SYRIAN REFUGEES

U.S. Agencies 

Conduct Financial 

Oversight Activities for 

Humanitarian 

Assistance but Should 

Strengthen Monitoring

Report to Congressional Requesters

October 2017

GAO-18-58

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-58, a report to 

congressional requesters

October 2017

SYRIAN REFUGEES

U.S. Agencies Conduct Financial Oversight Activities 

for Humanitarian Assistance but Should Strengthen 

Monitoring 

What GAO Found

The Department of State (State) and the U.S. Agency for International 

Development (USAID) have obligated more than $3.5 billion since fiscal year 

2012 to support humanitarian assistance for Syrian refugees in the Middle East. 

From fiscal years 2012 through 2017, State obligated about $2.8 billion for 

programs providing education, health, and protection, among other things, and 

USAID obligated $887 million for food assistance. Most of the funding was 

provided to public international organizations, such as the United Nations High 

Commissioner for Refugees and the World Food Programme, for programs in

Lebanon and Jordan. Food assistance has been provided in cash-based form, 

and there are cash-based programs in other sectors as well. For example, in 

Lebanon and Jordan, U.S. implementing partners provide cash-based assistance 

through mechanisms that include cards or iris scans (see fig.). 

Card for Delivering Cash-Based Assistance to Syrian Refugees in Jordan (left) and Iris Scan 

Checkout Screen at a Grocery Store in a Refugee Camp in Jordan (right)

State and USAID conduct a variety of financial oversight activities but face 

security-related monitoring challenges. For all 33 funding instruments in GAO’s

sample (representing 83 percent of State funding and 100 percent of USAID 

funding for fiscal years 2015 and 2016), State and USAID used risk assessments 

to inform their monitoring activities. Both agencies developed risk-based 

monitoring plans citing the number and frequency of in-person monitoring visits 

required to ensure financial oversight. However, due to security restrictions, 

State and USAID were unable to conduct all scheduled in-person monitoring 

visits in fiscal years 2015 through 2017. For example, during this period, USAID 

staff were unable to conduct any such visits in Iraq and were unable to conduct 

such visits in Lebanon for 7 months. State has hired local staff—who are able to 

access areas with security related restrictions for U.S. officials—to conduct some 

in-person monitoring visits and has considered other options but has not 

implemented them. USAID reports it has considered, but not implemented, 

alternative mechanisms for conducting in-person monitoring visits in areas where 

security conditions limit such visits by USAID officials. Without in-person 

monitoring, financial irregularities may go unnoticed or take longer to detect.

View GAO-18-58. For more information, 

contact Thomas Melito, (202) 512-9601 or 

MelitoT@gao.gov.

Why GAO Did This Study

The ongoing conflict in Syria has 

created a complex humanitarian crisis,

displacing more than 5 million Syrians

to neighboring countries. The United 

States has led the global funding effort 

to provide humanitarian assistance to 

people affected by the conflict. 

GAO was asked to review 

humanitarian assistance provided by 

State, USAID, and their implementing 

partners to Syrian refugees in the 

Middle East. This report examines (1) 

the amount of funding U.S. agencies 

have obligated and types of assistance

provided and (2) the extent to which 

State and USAID provide financial 

oversight of such assistance. GAO 

analyzed State and USAID data; 

examined a nongeneralizable sample 

of 33 funding instruments for fiscal 

years 2015 and 2016 involving 15 

implementing partners; analyzed State 

and USAID oversight activities; 

interviewed relevant officials, and 

conducted fieldwork in Lebanon and 

Jordan, where most of State and 

USAID’s humanitarian assistance 

funding has been obligated. 

What GAO Recommends

To improve financial oversight of 

programs assisting Syrian refugees, 

GAO recommends that State and 

USAID identify and implement a 

mechanism to conduct in-person 

monitoring visits in countries where 

security conditions limit such visits by

U.S. officials. State and USAID 

concurred with GAO’s 

recommendations. 
Page i GAO-18-58 Syrian Refugees

Letter 1

Background 3

State and USAID Have Obligated More Than $3.5 Billion to 

Support Cash-Based and Other Types of Humanitarian 

Assistance to Syrian Refugees in the Middle East 8

State and USAID Conduct Risk-Based Financial Oversight 

Activities for Humanitarian Assistance Provided to Syrian 

Refugees but Face Security-Related Monitoring Challenges 21

Conclusions 32

Recommendations for Executive Action 33

Agency Comments and Our Evaluation 33

Appendix I: Objectives, Scope, and Methodology 36

Appendix II: Location of Syrian Refugees and U.S. Government Travel Restrictions in Egypt, Iraq, 

Jordan, Lebanon, and Turkey 38

Appendix III: Comments from the Department of State 45

Appendix IV: Comments from the U.S. Agency for International Development 48

Appendix V: GAO Contact and Staff Acknowledgments 50

Tables

Table 1: Host Country Policies Regarding Syrian Refugees, as of 

October 2017, as Reported by State and the UN 5

Table 2: State and USAID Obligations for Humanitarian 

Assistance to Syrian Refugees, Fiscal Years 2012 

through 2107 9

Contents
Page ii GAO-18-58 Syrian Refugees

Figures

Figure 1: Number and Location of Registered Syrian Refugees in 

the Middle East, as of June 2017 4

Figure 2: State and USAID Obligations for Humanitarian 

Assistance to Syrian Refugees, Fiscal Years 2012 

through 2017 9

Figure 3: U.S. Obligations for Humanitarian Assistance to Syrian 

Refugees by Country, Fiscal Years 2012 through 2017 10

Figure 4: USAID Obligations for Food Assistance by Country, 

Fiscal Years 2012 through 2017 13

Figure 5: Image of the OneCard Used to Deliver Assistance in 

Lebanon 14

Figure 6: Beneficiaries’ Grocery Selections at a World Food 

Programme-Contracted Grocery Store (left) and the 

Interior of the Grocery Store (right), in Beirut, Lebanon 15

Figure 7: Example of a OneCard Used to Deliver Cash-Based 

Assistance in Jordan 16

Figure 8: A Refugee Purchases Food at a Grocery Store (left), 

and the Eye Pay Screen When Not in Use (right), in 

Za’atari Camp, Jordan 17

Figure 9: Results of a Roof Repair (left) and Nongovernmental 

Organization Staff Showing the GAO Team a Newly 

Installed Door with a Lock (right), in Tripoli, Lebanon 18

Figure 10: A school for Syrian refugees in Za’atari Camp, Jordan 19

Figure 11: Syrian Refugees Updating Their Registration 

Information and Preparing to Have an Iris Scan, at the 

United Nations High Commissioner for Refugees 

Reception Center in Beirut, Lebanon 20

Figure 12: Food for Peace, World Food Programme and GAO 

Officials Visit a Grocery Store in Za’atari Camp, Jordan 24

Figure 13: GAO, Nongovernmental Organization, and Department 

of State Officials Interviewing Beneficiaries of a Shelter 

Improvement Project near Irbid, Jordan 27

Figure 14: Number and Location of Registered Syrian Refugees in 

Egypt, as of December 2016 39

Figure 15: Number and Location of Registered Syrian Refugees in 

Iraq, as of December 2016 40

Figure 16: Number and Location of Registered Syrian Refugees in 

Jordan, as of December 2016 41

Figure 17: Number and Location of Registered Syrian Refugees in 

Lebanon, as of December 2016 42
Page iii GAO-18-58 Syrian Refugees

Figure 18: Number and Location of Registered Syrian Refugees in 

Turkey, as of December 2016 43

Abbreviations

COSO Committee of Sponsoring Organizations of the Treadway 

Commission 

FAPD Foreign Assistance Policy Directive

FFP Office of Food for Peace 

ISIS Islamic State of Iraq and Syria

ITS Informal tented settlements

NGO Nongovernmental organization

OIG Office of Inspector General 

PIO Public international organization

PRM Bureau of Population, Refugees, and Migration

State Department of State

UN United Nations

UNHCR United Nations High Commissioner for Refugees

UNICEF United Nations Children’s Fund 

USAID United States Agency for International Development 

WFP World Food Programme

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Page 1 GAO-18-58 Syrian Refugees

441 G St. N.W.

Washington, DC 20548

October 31, 2017

Congressional Requesters

The ongoing conflict in Syria has contributed to the largest worldwide 

refugee and displacement crisis since World War II. As of June 2017, 

more than 5 million refugees fleeing the conflict have registered with the 

United Nations High Commissioner for Refugees (UNHCR) or host 

governments, primarily in five countries—Egypt, Iraq, Jordan, Lebanon, 

and Turkey. Since 2013, the United States, through the Department of 

State (State) and the U.S. Agency for International Development 

(USAID), has led global funding efforts to provide humanitarian 

assistance to those affected by the Syrian conflict.

We were asked to review U.S. efforts to provide humanitarian assistance 

to individuals affected by the conflict in Syria. In July 2016, we analyzed 

U.S. humanitarian assistance to people inside Syria.1 In this report we 

examine humanitarian assistance provided by the United States to Syrian 

refugees in the Middle East, including (1) how much funding has been 

obligated and what types of assistance have been provided, and (2) the 

extent to which State and USAID provide financial oversight of such 

assistance.

To determine how much funding has been obligated by State and USAID, 

as well as the types of humanitarian assistance provided by their 

implementing partners, we obtained State and USAID obligations data for 

fiscal years 2012 through 2017 and analyzed relevant program 

documents, including the program descriptions provided by implementing 

partners in their funding applications. We determined that these data 

were reliable for reporting total obligations per country by checking the 

obligations data against data reported by State and USAID in other 

sources.

To determine the extent to which State and USAID provide financial 

oversight of the assistance, we obtained relevant policy documents, 

 1 GAO, Syria Humanitarian Assistance: Some Risks of Providing Aid inside Syria 

Assessed, but U.S. Agencies Could Improve Fraud Oversight, GAO-16-629 (Washington, 

D.C.: July 14, 2016). 

Letter
Page 2 GAO-18-58 Syrian Refugees

including State’s Federal Assistance Policy Directive2 (FAPD) and 

USAID’s Food for Peace Annual Program Statement, as well as 

guidance, risk assessments, and other documents related to program 

monitoring for the types of funding instruments used to provide 

humanitarian assistance to Syrian refugees. We examined the two USAID 

funding instruments for the World Food Programme that accounted for all 

USAID funding to Syrian refugees for fiscal years 2015 and 2016, and we 

also selected a nonprobability sample of 31 fiscal year 2015 and 2016 

State funding instruments from 14 different implementing partners. While 

not generalizable, the sample accounted for over 83 percent of State 

obligations for humanitarian assistance to Syrian refugees in the Middle 

East for those fiscal years. Using these funding instruments, the Foreign 

Assistance Policy Directive (FAPD), and Standards for Internal Control in 

the Federal Government3 we identified the relevant financial oversight 

activities for these instruments. For the purposes of this report, we 

focused our analysis on financial oversight activities related to internal 

control standards of risk assessment and program monitoring. In addition, 

we requested all State and USAID documentation related to the funding 

instruments in our sample and reviewed those that we received, including 

completed risk assessments and program monitoring plans and reports. 

We interviewed State, USAID, and implementing partner officials in 

Washington, DC; Switzerland; Jordan, and Lebanon; and conducted 

telephone interviews with State officials in Turkey and Iraq, to discuss 

their practices regarding risk assessments and control activities, as well 

as program monitoring practices. Additionally, we accompanied State 

officials on program monitoring visits in Lebanon and Jordan and met with 

14 implementing partners altogether. We selected these countries to visit 

because they received the greatest amount of funding from State and 

USAID in fiscal years 2015 through 2016. Results are not generalizable.

We conducted this performance audit from August 2016 to October 2017 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

 2 In May 2017, State replaced the FAPD with a new policy document—the Federal 

Assistance Directive—which applies to awards issued as of May 20, 2017. We consulted 

both of these policy documents.

3 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sep. 2014). 
Page 3 GAO-18-58 Syrian Refugees

conclusions based on our audit objectives. See appendix I for a more 

detailed discussion of our scope and methodology.

The ongoing conflict in Syria, which began in 2011, has displaced large 

numbers of people inside the country and within the Middle East. At the 

beginning of the conflict, Syrians, as well as Iraqi and Palestinian 

refugees who had been residing in Syria, fled mainly to Jordan, Lebanon, 

and Turkey. As the crisis persisted, refugees traveled in larger numbers 

to Turkey, with UNHCR reporting nearly 1 million Syrian refugees seeking 

protection in that country in 2015. Starting that year, an increasing 

number of Syrians have risked sea voyages to reach Greece and other 

countries in Europe, such as Germany and Sweden. The population of 

registered Syrian refugees in neighboring countries had largely stabilized 

by late 2016, according to State officials. As of June 2017, there were 

more than 5 million registered Syrian refugees living in neighboring 

countries: more than 3 million in Turkey, more than 1 million in Lebanon, 

more than 600,000 in Jordan, more than 200,000 in Iraq, and more than 

100,000 in Egypt 4 (see fig. 1).

 4 According to UNHCR, in Egypt, refugees that approached the organization after 2011 

were registered as asylum seekers, but are considered refugees by UNHCR. In Jordan, 

while UNHCR reports having registered more than 600,000 Syrian refugees, the 

government says that there are about 1.3 million Syrian refugees in the country. In 

Lebanon, UNHCR suspended registration of Syrian refugees in 2015 based on 

instructions from the Lebanese government. Thus, according to State and United Nations 

(UN) officials, the number of registered Syrian refugees likely underestimates the 

presence of such refugees in Lebanon. In Turkey, the government registers refugees and 

releases statistics on the refugee population.

Background

Numbers and Location of 

Syrian Refugees
Page 4 GAO-18-58 Syrian Refugees

Figure 1: Number and Location of Registered Syrian Refugees in the Middle East, as of June 2017

Note: Data represent refugees registered by the United Nations High Commissioner for Refugees 

(UNHCR) in Egypt, Iraq, Jordan, and Lebanon. In Turkey, the government registers refugees and 

releases statistics on the refugee population. Data for Egypt, Iraq and Turkey are as of July 2017; 

data for Jordan are as of September 2017; data for Lebanon are as of June 2017.
Page 5 GAO-18-58 Syrian Refugees

Several factors, including geographic accessibility, employment 

opportunities, and government policies, have affected Syrian refugees’

patterns of settlement in host countries. Although some refugee camps 

exist, the majority of Syrian refugees—about 90 percent, according to 

UNHCR—are living in urban and rural areas among host country 

populations. According to State, the security situation in each host 

country varies, though each faces a threat from terrorist groups or 

incidents of domestic unrest. As a result, there are travel restrictions for 

U.S. government personnel in each country. See appendix II for detailed 

maps of where Syrian refugees have settled in each of the five main host 

countries, as well as a description of the security situation in each 

country.

Countries hosting Syrian refugees have adopted differing policies on 

issues affecting refugees’ lives, such as employment and schooling. 

These policies, shown in table 1, affect the types of challenges refugees 

face in each host country, and in turn, influence the types of programs 

that implementing partners use to deliver humanitarian assistance.

Table 1: Host Country Policies Regarding Syrian Refugees, as of October 2017, as Reported by State and the UN

Country Refugee registering authority Employment Schooling

Lebanon United Nations High Commissioner 

for Refugees (UNHCR), but the 

government directed UNHCR to 

suspend registration of Syrian 

refugees in 2015

Refugees can work in three sectors—

agriculture, construction, and 

environment—but those without 

residency permits can be arrested. 

Residency permits have been 

expensive and difficult to obtain, and 

most Syrians work informally. The 

Lebanon Crisis Response Plan (2017-

2020) noted that the Lebanese 

Ministry of Labor reported that 2,067 

Syrians had applied for work permits 

since 2013.

Refugees who arrived earlier in the 

crisis are enrolled in the morning 

session, or “first shift,” while more 

recent arrivals are enrolled in an 

afternoon session, or “second 

shift,” at Lebanese schools, if 

available.

Jordan UNHCR Refugees can legally work in some 

sectors—including agriculture, 

construction, and manufacturing—but 

as of September 2017, Jordan had 

only issued 62,000 work permits and 

most refugees work illegally. 

Refugees can attend the “second 

shift” at Jordanian schools, if 

available. In some areas, refugees 

are integrated into single shift 

schools with Jordanian students. 

Host Country Policies 

Regarding Refugees
Page 6 GAO-18-58 Syrian Refugees

Country Refugee registering authority Employment Schooling

Turkey Turkish government Refugees can work legally in any 

sector if they have a work permit 

secured through an employer, but 

about 26,000 work permits have been 

issued and most refugees work 

illegally. 

Refugees can attend Turkish 

schools, and some attend 

Temporary Education Centers 

where they are taught by Syrian 

teachers. Of the Syrian refugee 

children that attend school, 53 

percent are enrolled in public 

schools.

Iraq UNHCR Refugees with a residency permit can 

work legally but often face long waits 

to obtain the permits.

Refugees can attend Iraqi schools.

Egypt UNHCR Refugees can obtain a work permit, 

but employers are reticent to hire 

them, due in part to their uncertain 

residency status. Residency permits 

are complicated and expensive to 

obtain and must be renewed every 6 

months.

Refugees can attend Egyptian 

schools.

Source: GAO analysis of Department State (State) and United Nations (UN) documents and interviews. | GAO-18-58

Note: This summary of policies is based on documents from and interviews with officials from the 

State Department and the UN. According to State, these were the applicable policies as of October 

2017.

Financial oversight of humanitarian assistance programs includes 

managing program funds to ensure they are spent in accordance with 

funding instruments by, among other things, assessing financial risks and 

monitoring the implementation of controls to mitigate those risks. 

Standards for Internal Control in the Federal Government provides the 

overall framework for establishing and maintaining internal control in the 

federal programs. In addition, COSO has issued an internal control 

framework that has gained broad acceptance and is widely used around 

the world.5 Both frameworks include the five components of internal 

control: control environment, risk assessment, control activities, 

 5

COSO was formed in 1985 to sponsor the National Commission on Fraudulent Financial 

Reporting, an independent, private sector initiative that studied the causal factors that can 

lead to fraudulent financial reporting and developed recommendations for public 

companies and their independent auditors, the U.S. Securities and Exchange Commission 

and other regulators, and educational institutions. In 1992, COSO issued Internal 

Control—Integrated Framework to help businesses and other entities assess and enhance 

their internal control. Since that time, according to COSO, its internal control framework 

has been recognized by regulatory standards setters and others as a comprehensive 

framework for evaluating internal control, including internal control over financial reporting. 

COSO updated its framework in May 2013 to enhance and clarify the framework’s use 

and application. 

Financial Oversight of 

Humanitarian Assistance
Page 7 GAO-18-58 Syrian Refugees

information and communication, and monitoring. Internal control generally 

serves as a first line of defense in safeguarding assets, such as food and 

nonfood items. In implementing internal control standards, management 

is responsible for developing the detailed policies, procedures, and 

practices to fit the entity’s operations and to ensure they are built into and 

are an integral part of operations.

Recent work by GAO and investigations conducted by the State and 

USAID Offices of the Inspector General (OIG) have highlighted the 

importance of financial oversight in providing humanitarian assistance. In 

our 2015 report on cash-based food assistance, we noted that financial 

oversight in cash-based food assistance programs includes managing 

program funds by assessing financial risks and implementing controls to 

prevent theft and diversion of cash, counterfeiting of vouchers, and 

losses.6 We recommended that USAID conduct systematic financial 

oversight of cash-based food assistance in its field locations.7 In our 2016 

report on humanitarian assistance for people inside Syria, we found that 

while U.S. agencies and their implementing partners had assessed some 

risks of providing such assistance, U.S. agencies could improve fraud 

oversight.8

USAID OIG has reported that assistance projects that unfold during an 

emergency response are at higher risk of fraud, waste, and abuse. 

Specifically, the USAID OIG has found that aid organizations providing 

life-saving assistance to refugees in the region surrounding Syria faced 

an extremely high-risk environment, and that the absence of adequate 

internal controls can jeopardize the integrity of these relief efforts and 

deny critical aid to those in need. Lastly, State and USAID OIG have 

conducted criminal investigations of U.S. humanitarian assistance for the 

Syria crisis, uncovering various types of fraud schemes and highlighting 

the potential vulnerabilities of these programs to fraud.

 6 GAO, International Cash-Based Food Assistance: USAID Has Developed Processes for 

Initial Project Approval but Should Strengthen Financial Oversight, GAO-15-328 

(Washington, D.C.: March 2015).

7

USAID agreed with our recommendation and told us they were developing training 

products to improve the capacity to oversee cash-based food assistance programming. In 

addition, they said they would continue to explore the use of third-party monitoring 

contracts in places where security and access constraints precluded in-person monitoring. 

However, as of September 2017, this recommendation had not been implemented.

8 GAO-16-629.
Page 8 GAO-18-58 Syrian Refugees

State and USAID have obligated more than $3.5 billion in humanitarian 

assistance funding to support Syrian refugees in the Middle East. U.S. 

agencies obligated most of their funding to public international 

organizations (PIO), but State also provided funding to nongovernmental 

organizations (NGO) for specific programs not covered by PIO activities. 

U.S. funding supported a variety of types of assistance, including food 

assistance and basic needs, and a significant share was provided in 

cash-based form through cards or other types of electronic platforms.

From fiscal years 2012 through 2017, State and USAID obligated 

approximately $3.7 billion to provide humanitarian assistance to Syrian 

refugees. The U.S. agencies providing humanitarian assistance to Syrian 

refugees are State’s Bureau of Population, Refugees and Migration 

(PRM) and USAID’s Office of Food for Peace (FFP). As shown in figure 2, 

in those fiscal years, State obligated more than 70 percent, or about $2.8 

billion, while USAID obligated about $887 million for food assistance to 

refugees.

State and USAID 

Have Obligated More 

Than $3.5 Billion to 

Support Cash-Based 

and Other Types of 

Humanitarian 

Assistance to Syrian 

Refugees in the 

Middle East

Since 2012, the United 

States Obligated More 

Than $3.5 Billion in 

Humanitarian Assistance, 

with Most Funding 

Supporting Refugees in 

Lebanon and Jordan
Page 9 GAO-18-58 Syrian Refugees

Figure 2: State and USAID Obligations for Humanitarian Assistance to Syrian 

Refugees, Fiscal Years 2012 through 2017

Table 2: State and USAID Obligations for Humanitarian Assistance to Syrian Refugees, Fiscal Years 2012 through 2107

Fiscal year

State obligations

(millions)

USAID obligations

(millions)

Total obligations

(millions)

2012 25.5 14.7 40.2

2013 446.3 162.6 608.9

2014 542.0 272.5 814.5

2015 551.8 244.1 795.9

2016 593.9 26.0 619.9

2017 632.4 167.4 799.8

Total 2,791.8 887.3 3,679.1 

Source: GAO analysis of Department of State and USAID data. | GAO-18-58

Note: Food for Peace (FFP) considers multiple factors before making contributions to humanitarian 

assistance operations, including the level of support provided by other donors. In 2016, Germany 

made a significant contribution to the World Food Programme’s Syrian refugee operation, allowing 

FFP to reduce support to this operation and increase its El Niño response in southern Africa.
Page 10 GAO-18-58 Syrian Refugees

The majority of funding provided by both State and USAID has supported 

Syrian refugees in two countries—Lebanon and Jordan. Specifically, from 

fiscal years 2012 through 2017, obligations for programs in Lebanon and 

Jordan totaled approximately $2.6 billion—nearly $1.6 billion in Lebanon 

and almost $1 billion in Jordan (see fig. 3). These two countries host the 

highest number of refugees per 1,000 inhabitants, and according to UN 

needs assessments, refugees in these countries, particularly in Lebanon, 

are experiencing high levels of vulnerability and need. While Turkey hosts 

the largest number of Syrian refugees overall, the Turkish government 

has taken a significantly larger role in assisting refugees, and thus their 

needs are relatively smaller, which is reflected in the smaller share of 

U.S. funding directed toward programs in Turkey. Programs in Iraq and 

Egypt each received smaller portions of the funding, consistent with the 

smaller populations of refugees in these countries.

Figure 3: U.S. Obligations for Humanitarian Assistance to Syrian Refugees by

Country, Fiscal Years 2012 through 2017

Note: The figure does not depict $15.7 million in State Department funds obligated to the Office of the 

United Nations High Commissioner for Refugees and the United Nations Relief and Works Agency for 

Palestine Refugees in the Near East for regional assistance.
Page 11 GAO-18-58 Syrian Refugees

The United States used three types of funding instruments—voluntary 

contributions, grants, and cooperative agreements—and two types of 

organizations—PIOs and NGOs—to provide humanitarian assistance to 

Syrian refugees. The majority of State funding has been provided through 

voluntary contributions to PIOs, such as UNHCR and the United Nations 

Children’s Fund (UNICEF). According to State guidance, voluntary 

contributions are discretionary financial assistance provided to PIOs, 

among other institutions, which are meant to directly support the activities 

of the organization or to sustain the general budget and operations of the 

PIO. While the funds may be used to advance specific activities and goals 

of the U.S. government, the central purpose of the funds is to enable the 

PIO to carry out its activities. According to State officials, this means that 

generally U.S. funding cannot be traced to specific PIO activities within a 

given country, since the funding is pooled with resources from other 

donor countries. State obligated about 88 percent of its funding for 

humanitarian assistance to Syrian refugees through voluntary 

contributions to PIOs from fiscal years 2015 through 2017.

All of USAID’s humanitarian assistance for Syrian refugees from fiscal 

years 2015 through 2017 was provided through grants to a PIO—the 

World Food Programme (WFP); the grants specify that USAID funding is

to be used to support WFP activities in all five Middle Eastern countries 

hosting Syrian refugees.9

The remainder of State’s funding was provided through cooperative 

agreements with NGOs. According to State guidance, PRM funds these 

organizations in situations where the NGOs’ programs are coordinated 

with the multilateral system and fill critical gaps in humanitarian 

assistance and protection programs. These organizations received about 

12 percent of State’s obligated funding for humanitarian assistance to

Syrian refugees in fiscal years 2015 through 2017. State’s funding for 

NGOs can be directly connected to specific programs and to program 

outcomes—the application for State funding requires the NGOs to provide 

a description of the program, including an implementation plan, key 

activities, and implementing partners, as well as objectives and indicators 

for program progress.

 9 WFP is the world’s leading humanitarian agency fighting hunger worldwide, delivering 

food assistance in emergencies and working with communities. 

Most U.S. Funding Has 

Been Provided Through 

Voluntary Contributions 

and Grants to PIOs
Page 12 GAO-18-58 Syrian Refugees

U.S. funding has supported a variety of types of humanitarian assistance 

in the five host countries, including food, shelter, education, health, basic 

needs, and protection. A significant share of the assistance provided by 

the United States and other donors is being provided in cash-based 

form10—there are cash-based components of assistance programs in 

several sectors in addition to food assistance, including shelter, 

education, and basic needs.

A large share of U.S. funding has supported food assistance, with 

USAID’s FFP obligating about $887 million to WFP to support cash-based 

programs11 from fiscal years 2012 through 2017, the largest of which 

were in Lebanon and Jordan (see fig. 4).

 10 In 2016, the United States participated in the Grand Bargain where donors and aid 

providers agreed to increased use and coordination of cash-based assistance where 

appropriate. 

11 In GAO-15-328, we noted that cash-based food assistance is generally for food 

purchased in the affected country or region through cash or vouchers, among other 

means. In this report, cash-based food assistance refers to interventions to improve food 

security by providing beneficiaries with cards, electronic vouchers, or other means for 

purchasing food.

Implementing Partners 

Supported by the United 

States and Other Donors 

Provide Cash-Based 

Assistance for Food and 

Other Needs

Food assistance
Page 13 GAO-18-58 Syrian Refugees

Figure 4: USAID Obligations for Food Assistance by Country, Fiscal Years 2012 

through 2017

WFP’s food assistance programs in each of these countries are entirely 

cash-based, with beneficiaries using cards, vouchers, or iris scans to 

purchase food. In Lebanon, WFP participates in an electronic platform 

where multiple implementing partners—in this case, WFP, UNHCR, 

UNICEF, and the Lebanese Cash Consortium—can load their cashbased benefits onto a single electronic card, the OneCard, which has 

multiple “wallets” for different types of assistance (see fig. 5).
Page 14 GAO-18-58 Syrian Refugees

Figure 5: Image of the OneCard Used to Deliver Assistance in Lebanon

The OneCard allows beneficiaries to receive assistance using point-ofsale terminals at selected retailers, as well as cash assistance through 

ATM withdrawals. To access the food assistance, according to WFP 

officials, a beneficiary (1) receives a text message to inform them that 

their monthly food assistance is available; (2) shops at one of the 

hundreds of stores WFP has contracted with to select groceries; and (3) 

at checkout, presents their OneCard and UNHCR registration certificate 

(which contains a photograph) and enters a personal identification 

number to verify their identity (see fig. 6).
Page 15 GAO-18-58 Syrian Refugees

Figure 6: Beneficiaries’ Grocery Selections at a World Food Programme-Contracted 

Grocery Store (left) and the Interior of the Grocery Store (right), in Beirut, Lebanon

Syrian refugees in Jordan access their food assistance in one of two 

ways—refugees living outside of camps use cards similar to those found 

in Lebanon to purchase food from WFP-contracted grocery stores (see 

fig. 7).
Page 16 GAO-18-58 Syrian Refugees

Figure 7: Example of a OneCard Used to Deliver Cash-Based Assistance in Jordan

In the camps, refugees utilize the “Eye Pay” system, using a scan of their 

irises rather than cash, vouchers, or e-cards to pay for food (see fig. 8). 

The system draws from UNHCR biometric registration data of refugees. 

According to WFP, once a beneficiary has their iris scanned, the system 

automatically communicates with UNHCR’s registration database to first 

confirm the identity of the refugee and checks the account balance before 

confirming the food purchase.
Page 17 GAO-18-58 Syrian Refugees

Figure 8: A Refugee Purchases Food at a Grocery Store (left), and the Eye Pay 

Screen When Not in Use (right), in Za’atari Camp, Jordan

Shelter-related assistance has been another component of the U.S. 

response to the refugee crisis. This type of assistance aims to help 

refugees find safe and affordable housing by increasing the stock of such 

housing in host countries and making it available to refugees, and in 

some cases, host populations, or providing cash for rent. For example, in 

Lebanon, State funds an NGO that carries out shelter improvements in 

Tripoli; according to the NGO, it works with a local implementing partner 

to identify neighborhoods with high concentrations of vulnerable residents 

(Syrian refugees or Lebanese citizens) with the aim of increasing social 

stability. NGO officials explained that homes in the neighborhood are 

assessed for possible needed improvements, such as installing strong 

doors with locks, replacing windows, and fixing leaks (see fig. 9). Before 

improvements are made, landlords must agree to allow the current tenant 

to stay and to freeze the rent for a specified period of time. In Jordan, 

State funds another NGO that runs a program that gives money to 

landlords to rehabilitate existing housing in the Irbid area in exchange for 

agreeing to provide Syrian refugees free rent for 12 to 18 months.

Shelter
Page 18 GAO-18-58 Syrian Refugees

Figure 9: Results of a Roof Repair (left) and Nongovernmental Organization Staff 

Showing the GAO Team a Newly Installed Door with a Lock (right), in Tripoli, 

Lebanon

Education has been one of the top funding priorities of the international 

community as it seeks to address the Syrian crisis, according to the 

Regional Refugee and Resilience Plan—the international planning 

partnership for the Syria crisis response. In 2016, UNHCR reported that 

35 percent of registered Syrian refugees in neighboring countries were of 

school age (defined as being between ages 5 and 17), and that the 

percentage of registered Syrian refugee children not attending school was 

61 percent in Turkey, 60 percent in Lebanon, and 30 percent in Jordan. 

State obligated about $482 million to UNICEF from fiscal years 2015 

through 2017 to support, among other things, its efforts to increase the 

capacity of host government education systems and to remove barriers to 

refugees’ attendance at school.

12 UNICEF programs have provided 

assistance with enrollment fees and residency requirements, 

transportation, and family income needs; some of this assistance is 

 12 U.S. funding also supported UNICEF programs to provide water and sanitation, 

hygiene, psychosocial services, and winterization kits, among other things. 

Education
Page 19 GAO-18-58 Syrian Refugees

provided in cash-based form. UNICEF also helps run schools in refugee 

camps in Jordan (see fig. 10).

Figure 10: A school for Syrian refugees in Za’atari Camp, Jordan

According to the international planning partnership for the Syria crisis 

response, programs in the health sector aim to strengthen and support 

national health systems that are increasingly under strain due to 

increased demand, while also providing direct services to the most 

vulnerable Syrian refugees. In addition to health programming through 

international organizations such as UNHCR and UNICEF, State funds 

several NGOs that run health clinics to meet the medical and 

psychosocial needs of Syrian refugees. We visited two of these clinics in 

Amman, and Mafraq, Jordan, and observed refugees registering for and 

attending appointments, participating in social support sessions, and 

volunteering at the clinics.

State funding for UNHCR, approximately $866 million from fiscal years 

2015 through 2017, provides support for the organization’s core 

mandate—to ensure the international protection of refugees, among 

others, who are no longer protected by their own governments. UNHCR 

programs in the five host countries seek to uphold the basic human rights 

of Syrian refugees by registering them, ensuring that they will not be 

returned involuntarily, and longer term, to find solutions such as 

integrating into countries of asylum or resettling in third countries (see fig. 

11). UNHCR, along with its implementing partners, promotes or provides

legal and physical protection and minimizes the threat of violence—

including gender-based violence—which many refugees are subject to. 

Some State-funded NGOs also provide protection-related services for 

Syrian refugees.

Health

Protection and Basic Needs
Page 20 GAO-18-58 Syrian Refugees

Figure 11: Syrian Refugees Updating Their Registration Information and Preparing 

to Have an Iris Scan, at the United Nations High Commissioner for Refugees 

Reception Center in Beirut, Lebanon

UNHCR, along with several other State implementing partners, provides 

assistance to meet refugees’ basic needs as part of its protection 

mandate. Basic needs programs, which UNHCR defines as multisectoral 

efforts to ensure the comprehensive well-being of refugees by focusing 

on individual household forms of assistance, are often cash based. For 

example, the programs provide in-kind relief items, such as blankets, 

soap, and diapers, as well as cash assistance to purchase items.
Page 21 GAO-18-58 Syrian Refugees

State and USAID conduct a variety of financial oversight activities of their 

PIO implementing partners, and State has created a risk-based 

management framework for financial oversight of NGO implementing 

partners, which includes conducting risk assessments, creating riskbased monitoring plans, reviewing program reports, and conducting 

monitoring visits at project sites. However, while State and USAID have 

made risk-based determinations about the number and frequency of site 

visits required, they are not able to conduct all planned monitoring visits 

because of security-related restrictions that prevent U.S. government 

officials from accessing areas of certain countries.

State conducts several financial oversight activities of its voluntary 

contributions to PIOs that provide humanitarian assistance to Syrian 

refugees. Voluntary contributions are meant to enable a PIO to carry out 

its activities. Although the funds may be used to advance specific 

activities and goals of the U.S. government, according to State and 

USAID officials, in most cases, U.S. funding cannot be traced to specific 

PIO activities within a given country because it is pooled with other donor 

countries.13 State guidance specifies that many of the standard terms and 

conditions do not specifically apply to voluntary contributions, and 

performance and program reporting are discretionary; however, the terms 

of the contribution agreements may require quarterly, annual or other 

periodic progress and financial reports. State’s OIG reported in 2017 that 

PRM had established standard operating procedures and systematic 

mechanisms to engage, monitor, and evaluate the effectiveness of the 

international organizations it funds.14 Based on our fieldwork in Jordan 

and Lebanon, interviews with PRM officials, and our review of State 

documentation, we found that State conducts the following financial 

 13 According to FFP officials, FFP earmarks assistance to specific activities within a larger 

UN operation, such as emergency and protracted relief operations managed by WFP, but 

the funding cannot be traced to specific distributions or activities because it is pooled with 

resources provided by other donor countries.

14Department of State Office of the Inspector General, Inspection of the Bureau of 

Population, Refugees, and Migration, ISP-I-17-10 (Washington, D.C.: February 2017).

State and USAID 

Conduct Risk-Based 

Financial Oversight 

Activities for 

Humanitarian 

Assistance Provided 

to Syrian Refugees 

but Face SecurityRelated Monitoring 

Challenges

State and USAID Conduct 

a Variety of Financial 

Oversight Activities of PIO 

and NGO Implementing 

Partners
Page 22 GAO-18-58 Syrian Refugees

oversight activities of PIOs receiving voluntary contributions to assist 

Syrian refugees:

• Maintaining and periodically renegotiating a framework for 

cooperation: In the case of UNHCR—PRM’s main PIO implementing 

partner—State negotiates a framework for cooperation with UNHCR 

on a biennial basis.15 The framework lays out shared objectives and 

priorities; UNHCR’s biennial budget; description of UNHCR’s 

implementation of results-based managerial reforms; and measures to 

promote improved accountability, coordination, and monitoring. 

According to State officials, this framework is a key mechanism by 

which State provides oversight of the funds contributed to the 

organization.

• Reviewing audit, financial, and programmatic reports: According 

to State officials, staff in PRM’s Comptroller’s Office review financial 

reports and annual external audit reports provided by their 

implementing partners. In addition, program officers in Washington, 

D.C. and refugee coordinators in the field review reports submitted by 

PIOs to monitor performance of programs providing humanitarian 

assistance to Syrian refugees.

• Conducting monitoring visits: To obtain information on the 

progress of projects in the field, as well as overall advocacy efforts for 

Syrian refugees with the host governments, refugee coordinators and 

Washington, D.C.-based program officers conduct monitoring visits to 

observe operations at project sites and meet with PIO officials.

• Reviewing risk assessments and mitigation measures: State 

officials explained that they obtain and review information on risks and 

mitigation strategies from PIOs and use this information during 

monitoring visits. For example, according to State officials, during 

UNHCR’s annual country operations planning process, refugee 

coordinators obtain information on antifraud and anticorruption 

measures that UNHCR has implemented. We found evidence of this 

type of information sharing in our review of State’s documentation for 

UNHCR programs in Lebanon and Turkey. Moreover, according to 

State officials, PRM updated instructions in the award letter to PIOs 

requiring that activities funded by the contribution be conducted in 

accordance with the recipients risk management framework including 

 15 State/PRM and UNHCR negotiate the Framework for Cooperation between the United 

States Department of State’s Bureau of Population, Refugees, and Migration and the 

Office of the United Nations High Commissioner for Refugees, on a biennial basis. 
Page 23 GAO-18-58 Syrian Refugees

assessments addressing the risk of fraud, in response to a 

recommendation in our prior report on humanitarian assistance to 

people inside Syria. 16

• Participating in sector working group meetings: In some countries 

hosting Syrian refugees, State officials attend sector working group 

meetings on a quarterly basis to obtain information on the 

performance of programs and coordination efforts with other 

implementing partners, national governments, and local governments, 

according to State officials.

Similarly, USAID conducts various activities to monitor WFP, its sole 

implementing partner for food assistance to Syrian refugees. Examples of 

these activities include the following:

• Reviewing risk assessments: FFP officials said that they review the 

risk assessment submitted by WFP during the award process and are 

in regular contact with WFP officials to mitigate risks. In addition, FFP 

officials noted that the fiscal year 2017 USAID Annual Program 

Statement for International Emergency Food Assistance17 requires all 

implementing partners, including WFP, to submit a risk assessment.

• Creating country monitoring plans: FFP has begun creating 

country monitoring plans to ensure regular monitoring of all FFP 

programs in a given country. According to FFP officials, the country 

monitoring plans use a risk-based approach to prioritize the 

monitoring of country projects across the FFP portfolio, establish the 

number of site visits per month and year, determine which monitoring 

activities to conduct, and allocate staff resources. FFP officials have 

created monitoring plans for Egypt, Iraq, Jordan, Lebanon, and 

Turkey and these documents list the planned and conducted site visits 

per year.

• Conducting monitoring visits: FFP officials in the region and 

program officers in Washington, D.C. conduct in-person monitoring 

visits to WFP implementation sites, such as grocery stores in cities 

and refugee camps, in addition to meetings with WFP officials (see 

fig. 12). FFP’s Monitoring and Evaluation Team has developed 

templates and questionnaires to assist field officers responsible for 

 16 GAO-16-629.

17 International Emergency Food Assistance funds food assistance programs for Syrian 

refugees in the region. 
Page 24 GAO-18-58 Syrian Refugees

monitoring projects, and according to FFP officials, the Monitoring and 

Evaluation Team is in the process of expanding available resources 

for the program monitoring visits.

Figure 12: Food for Peace, World Food Programme and GAO Officials Visit a 

Grocery Store in Za’atari Camp, Jordan

• Attending working group meetings and reviewing reports: FFP 

officials stated that they attend sector working group meetings; and 

review various reports, such as monthly situational reports and 

quarterly monitoring reports submitted by WFP.

State conducts a variety of activities—assessing institutional and 

terrorism risk of awards to implementing partners, developing risk-based 

monitoring plans, performing site visits, and conducting financial and 

administrative monitoring—to provide financial oversight of awards to 

NGOs supplying humanitarian assistance to Syrian refugees. State’s 

2016 FAPD notes the importance of having a risk-based management 

framework that emphasizes reducing fraud and other risks while 

improving performance and program outcomes. We found that State has 

created such a framework for its financial oversight of NGOs in our 

sample of funding instruments, which generally consists of the following 

activities:

State Has Created a RiskBased Management 

Framework for Financial 

Oversight of NGOs
Page 25 GAO-18-58 Syrian Refugees

• State conducts preaward risk assessments: The FAPD requires 

officers to identify, assess, and mitigate risk during the preaward 

phase and to ensure that each foreign assistance award is made in 

the best interest of the U.S. government. In response to this policy, 

PRM conducts a risk assessment of proposals before funding them to 

determine the risks these potential awards pose to PRM’s overall 

objective of providing humanitarian assistance, and we found that 

PRM conducted these risk assessment for all funding instruments (25 

of 25) in our sample. This process includes assessing several 

elements—such as the financial history of the organization, the extent 

to which the organization has significant audit findings, the reporting 

history of the organization from prior PRM awards, the risk of 

diversion or misuse of assistance, and the location of the 

program/implementation site(s)—to determine both the institutional 

and terrorism risks of activities by implementing partners. Programs 

implemented in areas characterized by access restrictions (i.e., travel 

restrictions) for U.S. officials receive higher risk ratings. Higher risk 

ratings demonstrate increased risk. For the preaward risk 

assessments in our sample, 17 of 25 had received a higher rating due 

to this condition. To determine the institutional and terrorism risks, 

PRM program officers assess several risk-related elements and 

categorize the resulting scores on a scale from low, relatively low, 

medium, to high risk. Based on our review of the 25 NGO awards in 

our sample, we found that State assigned risk levels ranging from low 

to medium for institutional risk and terrorism risk. Three awards were 

rated as having medium institutional risks, and the remaining 22 

awards were rated as low, or relatively low, risk. Four awards in our 

sample were rated as having a medium risk of terrorism, due to 

several factors, such as implementing cash assistance programs in 

areas with limited access to U.S. officials, the risk of potential conflict, 

or the presence of known terrorist organizations in those areas.

• State uses risk assessments to develop risk-based monitoring 

plans and to conduct site visits: State officials told us they assess 

various types of information they have collected from implementing 

partners, such as risk assessments, program activity reports, and 

monitoring and evaluation plans prepared by implementing partners, 

to develop and implement their own risk-based monitoring plans that 

allow them to determine and apply the appropriate level of oversight 

during the lifecycle of an award. The monitoring plans specify the 

number and frequency of site visits that State has determined to be 

appropriate to provide oversight. Based on our review of 

documentation associated with fiscal year 2015 NGO funding 

instruments in our sample, we found that State officials incorporated 
Page 26 GAO-18-58 Syrian Refugees

that information into their monitoring plans for that partner. We also 

found that, in the case where an NGO implementing partner in our 

sample reported instances of fraud in its program, State officials 

included that information in their monitoring plan for that partner. 

Refugee coordinators (PRM officials based at embassies or 

consulates abroad) and refugee specialists (locally employed staff 

who work with them) primarily conduct the quarterly monitoring visits. 

Program officers from Washington, D.C., also make field visits and 

maintain contact with implementing partners by telephone or email, 

according to State officials. We accompanied refugee coordinators 

and refugee specialists on their quarterly visits to 14 organizations in 

Jordan and Lebanon during our fieldwork and observed, for example, 

refugee coordinators and refugee specialists observing activities at 

the project site, reviewing the progress of the program in relation to its 

performance metrics, interviewing beneficiaries, and inspecting 

physical facilities, among other activities (see fig. 13). In addition, 

State officials told us that program officers in Washington, D.C., 

provide refugee coordinators with information from quarterly financial 

and programmatic reports to discuss with implementing partners 

during these visits, which we observed.
Page 27 GAO-18-58 Syrian Refugees

Figure 13: GAO, Nongovernmental Organization, and Department of State Officials 

Interviewing Beneficiaries of a Shelter Improvement Project near Irbid, Jordan

• State provides training to refugee staff for conducting financial 

and administrative monitoring: State has developed training for 

financial and administrative monitoring to prepare refugee 

coordinators, program officers in Washington, D.C., and locally 

employed staff to conduct annual financial and administrative 

monitoring visits, according to State officials. In addition, in cases 

where implementing partners have reported incidents of fraud and 

misuse, PRM has deployed staff from Washington, D.C, to review the 

organization’s financial controls and provide training to the affected 

implementing partners. State officials we interviewed in the field found 

the training to be beneficial to conducting their duties, given that they 

are not specialists in accounting or financial monitoring.

• State conducts financial and administrative monitoring: Refugee 

coordinators, refugee specialists, and Washington, D.C.-based 

program officers conduct an annual financial and administrative 

review of the financial and internal controls that NGO implementing 

partners have in place. State officials told us that the purpose of this 
Page 28 GAO-18-58 Syrian Refugees

monitoring is to understand the extent to which implementing partners 

are aware of their own internal controls framework and the extent to 

which they are following it. For example, State officials review 

documentation to ensure that salaries paid agree with the approved 

budget, that there is appropriate segregation of duties for purchasing 

and payment functions, and that implementing partners have 

vouchers for all travel-related expenses, among other procedures. In 

addition, refugee coordinators and refugee specialists select and 

review a nonprobability sample of vouchers to ensure that 

implementing partners have appropriate internal controls for 

documenting purchases of goods and services paid with State 

funding. Implementing partners we met with in Jordan noted benefits 

of the financial and administrative monitoring—they stated that the 

process provided them with greater insight on how to structure their 

internal controls to meet the reporting requirements under the terms of 

the cooperative agreement. These officials also stated that financial 

and administrative monitoring was an effective capacity-building 

exercise for training subimplementers on how to structure their 

controls to meet the reporting requirements for the implementing 

partner and State.

According to Standards for Internal Control in the Federal Government,

18

management should implement control activities through policies and 

periodically review such policies and related control activities, such as the 

development and implementation of monitoring plans, for continued 

relevance and effectiveness in achieving objectives or addressing related 

risks. State and USAID have developed risk-based monitoring plans that 

specify the number and frequency of site visits they have determined are 

necessary to ensure adequate program monitoring in each country. Site 

visits are an integral part of financial oversight and a key control to help 

ensure that management’s objectives are carried out. They allow U.S. 

officials to physically verify the projects’ implementation, observe cash 

disbursements, and conduct meetings with beneficiaries and the staff of 

the organizations to determine whether the project is being implemented 

in accordance with the award. However, embassy security restrictions 

constrain State and USAID officials’ ability to conduct in-person 

monitoring visits in Iraq, Lebanon, and Turkey, which limits their ability to 

ensure financial oversight of humanitarian assistance funding.

 18GAO-14-704G.

Security Restrictions Limit 

Planned Monitoring Visits 

and Inhibit In-Person 

Oversight
Page 29 GAO-18-58 Syrian Refugees

State officials located at the U.S. consulate in Erbil, Iraq explained that 

the ongoing operation to defeat the Islamic State of Iraq and Syria (ISIS) 

in northern Iraq and the general threat of terrorist attacks make Iraq a 

difficult environment in which to conduct monitoring visits of implementing 

partners.19 In Lebanon, U.S. officials face threats of violence due to 

political instability, internal conflict from sectarian tensions, and the 

presence of terrorist organizations such as Hezbollah.20

Due to the security environment in Iraq and Lebanon, U.S. government 

officials must live on U.S. government compounds, arrange all meetings 

off-compound at least 24 hours in advance, and travel in armored 

vehicles with armed security personnel. According to officials in both 

countries, reserving an armored vehicle and security personnel to 

conduct site visits can be difficult given the demand for these limited 

resources at the embassy. In addition, areas of the country judged to 

pose a greater security risk require an in-person security review by the 

regional security office in advance of the visit, according to officials. 

Furthermore, State and USAID officials said that in Lebanon there is very 

limited housing available on the embassy compound, making it very

difficult for U.S. government agencies to obtain additional personnel to 

meet operational needs. In Lebanon, State has a refugee coordinator 

based in the embassy in Beirut, but USAID does not have an FFP officer 

in the country. Rather, one of the FFP officers based in the U.S. embassy 

in Amman, Jordan, has the responsibility of monitoring FFP funding for 

programs in Lebanon. However, according to State and USAID officials, 

obtaining approval to visit the country can be difficult, even for just a few 

days.

State and USAID officials also identified security conditions as a limiting 

factor in their program monitoring in Turkey, as they are sometimes 

unable to conduct in-person monitoring visits because of security 

conditions, particularly in areas near the Syrian border. According to State 

 19 According to State officials, nearly all the Syrian refugees in Iraq are Syrian Kurds 

located in the Iraqi Kurdistan region, an autonomous region within Iraq. Officials noted that 

the Iraqi Kurdistan Region has its own government, manages assistance programs for 

refugees, and is generally receptive to hosting and assisting refugees because of the 

cultural and historical ties among Kurds.

20 In GAO-14-161, we noted that Hezbollah is a powerful Islamic militant and political 

group funded by Iran, and has been designated by the United States and Israel as a 

terrorist organization. We also noted that instability arising from the civil war in neighboring 

Syria that began in 2011 has exacerbated sectarian conflict within Lebanon. In May 2013, 

Hezbollah leaders confirmed their intervention in the Syrian conflict. 
Page 30 GAO-18-58 Syrian Refugees

officials and USAID, State has two refugee coordinators based in Turkey, 

and USAID has two FFP officers in the country as well.

Our review of State and USAID documentation for the funding 

instruments in our sample shows that because of restrictions imposed by 

the embassy due to the security condition in those locations, U.S. officials 

faced the following challenges in fully implementing the monitoring plans:

• Iraq: FFP officials were not able to complete any site visits or observe 

any activities, aside from one visit to a WFP warehouse, in fiscal 

years 2015 through 2017. In addition, according to the monitoring 

plan, multiple requests to conduct site visits in the area where Syrian 

refugee camps are located were denied by the regional security office.

• Lebanon: FFP officials completed 7 of 10 planned site visits in 

Lebanon in fiscal years 2015 through 2017, although 1 was 

postponed due to embassy space constraints. Further, the FFP officer 

conducted three additional phone conferences from Amman, Jordan, 

during this period due to travel restrictions. However, no one from 

FFP visited WFP programs in Lebanon between August 2016 and 

March 2017, a period of 7 months, despite the fact that USAID 

obligated about $87 million to these programs in fiscal years 2016 and 

2017. FFP officials explained that obtaining approval from the 

embassy to visit Lebanon had been difficult, and the embassy 

postponed a FFP official’s monitoring visit during the 7-month period, 

due to security restrictions. In addition, FFP officials told us that they 

thought it was important to be able to travel to program destinations 

and conduct oversight, regardless of security concerns.

• Turkey: In fiscal years 2015 and 2016, State officials had completed 

22 of 26 planned site visits in person, and conducted the remaining 4 

over the phone or through email, due to security concerns in Turkey. 

For USAID, FFP officers completed 16 of 20 planned monitoring visits 

in fiscal years 2015 through 2017. Four monitoring visits were 

cancelled by the regional security office due to security concerns.

In addition to planned in-person monitoring visits, refugee coordinators in 

Iraq and Turkey noted that security-related restrictions create challenges 

to completing their annual financial and administrative monitoring visits. 

According to State officials, these visits can take several hours, which 

make them difficult to conduct in areas where the security situation has 

prompted the embassy to impose restrictions on the movement of U.S. 

government employees. For example, according to the refugee 

coordinator in Iraq, she could not conduct these types of monitoring visits 

because they can require roughly 6 hours to complete, and consulate 
Page 31 GAO-18-58 Syrian Refugees

officials in northern Iraq are limited to 2 hours off compound. State 

officials in Turkey told us that they face similar restrictions when traveling 

to the border area with Syria to conduct these types of monitoring visits.

In general, State and USAID officials noted the importance of in-person 

monitoring at program sites and expressed concern that monitoring visits 

were not always possible. These visits provide them with an opportunity 

to observe and assess various aspects of program implementation and to 

identify potential problems. Without full implementation of their monitoring 

plans—i.e., conducting all planned in-person monitoring visits—State and 

USAID officials are limited in their ability to ensure financial oversight of 

humanitarian assistance funding. State officials have taken one 

measure—hiring locally employed staff 21 in Iraq, Lebanon, and Turkey to 

assist refugee coordinators with oversight activities— but neither State 

nor USAID has implemented additional mechanisms that might allow 

them to conduct more in-person monitoring visits in areas where the 

security restrictions limit access for U.S. government personnel. 

According to State officials, locally employed staff are not subject to the 

same security restrictions, and having these staff complete monitoring 

visits has allowed State to have visibility over the programs in areas of the

country that U.S. government personnel cannot access.22 For instance, 

in Lebanon, State used its locally employed staff person to conduct 20 of 

24 monitoring visits to implementing partners in our sample, in fiscal 

years 2015 and 2016. USAID has not taken a similar approach to hiring 

locally employed staff in these countries, although FFP officials explained 

that they are considering hiring a locally employed staff person in Amman 

to periodically travel to Lebanon to conduct monitoring visits of WFP 

programs, as they could travel to Beirut without embassy support. State 

officials in Iraq mentioned the possibility of expanding an existing contract 

with an independent third-party monitor for assistance programs for 

internally displaced Iraqi citizens to incorporate in-person monitoring for 

Syrian refugee programs in restricted areas. However, State has not 

taken action to expand the contract. According to PRM officials in 

Washington, D.C., they continue to discuss ways to expand an existing 

 21 Under State guidance, “locally employed staff” is the general term for foreign service 

nationals as well as some U.S. citizens who ordinarily reside in the host country and are 

thus subject to its labor law. Foreign service nationals are non-U.S. citizens employed at a 

U.S. mission and are under chief-of-mission authority. 

22 According to State/PRM officials, while locally-employed staff are subject to fewer 

security restrictions than U.S. officials, their personal safety and security are key 

considerations in any monitoring on behalf of the Department of State. 
Page 32 GAO-18-58 Syrian Refugees

third-party monitoring contract to incorporate the Syrian refugee program 

in Iraq, but no final decisions have been made.

We have found that agencies can pursue alternative mechanisms for 

monitoring programs when security conditions limit travel by U.S. 

government personnel. For example, in a 2010 report on monitoring 

foreign assistance programs in the Federally Administered Tribal Areas of 

Pakistan, we noted that U.S. agencies had undertaken several efforts to 

monitor implementation and verify the results of their programs in areas 

too dangerous for U.S. officials to access.23 The report noted that USAID 

had developed several procedures, such as hiring locally employed staff 

to conduct site visits and report on the conditions of the programs, and 

reviewing implementing partner reports, among other procedures.

The ongoing conflict in Syria has contributed to the largest refugee crisis 

since World War II, with more than 5 million Syrians displaced to 

neighboring countries. The United States has taken a leading role in 

providing humanitarian assistance to those affected by the Syrian conflict, 

obligating more than $3 billion, primarily in the form of voluntary 

contributions and grants to PIOs. Given the challenges of implementing 

projects during an emergency, the importance of financial oversight—

which includes understanding the risks that implementing partner 

organizations face and monitoring their activities to mitigate these risks—

is elevated. State and USAID have taken steps to provide financial 

oversight of humanitarian assistance, such as collecting and using 

information on risks, conducting site visits, and providing training to staff. 

However, given the security conditions inside some of the countries 

hosting Syrian refugees, State and USAID are not able to complete all of 

their scheduled monitoring visits, including in Lebanon, where programs 

with the largest share of U.S. humanitarian assistance obligations are 

implemented. In-person monitoring visits are a valuable source of 

information for State and USAID, and without such visits, financial 

irregularities may go unnoticed or take longer to detect. State and USAID 

have not secured additional mechanisms that could assist their 

monitoring efforts in countries where security conditions limit in-person 

oversight opportunities by U.S. government officials. As the conflict 

continues, refugees’ needs are mounting and the international community 

 23GAO, Combatting Terrorism: Planning and Documentation of U.S. Development 

Assistance in Pakistan’s Federally Administered Tribal Areas Need to Be Improved, 

GAO-10-289 (Washington, D.C.: Apr. 15, 2010). 

Conclusions
Page 33 GAO-18-58 Syrian Refugees

has limited resources to deal with several ongoing humanitarian crises. 

Therefore, implementing mechanisms to enhance in-person monitoring 

visits would help ensure that assistance is being used properly and 

reaching the intended beneficiaries.

We are making a total of two recommendations, including one to State 

and one to USAID:

State’s Bureau of Population, Refugees and Migration (PRM) should 

identify and implement a mechanism to conduct in-person monitoring 

visits in countries where security conditions limit such visits by PRM 

officials. (Recommendation 1)

USAID’s Office of Food for Peace (FFP) should identify and implement a 

mechanism to conduct in-person monitoring visits in countries where 

security conditions limit such visits by FFP officers. (Recommendation 2)

We provided a draft of this report to State and USAID for review and 

comment. State and USAID provided written comments that are 

reproduced in appendix III and appendix IV. State and USAID also 

provided technical comments, which we incorporated as appropriate.

State concurred with our recommendation and noted that it will work to 

identify mechanisms to be implemented for conducting additional inperson monitoring visits in Turkey, Lebanon, and Iraq where security 

conditions prevent U.S. personnel from regularly accessing PRM funded 

programming. In addition, State noted that it is currently seeking to add 

Syrian refugee programming in northern Iraq to the scope of an existing 

contract for third-party monitoring of PRM programs assisting internally 

displaced persons. Finally, State indicated that it will continue to employ 

locally hired refugee specialists in Jordan, Iraq, Lebanon, and Turkey to 

conduct in-person monitoring.

USAID also concurred with our recommendation and noted that it is 

developing a request to the U.S. Embassy in Jordan to hire a foreign 

service national—a locally employed staff member—to be based in 

Jordan with responsibility for monitoring humanitarian assistance 

programming in Lebanon. Further, USAID stated that it is also examining 

the feasibility of other options if approval for this position is not granted.

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 34 GAO-18-58 Syrian Refugees

We are sending copies of this report to appropriate congressional 

committees, the Secretary of State, the Administrator of USAID, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.

If you or your staffs should have any questions about this report, please 

contact me at (202) 512-9601 or melitot@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix V.

Thomas Melito

Director, International Affairs and Trade
Page 35 GAO-18-58 Syrian Refugees

List of Requesters

The Honorable Ileana Ros-Lehtinen

Chairman

The Honorable Ted Deutch

Ranking Member

Subcommittee on the Middle East and North Africa

Committee on Foreign Affairs

House of Representatives

The Honorable Gerald E. Connolly

House of Representatives

The Honorable Ron DeSantis

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-18-58 Syrian Refugees

You asked us to review U.S. efforts to provide humanitarian assistance to 

individuals affected by the conflict in Syria. In this report we examine 

humanitarian assistance provided by the United States to Syrian refugees 

in the Middle East, including (1) how much funding has been obligated 

and what types of assistance have been provided, and (2) the extent to 

which State and USAID provide financial oversight of such assistance.

To determine how much funding has been obligated by State and USAID, 

as well as the types of humanitarian assistance provided by their 

implementing partners, we obtained State and USAID obligations data for 

fiscal years 2012 through 2017 and analyzed relevant program 

documents, including the program descriptions provided by implementing 

partners in their funding applications. We determined that these data 

were reliable for reporting total obligations per country by checking the 

obligations data against data reported by State and USAID in other 

sources. We also reviewed relevant UN and other reports, such as those 

produced for the Regional Refugee Resilience Plan.1 We analyzed this 

information to determine funding amounts for various types of assistance 

provided to Syrian refugees in the Middle East. To obtain additional detail 

on the types of assistance provided by the United States, we interviewed 

State and USAID officials in Washington, D.C., and traveled to Jordan, 

Lebanon, and Switzerland, to interview officials from State, USAID and 

their implementing partners. We also conducted telephone interviews with 

State Department officials in Turkey and Iraq to obtain information on the 

types of humanitarian assistance provided to Syrian refugees in those 

countries.

To determine the extent to which State and USAID provide financial 

oversight of the assistance, we obtained relevant policy documents, 

including State’s Federal Assistance Policy Directive2 and USAID’s Food 

for Peace Annual Program Statement, as well as guidance, risk 

assessments, and other documents related to program monitoring for the 

types of funding instruments used to provide humanitarian assistance to 

 1 According to United Nations High Commissioner for Refugees and the United Nations 

Development Programme, the Regional Refugee Resilience Plan (3RP) is a nationally led 

process that incorporates plans developed under the leadership of national authorities 

from the governments of Egypt, Iraq, Jordan, Lebanon, and Turkey, to ensure protection, 

humanitarian assistance and strengthen resilience.

2 In May 2017, State replaced the FAPD with a new policy document—the Federal 

Assistance Directive—which applies to awards issued as of May 20, 2017. We consulted 

both of these policy documents.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-18-58 Syrian Refugees

Syrian refugees. We examined the two USAID funding instruments for 

WFP that accounted for all USAID funding to Syrian refugees for fiscal 

years 2015 and 2016, and we also selected a nonprobability sample of 31 

fiscal year 2015 and 2016 State funding instruments from 14 different 

implementing partners, representing a range of dollar values, 

implementing partner locations, and types of humanitarian assistance. 

While not generalizable, the sample accounted for over 83 percent of 

State obligations for humanitarian assistance to Syrian refugees in the 

Middle East for those fiscal years. Using these funding instruments, the 

Foreign Assistance Policy Directive (FAPD), and Standards for Internal 

Control in the Federal Government,

3 we identified the relevant financial 

oversight activities for these instruments. For the purposes of this report, 

we focused our analysis on financial oversight activities related to internal 

control standards of risk assessment and program monitoring. In addition, 

we requested all State and USAID documentation related to the funding 

instruments in our sample and reviewed those that we received, including 

completed risk assessments, and program monitoring plans and reports. 

Furthermore, we interviewed State and USAID officials in Washington, 

DC; and officials from State and implementing partner organizations in 

Switzerland. We also met with officials from State, USAID, and 

implementing partner organizations in Jordan and Lebanon; and 

conducted telephone interviews with officials in Iraq and Turkey, to 

discuss their practices regarding risk assessments and control activities, 

as well as program monitoring practices and training. Additionally, we 

accompanied State officials on program monitoring visits in Lebanon and 

Jordan and met with 14 implementing partners altogether. We selected 

these countries to visit because they received the greatest amount of 

funding from State and USAID in fiscal years 2015 through 2016. Results 

are not generalizable.

We conducted this performance audit from August 2016 to October 2017 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 3 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sep. 2014).
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 38 GAO-18-58 Syrian Refugees

The ongoing conflict in Syria, which began in 2011, has displaced large 

numbers of people inside the country and within the Middle East. Initially, 

refugees from Syria fled mainly to Jordan, Lebanon, and Turkey. As the 

crisis persisted, larger numbers traveled to Turkey, with UNHCR reporting 

nearly 1 million seeking protection there in 2015. The population of 

registered Syrian refugees in neighboring countries had largely stabilized 

by late 2016, according to State officials.

Several factors, such as geographic accessibility and government 

policies, have affected Syrian refugees’ patterns of settlement in host 

countries. About 90 percent of Syrian refugees are living in urban and 

rural areas among host country populations, according to UNHCR, 

although some refugee camps exist. Furthermore, the security situation in 

each host country varies, though each faces a threat from terrorist groups 

or incidents of domestic unrest, according to State. As a result, there are 

travel restrictions for U.S. government personnel in each country. See 

figures 14 through 18 for detailed maps of where Syrian refugees have 

settled in each of the five main host countries, as of December 2016, as 

well as a description of the security situation in each country.

Appendix II: Location of Syrian Refugees 

and U.S. Government Travel Restrictions in 

Egypt, Iraq, Jordan, Lebanon, and Turkey
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 39 GAO-18-58 Syrian Refugees

Figure 14: Number and Location of Registered Syrian Refugees in Egypt, as of 

December 2016

Egypt: Egypt has the smallest population of Syrian refugees in the 

region, with most registered individuals residing in the Greater Cairo area. 

There is also a large population of Syrian refugees in Alexandria.

U.S. government personnel in Egypt face threats from terrorist and violent 

political opposition groups. The Department of State (State) reports that 

terrorist attacks can occur anywhere in the country, including major 

metropolitan areas, and U.S. government personnel are prohibited from 

traveling to the Western Desert and the Sinai Peninsula.
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 40 GAO-18-58 Syrian Refugees

Figure 15: Number and Location of Registered Syrian Refugees in Iraq, as of 

December 2016

Iraq: Most registered Syrian refugees in Iraq are located in the Iraqi 

Kurdistan region in the north, particularly in the areas surrounding Erbil 

and Duhok. Nearly 40 percent of Syrian refugees live in official refugee 

camps. The largest camps are Domiz 1 Camp near Duhok, with about

32,000 registered Syrian refugees, and Darashakran near Erbil, with 

approximately 11,000 registered Syrian refugees.

Numerous terrorist and insurgent groups are active in Iraq, including the 

Islamic State of Iraq and Syria (ISIS). Anti-U.S. sectarian militias may also 

threaten U.S. citizens and western companies throughout Iraq. According 

to State, the U.S. government considers the potential personal security 

threats to U.S. government personnel in Iraq to be serious enough to 

require them to live and work under strict security guidelines. All U.S. 

government employees under the authority of the U.S. Chief of Mission 

must follow strict safety and security procedures when traveling outside 

the embassy and consulates. The mission will regularly restrict or prohibit 

movements by its personnel, often on short notice, due to security threats 

or demonstrations.
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 41 GAO-18-58 Syrian Refugees

Figure 16: Number and Location of Registered Syrian Refugees in Jordan, as of 

December 2016

Jordan: Syrian refugees in Jordan are clustered in the northwestern part 

of the country near the border with Syria. Most refugees are in urban or 

rural areas outside of camps, particularly in the governates of Amman, 

Irbid, Mafraq, and Zarqa. There are two large Syrian refugee camps—

Za’atari, established early on in the crisis, currently has about 80,000 

residents, and Azraq, which was established more recently, has about 

53,000 registered Syrian refugees—as well as one smaller official camp.

According to State, ISIS, its affiliates, sympathizers, and other violent 

extremist groups have successfully conducted attacks in Jordan and 

continue to plot against local security forces, U.S. and Western interests, 

and “soft” targets. Jordan’s prominent role in the counter -ISIS coalition 

and its shared borders with Iraq and Syria increase the potential for future 

terrorist incidents. All U.S. government personnel on official travel must 

receive prior permission to visit any area within 10 kilometers from the 

Jordan--Syria border, which includes the town of Ramtha. U.S. 

government personnel must also have permission for official travel on 

Highway 10 east of the town of Ruwayshid toward the Iraq border. On 
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 42 GAO-18-58 Syrian Refugees

occasion, the U.S. embassy temporarily makes other areas within Jordan 

off limits to its staff based on the security situation.

Figure 17: Number and Location of Registered Syrian Refugees in Lebanon, as of 

December 2016

Lebanon: Approximately 20 percent of the registered Syrian refugees in 

Lebanon are living in informal tented settlements (ITS), including in the 

Bekaa Valley region in the east of the country. According to UNHCR 

officials, throughout the crisis, the government has disavowed formal 

refugee camps and discouraged any long-term solutions for the refugees. 

The ITS lack permanent infrastructure, such as water and sewer systems, 

and according to State officials, residents often lack access to education 

and livelihood opportunities. Large concentrations of urban refugees can 

be found in Beirut and surrounding areas, as well as in the city of Tripoli 

in the north.

Violent extremist groups operate in Lebanon, including U.S. governmentdesignated terrorist organizations Hezbollah, ISIS, Al-Nusrah Front, 

Hamas, and the Abdullah Azzam Brigades, according to State. U.S. 

citizens have been the targets of terrorist attacks in Lebanon in the past. 
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 43 GAO-18-58 Syrian Refugees

The threat of anti-Western terrorist activity persists, as does the risk of 

death or injury as a nontargeted bystander. State considers the threat to 

U.S. government personnel in Beirut sufficiently serious to require them to 

live and work under strict security restrictions. The internal security 

policies of the U.S. embassy may be adjusted at any time and without 

advance notice. These practices limit, and may prevent, access by U.S. 

embassy officials to certain areas of the country, especially to parts of 

metropolitan Beirut, Tripoli, the Bekaa Valley, refugee settlements, 

Palestinian refugee camps, and southern Lebanon.

Figure 18: Number and Location of Registered Syrian Refugees in Turkey, as of 

December 2016

Turkey: More than 90 percent of Syrian refugees live outside camps in 

cities and towns across Turkey, with large concentrations in Istanbul and 

Ankara. The Turkish government, which is in charge of registering Syrian 

refugees and maintains all registration data, has established a number of 

refugee camps along Turkey’s border with Syria that house approximately 

9 percent of Syrian refugees.
Appendix II: Location of Syrian Refugees and 

U.S. Government Travel Restrictions in Egypt, 

Iraq, Jordan, Lebanon, and Turkey

Page 44 GAO-18-58 Syrian Refugees

State warns of increased threats from terrorist groups in Turkey, including 

the potential for reprisal attacks by terrorist groups due to continued 

Turkish military activity in Syria. U.S. government personnel living in or 

visiting Turkey continue to require approval from the U.S. embassy to visit 

the southeastern provinces of Hatay, Kilis, Gaziantep, Sanliurfa, Sirnak, 

Diyarbakir, Van, Siirt, Mus, Mardin, Batman, Bingol, Tunceli, Hakkari, 

Bitlis, and Elazig. Travel within Adana by U.S. government personnel may 

also be subject to restriction. Furthermore, the U.S. embassy may prohibit 

movements by its personnel and those of its subordinate consulates to 

these areas on short notice for security reasons.
Appendix III: Comments from the Department 

of State

Page 45 GAO-18-58 Syrian Refugees

Appendix III: Comments from the

Department of State
Appendix III: Comments from the Department 

of State

Page 46 GAO-18-58 Syrian Refugees
Appendix III: Comments from the Department 

of State

Page 47 GAO-18-58 Syrian Refugees
Appendix IV: Comments from the U.S. Agency 

for International Development

Page 48 GAO-18-58 Syrian Refugees

Appendix IV: Comments from the U.S. 

Agency for International Development
Appendix IV: Comments from the U.S. Agency 

for International Development

Page 49 GAO-18-58 Syrian Refugees
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 50 GAO-18-58 Syrian Refugees

Thomas Melito, (202) 512-9601, or melitot@gao.gov.

In addition to the contact named above, Elizabeth Repko (Assistant 

Director), Jason Bair (Assistant Director), Jennifer Young, Kyerion 

Printup, Lynn Cothern, Rathi Bose, Kimberly McGatlin, Justin Fisher, Neil 

Doherty, and Alexander Welsh made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact:

Staff 

Acknowledgments:

(101082)
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