperating on cross-border investigations. Officials from both
countries explained that while bilateral coordination did not cease after
the suspension of GC Armas meetings, overall collaboration slowed down
with fewer opportunities to promote bilateral firearms trafficking initiatives.

Corruption and Frequent
Turnover Continue to
Hamper Bilateral
Collaboration on Firearms
Trafficking

U.S. and Mexican authorities acknowledge the challenges to law
enforcement efforts posed by continuing corruption among some Mexican
officials. As we discussed in our 2009 report, concerns about corruption
within Mexican government agencies often limit U.S. officials’ ability to
develop a full partnership with their Mexican counterparts. Officials we
met with from ATF, ICE, CBP, and State continued to express such
concerns regarding corruption in Mexico. Some Mexico-based ICE
officials, for example, stated that they are conscious that their U.S.-based
colleagues will not always share with them all of the information they have
on firearms trafficking investigations because of concerns about
corruption. That is, ICE officials in the United States and along the U.S.Mexican border are concerned about sharing information with ICE
officials based in Mexico, fearing that the information may unintentionally
reach corrupt Mexican authorities and compromise their investigations.
According to ICE officials, concerns they had about corruption in Mexico
were exacerbated early in the Peña Nieto administration when a vetted

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unit of Mexican law enforcement officials that they trusted and that ICE
had trained and worked with for several years was disbanded.
U.S. officials also highlighted the problems frequent turnover in Mexican
law enforcement pose for bilateral efforts to combat criminal activities,
including firearms trafficking. Some U.S. officials explained that recurring
personnel changes aggravate the issue of corruption. In a country such
as Mexico, where there is an underlying concern about government
corruption, frequent turnover complicates efforts to develop trust with
counterpart officials. Other U.S. officials noted that there are no civil
service protections in Mexico, so there can be a virtually complete change
in the staff of a government agency when a new administration comes
into office, or even when the head of an agency is reassigned. As a
result, all of the people who received specialized training, such as
firearms recognition, can be removed suddenly leaving no institutional
memory, which complicates planning future collaboration and program
implementation. Similarly, ATF officials commented that oftentimes
Mexican law enforcement personnel in key positions for whom they
provided firearms training were subsequently replaced. While turnover
has been a recurring challenge for U.S. agencies working in Mexico,
various U.S. officials said that it appears to have been particularly
frequent in the past few years. For example, the spokesperson for one
U.S. agency in Mexico noted that in the past 5 years the division
responsible for implementing professional development at a key Mexican
law enforcement entity has been replaced seven times.

Over the Past Year,
Bilateral Collaboration on
Firearms Trafficking Efforts
Has Gained Momentum

While both U.S. and Mexican officials collaborating on firearms trafficking
said that bilateral efforts had been scaled back after the Peña Nieto
administration came into power, these officials noted that over the past
year collaborative activities have been bolstered and are gaining
momentum. For example, around the time of our fieldwork in Mexico,
CBP was working with Mexican authorities to deploy specially trained
canine units able to detect firearms and explosives around the country.
Similarly, ATF was providing training on firearms identification for
Mexican Customs. A Mexican Customs spokesman stressed the
importance of such training in helping front-line customs officers
recognize and safely secure not just firearms but also ammunition,
firearms’ components, and explosives that criminals try to smuggle across
the border. He explained that this training has been critical in allowing
officers at the border to perform their mission.

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Mexican Attorney General officials also noted their increasing level of
cooperation with U.S. authorities on firearms trafficking. They highlighted
ATF training on the use of eTrace and the resumption of GC Armas
meetings in 2015. ICE officials also told us that they have recently
reestablished the vetted unit in Mexico, which improves trusted working
relationships with Mexican counterparts. Finally, in addition to renewing
existing collaborative efforts with Mexican law enforcement counterparts,
ATF has also sought to reach out to other Mexican government entities.
For example, this year ATF has been collaborating with the Mexican Navy
on training for firearms and explosives detection, identification, and
seizure. Mexican Navy officers expressed gratitude for this training,
noting that they are increasingly confronting real-world situations that
require this type of knowledge.

The Current Weapons
Chapter Indicator in
the National
Southwest Border
Counternarcotics
Strategy Does Not
Adequately Measure
the Progress of U.S.
Agencies in
Stemming Firearms
Trafficking to Mexico

The indicator used in the Strategy to track progress by U.S. agencies to
stem firearms trafficking to Mexico does not adequately measure
implementation of the strategic objective. The Strategy includes strategic
objectives and indicators for each of its nine issue chapters to ensure
effective implementation. The strategic objective for the Weapons
Chapter is to “stem the flow of illegal weapons across the Southwest
border into Mexico.” ONDCP’s indicator for this chapter is the “number of
firearms trafficking/smuggling seizures with a nexus to Mexico.” The
Strategy does not further define the indicator, but ONDCP staff explained
that it refers to the number of firearms seized in Mexico that are traced by
ATF.
While ONDCP’s Strategy asserts that it is critical to have indicators that
enable tracking the implementation of objectives, this indicator for the
Weapons Chapter does not effectively track the status of efforts to stem
the flow of illegal weapons across the Southwest border. As previously
noted in this report, ATF officials readily acknowledge that shifts in the
number of guns seized and traced do not necessarily reflect fluctuations
in the volume of firearms trafficked from the United States to Mexico in
any particular year. There are many factors that could account for the
number of firearms traced in a given year beside the number of firearms
smuggled from the Unites States. Moreover, as discussed above, for
various reasons the number of firearms seized in Mexico and traced back
to the United States shifted significantly year to year after 2009 and then
declined steadily since 2011. Thus, while the number of firearms seized
and traced by ATF is useful to provide an overall indication of firearms of
U.S. origin found in Mexico, by itself it is not an adequate measure of
progress agencies are making to stem the flow of firearms trafficked from

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the United States into Mexico. Additionally, ONDCP has not reported
progress made on the strategic objective in the Weapons Chapter in 2011
or 2013. ONDCP staff said they anticipate that the 2015 Strategy will
include a section to report on the outcomes of the last 2 years, and they
plan to report on this indicator.
Beside the strategic objective and indicator, the Weapons Chapter of the
Strategy also includes five supporting actions, along with associated
activities to achieve those actions; see table 3. According to an ONDCP
spokesman, while the number of firearms seized in Mexico and traced by
ATF may be an indicator of the flow of firearms across the border, these
five supporting actions and their associated activities should also be
considered to get a full picture of the agencies’ progress in combating
arms trafficking. ONDCP officials said that they monitor progress in
combating arms trafficking by obtaining periodic information from ATF
and ICE on their implementation of these and other activities.

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Table 3: Supporting Actions and Activities in the Weapons Chapter of Office of National Drug Control Policy’s (ONDCP) 2013
National Southwest Border Counternarcotics Strategy
Supporting actions

Activities

Improve criminal intelligence and information sharing
related to illegal weapons trafficking

•
•
•

Increase the interdiction of illegal weapons
shipments to Mexico

•

Enhance cooperation with international partners in
weapons smuggling/trafficking investigations

•

•
•

•

•

Strengthen domestic coordination on weapons
smuggling/trafficking investigations

•
•
•
•
•

Increase successful federal prosecutions for illegal
weapons trafficking

•
•

Facilitate U.S. government interagency criminal intelligence sharing
Enhance programs at El Paso Intelligence Center targeting illegal weapons
smuggling/trafficking
Continue to employ programs to rapidly share weapons seizure information
among U.S. law enforcement agencies
Expand intelligence-driven interdiction of illicit weapons shipments destined
for Mexico through multiagency investigative efforts
Engage in international training on border security, postblast investigations,
firearms identification, and detection of concealment traps used for
smuggling/trafficking of firearms in vehicles
Complete and enhance the deployment of Spanish eTrace capabilities
among appropriate Mexican law enforcement agencies
Continue to monitor the end use of firearms legally exported from the
United States to Mexico through the Department of State’s Blue Lantern
Program
Maintain Drug Enforcement Administration; Federal Bureau of
Investigation; Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF);
and Immigration and Customs Enforcement liaison officers in Mexico
Modernize, expand, and network ballistics imaging technology with
Mexican law enforcement agencies
Improve support to state and local law enforcement efforts targeting illegal
weapons trafficking
Increase ATF staffing levels in the Southwest border region
Expand the use of the Border Enforcement Security Teams to disrupt
cross-border weapons trafficking networks
Continue applying standard proviso on export licenses requiring the
provision of serial numbers for firearms exported to Mexico
Improve U.S. government outreach to and coordination with federal
firearms licensees
Assign Organized Crime and Gang Section prosecutors to the Southwest
border
Target gun trafficking gangs

Source: GAO analysis of ONDCP’s 2013 National Southwest Border Counternarcotics Strategy. | GAO-16-233

Our review of the Weapons Chapter in the 2011 and 2013 Strategies
determined that, generally, accomplishments under each supporting
action were discussed. For example, in the 2011 Strategy, one supporting
action called for ATF to increase staffing at the El Paso Intelligence
Center Firearms and Explosives Trafficking Intelligence Unit through the
incorporation of partner agencies. In 2013, the Strategy included an
update that the unit had incorporated a CBP analyst dedicated to
weapons-related intelligence. Similarly, in 2011, the agencies said they

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had plans under way to train over 200 Mexican law enforcement
personnel in how to correctly use eTrace. The 2013 Strategy noted that
350 Mexican law enforcement personnel had received training on using
eTrace. Nevertheless, the supporting actions described in the Strategy
are not consistently linked to indicators or regularly measured. Currently,
the narrative related to these supporting actions typically covers ongoing
efforts by the agencies to address these actions, but it does not include a
measure of overall progress. By including these supporting actions and
activities in the Weapons Chapter as measures, ONDCP could better
assess the agencies’ efforts in combating firearms trafficking because this
would provide a more comprehensive assessment.

Conclusions

Although ATF and ICE have pledged, through the 2009 MOU, to
collaborate effectively to combat firearms trafficking, these agencies have
not set up a mechanism to monitor implementation of the MOU that would
allow them to identify and address information sharing and collaboration
challenges. Consequently, gaps in information sharing and some
disagreement about agency roles in the broader effort to combat firearms
trafficking have emerged that weaken the effectiveness of the MOU.
It is unclear to what extent ONDCP’s Strategy has advanced U.S.
government efforts to combat firearms trafficking, since the indicator used
to track progress, by itself, is not sufficient to measure progress made by
U.S. agencies in stemming arms trafficking to Mexico. Other actions that
agencies take to stem the flow of firearms from the United States into
Mexico may be worth considering as additional measures of progress,
such as the number of interdictions of firearms destined for Mexico, the
number of investigations leading to indictments for firearms trafficking
related to Mexico, and the number of convictions of firearms traffickers
with a nexus to Mexico. By including these types of measures in a
comprehensive indicator or set of indicators, ONDCP will be better
positioned to monitor progress on stemming firearms trafficking across
the Southwest border.

Recommendations for
Executive Action

We recommend that the Attorney General of the United States and the
Secretary of Homeland Security convene cognizant officials from ATF
and ICE to institute a mechanism to regularly monitor the implementation
of the MOU and inform agency management of actions that may be
needed to enhance collaboration and ensure effective information
sharing.

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To ensure effective implementation of the strategic objective of the
Weapons Chapter of the Strategy, we recommend that the ONDCP
Director establish a more comprehensive indicator, or set of indicators,
that more accurately reflects progress made by ATF and ICE in meeting
the strategic objective.

Agency Comments

We provided a draft of this report for review and comment to the
Departments of Homeland Security, Justice, and State; and the Office of
National Drug Control Policy.
DHS agreed with our recommendation regarding monitoring
implementation of the MOU and provided written comments in response
to the draft, reproduced in appendix II. In comments on the draft report
provided via e-mail by a designated ATF Audit Liaison Officer, DOJ also
agreed with this recommendation, noting that ATF officials will work with
counterparts at DHS to create a mutually acceptable method to further
enhance implementation of the MOU. State did not provide comments on
the draft report.
In e-mail comments provided by a designated General Counsel official,
ONDCP concurred with our recommendation to establish a more
comprehensive set of indicators for the Weapons Chapter of the Strategy.
Accordingly, ONDCP indicated that it would work with ICE and ATF to
develop additional indicators to evaluate their progress. The indicators
developed through this collaborative process will be used in future
iterations of the Strategy beginning with the next report in 2017.
ICE and ATF also provided technical comments which we incorporated
throughout the report where appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security; the Attorney General of
the United States; the Director of the Office of National Drug Control
Policy; the Secretary of State; and other interested parties. In addition,
the report is available at no charge on the GAO website at
http://www.gao.gov.

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If you or your staff have any questions about this report, please contact
me at (202) 512-6991 or farbj@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix III.

Jessica Farb
Acting Director, International Affairs and Trade

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Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

To identify data available on the origin of firearms trafficked to Mexico that
were seized and traced, we relied primarily on the Bureau of Alcohol,
Tobacco, Firearms and Explosives (ATF) data compiled by its National
Tracing Center (NTC).The data provided by NTC were obtained from
ATF’s Firearms Tracing System, most of which is developed through
eTrace submissions. We discussed with cognizant NTC officials the
methodology used to collect these data and reviewed supporting agency
documentation. Based on these discussions, we determined that NTC
data were sufficiently reliable to permit an analysis of where the firearms
seized in Mexico that were submitted for tracing had been manufactured
and whether they had been imported into the United States before
arriving in Mexico. For those firearms that were traced to a retail dealer in
the United States before being trafficked to Mexico, NTC data also
contained information on the states where they had originated. NTC trace
data also contained information allowing identification of the types of
firearms that were most commonly seized in Mexico and subsequently
traced. We corroborated this information in discussions with U.S. and
Mexican law enforcement officials.
Since firearms seized in Mexico are not always submitted for tracing
within the same year as they were seized, it was not possible for us to
develop data to track trends on the types of firearms seized year to year.
Similarly, we were unable to obtain quantitative data from U.S. or
Mexican government sources on the users of illicit firearms in Mexico.
However, there was consensus among U.S. and Mexican law
enforcement officials that most illicit firearms seized in Mexico had been
in the possession of organized criminal organizations linked to the drug
trade. The involvement of criminal organizations with ties to drug
trafficking in the trafficking of illicit firearms into Mexico was confirmed by
law enforcement intelligence sources. We learned about the use of
firearms parts for the assembly of firearms in Mexico through our
interviews with cognizant U.S. and Mexican government and law
enforcement officials and through review of ATF-provided documents.
To learn more about U.S. government efforts to combat illicit sales of
firearms in the United States and to stem the flow of these firearms
across the Southwest border into Mexico, we interviewed cognizant
officials from the Department of Justice’s (DOJ) ATF, the Department of
Homeland Security’s (DHS) Immigration and Customs Enforcement (ICE)
and Customs and Border Protection (CBP), and the Department of State
(State) regarding their relevant efforts. We obtained data from ATF and
ICE on funding for their respective efforts to address firearms trafficking to
Mexico, and data from ICE on seizures of southbound firearms. To

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Appendix I: Scope and Methodology

assess the reliability of the data, we discussed sources and the
methodology use to develop the data with agency officials. We
determined that the information provided to us was sufficiently reliable to
describe agencies’ efforts to combat firearms trafficking. We also
conducted fieldwork at U.S.-Mexico border crossings at El Paso, Texas,
and San Diego, California. In these locations, we interviewed ATF, CBP,
and ICE officials responsible for overseeing and implementing efforts to
stem the flow of illicit firearms trafficking to Mexico and related law
enforcement initiatives.
We reviewed and analyzed DOJ and DHS documents relevant to U.S.
government efforts and collaboration to address arms trafficking to
Mexico, including funding data provided to us by ATF and ICE, the 2009
memorandum of understanding (MOU) between ICE and ATF, data from
ICE on seizures of firearms destined for Mexico, data from ATF and ICE
on efforts to investigate and prosecute cases involving arms trafficking to
Mexico, and agency reports and assessments related to the issue. We
also reviewed relevant prior GAO reports, Congressional Research
Service reports and memorandums, and reports from DOJ’s Office of
Inspector General related to ATF’s efforts to enforce federal firearms
laws. We reviewed provisions of federal firearms laws relevant to U.S.
government efforts to address firearms trafficking to Mexico, including the
Gun Control Act of 1968, the National Firearms Act of 1934, and the Arms
Export Control Act of 1976. We did not independently review any Mexican
laws for this report.
To determine how well agencies collaborated with Mexican authorities to
combat illicit firearms trafficking, we conducted fieldwork in Mexico City,
Guadalajara, and border locations in Ciudad Juarez and Tijuana, Mexico.
In Mexico, we met with ATF, CBP, ICE, and State officials working on law
enforcement issues at the U.S. embassy. We interviewed Mexican
government officials engaged in efforts to combat firearms trafficking from
the Attorney General’s Office (Procuraduría General de la República), the
Federal Police (Policía Federal); the Ministry of Public Safety (Secretaría
de Seguridad Pública); the Ministry of Defense (Secretaría de la Defensa
Nacional); the Mexican National Intelligence Agency (Centro de
Investigación y Seguridad Nacional, or CISEN); the Mexican Navy
(Secretaría de Marina or Armada de Mexico); Customs (Servicio de
Administración Tributaria); the Forensic Science Institute of Jalisco
(Instituto Jalisciense de Ciencias Forenses); Attorney General Regional
Offices, Federal Police, and State Police in Tijuana and Ciudad Juarez;
and the State Attorney General in Guadalajara. Because our fieldwork
was limited to selected locations along the Southwest border and in the

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Appendix I: Scope and Methodology

interior of Mexico, our observations in these locations are illustrative but
are not generalizable and may not be representative of all efforts to
address the issue.
To assess the extent to which the National Southwest Border
Counternarcotics Strategy (Strategy) outlines U.S. goals and progress
made in efforts to stem firearms trafficking to Mexico, we reviewed the
2011 and 2013 versions of the Strategy’s Weapons Chapter and the 2010
implementation guide. We also met with Office of National Drug Control
Policy officials responsible for the implementation and monitoring the
Strategy, as well as with ATF and ICE officials responsible for writing the
Weapons Chapter and overseeing implementation and reporting on
activities described within their respective agencies.

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Appendix II: Comments from the Department
of Homeland Security
Appendix II: Comments from the Department
of Homeland Security

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Appendix II: Comments from the Department
of Homeland Security

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Appendix III: GAO Contact and Staff
Acknowledgments
Appendix III: GAO Contact and Staff
Acknowledgments

GAO Contact

Jessica Farb, (202) 202-512-6991 or farbj@gao.gov

Staff
Acknowledgments

In addition to the contact named above, Charles Johnson (Director), Juan
Gobel (Assistant Director), Francisco Enriquez (Analyst-in-Charge),
Danny Baez, and Julia Jebo-Grant made key contributions to this report.
Ashley Alley, Karen Deans, Justin Fisher, and Oziel Trevino provided
additional assistance.

(100044)

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