OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

July 29, 2008 

MEMORANDUM FOR SECRETARY OF STATE 

SECRETARY OF DEFENSE 

U.S. AMBASSADOR TO IRAQ 

COMMANDING GENERAL, MULTI-NATIONAL FORCE - IRAQ 

SUBJECT: Anticorruption Efforts in Iraq: U.S and Iraq Take Actions but Much Remains to Be 

Done (SIGIR 08-023) 

We are providing this report for your information and use. We performed this audit under the 

authority of Public Law 108-106, as amended, which also incorporates the duties and 

responsibilities of inspectors general under the Inspectors General Act of 1978, as amended. 

This report is the latest in a series of reports by the Special Inspector General for Iraq 

Reconstruction (SIGIR) on U.S. government anticorruption efforts in Iraq. SIGIR instituted 

reviews consistent with its mandate to review reconstruction activities in Iraq. Preventing and 

fighting corruption is key to accomplishing Iraq’s economic, social, and political reconstruction. 

SIGIR has described corruption in Iraq as the “second insurgency.” This report was conducted 

as SIGIR Project 8023. 

We considered written comments on a draft of this report from the U.S. Ambassador to Iraq, and 

the Multi-National Security Transition Command-Iraq when finalizing this report. The 

comments are addressed in the report, where applicable, and are included in their entirety in 

appendix D. 

We appreciate the courtesies extended to the staff. For additional information on the report, 

please contact Glenn Furbish, Deputy Assistant Inspector General for Audits (703) 428-1058/ 

glenn.furbish@sigir.mil. 

 Stuart W. Bowen, Jr. 

 Inspector General 
Table of Contents 

Executive Summary i 

Introduction 1

U.S. Has Taken Actions but Much Remains To Be Done 2

Government of Iraq Anticorruption Activities 7

Conclusion 11 

Recommendations 11 

Matter for Congressional Consideration 12 

Management Comments and Audit Response 12

Appendices 

A. Scope and Methodology 14 

B. Status of SIGIR Recommendations 16 

C. Acronyms 19 

D. Audit Team Members 20 

Management Comments 

U.S. Embassy - Iraq 21 

Multi-National Security Transition Command-Iraq 24 
Anticorruption Efforts in Iraq: U.S. and Iraq Take 

Actions but Much Remains to be Done

SIGIR-08-023 July 29, 2008

Executive Summary 

Introduction 

SIGIR has issued four reports addressing U.S. Embassy efforts to manage a multitude of U.S. 

government agency anticorruption programs, including those of the Department of State (DoS), 

Department of Justice, U.S. Agency for International Development (USAID), and Multi-National 

Force-Iraq (MNF-I). In a July 2006 report1

 SIGIR identified fundamental problems in 

implementing a U.S. anticorruption program such as the lack of coordination and leadership. 

SIGIR provided 12 recommendations to address these problems and to form a basis for assessing 

progress. For example, SIGIR recommended that DoS appoint a senior leader to direct the 

anticorruption program and provide continuity in program administration, and that a steering 

group be established to provide oversight over program activities and ensure that all agencies are 

working towards a common goal in an efficient and effective manner. In our April 2008 report2

SIGIR discussed how the U.S. Embassy had implemented actions to address two 

recommendations, but that actions were still needed to fully address the remaining ten. 

Our objectives for this report were to determine: 

• U.S. Department of State’s progress in implementing its revised anticorruption 

management plan, and addressing previous SIGIR recommendations, and 

• The anticorruption efforts of the Government of Iraq. 

Results 

Reducing corruption in Iraq will be a difficult and lengthy process, requiring a sustained 

commitment by all parties. Recent actions by the DoS and U.S. Embassy-Iraq show a continued 

commitment to improving the U.S. anticorruption program. Importantly, SIGIR determined that 

the Embassy has fully addressed 3 more of SIGIR’s previous 12 recommendations; 5 

recommendations are now closed. Some work has also been done to address the 7 open 

recommendations; however, more remains to be accomplished to fully establish and implement a 

comprehensive and effective program. Specifically, managers need to improve the existing 

program strategy and to address staffing and financial shortages. Enhanced U.S. Embassy 

oversight of anticorruption efforts should also improve program outcomes. 

 

1 Joint Survey of the U.S. Embassy-Iraq’s Anticorruption Program (SIGIR 06-021, July 28, 2006). 2 U.S. Anticorruption Efforts in Iraq: Progress Made in Implementing Revised Management Plan (SIGIR 08-016,

April 24, 2008) 

i
The U.S. anticorruption strategy that was produced in June 2008 was partially responsive to 

SIGIR’s recommendation. However, the strategy lacks metrics that tie program activities to 

goals, as well as baselines from which progress can be measured. Consequently, the U.S. 

government has not established a basis for assessing the program’s impact on reducing 

corruption in Iraq. This leaves future program investments vulnerable to wasteful spending, 

ineffectiveness and inefficiency. SIGIR also believes that the strategy could be improved by: 

• Capturing the lessons learned or best practices from previous U.S. and other donor 

anticorruption country programs around the world; 

• Identifying how it supports the Government of Iraq’s (GOI) anticorruption approach, or 

the extent to which the GOI is committed to the U.S. programs, and; 

• Identifying how the United States will address the emerging challenges of provincial 

leaders. 

The DoS and the Embassy have not moved aggressively to obtain the necessary program 

funding. The U.S. Embassy has identified $10 million in expired Iraq Relief and Reconstruction 

Fund (IRRF) funds as the primary funding source for new programs to support anticorruption 

efforts. These resources would be in addition to existing funding – such as USAID and 

International Narcotics and Law Enforcement Affairs funds – used for anticorruption related 

programs. In February 2008, the DoS submitted a request to Congress for these funds, but the 

Congress returned the request asking for additional details on how the money was to be used. As 

of July 9, 2008, the DoS had not resubmitted the request because it was still finalizing a list of 

anticorruption projects to be funded out of these monies. As a consequence, the level of 

resources that will be available for anticorruption activities is uncertain. 

As to the issue of program leadership, the Anticorruption Coordinator (Coordinator) informed 

SIGIR that efforts are made to share information between DoD and DoS entities implementing 

anticorruption programs but the approval of the Anticorruption Coordination Office (ACCO) of 

DoD activities is not required. For example, MNSTC-I meets with the ACCO and informs it of 

its efforts to bolster anticorruption training and execution in the Iraqi ministries of Defense and 

Interior, but is not required to vet its programs through the ACCO. SIGIR believes a formal 

leadership structure with the authority to ensure that all agency anticorruption activities address 

strategic plan priorities and that agencies work in concert, would improve program 

accountability and outcomes. 

Meanwhile, the GOI must do more to address corruption, though certain efforts have 

demonstrated progress. The U.S. Anticorruption Coordinator and the Chairman of the Iraq Joint 

Anticorruption Council (JACC) informed SIGIR that the improved security situation has 

increased the confidence of the GOI to begin to address the issue of corruption. For example, the 

GOI has ratified the United Nations (UN) Convention against Corruption (UNCAC), which can 

provide a roadmap to achieve anticorruption goals. Also, the Council of Representatives is 

currently considering draft legislation updating the mandates of the three primary anticorruption 

organizations of the GOI. Finally, GOI officials report progress addressing the 18 anticorruption 

initiatives identified in a January 2008 anticorruption conference. However, U.S. and UN 

officials remain concerned about the capacity of Iraq’s anticorruption organizations. Moreover, 

intimidation and threats continue to impede effective anticorruption efforts, and current GOI 

ii
regulations continue to have a corrosive effect on the perception of GOI’s commitment to 

aggressively address corruption. 

Recommendations 

SIGIR recommends that the Secretary of State expedite actions to provide the requested 

information to the Congress regarding the use of IRRF monies for anticorruption activities. 

SIGIR also recommends that the Ambassador direct the Coordinator for Anticorruption 

Initiatives to review the U.S. anticorruption strategy to ensure that it contains the following 

elements: 

• Recognition of global best practices in anticorruption programs 

• A description of how the U.S. strategy ties to the GOI anticorruption strategy and the 

anticorruption sections of the International Compact 

• A discussion of the GOI’s commitment and support for the U.S. approach and projects 

• Clear goals and objectives with criteria to measure progress 

• Local level anticorruption capacity building activities 

• A prioritization of anticorruption projects based on a strategic analysis of the need and 

resources available 

Moreover, SIGIR also recommends that the Ambassador and the Commanding General, MNF-I, 

work jointly to ensure that all U.S. government anticorruption programs, regardless of funding 

source or agency management, are fully vetted through and coordinated with the ACCO. 

Matter for Congressional Consideration 

Making meaningful and lasting changes to reduce corruption will require a sustained and lengthy 

effort on the part of the GOI and all groups seeking to help facilitate the process. Therefore, as 

the Congress considers future funding for this program it may wish to consider the need for 

dedicated funding predicated on the Embassy’s development of clear anticorruption goals, 

objectives and periodic reports on results. 

Management Comments and Audit Response 

The U.S. Ambassador and MNSTC-I provided written comments on a draft of this report.3 The 

comments are included in the Management Comments section of this report. In summary, the 

Ambassador stated that he did not believe that the report appropriately considers the full context 

in which anticorruption efforts are occurring. According to the Ambassador, the unique security 

situation has rendered inapplicable those lessons learned in other post-conflict environments, and 

a comprehensive assessment of Iraq’s anticorruption landscape and its anticorruption needs has 

 

3

 SIGIR’s quarterly reports generally summarize all audit reports issued during the quarter, including a synopsis of 

agency comments. However, SIGIR did not receive the Embassy’s comments in time to include them in our 

quarterly report. However, they are included in this final report. 

iii
not been possible due to the violence and sometimes chaotic on-the-ground realities. Only 

recently has the security situation made the prospect of making an assessment feasible, and the 

Embassy is taking steps to initiate the assessment. He also said that there is no comprehensive 

GOI anticorruption strategy. The Embassy has shared its approach with its GOI counterparts, 

but all elements of the GOI do not necessarily share the Embassy’s assessments or fully endorse 

what needs to be done. 

SIGIR recognizes the difficulties the Embassy faces in assessing corruption and promoting good 

governance in the midst of conflict and this report reflects those conditions. However, SIGIR’s 

criticism of the Embassy’s strategy is based not only on its lack of recognition of best practices, 

but also on its lack of clear overall anticorruption goals or specific and measureable objectives 

targeted at achieving these goals. Absent these features, program managers lack the tools to 

assess the effectiveness of their efforts and to make appropriate adjustment. Moreover, we also 

do not fully agree that all previous DoS experience in anticorruption and good governance 

activities in post-conflict environments are not applicable in Iraq. Structural difficulties the GOI 

experiences, such as a legacy that built into its mechanisms procedures and processes to advance 

it own corruption is not necessarily unique to Iraq. As such, USAID reports that it has 

implemented programs to advance the transparency and accountability of governments, train for 

and modernize the financial and judicial sectors, as well as to mobilize public support to pressure 

governments to make needed changes. We continue to believe that lessons learned from such 

efforts can be applicable to the condition in Iraq. The Ambassador also provided technical 

comments which we incorporated as appropriate. 

Both MNSTC-I and the Ambassador also expressed concern about a statement in the draft report 

that they do not coordinate their anticorruption activities with the ACCO. Our point was that no 

one single person or organization is accountable for all U.S. government anticorruption efforts. 

We acknowledge that MNSTC-I and the ACCO keep each other informed of their respective 

activities. We have added wording to this report to more specifically address MNSTC-I’s and the 

Ambassador’s point on coordination and our position on the need for greater program 

accountability. 

Finally, MNSTC-I expressed concern that SIGIR did not interview MNSTC-I officials or request 

documentation in the conduct of our review. The focus of this review was on how well the 

ACCO was addressing previous SIGIR recommendations, and planning and overseeing the U.S. 

government anticorruption program. As such, we did not perform new audit work specifically 

focused on MNSTC-I or, for example, Department of Justice management of anticorruption 

activities. However, we met with MNSTC-I personnel earlier this year during previous 

anticorruption work, and during this review attended Anticorruption Working Group meetings 

where MNSTC-I participated. We also out briefed MNSTC-I on the results of our work, 

particularly as it pertained to ACCO oversight of its activities. 

In our draft report, SIGIR discussed staffing issues within the Anticorruption Coordination 

Office. In his response to the draft, the Ambassador said that only one position remains vacant 

in this office. This is a positive step at this time. However, given that the Coordinator has 

expressed to SIGIR the difficulty he experiences in obtaining and retaining qualified staff, we 

continue to believe that the staffing issue remains a concern.

iv
Introduction

Background 

The U.S. Embassy and the Iraqi Prime Minister have stated that developing the capacity of the 

Government of Iraq (GOI) to address corruption is critical to GOI governance. The Ambassador 

reported that pervasive corruption poses a serious threat to Iraq’s stability and reconstruction 

efforts. Although data are not available to quantify the extent of corruption in Iraq, 

Transparency International determined that Iraq is perceived as one of the most corrupt nations 

in the world.4 Using polls and surveys, Transparency International concluded that Iraq was 

perceived as the most corrupt nation in the Middle East and North Africa and nearly the most 

corrupt nation in the world. Worldwide, out of 180 countries, only two other countries were 

perceived by its citizens as having a higher level of corruption than Iraq. 

SIGIR has issued four reports addressing U.S. Embassy efforts to manage a multitude of U.S 

government agency anticorruption programs, including those of the Department of State (DoS), 

Department of Justice, U.S. Agency for International Development (USAID), and Multi-National 

Force-Iraq (MNF-I). In a July 2006 report,5

 SIGIR identified fundamental problems that 

affected the implementation of U.S. anticorruption efforts such as a lack of coordination and 

leadership in anticorruption programs. SIGIR made 12 recommendations to address these 

problems and to establish a basis for assessing progress. SIGIR recommended, for example, that 

DoS appoint a senior leader to direct the anticorruption program and provide continuity in 

program administration, and establish a steering group to provide oversight over program 

management and ensure that all are working towards a common goal in an efficient and effective 

manner. In a July 2007 report, SIGIR assessed progress in implementing those 

recommendations and found that little progress had been made.6 SIGIR noted that the program 

lacked focus, the Embassy had not completed a recommended inventory and assessment of 

anticorruption activities, and the Embassy lacked a comprehensive, integrated plan that tied 

anticorruption activities to an overall U.S. Mission-Iraq strategy and a baseline to measure 

progress. SIGIR determined that as of June 30, 2007, the Embassy had fully implemented only 2 

of our 12 recommendations. In a January 2008 report,7

 SIGIR said that the U.S. Embassy-Iraq 

had developed and received DoS approval of a plan to improve the management of U.S. 

anticorruption activities, which included the appointment of a high ranking official to manage the 

anticorruption program. Our April 2008 report8

 discussed how the U.S. Embassy was beginning 

to implement the plan, but that actions were still needed to fully address the remaining ten SIGIR 

recommendations. 

 

4

 Transparency International Corruption Perceptions Index 2007 

5

, Joint Survey of the U.S. Embassy-Iraq’s Anticorruption Program (SIGIR 06-021, July 28, 2006) 6 Status of U.S. Government Anticorruption Efforts in Iraq (SIGIR 07-007, July 24, 2007) 7 U.S. Anticorruption Efforts in Iraq: Sustained Management Commitment is a Key to Success (SIGIR 08-008,

January 24, 2008) 

8 U.S. Anticorruption Efforts in Iraq: Progress Made in Implementing Revised Management Plan (SIGIR 08-016, 

April 24, 2008) 

1
U.S. Has Taken Actions but Much Remains to Be 

Done 

Recent actions by the DoS and U.S. Embassy-Iraq indicate a continued commitment to 

improving the U.S. anticorruption program. Since our last report, the Embassy has fully 

addressed 3 additional recommendations of the 12 made in our June 2006 report. However, 

more remains to be accomplished to fully establish and implement a comprehensive and 

effective program. Managers still need to address staffing difficulties and financial shortfalls, 

and U.S. management of anticorruption efforts needs improvement. Further, the Embassy’s June 

2008 anticorruption strategy still lacks metrics that tie objectives and programs to a goal, as well 

as baselines from which progress can be measured. 

Program Initiatives are Underway 

Since SIGIR’s last report in April 2008, the Anticorruption Coordination Office (ACCO) has 

continued to improve its management of anticorruption activities. The new management 

approach, which was approved by the Ambassador in January 2008 and which SIGIR described 

in depth in its last report, sought to elevate the importance of anticorruption activities within the 

Embassy, and to initiate specific actions in support of a reorganization plan. SIGIR concluded 

that full implementation of the plan should address all SIGIR recommendations. The 

Coordinator stated that to support the new approach, he has hired more staff, established a direct 

link to the Deputy Chief of Mission (DCM) on anticorruption issues, and reached out to the GOI 

and international partners on anticorruption issue. For example, the Coordinator noted that 

during the week of June 8-14, 2008, there were six meetings with United Nations (UN) 

personnel in Baghdad, as well as numerous emails and phone calls. 

As a result of these and other efforts, SIGIR found that the Embassy had met 3 more of our 12 

recommendations, These include (1) hiring an Iraqi to help forge U.S.-GOI anticorruption 

efforts, (2) providing periodic reports to the DCM on progress, barriers and funding needs, and 

(3) encouraging the GOI to establish relationships with regional and international partners. As 

such, the Embassy has fully addressed 5 out of the original 12 recommendations. Additionally, 

actions are underway that address the remaining 7 recommendations. 

Staffing 

Staffing shortages, aggravated by short term deployments have been a concern in managing the 

anticorruption program. Despite improvements in the structure and staffing of the ACCO, 

critical positions have gone unfilled and the Embassy has been relying on DoD personnel to 

temporarily fill vacant positions. The Coordinator informed us, for example, that the Deputy 

Coordinator position had not been filled. DoS officials informed us that they are attempting to 

address these issues. First, they noted that the U.S. Ambassador to Iraq has requested that all 

senior level officials, including the Coordinator, commit to staying two years at post. State 

officials noted that the Department has approved and funded all positions in the ACCO, and the 

Ambassador, in response to our draft, noted that he hoped to name a Deputy the week of July 28, 

2
2008. Nevertheless, the Coordinator reiterated to us that he faces continuing problems in finding 

qualified staff to fill positions. 

Funding 

Funding to support anticorruption activities remains uncertain. At present, the Embassy in Iraq 

does not have a funding stream dedicated to this effort. Rather, anticorruption activities are 

embedded within overarching programs, such as rule of law, and managed by the entity 

responsible for that activity such as the Department of Justice or USAID. To obtain funding, 

DoS submitted a request to Congress in February 2008, for $10 million in expired IRRF funds 

but the Congress returned the request asking for additional details on how the money was to be 

used. As of July 9, 2008 the DoS had not resubmitted the request because it was still finalizing a 

list of anticorruption projects to be funded out of these expired funds. 

Leadership 

SIGIR has consistently recommended that the U.S. Embassy establish a steering group that 

would have oversight of all U.S. government anticorruption programs to ensure that all 

initiatives are working toward a common goal in the most efficient and effective manner. We 

also recommended that the Ambassador establish a policy that would require all participating 

organizations to vet new anticorruption initiatives through an Embassy anticorruption steering 

group regardless of agency boundaries. Progress has been made in this area. However, DoS 

continues to rely on coordination rather than leadership of anticorruption activities. SIGIR 

continues to believe that program accountability and outcome would be improved if a joint 

executive steering group were created. 

To illustrate, in June 2008, the Ambassador instructed all mission elements “under his authority” 

to coordinate all anticorruption activities with the ACCO to ensure that they are consistent with 

the U.S. strategy. According to the ACCO Coordinator, DoD and DoS share information on 

their anticorruption activities, however, DoD is not required to obtain DoS approval for its 

activities. The Anticorruption Coordinator said that he is not aware of any conflicts between 

DoD and DoS activities, and that the coordination mechanism is effective. 

SIGIR acknowledges the coordination between DoD and DoS. However, we believe that 

implementing strategic plans and achieving objectives is more difficult when agencies can act 

unilaterally. Without a formal mechanism to ensure that all agency anticorruption activities 

address strategic plan priorities and that agencies work in concert, strategic plans become little 

more than guidance. For example, in a July 2006 SIGIR report on anticorruption we noted that 

there was no comprehensive list of ongoing anticorruption activities. An anticorruption working 

group that was leading the effort at that time said it was conducting an inventory of all ongoing 

anticorruption activities to identify areas of duplication and to determine where additional 

coordination is needed. However, two years later no inventory has been produced. SIGIR 

believes that designating an executive steering group and vesting it with accountability for 

anticorruption activities would eliminate problems like this and produce better results. 

3
Strategy Encouraging But Can Be Improved 

The U.S. Embassy has completed its SIGIR-recommended anticorruption strategy. The strategy 

is important to improving the management of the U.S. anticorruption program, but SIGIR 

believes it can be improved. 

The need for a comprehensive, integrated management strategy for anticorruption activities was 

first identified in a July 2007, SIGIR report on anticorruption along with the need for metrics that 

tie anticorruption activities to that plan. Since that time, the Embassy has drafted an 

Anticorruption Strategy Framework that outlines key elements for U.S. government engagement 

and programming. However, SIGIR’s analysis of the strategy shows that it still does not identify 

overall goals and measures for determining progress. The elements essential to strategic and 

performance planning are outlined in the Government and Performance Results Act (GPRA) of 

1993. The GPRA addresses the need to identify goals and objectives, a description of how the 

goals and objectives are to be achieved, and a description of program evaluations that can be 

used to revise goals and objectives. SIGIR believes GPRA standards are a good starting point 

from which to base an effective strategy. SIGIR’s analysis of the Embassy’s strategy identified 

objectives, and descriptions of how the objectives were to be achieved. However, the plan could 

be improved by including overall goals and measures for evaluating progress. 

A State Department official commented that the Department views this strategy more as a highlevel, macro overview than a strategic plan. Moreover, officials noted that given the difficulty in 

defining and measuring corruption, it is equally difficult to measure results unless they see clear 

indicators such as numbers of individuals prosecuted for corruption. They suggested that 

outputs, such as numbers of people trained, may be the best short term option to measure 

success. SIGIR recognizes the difficulty in measuring progress to curb corruption and that each 

implementing agency should have specific measurements for each of its programs. However, 

that does not negate the need to specify how all programs will be measured collectively for their 

progress in achieving broad goals and objectives. For example, the Embassy anticorruption 

strategy includes as a key element to meet its objectives engagement with the GOI to, among 

other things, eliminate the laws and regulations that inhibit the investigation and prosecution of 

corrupt activities. The strategy does not include criteria or metrics to evaluate progress. The 

type of information needed is illustrated in the GOI’s Commission on Integrity’s Strategy. For 

example, the Commission has a goal to amend laws and suggest new laws to counteract 

corruption. For that goal the strategy includes objectives, timeframes in which to complete each 

objective, the budget available for each objective and expected results. 

Other ways in which we believe the strategy could be improved include the following: 

• The plan should address lessons learned or best practices from previous U.S. and other 

donor anticorruption country programs around the world. To illustrate, USAID’s 2005 

worldwide anticorruption strategy emphasizes the need to develop programs based upon 

identification of a problem. Specifically, USAID identifies two types of corruption – 

“grand” and “administrative” corruption. The approaches to addressing grand and 

administrative corruption are different as grand corruption involves the exchange of 

resources, access or other advantages for high-level officials, privileged firms and their 

networks of elite operatives and supporters that can distort and manipulate entire systems 

4
to serve private interests. Administrative corruption usually refers to small transactions 

and mid-level and low-level government employees, and usually reflects specific 

weaknesses within systems. Responses to administrative corruption may include projects 

to support procurement and financial management reform and audit practices. 

The importance of identifying the type and extent of corruption is reflected in USAID’s 

caution that financing extensive bureaucratic reforms or new anticorruption agencies in 

countries with pervasive levels of corruption among high-level officials and members of 

the elite may not yield significant results. These interventions tend to work best in 

countries with a demonstrated commitment to address corruption. An official in the 

ACCO informed SIGIR that the Embassy agrees that building capacity of anticorruption 

institutions such as the CoI and BSA will have limited impact unless the GOI has the 

political will to create an environment that is conducive to their effective operation. As a 

result, he noted, the Mission plans to broaden the scope of the program to influence 

change in the overall government anticorruption environment. The strategy does not, 

however, include that change in approach or identify the type of corruption that the 

Embassy is dealing with. 

• The plan should identify how it supports the GOI anticorruption program and the extent 

to which the GOI is committed to the U.S. programs. Regarding U.S. support for GOI 

initiatives, the Chairperson of the Joint Anticorruption Council (JACC) voiced his 

concern over what he perceived to be declining levels of U.S. support for the Inspectors 

General (IGs) – a system the U.S. put in place at the beginning of the Iraq reconstruction 

effort. He noted that U.S. support for the IGs had declined after a former U.S. advisor 

left. Regarding GOI’s commitment, in previous audits, SIGIR found that the lack of GOI 

commitment jeopardizes the success of the project. For example, SIGIR reported on 

problems in developing an Iraq Financial Management Information System (IFMIS) 

which although not specifically an anticorruption program, if successful would have 

supported anticorruption efforts. Iraq’s financial structure was unable to monitor 

ministerial budgets and expenditures, leaving the ministries vulnerable to fraud, waste, 

and misappropriation of funds. The project was suspended for reasons related principally 

to security and the lack of GOI commitment.9

 SIGIR has also reported on difficulties in 

obtaining GOI support to assume responsibility for facilities the United States has 

constructed.10 

• The plan should identify how the U.S. will address the emerging challenges of provincial 

leaders. Specifically, the strategy notes that the move to elected provincial leaders will 

present new and difficult challenges from an anticorruption perspective. The United 

Nations Development Programme (UNDP) notes a similar need, especially as financial 

authority devolves to the provinces, and elections take place. However, there is no 

discussion of how the United States will meet the new challenge to assist in the 

development of anticorruption capacity at the local government level. In written 

comments on a draft of this report, the Ambassador said that a portion of the requested 

 

9 Interim Report on Efforts and Further Actions Needed to Implement a Financial Management Information System 

in Iraq (SIGIR-08-001, October 24, 2007); Efforts to Implement a Financial Management Information System in 

Iraq (SIGIR-08-007, January 25, 2008) 10 Transferring Reconstruction Projects to the Government of Iraq: Some Progress Made but Further Improvements 

Needed to Avoid Waste, (SIGIR- 08-017, April 28, 2008) 

5
IRRF funds is planned to go to the UNDP to support anticorruption institutions at the 

regional and provincial levels. 

In his written comments on a draft of this report, the Ambassador agreed that there is a need for a 

comprehensive assessment of Iraq’s corruption landscape and its anticorruption needs. 

However, he said that the traditional assessment process has not been possible due to the 

violence and sometimes chaotic on-the-ground realities. The Embassy indicated a portion of the 

requested reprogrammed IRRF is slated to be used for the United Nations Office of Drugs and 

Crime, who has a strong record working with countries on detailed self-assessments as part of 

their compliance with the UN Convention Against Corruption, to which Iraq acceded earlier this 

year. The Anticorruption Coordination Office is also actively pursuing expertise from the World 

Bank and other academic resources. 

6
Government of Iraq Anticorruption Activities 

The GOI has much to do to address corruption. However, the GOI has undertaken significant 

efforts. In a January 2008 conference, the GOI announced that it was kicking off a national 

campaign to deal with the epidemic of corruption and presented 18 specific anticorruption 

initiatives. The U.S. Anticorruption Coordinator informed SIGIR that the improved security 

situation has increased the confidence of the GOI to pursue corruption initiatives. For example, 

the GOI has ratified the UN Convention Against Corruption (UNCAC) which can provide the 

roadmap to achieve anticorruption goals. However, both U.S. and UN officials remain 

concerned about the capacity of the organizations to execute needed actions. Moreover, 

intimidation and threats continue to impede effective anticorruption efforts, and existing GOI 

regulations continue to have a corrosive effect on the perception of GOI’s commitment to 

aggressively address corruption. 

GOI Attempts to Formalize Anticorruption Activities 

In SIGIR’s April 2008 report, we noted that one key initiative announced at the January 2008 

conference was the drafting of legislation to harmonize the responsibilities of the anticorruption 

agencies. In its 2007 report on Iraqi human rights practices, DoS concluded that anticorruption 

institutions were fragmented and interaction among them was hampered by a lack of consensus 

on their role. The GOI has taken actions to formally institutionalize and clarify the roles and 

missions of its three principal anticorruption institutions - the BSA, CoI, and IGs. The GOI has 

done so by drafting three laws to replace the Coalition Provisional Authority (CPA) orders, 

which authorized the organizations. The draft laws make changes to better reflect UNCAC 

requirements and clarify the mandates of each organization. As of July 2008, the draft laws had 

gone through a second reading in the Council of Representatives. 

As discussed below, some evidence suggests that activity has increased in some of the 

anticorruption agencies, though all still confront significant problems. 

The Joint Anticorruption Council (JACC) 

The JACC was organized in 2007 to coordinate and formulate nationwide strategies to combat 

corruption, and comprises representatives from, among others, the Secretary General of the 

Council of Ministers and representatives from the BSA, CoI, IGs, and judiciary. The JACC 

Chairman informed SIGIR in June 2008 that it meets weekly but noted that its mission continues 

to evolve. To illustrate, the JACC initially began its work by attempting to coordinate the 

various Iraqi anticorruption organizations to eliminate overlap. It has since assisted in developing 

the 18 anticorruption initiatives introduced at the January 2008 anticorruption conference. In 

June 2008, the Chair of the JACC informed SIGIR that JACC had spent the last three months 

drafting the three draft laws coordinating the BSA, CoI and IGs’ missions and activities. The 

JACC also vets and recommends prospective Inspectors General. Currently, the JACC 

initiatives include supporting each ministry’s effort to establish an Internet website to promote 

transparency, and promoting a draft law to establish a Council of Public Service to encourage 

qualified Iraqis to enter government service. 

7
Commission on Integrity 

The CoI was established as an independent commission responsible for recommending and 

implementing laws to counter corruption, and initiatives for raising awareness and educating the 

public about the principles of transparency and integrity. With the assistance of the UNDP and 

Canadian advisors, the CoI developed a strategic plan that includes six strategic goals, including: 

(1) inspect and investigate possible cases of corruption; (2) promote the culture of patriotism, 

integrity and transparency; (3) complete disclosure of the financial interests of governmental 

officials; (4) develop the code of conduct for public servants; (5) review and amend laws and 

draft laws to counteract corruption; and (6) create a complementary relationship with the BSA, 

General Inspector Offices and stakeholders. The U.S. Embassy reported that as of June 2008, 

the United States through the Department of Justice’s International Criminal Investigative 

Training and Assistance Program, has a $5.3 million project and has trained over 270 

investigators. 

The DoS March 2008 Report on Human Rights Practices noted, however, that since its inception 

the CoI (previously named the Commission on Public Integrity (CPI) and so called in the human 

rights report) had adjudicated only approximately 241 of more than 3,100 cases under 

investigation. DoS concluded that this occurred because the CoI’s caseload far outstripped the 

organization’s investigative capacity and it experienced intimidation and lack of training. For 

example, the report detailed that during 2007 the CoI (CPI) confronted high-level attempts to 

influence prosecutions of members of the ruling party. Moreover, although the organization is 

required by law to enforce officials’ filing of financial disclosure reports, DoS concluded it was 

not powerful enough to enforce the requirement.11 In his response to our draft report, the 

Ambassador stated that the DoS Human Rights Report unfairly characterizes the CoI’s efforts. 

He said that the low number of cases the CoI was credited with processing in the report referred 

only to those where the judicial process is complete and the accused was found guilty. 

Moreover, the Ambassador noted that the numbers reflect problems in the court system as a 

whole and not just those related to corruption and similar problems have been noticed in 

terrorism and other high profile court matter. The Ambassador did not, however, provide any 

additional information to assess CoI activities 

In summing up the work of the CoI, a U.S. Embassy official informed SIGIR in July 2008 that 

the CoI is somewhat in disarray after three management changes in the past year, and although 

the staff is better trained and more professional than it was two years ago, it is considered less 

effective than previously. The official noted that not a single major Iraqi official has been taken 

to court since the former Director, Judge Rhadi, left the CoI in August 2007, while under his 

tenure the CoI referred two to three cases a month for prosecution. 

Board of Supreme Audit 

The BSA is an 80-year-old institution responsible for conducting audits of contracts and 

financial activities undertaken by the Council of Representatives, the Prime Minister’s Office, 

and the ministries. DoS’s Human Rights Report noted that by May 2007, CoI (CPI) records 

indicated that BSA referrals had more than doubled from the year before. Overall, a UNDP 

 

11 Country Reports on Human Rights Practices – 2007, March 11, 2008, Department of State, Bureau of 

Democracy, Human Rights and Labor 

8
official commented in June 2008 that the UN holds in high regard the work of the BSA. 

Specifically, the official noted that the BSA has a professional cadre of over 1,500 employees, 

has kept its institutional integrity and has a leader respected by Iraqis and the international 

community. A U.S. Embassy official cautioned that the BSA performs many audits but does not 

publish many of them so it is difficult to determine what is being achieved. However, the BSA 

reports that some audits are available on its website at www.bsairaq.net, and the remainder of the 

reports has been submitted to the Council of Representatives. U.S. training of staff at the BSA 

has been limited to funding six auditors for a Fellowship program with the U.S. Government 

Accountability Office. A much more extensive training program with UNDP meanwhile has 

begun a second phase of training. 

A senior BSA official wrote SIGIR that when the Coalition Provisional Authority reconstituted 

the BSA, it restricted BSA’s ability to implement the authority to investigate, refer financial 

violations directly to the court, or impose penalties on the violators. Moreover, she stated that 

the CPA deprived the BSA of its right to file lawsuits related to violation of Iraqi laws on the 

abuse of public funds, which, as she noted is the right of every Iraqi citizen. 

Inspectors General 

The GOI has a system of 31 IGs, with 1,250 staff, in the various ministries, the city of Baghdad, 

the central bank, and various endowments. Their mandate is to audit, inspect, and investigate 

their parent organizations to reduce fraud, waste and abuse. However, UN and U.S. officials 

view the IGs as among the least capable anticorruption agencies. A U.S. official in June 2008 

stated that there is no consensus within the GOI on what the IGs should do. In response, the 

Embassy reported that as of June 2008, the United States has used approximately $11 million in 

International Narcotics and Law (INL) funds transferred to USAID through an inter-agency 

agreement to train approximately 800 IG staff. As a result of this training and that provided by a 

U.S. contractor working for the Ministry of Defense, the Embassy reported that it had trained 

more than 935 IG staff. However, the JACC Chairman expressed concern to SIGIR that U.S. 

support for the IGs appears to be declining even though the U.S. was the major impetus behind 

their development. The Ambassador, though, stated that more U.S. government funds are now 

being spent on the IGs than at any time since their creation thanks to INL-funded training 

provided by USAID. 

GOI Joins UN Convention Against Corruption 

DoS officials point to Iraq’s becoming a State Party to the UNCAC in April 2008 as a tangible 

sign of the government’s political will to address corruption. A UNDP official stated that the 

UN will focus its assistance on UNCAC and International Compact with Iraq (ICI) goals. 

The UNCAC creates a global commitment and framework to prevent and address corruption, 

enabling effective national and international strategies. According to the Embassy, by joining 

the UNCAC, Iraq is obligated under international law to align its laws and institutions with the 

requirements of the UNCAC. The Convention requires members to develop a comprehensive 

national anticorruption strategy, review the existing legal and institutional framework, establish 

effective preventive measures such as codes of conduct and asset declaration systems, and 

promote ethical conduct, transparency, and accountability throughout society. 

9
The ICI is an Iraqi initiative to forge a five-year development partnership with the international 

community, including the UN and the World Bank. To assess progress, a monitoring matrix was 

prepared which includes goals, benchmarks, and indicative actions to measure success including 

anticorruption actions. For example, for 2008, one benchmark was to adopt and implement 

legislation, regulations, and procedures and strengthen the legal and institutional framework for 

anticorruption. One indicator of success was the ratification and implementation of the UNCAC, 

which as noted above, occurred in April. Another indicator was the completion of a master plan 

for the anticorruption agencies, and the development of task forces for high risk institutions. 

High-Level Decisions and Intimidation Can Impede Progress in 

Addressing Corruption 

UNDP and U.S. officials with whom we met in June 2008 were particularly concerned about the 

effect of legal statutes and the high level of intimidation on the ability of these anticorruption 

agencies to meet their missions. Their principal concerns are detailed below. 

Constitutional Provision: The Iraq Constitution provides immunity from arrest to members of 

the Council of Representatives (CoR) unless the member is caught in a criminal act or charged 

with a felony and the immunity is overturned by a majority vote of the CoR. 

Paragraph 136(b) of the Iraq Criminal Procedure Code: This code allows ministers to halt a 

corruption proceeding and thereby prevent the arrest of their employees. DoS reported in its 

2007 Human Rights Report that in 2007 ministers used this provision at least 67 times to halt the 

adjudication and arrest of employees, well above the 15 or more times it was used in 2006. DoS 

also noted that unlike 2006, in 2007 no new high-profile cases were brought to court. 

Administrative Order: On April 1, 2007, the Prime Minister’s Office issued an order to all 

Ministries including the CoI that effectively limited their authority. To illustrate, the memo 

stated that the CoI was not to refer any personnel in the Presidential Office, the Council of 

Ministers, or current or previous ministers to court without approval of the Prime Minister. 

Laws Codifying Anticorruption Institutions: U.S. officials with whom we spoke in June 2008 

generally viewed the draft laws formalizing the anticorruption entities as positive steps. 

However, not all of the laws’ specific terms were seen as supporting anticorruption efforts. One 

U.S. official pointed in particular to the IG draft law that requires corruption referrals to be 

turned over to the respective Minister, rather than directly to the CoI. The official concluded that 

such a provision would allow the Minister the option of not forwarding the referral. Additionally, 

an Embassy official stated that another serious concern is that the proposed draft law for the CoI 

reduces its jurisdiction by eliminating its function to initiate preliminary corruption investigation. 

The draft law would allow it to initiate an investigation only after a case is forwarded to court. 

The U.S. officer commented that this would be a significant retreat in the power of the CoI to 

discover and prepare for court action cases of corruption, and leaves the initial investigations 

solely in the hands of the IGs and the management of the agency being investigated.

10
Conclusion 

Reducing the level of corruption in Iraq will likely be a lengthy and difficult process. The 

likelihood of achieving this result will be enhanced by a sustained and robust U.S. anticorruption 

commitment. At the same time, the GOI will be required to make a similar commitment. 

The DoS and the U.S. Embassy continue to take actions to improve their management of the U.S. 

government anticorruption program in the short time since SIGIR’s last report. However, much 

remains to be done. Several years into the effort the strategic plan still lacks metrics for 

measuring program results. Staffing concerns, lack of funding, and the absence of a mechanism 

to evaluate all potential U.S. civilian and military programs to ensure that they are mutually 

supportive inhibits progress. This leaves future program investments vulnerable to wasteful 

spending, ineffectiveness, and inefficiency. 

The GOI has taken steps with U.S. assistance that if implemented effectively could start to 

address corruption in Iraq. GOI commitment to the UNAC may provide the most comprehensive 

approach to coping with the corruption problem in Iraq. Nevertheless, U.S. and UN officials 

agree that the GOI has yet to deal with corruption at the highest levels of the government. SIGIR 

recognizes the delicate political environment in which both the United States and GOI must 

operate and knows that that it is unrealistic to expect large scale improvements from a nascent 

democracy in a short time period especially in the midst of military conflict. Nevertheless, it is 

reasonable to expect both governments to agree on a prioritized set of benchmarks that can 

demonstrate positive movement in addressing the endemic corruption in Iraq. 

Recommendations 

SIGIR recommends that the Secretary of State expedite actions to provide the requested 

information to the Congress regarding the use of IRRF monies for anticorruption activities. 

SIGIR also recommends that the Ambassador to Iraq direct the Coordinator for Anticorruption 

Initiatives to review the U.S. anticorruption strategy to ensure that it contains the following 

elements: 

• Recognition of global best practices in anticorruption programs 

• A description of how the U.S. strategy ties to the GOI anticorruption strategy and the 

anticorruption sections of the International Compact 

• A discussion of the GOI’s commitment and support for the U.S. approach and projects 

• Clear goals and objectives with criteria to measure progress 

• Local level anticorruption capacity building activities 

• A prioritization of anticorruption projects based on a strategic analysis of the need and 

resources available 

11
Moreover, SIGIR also recommends that the Ambassador and the Commanding General, MNF-I, 

work jointly to ensure that all U.S. government anticorruption programs, regardless of funding 

source or agency management, are fully vetted through and coordinated with the ACCO. 

Matter for Congressional Consideration 

Making meaningful and lasting changes to reduce corruption will require a sustained and lengthy 

effort on the part of the GOI and all groups seeking to help facilitate the process. Therefore, as 

the Congress considers future funding for this program it may wish to consider the need for 

dedicated funding predicated on the Embassy’s development of clear anticorruption goals, 

objectives and periodic reports on results. 

Management Comments and Audit Response 

The U.S. Ambassador and MNSTC-I provided written comments on a draft of this report.12 

These letters are included in the report’s Management Comments section. In summary, the 

Ambassador stated that he did not believe that the report appropriately considers the full context 

in which anticorruption efforts are occurring. According to the Ambassador, the unique security 

situation has rendered inapplicable those lessons learned in other post-conflict environments, and 

a comprehensive assessment of Iraq’s anticorruption landscape and its anticorruption needs has 

not been possible due to the violence and sometimes chaotic on-the-ground realities. Only 

recently has the security situation made the prospect of making an assessment feasible, and the 

Embassy is taking steps to initiate the assessment. He also said that there is no comprehensive 

GOI anticorruption strategy. The Embassy has shared its approach with its GOI counterparts, 

but all elements of the GOI do not necessarily share the Embassy’s assessments or fully endorse 

what needs to be done. 

SIGIR recognizes the difficulties the Embassy faces in assessing corruption and promoting good 

governance in the midst of conflict and this report reflects those conditions. However, SIGIR’s 

criticism of the Embassy’s strategy is based not only on its lack of recognition of best practices, 

but also on its lack of clear overall anticorruption goals or specific and measureable objectives 

targeted at achieving these goals. Absent these features, program managers lack the tools to 

assess the effectiveness of their efforts and to make appropriate adjustment. We also do not fully 

agree that all previous DoS experience in anticorruption and good governance activities in post 

conflict environments are not applicable in Iraq. Structural difficulties the GOI experiences, 

such as a legacy that built into its mechanisms procedures and processes to advance it own 

corruption is not necessarily unique to Iraq. As such, USAID reports that it has implemented 

programs to advance the transparency and accountability of governments, train for and 

modernize the financial and judicial sectors, as well as to mobilize public support to pressure 

governments to make needed changes. We continue to believe that lessons learned from such 

 

12 SIGIR’s quarterly reports generally summarize all audit reports issued during the quarter, including a synopsis of 

agency comments. However, SIGIR did not receive the Embassy’s comments in time to included them in our 

quarterly report. Because of their significance, the comments are included here and discussed in the body of this 

report. 

12
efforts can be applicable to the condition in Iraq. The Ambassador also provided technical 

comments which we incorporated as appropriate. 

Both MNSTC-I and the Ambassador also expressed concern about a statement in the draft report 

that they do not coordinate their anticorruption activities with the ACCO. Our point was that no 

single person or organization is accountable for all U.S. government anticorruption efforts. We 

acknowledge that MNSTC-I and the ACCO keep each other informed of their respective 

activities. We have added wording to this report to more specifically address MNSTC-I’s and 

the Ambassador’s point on coordination and our position on the need for greater program 

accountability. 

Finally, MNSTC-I expressed concern that SIGIR did not interview MNSTC-I officials or request 

documentation in the conduct of our review. The focus of this review was on how well the 

ACCO was addressing previous SIGIR recommendations, and planning and overseeing the U.S. 

government anticorruption program. As such, we did not perform new audit work specifically 

focused on MNSTC-I or, for example, Department of Justice management of anticorruption 

activities. However, we met with MNSTC-I personnel earlier this year during previous 

anticorruption work, and during this review attended Anticorruption Working Group meetings 

where MNSTC-I participated. We also out briefed MNSTC-I on the results of our work, 

particularly as it pertained to ACCO oversight of its activities. 

In our draft report, SIGIR discussed staffing issues within the Anticorruption Coordination 

Office. In his response to the draft, the Ambassador said that only one position remains vacant 

in this office. This is a positive step at this time. However, given that the Coordinator has 

expressed to SIGIR the difficulty he experiences in obtaining and retaining qualified staff, we 

continue to believe that the staffing issue remains a concern.

13
Appendix A – Scope and Methodology 

We performed this audit under the authority of Public Law 108-106, as amended, which also 

incorporates the duties and responsibilities of inspectors general under the Inspector General Act 

of 1978, as amended. SIGIR initiated this review in May 2008 (Project 8023) as part of a 

quarterly assessment of U.S. Government anticorruption efforts in Iraq. The objective was to 

determine (1) the progress the Department of State made in implementing its new management 

approach and SIGIR recommendations to improve the management of anticorruption efforts for 

the calendar year quarter ending June 30, 2008, and (2) to provide information on GOI 

anticorruption efforts. We reviewed internal management controls within the context of specific 

plans, policies, and procedures aimed at improving the anticorruption program. For example, we 

addressed such internal control issues as maintaining the requisite number and level of 

competent staff to manage the multi-agency effort and developing systems to evaluate individual 

programs.

To determine Congressional actions related to anticorruption efforts in Iraq we reviewed 

pertinent legislation. To assess current U.S. efforts to strengthen management, we analyzed 

recent U.S. Embassy cables and other documents detailing new anticorruption measures as well 

as legislation providing a framework for strategic planning. We also met with Embassy 

personnel and attended meetings of the Embassy’s Anticorruption Working Group. 

To evaluate progress in addressing SIGIR recommendations, we analyzed previous, ongoing, and 

planned anticorruption management changes and assessed the extent to which they supported the 

objectives of the recommendations. In each instance, we concluded whether actions (1) were 

sufficient to completely address, and therefore close out, a specific recommendation; (2) were 

pending or underway, but not to the extent that they had resolved the particular problem; or (3) 

did not address the recommendation. 

We also met with officials from the Government of Iraq and the United Nations to discuss their 

anticorruption activities and aspects such as coordination with U.S. anticorruption officials. We 

reviewed pertinent GOI and UN documents such as draft laws and strategic plans to obtain 

additional information on GOI activities. 

We conducted this review in May, June, and July 2008 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. 

Use of Computer-processed Data 

We did not use computer-processed data to perform this review. 

Prior Coverage 

We reviewed the following reports and relied on them in conducting our review: 

14
• U.S. Anticorruption Efforts in Iraq: Progress Made in Implementing Revised 

Management Plan (SIGIR-08-016, April 24, 2008) 

• U.S. Anticorruption Efforts in Iraq: Sustained Management Commitment is a Key to 

Success (SIGIR-08-008, January 24, 2008) 

• Status of U.S. Government Anticorruption Efforts in Iraq (SIGIR- 07-007, July 24, 2007) 

• Joint Survey of the U.S. Embassy-Iraq’s Anticorruption Program (SIGIR-06-021, July 

28, 2006) 

15
Appendix B – Status of SIGIR Recommendations 

In July 2006, SIGIR issued a report on anticorruption activities that identified such problems as a 

lack of coordination and leadership. SIGIR made 12 recommendations to improve the 

management of U.S. anticorruption efforts. A year later, SIGIR reported that limited progress 

had been made in implementing these recommendations and that the U.S. Embassy was reestablishing and reorganizing its efforts to better oversee U.S. anticorruption activities. In 

January 2008, SIGIR reported that the Embassy had completed its proposed reorganization plan 

(which was approved by the Department of State on January 9, 2008). Our January and April 

2008 audits of the actions taken or planned indicated that they generally supported the outcomes 

SIGIR recommendations were designed to achieve but that 10 of 12 recommendations remained 

open pending full implementation of the strategy and actions. 

During the current review SIGIR assessed progress in implementing the new management 

approach and in addressing the ten remaining open recommendations. SIGIR’s review shows 

that three more recommendations have been closed.13 Nonetheless, seven SIGIR 

recommendations remain open pending full implementation of the management plan and other 

specific actions. Table 1 below presents U.S. Embassy actions on the closed recommendations 

as well as SIGIR’s analysis on the status of open recommendations, as of July 2008. 

Table 1—U.S. Embassy’s Actions on SIGIR’s Recommendations 

Recommendations to the U.S. 

Ambassador to Iraq 

Analysis of Actions Planned or 

Taken 

Analysis of 

Recommendation 

Status 

Recommendation 1: Provide the necessary 

resources to have sufficient direction and 

oversight of the U.S. Embassy’s anticorruption 

program, including a senior leader from DoS and 

a senior officer from the Multi-National Force-Iraq 

(MNF-I). Both positions should be filled with staff 

that has an appropriate background to bring 

value to the position. 

On March 11, 2008, the Department of State 

announced the appointment of Ambassador 

Lawrence Benedict as U. S. Embassy Baghdad’s 

first Coordinator for Anticorruption (Coordinator) 

initiatives. The Ambassador arrived in Baghdad 

on March 30. 2008. 

This recommendation is 

closed. 

Recommendation 2: Continue efforts to recruit 

an Iraqi local national staff member to provide 

support to the full-time anticorruption program 

manager. This person should have the necessary 

skills and level to be instrumental in forging joint 

U.S.-Iraqi anticorruption initiatives. 

The Anticorruption Coordination Office (ACCO) 

currently includes two Iraqis staffers, one who is 

a dual national, who interact with Iraqi 

government officials. 

This recommendation is 

closed.

 

13 A recommendation is closed when it has been implemented, when actions have been taken that essentially meet 

the recommendation’s intent, or when circumstances have changed and the recommendation is no longer valid. 

Absent these conditions, the recommendation remains open. 

16
Analysis of 

Recommendation 

Status 

Recommendations to the U.S. 

Ambassador to Iraq 

Analysis of Actions Planned or 

Taken 

Recommendation 3: Establish a joint executive 

steering group, chaired by the anticorruption 

program manager, with oversight of all U.S. 

Government anticorruption programs to ensure 

that all initiatives are working toward a common 

goal in the most efficient and effective manner. 

SIGIR noted in its January 2008 report that 

Embassy reorganization plans supported the 

intent of this recommendation. The Embassy 

established the ACCO to perform the functions of 

the joint executive steering group The 

Coordinator is the head of the ACCO and is part 

of the Chief of Mission’s (COM) senior staff, 

reporting to him through the Deputy Chief of 

Mission (DCM). Nevertheless, there is still no 

process to ensure that all U.S. Government 

initiatives, including civilian and military, are 

working toward a common goal, or metrics to 

determine whether they are being conducted in 

the most efficient and effective manner. 

This recommendation 

remains open, actions 

pending or underway. 

Recommendation 4: Direct the Joint Executive 

Steering Group to provide to the Deputy Chief of 

Mission periodic reports (at least quarterly) on 

progress, barriers, and funding needs to support 

the anticorruption program. 

The Coordinator stated that he meets regularly 

with the Deputy Chief of Mission to brief on 

anticorruption activities and programs. 

This recommendation is 

closed. 

Recommendation 5: Establish a policy that will 

require all participating organizations to vet new 

anticorruption initiatives through the new joint 

executive steering group. 

SIGIR was informed that the Ambassador has 

instructed all Mission elements under his 

authority to coordinate all anticorruption activities 

with the ACCO. However, this does not include 

U.S. military anticorruption activities. SIGIR has 

consistently called for the need to coordinate and 

vet all U.S. activities to eliminate stovepiping of 

reconstruction assistance. 

This recommendation 

remains open. 

Recommendation 6: Direct the joint executive 

steering group to conduct a complete review of 

each U.S.-funded anticorruption program and 

assess how that program helps achieve the U.S. 

Government’s strategic goals for anticorruption. 

We were informed that agencies under Chief of 

Mission authority have submitted an inventory of 

their anticorruption projects which are being 

reviewed for consistency with the Embassy’s 

anticorruption strategy. However, it is unclear 

the degree to which U.S. military activities are 

included, and the strategy does not provide clear 

goals and objectives from which programs can 

be assessed. 

This recommendation 

remains Open, Actions 

Pending or Underway. 

Recommendation 7: Direct the members of the 

ACWG to develop action plans for each activity’s 

program in concert with the overall strategic 

goals. 

The U.S. Ambassador has stated that the 

Embassy must design and implement a 

comprehensive, integrated anticorruption 

strategy. The ACCO drafted an anticorruption 

strategy in June 2008 and is reviewing current 

projects and programs to ensure they are 

consistent with that strategy 

This recommendation 

remains Open, Actions 

Pending or Underway. 

Recommendation 8: Establish a baseline for 

each anticorruption program to document a 

starting point for the program to measure 

progress. 

The ACCO informed SIGIR that the baseline is 

the anticorruption strategy, that it is developing 

metrics to measure the success of anticorruption 

programs, and expects to complete their 

development by August 2008. However, the 

strategy does not include specific and 

measurable baselines from which to assess 

progress. 

This recommendation 

remains Open 

Recommendation 9: Establish interim and longterm objective(s) for each anticorruption program 

consistent with the overall anticorruption program 

strategy. 

The ACCO has developed an anticorruption 

strategy but it does not contain interim and long 

term objectives from which program objectives 

can be assessed. 

This recommendation 

remains Open 

17
Analysis of 

Recommendation 

Status 

Recommendations to the U.S. 

Ambassador to Iraq 

Analysis of Actions Planned or 

Taken 

Recommendation 10: Engage Iraqi 

anticorruption counterparts in the new 

government and establish the joint U.S.-Iraq 

ACWG. 

On May 16, 2007, the JACC charter was signed 

by the Prime Minister and senior Iraqi leaders, 

and since then, the JACC has held several 

meetings. 

This recommendation is 

Closed. 

Recommendation 11: Encourage the GOI to 

establish its own anticorruption working groups 

with regional and international partners. 

According to the Coordinator, the GOI has been 

actively developing anti-corruption relationships 

with the international community on its own and 

with assistance from the U.S.G and others. 

Particularly illustrative is that Iraq became a 

State Party to the UN Convention on AntiCorruption (UNCAC) on April 16, 2008. Iraq has 

also engaged in other UN and World Bank 

workshops and other GOI governance activities. 

This recommendation is 

closed. 

Recommendation 12: Based on the unresolved 

recommendation 20 from the October 2005 DoS 

Office of Inspector General report, 14 develop 

and implement an action plan to: 

A) Identify the training requirements of the 

Commission on Public Integrity, Board of 

Supreme Audit, Central Criminal Court of 

Iraq, and the ministerial Inspector 

Generals, with special emphasis on 

requirements that apply to all four 

institutions. 

B) Prioritize the identified training 

requirements. 

C) Identify training solutions for the 

requirements that can cut across multiple 

institutions to avoid duplication and 

maximize resources. 

The ACCO stated in a June 2008 response to a 

SIGIR inquiry that its goal is to identify and meet 

the training needs of all GOI oversight personnel 

to include those in the Provinces, and that it has 

begun this process. Moreover, the Coordinator 

responded that the ACCO has been coordinating 

actively with the UNDP and USAID to identify 

training needs and eliminate duplication. If fully 

implemented, this plan would meet the intent of 

the recommendation. 

This recommendation 

remains Open, Actions 

Pending or Underway. 

 

14 DoS OIG, ISP-IQO-06-0, “Report of Inspection: Rule of Law Programs, Embassy, Baghdad, Iraq ,” October 

2005. 

18
Appendix C—Acronyms 

Acronym Description 

ACCO Anticorruption Coordination Office 

ACWG Anti-Corruption Working Group 

BSA Board of Supreme Audit 

CoR Council of Representatives 

CPA Coalition Provisional Authority 

CPI Commission on Public Integrity 

DoS Department of State 

DCM Deputy Chief of Mission 

GOI Government of Iraq 

GPRA Government and Performance Results Act 

ICI International Compact with Iraq 

IFMIS Iraq Financial Management Information System 

IG Inspectors General 

INL International Narcotics and Law Enforcement Affairs 

IRRF Iraq Relief and Reconstruction Fund 

JACC Joint Anticorruption Council 

MNF-I Multi-National Force-Iraq 

MNSTC-I Multi-National Security Transition Command-Iraq 

SIGIR Special Inspector General for Iraq Reconstruction 

TI Transparency International 

UN United Nations 

UNCAC U.N. Convention Against Corruption 

UNDP United Nations Development Programme 

USAID U.S. Agency for International Development 

19
Appendix D—Audit Team Members 

This report was prepared, and the audit work conducted, under the direction of David R. Warren, 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction. 

Staff members who contributed to the report include: 

Robert Gabriel 

Dan Haigler 

Joan Hlinka 

Philip Mastandrea 

20
Management Comments 

U.S. Embassy - Iraq 

21
22
23
Management Comments 

Multi-National Security Transition Command-Iraq 

24
25
SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, 

and operations in Iraq, the Special Inspector General 

for Iraq Reconstruction provides independent and 

objective: 

• oversight and review through comprehensive 

audits, inspections, and investigations 

• advice and recommendations on policies to 

promote economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention 

and detection of fraud, waste, and abuse 

• information and analysis to the Secretary of 

State, the Secretary of Defense, the Congress, 

and the American people through Quarterly 

Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go 

to SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, 

and Abuse in Iraq Relief 

and Reconstruction 

Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Kristine R. Belisle 

Director for Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

Email: PublicAffairs@sigir.mil 

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