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The Internationalization of Police:

The DEA in Mexico

Maria Celia Toro

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Little has been published on how countries react to the presence of foreign police
within their borders. Ethan A. Nadelmann has written a major work on the interna-
tionalization of United States criminal law enforcement agencies; its focus, however, is
on the "behavior and perspectives of U.S. officials" engaged in international law
enforcement activities. Still, his work has provided interesting clues for my own research
on Mexican policy toward drugs in the context of United States-Mexican relations.'
This article will focus on Mexico's experience with the Drug Enforcement
Administration (DEA), and in particular, on how and why that United States police
agency has become a powerful presence in Mexico and the source of bitter fights
between Mexico and the United States over the last fifteen years. The DBA's influ-
ence, I argue, has been consequential on two fronts: on the Mexican government
and its antidrug policies and on the organization and practice of drug trafficking in
Mexico. Leaving aside the critical issue of how, over the last fifteen years, the DEA has
modified the relationship between the Mexican government and drug traffickers, in
this article I will concentrate on the influence of the agency on Mexican drug policy
and on the challenge that DEA agents have come to represent for the Mexican state.
That challenge is to the most exclusive, that is, sovereign, of a state's powers,
namely, law enforcement. The police is not only in charge of legally enforcing a
country's laws; it is also the instrument of a central authority. The badge and gun
of DEA agents represent United States sovereign police power, which does not
extend beyond American borders. Many governments have come to accept the
occasional practice of hot pursuit across frontiers to arrest fleeing criminals, but
very few will tolerate the exercise of police power by a foreign agency. According
to Nadelmann, "The presence of foreign police may be accepted, but virtually
never the legal authority that underpins them in their own country." The impossi-
bility of enforcing one country's laws in another polity leads to extremely awkward
situations for the DEA in Mexico, which will be described in this article.'

Maria Celia Toro is director of the Center for International Studies at EI Colegio de Mexico. A shorter version of
this article was published in Spanish in Homenaje a RafaelSegovia, ed. Fernando Serrano Migall6n (Mexico City,
1998). The author wishes to thank David Thelen and Susan Armeny for assistance in the preparation of this article.
Readers may contact Toro at mctoro@colmex.rnx.

1 Ethan A. Nadelmann, Cops across Borders: The Internationalization of us. Criminal Law Enfircement (Un i-

versity Park, 1993), xix.


2 Hans J. Morgenthau, "The Political Conditions for an International Police Force," International Organiza-
tion, 17 (no. 2, 1963), 393; Nadelmann, Cops across Borders, 111.

The Journal ofAmerican History September 1999 623


624 The Journal of American History September 1999

The OEA in Other Countries

American antidrug agents have reached outside United States borders with the prime
objectives of enforcing their laws more effectively and of reducing the amount of
drugs smuggled into the United States. They began traveling abroad and stationed
themselves in other countries for the first time early in the twentieth century,
when-practically overnight-the international drug trade became illegal under
United States law. The first United States laws penalizing the import of opium and
cocaine were enforced by narcotics agents in the Treasury Department, concerned, as
a revenue and customs agency; with illegal imports. The United States Customs and

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Border Patrol were the most important agencies enforcing antidrug laws in the
1910s and 1920s. The international presence of United States antidrug enforcement
agents in those days was mostly "local," covering Canada and Mexico. Reaching out-
side usually meant crossing the border in hot pursuit of fleeing drug dealers, asking
the counterpart agency in another nation to locate the criminal-frequently an
American citizen-and send him back to the United States, or entering neighboring
countries on intelligence-gathering missions. At the beginning of this century, few
countries experienced drug-related transgressions of their territorial sovereignty as a
result of attempts to enforce United States drug laws.
In the 1920s, the Prohibition Unit, in charge of supervising narcotics enforce-
ment at the Department of the Treasury, had agents stationed in about ten coun-
tries. The internationalization effort, still modest, was then largely the work of one
individual, the legendary Commissioner Harry J. Anslinger, who "reached personal
agreements with the heads of twenty counterpart agencies in foreign countries to
exchange intelligence" and "had few inhibitions about sending his agents abroad on
investigations." In 1930 enforcement of alcohol and narcotics laws was separated
and assigned to the Bureau of Prohibition (in the Justice Department) and the Fed-
eral Bureau of Narcotics (FBN, in the Treasury Department)."
For thirty-two years the FBN was headed by Anslinger, famous within and outside
the United States for his toughness and a principal figure in the internationaliza-
tion of the bureau and the creation of antidrug programs that concentrated
police efforts "on the sources of supply." Largely on a personal basis, he devel-
oped a secret international network of narcotics-law enforcement officers from
various, mostly European, countries to exchange information "on the movements
of alleged international dope dealers." The FBN committed numerous excesses
and finally fell victim of police corruption, which led to the creation of the
Bureau of Narcotics and Dangerous Drugs in 1968 and to the consolidation of
drug-law enforcement in the Justice Department."
A relatively weak police office in the late 1960s, the Bureau of Narcotics and
Dangerous Drugs was reorganized in 1973 under a new name: the Drug Enforce-
ment Administration. The United States policy of building an informal interna-

3 Nadelmann, Cops across Borders, 95. See also David F. Musto, TheAmerican Disease: Origins ofNarcotic Con-
trol (New Haven, 1973), 183.
4 Nadelmann, Cops across Borders, 95, 139-40.
The DEA in Mexico 625

tional network of police agents, not very different perhaps from today's Interpol in
its purpose of linking national police agencies for the exchange of information and
experiences, was replaced during the Nixon administration by a more forceful policy
of ''Americanization'' of antidrug programs in various countries.
The true internationalization of United States police, antidrug agents in particu-
lar, began in the 1970s. Since the DBA's creation, the number and influence of its
agents in other countries has grown dramatically, and, in many countries of Latin
America, their power is today overwhelming. This agency's growth and worldwide
reach is closely related to the increase in international drug trafficking. The "wars on

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drugs" of the Reagan and Bush administrations in the 1980s were basically, though
not exclusively, fought by the DEA. 5
With the drug boom of the 1980s, DEA efforts inside and outside the United
States became more ambitious and daring. Between 1981 and 1990, the agency's
budget tripled within a heavily expanding United States federal budget for drug
abuse control, which reached more than $10 billion by the beginning of the 1990s.
Congress and United States courts provided the legal basis to extend United States
jurisdiction to drug offenses committed abroad. Consequently, in the 1980s the DEA
became a well-equipped police, amassing investigative resources and developing pow-
erful tactics to obtain drug-related information in other countries. With proper fund-
ing, a unique capacity to store and transmit information, suitable laws, and a warlike
rhetoric, the DEA grew into the most powerful organization combatting contraband
drugs in the United States. In 1987 it had close to 2,200 special agents and intelligence
analysts throughout the United States, and over 240 agents in 42 countries; by the
beginning of the 1990s, its agents stationed abroad covered more than 60 cities."
The most striking and consequential development from the perspective of inter-
national relations has been the extraterritorial extension of United States criminal
jurisdiction, most notably the extension of its judicial capacities in the 1980s. For
many countries in Latin America, this represented a drastic change in United States
antidrug policy. The enforcement of United States laws beyond United States bor-
ders, considered illegitimate by practically all nations, has been unique in the case of
drug trafficking, in comparison both with previous practice and with approaches to
other so-called transnational crimes. Perhaps the most important legislation affect-
ing international narcotics control was the 19'86 Anti-Drug Abuse Act, which out-
lawed the manufacture and distribution of drugs outside the United States if they
were intended for export to American territory. This law provided the basis for
United States federal grand jury indictments of foreign nationals, a practice that has
increased over the last ten years."

5The Drug Enforcement Administration (DEA) is neither the only United States law enforcement agency
enforcing antidrug laws today nor the only law enforcement body with an international presence, but it is cer-
tainly the most important on both accounts.
6 U.S. General Accounting Office, National Security and International Affairs Division, Drug Control: Interna-
tional Narcotics Activitiesof the United States: Briefing Report to the Honorable Frank H. Murkowski, US. Senate
(Washington, 1987),3.
7 "Anti-Drug Abuse Act of 1986," Public Law 99-570, H.R. 5484,99 Cong., 2 sess., Oct. 1986.
626 The Journal of American History September 1999

The power of United Stateslaw enforcement officials was equallyincreased by impor-


tant Supreme Court decisions that facilitated police activities outside the United States
by the DBA and other agencies, for example, the Supreme Court's refusal to apply the
Fourth Amendment to searches by United States law enforcement agents in foreign
countries (in United States v. Verdugo Urquidez) or the decision that United States
courts could rule on cases involving criminals who had been kidnapped from other
countries (in United States v. Alvarez Machain). Over the last fifteen years, the DBA
has maximized its capacity to gather evidence in foreign territories to be used in
prosecutions in United States courts. It has also consolidated its power to obtain for-

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mal extradition of fugitives to the United States and to take drug traffickers and
associated criminals to trial in the United States, luring them into United States ter-
ritory or arranging an abduction."
The external expansion of United States antidrug activity can be explained as an
effort to strip away the protection that criminals may obtain by changing national
jurisdictions and as a response to the emergence of so-called transnational crimes,
which compel law enforcers to look in other countries for information and to call for
worldwide cooperation. This depiction of the internationalization of police presents
the creation of a "transnational police" network as a natural response to the interna-
tionalization of crime. "Crime and law enforcement," Nadelmann argues, "have been
internationalized by technological developments in much the same way as other
types of transnational commerce and governmental regulation."? In this framework,
the internationalization of police is not problematic; it is further proof of inevitable
globalization. This "transnationalization" argument cannot explain, however, why
the export of police has become such a conflict-inducing issue between states (in
particular, between notoriously unequal states) or why United States antidrug agents
work abroad precisely the way they do.
The transnationalization hypothesis is oblivious to the fact that intelligence gath-
ering and law enforcement are functions over which all states claim sovereign, that
is, exclusive jurisdiction. It seems analytically more fruitful to begin by acknowledg-
ing that while criminals may indeed illegallycross national borders, police are bound
to abide by their own and other governments' legislation, which invariably estab-
lishes a state monopoly over police and intelligence activities. Because police are
national and policing a state affair, DBA agents acting in other countries cannot exer-
cise the most important power granted to police officers, namely, the power of arrest.
To work as an intelligence agency outside its jurisdiction (the only possible option
under the sovereignty premise), the DBA needs the host government's consent or it is
guilty of engaging in illegal espionage. The significance of sovereignty explains why

8 United States v. Verdugo Urquidez, 494 U.S. 259 (1990); United States o. AlvarezMachain, 504 U.S. 655

(1992); Secretarfa de Relaciones Exteriores, Limits to NationalJurisdiction: Documents andJudicialResolutions on


theAlvarezMachain Case (Mexico City, 1992). For the expansion of United States police and judiciary abroad, see
Nadelmann, Cops across Borders, 463-78; and Samuel I. del Villar, "La Suprema Corte de Justicia de Estados Uni-
dos y la Doctrina Bush-Rehnquist frente a Mexico" (The United States Supreme Court and the Bush-Rehnquist
doctrine regarding Mexico), in Mexico-Estados Unidos-Canadd, 1991-1992, ed. Gustavo Vega (Mexico City,
1993).
9 Nadelmann, Cops across Borders, 105.
The DEA in Mexico 627

even the most powerful states need to strike agreements with other states, no matter
how feeble, to make police cooperation possible.
In this power politics framework, the internationalization of police can take only
two forms: looking for a national counterpart (or creating one, the Americanization
policy) or disregarding national jurisdictions. Consequently, the internationalization
of the DEA is either the story of the reproduction of similar police units around the
world, a basically successful story in the case of many European countries, or, as in
Latin America, the story of an overreach, a systematic circumvention of sovereign
restrictions on police and intelligence activities. That latter expansion of United

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States domestic authority abroad, I argue, has prevailed in Mexico and, one can pre-
sume, in many other Latin American countries.

The DEA in Mexico

The presence of United States drug-law enforcement agents in Mexico was almost
simultaneous with the enactment, during the first two decades of this century, of
United States laws prohibiting the import of drugs, many of which were produced
in Mexico or traversed Mexican territory on their way to the United States market.
In a study of international drug-control policy, the historian William O. Walker III
has offered ample evidence of the unauthorized presence of United States anti-
drug agents in Mexico during the 1920s and 1930s. Walker documents unsuccess-
ful bilateral negotiations, most of them initiated by the Mexican government, to
formalize that presence. Efforts by the Mexican government to establish rules for
the conduct of the drug-law enforcers were invariably a response to activities
already underway. In 1930 the two countries reached an informal agreement for
the exchange of information on drugs, which did not prevent United States anti-
drug agents from crossing the border and gathering drug-related intelligence-
usually, but not always, notifying the United States embassy or consulates in Mex-
ico of their activities. 10
By the end of the 1930s, still relying on informal agreements, Treasury Depart-
ment special representatives policing the narcotics trade had become regular mem-
bers of the American embassy in Mexico City or worked, as they had done in the
1920s, under the authority of United States consulates, mostly in northern Mexico.
There is scant evidence, if any, regarding their number and activities after the
1930s, but there is no reason to assume that this situation changed before the mid-
1940s. United States antidrug agents were not crucial in the 1938 Mexican
opium eradication campaign and in the 1948 Mexican opium and marijuana
eradication program, which is usually referred to as the first major campaign
against drugs in that country.'! It was not until the 1970s that United States nar-
cotics agents began playing a major role in the design and implementation of
Mexican antidrug programs.

10 William o. Walker III, Drug Control in theAmericas (Albuquerque, 1981).


11 Ibid., 119-33; Nadelmann, Cops across Borders, 93-97.
628 The Journal of American History September 1999

The DBA as a "PoliceModel": Molding a Counterpart

With many agents stationed in Mexico, in the 1970s the DEA tried to form a Mexi-
can antinarcotics police unit trained in its own spirit and tactics. Turkey is frequently
mentioned as the place where Richard M. Nixon launched the first United States
"war on drugs," bringing that country to implement a draconian program of eradi-
cating what had been legal opium crops. But the best showcase of this new policy's
success was not Turkey, but Mexico.
The launching of a major antidrug campaign in Mexico, a turning point in
the history of Mexico's drug policy, was considered by both the United States and the

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Mexican governments as an example of what bilateral cooperation could accom-
plish. Three different programs were organized following DEA advice: eradication of
crops (marijuana and opium poppy plants), interdiction of drugs in transit (includ-
ing cocaine), and dislocation of drug-trafficking organizations. This three-pronged
policy has not been altered since it was established, although the resources commit-
ted to each of the programs have varied. A fourth program, against money launder-
ing, was initiated in the 1990s. 12
By 1975, when Operation Condor-the most ambitious drug crop eradication
program to date-was launched, Mexico had become a major opium and marijuana
production site, the main supplier of both drugs to the United States market, and a
transit point for cocaine (a small market in those days). According to Mathea Falco,
United States assistant secretary of state for international narcotics matters in those
years, Mexicans were supplying around 87 percent of the heroin and nearly 95 per-
cent of the marijuana available on the United States market. Drug-trafficking orga-
nizations had acquired power in traditional drug-producing and -exporting states,
such as Durango and Sinaloa, where the Mexican military, then and now the most
important eradication force, had to fight not only the increase of illegal crops but
also a growing number of armed peasants and smugglers."
For many years, the United States government had been fighting for more strin-
gent enforcement of antidrug laws in Mexico. There is evidence that the DEA was
concentrating efforts on the Mexican case and was ready to fight drug traffickers on
its own or through a "joint law enforcement" program in which the Mexican gov-
ernment refused to participate."
The Mexican government was well aware of its own technical and institutional
limitations and of the DEAS superior police and intelligence capabilities. In 1973
the head of Mexico's Federal Judicial Police had been arrested in San Antonio,
Texas, with eighty-nine pounds of heroin in his possession. Thus, in order to regain
control over intense drug-trafficking areas and to maintain drug-law enforcement

12 On Mexican policy against drugs since the beginning of the century, see Maria Celia Toro, Mexico's "\%r" on

Drugs: Causes and Consequences (Boulder, 1995).


13 Mathea Falco, Winning the \%r on Drugs: A NationalStrategy (New York, 1989), 36. Peter A. Lupsha, "Drug
Trafficking: Mexico and Colombia in Comparative Perspective," JournalofInternational Affairs, 35 (no. 1, 1981),
99.
14 Domestic Council, Drug Abuse Task Force, White Paper on DrugAbuse: A Reportto the President (Washing-
ton, 1975),50.
The DEA in Mexico 629

as a national responsibility, the Mexican government opted for an aerial eradica-


tion campaign. 15
Full implementation of the United States-Mexican drug control program began
in 1976. Under the circumstances (large expanses of land covered with marijuana
and opium poppy plants and powerful, armed traffickers defending them), a massive
aerial eradication campaign with defoliant chemicals seemed adequate. Mexican offi-
cials in charge of Operation Condor, the core program of the late-1970s campaign,
were optimistic about the possibilities of suppressing the market once and for all:
"before mid-year we are going to completely end the cultivation of drugs in this

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country," declared the civilian head of the campaign in January 1976. 16
Dozens of bilateral "letters of agreement" formalized financial and technical aid
for the Mexican government, none of them mentioning the DEAS support and activ-
ities. The core of the United States-Mexican program, however, was the training of
a special anti narcotics unit in Mexico, following the DEA model. Building indige-
nous drug-fighting capabilities in drug-producing and -transit countries, that is,
transforming foreign police into "vicarious surrogates," has been a preferred mode of
DEA action in other countries, and the program continues today in most Latin Amer-
ican countries, Mexico included."
Around thirty DEA agents offered assistance in identifying fields. And after they
discovered that some of the United States aircraft and equipment was not being used
to eradicate drugs and that some was used to spray water rather than defoliants over
the fields, they were allowed to oversee eradication operations. According to Richard
Craig, one of the few political scientists in the United States who has studied Mexi-
can drug policy in detail, 300 members of the 600-member Mexican Federal Judi-
cial Police involved in fighting the trade in narcotics were assigned to the campaign
full time. (That may be the number of Mexican police agents trained by the DEA in
those days.}"
The DBA's roles in the interdiction phase (to seize drugs in transit) and the immo-
bilization phase (to apprehend traffickers) were equally crucial. The Mexican police
and the approximately thirty DEA agents stationed in Mexico gathered and exchanged
information to build conspiracy cases against drug traffickers, especially those trans-
porting drugs from South America to the United States. The bilateral program
included the apprehension and expulsion to the United States of major drug traf-
fickers "without resort to formal extradition procedures." The willingness of the

15 Lyle C. Brown, "The Politics of U.S.~Mexican Relations: Problems of the 1970s in Historical Perspective,"
in Contemporary Mexico, ed. James W Wilkie et al. (Berkeley, 1976), 484. On the technical and financial assis-
tance from the United States government to the Mexican eradication campaign, see Richard Craig, "Operation
Condor: Mexico's Antidrug Campaign Enters a New Era," Journal of Interamerican Studies and World Affairs, 22
(Aug. 1980),345-63; and James Michael Van Wert, "Government of Mexico Herbicidal Opium Poppy Eradica-
tion Program: A Summative Evaluation" (Ph.D. diss., University of Southern California, 1982).
16 Richard Craig, "Human Rights and Mexico's Anti-Drug Campaign," Social Science Quarterly, 60 (March
1980),692.
17 Ethan A. Nadelmann, "Cops across Borders: Transnational Crime and International Law Enforcement"
(Ph.D. diss., Harvard University, 1987),303.
18 Richard Craig, "La Campana Permanente: Mexico'sAnti-Drug Campaign," Journal ofInteramerican Studies
and World Affairs, 20 (May 1978),119-20.
630 The Journal ofAmerican History September 1999

Mexican government, and of many others in Latin America, to cooperate in this


Operation Springboard of the 1970s "was facilitated by the fact that most of the tar-
gets were not citizens of their countries."!"
The results of these intensive and novel drug campaigns were astonishing. Mexi-
can authorities were able to destroy most of the clandestine crops of marijuana and
opium poppy in a few years. Thousands of hectares were defoliated. The amount of
heroin and marijuana seized reached the highest levels ever, except for the seizure
of marijuana in 1984. Major drug traffickers were incarcerated (the Herrera family,
Jorge Favela Escobar, and others). The program was characterized by "good working

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relationships" between Mexican and United States officials, and it was considered a
complete success. Mexico's share of United States heroin and marijuana imports
tumbled to around 25 percent or less in 1980, the lowest percentage ever."
The Americanization of antidrug programs abroad, emphasizing the training of
foreign police units, was not unique to Mexico. The policy was successfully tried in
Europe. In the case of many European police agencies, the DBA introduced new and
often previously unaccepted police practices believed to be conducive to more effec-
tive drug-law enforcement. The DEA forced a relaxation of strict limits on a variety
of police practices, many of them well-developed and legal conduct in the United
States. Nadelmann argues that the European police have been successfully Ameri-
canized by the passage of legislation that permits more use of "proactive investigative
techniques," such as the use of informants and of undercover operations, as well as
the presentation in court of evidence gathered by such means."
But tailoring a DBA counterpart, with carefully selected candidates trained in
anti narcotics tactics, has been impossible in Mexico and all other Latin American
countries. Special agents end up relying on unacceptable police practices or fall vic-
tim to corruption by drug traffickers. Without the support of an effective and reli-
able police force and of a properly working judiciary, many officers are assassinated
or killed in direct battles with traffickers. The policy, however, remains, with largely
the same consequences."

The DBA as an Intelligence Agency

Although it is not empowered to police other countries, the DEA does engage in
police-related activities outside the United States, the most important of which is
intelligence gathering. Intelligence gathering is crucial for the fulfillment of the

19 Ibid, 120. Nadelmann, Cops across Borders, 439.


20For Mexican figures on the amount of drugs destroyed or confiscated every year, 1974-1994, see Toro,
Mexico's "W'ltr" on Drugs, 19-20,25-26. James Michael Van Wert, "El control de los narc6ticos en Mexico: Una
decada de institucionalizacion y un asunto diplornatico" (The control of narcotics in Mexico: A decade of institu-
tionalization and a diplomatic affair), in Mexico -Estados Unidos 1985, ed. Gabriel Szekely (Mexico, 1986), 98.
The figures regarding Mexico's share of United States imports vary depending on the sources used but they all
coincide on the basic downward trend in the second half of the seventies.
21 Nadelmann, Cops across Borders, 189-249.
22 The acting director of the Mexican specialized antidrug unit (Instituto Nacional de Cornbate a las Drogas),
Jose de Jesus Gutierrez Rebollo, was indicted in February 1997 for alleged involvement with drug traffickers. See
Time, March 3, 1997, p. 19.
The DEA in Mexico 631

agency's main task: apprehending and incarcerating drug smugglers. Over the last
two decades, however, the DEA has become "intimately involved in the more opera-
tional aspects of criminal investigation abroad, typically in collaboration with for-
eign police officials. They have recruited and run informants, conducted physical
and electronic surveillance, employed undercover operations, [and] supervised con-
trolled deliveries of illicit drugs. "23
The agency's principal focus is on arrests and convictions, with a preference for
stopping smugglers and eliminating drugs as close as possible to their source. Intelli-
gence collected by the DEA around the world, plus drug-related intelligence gathered

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by many other United States agencies engaged in drug-law enforcement, including
the military, is analyzed and transmitted to operational agencies through the £1 Paso
Intelligence Center (EPIC). Since drug-related information is stored and passed on to
other law enforcers, national or foreign, contingent on a DEA decision, this gives the
DEA, as the police agency of a superpower with a worldwide presence, an advanta-
geous position, practically unparalleled, in international narcotics control. The other
important intelligence-gathering agency after 1982, when it was granted concurrent
jurisdiction with the DEA over drug law enforcement, is, of course, the Federal
Bureau of Investigation (FBI).24
As formal representatives of the DEA abroad, agents in Mexico work as a liaison-
personal de enlace-with their colleagues in the United States and their Mexican
counterparts, for the exchange of information. Some of the evidence collected by
DEA agents comes from the Mexican police itself. The United States agents agree to
share their own intelligence with the local counterparts-although they do not
always do so-in order to facilitate the latter's job of tracking down smugglers and
trafficking routes.
Paying informants is standard procedure for DEA agents. The money paid for
drug-related information is substantial, and it is offered to a variety of people. Within
the potentially huge world of possible informants, police and ex-police agents and
members of drug-trafficking groups are the most valuable. While police and drug traf-
fickers themselves can provide the most "juicy" information, they, like other infor-
mants, can also cheat DEA agents with misleading or false data. In the sordid world
of informants, all of whom have interests that go beyond helping the police, any-
thing can happen.
More important than money, which a trafficker can easily outbid, the DEA can
offer legal or undercover protection to police, traffickers, or other informants. It can offer
effective and credible protection-for instance, under the witness protection pro-
gram administered by the United States Marshals Service-to key informants, such
as major drug traffickers. Protection can be informal and clandestine or open and
legal, as in the case of drug traffickers from other countries taken to the United
States and offered reduced sentences in exchange for information regarding the orga-
nization of the drug market in their own countries.

23 Nadelmann, Cops across Borders, 107.


24 U.S. Congress, Office of Technology Assessment, The Bordermtr on Drugs (Washington, 1987),33.
632 The Journal of American History September 1999

Another police activity of DBA agents is undercover operations. An allowed police


practice in the United States, it has proven a powerful technique in other countries
too. Undercover operations by United States antidrug agents in Mexico can be
traced, that is, documented, to at least the 1930s. Evidence on such activities is obvi-
ously difficult to obtain. What are available, with all their shortcomings, are biogra-
phies of police and intelligence agents and some consular papers. Most undercover
operations today are "uncovered" by the media in the midst of major international
scandals, such as the Camarena affair in February 1985. After the murder of DBA
agent Enrique Camarena at the hands of Mexican traffickers and police who were

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on drug traffickers' payroll, the Mexican government and public learned that
Camarena had been working largely undercover. More recently, in 1998, an
undercover operation against money laundering called Casablanca (which was not
conducted by the DEA) was the origin of yet another diplomatic fight between
Mexico and the United States."
Finally, the DBA sets up "controlled deliveries" as an evidence-gathering strategy
and engages in electronic surveillance, typically wiretapping. That has proven an
effective police instrument to uncover major money-laundering operations.

Policing Mexico: The Extraterritoriality Issue

Many of the police activities already outlined have been carried out by DBA agents in
Mexico (and in many other Latin American countries) for a long time, and they
have often been arranged with the Mexican police as an important participant. In
fact, much of the "work" is done by Mexican agents who can either use their formal
police powers or are paid by the DEA.
In the 1980s, however, the DEA decided to work increasingly on its own, without
notifying Mexican authorities, be they police or others. Without diminishing its cus-
tomary activities-building local drug-fighting capabilities and gathering and shar-
ing information-the DBA did abandon its traditional cooperative scheme with its
counterparts in most of Latin America. In this framework, which had prevailed for
many decades, DBA agents or their predecessors stationed themselves in other coun-
tries in order to assist local antinarcotics police in the enforcement of antidrug laws,
to compile intelligence that could be used to seize drugs in transit or apprehend traf-
fickers in United States territory, or to ask local police to do both. In other words, for
a long time, the DEA was willing to work with local police and to assume its role as a
police agency in a foreign country, accepting the restrictions imposed by host gov-
ernments. These restrictions were never completely respected, but neither were they
so blatantly disregarded as in the last decade."

25 See Walker, Drug Control in theAmericas; and Nadelmann, Cops across Borders, 96. On the Camarena affair,
see Juan David Lindau, "Percepciones mexicanas de la polftica exterior de Estados Unidos: EI caso Camarena
Salazar" (Mexican perceptions of United States foreign policy: The case of Camarena Salazar), Foro Internacional
(Mexico City), 27 (April-June 1987), 562-75. On Casablanca, see Time, June 1,1998, pp. 12-17.
26 Maria Celia Toro, "Estrategias mexicanas de negociacion: EI caso del narcotrafico" (Mexican negotiating
strategies: The case of drug trafficking), in Mexico ante elfin de fa Guerra Fria (Mexico at the end of the Cold
War), ed.nan Bizberg (Mexico, 1998),334-35.
The DEA in Mexico 633

Mexico was not the only country that experienced this new turn in United States
drug policy. DEA agents and operations increased throughout Latin America,
most notably in Colombia, Peru, and Bolivia. After 1986 the United States gov-
ernment pressed the governments of Peru and Colombia to declare the cocaine
business a threat to national security. According to Walker, as those Latin Ameri-
can governments bowed to the pressure, they expanded their drug-control pro-
grams and came to rely on even more United States aid and growing numbers of
DEA agents."
By the mid-1980s, the DEA had apparently decided that working with the Mexi-

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can police was hopeless. The Americanization effort of the 1970s had not led to a
better narcotics police force in Mexico nor to a constant downsizing of the Mexican
drug market." The new policy was based on a long-held but until then discreetly
suppressed diagnosis about Mexican police, namely, that they were incorrigibly cor-
rupt. Further, the DEAS lack of confidence in local police who were all too fre-
quently involved in drug trafficking led to distrust of the whole Mexican criminal
justice system. The police agency thus turned to a forceful diplomacy to influence
other countries' antidrug programs and to clear the way for a new experiment: act-
ing as a "transnational police."
While the DEA was not the only United States law enforcement agency interested
in publicizing corruption in Mexico in the 1980s, in the case of drug-related corrup-
tion it was certainly the best informed and the one that fought most decidedly
against it. In their new role as tough diplomats, DEA agents found that the prevailing
environment in the United States allowed them to escalate pressure on recalcitrant
governments. Political pressure took many forms, from promoting media and con-
gressional oversight of corrupt police agencies in Mexico to leaking information to
the United States press that incriminated Mexican politicians and high-ranking offi-
cials (with or without basis), compiling lists of prominent Mexicans presumably
involved in drug trafficking, and calling for a "partial closure" of the United States-
Mexican border in February 1985 (a week-long heightening of scrutiny of vehicles
and people crossing the border) to accelerate Mexican investigations of Camarena's
kidnapping in Guadalajara. 29
Thus discrediting their counterparts, DEA agents turned "more operational" in
countries such as Mexico, aided by the United States government's increasing asser-
tion of judicial extraterritoriality. Taking Mexican criminals to the United States by
means forbidden by Mexican law-another way in which DEA agents have tried to
make their police power effective beyond United States borders-was an important
part of the new antidrug strategy. The kidnappings of Rene Martin Verdugo-Urqufdez
in 1986 and Humberto Alvarez Machafn in 1990, both Mexican citizens and resi-
dents suspected of involvement in the death of Enrique Camarena, were the most

27William o. Walker III, "International Collaboration in Historical Perspective," in DrugPolicy in theAmeri-


cas, ed. Peter H. Smith (Boulder, 1992), 275.
28 For the best analysis of United States expectations regarding Mexican antidrug programs, see Peter Reuter,
Questfor Integrity: TheMexican-US. DrugIssue in the 1980s (Santa Monica, 1992).
29 Lindau, "Percepciones mexicanas de la politica exterior de Estados Unidos."
634 The Journal of American History September 1999

conspicuous, but not the only, abductions of Mexican citizens sponsored by the DEA
in Mexico.
The single most important catalyst of the new policy [the "irregular rendition of
fugitives"] was the abduction, torture, and murder of Enrique Camarena. . . .
When U.S. efforts to investigate the incident faced not just resistance on the part
of the Mexican authorities but also substantial evidence that top Mexican officials
had been involved in both the abduction and the subsequent cover-up, the DEA
and the Justice Department officials reacted with fury.... the drug enforcement
agency combined with federal prosecutors and Justice Department officials in an
all-out effort to track down those involved in Camarena's murder and ensure that

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they were brought to trial."
A similar punitive outreach was also observed among United States prosecutors,
who began utilizing subpoenas more readily to obtain information from abroad,
especially in cases involving money laundering, and also in United States courts,
where the number of foreigners indicted on drug-trafficking charges grew to unprec-
edented levels. The number of Mexicans, some of them quite prominent, indicted
in United States courts and incarcerated in United States prisons for drug-related
crimes showed a dramatic increase toward the end of the decade.
All antidrug law enforcement operations in Mexico, from the more traditional to
the more sophisticated, were enlarged and enhanced. In a wild effort to circumvent
national jurisdictions limiting their power, DEA agents decided to rely more heavily
on the possibility of extraterritorially enforcing United States laws. In practical terms
that meant working toward the indictment of foreigners, in this case Mexicans, in
United States courts, taking Mexican drug traffickers to the United States, present-
ing them to United States courts, and putting them in United States prisons. In the
worst-case scenarios, the extraterritorial enforcement of United States drug laws
ended in United States occupation, albeit temporary, as in Bolivia in 1986, or inva-
sion, as in Panama in 1989.
The new policy, unsurprisingly, became a serious concern for Mexican authorities
and the most important source of conflict between Mexico and the United States
over drug trafficking.

Negotiating with the DEA: Understanding the Host Country

The Mexican government's first, early-twentieth-century, reaction to the presence of


United States drug-law enforcement agents in its territory, which usually involved a
sporadic, unauthorized police crossing at the United States-Mexican border in
search of fugitives, was to outlaw hot pursuit and to offer law enforcement coopera-
tion in return for United States acknowledgement of the Mexican border. Thus the
illegal crossing into Mexican territory by United States law enforcers in hot pursuit
of criminals represented the first, and for a long time remained the most open, form
of disregard for national jurisdictions.

30 Nadelmann, Cops across Borders, 447.


The DEA in Mexico 635

Bilateral clashes over sovereignty during the first decades of this century were
always acrimonious. Toward the end of the 1930s they were solved by informally
authorizing the presence of United States antinarcotics agents in Mexico to gather
intelligence (a presence that the Mexican government was unable to prevent), regu-
lating the crossings of United States law enforcers (who were required to inform
Mexican authorities about their crossing and departure dates in advance), and offer-
ing more effective assistance against border-crossing outlaws, drug traffickers, and
others. None of these Mexican rulings was always observed."
Sovereignty has been the most important power resource at the disposal of the

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Mexican government in its dealings with United States antinarcotics police. Sover-
eign prerogatives, which foreign security forces can challenge, explain Mexico's long-
standing resistance to granting United States police agents access to Mexican terri-
tory; they also explain why international agreements are in order when governments
assist each other in the police and criminal justice realms.
That sovereign power notwithstanding, bilateral agreements on the fundamental
points were impossible for many decades, and even today those agreements are con-
tinuously revised. Until the late 1960s, Mexican authorities were unable and at times
unwilling to negotiate a formal bilateral framework to establish the rules of conduct
for United States drug enforcement agents in Mexico. "Mexico chose," says Walker,
"largely to ignore what could have been construed as serious challenges to its sover-
eignty." More often than not, however, the United States government refused to dis-
cuss details regarding American narcotics agents in Mexico with the Mexican
government. 32 Both governments may have benefited from keeping the arrange-
ments informal: Mexico expressing its basic disapproval and hoping that United
States agents would assume their status as a police force in a foreign territory and act
accordingly, the United States content to work basically unrestricted, without having
to abide by its host's rules. This informality, nevertheless, was a factor in United
States agents' working as far away from public and governmental eyes as possible.
For the Mexican government, that was a highly undesirable development.
Mexico's decision to embrace open and formal cooperation with the DEA in the
1970s was largely a result of its inability to control DEA agents within its own terri-
tory. Unable to rely solely on its authority to mold the behavior of those police
agents, the Mexican government made bilateral agreement its chosen means to limit
United States police authority in Mexico. The United States government was willing
to sign such agreements because it admitted, at least in principle, the need to have
authorized and continuous access to Mexican police and to Mexico's criminal world.
With the deliberate purpose of deterring aggressive DEA tactics in the aftermath of
Camarena's assassination (most notably tactics of gathering evidence in Mexico for
use in the prosecution of Mexicans in United States courts and the rendition of
Mexican fugitives from United States justice), Mexican officials tried to accelerate

31 Walker, Drug Control in theAmericas. On changes in Mexico's antidrug programs in the 1930s, see Robert L.
Jones, TheEighteenth Amendmentand Our Foreign Relations (New York, 1933).
32 Walker, "International Collaboration in Historical Perspective," 273.
636 The Journal of American History September 1999

the signing of a Mutual Legal Assistance Treaty (MLAT) in 1987, in force as of May
1991, and asked for a modification of the 1978 United States-Mexican Extradition
Treaty. The Mexican government also signed a bilateral agreement specifically pro-
scribing abductions of Mexican citizens and sought to renegotiate bilateral guide-
lines for the activities of DEA agents in Mexico. In the 1980s, much of Mexico's haste
to come to terms with the United States on drug-trafficking issues was the result of
DEA activities that were considered an unacceptable breach of Mexican sovereignty.
The 1989 Agreement on Cooperation in Combatting Narcotics Trafficking and Drug
Dependency emphasizes that "The Parties will fulfill their obligations under this

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Agreement in accordance with the principles of self-determination, non-intervention
in internal affairs, legal equality; and respect for the territorial integrity of States."
The very text of the treaties is thus quite eloquent regarding Mexico's interest in
keeping drug-law enforcement as an exclusive prerogative of the state."
Apart from seeking bilateral understandings and forcefully protesting violations
of them, the other typical response of the Mexican government to the international-
ization of United States narcotics police has been enacting laws to regulate DEA activ-
ities in Mexico. The kidnapping of Alvarez Machafn, for instance, had an immediate
effect on Mexico's laws regarding DEA agents in its territory. In legislation sent by the
Mexican president to Congress and quickly passed, transnational kidnapping was
established as a crime "against the homeland." Mexican citizens who collaborated or
participated "in the kidnapping of persons within the national territory for the pur-
pose of their being delivered to foreign authorities" were to be severely punished. For-
eigners who participated in kidnapping for similar purposes were subject to immediate
expulsion. In addition, in July 1992 the Mexican president issued a "Decree on Rules
for the Temporary Stay of Foreign Agencies Representatives." Those agents
may only serve as liaison with the Mexican government for the purpose of sharing
information; their stay in the country shall be temporary; they are compelled to
"strictly observe applicable Mexican legislation"; and at no time may they engage
in functions "expressly assigned to Mexican authorities." . . . Agents shall be
accredited before the Ministry of Foreign Affairs and registered before the Minis-
try of the Interior, and the Office of the Attorney General. They will not be
immune from penal codes. They may not have contacts with other authorities
than those specified in the Dccree"
Information obtained by foreign agents, according to the new legislation, must be
shared "immediately" with their Mexican counterparts. Foreign agents promoting, or
engaging in the "incitement" of others to undertake, the kidnapping of Mexican nation-
als to another country shall be expelled "automatically" from the country, the respec-

33 u.s. Congress, Senate, Committee on Foreign Relations, Mutual LegalAssistance Cooperation Treaty with
Mexico, S. Treaty Doc. 100-13,100 Cong., 2 sess., Feb. 16,1988; Extradition Treaty between the United States
of America and the United Mexican States, May 4, 1978, 31 U.S.T. 5059, T.I.A.S. No. 9656. For the passage
from the 1989 agreement, see Secretarfa de Relaciones Exteriores, Limits to Nationaljurisdiction, 54-55. See also
ibid., 36.
34 Eugenio Ursiia Cocke, "Drug Traffic, Law and International Relations," Revista de Investigaciones Juridicas
(Mexico City), 18 (no. 18, 1994),291-92.
The DEA in Mexico 637

tive cooperation accord shall be "'immediately suspended,' and the responsible foreign
nation will be prevented from engaging in any further such activity in Mexico."35
President Carlos Salinas spoke strongly on the issue of kidnapping. At the end of
a Salinas-George Bush meeting in San Diego on July 14, 1992, the Mexican presi-
dent rejected as invalid the decision of the United States Supreme Court in United
States v. Alvarez Machain upholding the kidnapping of foreign nationals by United
States police. He declared that "Mexico forbids the operations of foreign agents in
its territory," "allows their presence only for drug information purposes," and "will
act strongly against whoever engages in violations of the pertinent law."36

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A third response, which I will mention only in passing, to actual or possible
encroachments on Mexican sovereign faculties to enforce antidrug laws has been to
reorganize Mexican programs against drug trafficking. All major "wars on drugs"
undertaken by the Mexican government have had an important outward orienta-
tion. This is not to minimize the domestic political threat posed by Mexican drug
traffickers. Mexican drug policy has been designed both to "prevent drug traffickers
from directly confronting state authority and, equally important, to prevent U.S.
police and judicial authorities from acting as a surrogate justice system in Mexico."37
If the sovereign right to grant, and establish the terms of, United States police
access to its national territory has been Mexico's most important strength, the lack of
a properly working criminal justice system, specifically the absence of a professional
police, has been its main weakness. The institutional limitations on Mexico's effec-
tive control of its illegal drug market have perhaps been the most important impedi-
ment to keeping antidrug law enforcement a national affair.
Mexico's quest for autonomy has been hampered, in fact rendered impossible, by
an increasingly punitive antidrug policy that has stimulated, rather than halted, drug
production and trafficking. The 1980s drug boom that Mexican authorities unsuc-
cessfully tried to suppress had a devastating impact on a traditionally feeble criminal
justice system, as the levels of drug-related corruption and violence in Mexico show.
Typically, when confronted with an emergency-as in the mid-1970s, the mid-1980s,
and the mid-1990s-Mexican officials in charge of narcotics control have relied on
DEA support to compensate for technical and institutional weaknesses. Such reliance is
a common thread in, for example, the aerial eradication program implemented by
the administrations of Luis Echeverria and Jose Lopez Portillo (Operation Condor),
the air interdiction program against cocaine smuggling during the Salinas administra-
tion (the Northern Border Response Force), and the current programs to seize drugs
crossing Mexican territorial waters and to fight money laundering. At the core of all
those antidrug programs have been joint United States-Mexican efforts, relying
heavily on DEA advice and intelligence.
As drug traffickers become more powerful and sophisticated, the Mexican drug-law
enforcement system is less able to develop effective countermeasures. In the 1970s the
Mexican government did develop a capacity to eradicate drugs, heavily relying on its
35 Ibid
36 Ibid, 292-93.
37 Toro, Mexico's "~r" on Drugs, 2.
638 The Journal of American History September 1999

military. Over time, the presence of the Mexican army in areas of opium and mari-
juana cultivation has grown to around twenty-five thousand soldiers; they are
engaged almost year round in manual eradication. Mexico also has the largest air
fleet on the continent for defoliating drug plants (mainly helicopters and light air-
craft for aerial spraying and transportation of personnel). Although the continuous
presence of the armed forces in rural areas may be regarded as a political necessity
and relying on soldiers a better option than increasing the number and powers of
police, eradication programs have shown their limitations: they are ineffective in
reducing drug cultivation and smuggling."

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Since 1987, most of the budget of the attorney general's office in Mexico has
been assigned to federal antidrug law enforcement, and antidrug activities dominate
the work of that office as far as implementation of justice is concerned. Police train-
ing, as well as the systematic discharge of police agents involved in drug trafficking,
has become routine. Yet for all those efforts, Mexico does not have a working judi-
ciary. Not only police, but also judges, prosecutors, and prison custodians have been
bought or intimidated by drug traffickers, The professionalization of police remains
the most elusive of all Mexican programs to reform its criminal justice system.
In this context, the DEA may be valuable to the Mexican government in several
ways: It acts as a warning mechanism regarding the extent of police and other gov-
ernment officials' corruption; it provides information on international drug traffick-
ing that the Mexican police cannot possibly gather on its own; and it is a constant
reminder of the weaknesses of local police agencies. Moreover, relying on the DEA
and, at times, on the United States criminal justice system can be a last resort for
Mexican authorities, a desperate way out, as the deportation in 1996 of the smug-
gler Juan Garda Abrego to the United States demonstrated."
Mexico's lack of control over its own police simply extends to foreign police. The
ways and means of Mexican police agents are as contrary to the rule of law as are
unauthorized DEA practices. In fact, very frequently, questionable DEA activities can-
not be called illegal given the absence of domestic legislation proscribing them. To
the extent that DEA agents hide information from the host government (arguing that
their Mexican counterparts are totally corrupt), their activities can be best described
as standard espionage. To the extent that Mexican police are paid (by the DEA) to
send delinquents to the United States in violation of Mexican law or are remuner-
ated to work for the DEA, the Mexican state loses its monopoly over law enforcement
and intelligence gathering in the territory it claims to govern. To the extent that an

38 The program combines aerial and manual eradication. After fields are sprayed from the air with defoliants,

soldiers cover the fields, using machetes to cut, or manually pulling out, opium poppies and marijuana plants.
Cutting poppy plants is necessary because for a day or two after herbicidal spraying, the flowers can still be har-
vested and used to produce opium. Marijuana, similarly, may sometimes be packed and shipped for consumption
immediately after spraying. Sergio Garda Ramirez, Narcotrdjico: Un punto de vista mexicano (Drug-trafficking: A
Mexican point of view) (Mexico City, 1989); Peter Reuter, "Eternal Hope: America's Quest for Narcotics Con-
trol," Public Interest (no. 79, 1985), 79-95; Javier Trevino, "Evaluaci6n de la estraregia internacional de erradi-
cacion de cultivos" (An evaluation of the international strategy for [drug] crop eradication), paper delivered at the
conference "El Colegio de Mexico-Harvard sobre un Nuevo Enfoque a la Estraregia Antinarc6ticos Mexico-
Estados Unidos," April 1988 (in Maria Celia Toro's possession).
39 Reforma (Mexico City), Jan. 17, 1996.
The DEA in Mexico 639

increasing number of Mexican drug traffickers face trial in United States courts, the
territoriality of law enforcement is at stake.
For traffickers and corrupt officials, the DEA represents a major threat to the con-
tinuation of their illegal businesses. For honest police, working with DEA agents can
easily turn into working for them. Neither promotion nor permanence in their jobs
depends on the foreign agents, but they can influence both. Whatever the day-to-
day relationship between Mexican police and DEA agents, there is little evidence that
over time they have developed a "sense of professionalism and police comradeship
which transcends national borders," as seems to be the case in the interaction

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between European and American police.t''

Conclusions

Students of world politics who focus on transnational relations explain the inter-
nationalization of police as the result of nations' common interest in fighting trans-
national crimes; police cooperation between countries in the form of joint law
enforcement operations will be a natural corollary of the inevitable rise in transna-
tional activities, both legal and illegal.
The internationalization of the most important United States police agency
enforcing antidrug laws, the DEA, has been dramatic during the last twenty years.
The activities of DEA agents in Mexico, and presumably in many other Latin Ameri-
can countries, do not quite fit within the model of international police in a border-
less world. Rather, the DBA's presence and work in Mexico is best explained as the
extraterritorial enforcement of United States antidrug laws.
In its effort to stop drug smuggling into the United States, the DEA has not only
proposed a police model for other countries to follow but has also worked as an
intelligence-gathering agency in foreign territories, learned to put pressure on other
governments, and, finally, tried to become a transnational police by increasingly rely-
ing on extraterritorially enforcing United States laws.
The sovereign authority that practically all governments bring to bear on foreign
police agents, of whatever nationality, explains that the DEA has been forced, while
abroad, either to circumvent national jurisdictions or to reshape, that is, American-
ize, drug-law enforcement in host countries as the only means to bolster United
States drug-law enforcement capabilities. For years, the creation and training of
specialized antinarcotics police units and intelligence gathering were the DEAS
most important jobs outside the United States. In Mexico, building a suitable
counterpart agency has not been possible. After the Americanization of drug-law
enforcement by other countries failed, the DEA slowly but surely itself American-
ized enforcement toward the end of the 1980s. 41 New or modified United States
antidrug laws, coupled with the export of legally and politically well equipped DEA

40 Ethan A. Nade1mann, "Unlaundering Dirty Money Abroad: u.s. Foreign Policy and Financial SecrecyJuris-
dictions," University ofMiami Inter-American Law Review, 18 (no. 1, 1986),43.
41 Bruce M. Bagley, "Colombia and the War on Drugs," Foreign-Affairs, 67 (no. 1, 1988),70-92.
640 The Journal of American History September 1999

agents, presented a novel and unique challenge to state authority in many Latin
American countries.
The DBA's ascendancy over Mexican drug policy has been significant. It has noto-
riously influenced antidrug legislation; the content, pace, and intensity of drug con-
trol programs; and police practices and targets. In some ways, during the 1980s the
influence of DBA agents was probably stronger abroad than in the United States.
Mexico has responded to the stationing of United States antidrug agents in its ter-
ritory in three ways: (I) legislating to prohibit specific activities by foreign police
agents; (2) negotiating bilateral agreements on the limits to those agents' capacities;

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and (3) adopting more stringent antidrug programs. Yet, by and large, the Mexican
state has been unable to make DBA agents behave as befits representatives of a foreign
police agency. Mexico's increasing reliance on United States police and intelligence
also explains an extremely peculiar situation-the admitting of superior security
forces into one's own territory.
As the Mexican government has painfully learned over time, DBA agents are far
from being freewheeling enforcement agents fighting drug traffickers around the
world. Their police activities both in the United States and abroad contract or
expand with United States policy and Iegislation." Historically, United States nar-
cotics agents have been more effectively restricted in their activities abroad by their
own government than by Mexican decisions and legislation. The foreign agent's ulti-
mate duty is to his own country; he may risk disobedience abroad, but he must be
careful to comply with his own government's regulations. In this sense, United States
drug-law enforcers traveling abroad cannot be seen as part of an effort to constitute
an international police force, but rather as a national police working, with more or
less restriction, in another polity.
The internationalization of police has been the result of a world power extend-
ing its police and judicial arms into other countries-in Latin America, into
countries with extremely weak criminal justice systems. Thus, in the case of the
United States and Mexico, two fundamentally unequal nations test the extent and
the limits of sovereignty.

42 For a similar argument on the conduct of powerful transnational actors, see Stephen D. Krasner, "Power
Politics, Institutions, and Transnational Relations," in BringingTransnational Relations Back In: Non-StateActors,
Domestic Structures, and International Institutions, ed. Thomas Risse-Kappen (New York, 1995).

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