Audit of USAID/West Bank and Gaza's Implementation of Executive Order 13224-Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism

摘要

The Regional Inspector General in Cairo, Egypt, conducted this audit to determine whether USAID/West Bank and Gaza implemented policies, procedures, and controls to comply with Executive Order 13224, which is intended to block property and prevent transactions with terrorists, potential terrorists, and their supporters. The audit found that USAID/West Bank and Gaza has, in fact, implemented policies, procedures, and controls. Our opinion was based on the missions (1) compliance with obtaining antiterrorism certifications from organizations awarded grants or cooperative agreements, (2) compliance with the inclusion of mandatory antiterrorism clauses in contracts and grants, (3) the correction of vetting database deficiencies previously identified, and (4) compliance with required vetting of organizations and individuals. With regard to required antiterrorism certifications and clauses, we reviewed all 42 prime awards and 20 randomly selected subawards that started during the 2-year period of January 1, 2005, through December 31, 2006. Of the 26 awards and subawards requiring antiterrorism certifications, all were compliant. Of the 60 awards and subawards requiring mandatory clauses, 59 were compliant. The one exception was a March 2005 purchase order subaward (no longer active) for approximately $91,000 that did not include the mandatory clauses; however, the applicability of mission guidance to purchase orders was not sufficiently clear. The mission made substantial progress in correcting vetting database deficiencies previously identified, which included deploying a new vetting database, providing a four-part name in almost all database records, limiting the information able to be entered into approved data tables, eliminating the ability to overwrite data, establishing a clear audit trail for changes made to the data, storing vetting reports in locked cabinets, and designating the head of the Office of Contracts Management as the system owner for the new vetting database.