2021 HIGH-RISK LIST
Special Inspector General for Afghanistan Reconstruction

The National Defense Authorization Act for FY 2008 (Pub. L. No. 110181) established the Special Inspector General for Afghanistan
Reconstruction (SIGAR).
SIGAR’s oversight mission, as defined by the legislation, is to provide for the
independent and objective• conduct and supervision of audits and investigations relating to the programs
and operations funded with amounts appropriated or otherwise made available
for the reconstruction of Afghanistan.
• leadership and coordination of, and recommendations on, policies designed
to promote economy, efficiency, and effectiveness in the administration of the
programs and operations, and to prevent and detect waste, fraud, and abusein such programs and operations.
• means of keeping the Secretary of State and the Secretary of Defense fully
and currently informed about problems and deficiencies relating to theadministration of such programs and operations and the necessity for andprogress on corrective action.
Afghanistan reconstruction includes any major contract, grant, agreement,or other funding mechanism entered into by any department or agency of the
U.S. government that involves the use of amounts appropriated or otherwise madeavailable for the reconstruction of Afghanistan.

As required by the National Defense Authorization Act for FY 2018 (Pub. L. No.
115-91), this report has been prepared in accordance with the Quality Standards
for Inspection and Evaluation issued by the Council of the Inspectors General on
Integrity and Efficiency.
Source: Pub.L. No. 110-181, National Defense Authorization Act for FY 2008, 1/28/2008; Pub. L. No. 115-91,
National Defense Authorization Act for FY 2018, 12/12/2017.

Cover photo:
An Afghan policeman keeps watch at a security outpost in the Maiwand district of Kandahar Province.
(AFP photo by Wakil Kohsar)

Front cover photo from AFP by Wakil Kohsar.

PUBLISHED IN ACCORDANCE WITH THE CIGIE QUALITY STANDARDS FOR INSPECTION AND EVALUATION.

SPECIAL INSPECTOR GENERAL FOR
AFGHANISTAN RECONSTRUCTION

I am pleased to present SIGAR’s 2021 High-Risk List to the 117th Congress
and the Secretaries of State and Defense. In keeping with SIGAR’s statutory
mandate to promote economy, effectiveness, and efficiency, the High-Risk
List identifies serious risks to the United States’ $143 billion reconstruction
effort in Afghanistan. This fourth report is issued at a time when peace negotiations between the Afghan government and the Taliban are stalled amid
continuing high levels of violence, putting the reconstruction effort at greaterrisk than ever before.
As we note in this report, whether or not the United States continues towithdraw its troops from Afghanistan pursuant to last year’s withdrawal
agreement with the Taliban, the new Administration and Congress will haveto decide whether and to what extent reconstruction will continue. Although
Afghanistan’s leadership have often stated that their goal is self-reliance,
Afghanistan today is nowhere near to being self-reliant—especially in funding its government operations, including military and police—from its own
resources. And, as highlighted in our report, reconstruction aid helps keep
Afghanistan from reverting to a terrorist safe haven.
U.S. funds appropriated since 2002 for Afghanistan’s reconstruction havebeen used to train, equip, and sustain the Afghan security forces, strengthen
government institutions, promote the rule of law, emphasize the protection ofhuman rights—particularly women’s rights—improve health and education,and stimulate economic development, among other objectives.
Today the gains from our nation’s investment in Afghanistan’s reconstruction face multiple threats: continued insecurity, uncertain post-peace
settlement funding, the challenge of reintegrating fighters, endemic corruption, lagging economic growth and social development, threats to women’s
rights, the illicit narcotics trade, and inadequate oversight by donors. In particular, the level of violence has increased, including not only attacks against
Afghan security forces, but also bomb attacks on civilians and targeted assassinations of midlevel officials, prominent women, and journalists. Meanwhile,
the COVID-19 pandemic is overwhelming Afghanistan’s health sector and having a severe impact on its economy and people.
The total number of U.S. and other Coalition troops in Afghanistan has
now fallen to the lowest level since the first days of the U.S. intervention.
The return of most service members after years of deployments is a welcome
development, but it brings a new set of challenges to sustaining what has beenachieved since 2001 in one of the world’s most isolated, impoverished, andconflict-plagued countries.
At the November 2020 Afghanistan Donor Conference held virtually in
Geneva, participants from 66 countries and 32 international organizations
pledged at least $3.3 billion in development aid for 2021, according to the2530 CRYSTAL DRIVE ARLINGTON, VIRGINIA 22202

United Nations, with annual commitments expected to stay at the same level
until 2024. This was down significantly from the amounts pledged in 2016,
and close to the bare minimum in civilian assistance, which, along withanother $3.6 billion in security assistance, is estimated by two experts asnecessary to preserve Afghanistan as a viable state.
Like its predecessors, this report is intended to provide an independentand sober assessment of the various risks now facing the Administration
and Congress as they seek to make decisions about the future of the U.S.
mission in Afghanistan. American taxpayers and Afghan citizens alike sharean interest in protecting the achievements of U.S. reconstruction efforts.
Conducting effective oversight of remaining reconstruction programs, evenat reduced levels of assistance, will likely be complicated by having fewer
U.S. civilian and military personnel in Afghanistan.
Regardless of the course chosen, SIGAR, as the largest oversight presence in Afghanistan and the only one with whole-of-government authority,
will remain the best U.S. defense against the waste, fraud, and abuse of
U.S. taxpayer funds in that country.
Sincerely,

John F. Sopko
Special Inspector General for Afghanistan Reconstruction

CONTENTS
2

4

EXECUTIVE SUMMARYINTRODUCTION

12
HIGH-RISK AREA 1:
Increasing Insecurity

22

28

32

HIGH-RISK AREA 2:

HIGH-RISK AREA 3:

HIGH-RISK AREA 4:

Uncertain Funding fora Post-Peace
Settlement

38
HIGH-RISK AREA 5:

The Need toReintegrate
Ex-Combatants

Endemic Corruption

44

48

HIGH-RISK AREA 6:

Illicit Narcotics Trade

HIGH-RISK AREA 7:

Lagging Economic
Growth and Social
Development

54

62

65

HIGH-RISK AREA 8:

CONCLUSION:

Inadequate Oversight

Risks Have NeverBeen Higher

Threats to
Women’s Rights

ENDNOTES

2021 HIGH-RISK LISTEXECUTIVE SUMMARYThe Special Inspector General for Afghanistan
Reconstruction (SIGAR) is publishing the 2021 HighRisk List to alert Members of the 117th Congress andthe Secretaries of State and Defense to major areasof the reconstruction effort in Afghanistan at risk ofwaste, fraud, abuse, mismanagement, or mission failure. Since 2014, SIGAR has developed a high-risk list
for each new Congress.
This fourth report is issued at a time when peace
negotiations between the Afghan government and the
Taliban are stalled amid continuing high levels of violence, putting the $143 billion reconstruction effort
at greater risk than ever before. The eight high-riskareas are:

INCREASING INSECURITY• Despite early hopes surrounding the February 29,
2020, U.S.-Taliban agreement and the initiationof Afghan peace talks in September 2020, Taliban
attacks on the Afghan National Defense andSecurity Forces (ANDSF) have intensified since
the deal, and ANDSF and civilian casualties
remain high.
• As of January 15, 2021, the United States has
about 2,500 troops in Afghanistan, the lowest
force level since 2001. U.S. funds appropriated for
ANDSF support in FY 2021 (roughly $3 billion)
are lower than they have been since FY 2008.
• NATO Resolute Support train, advise, andassist mission advisors have reduced contact
with Afghan security ministries and theirforces due to U.S. troop reductions and the
COVID-19 pandemic.
• Though some ANDSF capabilities have improved
since the last High-Risk List, the force still faces
long-term capability and sustainability challenges
that require various forms of continued U.S.
military support.

UNCERTAIN FUNDING FOR A
POST-PEACE SETTLEMENT
2• Afghanistan remains exceptionally dependent
on foreign aid, obtaining funds for almost 80%
of its $11 billion in public expenditures fromforeign donors in 2018, the most recent year that
estimates are available.

• Future funding for Afghanistan faces two
principal risks: (1) whether expanding theconditions donors set for funding will be
sufficient incentive to facilitate and maintain an
acceptable peace agreement, and (2) whether thelevel of foreign assistance during this uncertain
period is sufficient to prevent state collapse.
• International donors’ aid pledges have declined,
and the level of future years’ funding may fall—possibly to levels threatening the viability of the
Afghan state—if donor conditions are not met.
• The decrease in aid comes despite an earlier
World Bank estimate that peace would requirearound $5.2 billion in new and additional publicfinancing for civilian assistance through 2024.

NEED TO REINTEGRATE
EX-COMBATANTS• An Afghan peace agreement could entail
massive economic, social, political, and security
disruptions as the Afghan government seeks toreintegrate ex-combatants from both sides into
civil society.
• Afghanistan will likely face significant challenges
based on the mixed record of its reintegration
efforts since the late 1980s.
• Its success will be critical for Afghanistan toachieve lasting peace and stability.

ENDEMIC CORRUPTION• Afghanistan has long been perceived as one of
the world’s most corrupt states.
• The failure to effectively address systemic
corruption means U.S. reconstruction programs,
at best, will be subverted and, at worst, will fail.
• The Afghan government’s anticorruption efforts
have suffered from vague strategies and insufficientactions, despite donors’ exhortations and someanticorruption conditions attached to aid.
• The donor-negotiated Afghanistan Partnership
Framework commits to the principle ofconditioning future assistance, but failed to set
specific financial consequences for the Afghan
government if its anticorruption and otherobligations to donors are not met.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONEXECUTIVE SUMMARYLAGGING ECONOMIC GROWTH AND
SOCIAL DEVELOPMENT• Persistent corruption, an over-reliance oninternational aid, worsening security conditions,and limited government capacity, all compoundedby the COVID-19 pandemic, inhibit sustainable
progress in Afghanistan’s economic andsocial development.
• In 2020, the pandemic wiped out Afghanistan’smodest 3% growth in 2019 as the Afghan economy
contracted by an estimated 5% of GDP.
• According to the UN, about half of Afghanistan’s
population requires humanitarian assistance in
2021 due to health and socio-economic impacts ofthe pandemic—a six-fold increase in four years.
• The pandemic has also hampered progress in
Afghanistan’s education and health sectors by
causing school closures and forcing most of
the country’s limited health resources to be
redirected toward COVID-19 interventions.

ILLICIT NARCOTICS TRADE• Since 2002, the United States has appropriatedover $9 billion to help stem the expansion of
Afghanistan’s opium economy, yet Afghanistan
continues to dominate global opium cultivationand production.
• An estimated 163,000 hectares (ha; one ha isabout 2.5 acres) of opium poppy were cultivatedin Afghanistan during 2019. Although a 50%
reduction from the record high in 2017 (328,000ha), 2019 cultivation remained nearly three times
the pre-2002 average (1994–2001).
• The Afghan government does little to impede
the narcotics trade, which fosters corruption
and crime while providing significant revenue
for insurgents.
• The United States, the international community,
and the Afghan government have curtailed
counternarcotics efforts in recent years.

THREATS TO WOMEN’S RIGHTS• The gains Afghan women and girls have madein health, education, legal protections, andparticipation in public life, may not be protectedby whatever form of government might follow an
Afghan peace agreement.
• It remains to be seen whether Afghan government
negotiators will use their leverage to protect
women’s rights—or whether their leverage will
erode over time if the Taliban make further
battlefield gains.
• The Taliban’s practices in the areas they control
do not inspire confidence that their views on
gender roles and relations have evolved muchsince the 1990s.

INADEQUATE OVERSIGHT• A reduced U.S. civilian and military presencein Afghanistan amid a deteriorating security
environment could create new challenges for
conducting effective oversight of U.S.-funded
programs, grants, and contracts.
• Oversight has been weakened by instances ofpoor documentation, failure to monitor contract
compliance and work quality, inattention toholding contractors and grantees accountablefor unsatisfactory performance, and insufficient
control measures to mitigate the effects ofcorruption, among other issues.
• The ability to monitor, influence, and accountfor the distribution of U.S. aid is likely to decline
as more funds are executed by the Afghan
government, especially one that may incorporate
the Taliban as part of a peace settlement.

3

2021 HIGH-RISK LISTINTRODUCTIONSIGAR 2021 HIGH-RISK LIST: INTRODUCTION

4

U.S. troop strength in Afghanistan has fallen bynearly 98% since its 2011 peak1, but the largely
U.S.-funded reconstruction effort there continues. Congress has appropriated $143.27 billion
since Fiscal Year (FY) 2002 for reconstruction
activities such as security-force development,
health care, education, agriculture, rule of law,
governance, and other areas to build a stable,
peaceful, and democratic Afghanistan that will
not serve as a haven for terrorists. More than $8
billion from those appropriations remains available for disbursement.2
However, the path forward for reconstruction—whatever the outcome of current peace
negotiations between the Taliban insurgentsand the Afghan government—has never been
more fraught with risk. The Special Inspector
General for Afghanistan Reconstruction(SIGAR) is issuing this High-Risk List3 to bringto the attention of the 117th Congress and the
new Administration the following major sourcesof risk that expose Afghanistan reconstruction
efforts to waste, fraud, abuse, mismanagement,or mission failure:• Increasing Insecurity: Taliban attacks
on Afghan security forces have intensified,
while Afghan military and civilian casualties
remain high, Afghan security forces
face critical capability gaps requiringlong-term international support, and theNATO Resolute Support train, advise,
and assist mission has reduced contact
with Afghan security ministries and theirforces due to U.S. troop reductions and the
COVID-19 pandemic.
• Uncertain Funding for a Post-Peace
Settlement: International donors’ aid

pledges have declined, and the level offuture years’ funding may fall—possibly tolevels threatening the viability of the Afghanstate—if donor conditions are not met.
• The Need to Reintegrate
Ex-Combatants: An Afghan peaceagreement could entail massive economic,
social, political, and security disruptions
as the Afghan government reintegrates
ex-combatants from both sides into civilsociety. Its success will be critical for
Afghanistan to achieve lasting peaceand stability.
• Endemic Corruption: Afghanistan has
long been perceived as one of the world’s
most corrupt states, and the government’s
anticorruption efforts have suffered fromvague strategies and insufficient actions.
• Lagging Economic Growth and Social
Development: Afghanistan is poorand suffers from illiteracy, inadequate
infrastructure, weak governance,and now heavy impacts from the
COVID-19 pandemic.
• Illicit Narcotics Trade: Narcotics
production and trade remain at high levels,
little impeded by government, fostering
corruption and crime while providing
significant revenue for insurgents.
• Threats to Women’s Rights: Afghan
women and girls have made progress inhealth, education, legal protections, andparticipation in public life, but persistent
discrimination and possible policy changes
by whatever form of government might
follow an Afghan peace agreement threaten
to undermine their gains.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONINTRODUCTION• Inadequate Oversight: A reduced
U.S. civilian and military presence inAfghanistan amid a deteriorating security
environment could create new challenges
for conducting effective oversight of U.S.funded programs, grants, and contracts forreconstruction work.
As this fourth SIGAR High-Risk List goes topress, the United States has withdrawn all but
about 2,500 of its troops in Afghanistan, whileother Coalition countries have also reduced
their military footprint. This brings the total
number of U.S. and other Coalition personnel
in country to the lowest level since the firstdays of the U.S. intervention in Afghanistan
almost 20 years ago.4 That intervention followed
the September 11, 2001, attacks on the World
Trade Center and Pentagon by al-Qaeda terrorists, whose leaders had been given shelter in
Afghanistan by the Taliban regime.
The Taliban were expelled from power, but
continued to fight. Now the U.S.-backed government of the Islamic Republic of Afghanistan andthe Taliban insurgents have begun peace talks.
A U.S.-Taliban agreement signed on February
29, 2020, helped pave the way for those negotiations and for the U.S. troop drawdown. Under
this agreement, the remaining U.S. troops in
Afghanistan are to be withdrawn by May 1,
2021, if the Taliban meet certain conditions.5
The return home of U.S. service members
after so many years in Afghanistan is a welcome
development, yet it brings a new set of challenges to sustaining what has been achievedsince 2001 in one of the world’s most isolated,
impoverished, and conflict-plagued countries.
At the November 2020 Afghanistan Donor
Conference held virtually in Geneva, participants from 66 countries and 32 internationalorganizations pledged at least $3.3 billion indevelopment aid for 2021, according to theUnited Nations, with annual commitments
expected to stay at the same level until 2024.6
Conducting effective oversight of reconstruction programs, even at reduced levelsof assistance, will likely be complicated by
the reductions in U.S. civilian and military
personnel in Afghanistan. On the other hand,failing to provide substantial assistance could
increase the risk that Afghanistan once again
becomes a haven for terrorist groups capableof threatening the security of the United Statesor our allies. American taxpayers and Afghan
citizens share a common interest in protecting
the achievements of U.S. reconstruction efforts.
Doing so will require a sober assessment of thevarious risks that now confront Afghanistan.
While a November 2020 report from theUnited States Institute of Peace (USIP) says theprospects of a peace settlement in Afghanistan
are better than they have ever been in the last
decade and a half, it adds that, “Unfortunately,
the risks of state failure and renewed conflictare extremely high.”7 However desirable a peaceagreement might be, the USIP report notes that“the move from a war economy to a developing
one is fraught with pitfalls for government anddonors alike.”8
The situation in Afghanistan is fluid, but
recent developments make clear that reconstruction gains in a number of areas are evenmore threatened now than they were in 2019,
when SIGAR last reported on risks to a new
session of Congress. Among other concerns,
the level of violence has increased, including
not only attacks against Afghan security forces,
but also bomb attacks on civilians and targetedassassinations of midlevel officials, prominent
women, and journalists; increasing production
and trade in illegal drugs; and severe impacts
from the COVID-19 pandemic.9
The risks in these areas also pose serious threats to lasting peace. For example,
uncertainty about the funding of a post-peace
settlement and subsequent fluctuations indonor assistance could undermine the successful implementation and sustainability of any
peace agreement.
The grounds for these concerns, discussionof their possible impacts, and related questions

52021 HIGH-RISK LISTINTRODUCTIONOn December 22, 2020, Acting Defense Secretary Chris
Miller meets with Afghan President Ashraf Ghani in
Kabul. (DOD photo)for policymakers are laid out in the topical sections of this report.

ORIGIN AND ROLE OF THE HIGHRISK LIST

6This report is based upon SIGAR’s more than 12
years’ experience and reporting on Afghanistan
reconstruction. It aims to provide Congress,
the Administration, and other stakeholders andinterested parties with SIGAR’s best judgment
on what areas of the reconstruction effort might
be exposed to high risks of waste, fraud, abuse,or program-objective failure under current
circumstances and in the event of a complete
U.S. troop withdrawal and/or insufficient
donor assistance. SIGAR takes no positionon the scope, timing, or specifics of troop or
future funding levels, but merely notes possible

implications for the reconstruction program in
Afghanistan.
This report complies with SIGAR’s authorizing statute, Public Law No. 110-181, Section
1229 (2008), which tasks SIGAR not only tocarry out investigations, oversight, and reporting, but also “To provide for an independentand objective means of keeping the Secretaryof State and the Secretary of Defense fully andcurrently informed about problems and deficiencies relating to the administration of suchprograms and operations and the necessity forand progress on corrective action.”10 This HighRisk List is part of SIGAR’s execution of thatmandate. SIGAR hopes that Congress and theAdministration will find this report useful inconsidering U.S. options in Afghanistan.
As always, SIGAR stands ready to assist
Congress, the new Administration and otherstakeholders by providing briefings and supplying information from its audits, inspections,criminal investigations, quarterly reports,
and lessons-learned products that might help
determine the best way forward for U.S. reconstruction efforts in Afghanistan.

BACKGROUND FOR THE NEWCONGRESS
Since SIGAR published its 2019 High-Risk List,
the United States has drawn down its troops
in Afghanistan from around 14,000 to 2,500.
On November 17, Acting Secretary of Defense
Christopher Miller announced the most recent
withdrawal, saying that President Donald J.
Trump’s decision to reduce the troop countto this level was in keeping with his promise“to bring the wars in Afghanistan and Iraq toa successful and responsible conclusion, andto bring our brave service members home.”11
Under the terms of the U.S.-Taliban agreement,
the United States is to withdraw all remaining by May 1, 2021, if the Taliban meet theirown commitments.12

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

U.S.-TALIBAN AGREEMENT HIGHLIGHTSThe United States agreed to:
1.

2.

3.

4.

5.

6.
7.

Withdraw from Afghanistan all U.S., allied, and Coalition militaryforces, non-diplomatic civilian personnel, private security contractors,
trainers, advisors, and supporting services personnel within 14
months of the agreement’s announcement (by the end of April 2021)
a. In the first 135 days, reduce U.S. forces to 8,600,“proportionately bring reduction in the number of its allies
and Coalition forces,” and withdraw all U.S. forces from five
military bases
b. If the Taliban meet their agreement commitments, the UnitedStates, allies, and the Coalition will withdraw the rest of theirforces in the remaining 9.5 months
Coordinate with and seek approval of the relevant sides for the
release of up to 5,000 Taliban prisoners and up to 1,000 Afghangovernment prisoners before intra-Afghan negotiations begin
After intra-Afghan negotiations begin, initiate an administrative
review of current U.S. sanctions and the rewards list against Taliban
members, with the goal of their removal
After intra-Afghan negotiations begin, diplomatically engage withother members of the UN Security Council and Afghanistan toremove Taliban members from that sanctions list
Refrain from the threat or the use of force against the territorial
integrity or political independence of Afghanistan or intervening in its
domestic affairs
Seek UN Security Council recognition and endorsement for
the agreement
Seek economic cooperation for reconstruction with the new
post-settlement Afghan Islamic government, determined by the intraAfghan negotiations, and not intervene in its internal affairs

4.

5.

6.

7.

8.

Both parties agreed to:1.

3.

Start intra-Afghan negotiations by March 10, 2020
Include in the intra-Afghan negotiations agenda a discussion of apermanent and comprehensive ceasefire, to include the date andmodalities of a permanent and comprehensive ceasefire, including
joint implementation mechanisms, which will be announced alongwith the completion and agreement over the future political roadmapof Afghanistan
Not allow any of its members, other individuals or groups, including
al-Qaeda, to use Afghan soil to threaten the security of the UnitedStates and its allies

Seek positive relations with each other and expect that the relations
between the United States and the new post-settlement Afghan
Islamic government, determined by the intra-Afghan negotiations, will
be positive

Unresolved issues and issues part of wider
agreement-based discussions:
1.

The Taliban agreed to:
1.
2.

Send a clear message that those who pose a threat to the securityof the United States and its allies have no place in Afghanistan, andinstruct Taliban members not to cooperate with groups or individuals
threatening the security of the United States and its allies
Prevent any group or individual in Afghanistan from threatening
the security of the United States and its allies, prevent them fromrecruiting, training, and fundraising, and not host them
Deal with those seeking asylum or residence in Afghanistan
according to international migration law and the commitments of theagreement, so that such persons do not pose a threat to the securityof the United States and its allies
Not provide visas, passports, travel permits, or other legal documents
for entering Afghanistan to those who pose a threat to the security of
the United States and its allies
Ensure their obligations in the agreement apply in areas under
Taliban control until the formation of the new post-settlement Afghan
Islamic government, determined by intra-Afghan negotiations

2.

3.

The United States made several commitments that are not solely
under its control, including allied/Coalition troop levels, the Afghan
government’s release of Taliban prisoners, Afghan government
participation in peace negotiations, specific negotiation topics, andan eventual political settlement creating a new Islamic government.
While the United States can use its political and financial leverage,
and while NATO countries supported the agreement when it was
signed, sovereign nations are not bound to an agreement they havenot signed.
DOD says the Taliban lowering violence levels is a component of the
Taliban’s broader commitments in the agreement, although this does
not appear in the published text.
State says the agreement does not prohibit all Taliban attacks on
Afghan security forces, nor does it preclude the United States fromdefending them from such attacks.

Note: Classified “implementing arrangements” to the agreement have been made available to Congress.
Source: State, Agreement for Bringing Peace to Afghanistan between the Islamic Emirate of Afghanistan which is not recognized by the United States as a state and is known as the
Taliban and the United States of America, 2/29/2020; NATO, “Press conference by NATO Secretary General Jens Stoltenberg ahead of the meetings of NATO Defence Ministers on 17
and 18 February at NATO Headquarters,” 2/16/2021; OUSD-P, response to SIGAR vetting, 10/11/2020; State, email correspondence with SIGAR, 4/16/2020.

7

2021 HIGH-RISK LISTINTRODUCTION
According to the State Department’s 2021
Integrated Country Strategy for Afghanistan,
U.S. policy in Afghanistan is grounded in thefundamental objective of preventing attacks
on the United States by terrorists enjoying safe
haven or support in Afghanistan. State adds that
U.S. policy priorities and operations center on
ending the conflict between the Taliban
and wider Afghan society that perpetuates
instability and sustains an ecosystem forother insurgents and terrorists; supporting this country’s security institutions andconsolidating and sustaining the effectsof U.S. counterterrorism efforts to date;creating a sovereign, unified, and democratic Afghanistan at peace with itself andits neighbors on a path to prosperity andself-reliance for the benefit of all its citizens;and shifting responsibility to Afghans forsecuring their borders and their institutions
and meeting basic needs in a transparent andinclusive manner.13

8

The most important question for policymakers may be whether it is possible to pursue
these goals and policies with few or no U.S.
forces in the country.
Federal law tasks SIGAR with reportingon projects and programs using “any funding
mechanism” that supports “any of the following purposes: (A) To build or rebuild physicalinfrastructure of Afghanistan. (B) To establish
or reestablish a political or societal institution of Afghanistan. (C) To provide products
or services to the people of Afghanistan.”14
Additionally, SIGAR is to report on the “operating expenses of agencies or entities receiving
amounts appropriated or otherwise made available for the reconstruction of Afghanistan.”15
As the statutory language suggests, U.S.
reconstruction programs in Afghanistan haveencompassed a wide variety of activities,
including supporting Afghan security forces,
bolstering the government’s institutional
capacity, expanding energy and transportation
infrastructure, building schools and clinics,
training teachers and health-care workers, andpromoting business development and the country’s export potential.16
The costs of the U.S. military intervention in
Afghanistan and the subsequent reconstruction
effort have been significant. In human terms,
from October 7, 2001, through February 22,
2021, 1,897 U.S. military personnel were killedin action in Afghanistan, while another 415
died from non-hostile causes, and 20,666 were
wounded in action.17 In addition, 68 American
civilians were killed and 76 wounded while carrying out U.S.-funded reconstruction activities
from April 17, 2002, to December 31, 2018.18
In financial terms, an estimated $864.2 billion
has been obligated (committed for disbursement from appropriated funds) for all U.S.
activities in Afghanistan since 2001 throughSeptember 30, 2020, including war funding,reconstruction, diplomatic and consular programs, Afghanistan-related operations of U.S.
government entities, and military and embassy
construction projects. Of that amount, about$815.7 billion or 94% was obligated by the
Department of Defense (DOD).19
Other obligating agencies involved in
Afghanistan reconstruction have included
the Departments of State, Treasury, Justice,
Agriculture, and Commerce; the U.S. Agency
for International Development; the U.S.
Agency for Global Media; the U.S. International
Development Finance Corporation; and SIGAR.
Reconstruction costs for Afghanistan—comprising both support for Afghan security forces
and for civilian reconstruction programs—makeup about 15% of total U.S. funds obligated for
Afghanistan since 2001.20
Of the $143.27 billion Congress has appropriated for reconstruction and related activities in
Afghanistan since FY 2002, $88.32 billion (62%)
has gone toward security to build up the Afghan
military and police.21 Recent appropriations
are even more heavily tilted toward assisting
the Afghan security sector, with about $3.13
billion appropriated, or 68% of total FY 2020
reconstruction funding.22 The funds have beenmostly used to provide salaries, infrastructure,

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONINTRODUCTION

Daily life in Herat, Afghanistan. (UNAMA photo)

equipment, and training for the approximately
305,000 members of the Afghan National
Defense and Security Forces (ANDSF).23
Some $35.95 billion in U.S. funds has been
appropriated since FY 2002 for governanceand economic development, or 25% of reconstruction spending.24 However, this effort has
been scaled down. The FY 2020 appropriation
for governance and economic development of$414 million amounts to 9% of total FY 2020
spending on Afghanistan reconstruction.25 Some
$9 billion has been appropriated for counternarcotics programs since 2002 or 6% of total
reconstruction funds.26
Most of the remaining reconstruction
spending since 2002 has gone to support civilian operations and humanitarian initiatives.
Another major focus of the reconstruction
effort is combating widespread corruption in
Afghan society, including its government andmilitary institutions.
As of December 31, 2020, $8.23 billion
appropriated for Afghanistan reconstruction
remained to be disbursed from the eight largest
reconstruction funds.27 Additional allocations ofappropriated funds to Afghanistan programs are
expected in FY 2021.

RECONSTRUCTION AID HELPS KEEP
AFGHANISTAN FROM REVERTING TOA TERRORIST SAFE HAVEN
Whether or not the United States continues
to withdraw its troops from Afghanistan, the
new Administration and Congress will have todecide—given the U.S. goal that Afghanistan
should not again become a haven for al-Qaeda
and other terrorists—whether and to what
extent reconstruction aid will continue. It
could be a critical decision, for it was not thewithdrawal of Soviet troops in 1989 that led tothe collapse of Afghan President Mohammed
Najibullah’s regime in 1992, but the end ofSoviet security assistance.28 Afghanistan’s
leaders have often said their goal is national
self-reliance. But Afghanistan today is nowhere
near to being self-reliant—especially in funding
its government operations, including militaryand police, from its own resources.
According to a recent Overseas Development
Institute (ODI) report coauthored by the WorldBank’s lead economist for Afghanistan, in 2018(the most recent year for which full data isavailable), Afghanistan received at least $8.6
billion in foreign aid, representing almost 80%

92021 HIGH-RISK LISTINTRODUCTION

A lemon-juice vendor pushes his cart in Jalalabad,
capital of Nangarhar Province. (UNAMA photo)10of the nation’s $11 billion in public expenditures(estimates for total on-budget and off-budget
assistance).29 On-budget donor funds are thoseincluded in the Afghan national budget andmanaged through Afghan government systems.
Off-budget funds are those that do not meet theconditions of on-budget assistance.30
The largest financial expense by far is to train,equip, and sustain the ANDSF. However, according to the DOD, given the persistence of theinsurgency and continued slow economic growth,
full self-sufficiency by 2024 (the year up to which
donors have agreed to continue financial support to the Afghan government) does not appear
realistic, even if security or economic conditions
were to improve dramatically.31
For FY 2021, DOD estimates Afghanistan’ssecurity funding requirement, including
off-budget funding (U.S.-managed rather thanby Afghan ministries or channeled throughmultidonor trust funds), at about $4.29 billion,
for which the United States appropriated $3.05
billion. Afghanistan, by comparison, plans tocontribute only $610 million to the 2021 requirement, approximately 24% of its total estimateddomestic revenues for the coming year, to cover
the expenses of its Ministry of Interior (including all police forces) and Ministry of Defense(including the army and the air force).32

The United States has pledged to continue
support for reconstruction. At the July 2018
NATO Summit in Brussels, NATO allies agreed
to extend their financial sustainment of the
ANDSF through 2024.33 At the November 2020
Afghanistan Conference in Geneva, international
donors reaffirmed their intention to provide atleast $3.3 billion in development aid for one year,with annual commitments expected to stay at
the same level until 2024. The United States, for
its 2021 pledge, made half of its potential $600
million in civilian assistance (not including thelarger sums pledged separately to security assistance) for the year contingent upon progress inthe peace process.34
The “expert note” assessment released last
fall by the UK’s Overseas Development Institutesaid maintaining a viable Afghan state will
require close to the amount in civilian assistance pledged in Geneva, plus an additional$3.6 billion in security assistance. The authors
said this would represent a considerable reduction from current spending and would needto carried out gradually and be carefully targeted, if state functionality is to be preserved.
Reductions below this level are likely to be“highly destabilizing,” the report says. In particular, “the security forces could not sustain
cuts of this magnitude and expect to remainfunctional. Nor could Afghan society easilyadjust to the massive demobilization that would
be required.”35

CORRUPTION REMAINS ANONGOING CHALLENGE
Although the Afghan government has made some
progress in anticorruption efforts, SIGAR wrote
to donors in November 2020 that the Afghan
government has a mixed record of completingreforms and only “through aggressive and effective oversight of donor funding and government
reforms can we ensure that the gains of thelast 19 years are not lost.”36 The Afghan government’s official anticorruption strategy expired inSPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONINTRODUCTION
December 2019, and both international donors
and the UN have expressed concerns about specifics of the draft replacement strategy and thegeneral state of anticorruption efforts.37
At the request of Congress, SIGAR is conducting its third assessment of the Afghan
government’s anticorruption measures. SIGAR
issued its first anticorruption assessment as
directed by Congress in May 2018. Congressthen required SIGAR, through the explanatory
statement for the Consolidated Appropriations
Act, 2018, to continue monitoring the Afghan
government’s progress in implementing
the strategy and to provide an update to
the 2018 audit. That update was issued in
November 2019.

RECONSTRUCTION REQUIRESROBUST OVERSIGHT
With a much-reduced or zero U.S. troop presence in Afghanistan, the U.S. reconstruction
mission there could require even more oversightattention than in the past. As SIGAR has repeatedly reported:• Afghanistan remains one of the world’s
poorest and most dangerous countries.
• The ANDSF cannot protect the populationfrom insurgents in large parts of the country.
• The central government’s institutional
capabilities are generally weak, and often
lacks the capacity to manage and accountfor donor funds.
Whether U.S. troops are wholly withdrawn,
reduced, or increased, SIGAR will continue toprovide the oversight of U.S. taxpayer funds
necessary to maintain the reconstruction program in Afghanistan. SIGAR has worked foryears with Afghan civil-society organizations to
expand its outreach to areas beyond the controlof the U.S. military.
Further, if more U.S. funds are to be disbursed on-budget—either directly to the Afghan
government or through multilateral trust

funds—it will be vitally important that the ministries have strong accountability measures andinternal controls in place.

CONCLUSION
The High-Risk List focuses on program areas
and elements of the reconstruction effort thatare: (1) essential to success; (2) at risk of significant and large-scale failure due to waste, fraud,or abuse; and (3) subject to the control or influence of the U.S. government.
Using these criteria, SIGAR has identified
eight high-risk areas:• Increasing Insecurity• Uncertain Funding for a Post-Peace
Settlement• The Need to Reintegrate Ex-Combatants• Endemic Corruption• Lagging Economic Growth and Social
Development• Illicit Narcotics Trade• Threats to Women’s Rights• Inadequate OversightFunding for a post-peace settlement is a newarea for the High-Risk List and reflects SIGAR’sconcern that neglect of post-peace fundingneeds might recreate the resource-starved scenario that proved disastrous for Afghanistan andthe world after Soviet troops withdrew in 1989
and the USSR stopped its security assistance.
One area included in the 2019 list—civil-policing capabilities—is treated differently inthis edition. The civil-policing discussion now
appears in the Increasing Insecurity section.
As with the 2019 report, this 2021 edition
discusses sustainability as an aspect of eachrisk topic, because it affects every area ofreconstruction in Afghanistan. Likewise, themore recent and pervasive impacts of the
COVID-19 pandemic are discussed throughout
the report, as they also affect every aspect ofreconstruction.

11Caption
An Afghan National Army-Territorial Force member watches security demonstrations at the Kabul Military Training Center. (DOD photo)

HIGH-RISK AREA 1

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INCREASING INSECURITY

HIGH-RISK AREA: INCREASING INSECURITY
WHY IT IS A HIGH RISKThe United States has sought over the past 19
years to build up the Afghan National Defense
and Security Forces (ANDSF) to protect theAfghan population and expel terrorist groups
from the country.38 Without a fully capable,
professional, and sustainable ANDSF to provide security, other large-scale reconstruction
investments such as governance and economic
and social-development programs are at risk.
Security remains the most crucial and enduring high-risk area for Afghanistan because the
Taliban have not significantly changed theirtactics, high levels of violence, or politicalobjectives, and terrorist groups in Afghanistan
like Islamic State-Khorasan (IS-K) and al-Qaeda,
although reduced, remain in the country.39
The United States has made a very large
investment in Afghanistan’s security. As of
December 31, 2020, the United States has
appropriated roughly $88.3 billion to build,equip, train, and sustain the ANDSF. That sum
represents 62% of the nearly $143.3 billion
appropriated for all Afghanistan reconstruction
since Fiscal Year (FY) 2002.40 Yet, security-related threats to the reconstruction effort haveincreased since SIGAR published its 2019 HighRisk List, mainly because of rising Taliban
violence and ANDSF capability gaps.
Despite early hopes surrounding the Taliban’scommitments in the February 29, 2020, U.S.Taliban agreement and the initiation of Afghan
peace talks in September 2020, U.S. ForcesAfghanistan (USFOR-A) reported high levelsof enemy-initiated violence during most of2020.41 The Taliban killed thousands of Afghan

civilians and ANDSF members, and the level ofviolence has hindered the ANDSF from building
critical capabilities. At the same time, ANDSF
and Coalition forces have inflicted significant casualties on the Taliban, IS-K, and otherinsurgent groups.42
With or without a sustainable peace agreement and a nationwide ceasefire, Afghanistan
requires an army to protect its populationfrom internal and external threats, civil police
to keep order and respond to criminal activity, and border police to maintain territorial
integrity. Afghanistan will likely continue tobe threatened by multiple violent-extremist
organizations. Any political agreement risks
subordinate groups going rogue, possibly manifesting as another insurgency or insecurity from
criminal gangs or networks. These issues could
become even more pronounced if U.S. forces
are no longer in country to provide counterterrorism support and to train, advise, and assist
Afghanistan’s security institutions.

WHAT SIGAR FOUND
Since the 2019 High-Risk List, SIGAR has
issued 13 security-related reports and eightquarterly updates on Afghan security and the
U.S. and Coalition mission to train, advise, andassist the ANDSF.
Some security-related issues SIGAR identified include:• In FY 2017–FY 2020, DOD did not conduct
the required monitoring to account forsensitive defense articles transferred to theAfghan government. The requirements are

13

2021 HIGH-RISK LIST

HIGH-RISK AREA
designed to minimize national-security risks
by preventing the diversion or misuse of
items that incorporate sensitive technology.
Consequently, some sensitive technology
provided to the Afghan government was
susceptible to theft or loss.43• Since 2010, DOD has appropriated over
$8.5 billion to develop a capable andsustainable Afghan Air Force (AAF) andSpecial Mission Wing (SMW), but will needto provide continued, expensive contractor
logistics support for aircraft maintenanceand maintainer training. Fewer U.S. andCoalition forces will increase the reliance on
contractors, creating additional operationaland oversight risks and challenges. Further,
the potential withdrawal of contractors
from Afghanistan may leave the AAF and
SMW without vital support if DOD does not
identify alternatives.44• Divided responsibilities among U.S.
agencies and military services fordeveloping ANDSF capabilities, as well as
short-term deployments of U.S. advisors,caused uneven ANDSF development and
impeded standardized security-sector
assistance programs.45• Insufficient data to assess, monitor, andevaluate U.S. advisors assigned to Afghan
security ministries led DOD to request
personnel with the wrong experience,advisors to receive inadequate training,understaffing, and DOD’s inability tomeasure the effectiveness of its more than$421 million civilian advisor contracts.46• Ineffective management and oversightof U.S.-purchased fuel, equipment, anduniforms for the ANDSF resulted in millionsof taxpayer dollars being lost to waste
or fraud.47• Many ANDSF structures built by U.S.funded contractors were found to be
shoddily constructed, unsafe, and, in somecases, unused.48
14

For all of its internal and external challenges,
over the last two years, the ANDSF has maintained control of Kabul, provincial capitals,
major population centers, most district centers,
and most portions of major ground lines ofcommunications.49 Though some ANDSF capabilities have improved in this time, the force willcontinue to contend with a complex security
environment and to face long-term capability
and sustainability challenges that require various forms of continuing U.S. military support.
Commander of U.S. and Coalition forces in
Afghanistan General Austin Scott Miller summarized this on December 16, 2020, saying the
ANDSF need the most help “ensuring that theproper flow of those things that field an army
or field a police force, which are logistics orclasses of supply … [and] making sure [theANDSF] know we’re still there from an air support standpoint and able to help and protect
them during combat operations.”50

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST
The main security-related events in Afghanistan
since 2019 include:51• the signing of the U.S.-Taliban agreement on
February 29, 2020, calling for the complete
withdrawal of U.S. troops by May 1, 2021, if
the Taliban meet certain conditions;• related U.S. force-level reductions in June
2020 (to roughly 8,600), in November 2020
(to 4,000–5,000), and in January 2021 (to2,500); and• the start of Afghan peace negotiationsin September 2020, that have so far
not reduced violence or produced anationwide ceasefire.

The U.S.-Taliban Agreement Signed

The United States signed an agreement with
the Taliban on February 29, 2020, providing for
the withdrawal of all U.S. troops and associatednondiplomatic personnel from Afghanistan by

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INCREASING INSECURITY

U.S. Special Representative for Afghanistan Reconciliation Zalmay Khalilzad (left) discusses the peace process with
President Ghani (right) on June 10, 2020. (Afghan government photo)May 1, 2021, if the Taliban meet a number ofconditions. The agreement commits the Taliban
to prevent its members and other individuals orgroups from using Afghan soil “to threaten the
security of the United States and its allies,” toenter into negotiations with the Afghan government to determine “the date and modalities of apermanent and comprehensive ceasefire,” andto reach “agreement over the future politicalroadmap of Afghanistan.”52 For a breakdown ofeach parties’ commitments in the agreement,see page 7.
The agreement also encouraged the releaseof up to 5,000 Taliban prisoners held by theAfghan government and up to 1,000 government
prisoners held by the Taliban before the startof Afghan peace negotiations. These prisoners
were released before negotiations began, buttalks hit an impasse in December 2020 whenthe Afghan government refused the Taliban’s
demand to release an additional 7,000 Taliban
prisoners, citing continuing Taliban violence.53
Reports emerged that some released Taliban
prisoners have already returned to the battlefield. If the Taliban authorized this, it would

expressly contradict their commitments inthe agreement.54
The U.S.-Taliban agreement further requires
the Taliban to discuss the date and modalities
of a permanent and comprehensive ceasefire,
and to complete an agreement over the political
future of Afghanistan.55 Though Afghan government representatives have repeatedly called
for a ceasefire between the ANDSF and the
Taliban,56 on September 25, 2020, Ambassador
Khalilzad said, “The Talibs will not accept aceasefire, comprehensive and permanent, until
there’s a political settlement. And that’s not
unprecedented in similar conflicts elsewhere.”57
As of February 2021, no publicly apparent progress has been made during intra-Afghan talks oneither of these goals.
Since at least July 2020, several U.S. officials
have indicated that the Taliban have failed
to meet their commitments stipulated in or
broadly part of the U.S.-Taliban agreement—inparticular those regarding counterterrorism
guarantees, not attacking U.S. and Coalition
forces, and reducing levels of Taliban violence—whose importance these officials have15

2021 HIGH-RISK LIST

HIGH-RISK AREA
repeatedly stressed.58 When asked as recently
as February 16, 2021, whether the Taliban
were fulfilling their agreement pledges, NATO
Secretary General Jens Stoltenberg said “there
is still a need for the Taliban to do more whenit comes to delivering on their commitments…
to reduce violence, to negotiate in good faith,
and to make sure that they break all ties withinternational terrorists, not provide them any
support.”59 That same day DOD officials said the
Biden Administration was reviewing the U.S.
government’s entire Afghanistan policy, including Taliban compliance or noncompliance with
the U.S.-Taliban agreement.60

U.S. Force Level Reductions andMission Impact

16

When SIGAR issued the 2019 High-Risk List,roughly 14,000 U.S. military personnel wereserving in Afghanistan, 8,475 of whom were partof the train, advise, and assist mission to build amore capable ANDSF. The rest were in support
roles or serving the counterterrorism mission.61
Following U.S.-Taliban agreement in February
2020, the U.S. force presence has declined significantly, from a total of 8,600 troops in June
2020, the first reduction stipulated in the agreement,62 to 4,000–5,000 by the end of November
2020, and to 2,500 by January 15, 2021, after
President Trump determined that conditions
permitted the move.63 DOD said this new level isthe lowest since 2001.64
Of the 9,592 troops serving the Resolute
Support (RS) mission in Afghanistan as ofFebruary 2021, 7,092 belong to Coalition(NATO and some non-NATO) allies. Though
the agreement commits the U.S. to reducing allied forces in the country alongside its
own drawdown, allied countries have only
decreased their forces by roughly 1,500 since
the agreement was signed.65 Both U.S. andNATO officials say their force posture is conditions-based, and as of February 18, 2021,
Secretary General Stoltenberg said the U.S. and
its NATO allies “have made no final decisionon the future of our presence. As the May 1
deadline is approaching, NATO allies will continue to closely consult and coordinate in the
coming weeks.”66
DOD acknowledged in January 2021 thatthe latest U.S. force-level reduction introduced
some limitations on force capacity and on the
train, advise, and assist mission.67 The COVID19 pandemic compounded this impact. U.S.
and Coalition personnel may still conduct
only limited, mission-essential, face-to-faceadvising with their Afghan counterparts.68 U.S.
advisors have relied more on videoconferencing, e-mail, text messaging, telephone, andother remote methods than on much-preferredface-to-face interactions.69
Notwithstanding the complications for the
train, advise, assist mission, USFOR-A insiststhat its ability to execute and/or oversee costly
and necessary taxpayer-funded contracts totrain and sustain the ANDSF, and to provide
them hundreds of millions of dollars’ worth ofequipment and direct-assistance funds, has thus
far “not been adversely affected by the reduction of force levels”70—an assurance not yet
tested by time or independent audit.

U.S. Funding Decreases

Annual U.S. appropriations for the Afghanistan
Security Forces Fund (ASFF) are at their lowest
levels since FY 2008. Congress appropriatedroughly $3 billion in FY 2021 for ASFF—used
to build, equip, train, and sustain the ANDSF—
and rescinded $1.1 billion from the $4.2 billion
FY 2020 appropriation.71 Because this is stilla sizable financial investment in Afghanistan
and includes some direct funding to the Afghan
government (including hundreds of millionsof dollars per year for things like Ministry of
Defense (MOD) forces’ salaries),72 it is important that DOD and independent oversightagencies like SIGAR continue to protect thesefunds and have access to Afghan financial systems and records.
In October 2020, NATO allies reaffirmed
their commitment to the RS mission and toSPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INCREASING INSECURITY

The A-29 Super Tucano is one of several types of aircraft deployed by the Afghan Air Force. (NATO photo)

Afghanistan’s security and stability, by extending their financial sustainment of the ANDSF
through 2024, although they did not specify atwhat levels.73 It is also unclear how adjustments
to U.S. financial contributions to Afghanistan
might impact NATO and other Coalition countries’ commitments.

Escalating Taliban Violence Is Causing
Increased Insecurity
The Taliban maintain a high level of violence
despite the major political breakthroughs of
the U.S.-Taliban agreement and the start of
intra-Afghan peace negotiations. Each quarter
since the agreement was signed (April–June,
July–September, and October–December 2020)
has seen a higher average number of enemy-initiated attacks compared to the same quarters
in 2019.74 Since the February 2020 agreement,
the Taliban have focused on attacking exposed
ANDSF outposts, fought particularly heavily
in their historical strongholds of Kandahar andHelmand Provinces, and conducted targetedassassinations against mid-level government

officials, civil society leaders, and journalists,
especially in the city of Kabul.75 General Miller
said in December 2020 that “clearly, the Taliban
use violence as leverage. It is a tool they’ve
used for a long time and it’s one they are loath
to abandon.”76 On February 17, 2021, General
Miller also expressed concern about the possibility of an intense Taliban spring offensive,and said “Taliban violence is much higher thanhistorical norms. It just doesn’t create the conditions to move forward in what is hopefully ahistoric turning point for Afghanistan.”77
Civilian casualties remain high, decreasing
by a modest 5–6% in 2020 compared to the last
two years.78 Civilian casualties in the last quarter of 2020 were the third highest in the last
two years.79
Increased violence also hinders the ANDSF’s
ability to build critical capabilities. President
Ghani said that 3,560 ANDSF troops were
killed between the signing of the U.S.-Taliban
agreement in February and July 21, 2020.80 HighANDSF casualties directly impact the force’s
ability to fight insurgents, not only because theirforce strength is reduced, but also because new,17

2021 HIGH-RISK LIST

HIGH-RISK AREA
inexperienced recruits are often not as capable
as their predecessors.
According to DOD, “The Taliban is calibrating its use of violence to harass and undermine
the ANDSF and [the Afghan government], but[to] remain at a level it perceives is within thebounds of the agreement, probably to encourage a U.S. troop withdrawal and set favorable
conditions for a post-withdrawal Afghanistan.”81

Threats from Terrorist Groups Are
Diminished but Remain
Islamic State-Khorasan

18

The 2019 High-Risk List reported an IS-K presence in several districts in Nangarhar Province
with expansion into Kunar and Jowzjan
Provinces. DOD reported in June 2020 thatsustained pressure from the ANDSF, Coalition
forces, and the Taliban killed IS-K fighters andinduced surrenders, leading IS-K to relinquish
control of territory in southern Nangarhar
Province and in Kunar Province.82 The UN
reported in December 2020 that the number ofincidents claimed by or attributed to IS-K wasconsiderably lower in 2020 than in the same
period in 2019 (11 compared with 343).83
Despite these developments, DOD said IS-K
maintains the ability to conduct mass-casualty
attacks. After being dislodged from territory it
controlled, IS-K may be adjusting to a smallergroup posture in urban areas, making themmore difficult to locate and identify.84 The
United States currently conducts air strikes andground raids against IS-K and other terrorist
organizations active in Afghanistan unilaterally
or in coordination with Afghan forces.85
DOD said in October 2020 that while someunits of the Afghan Special Security Forces(ASSF)—the ANDSF’s primary offensive andcounterterrorism forces—“have proven highly
capable of conducting independent operations,”
they “would benefit from continued partnershipwith U.S. and Coalition forces.” The ASSF rely
on international funding, contracted logistics
support for aircraft and vehicles, ordnance andcommunication-equipment procurement, andcontracted training to develop commandos.86

Al-Qaeda

While the Taliban commited in their agreementwith the United States not to allow al-Qaeda “touse the soil of Afghanistan to threaten the security of the United States and its allies,” al-Qaeda
operatives continue to appear in Talibancontrolled territory. The latest reported instancewas on October 25, 2020, when Afghan security
forces killed an Egyptian man known as Husam
Abd-al-Ra’uf, alias Abu Muhsin al-Masri, a senior
member of al-Qaeda on the FBI’s “Most Wanted
Terrorists” list.87
According to the UN in May 2020, “Thesenior leadership of al-Qaeda remains present in Afghanistan, as well as hundreds ofarmed operatives, al-Qaeda on the Indian
Subcontinent, and groups of foreign terrorist
fighters aligned with the Taliban.” The UN
notes that the Taliban and al-Qaeda have hadstrong historic links, and suggests the threat is
growing, as information indicates that al-Qaeda“is quietly gaining strength in Afghanistan
while continuing to operate [in 12 provinces]with the Taliban under their protection.” The
UN also raises questions about whether the
Taliban intend to and actually can carry out
their antiterrorism commitment and, if they try,
whether die-hard Taliban members will defectto other movements.88

Continuing but Incomplete Efforts to
Build ANDSF Capacity
Persistent ANDSF weaknesses in missioncritical areas continue to hinder the force’s
effectiveness, readiness, and sustainability.
These include nascent personnel accountability
and payroll capabilities, logistics challenges,
and heavy reliance on U.S.-funded contractors
for maintenance of U.S.-provided vehicles
and aircraft.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INCREASING INSECURITY

An officer reviews Afghan soldiers graduating basic warrior training. (RS photo)

Personnel Accountability and
Pay Systems

Since 2016, RS advisors have worked to reduce
the ANDSF’s reliance on an error-prone,
paper-based personnel records system by implementing the electronic Afghan Personnel and
Pay System (APPS) to account for personnel
and manage payroll.89 As of January 2021, theUnited States has spent $50.2 million to build
and sustain this system since it was created in2016, about $14.4 million of which was spentsince the 2019 High-Risk List.90
MOD began using APPS to generate payroll
starting in October 2019—(though the Ministryof Interior (MOI) still had not as of January2021),—and there have been several MOD, MOI,
and U.S. efforts to cleanse the system’s rollsof nonexistent, or “ghost” personnel, to avoid
fraudulent and wasteful salary payments.91
As of December 2020, the ANDSF had madeonly minimal progress toward reaching the
APPS performance milestones required forthem to take over ownership, management,
and sustainment of the system, which may stilltake several years. A continued U.S. advisor

presence and much work are needed to ensure
U.S. funds for ANDSF salaries are protected,
especially as the U.S. troop presence decreases.
Until then, the United States will continue tofund and oversee APPS.92

Logistics and Inventory Management

The MOD and MOI face challenges managing
logistics across their forces. One major aspectof this includes implementing, properly utilizing,and maintaining their electronic Core Inventory
Management System (CoreIMS) that would
enable the ANDSF to solve a myriad of logistics
issues through better tracking what equipment
it has, where it is located, and its functional or
repair status.93
According to DOD, although CoreIMS has
been used as the ANDSF’s automated logistics
system of record since 2010, the ANDSF has
not yet been able to fully implement CoreIMS
across the force. Additionally, because thesystem is network-based, longstanding
internet-connectivity issues prevent it fromfunctioning at some local sites.94

192021 HIGH-RISK LIST

HIGH-RISK AREA
The ANDSF is not scheduled to achieve fullindependent use of CoreIMS until 2024 and willcontinue to contract out technical maintenanceof the system—contracts the United States will
likely fund—for at least the next several years.95

Vehicle and Aircraft Maintenance

20

Another important area where the ANDSF lacks
critical capacity is in vehicle and aircraft maintenance. Since the 2019 High-Risk List, theANDSF has not meaningfully improved its ability to independently maintain its U.S.-provided
vehicles and aircraft so that the United States
can stop funding costly contracts for maintenance training and provision.
DOD has acknowledged that building anorganic Afghan aircraft maintenance capability
is a years-long process. Training a fully qualified routine-level maintainer can take up to 18
months, and an advanced-level maintainer up
to 7.5 years. As of January 2021, the Afghan
Air Force (AAF) has filled just under half of its
maintainer positions with personnel trained
and certified in the required aircraft-maintenance specialties and at the required
certification levels.96
Additionally, due to overall U.S. force reductions, the train, advise, and assist command for
the AAF (TAAC-Air) has reduced its manpowerby 94% since the fall of 2019. This changed its
primary mission from direct AAF training andadvising to managing U.S.-funded contracts for
AAF aircraft procurement and maintenance,
pilot and mechanic training, and infrastructure
support. The United States committed in the
U.S.-Taliban agreement to reduce and eventually withdraw “private security contractors”
and “supporting services personnel.” TAAC-Air
assessed in January 2021 that without continued
contractor support, none of the AAF’s airframes(UH-60, MD-530, etc.) can be sustained as combat effective for more than a few months.97
Since December 2017, ANDSF vehicle
maintenance has been streamlined into one
National Maintenance Strategy contract, forwhich the United States has obligated a total of$787.5 million as of October 2020. The contract
stipulates that contractors are responsible formaintaining the majority of ANDSF vehicles
while they train the Afghan National Army
(ANA) and Afghan National Police (ANP) toperform vehicle maintenance. The aim is toeventually transition full vehicle-maintenanceresponsibility to the ANA and ANP, but that goalis years away from fruition.98
Yet, ANDSF maintenance capacity has
declined over the last two years. The 2019
High-Risk List reported that as of November
2018, the ANA was responsible for 51.1% of its
vehicle maintenance and the ANP only 15.9%.
As of December 2020, the ANA was completing
just under 20% of maintenance work orders,
and the ANP slightly more than 12%, well below
their goals of 80% for the ANA and 35% for
the ANP.99

Securing Communities with
Civilian Policing

The MOI also continues to face challenges withcivilian policing—maintaining order throughthe rule of law in communities no longer atrisk of violent insurgent or criminal control.
Establishing the rule of law and maintaining everyday security through an effective
and legitimate police force is important tolay the groundwork for a potential future,
post-peace environment.100
After two decades of international support,
Afghanistan currently has a small number ofhighly trained specialized police forces thathave emerged under the tutelage of international advisors.101 These police forces excel
at high-risk arrests and investigations using
advanced technical approaches, such as wiretaps.102 These specialized police forces are an
important ANDSF asset in the ongoing war;
however, their capabilities are likely to deteriorate once the international advisor presence
is reduced.103
At the same time, the Afghan government
still lacks a police force that can legitimately

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INCREASING INSECURITY
enforce the rule of law on a day-to-day basis.
The Afghan Uniformed Police (AUP), responsible for this civilian policing mission, are largely
illiterate and poorly trained. Although the largest element of the ANP, the AUP often lack thebasic skills to conduct criminal investigations.
They often operate from isolated checkpoints
and heavily fortified police stations, creatinga barrier between them and the citizens they
are supposed to serve and protect. Further,many AUP are considered abusive, predatory,
and corrupt.104
Regardless of an eventual Afghan peaceagreement, criminality in the country is not
merely a function of the Taliban-led insurgency
and will persist. Crime levels have been risingsteadily for years—most noticeably in Kabul,
which has historically had relatively low crime
rates. Since the 2019 High-Risk List, rampant
criminality prompted extensive police crackdowns, but two decades of militarized training
focused on suicide bombings and terrorist
infiltrations left the Afghan police ill-equipped
to handle widespread robbery, kidnapping, andmurder. By 2020, garden-variety crime constituted the biggest concern for Kabul’s residents,
where criminal activity had expanded into previously safe central neighborhoods and became
increasingly brazen and violent.105
Without an effective and democratic police
force securing communities, persistent criminal
activity and lawlessness will threaten to undo
any achievements made by the ANDSF, andcould cause instability and reignite violence.

QUESTIONS FOR POLICYMAKERS• What impact will the reduction in U.S. andCoalition forces and the consolidation ofinternational advisors at higher ANDSF
levels have on the train, advise, and assist
mission and on ANDSF capabilities? How
will these impact the ANDSF’s ability tomaintain security?
• What impact will the reduction of U.S. andCoalition forces and of reconstruction
funding have on the counterterrorism
mission in Afghanistan?
• Should the United States recalibrate thetypes and levels of security assistance toAfghanistan now that the number of U.S.
forces in the country is at its lowest level
since 2001, and if so, what would thatlook like?
• With a dramatically reduced footprint, howwill DOD ensure that U.S. security-related
financial investments in Afghanistan are notwasted or susceptible to fraud? How long is
the United States willing to fund expensive
personnel and logistics sustainment
contracts upon which the ANDSF heavily
relies, but for which the Afghan government
cannot pay?
• After more than $88 billion appropriatedso far to build, equip, train, and sustain
the ANDSF, are Afghan forces capableof maintaining the status quo against the
Taliban until an Afghan peace agreement
is implemented or longer-term if a peacedeal does not emerge? If not, what options
should be considered to ensure they can,and for how long?

21

Caption
Member of the Taliban negotiation team, in Doha, Qatar. (State photo)

HIGH-RISK AREA 2

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONUNCERTAIN FUNDING FOR
A POST-PEACE SETTLEMENT

HIGH-RISK AREA: UNCERTAIN FUNDING FOR
A POST-PEACE SETTLEMENTWHY IT IS A HIGH RISK
Afghanistan remains exceptionally reliant upon
foreign assistance, creating both an opportunity
for donors to influence events there as foreign
troops depart, and risks to a potential peace ifthey reduce assistance too much, too fast, or
insist on conditions that cannot be achieved by
the parties to the conflict. U.S. reconstruction
programs aimed at promoting economic development, rule of law, respect for human rights,
good governance, and security for the Afghan
people may become the primary lever of U.S.
influence in the country for stability and a negotiated peace.106
Future funding for Afghanistan faces two
principal risks:
1. whether expanding the conditions donors
set for funding will be sufficient incentive tofacilitate and maintain an acceptable peaceagreement
2. whether the level of foreign assistanceduring this uncertain period is sufficient toprevent state collapse
Requiring the Taliban to adhere to donor
conditions for assistance could complicate
an already complex dynamic. Donors haveincreasingly described the continuation of
post-peace foreign assistance as conditional on
ambitious goals that require action by actors
beyond the Afghan government. In what may
be an oblique reference to the Taliban andother armed groups, donors acknowledge thatseveral of their desired outcomes are dependent upon “external factors outside [Afghan
government] control.”107

Given the context of the peace process,donors increasingly recognize that the Taliban
will need to play a role if progress is to be madetoward at least some of the donor-prioritizedoutcomes, including reductions in civilian casualties and decreases in the proportion of the
population who fear for their personal safety.108
Further, donors have advised the Afghan
government and the Taliban that “sovereigndecisions made by Afghans in these talks about
their country’s future governing arrangements
will determine donor development and budget
support to Afghanistan.”109
State reported that the pressure created by
its “new conditions-based strategy” brought thetwo parties to the negotiating table.110 Whether
the approach ultimately facilitates an acceptable peace agreement remains uncertain.
Including the Taliban in high-level conditions
for foreign assistance would be a significant
departure from the past when donor conditionality was generally focused on Afghan
government performance.111 As SIGAR has longreported, even when conditionality involved
only the Afghan government, it has been difficult to influence behavior.112
With regard to risks associated with theamount of foreign assistance, recent analysis suggests the Afghan government already faces greatstress. According to a recent Overseas
Development Institute (ODI) report coauthoredby the World Bank’s lead economist for
Afghanistan, in 2018 (the most recent year forwhich full data is available), Afghanistan received
at least $8.6 billion in foreign aid, representing

23

2021 HIGH-RISK LIST

HIGH-RISK AREA
almost 80% of the nation’s $11 billion in public
expenditures (estimates for total on-budget andoff-budget assistance).113 On-budget donor funds
are those included in the Afghan national budget
and managed through Afghan government systems. Off-budget funds are those that do not meetthe conditions of on-budget assistance. As the
ODI authors observe, Afghanistan’s unprecedented aid dependence has shaped Afghanistan’s
political system and economy.114
On-budget assistance: encompasses donor
funds that are aligned with Afghan government
plans, included in Afghan government budget
documents, and included in the budget approvedby the parliament and managed by the Afghantreasury system. On-budget assistance is primarily
delivered either bilaterally from a donor to Afghan
government entities, or through multidonor trust
funds. (DOD prefers the term “direct contributions”
when referring to Afghanistan Security Forces Fund(ASFF) monies executed via Afghan government
contracts or Afghan spending on personnel.)
Off-budget assistance: encompasses
donor funds that are excluded from theAfghan national budget and not managed
through Afghan government systems.
Source: SIGAR, Quarterly Report to the United States Congress,
7/30/2014, p. 130; Ministry of Finance, “Aid Management Policy
for Transition and Beyond,” 12/10/2012, p. 8; State, response to
SIGAR vetting, 1/14/2016; DOD, OSD-P, response to SIGAR vetting,
1/15/2018.

24

At the November 2020 Afghanistan Conference
held virtually in Geneva, participants from 66
countries and 32 international organizations
pledged at least $3.3 billion in development aid
for one year, with annual commitments expected
to stay at the same level until 2024, the UN said.
Assuming these pledges are fulfilled over the four
years, this represents a 15% decrease comparedto the amount of aid pledged at the 2016 Brussels
Conference.115 The United States, for its 2021
pledge, made half of its potential $600 million indevelopment assistance for the year contingent
upon progress in the peace process.116
The amount pledged, if wholly fulfilled, comesclose to the $3 billion in donor assistance for civilian expenditures that the authors of the ODI note
determined was the minimum yearly amount necessary to preserve Afghan state functionality in
2025–2026.117 The authors found that an additional$3.6 billion would be required for security, mostly
from the United States, as it is presently the “only[security sector] donor of real consequence.”118
The decrease in aid comes despite an earlier
World Bank estimate that peace would requirearound $5.2 billion in new and additional publicfinancing for civilian assistance through 2024.
According to the World Bank, its proposed
post-settlement suite of programs is necessary
for “signaling change” that peace delivers a shortterm, noticeable improvement in living standards,
increasing the chance of sustaining peace.119
Many of the efforts in the high-risk areas identified in this report will be unlikely to take place at
all in the absence of sustained (and in some cases
additional) donor support.
Cuts beyond the $6.6 billion recommended
by the ODI authors would, in their view, behighly destabilizing:120
They would lead to reduced economy-wide
demand, fewer jobs, lower incomes andincreased poverty—along with serious macroeconomic impacts (Afghanistan’s trade
deficit of 35 percent of GDP is financed bycurrent levels of external grants). Significant
political disruptions are also likely to result
from eliminating off-budget development
and military procurement programmes: these
support established patronage channels.
Most importantly, security forces could notsustain cuts of this magnitude and expect toremain functional. Nor could Afghan society
easily adjust to the massive demobilisationthat would be required: the same economic
crunch means that ex-combatants would
have few employment opportunities outside
the militias, jihadist groups and criminal
enterprises for which their skill sets have
prepared them.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONUNCERTAIN FUNDING FOR
A POST-PEACE SETTLEMENT

Socially distanced press event at the 2020 Afghanistan Conference in Geneva, Switzerland. (UNAMA photo)

The ODI authors advocate concentrating
any development-assistance cuts in off-budget
activities in order to retain on-budget funding.
According to the authors, cuts in off-budget
activities are unlikely to have major or immediate impacts on growth compared with cuts to
on-budget expenditures managed by the Afghan
government.121 As discussed in more detail on
pages 56–58, SIGAR’s experience shows that as
the United States provides more reconstruction
funds on-budget, whether through bilateraltransfers or disbursement via multilateral trust
funds, it will be vital that Afghan ministries havestrong accountability measures and internal
controls in place because external visibility into
the use of funds is likely to shrink.122

WHAT SIGAR FOUND
Senior Trump Administration officials made several references to leveraging future U.S. foreignassistance to influence Afghanistan’s post-peace
political and human-rights landscape. Secretaryof State Michael Pompeo, in remarks at the
opening of Afghanistan peace negotiations,

told the negotiating teams that their choices
on a future political system for Afghanistan—
including women’s participation in politicallife—would affect “both the size and scope ofUnited States future assistance.”123
Special Representative for Afghanistan
Reconciliation Zalmay Khalilzad, when discussing avenues for U.S. influence on the
future of Afghanistan and women’s rights,
told Congress “we will have the leverage of
future relations and assistance.”124 He drew a
distinction between countering threats to U.S.
national security that could warrant the use of
military force, and advancing U.S. values onhuman rights, for which economic and diplomatic leverage were the appropriate tools forshaping behavior.125
In September 2019, Acting U.S. Assistant
Secretary of State for South and Central Asia
Alice G. Wells told Congress that post-peace foreign assistance could provide the international
community with a “substantial amount of leverage” over the Taliban.126
The United States is not alone in tying
future foreign assistance to the peace talks.
The European Union’s Special Envoy for25

2021 HIGH-RISK LIST

HIGH-RISK AREA

U.S. Special Representative for Afghanistan Reconciliation Zalmay Khalilzad meets with the Taliban negotiation teamin Doha, Qatar. (State photo)

26

Afghanistan, Roland Kobia, wrote that the
EU and U.S. governments were fully aligned
on donor conditionality based on sustaining
the values, rights, and “republican” efforts in
Afghanistan.127 In November 2020, representatives for donor countries—including the UnitedStates—that collectively provide 80% of official
development assistance to Afghanistan wrote
to the Afghan government and Taliban negotiating teams that “sovereign decisions madeby Afghans in these talks about their country’s
future governing arrangements will determine donor development and budget support
to Afghanistan.”128
Donors have signaled their interest in mobilizing “all available instruments to accompany
and follow up on a peace settlement,” including
extending development programs to previously underserved areas.129 Yet donors are also
signaling that their future assistance depends
not only on Afghan government actions, buton those of the opposition Taliban, introducing a new dynamic to an already uncertain
foreign-assistance future. In statements thatappear directed at both sides, donors are calling

for respect of the democratic system enshrinedin the Afghan constitution and “full equality
between women and men, girls and boys, inall aspects of life, political, economic andsocial” as necessary conditions for continued
international support.130
The Taliban appear to have made administration of donor-funded service delivery a
key aspect of their governing strategy in areas
they control. While the Taliban have not ruled
Afghanistan since 2001, they still exert a heavy
influence on the Afghan government’s deliveryof public services in many parts of the country.
The Taliban seldom provide services themselves, but reportedly can co-opt, modify, or
choose to facilitate or hinder Afghan government provision of services.131
A number of studies from 2017 to 2019 by
the Afghanistan Analysts Network (AAN), theUnited States Institute of Peace (USIP), theOverseas Development Institute (ODI), and theWorld Bank highlight a rarely acknowledged
aspect of service delivery in Afghanistan: bargains with insurgents are often necessary when
operating in areas they control or influence.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONUNCERTAIN FUNDING FOR
A POST-PEACE SETTLEMENT
According to the scholar Antonio Giustozzi,
some Taliban leaders seem to believe theirinvolvement in service delivery can be a sourceof political legitimacy. Since the group has few
resources to provide services themselves, it ismore efficient, according to Giustozzi, for the
movement to “hijack” Afghan government-provided services.132
An Afghan government that includes the
Taliban would be an added challenge for future
funding. In September 2020, Ambassador
Khalilzad told Congress that current U.S.
policy prohibits providing assistance to the
Taliban. If the Taliban become part of a future
government, he added, the U.S. Congress andExecutive Branch would need to make legal
and policy changes to allow for continued
foreign assistance.133
To date, it remains unclear what compromises, if any, the Taliban would be willing to
make in order to be more involved in development policymaking. The February 2020
U.S.-Taliban agreement included language
committing the United States to seek economic
cooperation for reconstruction of the post-settlement Afghan Islamic government (provided
such reconstruction did not interfere in the
post-settlement government’s internal affairs).134
The Taliban’s ambiguity on several key policy
matters might afford them greater flexibility
during Afghan peace negotiations, but makes
it harder for donors to assess the Taliban’s
ability to follow through on any agreements. In
December 2020, two ODI researchers warned
donors not to assume the Taliban had reached
an internal consensus on many of the issues
at the forefront of donor concerns, such as
their post-peace political ambitions or social
policies including girls’ education. Despite theestablishment of a well-developed “parasitic”
Taliban shadow state, these researchers argued
the Taliban’s failure to articulate “a clear,coherent vision for the future of Afghanistan”
is a significant weakness.135 Whereas the
Taliban’s leadership understands the negative
consequences should they fail to conform tohuman-rights frameworks, they report that
Taliban sources in the field expect the negotiations to result in a return of the Taliban’s
1990s-style government.136

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LISTThe uncertainty of continued funding for apeace settlement was not a high-risk area inthe 2019 High-Risk List.

QUESTIONS FOR POLICYMAKERS• What evidence is there that the Taliban
will moderate their policies on democracy
and human rights in response to donors
conditioning future assistance on certain
actions and reforms?
• What kind of assistance planning should
Congress and U.S. implementing agencies
prepare for in the event the Afghan
government and the Taliban cannot reach apeace agreement, or if the Taliban refuses
to fully embrace donor conditions for
future funding?
• How much can donor assistance decrease
without (1) destabilizing the Afghan
government and the ANDSF, (2) returning
Afghanistan to civil war and perhaps once
again becoming a haven for international
terrorists, and (3) encouraging the Taliban
to resolve the conflict through conquest?

27

Released Taliban prisoners leave Afghan government custody. (Afghan government photo)

HIGH-RISK AREA 3

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THE NEED FOR REINTEGRATIONHIGH-RISK AREA: THE NEED FOR REINTEGRATION
WHY IT IS A HIGH RISK
The top priority for the U.S. mission in
Afghanistan is a successful peace process tocreate the stability “that is essential to ensure
this country is never again a base for terrorist
threats against the United States, its allies, or its
interests.”137 A critical step toward realizing thatpriority is developing a process to reintegrate
ex-combatants from both sides into normal
political, social, and economic life once a peace
settlement permits reducing the numbersof fighters.
In September 2020, the Afghan government
and the Taliban initiated the long-awaited
intra-Afghan negotiations.138 These talks
began after the Afghan government andTaliban released several thousand of eachother’s prisoners. According to U.S. Special
Representative for Afghanistan Reconciliation
Zalmay Khalilzad, the Afghan government held
approximately 13,000 Taliban prisoners at thetime of the U.S.-Taliban agreement in February
2020.139 As of February 2021, the Afghan government reported it had released approximately
5,500 Taliban prisoners. In February 2021,
Afghanistan’s first vice president Amrullah
Saleh claimed that an unspecified number ofthese released Taliban fighters had returned tothe battlefield.140
The Taliban have 55,000–85,000 fighters,
according to the United Nations, based on
estimates provided by member states.141
Depending on the terms of a peace agreement,
some Taliban fighters will be integrated into
the Afghan National Defense and Security
Forces; others will need to transition to productive noncombatant status in civil society.
The same holds true for an unknown numberof Afghan state-aligned formal and informal
security forces.
The UN defines reintegration as “the process by which ex-combatants acquire civilian
status and gain sustainable employment
and income,” adding that this “often necessitates long-term external assistance.” That
process can be complex and long-term, withsocial, economic, political, security, andhumanitarian dimensions.142
Reintegration programs have often been
implemented as part of a series of disarmament, demobilization, and reintegration efforts
meant “to deal with the post-conflict security
problem that arises when combatants are left
without livelihoods and support networks.”143
Reintegration efforts aim to return former fighters to civilian activities, and more broadly, tocontribute to peace-building, conflict prevention, and reestablishing the state’s legitimate
monopoly over the use of force.144
Afghanistan will likely face significant
challenges based on the mixed record of reintegration efforts since the late 1980s.145 The natureand extent of those challenges will depend
largely on the peace process itself, its level ofinclusivity, trust among the parties, the degree
to which reintegration issues are decidedin an agreement or deferred, and numerous
other elements. However, several factors
could undermine Afghanistan’s reintegration
efforts, including:146• a weak economy that currently offers few
sustainable livelihood options• ongoing insecurity• political uncertainty

292021 HIGH-RISK LIST

HIGH-RISK AREA

Reintegrated insurgent leader Ghaffar Tufaan. (Resolute Support photo)• poor social cohesion within a population
traumatized by decades of war• weak governance and rule of law
Moreover, if reintegration requires long-term
assistance, donor fatigue is a very real concern,for reintegration programming involves extensive data collection and analysis, information
management, vetting, monitoring and evaluation, capacity development of host government
institutions, and resource mobilization.147
Together, these contextual and programmatic
issues will test the ability of Afghan stakeholders and donors to successfully design andimplement reintegration efforts.

WHAT SIGAR FOUND30

In September 2019, SIGAR issued a lessonslearned report that examined the five main post2001 reintegration efforts in Afghanistan andassessed their effectiveness. SIGAR found thatthe absence of a comprehensive political settlement or peace agreement was a key reason priorreintegration programs aimed at Taliban fightersfailed. Other important factors were insecurity
and threats against program participants, a weakeconomy offering few legal economic opportunities, and limited government capacity to
implement a program.148
Consequently, none of the reintegration
programs enabled a significant number of
ex-combatants to socially and economicallyrejoin civil society. Programs specificallytargeting Taliban insurgents did not weaken
the insurgency to any substantial degree
or contribute meaningfully to parallelreconciliation efforts.149

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LISTSIGAR continues to monitor for any new U.S.supported reintegration efforts as the Afghan
peace process develops. But since the 2019
High-Risk List, State has reported no substantially new financial support to peace andreconciliation activities.150 It appears that the
principal U.S. government agencies that could
be involved in reintegration efforts are awaiting

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THE NEED FOR REINTEGRATION

Taliban prisoners released by the Afghan government as a confidence-building measure. (Afghan government photo)further developments in the intra-Afghan
negotiations before committing to a particular
reintegration approach. If so, their restraint is
consistent with SIGAR’s warning that “a reintegration program runs a high risk of failure in
the absence of a political settlement or peaceagreement.”151 Further, the latest World Bank
public post-peace funding document does notinclude the cost of disarmament, demobilization, and reintegration programming in theirprojected funding estimates.152 However, it may
be prudent to continue preliminary planningfor such a program in anticipation of a possible
peace agreement.
On September 26, 2019, the Senate
Appropriations Committee issued S. Rept. 116126, accompanying the Department of State,
Foreign Operations, and Related Programs
Appropriations Bill, 2020. The report directed
SIGAR to assess “the extent to which the
Department of State and USAID have developed
strategies and plans for the provision of continued reconstruction assistance to Afghanistan
in the event of a peace agreement, including
a review of any strategies and plans for monitoring and evaluating the effectiveness of suchassistance and for protecting the rights of
Afghan women and girls.”153 SIGAR anticipatescompleting this work in mid-2021.

QUESTIONS FOR POLICYMAKERS• Should the international community
encourage Afghan peace negotiators toinclude the reintegration of ex-combatants
as a focused area of discussion?
• If a reintegration program were established,
who would be responsible for designing,
implementing, and funding it, and whatrole would the United States play inreintegration efforts?
• Do donors have the appetite to commit
to a series of long-term, post-conflictreintegration activities, and the ability toeffectively implement them?
• How should U.S. agencies adjust current
assistance and programming to ensurethat they are conducive to future, potential
reintegration efforts?
31Caption
Two boys walk through a Jalalabad market in the eastern province of Nangarhar. (UNDP photo)

HIGH-RISK AREA 4

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

ENDEMIC CORRUPTIONHIGH-RISK AREA: ENDEMIC CORRUPTION
WHY IT IS A HIGH RISK
Corruption threatens all U.S. and international
efforts in Afghanistan.154 Corruption particularly threatens developing a functional Afghan
government and effective security forces toaddress the insurgency.155 Corruption not only
erodes Afghans’ trust in their government, butalso compromises the intended outcomes ofdevelopment interventions, and undermines
security by fueling insurgent and corrupt
power structures.156
SIGAR’s September 2016 Lessons Learned
Program report, Corruption in Conflict, foundthat corruption substantially undermined the
U.S. mission in Afghanistan from the very
beginning. SIGAR concluded then, and remains
concerned, that the failure to effectively address
the problem means U.S. reconstruction programs, at best, will be subverted by systemic
corruption and, at worst, will fail.157
Donors continue to demand concrete anticorruption actions from the Afghan government.
At the November 2020 Afghanistan Conference,
participants from 66 countries and 32 international organizations adopted the Afghanistan
Partnership Framework (APF), calling for theAfghan government to carry out a “meaningful,demonstrable fight against corruption” as acondition for continued international support.158
Secretary of State Michael Pompeo said theAfghan government must implement “real anticorruption efforts” essential for stability andsecurity in the country.159
At the conference panel on corruption,
U.S. Chargé d’Affaires Ambassador Ross
Wilson called for “vigorous public action to
identify, prosecute, and effectively punish corrupt officials involved in the taking of publicresources.”160 UN Special Representative of theSecretary-General Deborah Lyons said it was“past time for those who are responsible [forcorruption] to be held accountable,” labelingcorruption a “silent cancer steadily affecting all
aspects of the lives of Afghan citizens.”161
Surveys show corruption remains a widespread issue affecting Afghans. According to
the latest Asia Foundation survey results, 85%of respondents in 2020 reported that corruption
was a major problem in their daily life and 95%
of respondents said corruption was a major
problem in Afghanistan as a whole.162

WHAT SIGAR FOUNDSIGAR has reported on Afghanistan’s anticorruption issues since 2016, beginning with theLessons Learned Program report, Corruption
in Conflict, which offers a historical viewof corruption in Afghanistan since 2001. In
response to that report, Congress directed
SIGAR to examine the creation and implementation of Afghanistan’s Anti-Corruption
Strategy; the first of three mandates to date.
SIGAR issued the first anticorruption strategy
assessment report in May 2018 and the secondin November 2019; the third is scheduled forrelease in spring 2021.163
SIGAR found that the Afghan government
has taken limited steps to curb systemic corruption, but that more tangible action is required.164
While the Afghan government has repeatedly
assured the international community that it has
the political will to combat corruption and makeneeded institutional reforms, it has a mixed33

2021 HIGH-RISK LIST

HIGH-RISK AREA

Former police commander Zemarai Paikan was convicted in absentia of corruption in December 2017, but despite an
outstanding warrant, was not arrested until August 2020. (NATO Training Mission Afghanistan photo by Pamela Smith)34

record of completing the necessary reforms.165
The Afghan government often makes “paper”
reforms, such as drafting regulations or holding
meetings, rather than taking concrete actions
that would reduce corruption, like arrestingor enforcing penalties on powerful Afghans.
SIGAR’s cumulative work has repeatedly identified the impunity of powerful Afghans as an
ongoing issue, and the Afghan government continues to face challenges with the extradition,
arrest, and prosecution of corrupt individuals.166
SIGAR investigations have identified corruption at virtually every level of the Afghanstate—from salaries paid by international
donors for Afghan soldiers and police who do
not exist—to theft of U.S.-military provided fuelon a massive scale.167 Furthermore, SIGAR’s
work has found that the Afghan government
tends to take meaningful action only whendonors are engaged and call for reforms to curb
systemic corruption.168
Donor nations at the 2020 Afghanistan
Conference in Geneva missed an opportunity
to strongly address the growing problems ofcorruption in Afghanistan.169 According to the

UN Secretary-General, little action resulted
from intensified pressure on the Afghan government to enhance tangible anticorruption resultsahead of the conference.170
Further, while the APF did outline a numberof principles, outcomes, and jointly agreed priority areas (including established reform targets
for 2021), the targets for 2022 and beyond are
merely “indicative” and subject to revision insubsequent annual meetings.171
The APF fell short in one key respect about
corruption: although it commits to the principle of conditioning future assistance, it failed
to articulate specific financial consequences
for the Afghan government if its obligations todonors are not met (including those related tocorruption). As a result, it is unclear if whatever consequences are eventually set will besevere enough to alter the Afghan government’s behavior and incentivize meaningful
anticorruption reforms.
According to USAID, donors formally andinformally track outcomes or reform targets to gauge progress in Afghanistan and
the APF “implies that there will be financial

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

ENDEMIC CORRUPTION
consequences” if the Afghan government does
not achieve the minimum conditions. Whilespecific dollar values are not tied to outcomes
and reform targets, many are designed toclosely align with milestones in the Afghanistan
Reconstruction Trust Fund (ARTF) incentive
program and European Union state-building
program. According to State, the World Bank
told ARTF donors that it planned to alignits objectives with the APF and the Afghan
National Peace and Development Framework
II, meaning funding may be conditional onthese targets when some of the APF’s outcome indicators are linked to the ARTF 2021
incentive program.172

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST
Throughout 2020, the Afghan government hasreported on the anticorruption and institutional
reform benchmarks in the 2018 Geneva Mutual
Accountability Framework (GMAF) and theself-imposed benchmarks it created in response
to SIGAR’s November 2019 anticorruption
assessment. In July 2020, the Afghan government said that it had completed 85% of the
GMAF benchmarks related to anticorruption,
governance, rule of law, and human rights.173
However, international donors and Afghan
government officials have acknowledged thatsome GMAF benchmarks are poorly worded
and have disagreed over when a benchmark
has actually been achieved.174 In response
to SIGAR’s November 2019 anticorruption
assessment, the Afghan government agreed
to implement all eight of SIGAR’s matters forconsideration to improve its anticorruption
efforts, and created 27 time-bound reforms that
it would implement by June 2020. In August
2020, the Afghan government provided documentation showing that it had implemented 16of those 27 benchmarks.175
Even if all benchmarks had been attained asplanned, not all benchmarks are equal. SIGAR

sorted the 27 Afghan government-createdanticorruption reforms into two categories—
tangible and intangible. “Tangible” reforms aredefined as concrete actions that are likely to
reduce corruption, such as the arrest of corrupt actors. “Intangible” reforms are those thatwill require further steps beyond the reform
itself. For example, the Afghan government
committed to passing a regulation on asset
recovery, but the regulation needs to be enacted
and enforced according to the law in order toreduce corruption.176
Of the 16 benchmarks for which the Afghan
government provided evidence of implementation, four resulted in tangible reforms, while
the remaining 12 constituted intangible legal
or regulatory reforms. Of the 11 reforms thatare incomplete, nine would have had a tangible
impact on anticorruption and two would haveproduced intangible reforms.177
One example of a tangible outcome would
be the Afghan government meeting its benchmark to review the performance of all Major
Crimes Task Force (MCTF) personnel andreplace weak performers. Reportedly as aresult of these performance evaluations, threesenior officials, including the then-head of the
MCTF and two managers, were removed fromtheir positions. According to MCTF officials,
this effort removed weak performers froman anti-corruption institution and supported
high performers.178
However, time may show that such reported
successes are mixed. The MCTF has faced
several leadership changes and corruption allegations over the years making it difficult to tellwhether a change is a genuine effort at reformor something else. For example, DOJ told
SIGAR that the MCTF director was unexpectedly dismissed after leading an investigationthat resulted in the arrest of Herat’s mayor on
October 26, 2020, suggesting that his firing could
have been retaliation rather than an anticorruption measure.179 In another example, in October
2018, SIGAR reported on DOJ’s concerns overcorruption and high polygraph-test failure rates

35

2021 HIGH-RISK LIST

HIGH-RISK AREA

Donor and Afghan government representatives prepare to discuss corruption during a side event of the 2020
Afghanistan Conference. (UN photo)36

in the MCTF. DOJ reported at the time that aformer MCTF director was found to be corrupt
following an Afghan government investigation.
Then in October 2020, SIGAR reported thatthe director of the MCTF was (again) removed
following corruption allegations. According to
the Combined Security Transition CommandAfghanistan (CSTC-A), several MCTF unit chiefs
and investigators were corrupt and had extorted
suspects in return for suppressing or nullifying
cases. Further, CSTC-A reported collusion at
the time between MCTF and Anti-Corruption
Justice Center members as well as bribery withsenior ministry officials.180
The newly appointed MCTF director has noprevious police or investigative experience,
CSTC-A reported to SIGAR.181 Further, hefaces his own allegations of corruption, withat least one news report claiming he is in debt
to Sweden’s tax authority for alleged pension
fraud there.182
By contrast, the Afghan government’s effort
to reduce legal immunity is an example of abenchmark with no tangible impact. To meetthis benchmark, in March 2020 the Afghan

government held a meeting to review its laws
and identify possible loopholes that provided
legal immunity for powerful individuals.
Meeting participants concluded that article 102of the Afghan Constitution may contain immunity loopholes that required legal interpretationby the Supreme Court. The Administrative
Office of the President was tasked with following up on these issues, but as of September
2020, it had not done so. As a result, no
actual reforms to reduce legal immunity havebeen achieved.183
Since 2019, CSTC-A, which administers
on-budget security assistance funding to theAfghan government, changed its approach toconditionality—or pegging assistance levels toreforms—to place greater emphasis on working with “reliable” (i.e., not corrupt) Afghan
partners. In contrast to the previous CSTC-A
practice of levying financial penalties (which
CSTC-A has described as “detrimental andunrealistic”), CSTC-A says it now uses positive reinforcement. A key CSTC-A objective isreplacing corrupt actors with “reliable partners”

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

ENDEMIC CORRUPTION
who demonstrate their desire to work towardbuilding viable security institutions.184
CSTC-A believes its approach to conditionality has proven effective. However, several of
their successes seemingly continue to involve
penalties (or the threat of penalties). CSTC-A
attributes improved MOD personnel-attendance
record keeping to conditions it imposed in
October 2019. CSTC-A’s withholding of delegated funds led the MOD in one case to pay
outstanding invoices and in another to launch
an investigation into a procurement chief who,
in return for kickbacks, directed contracts tofriends and relatives.185
Fuel accountability is another area ofimprovement, following the MOI’s implementation of a policy halting fuel deliveries to units
that fail to report fuel consumption and of
decreasing fuel allotments to units that are latein their reporting.186
Despite this new approach, CSTC-A’spartners have sometimes demonstrated
questionable motives. For example, CSTC-A
reported that it and other donors had tothreaten to withdraw their intelligence support
and funding after the MOI sought to appoint a
corrupt former provincial chief of police, who
was himself involved in significant narcotics
trafficking, to a key counternarcotics role withaccess to all narcotics intelligence.187

QUESTIONS FOR POLICYMAKERS• What tangible, anticorruption-related
reform benchmarks should be demanded
and/or incentivized by donors as part of
the Afghanistan Partnership Framework
process (and follow-on) that was issued
at the November 2020 Afghanistan Donor
Conference? How will donors reliably
measure these most relevant indicators?
• Are reform benchmarks too vague or bland,
having no meaningful impact on rampant
institutional corruption? What is the bestforum to differentiate between intangible
and real anticorruption efforts?
• What forms of financial penalties
and/or incentives best foster real
anticorruption progress?
• What are reasonable expectations for
Afghan government anticorruption-related
results given competing challenges of (1)regime stability and potential difficulties if
a peace agreement results in the integrationof the Taliban into an amalgamatedgovernment and (2) reform?
• How will donors adapt their anticorruption
monitoring methods if international troops
depart the country? How can CSTC-A
continue its efforts to ensure its partners are“reliable” if it has reduced interactions withthese partners?

37Caption
Empty streets of Khair Khana neighborhood in Kabul. (UNAMA photo)

HIGH-RISK AREA 5SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONLAGGING ECONOMIC GROWTHAND SOCIAL DEVELOPMENT

HIGH-RISK AREA: LAGGING ECONOMIC GROWTHAND SOCIAL DEVELOPMENT
WHY IT IS A HIGH RISKThe U.S. government’s current Integrated
Country Strategy (ICS) for Afghanistan, publicly
released in February 2021, states that no U.S.
efforts to promote a stable Afghanistan canbe sustained without accelerating private sector-driven growth in the licit Afghan economy
and making social gains in health, education,
and women’s empowerment.188 Accordingly, theU.S. government has made substantial investments to boost economic growth, governance,and social development across the country,with appropriations totaling $35.95 billion
since 2002.189
Despite this support, Afghanistan continues to be plagued by sluggish economic
growth with stagnating indicators in thehealth and education sectors. Persistent corruption, an over-reliance on internationalaid, worsening security conditions, and limited government capacity inhibit sustainable
progress in Afghanistan’s economic andsocial development.
During 2020, the emergence of the COVID19 pandemic and the uncertainty of the Afghan
peace talks compounded many of these perennial economic and social challenges. COVID-19
has overwhelmed Afghanistan’s limited healthcare system and severely constricted economic
activity, resulting in increased poverty andunemployment. As COVID-19 continues to ravage Afghanistan, the pandemic is undoing themodest progress made in economic and social
development in recent years and further threatens the country’s political stability.

Besides the pandemic, the uncertainty surrounding the ongoing peace process, increasing
violence, future levels of donor assistance, andreintegration of former combatants and Afghan
returnees into a struggling economy with highunemployment, has undermined investor confidence in the Afghan economy and potentiallyjeopardizes economic recovery from the effects
of COVID-19.

WHAT SIGAR FOUND
Even before COVID-19 struck Afghanistan in
February 2020, the Afghan economy sufferedfrom sluggish growth, with annual GDP growthnever rising above 3% since the 2014 phased
military drawdown of U.S. and Coalition forces.
In recent years, Afghanistan has struggled witha number of economic challenges, including theeffects of extreme weather such as droughts
and flash flooding. In September 2019, the State
Department also noted further pressure caused
by a drop in remittances from Iran—where
many Afghan migrants work—due to that country’s increasing economic struggles, partly as aresult of U.S. sanctions, and the economic andsocial support burdens caused by the sharp
increase in Afghan returnees, especially in
Afghanistan’s western provinces.190
In December 2019, the International
Monetary Fund predicted economic growth in2020 would reach 3.5%, aided by the recovery
in the agricultural sector following a widespread drought in 2018.191 In 2020, however,Afghanistan’s more modest 3% growth in2019 was wiped out as the Afghan economy

392021 HIGH-RISK LIST

HIGH-RISK AREA

40

contracted by an estimated 5% of GDP amid the
COVID-19 pandemic.192 The resulting shutdownof international trade routes along with the government-mandated lockdown led to a decline ineconomic activity for an already anemic economy, resulting in increases in unemployment,
food insecurity, and overall poverty levels.193
The United Nations Development Programme
estimates that poverty in Afghanistan, defined as
2,064 afghanis per person per month or around$1 in daily income, has increased to 68% from its
pre-pandemic level of 55%.194 According to theUN, the number of Afghans requiring humanitarian assistance in 2021 has reached approximately
half of Afghanistan’s total estimated population
due to the health and socio-economic impactof the COVID-19 pandemic. This figure is nearly
double that of the previous year, and a six-foldincrease as compared to four years ago. In
January 2021, the UN’s Humanitarian Response
Plan for Afghanistan announced that $1.3 billion
is required in 2021 to reach individuals in needof aid.195
As expected, SIGAR found that the COVID19-related restrictions on overall economic
activity led to a decline in sustainable domestic
revenues for the Afghan government. Those revenues fell by 2.8%, year-on-year, in 2020, while
government expenditures increased by 8.1% ascompared to the previous year’s.196 As SIGAR
has noted, the Afghan government needs tostrengthen its fiscal capacity in order to support
the domestic infrastructure and institutions necessary for sustainable economic growth.197
Yet, donor grants totaling at least $8.6 billion
per year (covering both security and civilian
assistance) currently finance almost 80% of
Afghanistan’s $11 billion in public expenditures(estimates for total on-budget and off-budget
assistance). On-budget donor funds are thoseincluded in the Afghan national budget andmanaged through Afghan government systems.
Off-budget funds are those that do not meet theconditions of on-budget assistance.198 The revenue losses caused by COVID-19 further diminish
the Afghan government’s ability to wean itself

Sustainable Domestic Revenues: According to
Afghan Ministry of Finance officials, these arerevenues such as customs, taxes, and nontax
fees. Multilateral institutions, including the WorldBank and the International Monetary Fund(IMF), use reports of these revenues to judge
the Afghan government’s fiscal performance.
One-Off Domestic Revenues: These are nonrecurring
revenues arising from one-time transfers offunds, such as central bank profits, to the Afghan
government. The IMF excludes central banktransfers from its definition of domestic revenues
for the purpose of monitoring Afghanistan’s
fiscal performance under its Extended Credit
Facility arrangement with the government.
Source: SIGAR, communications with MOF officials, 8/21/2017;
SIGAR, communications with IMF officials, 9/7/2017.

from international assistance and toward financial self-sufficiency.
As the Afghan government assumes a more
prominent role in managing its own economic
and social development in the coming years,
its limited fiscal capacity may be inadequate tosustain the infrastructure (e.g., roads, reliable
power generation, and economic supply chains)and institutions (e.g., government ministries)
that, while flawed, are necessary underpinnings
for sustainable economic growth. The government’s lack of financial sustainability is an issue
affecting all high-risk areas identified by SIGAR.
COVID-19 has also severely stretched
Afghanistan’s health-care and education sectors.
The health-care sector already lacked adequate
resources and capacity before the pandemic.
Afghanistan has a nationwide average of only
4.6 medical doctors, nurses, and midwives
per 10,000 people, far below the World HealthOrganization’s critical-shortage threshold of 23
per 10,000 people.199 In a March 2020 review,
SIGAR also found that many health facilities
in Afghanistan, while operational, lacked electricity and water, showed damage or lack of

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONLAGGING ECONOMIC GROWTHAND SOCIAL DEVELOPMENT

Shuttered shops in Kabul during the COVID-19 lockdown. (UNDP photo)proper maintenance, possessed damaged or
substandard medical-waste incinerators, andreported shortages of female staff to allow for
the treatment of female patients in accordancewith Afghan customs.200
Unsurprisingly, Afghanistan’s pandemic
response has been hampered by limited
resources, including personal protective equipment (PPE), ventilators, hospital beds, testing
capacity, and medical staff, in addition to
management challenges further inhibiting thegovernment’s ability to contain and treat thedisease. The country’s limited health resources
have been largely redirected towards COVID-19
interventions, leaving many other health areas
untreated, potentially undoing health gains
made over the previous decade.201
During March–August 2020, for example,
polio vaccinations were temporarily suspended
over fears of spreading COVID-19 among targeted children, their families, and vaccinators,
with many polio-surveillance volunteers instead
assisting with COVID-19 surveillance, caseidentification, and community contact tracing.202 Afghanistan and Pakistan are the only
two countries in the world where polio remains
endemic. Due to the suspended vaccination
campaign and continued insecurity in certain

areas, according to World Health Organizationand UNICEF officials, Afghanistan reported 56
polio cases in 2020, up from 28 in 2019.203 Even
before the COVID-19 pandemic, polio cases
were already rising, increasing from 14 reported
cases in 2017 to 21 in 2018.204
Given the pervasive impact of COVID-19
within Afghanistan, public health officials estimate at least one-third of the population has
contracted the disease. Future health programs
will have to grapple with the long-term andlingering health effects of COVID-19, as well as
secondary, indirect impacts of the pandemic
due to the limited capacity of the public healthsector, including increased child-mortality rates
and antimicrobial resistance.205
Health-care facilities and workers have also
been deliberately attacked by both antigovernment and progovernment forces amid an uptick
in violence. In June 2020, the United Nations
released a special report detailing 15 attacks
involving health-care facilities between March
11 and May 23, 2020, including 12 deliberate
attacks and three instances of incidental harmfrom fighting. Ten of these were attributed to
the Taliban.206 Afghanistan’s education sector
also has been hit hard by COVID-19. Schools
closed on March 14, 2020, to slow the spread41

2021 HIGH-RISK LIST

HIGH-RISK AREA

In Lashkar Gah, Helmand Province, the U.S.-supported Lincoln Learning Center shares public health information on
COVID-19 with market vendors. (U.S. Embassy Kabul photo)

42of the disease. While schools reopened in fall2020, many students reported having little tono contact with teachers during the lockdown,with distance learning hampered by the lack ofelectricity and limited access to the internet.207
At the end of 2020, the Ministry of Education
reclosed schools as COVID-19 cases increased
during a second wave of the disease.208 Given
the worsening economy and the pressure on
students to find work to help support their families, among other challenges, many students
may not find their way back into school.209
The Afghan government has made substantial progress since 2002 in expanding access to
education compared to the years under Taliban
rule. However, even before the pandemic,
the education sector faced numerous challenges due to continued insecurity and criticalshortages in resources, with many students,
especially girls, remaining out of school. Prior
to the spread of COVID-19, 2.6 million girls, orapproximately 60% of school-aged girls, werereportedly out of school.210
This figure may include students who are still
officially enrolled as the Ministry of Education
counts students who have been absent for up

to three years as still enrolled, in the hope they
may reenter school.211
SIGAR found in an October 2019 review
that a number of USAID-funded schools
showed signs of infrastructure damage; a lackof proper maintenance, including incidents
that could be hazardous to students; andinsufficient resources such as desks, chairs,
tables, and access to electricity, leading manyteachers to teach outside on rugs or in tents.212
Given the many challenges the Afghan government faces to becoming a self-financing
state, there are concerns over its ability tomaintain, let alone expand, the level of educational access in the country without continued
international assistance.

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST
When SIGAR issued its 2019 High-Risk List,
Afghanistan had sluggish economic growth
and rising poverty levels, exacerbated bywidespread insecurity and pervasive corruption within the government. Despite U.S.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONLAGGING ECONOMIC GROWTHAND SOCIAL DEVELOPMENT
government efforts, the Afghan government
continues to be heavily reliant on donor assistance and struggles to attract private sector
investment. The same economic and social
issues remain key challenges to sustainableeconomic growth and social development.
Furthermore, both the COVID-19 pandemic
and the uncertainty surrounding the ultimate
outcome of the Afghan peace process now castlong shadows over future prospects for economic and social development.
During the November 2020 Afghanistan
Conference in Geneva, international donors
pledged at least $3.3 billion to Afghanistan
in development assistance for 2021, according to the UN, and indicated the potential for
between $12 billion and $13.2 billion in civilian
aid over the next four years.213 This is a dropfrom the $15.2 billion pledged over four years
in the 2016 donors’ conference. (Security
assistance is pledged separately.) This figure
falls to what some experts consider the bareminimum required for Afghanistan to remain a“viable state.”214
For many donors, continued support iscontingent on participants making sufficient
progress in the Afghan peace talks and protecting human rights. The U.S. government also hasmade it clear that its future assistance will be
conditioned on the conduct and decisions of theparties involved in the peace talks.215
Even in the best-case scenario for
Afghanistan—if the Afghan government
brings the COVID-19 pandemic under control
and negotiates a peace agreement with the
Taliban—success will not translate immediately
into sustainable licit economic growth, as many
enduring barriers will remain. These include
a limited pool of skilled labor, the lingering
effects of four decades of near-continuous
conflict, deficits in physical and institutional
infrastructure, and heavy reliance on foreign
donor support. In addition, widespread corruption would continue to undermine investor
confidence in the Afghan economy.216

A peace agreement could not only lead to thechallenge of reintegrating ex-combatants into
the Afghan economy, but also to the return of alarge number of Afghans from abroad, including
over two million Afghans residing in Pakistan
and nearly 3.5 million Afghans in Iran (figures
include refugees).217 Upon their return, they
could be facing a weak licit labor market unable
to fully assimilate the large influx of labor in
the short term, potentially exacerbating alreadyhigh unemployment and poverty figures.
Overall, many uncertainties remain, including the future levels of economic and security
assistance and Afghanistan’s overall politicalstability. However, it is clear that sustainableeconomic and social development must playa significant role in supporting U.S. strategic objectives in Afghanistan. While the U.S.
government believes that private-sector-led economic growth will be key to supporting a future
peace agreement and to promoting the politicalstability of the country, low levels of growth
could have the opposite effect.

QUESTIONS FOR POLICYMAKERS• What can be done to facilitate more private
sector investment in Afghanistan?
• What would be the broader effects on the
Afghan economy if U.S. military personnel
continue to withdraw?
• What changes will need to be made for
U.S. economic and social development
programming to be safely and effectively
implemented and monitored if most
U.S. military and civilian personnel arewithdrawn from Afghanistan?
• How will U.S. economic and social
development funding be adjusted if a peaceagreement is not forthcoming?
• How will U.S. economic and social
development programs in Afghanistan need
to be adjusted due to COVID-19?
43

Caption
An Afghan National Army soldier poses with a poppy near the village of Karizonah, in Logar Province. (U.S. Air Force photo)

HIGH-RISK AREA 6

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THE ILLICIT NARCOTICS TRADE

HIGH-RISK AREA: THE ILLICIT NARCOTICS TRADE
WHY IT IS A HIGH RISK
Since 2002, the United States has appropriatedover $9 billion to help stem the expansion of
Afghanistan’s opium economy,218 yet more than
18 years later, Afghanistan continues to dominate global opium cultivation and production.
Various U.S. government agencies havesought to address Afghanistan’s narcotics tradethrough interdiction and counterdrug law
enforcement; opium-poppy eradication; alternative development programs aimed at creating
licit livelihood opportunities; and the mobilization of Afghan political and institutional
support, to little effect.219
According to the United Nations Officeon Drugs and Crime’s (UNODC) 2020 World
Drug Report, an estimated 163,000 hectares(ha; one ha is about 2.5 acres) of opium poppy
were cultivated in Afghanistan during 2019
(more current reporting has been delayed as
explained below). Although a 50% reduction
from the record high in 2017 (328,000 ha), 2019cultivation remained nearly three times the pre2002 average (1994–2001).220 In fact, UNODC
reported that the gross income from opiates
exceeded the value of the country’s officially
recorded licit exports in 2019.221 Based on 2018
data, Afghan opiate production accounted for
84% of global morphine and heroin seizures,222
providing a rough indication of the overall sharethat Afghan opiates have in the global market.
As SIGAR has repeatedly noted, the deleterious effects of the illicit narcotics trade in
Afghanistan extend beyond health impacts. It
also helps fund insurgents, foster corruption,and provoke criminal violence.223

The Taliban insurgency is linked to opiumpoppy cultivation. The Taliban stronghold ofsouthern Afghanistan accounts for the largest share—68% of the national cultivation
total. Helmand was the leading poppy-cultivating province at 136,798 hectares in 2018,with Kandahar (23,410 ha) and Uruzgan(18,662 ha) Provinces ranked second andthird, respectively.224 All told, insurgent-dominated districts accounted for 47% of
opium-poppy cultivation compared to 25% forgovernment-dominated districts.225
Even in the midst of the COVID-19 pandemic
and its serious effects on global economies,
Afghanistan’s opium economy has remained
resilient. UNODC reported that Afghanistan’s
2020 opium-poppy harvest was largely uninterrupted by COVID-19.226 In contrast, the State
Department’s Bureau of International Narcotics
and Law Enforcement Affairs (INL) said COVID19 forced the Afghan government to reduce its
counternarcotics operations.227

WHAT SIGAR FOUND
Since the 2019 High-Risk List, SIGAR has
issued a performance audit report, a financial
audit report, an alert letter, a review, and eightquarterly reports that have highlighted various
aspects of U.S. counternarcotics reconstruction
programs in Afghanistan.
In response to SIGAR’s 2018 lessons-learned
report, Counternarcotics: Lessons From the
U.S. Experience in Afghanistan, on September
17, 2018, the Senate Caucus on International

45

2021 HIGH-RISK LIST

HIGH-RISK AREA
Narcotics Control requested that SIGAR conduct a review of the U.S. government’s current
counternarcotics efforts in Afghanistan. The
caucus asked SIGAR to determine the status of
the State Department-led interagency 2012 U.S.
Counternarcotics Strategy for Afghanistan andState’s revision of, or plans to revise, this strategy. SIGAR published an alert letter in January
2020 outlining how State has not revised, anddoes not plan to revise, that strategy. Rather,
State said the South Asia Strategy serves as
overall guidance for U.S. strategic priorities in
Afghanistan and counternarcotics efforts.228
The only available unclassified description of
the South Asia Strategy—a 2017 speech by
President Trump—did not mention narcotics.229
SIGAR also issued an audit report on theState Department’s drug-treatment programs in
July 2019, a report on Afghanistan’s justice sector case-management system in January 2020,
and a financial audit of the State Department’s
drug-treatment programs in September 2020.
SIGAR found that State INL does not know
the impact of more than $50 million invested
in drug-demand and treatment programs, that
State-contracted support to Afghanistan’s
drug-treatment system resulted in over $23
million in questioned costs, and that the Statesupported Afghan case-management system
was incomplete and contained no safeguards toprevent theft of seized or forfeited assets.230

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST46

As reported in numerous recent SIGAR publications, the U.S. government has on a numberof fronts deemphasized, reorganized, or paused
some counternarcotics programming, despite
worrisome trends in Afghan narcotics production. The international community and Afghan
government have similarly minimized counternarcotics initiatives.
In November 2020, international donors
at Geneva did not include poppy-cultivation

estimates among the outcomes or targets outlined in the agreed to Afghanistan Partnership
Framework (APF). The APF is supposed toreflect a revised form of conditionality, so thiswould appear to be a missed opportunity for
donors to demand measurement of an important crosscutting indicator of Afghanistan’s
enduring poverty, lawlessness, insecurity,and corruption.231
The narcotics industry was included in the
Afghan government’s Afghan National Peaceand Development Framework II (ANPDF
II) that was presented at Geneva, but onlyin terms of the broader arena of illicit economic activities, such as illegal mining andmoney laundering. ANPDF II measures
outlined to combat illicit economic activity
included regional cooperation, improved
border crossings, and support to alternative
livelihoods development.232
The most important concrete measuretaken by the Afghan government was President
Ghani’s decree in January 2019 dissolving the
Ministry of Counter Narcotics (MCN) andtransferring relevant responsibilities to the
Ministry of Interior’s (MOI) Counter Narcotics
Police of Afghanistan (CNPA), Ministry ofAgriculture Irrigation and Livestock, Ministryof Public Health, and the National Statistics
and Information Authority (NSIA).233 Although
SIGAR noted in 2018 that the MCN often lacked
the political influence, financial resources, andimplementing capacity to fight the burgeoning
drug trade, it was able to perform some important functions such as administering donor
funds, including those from INL.234
State provided no information on why theAfghan government chose to dissolve the MCN,
and offered that some narcotics-related programing would be little affected, since someministries, such as the Ministry of Public Health,already exercised significant responsibilities
over narcotics-related programs.235 However,
INL said in January 2021 that counternarcotics
policymaking has suffered because processes
were “likely unclear and confusing due to theSPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THE ILLICIT NARCOTICS TRADE
recent dissolution of MCN and distribution of
its activities.”236
Additionally, once given all responsibility for poppy-survey-related work, the NSIA
quickly derailed over a decade of cooperation
between the MCN and the UNODC on the
biannual Afghan opium surveys. The 2019
survey was finally released in February 2021,
nearly a year and a half behind schedule. The
2020 survey reports have yet to be released,
although they are considered essential tools
for planning, implementing, and monitoring
counternarcotics efforts.237
In 2019, NSIA specifically objected to
UNODC’s measurement of the opium-poppy
yield, even though UNODC was using the same
sampling methodology since 2012, employing
field measurements of mature poppy plants.238
These disagreements over yield measurement
prevented the 2019 Afghanistan Opium Survey
reports from being released on time.239 Yet
NSIA did not implement alternative samplingtechniques during the 2020 season. So NSIA
performed no field sampling, random or otherwise, in 2020. Without field sampling, UNODC
began developing satellite-imagery methods toestimate the 2020 opium-poppy yield.240 NSIA
continues to review this satellite-imagery methodology and has not approved it.241
Finally, one of the few counternarcotics-specific INL programs in recent years is
now inoperative from INL’s perspective. The
Governor-Led Eradication program (GLE) provided direct eradication assistance to the MCN
for every UNODC-verified hectare of eradicatedpoppy.242 But since the MOI has assumed management of the program with the CNPA as theimplementing entity, INL must now complete an
audit of the MOI’s financial-control mechanisms
before it can provide support to MOI for GLE
programming.243 INL has provided no updates to
the GLE program since July 2020 because there
have been no developments in overcoming thisfunding roadblock.244

QUESTIONS FOR POLICYMAKERS• Given the consistent failure of U.S.
counternarcotics programs in Afghanistan
over the past 19 years and their decreasingemphasis as a U.S. programmatic priority,
can the U.S. government support effective
counternarcotics programs with a muchsmaller U.S. military and civilian presence,
and without much improved Afghan
political will?
• How would a potential peace agreement
between the Afghan government
and the Taliban be leveraged by U.S.
implementing agencies to positively
influence the development of more effective
counternarcotics programs in Afghanistan?
• Will U.S. or Afghan counternarcotics
operations targeting narcotics-associatedgroups like the Taliban be carried out during
a cease-fire or after a peace settlement?
• Will an increase in narcotics trafficking
enrich terrorists and the Taliban andtherefore threaten U.S. security?

47

Caption
Public hearing on National Inquiry on Women, Peace and Security. (UNAMA photo)

HIGH-RISK AREA 7

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THREATS TO WOMEN’S RIGHTSHIGH-RISK AREA: THREATS TO WOMEN’S RIGHTS
WHY IT IS A HIGH RISK
Improving the lives of women and girls andadvancing women’s equality in Afghanistan
have been key goals of the United States.
DOD, State, and USAID have disbursed atleast $787.4 million from 2002 to 2020 on
programs that specifically and primarily supported Afghan women and girls in the areasof health, education, political participation,access to justice, and economic participation.
The total U.S. investment in women and girls,
however, is higher since hundreds of additional
U.S. projects and programs have included an
unquantifiable gender component.245
Afghan women and girls have made substantial gains over the past nearly two decades. They
have greater access to life-saving health care,
and as many as 3.5 million girls (out of roughlynine million students) are enrolled in school,
though the number of girls actually attendingis almost certainly lower.246 Afghanistan’s legal
framework—at least on paper—offers womenmany protections, including equal rights for
women and men.247 Eighty-six women serve inparliament.248 Women now represent roughly
one-third of the nation’s teachers, and an estimated 10,000 women are doctors, nurses, andother health professionals.249
Despite these improvements, Afghanistan
remains one of the most challenging places in
the world to be a woman—with high maternal-mortality ratios, endemic gender-based
violence, still-limited access to educationand health care, and pervasive harassment of
women who work outside the home, especiallyin nontraditional roles.250 In 2018, the United

Nations ranked Afghanistan 143rd for genderequality among 162 countries.251
Ongoing peace negotiations between the
Afghan government and the Taliban raisequestions and concerns about whether thefragile gains made by women and girls will bepreserved in a future peace agreement. In a
February 2020 opinion piece published in the
New York Times, Sirajuddin Haqqani, the deputy Taliban leader, said the Taliban envisioned
an Afghanistan “in which all Afghans haveequal rights, where the rights of women thatare granted by Islam—from the right to education to the right to work—are protected.”252
But given the Taliban’s track record of interpreting the rights Islam grants to women,
women’s-rights advocates are wary. Ghizaal
Haress, assistant professor at the American
University of Afghanistan, said, “If we leave it
to [the Taliban’s] broad interpretation or to thebroad idea of women’s ‘Islamic values,’ thenwe’re going to be in trouble.”253
Overall, another long-term danger for Afghan
women is that Afghan peace negotiations break
down, plunging the country into worse violence.
Physical insecurity remains one of the biggest
challenges facing women, both directly andindirectly.254 Women and girls suffer not only
loss of life, injury, disability, and mental trauma,
but also the loss of male breadwinners, increasingly desperate poverty, the social stigma anddiscrimination that accompany widowhood andpermanent disability, and reduced access tobasic services.255

492021 HIGH-RISK LIST

HIGH-RISK AREA

Women discuss their role in the ongoing Afghanistan peace negotiations in Qatar. (UNAMA photo)

50

Another key risk is how the reduction in
U.S. and Coalition troops will affect the existing rights of women and girls. With only 2,500
U.S. troops in country,256 the Afghan National
Defense and Security Forces’ (ANDSF)
ability to resist Taliban attacks and protect
Afghanistan’s citizenry has already been tested.
Both Afghan government and Taliban leverageat the negotiating table will be determined inpart by what happens on the battlefield.257 Thus,
reduced Coalition support to the ANDSF could
indirectly affect the balance of the negotiating
parties’ leverage.
Moreover, while the expectation is that
Afghan government negotiators will use theirleverage to preserve women’s rights, it remains
to be seen how hard they will push to do so—or
how their leverage might erode over time if the
Taliban make further battlefield gains. It is also
unclear to what extent the Taliban will use theirleverage to try to erode legal rights and accessto services for women and girls.
Finally, the COVID-19 pandemic and its
impact on Afghanistan’s vulnerable public-health infrastructure and economy also
threaten to undermine women’s status andquality of life. Overall, these challenges createmuch uncertainty regarding the extent to which
Afghan women and girls will be able to maintainand build upon their gains made since 2002.

WHAT SIGAR FOUND
In February 2021, SIGAR published its ninth
lessons-learned report, Support for Gender
Equality: Lessons from the U.S. Experiencein Afghanistan. The report examined U.S. gender-equality efforts in Afghanistan since 2002,
the gains women have made, and ongoing barriers to progress, and made recommendations for
how U.S. agencies can best continue to support
Afghan women and girls in the future.258
Women and girls have achieved important
progress since the beginning of United States’
military intervention in 2001. Between 2002
and 2018, the number of trained midwives grewfrom an estimated 467 to 4,000.259 In 2002, only
14% of births were attended by skilled healthpersonnel; in 2018, that number was nearly
60%.260 The proportion of health facilities staffedSPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THREATS TO WOMEN’S RIGHTS
with at least one female health worker rosefrom 25% in 2002 to 92% in 2017.261
A reflection of these and other gains is thatthe maternal-mortality ratio—the number ofwomen who die due to birth- or pregnancy-related complications—has declined, possibly
by as much as 19% or more. A caveat is thatthe methodologies used to generate maternalmortality data have varied over time, and thereliability of some data has been questioned.
Thus, while a decline in maternal deaths has
likely occurred, a precise measurement of the
reduction remains elusive.262
In 2001 there were few, if any, female teachers in public schools; by 2018 approximately
70,000 women worked as teachers.263 Literacy
rates among girls rose from 20% in 2005 to
39% in 2017.264 In a landmark achievement for
women’s political participation, the 2004 constitution reserves 27% of seats in the parliament
for women.265 Almost 50% of the 9,708 elected
community-development council members
across the country are women.266 Improvements
in women’s economic participation, access tojustice, and participation in the security forces
have been more modest, but nonetheless represent critical progress.267
The positive gains across these sectors,
however, are tempered by the reality that significant barriers continue to impede progress
for women and girls. Girls’ access to educationis constrained by the lack of female teachers,of schools, of separate girls’ bathrooms, andby cultural and familial pressures on girls towithdraw from school at puberty.268 Women’s
access to health care is hampered by a lackof female health-care providers, restrictive
sociocultural practices, lack of education,and prohibitive costs.269 Gains in many areas
have been geographically uneven, with rural
women and girls experiencing significantly lessimprovement overall.270
SIGAR’s lessons-learned report concluded
that between 2002 and 2020, U.S. efforts to support women and girls’ equality in Afghanistan
yielded mixed results. Considerable investment

contributed to indisputable gains—especiallyin education and maternal health. Key factors
in improving the access of women and girls
to health care and education were existing
expertise and capacity within aid organizations,
popular demand for these services, consistentfunding, and rigorous impact evaluations of programs. Community-based education has proveneffective as a reliable, culturally accepted modelfor delivering primary education in areas where
the formal education system does not operate,and especially in closing the enrollment andachievement gap between girls and boys.271
Yet U.S. programming also had shortcomings.
USAID was unable to field the resources andexpertise needed to effectively integrate gender-related objectives across programs. In somecases, U.S. efforts could have benefited froma greater appreciation of the Afghan culturalcontext, and might have set more realistic goals
if officials had better understood formidable
cultural and social barriers. Further, in the earlyyears, public rhetoric that closely linked women’s rights to the war against the Taliban likely
fostered unrealistic expectations of what could
be achieved. On the positive side, however,
U.S. political attention to these issues meantthat agencies could obtain resources for women’s-equality efforts that are underfunded inmany countries around the world.272
An October 2020 SIGAR audit found that one
focus of DOD’s investments to support Afghan
women and girls—building facilities for female
police and military troops—failed to achieve its
goals. SIGAR reviewed DOD’s construction of
29 such facilities built under contracts awarded
between 2015 and 2017. SIGAR selected 17 of
the 29 projects for site visits, and found that
only three projects were mostly being used asintended. Of the remaining 14 projects, six werecompletely unused, five were mostly unused,
and three were not used as intended—butinstead were used by men in the ANDSF.273
SIGAR identified multiple reasons that facilities intended for women were not being used,
including Afghan cultural hostility to women51

2021 HIGH-RISK LIST

HIGH-RISK AREA

Women attending a UN-sponsored International Women’s Day event and awards ceremony in Afghanistan.
(UNDP photo)52

training in some local areas where the projects
were located, the absence of necessary utilities
such as water and electricity, and the Afghan
government’s failure to procure needed equipment and furniture in a timely manner.274
While not all U.S. efforts worked as intended,
the lessons-learned report broadly concluded
that the impact of U.S. backing for Afghan
women’s rights should not be underestimated.
There are intangible, hard-to-measure benefits
from U.S. support for women and girls; thesheer existence of programming and U.S. policy
attention on women’s status and rights form
part of the “scaffolding” for wholesale change in
Afghan social norms, according to one former
civilian NATO official.275 Afghan women themselves point to the vocal support by the UnitedStates and other international actors as a key
factor in advancing their rights and participation in the public sphere.276

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST
The threats to Afghan women’s rights may be
more dangerous in 2021 than when the 2019
High-Risk List was issued. With the Taliban
increasing the tempo of attacks against Afghan
security forces and refusing to enter into acomprehensive ceasefire, they maintain significant leverage in peace negotiations withthe government. That their negotiating teamexcludes women does not inspire confidence
that Taliban views on gender roles and relations
have evolved.277
Another deeply troubling threat to women’ssecurity has emerged: an increase in targetedkillings of community leaders, attacks which
often go unclaimed. The New York Times documented at least 136 such killings—of civil
servants, journalists, and human rights workers—in 2020.278

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

THREATS TO WOMEN’S RIGHTS
On January 17, 2021, unidentified gunmen
shot and killed two female judges on their way
to work at the Supreme Court in Kabul.279
To anticipate how the Taliban might govern ifthey play a role in a future Afghan government,
it is instructive to consider Taliban practices
today. Detailed, reliable information on the
topic is limited, making it difficult to draw firm
conclusions. But a 2020 Human Rights Watch
report said few Taliban officials allow girls toattend school past puberty, and “others do not
permit girls’ schools at all.”280 The Taliban claimthat the social restrictions in areas they control
reflect local community norms, not imposedby them—which may be partly true, especiallyamong more conservative rural communities.281
Yet more worrying, in 2019, the United
Nations Assistance Mission in Afghanistan(UNAMA) documented four occasions ofhuman rights violations against women by
the Taliban—three public lashings and one
execution, all on grounds of “immoral” acts.
The executed woman’s “crime” included beingalone with a man helping her flee an abusive
home. The man received 40 lashes on so-called
charges of elopement.282 Ultimately, the kind oflife Afghan women might face under any government in which the Taliban exert influence
will be a product of the Taliban’s willingness—or unwillingness—to negotiate their differenceswith the Afghan government and local communities, and the varying beliefs and practices
within their own ranks.
Regardless of what happens in peace negotiations, the COVID-19 pandemic highlights
the challenges facing women. Cultural norms
often demand that women patients see afemale doctor, who are in short supply. Mehdi
Hakimi, a lecturer at Stanford University, told
SIGAR, “Due to deeply entrenched sociocultural
norms, many Afghans are reluctant to allow
their mothers, wives, daughters, or sisters tovisit a doctor directly, or at all, if that doctor
is a male. Such misguided notions of ‘honor,’
which is another form of violence, can prevent proper medical diagnosis and access tolife-saving treatment, and result in profoundly
perilous consequences.”283
Johns Hopkins University suggested a possible 18% increase in child mortality and a 14%
increase in maternal mortality as indirect consequences of the virus’s spread.284 Layoffs alsopose a threat to the gains women have madein the workforce.285 In 65 interviews commissioned by SIGAR, many respondents—men andwomen—cited an increase in domestic violence
during the pandemic.286

QUESTIONS FOR POLICYMAKERS• How can the United States use its existingleverage—diplomatic, financial, andmilitary—to press both Afghan government
and Taliban negotiators to ensure thata peace agreement includes languagethat protects women’s and girls’ rights ascurrently enshrined in Afghan law, and does
not constrain their access to services?
• How can the United States best amplify thevoices and participation of a wide rangeof Afghan women leaders—representing
various ethnicities, geographies, andsocioeconomic backgrounds—in theongoing Afghan peace negotiations?
• How can DOD, State, and USAID identify
and build on what has worked in U.S. gender
programming in Afghanistan, and amend or
avoid what has not?
• What policy responses are Congress andthe Administration prepared to pursue if
women’s and girls’ rights are not protected?
• What steps will U.S. agencies need to taketo continue delivering assistance to support
Afghan women, girls, and gender equality,
in the event that the Taliban become
part of national, provincial, and district
governing bodies?

53Caption
Partial aerial view of Kabul. (DOD photo)

HIGH-RISK AREA 8SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INADEQUATE OVERSIGHT

HIGH-RISK AREA: INADEQUATE OVERSIGHT
WHY IT IS A HIGH RISK
Afghanistan’s pervasive insecurity and corruption have severely inhibited U.S. reconstruction
efforts, as well as efforts to oversee them.
SIGAR’s work has consistently noted that mostof the funds appropriated for Afghanistan
reconstruction since 2002 could have beenspent more wisely and cost-effectively—andachieved better and longer-lasting outcomes—
with more oversight.287
Responding to a Congressional request,
SIGAR launched a series of efforts to quantify
the amount of waste, fraud, and abuse it identified in U.S.-funded programs. This work has
identified nearly $19 billion (or 30% of the $63
billion SIGAR has cumulatively reviewed) lostfrom 2008 to December 31, 2019.288 Additionally,
since 2008, SIGAR has identified $3.82 billion insavings for the U.S. taxpayer.289
Effective oversight has been weakened bypoor documentation, failure to monitor contract
compliance and work quality, inattention toholding contractors and grantees accountablefor unsatisfactory performance, insufficient
control measures to mitigate the effects of corruption, and other issues.290 Ongoing problems
with contract compliance, documentation andaccountability, and institutional memory loss
caused by frequent personnel rotations havebeen made even more challenging by the withdrawal of substantial numbers of U.S. militaryand civilian personnel, COVID-19 restrictions,and the uncertainty surrounding an Afghan
peace agreement.291
These problems are compounded by deteriorating security that has made it impossible for
U.S. personnel to access many reconstruction

project sites and programs in Afghanistan. Withfewer U.S. agency oversight personnel in-country, the Inspector General testified in 2020 that
The Congress should consider requiring
DOD, State, USAID, and other relevant executive agencies to ensure adequate oversight,
monitoring and evaluation efforts continue
and not be dramatically reduced as part of aright-sizing program, as witnessed recently
by State’s personnel reductions at the
Kabul embassy. Without adequate oversightstaffing levels and the ability to physicallyinspect, monitor, and evaluate programs,
Congress should consider the efficacy ofcontinuing assistance.292

OVERSIGHT OF U.S. FUNDS MORE
ESSENTIAL THAN EVER
Since FY 2002 Congress has appropriated$143.27 billion for Afghanistan reconstruction,of which more than $8.23 billion remains to be
spent.293 Yet Afghanistan is still nowhere near
being able to fund its current government withdomestic revenues and will require substantial
donor assistance in the future.294 Further appropriations are expected in the coming years, so
vigilant oversight and Afghan reform initiatives
will be important means of protecting American
taxpayers’ money as more of it passes into budgetary control by Afghan ministries.295
To illustrate the large scale of funding thatmight be expected, a draft World Bank plancalled for $5.2 billion over five years in postpeace spending, while others estimate around$6.6 billion in additional assistance will be

55

2021 HIGH-RISK LIST

HIGH-RISK AREAA SIGAR audit found a $6.4 million women’s facility at the police academy in Kabul sat unused. (SIGAR photo)required annually for a viable Afghan state
to operate.296
At the November 2020 Afghanistan
Conference in Geneva, donors pledged toprovide at least $3.3 billion for Afghanistan’s
development priorities in 2021, with annual
commitments expected, subject to annual
review, to stay at that level through 2024.297(Security assistance is pledged separately.) The
United States made available up to $600 million
for civilian assistance in 2021.298

WHAT SIGAR FOUND56

SIGAR has documented hundreds of casesof waste, fraud, and abuse of U.S. funds provided off-budget (U.S.-managed rather than by
Afghan ministries) just in the last few years.
SIGAR has documented hundreds of cases ofwaste, fraud, and abuse of U.S. funds just in
the last few years.299 This is why the Inspector
General called oversight “mission-critical toany successful reconstruction and development
program in Afghanistan.”300 Most of the wasted

funds related to agencies’ ineffective or inadequate internal controls.301 But of particular
oversight concern is the suggestion that as theUnited States reduces its military and civilian presence in Afghanistan, an even greater
proportion of U.S. financial support will be
provided as on-budget assistance (directly to
the Afghan government or through multilateraltrust funds).302
While there may be some benefits to providing on-budget funds, there are also atypicalrisks because Afghanistan, which suffers fromlimited institutional capacity, lacks a tradition ofa strong central government, and is combating
an armed existential threat while attempting
social and economic development.
Notably, the ability to monitor, influence, andaccount for the distribution of U.S. aid is likely
to decline as more funds are executed by theAfghan government,303 especially one that may
incorporate the Taliban as part of a peace settlement. U.S. law enforcement would also thenlose effective oversight and criminal jurisdiction
for those who embezzle, steal, bribe, extort,

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INADEQUATE OVERSIGHT

A U.S.-supported hotel-construction project left a security threat—an unfinished building overlooking the U.S. Embassy
compound in Kabul. (SIGAR photo by Adam Bonfanti)

or misappropriate procurements made with
on-budget funds.304
There is already evidence that an increasing portion of U.S. appropriations for civilian
development assistance is being channeledon-budget.305 Since 2002, the United States has
provided more than $16.90 billion in on-budget
development and security assistance to theAfghan government. More than $10.94 billion
went to Afghan government ministries andinstitutions, and nearly $5.96 billion to threemultinational trust funds—the World Bank’s
Afghanistan Reconstruction Trust Fund (ARTF),
the United Nations Development Programme’s
Law and Order Trust Fund for Afghanistan,and the Asian Development Bank’s Afghanistan
Infrastructure Trust Fund.306
This trend is likely to hold, especially if apeace agreement is reached and substantial
numbers of U.S. government personnel departAfghanistan. SIGAR does not question thatpolicy, but cautions that with fewer U.S. government personnel in Afghanistan to oversee
the use of U.S. funds, Congress should insist
on effective internal controls, monitoring, andaccountability by the recipient internationalorganizations and Afghan ministries.307 Equallyimportant, SIGAR and other agencies must beable to provide oversight of those measuresand controls.
SIGAR has discovered, investigated, andaudited several troubling instances of waste,fraud, and abuse (or serious risks of such) of
U.S. on-budget funds. For example:• A SIGAR investigation found that theawardees of a $1 billion Afghan Ministryof Defense fuel-procurement contract in2013 had colluded to rig their bids above
previously competitive price levels, withevidence of attempted bribery.308• In 2018, SIGAR found significant
deficiencies in the World Bank’s ARTF
controls, including ineffective oversightand accounting of U.S. funds, and a lackof meaningful performance indicators andmeasures to oversee project performance.
SIGAR believes that the limitations andlack of transparency puts billions of U.S.
taxpayer dollars at risk.309

57

2021 HIGH-RISK LIST

HIGH-RISK AREA

A solar power substation built through the Power Transmission and Connectivity Project. (SIGAR photo)• A September 2019 audit documented
that USAID continued to provide
on-budget funding to Afghanistan’snational power utility for construction
and commercialization activities despite
concerns about the utility’s internal
controls, management of public finances,and vulnerabilities to corruption.310

58

SIGAR has found that donor oversight isoften a catalyst for Afghan reforms, and that theright kind of oversight relies on benchmarksthat are both well-defined and verifiable.311 In
Afghanistan’s conflict setting, though, rules are
not rigorously observed and documentation isoften incomplete and unverifiable.312
In some cases, this is due to Afghanistan’s
unique and difficult operating environment,changes in internal agency policies over time,and frequent turnover in project staff. This was
especially true of U.S. support to Afghanistan’s
power-sector programs. For example, a 2019
SIGAR audit examined the $775 million spent
by DOD and USAID since 2004 to increaseelectric generating capacity in Helmand andKandahar Provinces in southern Afghanistan.
SIGAR found that DOD did not collect orreport strategic-level performance data for
its projects because it was not required to doso, even though it acknowledged the projects’
importance for counterinsurgency and socioeconomic-development objectives. Further,
USAID collected and reported incomplete performance data (baselines, targets, and results)
for its strategic-level performance indicators,
and could not determine the full extent to which
its projects supported expanded sustainablephysical infrastructure and agriculture-led economic growth.313
These are not mere paper exercises infinance and process. Poor oversight risks
lives.314 In 2019–2020, SIGAR issued 13 inspection reports that identified construction or
maintenance deficiencies and/or safety hazards of U.S.-funded reconstruction projects.
In March 2020, SIGAR issued a summary offindings from site visits at 269 health facilities
across 10 provinces. Several of these facilities
may put occupants at risk from structural deficiencies, including damaged walls; damaged orSPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INADEQUATE OVERSIGHT
missing roofs, windows, and doors; or settlingor deteriorating foundations. Damage to two
facilities was so severe that SIGAR immediately
issued alert letters to USAID.315
SIGAR’s work shows why having personnel
physically present and able to move about thecountry is essential for effective oversight. As
the Inspector General has said, “Sometimes simply no substitute for getting out and kicking thetires.”316 Without physical presence and access,it is difficult to determine whether training iseffective, equipment is operable, clinics arestocked with medicines, schools are open, or
buildings are safe and functional.
In one illustrative case, SIGAR found that
despite providing $85 million in loans for
the Marriott Kabul Hotel and Kabul Grand
Residences, built across the street from U.S.
Embassy Kabul, the U.S. government’s Overseas
Private Investment Corporation (OPIC) failed toprovide oversight of the construction projects.
As a result, the two buildings sat neglected andabandoned for years, posing a severe security
threat—its upper levels provide a view into
the embassy compound—that SIGAR warned
the State Department about in November
2016. SIGAR found that OPIC did not conduct
direct oversight or receive an objective, independent assessment of construction progress,
and that it provided loans based on inaccurate
and potentially fraudulent information, which
in turn resulted in a significant loss of U.S.
taxpayer dollars.317
SIGAR has the largest oversight presence inAfghanistan, with more auditors, analysts, andinvestigators in country than any other U.S. government agency. Some SIGAR staff who were
temporarily reassigned to the United States dueto the COVID-19 pandemic have since returned.
SIGAR also plans to supplement its resident
staff again with personnel on short-term temporary duty in Afghanistan as conditions allow.
But even without COVID-19-related restrictions, large portions of Afghanistan remain
inaccessible to SIGAR and other U.S. civilians working under Embassy Kabul’s Chiefof Mission authority. While the U.S. Embassy
accommodates travel requests as practicable,most embassy personnel, including USAID
and State Department program officers, havelong been restricted to the international zone
in Kabul due to security concerns. SIGAR andother agency staff are similarly limited, although
SIGAR personnel are sometimes able to travel
under State Department and U.S. military protection, subject to chief-of-mission permission.
To maintain aggressive oversight efforts
in the face of these dangers, SIGAR employs
alternative means to ensure visibility on U.S.funded projects. These include using a widely
advertised telephone and email hotline to report
information; employing satellite imagery; hiring
Afghan nationals who can travel at less personalrisk than U.S. nationals; leveraging SIGAR’s
institutional memory to develop, nurture, andexpand an extensive network of Afghan- andU.S.-based sources; maintaining robust outreachto Afghan government officials; and partneringwith nongovernmental organizations whose
work SIGAR verifies.318 There is no shortage ofissues to examine. Since the 2019 High-Risk
List was issued, SIGAR has received 306 hotline
complaints, opened 55 new investigations, andclosed 129 investigations.319
In response to Afghanistan’s unstable security situation, donors, their implementing
partners, and others often seek to manage andmonitor their programs remotely. While thisalternative can overcome some limitations,past studies have found that remote management can lead to inaccurate project data andreporting, as well as to fraud, corruption, or
failure to report corruption.320 For example, ina November 2019 audit of USAID’s emergency
food assistance to Afghanistan, SIGAR foundthat more than 91% of USAID’s implementing
partners’ formal quarterly, biannual, annual,and final project-performance reports lacked
information required by USAID’s award agreements. Additionally, from 2014 through October
2018, USAID conducted only one site visit to592021 HIGH-RISK LIST

HIGH-RISK AREA

Detached pond liner air vent at a wastewater treatment facility. (SIGAR photo)

food-assistance project or partner locations due
to insecurity.321
The United States therefore relies heavily
on Afghan and contractor reporting, which
often cannot be independently verified. Evenif high standards of practice were more consistently applied, the ability of U.S., Coalition,and international personnel to monitor, manage, and oversee programs in Afghanistan will
only become more problematic if the security
environment does not improve markedly, or
if a possible peace agreement entails further
reductions in foreign personnel without any
accompanying improvement in Afghanistan’s
governance.

WHAT HAS CHANGED SINCE THE
2019 HIGH-RISK LIST

60

Since the 2019 High-Risk List was issued, theAfghan government and the Taliban enteredpeace negotiations. The United States also
signed an agreement with the Taliban that calls
for the phased, conditions-based withdrawalof all foreign forces from Afghanistan by May
2021 in exchange for reduced levels of violence and various Taliban counterterrorism
and political guarantees.322 In testimony to theHouse Committee on Oversight and Reform in
January 2020, the Inspector General warned
that the stewardship of U.S. taxpayer funds andachievement of reconstruction goals could suffer if such troop reductions are accompanied bylarge-scale withdrawals of U.S. operational andoversight personnel.323
In addition to regular reporting on the impactof rising insecurity in Afghanistan and pandemic-related restrictions on the physical movementand deployment of U.S. military personnel
and their oversight of Afghan security forces,
in October 2020, SIGAR began documenting
challenges these troop reductions had on U.S.
capabilities and the train, advise, and assist mission, including:324• inability to monitor below the corps orzone headquarters levels, or to partner withlower-echelon Afghan forces

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTION

INADEQUATE OVERSIGHT• reduced ability to verify Afghan data, forcing
a greater reliance on Afghan self-reporting
to assess, monitor, and evaluate
U.S. financial assistance will continue forthe foreseeable future,325 but its scope will
likely depend on the outcome of Afghan peacetalks.326 The extent of U.S. reconstruction
efforts in Afghanistan should a sustainable
peace agreement be reached has also not yet
been determined, nor has the size of the overall
U.S. presence that will remain in Afghanistan
to administer and oversee these programs. But
previous reductions in DOD, State, and USAID
personnel levels have had detrimental effects
on U.S. oversight,327 and further reductions arelikely to have additional repercussions.

Long-Term Oversight Requires Greater
Accountability of Donor Aid
Donor funds have continued to flow despite theAfghan government’s failure to fully embrace
reforms.328 But as U.S. agency footprints in
Afghanistan shrink, it will become increasingly important that the U.S. and other donors
perform aggressive and effective oversight ofassistance by, for example, demanding in funding agreements: complete transparency andaccess, measurable and verifiable benchmarks
with tangible outcomes, periodic reassessmentof funding goals and Afghanistan’s needs, andhigh level political buy-in from all sides.
The Afghanistan Partnership Framework(APF) resulting from the November 2020
donor conference in Geneva contained theconditions and goals necessary for continued international support, but did not specify
consequences should the government fallshort.329 While the APF creates opportunities
for donors to impose more specific and measurable conditions than in previous frameworks
whose provisions did not substantially affectassistance levels,330 SIGAR will monitor what,of the various principles, outcomes, and/or

reform targets donors financially incentivize forparticular achievements.

QUESTIONS FOR POLICYMAKERS• Have U.S. agencies and their implementing
partners established and adhered to specific,
measurable, meaningful, and operationallypracticable metrics for determining
successful project outcomes, and forprotecting U.S. taxpayer dollars from waste,fraud, and abuse?
• How has the reduction of U.S. military andcivilian personnel affected agency oversightplans? Have agencies reviewed plans toensure that adequate safeguards can be
maintained to detect, deter, and mitigate
waste, fraud, and abuse of the billions ofdollars they collectively execute? Have any
foreseeable limitations and resource needs
been reported to Congress?
• If more (or most) U.S. assistanceto the Afghan government moves
on-budget, whether through bilateraltransfers or disbursement throughmultilateral trust funds, what are the best
oversight mechanisms to protect U.S.
reconstruction funds?
• Should U.S. agencies maintain any directoversight of on-budget funds once they aretransferred, and if so, at what levels? Whatis an acceptable risk for U.S. implementing
agencies yielding their financial andprogrammatic oversight responsibilities
to multilateral institutions? Should
Congress require regular risk assessments
and findings?

61

Caption
An Afghan woman with burqa in a mild sandstorm, near Balkh. (Afghanistan Matters photo)

CONCLUSION

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONRISKS HAVE NEVER BEEN HIGHERCONCLUSION: RISKS HAVE NEVER BEEN HIGHER
With the leverage of a substantial foreign troop
presence in Afghanistan rapidly diminishing,
U.S. reconstruction programs aimed at promoting security, health, education, economic
development, rule of law, respect for humanrights, and good governance for the Afghan
people may become the primary lever of U.S.
influence in the country. However, the U.S.
reconstruction mission is at greater risk in 2021
than at any point in the past 20 years.
Peace negotiations remain stalled, while
security-related threats to the Afghanistan
reconstruction effort have increased since
SIGAR issued its 2019 High-Risk List. The
threats are mainly due to the rising level of
Taliban violence, persistent capability gaps
within the Afghan security forces, and overall
deterioration of the security environment. At
the same time, donors’ pledged civilian assistance has fallen to what some experts consider
the bare minimum for maintaining Afghanistan
as a viable state.331
One of the world’s poorest countries,
Afghanistan has suffered from 40 years of fighting. The past year has added to those miseries
with escalating insurgent attacks, rising crime,
targeted killings, the COVID-19 pandemic, andincreased incidence of polio, economic distress,
and growing food insecurity.
Crime levels have been steadily rising foryears—most noticeably in Kabul, which has historically had relatively low crime rates. But by
2020, garden-variety crime constituted the biggest concern for the residents of Kabul, where
criminal activity had spread into previously
safe neighborhoods and grown increasingly
brazen and violent.332 Extensive police crackdowns ensued, but two decades of militarized

police training, focused on suicide bombingsand terrorist infiltrations, left Afghan police
ill-equipped to handle cases of robbery, kidnapping, and murder.333
The January 2021 update to the UN’s
Humanitarian Response Plan for Afghanistan
paints “a shocking picture of escalating suffering, hunger and danger.” The UN says
humanitarian interventions are planned for 15.7
million people in 2021 compared to 2.3 million
people four years ago—a six-fold increase
largely driven by food insecurity and economic
and health-related complications from the
COVID-19 pandemic. UN assessments show
76% of the population needs humanitarian foodassistance—second-worst in the world—andnearly 50% of Afghan children under five yearsof age face acute malnutrition.334
Even if there is a peace agreement, there arealso questions and concerns about whether afuture government that includes the Taliban
will preserve the fragile gains made by Afghan
women and girls. Likewise, corruption remains
a major challenge. While the Afghan government has taken limited steps to curb corruption,
more tangible action is required.
Although Afghanistan remains the world
leader in opium production, the U.S. government has on a number of fronts deemphasized,
reorganized, or paused some counternarcotics programming, despite worrisome trends
in Afghan narcotics production. Equally concerning, the international communityand Afghan government have also downplayed counternarcotics in recent years.
As U.S. military and agency footprints in
Afghanistan shrink, it will become increasingly important that the U.S. and other donors

632021 HIGH-RISK LIST

CONCLUSION
perform aggressive and effective oversight byinsisting that funding agreements include:• measurable and verifiable benchmarks withtangible outcomes,• periodic reassessment of funding goals
and Afghanistan’s needs,• high-level political buy-in from U.S., Afghan,
and international officials,• full and unfettered access to on-budget
funding flowing through Afghan ministries
As the largest U.S. oversight presencein Afghanistan—and the only one withwhole-of-government oversight authority—SIGAR stands ready to work with the
Administration and Congress to ensure thatreconstruction funds are put to the best possible use despite these rising risks to thesuccess of two costly decades of reconstructionin Afghanistan.

64

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTESENDNOTES
1.

2.
3.

4.

5.

6.

7.

8.

Congressional Research Service, Department of
Defense Contractor and Troop Levels in Afghanistan
and Iraq: 2007–2018, report R44116, updated
5/10/2019, p. 7. The report also indicates in thesame table that in the second quarter of FY 2011 theUnited States then employed more than 90,000 contractors in Afghanistan—a number that increased as
the troop count began to decline, https://crsreports.
congress.gov/product/pdf/R/R44116.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, pp. 29, 173. SIGAR analysis.
PDF versions of this report and of predecessors
prepared for the sessions of Congress beginning in
2015, 2017, and 2019 are posted on the agency’s website, www.sigar.mil.
A recent troop-strength “placemat” published by
the NATO-led Resolute Support Mission (RS) in
Afghanistan lists just under 16,000 U.S. and othertroops (about 8,000 U.S. at that time), compared
to a February 2011 placemat from the predecessor
International Security Assistance Force (ISAF) that
listed nearly 132,000 (about 90,000 U.S.) international troops. Resolute Support Mission, Key Facts
and Figures, accessed 2/9/2021, rs.nato.int/rsm/
newsroom/key-facts-and-figures; ISAF, Key Facts
and Figures, 2/3/2011.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, pp. 2, 4.
UN, “Strong Support for Afghanistan at the 2020
Afghanistan Conference,” 11/24/2020, https://unama.
unmissions.org/strong-support-afghanistan-2020-afghanistan-conference.
Khyber Farahi and Scott Guggenheim, Pathwaysfor Post-Peace Development in Afghanistan,
USIP Special Report No. 487 (11/2020),
p. 20, https://www.usip.org/sites/default/
files/2020-11/20201103-sr_487-pathways_for_postpeace_development_in_afghanistan-sr.pdf.
Khyber Farahi and Scott Guggenheim, Pathwaysfor Post-Peace Development in Afghanistan,
USIP Special Report No. 487 (11/2020),
p. 1, https://www.usip.org/sites/default/

9.
10.
11.

12.

13.

14.
15.
16.

17.
18.
19.

20.

files/2020-11/20201103-sr_487-pathways_for_postpeace_development_in_afghanistan-sr.pdf.
See SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, for more detailed discussions.
Pub. L. No. 110-181, §1229(a)(3).
SIGAR, 2019 High-Risk List, 3/2019, p. 13; DOD,
Enhancing Security and Stability in Afghanistan,
12/2018, p. 3; DOD, “Acting Secretary Miller
Announces Troop Levels in Afghanistan andIraq,” transcript, 11/17/2020, defense.gov/
Newsroom/ Transcripts/Transcript/Article/2418641/
acting-secretary-miller-announces-troop-levels-in.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, pp. 2, 4.
State, Integrated Country Strategy: Afghanistan,
updated 11/15/2020, p. 2, https://www.state.gov/
wp-content/uploads/2021/02/ICS_SCA_Afghanistan_
Public-Release.pdf.
Pub. L. No. 110-181, §1229(i)(2).
Pub. L. No. 110-181, §1229(i)(1)(E).
SIGAR, High-Risk U.S. Reconstruction Program
Areas in Afghanistan, Statement of John F.
Sopko, Special Inspector General for Afghanistan
Reconstruction, Testimony Before the Subcommittee
on National Security Committee on Oversight andReform U.S. House of Representatives, SIGAR 19-29TY, 4/3/2019, p. 4, https://www.sigar.mil
DOD, “Casualty Status,” 2/15/2021, accessed online
2/22/2021.
SIGAR, The Human Cost of Reconstruction in
Afghanistan, SIGAR 20-25-SP, 2/2020, p. 6.
SIGAR analysis of DOD’s Cost of War Update as of
September 30, 2020, response to SIGAR data call,
1/8/2021; and SIGAR analysis of agency-reported
obligation data of funds outlined in Appendix B
of SIGAR’s Quarterly Report to the United States
Congress, 10/30/2020.
SIGAR analysis of DOD’s Cost of War Update as of
September 30, 2020, response to SIGAR data call,
1/8/2021; and SIGAR analysis of agency-reported
obligation data of funds outlined in Appendix B
of SIGAR’s Quarterly Report to the United States
Congress, 10/30/2020.

65

2021 HIGH-RISK LIST

ENDNOTES
21.
22.
23.
24.
25.
26.
27.
28.

29.

30.

31.
32.

33.
34.
35.

36.
37.

66

38.

SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 25; SIGAR analysis.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 173; SIGAR analysis.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2019, pp. 30, 49, 59.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021; SIGAR analysis.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 173; SIGAR analysis.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 26; SIGAR analysis.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 29.
Shane Smith, “No more ‘92s: Lessons for U.S.
Afghanistan Policy from the Post-Soviet Withdrawal
and the Najibullah Regime It Left Behind,” Air
University (U.S. Air Force), 3/2013, pp. 4, 9.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 4.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 1.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2018, pp. 2, 109.
DOD, Department of Defense Budget, Justification
for FY 2021 Overseas Contingency Operations(OCO), Afghanistan Security Forces Fund (ASFF),
2/2020, pp. 107–109; SIGAR, Quarterly Report to
the United States Congress, 1/30/2021, p. 193; IMF
Country Report No. 20/300, 11/2020, p. 26; Treasury
Reporting Rates of Exchange, exchange rates at
December 31, 2020, at www.fiscal.treasury.gov,
accessed 1/19/2021; SIGAR analysis.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2018, p. 2.
State, “Remarks at 2020 Afghanistan Conference,”
11/24/2020.
Tobias Haque and Nigel Roberts, “Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state?” Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project (10/2020), pp. 7, 11, https://l4p.odi.org/assets/
images/ODI-L4P-Afghanistan-aid-requirementsHaque-and-Roberts-2020.pdf.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, pp. 2, 7.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, pp. 101–102.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2017, p. 1.

39.
40.
41.
42.

43.

44.

45.

46.

47.

48.

49.
50.

DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 1.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, Appendix B, pp. 172–173.
USFOR-A, response to SIGAR vetting, 1/15/2021 and10/19/2020.
RS, response to SIGAR data call, 1/6/2021; VOA,
“Afghan Government: Over 3,500 Troops Killed
Since U.S.-Taliban Agreement, 7/26/2020; see Afghan
Ministry of Defense press releases from the last
two years. Examples include: Afghan Ministry of
Defense, “80 Taliban were killed during the 24 past
hours!” 2/15/2021; DOD, Enhancing Security andStability in Afghanistan, 12/2019, p. 15.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, pp. 54, 57, 121, 131, 133;
State, Integrated Country Strategy: Afghanistan,
11/15/2020, p. 3; VOA News, “Russian Envoy Visits
Pakistan as Part of Effort to Jumpstart Stalled
Afghan Peace Process,” 2/19/2021.
Unclassified description of classified audit.
[Classified] Afghan Air Forces: DOD Has Taken
Steps to Develop Afghan Aviation Capability but
Continued U.S. Support is Needed to Sustain Forces,
SIGAR 21-14-C-AR, 1/2021, in SIGAR, Quarterly
Report to the United States Congress, 1/30/2021,
pp. 4–5.
SIGAR, Divided Responsibility: Lessons from U.S.
Security Sector Assistance Efforts in Afghanistan,
6/2019, p. 36.
SIGAR, Divided Responsibility: Lessons from U.S.
Security Sector Assistance Efforts in Afghanistan,
SIGAR 19-39-LL, 6/2019, pp. 56–57.
SIGAR, Divided Responsibility: Lessons from U.S.
Security Sector Assistance Efforts in Afghanistan,
SIGAR 19-39-LL, 6/2019, pp. 67–95.
SIGAR, Afghan Ministry of Interior Security
Upgrades: Project Was Generally Completed
According to Contract Requirements, But
Construction and Maintenance Problems Exist,
SIGAR 20-45-IP, 7/2020; SIGAR, Afghan National
Police Women’s Compound at the Herat Regional
Training Center: Construction Deficiencies Exist,
and the $3.1 Million Compound Has No Electricity
and Has Never Been Used, SIGAR 20-15-IR, 12/2019;
SIGAR, Afghan National Army Garrison at South
Kabul Afghanistan International Airport: New
Construction and Upgrades Generally Met Contract
Requirements, but a Safety Hazard and Maintenance
Issues Exist, SIGAR 19-53-IP, 8/2019.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 2.
RS, response to SIGAR vetting, “Transcript: COMRS,CJCS, US EMB On-record Interview 16 December
2020,” 1/6/2021.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES
51.

52.

53.

54.
55.

56.

57.

58.

State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a stateand is known as the Taliban and the United Statesof America, 2/29/2020, p. 2; Ambassador Zalmay
Khalilzad, Principal Deputy Assistant Secretary of
Defense for Indo-Pacific Security Affairs, Spoken
Testimony before the House Subcommittee on
National Security, House Oversight and Reform
Committee, 9/22/2020; DOD, “Sec. Esper Interview
With Fox News’ ‘Justice with Judge Jeanine,’
8/8/2020; RFE/RL, “Top General Says U.S. Troop
Cut In Afghanistan Hits 8,600 Target In Line With
Taliban Deal,” 6/18/2020; DOD, “Statement by Acting
Defense Secretary Christopher Miller on force
Levels in Afghanistan,” 1/15/2021.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, pp. 2, 4.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, p. 2; Afghanistan Times, “Taliban
expects additional 7,000 of their prisoners to bereleased,” 12/7/2020.
Foreign Policy, “Defying Peace Deal, Freed Taliban
Return to Battlefield,” 9/3/2020.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, p. 2.
Permanent Mission of Afghanistan to the United
Nations, “Statement by H.E. Ashraf Ghani, Presidentof the Islamic Republic of Afghanistan, General
Debate of the 75th Session of the United Nations
General Assembly,” 9/22/2020, p. 8.
PBS News Hour, “Amb. Khalilzad on peace negotiations and reducing violence in Afghanistan,”
9/25/2020.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, p. 2; David F. Helvey, Performing
the Duties of Assistant Secretary of Defense forIndo-Pacific Security Affairs, and Ambassador
Zalmay Khalilzad, Special Representative for
Afghanistan Reconciliation, Spoken Testimony
before the House Subcommittee on National
Security, House Oversight and Reform Committee,
9/22/2020; Statement by RS/USFOR-A Commander
General Austin Scott Miller, (@ResoluteSupport),

59.

60.
61.

62.

63.

64.

65.
66.
67.
68.

69.
70.
71.

“Violence needs to come down, and it needs to comedown so we have an opportunity for a sustainable
peace pathway,” 7/27/2020, https://twitter.com/
ResoluteSupport/status/1287770694223306752; State,“Secretary Michael R. Pompeo Remarks to TravelingPress,” 9/11/2020; DOD, Enhancing Security andStability in Afghanistan, 6/2020, p. 18.
NATO, “Press conference by NATO Secretary
General Jens Stoltenberg ahead of the meetings ofNATO Defence Ministers on 17 and 18 February at
NATO Headquarters,” 2/16/2021.
DOD, “NATO Defense Ministerial Background
Briefing,” 2/16/2021.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2018, p. 3; NATO, “Resolute Support
Mission (RSM): Key Facts and Figures,” 12/2018,
p. 2; NATO, “Resolute Support Mission (RSM): Key
Facts and Figures,” 11/2019; OUSD-P, response to
SIGAR data call, 12/20/2018.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 18; RFE/RL, “Top General
Says U.S. Troop Cut In Afghanistan Hits 8,600 Target
In Line With Taliban Deal,” 6/18/2020.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, p. 2; RFE/RL, “Top General Says
U.S. Troop Cut In Afghanistan Hits 8,600 Target In
Line With Taliban Deal,” 6/18/2020; David F. Helvey,
Performing the Duties of Assistant Secretary of
Defense for Indo-Pacific Security Affairs, Spoken
Testimony before the House Subcommittee on
National Security, House Oversight and Reform
Committee, 9/22/2020; DOD, “Statement by Acting
Defense Secretary Christopher Miller on force
Levels in Afghanistan,” 1/15/2021.
DOD, “Statement by Acting Defense Secretary
Christopher Miller on Force Levels in Afghanistan,”
1/15/2021.
NATO, “Resolute Support Mission (RSM): Key Facts
and Figures,” 2/2021 and 2/2020.
Reuters, “No decision on any NATO withdrawal fromAfghanistan, Stoltenberg says,” 2/18/2021.
OUSD-P, response to SIGAR vetting, 1/6/2021.
CSTC-A, response to SIGAR data call, 12/16/2020;
CSTC-A, response to SIGAR vetting, 10/11/2020;
DOD OIG, Operation Freedom’s Sentinel: October 1,
2020–December 31, 2020, pp. 28–30.
CSTC-A, response to SIGAR data call, 12/16/2020 and
9/22/2020.
USFOR-A, response to SIGAR vetting, 1/6/2021.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 30 and Appendix B, pp.
172–173.

67

2021 HIGH-RISK LIST

ENDNOTES
72.

73.

74.
75.

76.

77.

68

78.

SIGAR, Testimony before the Subcommittee on
National Security, Committee on Oversight andGovernment Reform, U.S. House of Representatives,“Why ANSF Numbers Matter: Inaccurate andUnreliable Data, and Limited Oversight of On-Budget
Assistance Put Millions of U.S. Taxpayer Dollars
at Risk,” 4/29/2015, p. 2; SIGAR analysis of MOFprovided AFMIS data exported 1/18/2020 and
4/14/2020; SIGAR analysis of USAID-provided AFMIS
data exported 10/18/2017 and 1/12/2019.
NATO, “NATO Allies and partners reaffirm their commitment of financial support for sustainable Afghan
security forces,” 10/19/2020.
USFOR-A, response to SIGAR vetting, 1/15/2021,
10/19/2020, and 7/19/2020.
Foreign Policy, “The U.S. Once Surged into Helmand
Province. Now the Taliban Is, Too,” 10/20/2020;
NPR, “Tens Of Thousands Flee Latest Taliban
Offensive, And Afghan Civilian Casualties Rise,”
10/13/2020; USFOR-A Spokesman COL Sonny
Leggett. (@USFOR_A), “Resolute Support Cdr.
Gen. Scott Miller visited #Helmand on Thursday toassess the security situation & meet with provincial leaders. He congrat’d Brig. Gen. Sami Sadaton his appointment as 215th Maiwand Corps CDR,
overseeing #Afghan Army operations in Helmand &#Nimroz,” 12/19/2020, https://twitter.com/USFOR_A/
status/1340234337720086536; Defense One, “Milley
Meets with Taliban in Fragile Peace Negotiations,”
12/17/2020; RS, response to SIGAR vetting,“Transcript: COMRS, CJCS, US EMB On-Record
Interview 16 December 2020,” 1/6/2021; AFP, “Scoresof Taliban fighters killed as fighting rocks insurgent
bastion,” 12/13/2020; Defense Post, “Thousands ofAfghan Families Flee Fighting in Insurgent Bastion
Kandahar,” 1/7/2021; NPR, “Tens Of Thousands
Flee Latest Taliban Offensive, And Afghan Civilian
Casualties Rise,” 10/13/2020; NPR, “People in The
Afghan Capital Kabul Are Uneasy About U.S. Troop
Drawdown,” 12/16/2020; New York Times, “‘Sticky
Bombs’ Sow Terror and Chaos in a City on Edge,”
12/16/2020; Reuters, “‘The Fear is Intense’: Afghan‘Sticky Bombs’, Used by Taliban, On the Rise,”
12/17/2020; Washington Post, “Targeted killingsof journalists are on the rise across Afghanistan,”
12/27/2020; New York Times, “Targeted Killings Are
Terrorizing Afghans. And No One Is Claiming Them,”
1/2/2021.
RS, response to SIGAR vetting, “Transcript: COMRS,CJCS, US EMB On-Record Interview 16 December
2020,” 1/6/2021.
Reuters, “Afghanistan peace talks under threat
as major Taliban spring offensive takes shape,”
2/17/2021.
RS, response to SIGAR data call, 1/6/21; SIGAR, analysis of RS-provided data, 1/2021.

79.
80.
81.

82.
83.

84.
85.
86.

87.

88.

89.

90.

91.
92.

93.

94.

95.

RS, response to SIGAR data call, 1/6/21; SIGAR, analysis of RS-provided data, 1/2021.
VOA, “Afghan Government: Over 3,500 Troops Killed
Since U.S.-Taliban Agreement,” 7/26/20.
DOD, Enhancing Security and Stability in
Afghanistan,” 6/2020, pp. 27–28; OUSD-P, response to
SIGAR vetting, 10/11/2020.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 2.
UN, report of the Secretary-General, The situationin Afghanistan and its implications for international
peace and security, 12/9/2020, p. 5.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 2.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2018, pp. 1, 9.
OUSD-P, response to SIGAR vetting, 10/11/2020;
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, p. 9.
State, Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a stateand is known as the Taliban and the United Statesof America, 2/29/2020, p. 3; FBI: Wanted by the FBI:
Husama-abd-al-Ra’uf audio transcript of broadcast
spot, 1/8/2020, fbi.gov/audio-repository/wanted-podcast-husam-al-rauf.mp3/view; WSJ, “Key Al Qaeda
Leader Killed in Afghanistan,” 10/25/2020.
United Nations Security Council, “Letter dated 19
May 2020 from the Chair of the Security Council
Committee established pursuant to regulation 1988
(2011), addressed to the President of the Security
Council,” transmitting the eleventh report of theAnalytical Support and Sanctions Monitoring Team,
6/27/2020.
DOD OIG, Audit of the Planning for and
Implementation of the Afghan Personnel and Pay
System, 8/15/2019, i.
CSTC-A, response to SIGAR vetting, 1/15/2021; DOD
OIG, Audit of the Planning for and Implementationof the Afghan Personnel and Pay System,
8/15/2019, i.
CSTC-A, response to SIGAR data call, 12/16/2020.
CSTC-A, response to SIGAR data call, 12/16/2020;
CSTC-A, response to SIGAR vetting, 10/11/2020,
10/19/2020, and 1/6/2021.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, pp. 33–34; OUSD-P, response to
SIGAR vetting, 10/18/2020.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2020, pp. 33–34; OUSD-P, response
to SIGAR vetting, 10/18/2020; CSTC-A, response to
SIGAR data call, 12/16/2020.
CSTC-A, response to SIGAR data call, 9/22/2020 and
response to SIGAR vetting, 10/19/2020; OUSD-P,
response to SIGAR vetting, 1/6/2021.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES
96.

97.

98.

99.

100.

101.

102.

103.

RS, response to SIGAR data call, 1/6/2021; VOA,
“Afghan Government: Over 3,500 Troops Killed Since
U.S.-Taliban Agreement,” 7/26/2020; see Afghan
Ministry of Defense press releases from the last
two years. Examples include: Afghan Ministry of
Defense, “80 Taliban were killed during the 24 past
hours!” 2/15/2021; DOD, Enhancing Security andStability in Afghanistan, 12/2019, p. 15.
DOD OIG, Operation Freedom’s Sentinel: October
1, 2020–December 31, 2020, pp. 28–30; State,
Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica, 2/29/2020, p. 1.
OUSD-P, response to SIGAR vetting, 10/18/2020;
DOD OIG, Operation Freedom’s Sentinel: April 1,
2020–June 30, 2020, pp. 23–24.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2018, pp. 64–65, 94–95; CSTC-A,
response to SIGAR vetting, 10/19/2020; CSTC-A,
response to SIGAR data call, 1/5/2021.
UNODC and USIP, “Criminal justice reform in
post-conflict states: A guide for practitioners,”
United Nations, 11/2011.
DOD, Enhancing Security and Stability in
Afghanistan, 6/2019, p. 78; DOD, Enhancing Security
and Stability in Afghanistan, 12/2019, p. 2; Marty
Skovlund Jr., “This Elite Police Fore is Afghanistan’s
Secret Weapon Against Violent Extremists,” Task
and Purpose, 11/15/2007; DOD, Report on Progress
Toward Security and Stability in Afghanistan,
11/2013, p. 65.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2017, p. 96; DOD, Enhancing
Security and Stability in Afghanistan, 12/2015, p. 76;
DOJ, “Statement of Thomas M. Harrigan, Assistant
Administrator and Chief of Operations, Drug
Enforcement Agency,” United States Senate’s Caucus
on International Narcotics Control, 7/20/2011, p. 4;
DOJ, “Drug Enforcement and the Opioid Crisis:+ $290.5 Million in Program Enhancements andTransfers;” FY 2020 Budget Request, p. 2; DOJ,
“Statement of Thomas M. Harrigan, Assistant
Administrator and Chief of Operations, Drug
Enforcement Agency,” United States Senate’s Caucus
on International Narcotics Control, 7/20/2011, p. 3.
DOD, Enhancing Security and Stability in
Afghanistan, 12/2017, p. 96; DOD, Enhancing
Security and Stability in Afghanistan, 12/ 2015, p. 76;
DOJ, “Statement of Thomas M. Harrigan, Assistant
Administrator and Chief of Operations, Drug
Enforcement Agency,” United States Senate’s Caucus
on International Narcotics Control, 7/20/2011, p. 4;
DOJ, “Drug Enforcement and the Opioid Crisis:+ $290.5 Million in Program Enhancements and

104.

105.

106.
107.
108.
109.

110.
111.
112.

113.

114.

115.

116.
117.

Transfers;” FY 2020 Budget Request, p. 2; DOJ,
“Statement of Thomas M. Harrigan, Assistant
Administrator and Chief of Operations, Drug
Enforcement Agency,” United States Senate’s Caucus
on International Narcotics Control, 7/20/2011, p. 3.
New York Times, “They Fight Suicide Bombers.
But Can Afghan Police Fight Crime?” 2/8/2020;
Afghanistan Analysts Network, “Kabul’s Expanding
Crime Scene (Part 2): Criminal activities and thepolice response,” 2/21/2020; German Federal Foreign
Office, “Supporting the training and literacy of the
Afghan National Police Force,” n.d.; TOLOnews,“60,000 Afghan Police Are Illiterate,” 4/22/2016;
Asia Foundation, “A Survey of the Afghan People:
Afghanistan in 2016,” 2016, p. 109.
New York Times, “They Fight Suicide Bombers. But
Can Afghan Police Fight Crime?,” 2/8/2020; Foschini,“Kabul’s Expanding Crime Scene (Part 2): Criminal
activities and the police response,” Afghanistan
Analysts Network, 2/21/2020.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, v.
“Afghanistan Partnership Framework,” 11/24/2020,
p. 5.
“Afghanistan Partnership Framework,” 11/24/2020,
p. 6.
“Key elements for sustained international support toPeace and Development in Afghanistan,” 11/17/2020,
p. 1.
State, Integrated Country Strategy: Afghanistan,
11/15/2020, p. 2.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2019, p. 115.
SIGAR, “Prepared Remarks of John F. Sopko Special
Inspector General for Afghanistan Reconstruction
Carnegie Endowment for International Peace,”
12/10/2014.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 4.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 4.
UN, Strong Support for Afghanistan at the 2020
Afghanistan Conference, 11/24/2020; “Geneva
Conference on Afghanistan: Joint Communiqué,”
11/28/2018, p. 5; “Communiqué 2020 Afghanistan
Conference,” 11/24/2020, p. 1.
State, “Remarks at 2020 Afghanistan Conference,”
11/24/2020.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintain69

2021 HIGH-RISK LIST

ENDNOTES
118.

119.
120.

121.

122.

123.
124.
125.
126.
127.
128.

129.

130.
131.
132.
133.
134.
135.

70

136.

a stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 11.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 11.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2019, p. 105.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 7.
Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, pp. 8, 16.
John F. Sopko, “U.S. Reconstruction Efforts in
Afghanistan: Key High-Risk Areas to Persist into
Future,” testimony before the Senate Subcommittee
on Department of State, Foreign Operations, andRelated Programs, Committee on Appropriations,
SIGAR 19-32-TY, 4/9/2019.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 110.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 110.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 110.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2019, p. 105.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 110.
“Key elements for sustained international support toPeace and Development in Afghanistan,” 11/17/2020,
p. 1.
“Key elements for sustained international support toPeace and Development in Afghanistan,” 11/17/2020,
p. 1.
“Afghanistan Partnership Framework,” 11/24/2020,
pp. 2–5.
SIGAR, Quarterly Report to the United States
Congress, 7/30/2019, p. 122.
SIGAR, Quarterly Report to the United States
Congress, 7/30/2019, p. 122.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 110.
SIGAR, Quarterly Report to the United States
Congress, 4/30/2020, p. 104.
ODI, “Governance, violence, and aid: the donor–
Taliban dilemma,” 12/11/2020.
ODI, “Governance, violence, and aid: the donor–
Taliban dilemma,” 12/11/2020.

137. State, Integrated Country Strategy: Afghanistan,
2/2021, p. 2.
138. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 105.
139. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 105.
140. TOLOnews, “Saleh Blames Released Taliban for
Violence, No More ‘Blind Trust’, 2/11/2021.
141. United Nations Security Council, Letter Dated 19
May 2020 from the Chair of the Security Council
Committee Established Pursuant to Resolution 1988
(2011) Addressed to the President of the Security
Council, S/2020/415, 5/27/2020, p. 11.
142. UNDP, “Practice Note: Disarmament, Demobilization
and Reintegration of Ex-combatants,” 2011, p. 11;
UN, Operational Guide to the Integrated
Disarmament, Demobilization and Reintegration
Standards (IDDRS), 2014, pp. 24–25.
143. UN, Operational Guide to the Integrated
Disarmament, Demobilization and Reintegration
Standards (IDDRS), 2014, pp. 24–25.
144. UN, Operational Guide to the Integrated
Disarmament, Demobilization and Reintegration
Standards (IDDRS), 2014, p. 24; Jeremy Weinsteinand Macartan Humphreys, “Disentangling theDeterminants of Successful Demobilization andReintegration,” Working Paper Number 69, Center
for Global Development, September 2005, p. 3; UN,
Operational Guide to the Integrated Disarmament,
Demobilization and Reintegration Standards(IDDRS), 2014, pp. 24–25.
145. UK Foreign & Commonwealth Office, “Reintegration
and Reconciliation in Conflict: Experience andLessons,” July 2016, p. 2.
146. UN, Operational Guide to the Integrated
Disarmament, Demobilization and Reintegration
Standards (IDDRS), 2014, pp. 33–34.
147. UN, The Integrated Disarmament, Demobilization,
and Reintegration Standards (IDDRS): Module 4.30
Reintegration, 2006, pp. 11–30, 56.
148. SIGAR, Reintegration of Ex-Combatants: Lessons
from the U.S. Experience in Afghanistan, SIGAR
19-58-LL, 9/2019, i.
149. SIGAR, Reintegration of Ex-Combatants: Lessons
from the U.S. Experience in Afghanistan, SIGAR
19-58-LL, 9/2019, i.
150. State, response to SIGAR data call, 6/23/2019,9/19/2019, 12/23/2019, 6/18/2020, and 9/22/2020.
151. SIGAR, Reintegration of Ex-Combatants: Lessons
from the U.S. Experience in Afghanistan, SIGAR
19-58-LL, 9/2019, i.
152. World Bank, Financing Peace: Fiscal Challenges
and Implications for a Post-Settlement Afghanistan,
12/1/2019, ii.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES
153. U.S. Senate, Department of State, Foreign
Operations, and Related Programs Appropriations
Bill, Report 116-126, 9/26/2019, p. 32.
154. John F. Sopko, “The State of Corruption in
Afghanistan and the Role of Independent
Institutions” (remarks presented at an Integrity
Watch Afghanistan webinar), 6/24/2020.
155. SIGAR, Quarterly Report to the United States
Congress, 1/30/2020, iv.
156. SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 1.
157. SIGAR, Corruption in Conflict: Lessons from the
U.S. Experience in Afghanistan, 9/2016; SIGAR,
Afghanistan’s Anti-Corruption Efforts Alert Letter,
SIGAR 21-09-AL, 11/6/2020, p. 1.
158. UNAMA, “Communiqué 2020 Afghanistan
Conference,” 11/24/2020, p. 1; “Afghanistan
Partnership Framework,” 11/24/2020, pp. 2–4.
159. State, “Remarks at 2020 Afghanistan Conference,”
11/24/2020.
160. Ross Wilson, remarks delivered to the Afghanistan
2020 Conference Side Event on Institutionaland Societal Methods for Fighting Corruption,
11/23/2020.
161. Deborah Lyons, remarks delivered by Ramiz
Alakbarov on behalf of Deborah Lyons to theAfghanistan 2020 Conference Side Event on
Institutional and Societal Methods for Fighting
Corruption, 11/23/2020.
162. In 2019, the Asia Foundation reported that 67.9% of
those surveyed said corruption was a major problem in their daily life and 85.1% of those survey said
corruption was a major problem in Afghanistan
as a whole. Due to COVID-19 pandemic, the Asia
Foundation was unable to conduct its annual in-person Survey of the Afghan People in 2020. Instead,in 2020, the Asia Foundation gathered the views ofover 4,300 Afghans aged 18+ by telephonic interview using random digit dialing. Asia Foundation,
Afghanistan Flash Surveys on Perceptions of Peace,
Covid-19, and the Economy: Wave 1 Findings,
11/23/2020, ii, pp. 70–71; Asia Foundation, A
Survey of the Afghan People: Afghanistan in 2019,
pp. 142–143.
163. SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, pp. 1–2.
164. SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 2; SIGAR,
Quarterly Report to the United States Congress,
1/30/2021, p. 90.
165. SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 2.
166. SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 2.
167. John F. Sopko, “The State of Corruption in
Afghanistan and the Role of Independent

168.
169.
170.
171.
172.
173.
174.
175.
176.
177.
178.
179.
180.
181.
182.

183.
184.
185.
186.
187.
188.
189.
190.

191.

192.

Institutions” (remarks presented at an Integrity
Watch Afghanistan webinar, 6/24/2020).
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, pp. 1–2.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, iv.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 90.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 89.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 89.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, pp. 2–3.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, pp. 2–3.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 3.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 3.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 3.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 3.
DOJ, response to SIGAR data call, 12/29/2020.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 127.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 127.
Fria Tider (Free Times, Sweden), “Afghan election:
One major winner under investigation for benefit
fraud in Sweden,” 12/22/2019.
SIGAR, Afghanistan’s Anti-Corruption Efforts Alert
Letter, SIGAR 21-09-AL, 11/6/2020, p. 3.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 114–115.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 115.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 115.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 115.
State, Integrated Country Strategy: Afghanistan,
11/15/2020, pp. 3, 7.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 25.
State, SCA, response to SIGAR data call, 9/18/2019;
SIGAR, Quarterly Report to United States Congress,
7/30/2020, p. 135; SIGAR, Quarterly Report to UnitedStates Congress, 10/30/2020, p. 167.
IMF, Staff Report for the 2019 Article IV
Consultation and the Sixth Review under the
Extended Credit Facility Arrangement, 12/4/2019,
pp. 1, 7.
Asian Development Bank, “Afghanistan and ADB,”
9/2020.

71

2021 HIGH-RISK LIST

ENDNOTES

72

193. SIGAR, Quarterly Report to the United States
Congress, 7/30/2020, pp. 134, 139.
194. United Nations Development Programme,“Afghanistan: Coronavirus Socio-Economic Impact
Assessment,” 7/22/2020, pp. 1, 12.
195. UN OCHA, Humanitarian Response Plan,
Afghanistan, 2018–2021, 1/2021, p. 5.
196. SIGAR, Quarterly Report to the United States
Congress, p. 119.
197. SIGAR, Quarterly Report to the United States
Congress, 10/30/2019, p. 138; SIGAR, Quarterly
Report to the United States Congress, 4/30/2020,
p. 135.
198. Tobias Haque and Nigel Roberts, Afghanistan’s Aid
Requirements: How much aid is required to maintaina stable state? Expert note hosted by the Overseas
Development Institute (UK) Lessons for Peace project, 10/2020, p. 1.
199. Eastern Mediterranean Health Journal, Najibullah
Safi, Ahmad Naeem, Merette Khalil, Palwasha
Anwari, and Gulin Gedik, “Addressing health workforce shortages and maldistribution in Afghanistan,”Vol. 24, No. 9, 12/8/2018, p. 951.
200. SIGAR, Health Facilities in Afghanistan:Observations From Site Visits At 269 Clinics andHospitals, SIGAR 20-28-SP, 3/2020, p. 10.
201. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 146–149.
202. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 146–149.
203. Global Polio Eradication Initiative, “Afghanistan:
Polio this week in Afghanistan,” 1/14/2021; NPR,
Jason Beaubien, “The Campaign To Wipe Out Polio
Was Going Really Well...Until It Wasn’t,” 10/30/2020;
UNICEF, Polio Eradication, 2/2021.
204. NPR, Jason Beaubien, “The Campaign To Wipe
Out Polio Was Going Really Well…Until It Wasn’t,”
10/30/2020; SIGAR, Quarterly Report to the UnitedStates Congress, 1/30/2020, p. 147.
205. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 148–149.
206. UNAMA, Afghanistan Protection of Civiliansin Armed Conflict Special Report: Attacks on
Healthcare During the COVID-19 Pandemic,
6/20/2020, p. 3.
207. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 174–175.
208. SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 146.
209. Global Partnership for Education, Jordan P. Naidoo
and Abdul Wassay Arian, “Afghanistan’s COVID19 Education Response,” 6/23/2020; World VisionInternational, “50% of families in Afghanistan forced
to send their children to work during COVID-19 pandemic,” 11/20/2020.

210. Al Jazeera English, “Up to 60 percent of Afghan girls
out of school: report,” 6/3/2018; SIGAR, Quarterly
Report to the United States Congress, 7/30/2020,
p. 151; SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 173-174.
211. SIGAR, Quarterly Report to the United States
Congress, 7/30/2020, p. 149.
212. SIGAR, Observations of Site Visits at 171 Afghan
Schools Funded by USAID, SIGAR 20-03-SP, 10/2019,p. 12.
213. SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 117.
214. ODI, Tobias Haque and Nigel Roberts, Afghanistan’s
Aid Requirements: How much aid is required tomaintain a stable state?, 10/2020, p. 8.
215. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, pp. 150–151.
216. SIGAR, Private Sector Development and Economic
Growth: Lessons from the U.S. Experiencein Afghanistan, SIGAR 18-38-LL, 4/2018, ix;“TOLOnews, “Zarmina Mohammadi, “Lack of Skilled
Labor A Drawback For Investors,” 4/28/2017.
217. Arab News, Naimat Khan, “Afghan refugees hopepeace talks will finally take them ‘home,’” 9/15/2020;
UNHCR, “Refugees in Iran,” Accessed 12/2/2020;
USAID, Country Development Cooperation Strategy
FY2019-2023, 11/27/2018, p. 13.
218. SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 172.
219. SIGAR, Counternarcotics: Lessons from the U.S.
Experience in Afghanistan, 2018, p. 3.
220. UNODC, “World Drug Report 2020, booklet 1,”
6/2020, p. 40; SIGAR analysis of UNODC data,
6/2020.
221. UNODC, Afghanistan Opium Survey 2019: Socioeconomic survey report, 2/2021, p. 5.
222. UNODC, “World Drug Report 2020, booklet 3”
6/2020, p. 17.
223. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 129.
224. UNODC, Afghanistan Opium Survey 2018:
Cultivation and Production, 11/2018, pp. 5–6, 14,
16–17; State, INL, response to SIGAR vetting,
1/15/2019.
225. SIGAR analysis; UNODC, Afghanistan Opium Survey
2018: Cultivation and Production, 11/2018, pp. 61–68;
USFOR-A, response to SIGAR data call, 12/19/2018.
226. UNODC, World Drug Report 2020, 6/2020, p. 24.
227. State, INL, response to SIGAR data call, 6/17/2020
and 9/17/2020; State, INL, response to SIGAR vetting,
10/13/2020.
228. SIGAR, Quarterly Report to the United States
Congress, 10/30/2020, p. 132; SIGAR, U.S.
Counternarcotics Strategy in Afghanistan,
SIGAR 20-18-AL, 1/10/2020.

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES
229. White House, “Remarks by President Trump on theStrategy in Afghanistan and South Asia,” 8/21/2017.
230. SIGAR, Drug Treatment in Afghanistan: The Overall
Impact and Sustainability of More than $50 Million
in Department of State Projects is Unknown,
SIGAR 19-49-AR, 7/2019; SIGAR, Afghanistan’s
Justice Sector Case Management System: Seized or
Forfeited Assets Were Not Tracked and Nationwide
Implementation is Not Complete, SIGAR 20-20-SP,
1/2020; SIGAR, Department of State’s Efforts to
Develop and Sustain Afghanistan’s Drug Treatment
System: Audit of Costs Incurred by the Colombo
Plan for Cooperative Economics and Social
Development in Asia and the Pacific Results in Morethan $23 Million in Questioned Costs, SIGAR 20-54FA, 9/2020.
231. State Department, “U.S. Reinforces Commitment
to Secure, Stable, Democratic, and Self-Reliant
Afghanistan at 2020 Conference,” 11/24/2020; SIGAR,
Quarterly Report to the United States Congress,
1/30/2021, iv.
232. MOF, “Afghanistan National Peace and Development
Framework (ANPDF II) 2021-2025,” n.d., pp. 40–41.
233. State, INL, response to SIGAR data call, 6/20/2019.
State, INL, response to SIGAR vetting, 4/12/2019;
GIROA, Presidential Decree Number 139, 1/14/2019.
234. SIGAR, Counternarcotics: Lessons from the U.S.
Experience in Afghanistan, SIGAR 18-52-LL, 6/2018,p. 178; State, INL, response to SIGAR vetting, 1/2020.
235. State, INL, response to SIGAR vetting, 1/10/2020;
State, INL, response to SIGAR vetting, 1/15/2019.
236. State, INL, response to SIGAR vetting, 1/6/2021.
237. State, INL, response to SIGAR data call, 9/21/2020;
State, INL, response to SIGAR data call, 6/17/2020;
UNODC, “Afghanistan Opium Survey 2018:
Challenges to sustainable development, peace andsecurity,” 7/2019, p. 2; UNODC, Afghanistan Opium
Survey 2019: Socioeconomic survey report, 2/2021.
238. State, INL, response to SIGAR data call, 6/17/2020;
State, INL, response to SIGAR vetting, 7/7/2020.
239. State, INL, response to SIGAR data call, 6/17/2020.
240. State, INL, response to SIGAR data call, 6/17/2020.
241. State, INL, response to SIGAR data call, 12/16/2020.
242. State, INL, Governor Led Eradication Amended
Implementing Instructions for the Letter ofAgreement on Police, Criminal Justice, andCounternarcotics Support Programs of March 9,
2006, between the Government of the United Statesof America and the Islamic Republic of Afghanistan,
4/23/2014; GAO, Afghanistan Drug Control: Despite
Improved Efforts, Deteriorating Security Threatens
Success of U.S. Goals, GAO 07-78, 11/2006, pp. 16,19.
243. State, INL, response to SIGAR vetting, 1/2020 and
10/2020.
244. State, INL, response to SIGAR vetting, 10/9/2020.

245. SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, p. ix.
246. Due to potential inflation of student enrollment
data, 3.5 million is likely a high estimate, but is thebest available; SIGAR, Support for Gender Equality:
Lessons from the U.S. Experience in Afghanistan,
SIGAR 21-18-LL, 2/2021, i, ix, pp. 65, 77.
247. Government of Afghanistan, The Constitution of
Afghanistan, 1/26/2004.
248. Inter-Parliamentary Union website, Afghanistan,
https://data.ipu.org/node/1/basic-information?chamber_id=13574, accessed 11/28/2020.
249. EMIS data from 2018 has the total numberof teachers at 75,000 (EMIS, “Teachers &Enrollment—1396–1387,” dataset, Tab 1, accessed
2/1/2020); Government of Afghanistan, National
Statistics and Information Authority, “Afghanistan
Statistical Yearbook: 2018–2019,” Issue No. 40,
7/2019, p. 55; Belquis Ahmadi, Afghanistan Talks: No
Women, No Peace, United States Institute of Peace,
3/1/2019.
250. WHO, UNICEF, UNFPA, World Bank Group, andthe United Nations Population Division, Trends inMaternal Mortality, 2019, p. 71; Sarah Bibler andNaila Rafique, Violence against Women in Electionsin Afghanistan: An IFES Assessment, International
Foundation for Electoral Systems (IFES), 4/2019,p. 18; United States Agency for International
Development, A Guide to Gender Practice inAfghanistan: 2010–2014, 2014, xlix, p. 1; SIGAR,
Support for Gender Equality: Lessons from the U.S.
Experience in Afghanistan, SIGAR 21-18-LL, 2/2021,
pp. 54, 66.
251. UN Development Programme, Human Development
Report 2019: Beyond income, beyond averages,
beyond today: Inequalities in human development in
the 21st century, 2019, p. 318.
252. New York Times, Sirajuddin Haqqani, “What We, theTaliban, Want,” 2/20/2020.
253. “Ensuring an Inclusive Afghan Peace Process,”panel discussion hosted by Georgetown University
Institute for Women, Peace and Security, 7/11/2019,
electronic p. 3.
254. UNAMA, Afghanistan, Protection of Civiliansin Armed Conflict, Annual Report 2017, 2/2018,
pp. 9–10; SIGAR, Quarterly Report to the UnitedStates Congress, 10/31/2016, pp. 4, 10.
255. UNAMA, Afghanistan: Protection of Civilians in
Armed Conflict 2009, p. 4; UNAMA, Afghanistan:Protection of Civilians in Armed Conflict 2019,
pp. 19–20; UNAMA, Afghanistan: Protection of
Civilians in Armed Conflict 2014, pp. 15–16; Human
Rights Watch, Disability Is Not a Weakness, 4/2020,
p. 3.

73

2021 HIGH-RISK LIST

ENDNOTES

74

256. DOD, “Acting Secretary Miller Announces
Troop Levels in Afghanistan and Iraq,” transcript, 11/17/2020. defense.gov/Newsroom/
Transcripts/Transcript/Article/2418641/
acting-secretary-miller-announces-troop-levels-in
257. John R. Allen and Vanda Felbab-Brown, “The fateof women’s rights in Afghanistan,” The Brookings
Institution, 19A The Brookings Gender Equality
Series, 9/2020.
258. SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021.
259. Alison Farnham, Olena Kuzyakiv, Skills-Gap Training
for Midwives in Rural Afghanistan: An Evaluation,
Harvard Center of Excellence in Maternal Health,8/19/2019; World Bank, How has Afghanistanachieved better health for its citizens?, 4/5/2018, p. 5.
260. USAID, Fact Sheet: Improved Health for Afghan
Mothers and Children, 5/2015, electronic p. 2; World
Health Organization, Global Health Observatory
Data Repository: Births attended by skilled healthpersonnel, n.d.
261. USAID, Fact Sheet: Improved Health for Afghan
Mothers and Children, 5/2015; World HealthOrganization, Addressing health workforce shortages and maldistribution in Afghanistan, 2018,
p. 955.
262. The difficulty of obtaining data means estimatesof the degree of the decline are not highly reliable;
SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, pp. 51–52.
263. 70,000 reflects the Afghan Ministry of Education’s
2018 estimate of between 66,000 and 75,000 womenin teaching jobs. Education Ministry Information
System, “Teachers & Enrollment—1396–1387,”
dataset, Tab 1, accessed 2/1/2020; Government of
Afghanistan, National Statistics and Information
Authority, “Afghanistan Statistical Yearbook: 2018–2019,” Issue No. 40, 7/2019, p. 55.
264. Government of Afghanistan, Central Statistics
Organization, Afghanistan Living Conditions Survey:
2016–2017, 2017, p. 165.
265. Government of Afghanistan, The Constitution of
Afghanistan, 1/26/2004; Afghanistan Research and
Evaluation Unit, Women’s Rights, Gender Equality,
and Transition: Securing gains, moving forward,
9/2013, p. 10; SIGAR analysis.
266. Government of Afghanistan, Citizens’ Charter
National Priority Program, 12/2016, electronic
p. 3; Government of Afghanistan, Citizens’ Charter
Quarterly Progress (Fourth Quarter; Reflecting
Annual Standing), 1/2019, p. 2; SIGAR analysis.
267. The number of women serving in the Afghan
National Police rose from 180 in 2005 to 3,650 in
2019. Just 5% of Afghan judges in 2007 were women,

268.

269.

270.

271.

272.

273.

274.

275.

but by 2018, the proportion had risen to 13%.
Women’s share of secure jobs in urban areas rosefrom 27% in 2007 to 42% a decade later. Their shareof civil service jobs (excluding the Afghan army andpolice) increased from 18% in 2007 to 25% in 2019;
SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, pp. 102–103, 114–115.
Government of Afghanistan, Ministry of Education,
Education for all 2015 National Review Report:
Afghanistan, 5/2015, pp. 26, 28–29, 83.
Isobel Coleman, Gayle Tzemach Lemmon, Maternal
Health in Afghanistan: Improving Health andStrengthening Society, Council on Foreign Relations,9/2011, p. 3; Denise Byrd, Myra Betron, Integrating
Gender from Start to Finish, Inside and Outside:
Lessons from Afghanistan’s Health Services Support
Project, Jhpiego, 2015, pp. 2, 7.
Ministry of Education, Government of Afghanistan,
United Nations Children’s Fund, and Samuel Hall, All
in School and Learning: Global Initiative on Out-OfSchool Children–Afghanistan Country Study, 2018,
pp. 20–21.
SIGAR, Support for Gender Equality, Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, i, pp. 77, 155.
SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, pp. 35, 47, 149.
The audit found that DOD could not provide needs
assessments for 27 of the 29 projects examined, nordocumentation of project funding approvals for anyof the 29 projects. Without these documents, SIGAR
could not determine the need for these particular
projects. Further, the Combined Security Transition
Command-Afghanistan (CSTC-A) told SIGAR thatit measured success based on project completion,rather than whether the facility was being used
for its intended purpose. After the initiation of theaudit, CSTC-A began an internal review and plans torevise how it measures success and the use of thesefacilities to support women in the ANDSF. SIGAR,
Facilities to Support Women in the Afghan Security
Forces: Better Planning and Program Oversight
Could Have Helped DOD Ensure Funds Contributed
to Recruitment, Retention, and Integration, SIGAR
Audit 21-04-AR, 10/2020, electronic pp. 2–3.
SIGAR, Facilities to Support Women in the Afghan
Security Forces: Better Planning and Program
Oversight Could Have Helped DOD Ensure Funds
Contributed to Recruitment, Retention, andIntegration, SIGAR Audit 21-04-AR, 10/2020, electronic p. 3.
Ben Acheson, independent consultant and former
director of the Office of NATO’s Senior Civilian

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES
276.

277.
278.
279.
280.

281.

282.

283.

284.
285.
286.

Representative, correspondence with SIGAR,
10/6/2020.
SIGAR, Support for Gender Equality: Lessons fromthe U.S. Experience in Afghanistan, SIGAR 21-18-LL,
2/2021, pp. 33, 79–80.
Pajhwok Afghan News, “Biographies of intra-Afghan
peace talk negotiators,” 9/10/2020.
New York Times, “Targeted Killings Are Terrorizing
Afghans. And No One Is Claiming Them,” 1/2/2021.
BBC, “Afghanistan conflict: Female judges shot deadin Kabul,” 1/17/2021.
Human Rights Watch, You Have No Right toComplain: Education, Social Restrictions and Justicein Taliban-Held Afghanistan, 6/30/2020, p. 5.
Human Rights Watch, You Have No Right toComplain: Education, Social Restrictions and Justicein Taliban-Held Afghanistan, 6/30/2020, pp. 5–6.
UNAMA reports from 2007 to 2016 do not always
specifically attribute human rights abuses of women
specifically to the Taliban, or give specific numbersof such incidents; in 2013, there were simply too
many to count. But the reports make it clear that“anti-government elements” have routinely targeted
women, either for alleged violations of Sharia law,
for working in “male” occupations such as theAfghan National Police, or for being a women’s
rights activist. SIGAR analysis of “Reports on theProtection of Civilians in Armed Conflict,” UNAMA,
2007–2019.
Mehdi Hakimi, executive director of the Rule of Law
Program and lecturer at Stanford University, SIGAR
interview, 5/22/2020.
SIGAR, Quarterly Report to the United States
Congress, 7/30/2020, p. 128.
Malika Qanih, owner of Afghan pharmaceutical company Sun Pharma, SIGAR interview, 7/13/2020.
Female participant of a USAID-funded program,
Nangarhar Province, SIGAR-commissioned interview, 8/12/2020; male relative of a female participantof a USAID-funded program, Farah Province,
SIGAR-commissioned interview, 8/12/2020; female
participant of a USAID-funded program, Balkh
Province, SIGAR-commissioned interview, 8/13/2020;
male member of a community development council, Kandahar Province, SIGAR-commissioned
interview, 9/1/2020; female participant of a
USAID-funded program, Nangarhar Province,
SIGAR-commissioned interview, 8/12/2020; female
participant of a USAID-funded program, Bamyan
Province, SIGAR-commissioned interview, 8/12/2020;
female participant of a USAID-funded program,
Bamyan Province, SIGAR-commissioned interview,
8/12/2020; male relative of a female participantof a USAID-funded program, Helmand Province,
SIGAR-commissioned interview, 8/25/2020; female
participant of a USAID-funded program, Kunar

287.

288.

289.
290.
291.

292.

293.
294.

295.
296.

Province, SIGAR-commissioned interview, 8/13/2020;
female participant of a USAID-funded program,
Kunar Province, SIGAR commissioned interview,
8/13/2020; female participant of a USAID-funded
program, Kandahar Province, SIGAR commissioned
interview, 8/16/2020.
SIGAR, Prepared Remarks of John F. Sopko, Special
Inspector General for Afghanistan Reconstruction,“18 Years of Reconstruction: Lessons from the U.S.
Experience in Afghanistan,” Maxwell School of
Citizenship and Public Affairs, Syracuse University,
Syracuse, NY, 3/10/2020, pp. 2, 12.
SIGAR, Update on the Amount of Waste, Fraud, andAbuse Uncovered through SIGAR’s Oversight Workbetween January 1, 2018, and December 31, 2019,
SIGAR 21-05-SP, 10/2020, ii, pp. 1–2.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 3.
SIGAR, High-Risk List, 1/2017, p. 3; SIGAR, HighRisk List, 1/2017, pp. 3, 16.
SIGAR, Challenges to Effective Oversight of
Afghanistan Reconstruction Grow as High-Risk
Areas Persist, Statement of John F. Sopko for the
Senate Committee on Appropriations, Subcommittee
on the Departments of State, Foreign Operations,and Related Programs, 2/24/2016, p. 14; SIGAR,
Quarterly Report to the United States Congress,
1/30/2021, pp. 54, 57, 121, 131, 133; State, Integrated
Country Strategy: Afghanistan, 11/15/2020, p. 3; VOA
News, “Russian Envoy Visits Pakistan as Part ofEffort to Jumpstart Stalled Afghan Peace Process,”
2/19/2021.
John F. Sopko, “U.S. Lessons Learned in
Afghanistan,” Testimony Before the House
Committee on Foreign Affairs, SIGAR 20-19-TY,
1/15/2020, p. 19.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 29.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, pp. 124–125; SIGAR analysis
of IMF, Request for a 42-Month Arrangement Under
the Extended Credit Facility—Press Release; Staff
Report; and Statement by the Executive Director for
the Islamic Republic of Afghanistan, IMF Country
Report No. 20/300, 11/2020, pp. 4, 26.
SIGAR, Quarterly Report to the United States
Congress, 1/30/2017, p. 3.
World Bank, “Post-Settlement Economic Initiatives,”
03/26/2019, i; Tobias Haque and Nigel Roberts,“Afghanistan’s Aid Requirements: How much aid isrequired to maintain a stable state?” Expert note
hosted by the Overseas Development Institute (UK)Lessons for Peace Project, 10/2020, p. 10, https://l4p.odi.org/assets/images/ODI-L4P-Afghanistan-aidrequirements-Haque-and-Roberts-2020.pdf.

752021 HIGH-RISK LIST

ENDNOTES

76

297. Ministry of Foreign Affairs of Finland, “Strong
Support for Afghanistan at the 2020 Afghanistan
Conference,” Press Release, 11/24/2020.
298. State, “Remarks at the 2020 Afghanistan
Conference,” 11/24/2020, pp. 2–3.
299. SIGAR, Update on the Amount of Waste, Fraud, andAbuse Uncovered through SIGAR’s Oversight Workbetween January 1, 2018 and December 31, 2019,
SIGAR 21-05-SP, 10/2020, pp. 2, 6.
300. John F. Sopko, “U.S. Lessons Learned in
Afghanistan,” Testimony Before the House
Committee on Foreign Affairs, SIGAR 20-19-TY,
1/15/2020, p. 19.
301. SIGAR, Update on the Amount of Waste, Fraud, andAbuse Uncovered through SIGAR’s Oversight Workbetween January 1, 2018 and December 31, 2019,
SIGAR 21-05-SP, 10/2020, pp. 2, 6.
302. SIGAR, Prepared Remarks of John F. Sopko, Special
Inspector General for Afghanistan Reconstruction,“Remarks on the 2019 SIGAR High-Risk List,” Center
for Strategic and International Studies, Washington
DC, 3/28/2019, p. 5.
303. SIGAR, Quarterly Report to the United States
Congress, 1/30/2017, p. 6.
304. SIGAR, Quarterly Report to the United States
Congress, 1/30/2017, p. 6.
305. U.S. on-budget funding for security has declinedin the last two years, but has remained relatively
steady at approximately one-fifth to one-quarterof security assistance appropriations, with somevariation, since FY 2015. As U.S. appropriations forgovernance and development accounts have fallen
since FY 2017, on the other hand, on-budget funding for civilian assistance programs has grown toexceed 50% of these appropriations. SIGAR analysis.
306. SIGAR, Quarterly Report to the United States
Congress, 1/30/2021, p. 27.
307. SIGAR, Testimony Before the Homeland Security
and Governmental Affairs Committee (HSGAC)
Subcommittee on Federal Spending Oversightand Emergency Management (FSO), U.S. Senate,
Oversight of U.S. Spending in Afghanistan,Statement of John F. Sopko, 5/9/2018, p. 6.
308. SIGAR, Quarterly Report to the United States
Congress, 1/30/2017, pp. 3–5.
309. SIGAR, Update on the Amount of Waste, Fraud, andAbuse Uncovered through SIGAR’s Oversight Workbetween January 1, 2018 and December 31, 2019,
SIGAR 21-05-SP, 10/2020, p. 9.
310. SIGAR, USAID’s Power Transmission Expansion
and Connectivity Project: The Project is Behind
Schedule, and Questions Remain about the Afghan
Government’s Ability to Use and Maintain the New
Power Infrastructure, SIGAR 19-57-AR, 9/2019, i.
311. SIGAR, Afghanistan’s Anti-Corruption Efforts,
SIGAR 21-09-AL, 11/6/2020, p. 6.

312. John F. Sopko, “Risks to Sustainable Peacein Afghanistan,” Testimony Before the House
Committee on Oversight and Reform, Subcommittee
on National Security, SIGAR 20-24-TY, 1/28/2020,
p. 22.
313. SIGAR, Afghanistan’s Energy Sector: USAID and
DOD Did Not Consistently Collect and Report
Performance Data on Projects Related to Kajaki
Dam and Concerns Exist Regarding Sustainability,
SIGAR 19-37-AR, 5/2019, pp. 1, 8–11.
314. SIGAR, Afghanistan’s North East Power System
Phase I: Construction Deficiencies, Contractor
Noncompliance, and Poor Oversight Resulted in a
System that May Not Operate Safely or At Planned
Levels, SIGAR 19-50-IP, 8/2019, pp. 7, 12; SIGAR,
Afghan National Police Women’s Compound at the
Jalalabad Regional Training Center: Construction
Generally Met Contract Requirements, but FireRelated Deficiencies Pose Safety Hazards and theAlmost $6.7 Million Facility Has Never Been Used,
SIGAR 19-48-IP, 7/2019, pp. 2–4; SIGAR, Improvised
Explosive Devices: Unclear Whether Culvert Denial
Systems to Protect Troops Are Functioning or Were
Ever Installed, SIGAR SP-13-8, 7/2013, p. 1.
315. SIGAR, Health Facilities in Afghanistan:Observations from Site Visits at 269 Clinics andHospitals, SIGAR 20-28-SP, 3/2020, p. 6.
316. SIGAR, Prepared Remarks of John F. Sopko, Special
Inspector General for Afghanistan Reconstruction,“Oversight in Conflict: Detecting Fraud in
Challenging Environments,” Association of Certified
Fraud Examiners, Law Enforcement & Government
Anti-Fraud Summit, Washington DC, 11/7/2019, p. 10.
317. SIGAR, Inquiry Letter: Department of State Plans for
Marriott Kabul Hotel and Kabul Grand Residences,
12/11/2017, p. 1.
318. SIGAR, Prepared Remarks of John F. Sopko, Special
Inspector General for Afghanistan Reconstruction,“Oversight in Conflict: Detecting Fraud in
Challenging Environments,” Association of Certified
Fraud Examiners, Law Enforcement & Government
Anti-Fraud Summit, Washington DC, 11/7/2019, pp. 2,
4–5, 10.
319. SIGAR analysis of Quarterly Report to the UnitedStates Congress, 4/30/2019 pp. 205–206, 7/30/2019
pp. 221–222, 10/30/2019 pp. 207–208, 1/30/2020
pp. 177–178, 4/30/2020 pp. 173–174, 7/30/2020
pp. 185–186, 10/30/2020 pp. 209–210, and 1/30/2021
pp. 179–180.
320. TEARFUND, Monitoring and Accountability
Practices for Remotely Managed Projects
Implemented in Volatile Operating Environments,
12/22/2012, pp. 10–25; Secure Access in Volatile
Environments (SAVE), Resource Paper, The
Use of Third-Party Monitoring in Insecure
Contexts, Lessons from Afghanistan, Somalia,

SPECIAL INSPECTOR GENERALI AFGHANISTAN RECONSTRUCTIONENDNOTES

321.

322.

323.

324.

325.

326.

327.
328.

and Syria, 10/2016, p. 18; Secure Access in Volatile
Environments (SAVE), Final Report, Eyes andEars on the Ground: Monitoring Aid in Secure
Environments, 10/2016, p. 38. SIGAR and UnitedStates Institute of Peace, Report on an International
Symposium on Monitoring and Management in
Insecure Environments: Applying Best Practices to
Afghanistan, 6/18/2014, p. 5.
SIGAR, Emergency Food Assistance to Afghanistan:
Incomplete Reporting and Limited Site Visits
Hindered USAID’s Oversight of Millions of Dollars ofFood Assistance, SIGAR 20-10-AR, 11/2019, pp. 4–5.
“Agreement for Bringing Peace to Afghanistan
between the Islamic Emirate of Afghanistan which
is not recognized by the United States as a state andis known as the Taliban and the United States ofAmerica,” 2/29/2020, p. 1.
John F. Sopko, “Risks to Sustainable Peacein Afghanistan,” Testimony Before the House
Committee on Oversight and Reform, Subcommittee
on National Security, SIGAR 20-24-TY, 1/28/2020,
p. 25.
USFOR-A said its ability to execute and/or oversee
costly and necessary taxpayer-funded contracts totrain and sustain Afghan forces, and to provide themhundreds of millions of dollars’ worth of equipment
and direct assistance funds has thus far not been
adversely affected. SIGAR, Quarterly Report to theUnited States Congress, 10/30/2020, pp. 77–78, and1/30/2021, iii, p. 56; CTSC-A, response to DOD OIG
data call, 9/25/2020.
“Joint Declaration between the Islamic Republicof Afghanistan and the United States of America
for Bringing Peace to Afghanistan,” 2/29/2020, p. 3;
State, response to SIGAR vetting, 4/14/2020.
David F. Helvey, Performing the Duties of Assistant
Secretary of Defense for Indo-Pacific Security
Affairs, and Ambassador Zalmay Khalilzad, Special
Representative for Afghanistan Reconciliation,
Spoken Testimony before the House Subcommittee
on National Security, House Oversight and Reform
Committee, 9/22/2020; State, “Secretary Michael R.
Pompeo Remarks to Traveling Press,” 9/11/2020;
DOD, “Secretary Esper Address to Service Members
in Afghanistan, 2/29/2020; DOD, “Department of
Defense Press Briefing by Secretary Esper andGeneral Milley in the Pentagon Briefing Room,”
3/2/2020; State, response to SIGAR vetting,
10/13/2020.
SIGAR, Quarterly Report to the United States
Congress, 7/30/2013, p. 3.
SIGAR, Quarterly Report to the United States
Congress, 10/30/2017, pp. 150–151; 1/30/2021, p. 26;
SIGAR, Afghanistan’s Anti-Corruption Efforts,
SIGAR 21-09-AL, 11/6/2020, p. 2.

329. “Afghanistan Partnership Framework,” 11/24/2020,
p. 2.
330. SIGAR, Quarterly Report to the United States
Congress, 10/30/2017, pp. 150–151.
331. Reuters, “Foreign donors pledge $12 billion overfour-years for Afghanistan with tougher conditions,” 11/24/2020; ODI, Tobias Haque and Nigel
Roberts, Afghanistan’s Aid Requirements: Howmuch aid is required to maintain a stable state?,
10/2020, p. 8. https://l4p.odi.org/assets/images/
ODI-L4P-Afghanistan-aid-requirements-Haque-andRoberts-2020.pdf.
332. New York Times, “They Fight Suicide Bombers. But
Can Afghan Police Fight Crime?” 2/8/2011; Afghan
Analysts Network, Kabul’s Expanding Crime Scene(Part 2): Criminal activities and the police response,
2/21/2020.
333. Afghanistan Analysts Network, Kabul’s Expanding
Crime Scene (Part 2): Criminal activities and thepolice response, 2/21/2020; New York Times, “TheyFight Suicide Bombers. But Can Afghan Police Fight
Crime?”, 2/8/2020.
334. UN, Office for the Coordination of Humanitarian
Affairs, Asia Pacific Regional Humanitarian Update:
Afghanistan Humanitarian Response Plan 2018–2021(January 2021 revision), update of 1/22/2021, p. 3,
https://reports.unocha.org/en/country/

77

.,

'. • '"" ,!.',..,.-.

•. - ,

r-,.

• ,

.

}

'

•

~..~: :·.'•'~."'~ ~,•> ,;,~-;. · ·
•

;

C'

•

,. '

,:" X

~-,!

t ...
"•
., .,. ., . . ~ -- .,,,,. ,'., -, • .. ',:'.'? / ,£;' . .

,.

.

"

I

< •

,

]

.. '

' '

•·-;
'

'"· ,.

.. ' .

' • •,•. ," ". • . •' .. '
'~
,...,

' '

'

•

.•.

• • " " ,;--•• '---·•>,;.•,,t,,• .

"' . , . .'" ' ·-'•. ,._ " ~ .,.:,c' .' ': _• ·•;< : , ,~-- ·~·•J.l~ ..-~-,•,.. , . ' . .. .. .
,. ,,·' ;\,,,-·.,:-•·-•U:
',

- ,.

.J . i. ..r •:·,,..
•·- .. i " . .'..✓. . .. ;. . ., , '.
~,..\i;. ,:, ,.:,' :, ," -._. •~'·• , '. i,',,~ .·• A f .~ • •. ' 'A,~c,·, '-: . '. \,•- -•.•'.,:•. ,:t.• ,;- ~-~~e",· .,,,_. .r..l ._. ['•·: .. - .. , ,- . . , ....._.. -c·'• '''""•' -, . '·-•-- '\!\'' ,_,._ .• ' -• ' ,.. "! •• ' ' '' ._,,,.

'" ;• ,

·

•

•·

•

•

,. .,' .
< '

'

.

,

'

••• , ... , ,

_...,

S

•

.•

'•, •.

,. < . . .. ,.. "
<

<

•'

-

·- '""- ,;: ......
"· .,-.
' _,..... ,,. '

'' '

0 ••
'

C ·.:_,,.!, , 0 ..;', .- , , -,-,·,,.. l;, t ' .. ,. • ·;,'·I ~\: .~.:

~

«

.

..

,,

•

•

,,

',
,f

;-

L'

,,

~

--!',,..,tr:' ••,:~. :-,,.

-.- ,.-

"

1· f

i

-.

-t_ . . . .

' .
' .

·"

~

'' -

•,
'

,,,_

' ,

~

lr-1_'... ,_

L·• •_._.

,.

l,

,:

r'

I

1

JOWZJAN

BALKH

SAMANGANFARYAB
SAR-E PULBADGHISHERATGHOR

KUNDUZBADAKHSHANBAGHLANPANJSHIR NURISTANKAPISA
PARWANKUNARBAMYANLAGHMANKABULWARDAKNANGARHARLOGARDAYKUNDIPAKTIYAGHAZNIKHOSTURUZGAN

FARAH

ZABUL

NIMROZTAKHARHELMANDKANDAHARPAKTIKA

Provinces where SIGAR has conducted
or commissioned audit, inspection,
special project, and/or investigation
work as of December 31, 2020.

SIGAR
SPECIAL INSPECTOR GENERALFOR AFGHANISTAN RECONSTRUCTION
2530 Crystal Drive
Arlington, VA 22202
www.sigar.mil

WASTE, FRAUD, OR ABUSE MAY BE REPORTED TO SIGAR’S HOTLINE
By phone: Afghanistan
Cell: 0700107300
DSN: 318-237-3912 ext. 7303
All voicemail is in Dari, Pashto, and English.
By phone: United States
Toll-free: 866-329-8893
DSN: 312-664-0378
All voicemail is in English and answered during business hours.
By fax: 703-601-4065
By e-mail: sigar.hotline@mail.mil
By Web submission: www.sigar.mil/investigations/hotline/report-fraud.aspx
SIGAR 21-22-HRL~ SIGAR-

Report Waste, Fraud or Abuse