OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

July 28, 2006 

MEMORANDUM FOR U.S. AMBASSADOR TO IRAQ 

 DIRECTOR, IRAQ RECONSTRUCTION MANAGEMENT 

 OFFICE 

SUBJECT: Joint Survey of the U.S. Embassy-Iraq’s Anticorruption Program 

(SIGIR-06-021) 

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

in accordance with our statutory duties contained in Public Law 108-106, as amended, 

which requires that we provide for the independent and objective conduct of audits, as 

well as leadership and coordination of and recommendations on policies designed to 

promote economy, efficiency, and effectiveness in the administration of Iraq relief and 

reconstruction programs and operations and to prevent and detect waste, fraud and abuse. 

This report discusses the results of a joint Special Inspector General for Iraq 

Reconstruction (SIGIR) and Department of State Inspector General review and analysis 

of the U.S. Embassy-Iraq’s Anticorruption Program. This report presents SIGIR’s 

position on the results of this work. 

We considered management comments from the U.S. Embassy-Iraq on a draft of this 

report when preparing the final report. Its comments are addressed in the report where 

applicable, and a copy of its comments is included in the Management Comments section 

of this report. 

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

report, please contact Mr. Joseph T. McDermott at (703) 343-7926, or by email at 

joseph.mcdermott@iraq.centcom.mil; or Mr. Clifton Spruill at (703) 343-9275; or by 

email at clifton.spruill@iraq.centcom.mil. For the final report distribution, see 

Appendix F. 

 

Stuart W. Bowen, Jr. 

 Inspector General 

cc: Distribution 

400 Army Navy Drive • Arlington, Virginia 22202
Special Inspector General for Iraq Reconstruction 

SIGIR-06-021 July 28, 2006 

 

Joint Survey of the U.S. Embassy-Iraq’s Anticorruption Program 

Executive Summary 

Introduction. Corruption in Iraq siphons resources from needed government services 

and reduces the willingness of international investors to invest in Iraq. It has been 

identified as a major barrier to establishing citizens’ trust and confidence in their 

government and to improving economic growth and prosperity. Unless reforms are put in 

place, corruption may jeopardize the political stability of the new government. The U.S. 

Embassy-Iraq has identified assisting the Iraqi government in its efforts to reduce 

corruption as one of its highest priorities. 

The Special Inspector General for Iraq Reconstruction (SIGIR) and the Department of 

State, Office of the Inspector General, jointly initiated this survey of the U.S. EmbassyIraq’s Anticorruption Program at the request of the U.S. Ambassador to Iraq. The work 

was primarily performed within the International Zone in Baghdad, Iraq, and in 

Washington, D.C. This product reports SIGIR’s position on the results of the joint work 

that address the survey objectives. 

Objectives. The objectives of this survey were to determine (1) which U.S. government 

agencies participate in the anticorruption program in Iraq, and whether they have a 

coordinated strategic plan with identified goals; (2) whether program outcomes and 

metrics have been established to measure progress and success; and (3) whether 

organizational roles and responsibilities have been clearly identified and resources 

provided to meet the program goals. In addition, the survey was to identify international 

leading practices from other organizations that have had successful experience in 

reducing corruption. We did not compare the U.S. Embassy-Iraq initiatives to the lessons 

learned from these leading practices since the joint U.S.-Iraq Anticorruption Working 

Group is still in the formulation stage. We plan to do this comparison in a future review. 

We also provide other observations we made during the survey that related to the 

anticorruption program. 

Results. Since the start of the Coalition Provisional Authority in June 2003, the U.S. 

government has been working with the Iraqi government to establish organizations, 

systems, training, and an environment to increase citizens’ trust and confidence in the 

Iraqi government and to increase the transparency and accountability of overall 

government operations. However, because of many other priorities, these efforts have 

not been focused and adequate leadership resources have not been provided. Both of 

these conditions have been recognized and the U.S. Embassy-Iraq has initiated action to 

address these shortfalls. We identified that U.S. government expenditures on 

anticorruption activities has been modest when compared to the total spent for Iraq 

reconstruction. 

Total funding for ongoing and planned anticorruption activities through June 15, 2006, 

was approximately $65 million, or less than .003% of the total IRRF funding to date. 

However, we also did not identify nor has the U.S Embassy-Iraq made a case for 

i
additional funding, other than the need to add additional staff to improve overall 

leadership and program continuity. 

In late 2005, the U.S. Embassy-Iraq reconstituted its Anticorruption Working Group 

(ACWG) and in December 2005 released its strategic plan for reducing corruption in 

Iraq. The ACWG is comprised of the following organizations:1

• Economic Counselor, U.S. Embassy-Iraq (ACWG chairman) 

• Political Affairs Section, U.S. Embassy-Iraq 

• Political-Military Affairs Section, U.S. Embassy-Iraq 

• Public Affairs Section, U.S. Embassy-Iraq 

• Foreign Commercial Service, U.S. Embassy-Iraq 

• Iraq Reconstruction Management Office Liaison to the Commission on Public 

Integrity 

• Department of Justice 

• U.S. Agency for International Development 

• Bureau of International Narcotics and Law Enforcement Affairs, U.S. Department 

of State 

• U.S. Department of Treasury 

• Multi-National Force-Iraq Inspector General 

• Strategic Effects, Multi-National Force-Iraq 

• Multi-National Security Transition Command-Iraq 

The ACWG’s strategic plan focuses on reforms in three areas: Market Reforms; Financial 

Transparency; and Public Integrity. At the time of this report, the ACWG was 

considering adding a fourth area – Technical and Law Enforcement Measures. The plan 

also establishes specific goals for each area. For example, some Market Reform goals are 

to reverse the trend of capital leaving the country and assist the market economy through 

market pricing of goods and services. Examples of strategic goals in the other areas 

include establishing transparent budget and procurement procedures, and increasing the 

number of anticorruption investigations. A full listing of the goals for each area is in 

Appendix B of this report. 

In support of its strategy, the ACWG has established indicators for measuring the 

progress of its planned activities. For example, a goal in the first year for financial 

transparency is for the Iraqi government to develop the ability to monitor financial 

transactions within the public and private sectors. The indicator is the government-wide 

installation of a financial management information system. In general, our review of the 

indicators for the individual goals and objectives found that they are well-defined, and 

measurable. However, indicators for measuring the outcomes of the overall ACWG 

strategic activities (e.g., the reduction of corruption across Iraqi society) have not yet 

been established. 

At present, a clear delineation of each participating U.S. organization’s roles and 

responsibilities is pending development while the ACWG gathers data on each 

organization’s ongoing programs and projects. Many of the ACWG participating 

agencies had anticorruption activities ongoing when the ACWG was revitalized and the 

 

1

 SIGIR attends these meetings as an observer. 

ii
ACWG is conducting an inventory of all ongoing anticorruption activities to identify 

areas of duplication and to determine where additional coordination is needed. For 

example, three ACWG members have outreach programs ongoing that could be 

duplicative. According to the ACWG Chairman, delineating roles and responsibilities 

and coordinating activities is somewhat hampered by a lack of cooperation, and the 

unwillingness of some members to share information on programs and projects. Some 

members also lack a commitment to a common strategy and goal. 

While there has been some improvement in sharing information and cooperation, mainly 

through the efforts of the ACWG Chairman, more could be done. Currently, there is no 

single office that has the authority or responsibility for oversight and to ensure all 

anticorruption efforts are focused on a common goal or that efforts are being performed 

in the most efficient manner. This lack of a single point of contact on the U.S. 

government side will become more acute as the Iraqi government consolidates its anticorruption efforts. It is important that the wide range of initiatives being undertaken by 

the ACWG members; Multi-National Force-Iraq; Multi-National Security Transition 

Command-Iraq; and the Embassy be fully coordinated with the Iraqi government. This 

includes presenting a coherent set of programs to the Prime Minister and the staff he has 

designated to work the issue on his behalf. 

Recommendations. Based on our results of survey, we recommend to the U.S. 

Ambassador to Iraq: 

1. In response to the request from the U.S. Embassy-Iraq’s Economic Counselor, 

provide the necessary resources to have sufficient direction and oversight of the 

U.S. Embassy’s anticorruption program, including a senior leader from the 

Department of State and a senior officer from the Multi-National Force-Iraq. Both 

of these positions should be filled with staff that has such a background to bring 

value to the position. 

2. Continue the ongoing efforts to recruit an Iraqi local national staff member to 

provide support to the full-time Anticorruption Program Manager. This individual 

should have the necessary skills and rank to be instrumental in forging joint U.S.-

Iraqi anticorruption initiatives. 

3. Establish a joint executive steering group, with the Anticorruption Program 

Manager as the chairperson, that would have oversight on all U.S. government 

anticorruption programs to ensure that all initiatives are working toward a common 

goal in the most efficient and effective manner. 

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. 

5. Establish a policy that will require all participating organizations to vet new 

anticorruption initiatives through the new joint executive steering group. 

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. 

7. Direct the members of the ACWG to develop action plans for each activity’s 

program in concert with the overall strategic goals. 

8. Establish a baseline for each anticorruption program to document a starting point 

for the program in order to measure progress. 

iii
9. Establish interim and long term objective(s) for each anticorruption program 

consistent with the overall anticorruption program strategy. 

10. Engage the Iraqi anticorruption counterparts within the new government and 

establish the joint U.S.-Iraq Anticorruption Working Group. 

11. Encourage the new Iraqi government to establish its own anticorruption working 

groups with regional and international partners. 

Prior Report and Management Actions Related to Recommendations Made Related to 

Anticorruption Initiatives. In October 2005, U.S. Department of State, Office of 

Inspector General issued Report of Inspection, “Inspection of Rule-of-Law Programs, 

Embassy Baghdad.” The report made 21 recommendations regarding Rule of Law 

initiatives. Recommendation number 20 in the report directly addressed anticorruption 

and specifically stated, “Embassy, Baghdad, in coordination with the Bureau of 

International Narcotics and Law Enforcement Affairs, should seek and support Iraqi 

efforts to design and establish a training facility for anticorruption personnel from, and 

with the support of, all three institutions of the Iraqi anticorruption structure”. The 

institutions referred to were the Board of Supreme Audit, Ministry Inspectors General, 

and the Commission on Public Integrity. 

The U.S. Embassy response to this recommendation was “generally supports this 

concept. However, this proposal requires agreement among several entities of the Iraqi 

government as well as significant commitments of funds and personnel. Embassy will 

continue to evaluate the viability of this concept and its likely benefits vis-a-vis other 

proposals.” 

Our review disclosed that, although the Iraqi government has provided initial funds to the 

Commission on Public Integrity to establish this initiative, the recommendation continues 

to be evaluated by the U.S. Embassy-Iraq, and no further progress has been made in 

obtaining a facility for all three anticorruption institutions. 

Recommendations. Based on this prior review and the results of our review, we are 

adding additional recommendations for the U.S. Embassy: 

12. 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 Ministry 

Inspectors General with special emphasis on requirements that apply to all 

four institutions. 

b. Prioritize the identified training requirements. 

c. Identify training solutions for those requirements that can cut across multiple 

institutions to avoid duplication and maximize resources. 

Management Comments and Audit Response. We received comments from the U.S. 

Embassy-Iraq, who concurred with our findings and recommendations. Actions are 

being planned or are underway to implement the recommendations. Among the actions 

the Embassy Staff is taking is the appointment of a senior foreign service officer to 

supervise the anticorruption program, and the establishment of a joint executive steering 

group that will have oversight on all U.S. government anticorruption programs. We 

consider the Embassy’s comments to be fully responsive to our report. 

iv
Table of Contents 

Executive Summary i 

Introduction 

Background 1 

Objectives 2 

Findings 

 U.S. Embassy Anticorruption Working Group Program Strategy 3 

 Anticorruption Program Outcomes and Metrics 5 

 Organizational Roles and Responsibilities, Resources 

 and Other Available Support 6 

 International Leading Practices for Reducing Corruption 11 

Conclusion and Recommendations 13 

Appendices 

A. Scope and Methodology 15 

 B. U.S Embassy’s Anticorruption Strategic Goals and Objectives 16 

 C. Anticorruption Program Inventory and Funding 

as of June 15, 2006 17 

 D. Iraqi Anticorruption Accountability Organizations Process Flowchart 19 

E. Acronyms 20 

 F. Report Distribution 21 

 G. Survey Team Members 23 

Management Comments 

 U.S. Embassy, Baghdad, Iraq 24
1 

Introduction 

Background 

In its October 30, 2005, Quarterly Report to the United States Congress, the Special Inspector 

General for Iraq Reconstruction (SIGIR), identified corruption within Iraqi society as a serious 

threat to the country’s progress toward prosperity. Corruption was endemic in the prior regime, 

and the legacy of corruption still burdens the country. For example, Iraq reportedly loses more 

than $2 billion annually in stolen gasoline and diesel supplies.2 

 

Assisting Iraqi government institutions in their fight against corruption is an important U.S. 

policy objective. Corruption directly undermines the effectiveness of the U.S. reconstruction 

effort and impedes Iraq’s progress toward becoming a democratic, market-oriented society. For 

this reason, and because the Iraq Relief and Reconstruction Fund (IRRF) directly supports 

important U.S. anticorruption programs in Iraq, SIGIR and the Department of State’s (DoS) 

Office of the Inspector General (OIG) continue to pay close attention to U.S. support for Iraqi 

anticorruption efforts. 

Since inception of the Coalition Provisional Authority (CPA) in June 2003, the U.S. government 

has been working with the Iraqi government to establish organizations, systems, training, and an 

environment to increase citizens’ trust and confidence in the Iraqi government and the 

transparency and accountability of overall government operations. The CPA issued several 

orders and established service organizations to improve accountability within the interim Iraqi 

government, which remain in effect today. For example, the CPA introduced an order to require 

financial disclosure reporting by senior Iraqi government officials, including police and army 

officers from the rank of captain and above, to identify potential or implied conflicts of interest 

in the conduct of responsibility. In establishing the service organizations for integrity and 

accountability, CPA recognized the need to continue the work of the Board of Supreme Audit 

(BSA) and established the Commission on Public Integrity (CPI), the Central Criminal Court of 

Iraq (CCCI), and the Inspectors General (IG) offices in each of the ministries (see Figure 1). For 

the process flowchart descriptions of the Iraqi Anticorruption Accountability Organizations, see 

appendix D. 

 Figure 1. 

However, beginning in the last half of 2005, high-level officials within the U.S. government 

expressed a growing dissatisfaction with the efforts of the U.S. Embassy’s anticorruption 

campaign in Iraq. On November 12, 2005, at SIGIR’s urging, the U.S. Ambassador to Iraq held 

an Anticorruption Summit. Participants at this summit included both U.S. and Iraqi officials 

 

2

 Testimony presented to the Senate Foreign Relations Committee on July 20, 2005, by Mr. Keith Crane, Senior 

Economist, Rand Corporation. 
2 

with direct responsibilities in the anticorruption efforts in Iraq. The summit resulted in the 

rejuvenation of a previously inactive U.S. Embassy Anticorruption Working Group (ACWG) 

under the chairmanship of the U.S. Embassy’s Economic Counselor. Another planned outcome 

of the summit meeting was to create a joint U.S.-Iraqi Anticorruption Working Group. 

In addition to the ACWG, the U.S. Embassy established the Ministerial Transition Action Group 

to help address Iraqi corruption issues. The Ministerial Transition Action Group was created to 

influence and support the transition of the interim Iraqi Transitional Government to the newly 

elected Iraqi government without major disruption to critical ministry functions or to governance 

capacity building programs. The Ministerial Transition Action Group prepared a ministry 

transition action plan, dated December 26, 2005, that includes, among others, sections on 

continuity of governance, retention of key personnel and assets, and anticorruption. The 

anticorruption section discusses the involvement of various Iraqi public integrity institutions 

such as the Board of Supreme Audit, Commission on Public Integrity, Central Criminal Court of 

Iraq, and the Ministry Inspectors General. The action plan calls for raising public awareness 

among Iraqi citizens of the new government’s anticorruption message and its interest in fighting 

corruption. SIGIR attends the weekly Ministerial Transition Action Group meetings as an 

observer. 

Objectives 

The objectives of this survey were to determine: 

• which U.S. government agencies participate in the anticorruption program in Iraq, and 

whether they have a coordinated strategic plan with identified goals 

• whether program outcomes and metrics been established to measure progress and 

success 

• whether organizational roles and responsibilities have been clearly identified and 

resources provided to meet the program goals 

In addition, the survey identified international leading practices from other organizations that 

have had successful experience in reducing corruption. We did not compare the U.S. EmbassyIraq initiatives to the lessons learned from these leading practices since the joint U.S.-Iraq 

Anticorruption Working Group is still in the formulation stage. We plan to do this comparison 

in a future review. We also provide other observations we made during the survey that related to 

the anticorruption program. 

For a discussion of the audit scope and methodology and prior coverage, see Appendix A. For 

the U.S. Embassy Anticorruption Strategic Goals and Objectives, see Appendix B. For a list of 

anticorruption initiatives and related funding, see Appendix C. For a description of the Iraqi 

Anticorruption Accountability Organizations, see Appendix D. For definitions of the acronyms 

used in this report, see Appendix E. For a list of the survey team members, see Appendix G. 
3 

U.S. Embassy Anticorruption Working Group 

Program Strategy 

In late 2005, the U.S. Embassy-Iraq reconstituted its anticorruption working group and in 

December 2005, the working group released its strategic plan for reducing the level of 

corruption in Iraq. 

In November 2005, at the urging of SIGIR, the U.S. Ambassador to Iraq convened an 

anticorruption summit that brought together both U.S. and Iraqi officials. The summit resulted in 

rejuvenating a previously inactive U.S. Embassy Anticorruption Working Group (ACWG) and 

placing it under the leadership of the U.S. Embassy’s Economic Counselor. The aim of the 

ACWG was to develop an anticorruption strategy and to coordinate all U.S.-led anticorruption 

activities with this strategy. These are the participating organizations3: 

• Economic Counselor, U.S. Embassy-Iraq (ACWG chairman) 

• Political Affairs Section, U.S. Embassy-Iraq 

• Political-Military Affairs Section, U.S. Embassy-Iraq 

• Public Affairs Section, U.S. Embassy-Iraq 

• Foreign Commercial Service, U.S. Embassy-Iraq 

• Iraq Reconstruction Management Office Liaison to the Commission on Public Integrity 

• Department of Justice 

• U.S. Agency for International Development 

• Bureau of International Narcotics and Law Enforcement Affairs, U.S. Department of 

State 

• U.S. Department of Treasury 

• Multi-National Force-Iraq Inspector General 

• Strategic Effects, Multi-National Force-Iraq 

• Multi-National Security Transition Command-Iraq 

On December 28, 2005, the ACWG issued its first Anticorruption Strategy. Essentially, the 

strategy focuses on reforms in three areas: Market Reforms; Financial Transparency; and Public 

Integrity, and establishes specific desired end-states for each reform area. The desired end-states 

for the three areas are: 

• Market Reforms: A functioning market economy with market pricing of goods and 

services, and a reversal of the trend of capital leaving the country. 

• Financial Transparency: An Iraqi government with standardized, transparent budget 

and procurement procedures that is an active partner with regional states, trading 

partners, potential investors and donors in investigating and combating corruption. 

• Public Integrity: An Iraqi government that adheres to the rule of law and is capable of 

ensuring that government, donor, and international financial institution resources are 

effectively used on behalf of its people. 

 

3

 SIGIR attends the working group meetings as an observer. 
4 

At the time of this report, the ACWG was considering adding a fourth area – Technical and Law 

Enforcement Measures – which would spell out specific implementation actions that would be 

targeted for the short, medium and long-term. Currently, the U.S. Embassy Anticorruption 

Strategy is on its fourth iteration. 

The ACWG Chairman describes the mission efforts to achieve these end states as wide-ranging, 

and at different levels of development. Nonetheless, each desired end-state is supported by goals 

and objectives and a time line for achievement. For example, in Market Reforms the first year 

goals are to: 

• continue subsidy reforms for oil and gas 

• establish more comprehensive billing practices for electric power 

• reintroduce electrical tariff reform to the National Assembly 

• educate public decision makers on the link between corruption and the absence of market 

reform 

• introduce legislation to promote foreign direct investment 

For a full listing of the goals and objectives for each reform area, see Appendix B. 

Based on our analysis of the strategic goals and objectives for achieving each of the reforms, we 

believe the activities are well thought out and appropriate to the goals. However, managing a 

task of this scope is likely to require additional resources. At present, the leadership of the 

ACWG is vested part time in the U.S. Embassy-Iraq’s Economic Counselor. The Economic 

Counselor has recognized the need for additional resources and has prepared a request to the 

Ambassador for additional support to include one full time Foreign Service Officer and one full 

time resource from the Multi-National Force-Iraq. In addition, actions are underway to identify a 

locally employed staff member to provide continuity and to facilitate U.S.-Iraq joint integration 

issues. 
5 

Anticorruption Program Outcomes and Metrics 

No mechanism has yet been established for regular review of the various anticorruption 

programs and how they help to achieve overall strategic goals. However, the ACWG has 

established indicators for measuring the progress of each of its planned activities. In general, our 

review of the activity indicators for individual reform goals and objectives found that they are 

well-defined, and measurable. 

At present, the ACWG has not established indicators for measuring the outcomes of its overall 

strategic activities (e.g., the reduction of corruption across Iraqi society) and how well its 

programs are helping to achieve strategic goals. We believe a mechanism needs to be 

established for regular reviews of the anticorruption program and assessing how well each of the 

anticorruption programs relate to and help achieve the U.S. government’s strategic goals for 

anticorruption. Metrics may also prove to be useful in measuring program progress. For 

example, a qualitative measure, such as the Corruption Perception Index, maintained by 

Transparency International, could be used. Currently, the Corruption Perception Index ranks 

Iraq as the 21st most corrupt country. This perception index rating could be one method of 

measuring the effectiveness of anticorruption initiatives. Surveys might also prove useful in 

quantifying the effect of program activities and measuring progress. At present some elements 

of the ACWG are utilizing surveys to measure progress, but this is a new initiative. 

 

As stated, the ACWG and its member organizations have done a good job of identifying bench 

marks and indicators for measuring progress toward individual goals. Each desired end-state is 

supported by goals and objectives and a timeline for achievement and each of those goals and 

objectives is supported by an indicator that allows measurement of progress. For example, a 

year one goal for market reforms is to continue subsidy reforms in oil and gas. The International 

Monetary Fund has established subsidy targets for these commodities, and measuring progress 

towards those targets provides a measure of the success of the ACWG’s activities. Similarly, a 

public integrity reform goal is the investigation and prosecution of corruption cases. The 

indicator for activities addressing this goal is the number of investigations referred to courts. 

While metrics have been established for measuring progress toward individual goals, it should be 

noted that some indicators are not short term and may take years to accomplish. For example, 

the Multi-National Security Transition Command-Iraq (MNSTC-I) has developed and supports 

an Iraqi Center for Military Values, Principles, and Leadership. Its goal is to inform and 

influence key leaders, the military, the public, and other ethics compliance organizations. 

MNSTC-I has established 34 values they intend to convey through the Center. However, there is 

an expectation that it may take nearly two generations to fully realize these outcomes. 

According to MNSTC-I officials, they only expect to achieve 5 or 6 of the values during the first 

2 to 3 years of the program. 
6 

Organizational Roles and Responsibilities, Resources, 

and Other Available Support 

At present, a clear delineation of each participating U.S. organization’s role and responsibilities 

is pending development while the ACWG gathers data on all ongoing programs and projects. 

Many of the ACWG participating agencies had anticorruption activities ongoing when the 

ACWG was revitalized and the ACWG is conducting an inventory of all ongoing anticorruption 

activities to identify areas of duplication and to determine where additional coordination is 

needed. Moreover, the role and responsibilities of Iraqi organizations in combating corruption 

remains unknown because of delays in forming the new Iraqi government and uncertainty over 

the roles the four Iraqi government institutions involved in anticorruption will play. Further, we 

identified that a relatively modest amount of U.S. resources are currently available for 

anticorruption program activities when compared to the total U.S. reconstruction funding for 

Iraq. However, we did not identify, nor has the ACWG made a case for, additional funding other 

than the need to add additional staff to provide overall leadership and program continuity. 

U.S. Organizations Roles, Responsibilities and Coordination. While the ACWG has moved 

forward by identifying individual programs, the roles and responsibilities have not been fully 

determined for each of the U.S. organizations involved in anticorruption activities. According to 

the ACWG Chairman, an inventory of ongoing activities is a necessary first step in assigning and 

coordinating roles and responsibilities. However, in a February 2006 briefing to the Deputy 

Chief of Mission on “Anti-Corruption Efforts in Iraq,” the ACWG Chairman said that the 

completion of the inventory has been hampered by a lack of cooperation and acceptance of a 

common strategy and goal by some of the participating organizations, as well as an 

unwillingness to share information on programs and projects. According to the ACWG 

Chairman, he has grown frustrated with learning about anticorruption initiatives after 

implementation rather than as part of a coordinated strategic approach that has been vetted by the 

ACWG. Learning about anticorruption initiatives, after the fact, does not allow for optimal 

coordination and utilization of available resources to achieve the ACWG’s strategic goals. The 

solution is “a coordinated media approach, an inventory of all programs and projects, and the 

ACWG to coordinate Mission efforts.” 

One example of the lack of program coordination relates to the public education and outreach 

programs supporting anticorruption. The U.S. Embassy’s Public Affairs Section, the Iraq 

Reconstruction Management Office’s senior consultant to the Commission on Public Integrity, 

and U.S. Agency for International Development (USAID) are the primary organizations involved 

in this effort. Discussions that arose during our attendance at the weekly ACWG meetings 

indicated that these organizations have not always been fully aware of the public education and 

outreach work being performed by each other and could benefit from stronger interagency 

coordination. Recently, the ACWG established a media sub-group to ensure that all those 

working with the media are aware of the initiatives of each organization. 

Training is another example of an area that could benefit from better coordination. Four Iraqi 

institutions comprise the main infrastructure for Iraqi anticorruption efforts. They are: the 

Central Criminal Court of Iraq; Commission on Public Integrity; Board of Supreme Audit; and, 

the ministry inspectors general. Appendix D outlines some key responsibilities and provides a 

process flowchart on how each institution interacts within the anticorruption system. Training 

has been uneven with the Commission on Public Integrity and Central Criminal Court of Iraq 

receiving the most attention and the Board of Supreme Auditors and Ministry Inspectors General 

the least. Some discussion has taken place regarding the establishment of training facilities for 

the various institutions that range from one central facility for all institutions to separate facilities 

for each institution. The ACWG should identify the training requirements of these 

accountability organizations with special emphasis on core requirements that apply to all four 
7 

 

institutions, prioritize those requirements, and identify training solutions for them that can cut 

across multiple institutions to avoid duplication and optimize the use of scarce resources. This 

will also lead to these organizations working closer together and recognition of how each of their 

efforts collectively could achieve greater results. To its credit, the ACWG has begun efforts to 

focus on the training issue by preparing an inventory of anticorruption programs and including 

discussions in group meetings about coordinating training to avoid duplication of effort but much 

remains to be done. 

A critical component of the U.S. strategic plan is the creation of a joint U.S.-Iraq Anticorruption 

Working Group to help in establishing the reforms within Iraq. The pace of the formation of an 

Iraqi government has delayed creation of this working group. More importantly in the near term, 

to demonstrate to the Iraqi people its government’s political will and to help restore public 

confidence in the integrity of their government, anticorruption initiatives must be Iraqi-led 

initiatives with the U.S. providing assistance. 

On May 17, 2006, we met with the Deputy Chief of Mission who stated the immediate focus of 

attention for the U.S. Embassy’s Iraq mission (and for the Secretary of State) is the corruption 

that impacts on infrastructure integrity, particularly in the Ministries of Oil and Electricity. The 

Deputy Chief of Mission further stated that these infrastructures are critical to Iraq’s future 

stability. 

Another U.S. Embassy working group, the Infrastructure Integrity Task Force, chaired by the 

Embassy’s Ambassador for Political-Military Affairs, also meets weekly and addresses 

corruption to a lesser extent, as well as sabotage, smuggling and theft within the oil and 

electricity sectors. This working group’s focus is the protection of revenue-producing 

infrastructure and the effective delivery of essential services. The Coordinator for Infrastructure 

Integrity Issues also attends the ACWG weekly meetings. SIGIR now attends the weekly 

Infrastructure Integrity Task Force meetings as observers. 

Resources. Precise calculation of funding related to anticorruption poses a challenge because it 

is often embedded in programs designed ostensibly for other purposes. For example, USAID has 

expended approximately $10 million through April 2006 to install and implement the payment 

module of the electronic Iraqi Financial Management System. The primary purpose of the 

electronic payment system is to provide accountability and transparency for Iraqi government 

payments which should provide anticorruption benefits. The Multi-National Security Transition 

Command-Iraq is funding a $143 million contract to, among other things; establish an Iraqi 

military leadership center for the Ministry of Defense. The leadership center will include 

training in the ethics and values required of a professional military but which should also have 

long-term anticorruption benefits. 

However one measures the embedded anticorruption funding, the expenditure of U.S. 

government funds on anticorruption has been modest when compared to the total spent for Iraq 

reconstruction. Funding has come primarily from the Iraq Relief and Reconstruction Fund 

(IRRF), and the main conduits for government anticorruption funding have been USAID, the 

DoS Bureau of International Narcotics and Law Enforcement Affairs, the Department of 

Treasury, and Multi-National Security Transition Command-Iraq. Total funding for ongoing and 

planned anticorruption activities identified through June 15, 2006, was approximately $65 

million. This represents less than .003% of the total IRRF funding to date of over 

$20.88 billion4

. For an inventory of current and proposed anticorruption program funding, 

developed during this survey, see Appendix C. 

4

 U.S. Congress appropriated $2.48 billion under Public Law 108-11, and an additional $18.4 billion under Public 

Law 108-106, for a total of $20.88 billion for the reconstruction of Iraq. 
8 

Although, given that only a modest amount of funding for anticorruption has been identified, we 

did not identify nor has the ACWG made a case for additional funding, other than the need to 

add additional staff to provide overall leadership and program continuity. When the ACWG 

does focus more on its programs and required resources, additional U.S. funding for 

anticorruption programs beyond FY 2006 will be problematic at best, due to the decline of 

available IRRF funds as reconstruction enters its final phase and overall constraints on the U.S. 

budget. The recent formation of the Iraqi government provides a new opportunity to engage the 

government in initiatives that can institutionalize anticorruption reforms. 

Challenges for the U.S. Embassy and anticorruption program officials include convincing the 

Iraqi government to commit sufficient Iraqi resources to reduce the level of corruption. 

Although we are seeing audit reports from several of the Ministry Inspectors General and the 

Board of Supreme Audit and investigative cases from the Commission on Public Integrity that 

are addressing corruption, Iraqi government support for anticorruption efforts has been uneven. 

For example, the Iraqi government committed to funding a training institute for the Commission 

on Public Integrity, but has largely neglected support for the inspectors general training. 

Specifically, in October 2005, the DoS OIG issued a Report of Inspection, “Inspection of Ruleof-Law Programs, Embassy Baghdad.” The report made 21 recommendations regarding Rule of 

Law initiatives, and the U.S. Embassy-Iraq was directly responsible for taking corrective actions 

for 13 of the recommendations. In addition, the U.S. Embassy-Iraq has coordination 

responsibilities for corrective actions on 3 of the remaining 8 recommendations, and 5 

recommendations are the responsibility of other State Department sections or bureau for 

corrective actions. 

Recommendation number 20 in the report directly addressed anticorruption and specifically 

stated, “Embassy, Baghdad, in coordination with the Bureau of International Narcotics and Law 

Enforcement Affairs, should seek and support Iraqi efforts to design and establish a training 

facility for anticorruption personnel from, and with the support of, all three institutions of the 

Iraqi anticorruption structure”. The institutions referred to were the Board of Supreme Audit, 

Ministry Inspectors General, and the Commission on Public Integrity. 

The U.S. Embassy response to this recommendation was “generally supports this concept. 

However, this proposal requires agreement among several entities of the Iraqi government as 

well as significant commitments of funds and personnel. Embassy will continue to evaluate the 

viability of this concept and its likely benefits vis-a-vis other proposals.” 

Our review disclosed that although the Iraqi government has provided initial funds to the 

Commission on Public Integrity to establish this initiative, the recommendation continues to be 

evaluated by the U.S. Embassy-Iraq, and no further progress has been made in obtaining a 

facility for all three anticorruption institutions. 

On May 18, 2006, we met with Ministry of Interior officials, the Interior Inspector General, and 

the Inspector General’s Audit Director. Through a translator, we spoke to the Audit Director 

about the challenges faced in providing oversight to Ministry of Interior programs. The Audit 

Director stated that he has six auditors to review Ministry of Interior programs and only one 

computer to support the six auditors. According to the Audit Director he needs 70 auditors to 

provide adequate oversight of Interior programs throughout the country. If the Iraqi government 

hopes to institutionalize anticorruption reforms, adequate resources and independent budgets are 

needed for all the accountability organizations and their auditors, inspectors and investigators. 

The issue of adequate resources should be addressed by the joint U.S.-Iraq Anticorruption 

Working Group. 
9 

 

Further, security concerns, the lack of a permanent full-time Iraqi government, and corruption 

perceptions, have constrained the full participation of international donors in Iraq reconstruction 

and development to date. Even so, international donors have provided funding for various Iraqi 

projects through mechanisms such as the International Reconstruction Fund Facility for Iraq 

which includes the World Bank International Trust Fund and the United Nations Development 

Group’s Iraq Trust Fund. Twenty-six donors have pledged $1.4 billion to the International 

Reconstruction Fund Facility for Iraq. Anticorruption funding from these sources has been 

limited to date although that appears to be changing. For example, the United Nations 

Development Group recently financed a $4.8 million project to have the Audit Board of Jordan 

provide training to Iraq’s Board of Supreme Audit over an 18 month period. In addition, the 

International Compact for Iraq5 has identified donors who may become involved in 

anticorruption projects. 

On May 20, 2006, the newly appointed Iraqi Prime Minister, in presenting the newly formed 

Council of Ministers to the Iraqi Parliament, outlined a 33-point program designed to restore 

Iraqi sovereignty and provide for good governance. The Prime Minister identified specific 

challenges facing the new government including “tackling administrative and financial 

corruption." The forming of the new Iraqi government will set the stage for a critical U.S. 

anticorruption initiative, the joint U.S.-Iraq Anticorruption Working Group, to provide focused 

joint attention on anticorruption issues. Until recently, the pace of government formation 

precluded this initiative. On June 20, 2006, we met with the Deputy Prime Minister who 

informed us that corruption was getting worse and that anticorruption initiatives are a high 

priority for the new Iraqi government. He further stated the types of international assistance 

needed, among other support, to include training and assistance in developing new policies and 

processes for procurement and financial management. 

Other Available Support. During the course of this survey, we noted several U.S. and 

international organizations that have offered or may be able to provide support to the Iraqi 

government in establishing its anticorruption programs. These are our observations: 

• In January 2006, the U.S. Comptroller General, head of the U.S. Government Accountability 

Office, visited Iraq and met with the President of the Board of Supreme Audit, at which time 

he pledged assistance in providing training. The President’s Council on Integrity and 

Efficiency which is comprised of various U.S. Offices of Inspectors General, also pledged to 

provide assistance to support the Ministry Inspectors General offices6. 

• The World Bank recently announced an expansion of its presence in Iraq. It recognizes the 

importance of reducing corruption and hopes to hold an anticorruption workshop in the near 

future that would include representatives from, among others, Iraq’s accountability 

organizations; the U.S. Department of Justice; and the U.S. Special Inspector General for 

Iraq Reconstruction. The World Bank recently performed an Operation Procurement Review 

and could be engaged to assist with developing procurement standards and appropriate 

changes to ensure procurement transparency. 

• Members of the Coalition are also participating in Iraq’s anticorruption capacity building. 

The British Embassy in Baghdad sends a representative who periodically attends the ACWG 

meetings. The British representative mentioned an interest in working on training issues with 

the anticorruption entities. In addition, the United Kingdom's National Board of Audits has 

conducted some anticorruption training for Board of Supreme Audit auditors in Amman, 

Jordan. 

5

 The International Compact for Iraq is a new initiative that addresses international support for long term initiatives 

including anticorruption. 

6 President’s Council on Integrity and Efficiency, proposal for Supporting Iraqi IG System – A nation building 

initiative, dated February 10, 2006. 
10 

 

• The Board of Supreme Audit is a member of the International Organization of Supreme 

Audit Institutions and it may benefit from a training offer from the Kingdom of Morocco's 

supreme audit agency. There is also a regional subgroup, the Arab Organization of the 

Supreme Audit Institutes, which could be a regional support group for the Iraqi 

accountability organizations. 

As illustrated, there are multiple sources of potential and actual support7 for assisting the Iraqi 

accountability offices in their efforts to fight corruption. However, we did not identify any 

single source for coordinating outreach to this type of support by the Iraqi government, the U.S. 

government, the Coalition, or international organizations. The issue of coordinating these 

resources could also be an initiative addressed by the joint U.S.-Iraq Anticorruption Working 

Group or an expansion of this joint work group to include a more international focus sometime in 

the future. 

7

 Our identification of sources is by no means complete. We identified many of these programs and efforts by 

means of informal sources. 
11 

International Leading Practices for Reducing 

Corruption 

Modeling international leading practices in anticorruption could engender both the political will 

to fight corruption and the capability to do so in Iraq. Organizations such as Transparency 

International, the United Nations, the World Bank, the International Monetary Fund, the 

Organizational Commission on Economic Development, and the other international agencies for 

international development support anticorruption and good governance programs throughout the 

world. These organizations also monitor and report accomplishments and lessons learned in 

anticorruption. Such reports could provide good, solid support for the Iraqi government as it 

formulates a strategy to fight corruption and reinforces the need to implement the required laws 

and standards to obtain International support for the new government. 

Another example of international assistance is the United Nations Convention that was adopted 

on October 31, 2003. According to the United Nations, this is the first legally binding 

instrument to combat corruption. The United Nations Convention Against Corruption (UNCAC) 

creates the opportunity to develop a global language about corruption and a coherent 

implementation strategy. As part of the United Nations efforts to assist countries in 

implementing its conventions, they are providing various resources. 

In order to gain citizens trust and confidence as well as progress towards economic growth and 

prosperity, best practices in the international fight against corruption identify three key 

contributing elements to good government and contributing key characteristics for each. The 

ability for Iraq to attract international donors to assist in democracy building will depend on its 

ability to reduce perceived government-wide corruption. The Table 1 identifies these 

contributing elements and key characteristics. 

 Table 1. Best Practices in Anticorruption

Contributing 

Elements 

Key Characteristics 

Rule of Law 

Incentives Civil Service Reform 

Checks and Balances 

Financial Disclosure 

Transparency Due Process 

Free Press 

Enforcement of Laws 

Accountability Oversight 

Independent Judiciary 

 Source: SIGIR Research. 

Other international leading practices promote strategic planning and budgeting, professional 

codes of conduct, civil society participation and oversight, whistleblower protection, conflict of 

interest rules, integrity pacts and debarment in contracting and rigorous prosecution, 

performance accountability reporting, and performance management. For the accountability 

organizations key characteristics also include independence and professional standards. 

However, the ability to successfully fight corruption in Iraq will ultimately depend on a 

sufficient level of commitment (political will) to implement reforms by the Iraqi’s themselves. 

Pervasive illegal activity negatively effects progress in reforming legal, judicial and economic 
12 

systems and sustaining policy objectives to fight corruption. The public will not judge the new 

Iraqi government’s anticorruption program to be a success without reaching milestones, such as: 

• improved survey results 

• aggressive prosecutions 

• adoption of anticorruption laws and regulations 

• creation of an impartial civil service system 

• transparency to the general public on financing of political parties and government 

procurement 

• equitable salaries for government officials 

Encouraging the use of a strategic approach with milestones and metrics to measure progress 

through self-assessment and external oversight by International organizations also creates an 

atmosphere of trust and viability with the public. 
13 

Conclusion and Recommendations 

Conclusion 

According to senior Iraqi officials, corruption is worsening in Iraq. Addressing corruption is a 

long-term effort and the new Iraqi government needs the assistance of the international 

community to provide leading practices and processes that provide transparency in government 

operations and promote the identification of corrupt practices or reduce the opportunities for 

corruption. 

An effective Iraqi government is basic to the success for democracy and good government in 

Iraq. Implanting integrity throughout Iraq’s public institutions is a generational challenge. The 

institutional framework for Iraqi anticorruption activities is in place but it is fragile and 

immature. Judicial prosecutions of corruption cases have been few. Improved collaboration 

among the three public integrity/accountability institutions, and between them and the courts, is a 

priority. 

The U.S. government has been active in assisting the Iraqi government in developing processes 

and practices to reduce corruption. In December 2005 the ACWG was re-energized and it is still 

in its early stages of becoming an effective organization. There is a recognition that more needs 

to be done to ensure effective coordination with the U.S. government and the Iraqi government. 

However, full time leadership is needed to ensure the U.S. efforts achieve the goals established 

in the current ACWG anticorruption strategy. 

Recommendations, Management Comments and Audit Response 

To ensure that greater emphasis is given to this important goal, we recommend to the U.S. 

Ambassador to Iraq: 

1. In response to the request from the U.S. Embassy-Iraq’s Economic Counselor, provide the 

necessary resources to have sufficient direction and oversight of the U.S. Embassy’s 

anticorruption program, including a senior leader from the Department of State and a senior 

officer from the Multi-National Force-Iraq. Both of these positions should be filled with 

staff that has such a background to bring value to the position. 

2. Continue the ongoing efforts to recruit an Iraqi local national staff member to provide 

support to a full-time Anticorruption Program Manager. This individual should have the 

necessary skills and rank to be instrumental in forging joint U.S.-Iraqi anticorruption 

initiatives. 

3. Establish a joint executive steering group, with the Anticorruption Program Manager as the 

chairperson, that would have oversight on all U.S. government anticorruption programs to 

ensure that all initiatives are working toward a common goal in the most efficient and 

effective manner. 

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. 

5. Establish a policy that will require all participating organizations to vet new anticorruption 

initiatives through the new joint executive steering group. 
14 

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. 

7. Direct the members of the ACWG to develop action plans for each activity’s program in 

concert with the overall strategic goals. 

8. Establish a baseline for each anticorruption program to document a starting point for the 

program in order to measure progress. 

9. Establish interim and long-term objective(s) for each anticorruption program consistent 

with the overall anticorruption program strategy. 

10. Engage the Iraqi anticorruption counterparts within the new government and establish the 

joint U.S.-Iraq Anticorruption Working Group. 

11. Encourage the new Iraqi government to establish its own anticorruption working groups 

with regional and international partners. 

12. Based on the unresolved recommendation number 20 from the October 2005 DoS OIG 

report, 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 Ministry Inspectors General with 

special emphasis on requirements that apply to all four institutions. 

b. Prioritize the identified training requirements. 

c. Identify training solutions for those requirements that can cut across multiple 

institutions to avoid duplication and maximize resources. 

 

Management Comments and Audit Response. We received comments from the U.S. 

Embassy-Iraq, who concurred with our findings and recommendations. Actions are being 

planned or are underway to implement the recommendations. Among the actions the Embassy 

Staff is taking is the appointment of a senior foreign service officer to supervise the 

anticorruption program, and the establishment of a joint executive steering group that will have 

oversight on all U.S. government anticorruption programs. We consider the Embassy’s 

comments to be fully responsive to our report. 
15 

Appendix A. Scope and Methodology

SIGIR and the DoS/OIG initiated this joint survey on April 14, 2006 (Project No. 6011). The 

objectives of the joint survey were to determine: (1) the U.S. government agencies participating 

in the anticorruption program in Iraq, and whether they have a coordinated strategic plan with 

identified goals; (2) whether program outcomes and metrics have been established to measure 

progress and success; and (3) whether organizational roles and responsibilities have been clearly 

identified and resources provided to meet the program goals. In addition, the survey was to 

identify international leading practices from other organizations that have had successful 

experience in reducing corruption and to compare the U.S. Embassy-Iraq Program to any lessons 

learned from these initiatives. 

To determine the U.S. government agencies participating in the anticorruption program in Iraq 

and whether they have a coordinated strategic plan, we attended the weekly U.S. Embassy 

Anticorruption Working Group (ACWG) meetings and reviewed previous meeting minutes. We 

also reviewed the Embassy’s Anticorruption Strategy, dated December 28, 2005. 

To determine whether anticorruption program outcomes and metrics have been established to 

measure progress and success, we reviewed the Embassy’s Anticorruption Strategy dated 

December 28, 2005, and discussed it with the ACWG Chairman. In addition, we interviewed the 

ACWG participants and reviewed available program documentation to determine if their 

individual anticorruption programs had identifiable outcomes and metrics. 

To determine whether organizational roles and responsibilities have been clearly identified and 

resources provided to meet the program goals, we interviewed the ACWG participants. We also 

reviewed several versions of the ACWG’s Anticorruption Programs Inventory. This document is 

continuously updated as funds are reallocated, old activities are completed, and new activities are 

started. The last ACWG programs inventory provided to us was dated May 21, 2006. 

To identify international leading practices from other organizations that have had successful 

experience in reducing corruption we researched numerous reports on how corruption was 

reduced in other countries throughout the world. 

We conducted this survey in Washington, D.C., between April 17 and May 7, 2006; and in 

Baghdad, Iraq, from April 2006 through June 2006. The survey was conducted in accordance 

with generally accepted government auditing and inspections standards. 

Use of Computer-Processed Data. We did not use computer-processed data to perform this 

survey. 

Prior Coverage. We reviewed the following reports. 

• Department of State, Office of the Inspector General, Report of Inspections, Rule of Law 

Programs, Embassy, Baghdad, Report #ISP,IQO-06-01, October 2005. 

• United Nations, Office of Drugs and Crime, Report on the Sixth Meeting of the 

International Group for Anti Corruption Coordination (IGAC, Brussels, 30 September – 

01 October 2004. 

• U.S. Government Accountability Office: Foreign Assistance: U.S. Anti-Corruption 

Programs in Sub-Saharan Africa – Will Require Time and Commitment (GAO-04-506) 

April 2004. 

• USAID, Audit of the Status of USAID’s Anti-Corruption Efforts in Assisted Countries, 

(Audit report No: 9-000-98-0002-P), 01 September 1998.
16 

Appendix B. U.S. Embassy’s Anticorruption Strategic 

Goals and Objectives 

1. Market Reforms 

a. Functioning market economy with market pricing of goods and services supplants 

state dominated economy 

b. State-Owned Enterprises dismantled 

c. Foreign Direct Investment on par for region and resource base 

d. Capital flight reversed 

2. Financial Transparency 

a. Iraqi government has standardized, transparent budget and procurement

procedures 

b. Iraq is an active partner with regional states, trading partners, potential investors 

and donors in investigating and combating corruption 

3. Public Integrity 

a. Iraqi government adheres to the rule of law

b. Government, donor and international financial institution resources are effectively 

utilized on behalf of Iraq’s people 

c. Media, Non-Government Organizations and public are active in anti-corruption 

effort 
17 

Appendix C. Anticorruption Program Inventory and 

Funding as of June 15, 2006 

The following information summarizes the anticorruption programs as determined by SIGIR and 

DoS OIG during this survey. 

Programs Funded Descriptions Notes 

Commission on Public Integrity (CPI) $8,519,000 INL Funding for CPI Efforts Note 1 

 2,679,000 IRMO Funding for CPI Efforts Note 1 

 500,000 INL Proposed Funding for CPI Media Anticorruption Work Note 2 

CPI Total $11,698,000 

Board of Supreme Audit (BSA) $1,000,000 INL Proposed Funding to Strengthen Training and Mentoring Note 2 

BSA Total $1,000,000 

Inspector General (IG)-All Ministries $2,000,000 INL Proposed Funding to Strengthen IG Training and Mentoring Note 2 

Inspector General-Ministry of Oil 600,000 IRMO Funding for IG Training Courses Note 3 

IG-Ministries of Defense and Interior 4,000,000 MNSTC-I Funding to Strengthen IG Training and Mentoring Note 4 

Inspector General Total $6,600,000 

Other $2,000,000 PAS Funding for Anticorruption Efforts Note 5 

 8,000,000 MNSTC-I Funded IJF Ethics and Leadership Center Note 6 

 12,100,000 USAID Funded Iraq Civil Society Program (ICSP) Note 7 

 2,500,000 INL Proposed Funding for USAID’s ICSP and Media Work Note 2 

 140,000 IRMO Funded Financial Management Training Courses Note 3 

 280,000 IRMO Funded E-government and IT Management Training Courses Note 3 

 5,000,000 INL Proposed Funding for the Financial Management Information 

 System (FMIS) Public Payroll Module Note 2 

 3,400,000 IRMO Funded FMIS Procurement and Budget Modules Note 8 

 12,000,000 USAID & Treasury Funding for FMIS Payment Module Note 9 

Other Total $45,420,000 

TOTAL PROGRAM FUNDS $64,718,000 

EXPLANATORY NOTES: 

Note 1: Commission on Public Integrity 

The Commission on Public Integrity (CPI) investigates allegations of corruption within the government. The Department of State’s Bureau of 

International Narcotics and Law Enforcement Affairs (INL) has provided $8,519,000 to support CPI investigator training provided through the 

Department of Justice’s International Criminal Investigative Training Program (ICITAP) and various support services such as translation 

activities through a contract with DynCorp International. The Iraq Reconstruction Management Office (IRMO) assigned a team of consultants to 

support the CPI and has expended $2,679,000 for, among other items, weapons, ammunition, and tactical training equipment, printing and 

publication of the Iraqi Code of Conduct and various education outreach efforts. 

Note 2: Proposed INL Funding 

The Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL) recently received a $15 million reallocation of 

Iraq Relief and Reconstruction Fund (IRRF) money for Rule of Law activities. INL designated $11 million of the reallocated funds to support 

specific anticorruption efforts in accordance with priorities established by the U.S. Embassy’s Anticorruption Working Group. Those priorities 

are funding the Iraq Financial Management Information System’s public payroll module; strengthen training and mentoring at the Board of 

Supreme Audit and ministry Inspectors General, providing additional funds for the U.S. Agency for International Development’s Iraq Civil 

Society Program, and USAID and CPI anticorruption media efforts. An INL representative told us the individual program priorities may change 

prior to final obligation of the funds but the entire $11 million would be used for anticorruption programs. 
18 

Note 3: Ministry of Oil Training Courses 

The Iraq Reconstruction Management Office (IRMO) proposes sending Ministry of Oil employees to training courses in Amman, Jordan, and 

Cairo, Egypt. The training courses are intended to expose the employees to modern practices in accounting, auditing, financial management and 

information technology. IRMO proposed funding $1,020,000 for this effort. 

Note 4: Ministries of Defense and Interior Inspector General Training and Mentoring 

Past assistance to the Inspector Generals has been primarily limited to mentoring by one part-time advisor. Recently, the Multi-National Security 

Transition Command-Iraq (MNSTC-I) established a capacity building program for the Ministries of Defense and Interior that includes embedding 

eight U.S. advisors in the inspector general and legal organizations. MNSTC-I estimated this effort will cost approximately $4 million. 

Note 5: U.S. Embassy Public Affairs Section (PAS) 

The Embassy’s public affairs section has been active in monitoring the media for coverage on anticorruption and organizing exchange programs 

and other training opportunities with anticorruption as the focus. Recently, the public affairs section received additional funding of $15 million 

directed to developing media programming. A PAS representative stated that $2 million of those funds would be dedicated to anticorruption 

efforts. 

Note 6: Iraqi Joint Force (IJF) Values and Leadership Center 

MNSTC-I is supporting the development of the Iraqi Center for Military Values, Principles and Leadership. Approximately $8 million has been 

committed for the Leadership Center. Its goal is to build an institution that will focus on doctrinal development and education and training to 

professionalize the Iraqi Joint Forces (IJF) in the specific areas of ethics and leadership. Its principal audience is Iraqi military personnel. There 

will be more than one teaching location. Initial staffing will include 13 contractor personnel, four military personnel and some Iraqi staff. The 

goal is to train Iraqi instructors who will be expected to continue the program. MPRI, Incorporated has been engaged to develop a full curriculum 

of ethical precepts and values for the Leadership Center as part of a $143 million capacity building contract. They have established 34 program 

outcomes they hope the Leadership Center will achieve but recognize that many of them require cultural changes that will take a generation or 

more to fully accomplish. 

Note 7: Iraq Civil Society Program 

The U.S. Agency for International Development funds a contract with America’s Development Foundation to strengthen civil society 

organizations. One key focus of the work is anticorruption. The total contract is valued at $43 million, with approximately $9 million dedicated 

to anticorruption efforts. USAID proposes funding the contract with an additional $16.2 million of reallocated funds with approximately $3.1 

million dedicated to anticorruption efforts. 

Note 8: Iraqi Financial Management Information System Procurement and Budget Modules 

The IRMO Office of Financial and Fiscal Affairs is providing $3.4 million to install and implement the procurement and budget modules of the 

Iraqi Financial Management Information System. These modules should provide greater accountability and transparency for Iraqi government 

financial transactions. 

Note 9: Iraqi Financial Management Information System Payment Module 

The U.S. Agency for International Development funds a BearingPoint contract to complete and install the payment module of the Iraqi Financial 

Management Information System (FMIS). The contractor has specific responsibility for developing and implementing the FMIS payment 

module. The project’s first task was to identify spending units throughout the country that have the independence to make payments, have bank 

accounts, and have the capability of creating trial balances. Approximately 56 spending units will receive the FMIS payment module in the first 

phase and 126 spending units will receive it during the second phase of implementation. Implementation means all personnel are trained, all 

necessary equipment has been installed, internet connectivity is available, and data can be input from the spending units directly into the central 

database at the Ministry of Finance. Approximately 85% of the requirements have been completed at a cost of $10 million. The U.S. Department 

of Treasury has agreed to fund an additional $2 million to complete the remaining requirements. 
Appendix D. Iraqi Anticorruption Accountability 

Organizations Process Flowchart 

Iraq Commission of Public 

Integrity (CPI) 

 -Full-time capacity development support 

 provided by IRMO Consultant to CPI 

-Iraq CPI Employs: 

• Financial Auditors 

• Investigators 

• Attorneys 

Board of Supreme Audit 

(BSA) 

Iraq’s Supreme Audit Institute 

-Works w/Treasury Attaché 

-Audits all government actions 

- Responsible for Iraqi audit and 

 accounting standards 

-Audits State Owned Banks 

-Receives limited capacity 

 development support 

Office of the Inspector General 

(IG’s) 

• 31 Ministries – Each have an IG 

Office 

• Audits records and investigates it’s 

Ministries 

- Receives limited capacity 

development support Central Criminal Court of Iraq 

(CCCI) 

Nationwide Primary 

Investigative and Trial Court 

CCCI Maintains 

• 18 Provinces 

• 57 Judges Nationwide 

 -24 in Baghdad 

 -12-15 hear insurgent cases 

 - 4 hear matters of Iraq CPI 

- Supported by U.S. DOJ 

- Assisted by U.S. Marshal Service 

Ministry 

Public 

Officials 

 Citizens 

Hotline 

 

Adjudications 

19 
20 

Appendix E. Acronyms 

BSA Board of Supreme Audit 

CCCI Central Criminal Court of Iraq 

CPA Coalition Provisional Authority 

CPI Commission on Public Integrity 

DoS Department of State 

IRMO Iraq Reconstruction Management Office 

IRRF Iraq Relief and Reconstruction Fund 

MNSTC-I Multi-National Security Transition Command-Iraq 

SIGIR Special Inspector General for Iraq Reconstruction 

USAID U.S. Agency for International Development 
21 

Appendix F. Report Distribution 

Department of State 

Secretary of State 

Senior Advisor to the Secretary and Coordinator for Iraq 

U.S. Ambassador to Iraq 

Director, Iraq Reconstruction Management Office 

Mission Director-Iraq, U.S. Agency for International Development 

Inspector General, Department of State 

Department of Defense 

Secretary of Defense 

Deputy Secretary of Defense 

Director, Defense Reconstruction Support Office 

Under Secretary of Defense (Comptroller)/Chief Financial Officer 

 Deputy Chief Financial Officer 

 Deputy Comptroller (Program/Budget) 

Inspector General, Department of Defense 

Director, Defense Contract Audit Agency 

Director, Defense Finance and Accounting Service 

Director, Defense Contract Management Agency 

Department of the Army 

Assistant Secretary of the Army for Acquisition, Logistics, and Technology 

Principal Deputy to the Assistant Secretary of the Army for Acquisition, 

Logistics, and Technology 

Deputy Assistant Secretary of the Army (Policy and Procurement) 

Director, Project and Contracting Office 

Commanding General, Joint Contracting Command-Iraq/Afghanistan 

Assistant Secretary of the Army for Financial Management and Comptroller 

Chief of Engineers and Commander, U.S. Army Corps of Engineers 

 Commanding General, Gulf Region Division 

Auditor General of the Army 

U.S. Central Command

Commanding General, Multi-National Force-Iraq 

Commanding General, Multi-National Security Transition Command-Iraq 

Commander, Joint Area Support Group-Central 

Other Federal Government Organizations 

Director, Office of Management and Budget 

Comptroller General of the United States 

Inspector General, Department of the Treasury 

Inspector General, Department of Commerce 

Inspector General, Department of Health and Human Services 

Inspector General, U.S. Agency for International Development 

President, Overseas Private Investment Corporation 

President, U.S. Institute for Peace 
22 

Congressional Committees and Subcommittees, Chairman and 

Ranking Minority Member 

U.S. Senate 

Senate Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on State, Foreign Operations and Related Programs 

Senate Committee on Armed Services 

Senate Committee on Foreign Relations 

Subcommittee on International Operations and Terrorism 

Subcommittee on Near Eastern and South Asian Affairs 

Senate Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Financial Management, Government Information and 

International Security 

Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the District of Columbia 

U.S. House of Representatives 

House Committee on Appropriations 

Subcommittee on Defense 

Subcommittee on Foreign Operations, Export Financing and Related Programs 

Subcommittee on Science, State, Justice and Commerce and Related Agencies 

House Committee on Armed Services 

House Committee on Government Reform 

Subcommittee on Management, Finance and Accountability 

Subcommittee on National Security, Emerging Threats and International 

Relations 

House Committee on International Relations 

Subcommittee on Middle East and Central Asia 
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Appendix G. Survey Team Members 

This report was prepared under the direction of Joseph T. McDermott, Assistant Inspector 

General for Audit, Office of the Special Inspector General for Iraq Reconstruction. 

The joint survey was conducted under the direction of Joseph T. McDermott, Assistant 

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

Reconstruction, and Ambassador Vincent Battle of the Department of State, Office of the 

Inspector General. 

Staff members who contributed to the report include: 

Glenn Furbish, SIGIR 

Robert Gabriel, SIGIR 

Frank Gulla, SIGIR 

Andrea Leopold, DoS OIG 

Sandra March, SIGIR 

Diane N. Recio, SIGIR 

Special thanks to Ms. Linda Ehrichs of Transparency International Berlin, Germany, for 

providing a copy of the Global Corruption Report 2006. 
Management Comments 

U.S. Embassy-Baghdad, Iraq 

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