Four of eight leading practices were not fully addressed
Before a May 2026 Justice Department memorandum, GAO found that the Drug Enforcement Administration and ICE’s Homeland Security Investigations generally addressed four of eight leading interagency collaboration practices. The other four—accountability, sustained leadership, organizational culture and updated agreements—were not fully addressed.
The agencies had a June 2009 cooperation agreement and a January 2021 joint letter. Nevertheless, they never fully sustained the required Headquarters Review Team and had not fully implemented the joint training called for in 2021.
| Measure | Result | Status |
|---|---|---|
| Leading practices reviewed | 8 | GAO framework |
| Generally addressed | 4 | 50% |
| Not fully addressed | 4 | 50% |
| GAO recommendations | 5 | All open on report page |
New legal direction did not settle the old requirements
A January 2025 Office of Legal Counsel opinion and the May 2026 acting-attorney-general memorandum changed the operating context. As of June 2026, Justice officials were still determining how the newer memorandum affected the 2009 and 2021 requirements.
That uncertainty extended to field-office notification, operational plans, the review team and joint training. The record therefore shows both incomplete implementation and uncertainty over whether the underlying rules continued unchanged.
The fieldwork was informative but not nationally representative
GAO visited nine DEA and HSI field offices selected to cover different regions and drug-seizure volumes over eight and a half years. The sample was explicitly nongeneralizable, so it cannot produce a nationwide compliance rate for every office.
GAO combined those interviews with agreements, policies, headquarters interviews and legal requirements. The national finding rests on agency-wide documents and leadership responsibilities, not a statistical extrapolation from nine locations.
Agency disagreement remains part of the record
GAO issued five recommendations to clarify which requirements remain, update or replace the agreements and explain supervisory mechanisms. Justice agreed; Homeland Security disagreed. GAO maintained that the recommendations were valid.
This analysis establishes a governance gap, not a failed drug case or missed seizure. Half the collaboration framework remained incomplete, and the agencies lacked settled direction about agreements dating back five and 17 years.