Audit 

Report 

Coalition Provisional Authority Control 

Over Seized and Vested Assets 

Report Number 04-008 July 30, 2004 

Office of the Inspector General 

Coalition Provisional Authority 
COALITION PROVISIONAL AUTHORITY 

OFFICE OF THE INSPECTOR GENERAL

400 Army Navy Drive • Arlington, Virginia 22202

July 30, 2004 

MEMORANDUM FOR U.S. AMBASSADOR TO IRAQ 

DIRECTOR, IRAQ RECONSTRUCTION MANAGEMENT OFFICE 

SUBJECT: Reissue of Office of the Inspector General, Coalition Provisional Authority, 

Report Number. 04-008, “Coalition Provisional Authority Control Over Seized 

and Vested Assets Iraq” 

We are reissuing our report on the Coalition Provisional Authority Control Over Seized 

and Vested Assets Iraq dated July 28, 2004, to clarify a conclusion of the audit. Our clarification 

is reflected in the Executive Summary (page i) and on page 6 of this report. The summary of the 

audit was accurately reflected in the Quarterly Report and Semiannual Report to the United 

States Congress dated July 30, 2004. 

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 which mandates the 

conduct of audits relating to the treatment, handling, and expenditure of funds by the Coalition 

Provisional Authority or its successor entities on Iraq reconstruction, and of the programs, 

operations, and contracts carried out in utilizing such funds. We considered management 

comments on a draft of this report in preparing the final report. 

Comments on the draft of this report were responsive to our recommendations. 

Therefore, no additional comments are required. 

We appreciate the courtesies extended to the staff. Questions should be directed to Mr. 

Brian Flynn at (703) 343-9230 or Mr. William Whitehead at (703) 343-9229. Management may 

request a formal briefing on the results of this audit. See Appendix D for the report distribution. 

 Stuart W. Bowen, Jr. 

 Assistant Inspector General for Auditing 

 Coalition Provisional Authority 
i

Office of the Inspector General 

Coalition Provisional Authority 

Report Number 04-008 July 30, 2004 

Coalition Provisional Authority Control 

Over Seized and Vested Assets 

Executive Summary

Introduction. After major combat operations ceased in May 2003, the Coalition Provisional 

Authority (CPA) was established in order to provide for the temporary governance of Iraq. CPA 

Regulation Number 2, “Development Fund for Iraq,” June 10, 2003, established the role of CPA 

to manage the Developmental Fund for Iraq (DFI). United Nations Security Council Resolution 

1483, May 22, 2003, established the DFI. A portion of the funds for the DFI came from seized 

and vested assets. 

Objective. The overall objective was to determine whether the CPA implemented effective 

safeguards to ensure accountability and control for the seized and vested assets. Specifically, our 

objectives were to determine whether the CPA had adequate and effective policies and 

procedures in place to prevent fraud, waste, and abuse in the management of seized and vested 

funds; in the allocation, distribution, and controls of Iraqi non-cash assets; and whether all seized 

and vested assets were used for the benefit of the Iraqi people. 

Conclusions. Facilities Management Office personnel did not adequately manage, secure, and 

safeguard non-cash assets in compliance with CPA established policies and procedures for the 

management of non-cash assets. Further, an inventory was not performed to determine the noncash assets in the custody of the CPA. As a result, a potential loss or theft of non-cash assets 

existed and, therefore, CPA would not be able to ensure that non-cash assets would be available 

for the use and benefit of the Iraqi people. 

We examined 20 Program Review Board (PBR) requests and the supporting documentation for 

the associated 60 disbursements totaling $120.1 million. Of the 60 disbursements, no 

documentation existed in the files for 5 disbursements totaling $99.1 million and only the 

signature of the recipient existed in the files for 25 disbursements totaling $17.2 million. 

Further, one of the PRB requests did not have approval documents from the PRB or the CPA 

Administrator on file. As a result, the validity and the purpose of disbursements for $116.3 

million could not be determined at the time of the audit because of the absence of documentation 

in the files. However, during final discussions with the CPA Comptroller’s office at the 

conclusion of the audit, comptroller personnel produced the disbursement documentation and the 

approval documentation that we had identified as missing. 

Recommendations. We made three recommendations to improve the accountability and 

security of seized and vested assets. We recommended that: (1) the Director of the Iraq 

Reconstruction Management Office, the successor to the CPA, require that hand receipts for 

borrowed assets be reviewed to determine that the personnel signed as being responsible for the 

assets have not redeployed and that the locations of the assets are known; (2) provide the 

Ministry of Culture with the hand receipts for seized assets signed out to individuals or 
ii

organizations for their use; and (3) ensure seized and vested payment files contain proper 

documentation approving the use and disbursement of funds. 

Management Comments. We received comments on the draft report from the CPA Facilities 

Property Manager, the CPA Deputy Comptroller, and the Office of the Secretary of Defense 

(OSD). The CPA Facilities Property Manager and the CPA Deputy Comptroller concurred with 

the findings and recommendations. Officials of the OSD provided additional comments to the 

draft report, which were considered in the preparation of the final report. 

Audit Response. Management comments addressed the issues raised in the findings and actions 

planned and taken should correct the problems. 
Table of Contents 

Executive Summary i

Introduction

Background 1 

Objective 2 

Finding 

Management of Seized Non-Cash Assets 3 

Stewardship for Seized and Vested Cash 5 

Appendices 

A. Scope and Methodology 8 

B. Management Comments 9 

C. Acronyms 12 

D. Report Distribution 13

E. Audit Team Members 14
1 

Background 

After major combat operations ceased in May 2003, the Coalition Provisional Authority (CPA) 

was established in order to provide for the temporary governance of Iraq. CPA Regulation 

Number 2, “Development Fund for Iraq,” June 10, 2003, established the role of CPA to manage 

the Developmental Fund for Iraq (DFI). United Nations Security Council Resolution 1483, May 

22, 2003, established the DFI. A portion of the funds for the DFI came from seized and vested 

assets. The scope and methodology used to perform this audit are discussed at Appendix A. The 

acronyms used in this report are shown at Appendix C and the audit team members are shown at 

Appendix E. 

Seized Funds. A portion of the seized funds came from the assets of Baath Party members and 

Saddam Hussein that were held in bank accounts in countries other than the U.S. Other seized 

assets were funds recovered by coalition forces. All seized funds were under the stewardship of 

the CPA Comptroller’s office. 

Vested Funds. Vested funds came from the assets of Baath Party members and Saddam Hussein 

that were held in bank accounts within the U.S. Those assets were vested in the U.S Treasury by 

Executive Order 13290, March 24, 2003. All vested funds were under the stewardship of the 

CPA Comptroller’s office. 

Seized Non-Cash Assets. Along with the funds that were seized by coalition forces, there were 

numerous non-cash assets seized. During combat operations, coalition forces frequently came 

across and seized Baath Party assets such as artwork, jewels, rugs, and other assets. Those 

seized non-cash assets (non-cash assets) were to be turned over to the CPA, as directed by CPA 

Order Numbers 4 and 9. 

Coalition Provisional Authority Regulation Number 2. CPA Regulation Number 2, 

“Development Fund for Iraq,” June 10, 2003, described responsibilities for the administration, 

use, accounting, and auditing of the DFI. 

Coalition Provisional Authority Regulation Number 3. CPA Regulation Number 3, “Program 

Review Board,” June 18, 2003, assigned responsibility to the CPA Program Review Board for 

recommending disbursements of the seized and vested funds and assets.

Coalition Provisional Authority Order Number 4. CPA Order Number 4, “Management of 

Property and Assets of the Iraqi Baath Party,” May 25, 2003, required that all seized assets be 

placed under the control of the CPA. CPA Order Number 4 further provided that the CPA was 

to hold in trust all the property and assets of the Baath Party that had been seized in accordance 

with CPA Order Number 4 for the use and benefit of the people of Iraq. 

Coalition Provisional Authority Order Number 9. CPA Order Number 9, “Management and 

Use of Iraqi Public Property,” June 8, 2003, required that the CPA Facilities Management Office 

(FMO) compile and maintain a register of property and assets that documented relevant 

information concerning all public property occupied, used, managed, and assigned by the CPA. 
2 

Objective 

The overall objective was to determine whether the CPA implemented effective safeguards to 

ensure accountability and control for the seized and vested assets. Specifically, our objectives 

were to determine whether the CPA had adequate and effective policies and procedures in place 

to prevent fraud, waste, and abuse in the management of seized and vested funds; in the 

allocation, distribution, and controls of Iraqi non-cash assets; and whether all seized and vested 

assets were used for the benefit of the Iraqi people. 
3 

Management of Seized Non-Cash Assets 

FMO personnel did not adequately manage, secure, and safeguard non-cash assets in compliance 

with CPA established policies and procedures for the management of non-cash assets. Further, 

an inventory was not performed to determine the non-cash assets in the custody of the CPA. 

This occurred because FMO did not follow the guidance set forth by the CPA Administrator. As 

a result, a potential loss or theft of non-cash assets existed and, therefore, CPA would not be able 

to ensure that non-cash assets would be available for the use and benefit of the Iraqi people. 

Policies and Procedures for Seized Assets 

CPA Orders Number 4 required the CPA to compile and maintain a register of Baath Party 

property and assets and CPA Order Number 9 assigned the responsibility to FMO to compile and 

maintain a Register of Property and Assets. CPA Order Number 4 also stated that any 

expenditure or use of the seized assets by the CPA be recorded and open to audit. We believe 

that the intent of those two orders was to require FMO to be responsible for securing and 

safeguarding Iraqi non-cash assets and was designed to reduce the risk of fraud, waste, and abuse 

of seized assets. 

Management of Seized Non-Cash Assets 

FMO personnel did not adequately manage, secure, and safeguard non-cash assets in compliance 

with CPA established policies and procedures for the management of non-cash assets. Further, 

an inventory was not performed to determine the assets in the custody of the CPA. 

Use of Non-Cash Assets. The facilities management team did not follow the guidance set forth 

by the CPA Administrator in CPA Order Number 9. Although authorized to use seized assets by 

CPA Order Number 9, individuals or organizations utilizing the assets needed to be held 

responsible for their use. The FMO allowed personnel to sign out non-cash assets for use in 

offices and villas. We reviewed all 24 available sign out sheets and the following discrepancies 

were identified. 

• 4 of the 24 hand receipts were not completely filled out. 

• 2 of the 24 were not written on the correct form. 

• 1 of the 24 identified only the item being signed for but no other information. 

The items ranged from carpets and furniture to vases and wine glasses. Using the hand receipts 

that we acquired from the FMO, we attempted to verify the existence of the borrowed items. We 

were unable to verify the existence of all the non-cash assets due to the inadequate sign out 

procedures. 

Inventory of Non-Cash Assets. We attempted to review the prior inventories that were 

conducted on the items and determined that the only inventories were for the non-cash assets 

seized from Uday Hussein and some jewelry. An inventory had not been conducted on the 

vehicles and other assets of the old regime prior to the audit. The room where Uday Hussein’s 

assets were kept was inventoried once before our audit, but the inventory was incomplete. We 

inventoried the room and found more assets than had been originally recorded on the inventory. 

Numbers within the existing list of assets were skipped, and the previous inventory was not 

signed by the personnel who conducted the inventory. Also, personal items were kept in the 

same area with the non-cash assets. Management had the personal items removed. 
4 

Compliance With Established Policies and Procedures 

FMO did not follow the guidance set forth by the CPA Administrator. 

Chain-of-Custody. CPA facilities management personnel did not sign for the non-cash assets or 

take responsibility for them. Further, no accountable officer was assigned to control the noncash assets or ensure that a proper chain-of-custody existed. Without a signed chain-of-custody 

form, no visibility existed as to the person responsible for controlling the assets. 

The seized jewels were the only non-cash assets that had a chain-of-custody form. Although a 

chain-of-custody was present for the jewelry, the chain-of-custody form was more than 5 months 

old and the custodian had departed the country. No one else assumed responsibility; therefore, a 

valid chain-of custody did not exist. In addition, the previous chain-of-custody did not list the 

jewelry by item (it only stated that five boxes contained gems). The CPA facilities management 

team began to sign the chain-of-custody forms and take responsibility for the non-cash assets 

after auditors and management completed an inventory on April 25, 2004. FMO personnel took 

custody of the non-cash assets immediately after the inventory was completed. 

Tours of Non-Cash Assets. FMO allowed personnel to tour the facilities where the non-cash 

assets were stored. The assets should have been secured to prevent loss and damage to the 

goods. Instead of keeping personnel out of the seized assets room, the tours allowed groups into 

the room and encouraged photographs to be taken with the items. Once we discussed the tours 

with FMO management, the tours were stopped. Unsecured assets enhanced the chance of the 

theft of the non-cash assets. 

Conclusion 

The potential for loss or theft of non-cash assets existed without adequate inventory controls in 

place. The CPA would not be able to ensure that non-cash assets would be available for the use 

and benefit of the Iraqi people without adequate inventory controls in place. 

However, the Iraq Ministry of Culture took possession of the non-cash property after sovereignty 

passed to the Interim Iraqi Government. The Ministry plans to sell a majority of the assets and 

place the proceeds into an education fund for the Iraqi schools. If those actions occur, it would 

help to ensure that the non-cash assets benefit the Iraqi people. 
5 

Stewardship for Seized and Vested Cash 

We examined 20 Program Review Board (PBR) requests and the supporting documentation for 

the associated 60 disbursements totaling $120.1 million. Of the 60 disbursements, no 

documentation existed in the files for 5 disbursements totaling $99.1 million and only the 

signature of the recipient existed in the files for 25 disbursements totaling $17.2 million. 

Further, one of the PRB requests did not have approval documents from the PRB or the CPA 

Administrator on file. This occurred because the CPA Comptroller’s office did not ensure that 

the proper documentation to support the disbursements was maintained in the appropriate files. 

As a result, the validity and the purpose of disbursements for $116.3 million could not be 

determined. 

Policies and Procedures for Seized Assets 

CPA Regulation Number 2 stated that sums may be disbursed from DFI to meet humanitarian 

needs of the Iraqi people and for the economic reconstruction and repair of Iraq’s infrastructure; 

for the continued disarmament of Iraq; for the costs of Iraq’s civilian administration; and for 

other purposes benefiting the Iraqi people. It also states that only the CPA Administrator, or a 

person delegated to the duty, may approve disbursements from the DFI. 

Stewardship for Seized and Vested Cash 

We examined 20 Program Review Board (PBR) requests and the supporting documentation for 

the associated 60 disbursements totaling $120.1 million. Of the 60 disbursements, no 

documentation existed in the files for 5 disbursements totaling $99.1 million and only the 

signature of the recipient existed in the files for 25 disbursements totaling $17.2 million. 

Further, one of the PRB requests did not have approval documents from the PRB or the CPA 

Administrator on file. 

Support from Disbursements Made With Seized and Vested Funds. We reviewed each 

disbursement to verify whether support existed for the disbursement. Out of the 60 

disbursements reviewed, 30 contained adequate supporting documentation. The remaining 30 

disbursements had either no documentation of the disbursement on file or only contained the 

signature of the trusted person. Five disbursements had no documentation of the disbursement in 

the file. The total dollar value of the five disbursements was more than $99.1 million. The 

remaining 25 disbursements contained only the signature of the recipient and totaled more than 

$17.2 million. 

PRB number 555 contained only the signature of the trusted person and no other supporting 

documentation for the disbursement. PRB 555 was used to make a cash disbursement to the 

Governing Council Housing Security project. The Governing Council Housing Security project 

was established in order to allow the Governing Council personnel a secure place to live while 

serving as a member of the council. Proper supporting documentation reduces the risk of fraud, 

waste, and abuse. 

Approval for Projects Using Seized and Vested Funds. We reviewed the documentation 

maintained by the CPA Comptroller’s office to determine whether the 20 selected requests for 

funding using seized and vested funds were properly approved. We reviewed the requests to 

determine if approval was accomplished by both the PRB and the CPA Administrator. Out of 

the 20 PRB requests reviewed, one approval (PBR number 463) was not on file. PRB number 

463 provided $60 million to replenish the Commanders Emergency Response Fund. The 
6 

Commanders Emergency Response Fund provides funds for reconstruction and rehabilitation 

projects managed primarily by U.S. Army division commanders. 

Supporting Documentation 

The CPA Comptroller’s office did not ensure that the proper documentation to support the 

disbursements was maintained in the appropriate files. 

Approval Process. The CPA Comptroller’s office served as the steward of the seized and 

vested funds. The CPA Comptroller’s office should not have allocated funds unless the PRB and 

CPA Administrator approved the funds. After required approvals, the CPA Comptroller’s office 

allocated the funds for the approved project. The disbursal of funds occurred when the party 

responsible for the project requested the funds be disbursed. 

Documentation of Disbursements. The individual or agency to which the funds were disbursed 

then became responsible for providing the supporting documentation to the CPA Comptroller’s 

office for the payment. The CPA Comptroller’s office did not ensure that the proper 

documentation to support the disbursements was maintained in the appropriate files. 

Use of Seized and Vested Cash to Benefit the Iraqi People 

The PRB board discussed projects at their meetings and decided which ones should be funded, as 

well as, which fund source (seized, vested, or other DFI) should be used to pay for the project. 

We reviewed 20 projects that were approved by the PRB board. The 20 projects described 

within each PRB were determined to be for the benefit of the Iraqi people. 

For example, PRB number 557 established the Sunni Engagement Strategy. The 82nd Airborne 

Division Sunni Engagement Strategy was for proposed incentives, including a surge in highvisibility, quick–impact projects to engage and enfranchise Iraqi moderates. The Sunni 

Engagement Strategy was intended to address a number of overlapping concerns affecting a 

variety of discrete elements of Iraqi society. The 82nd Airborne Division targeted Sunni 

communities and leaders within a particular geographic area to foster an Iraqi national identity 

not based on sectarian or ethnic lines. 

Conclusion 

The validity and the purpose of disbursements for $116.3 million could not be determined at the 

time of the audit because of the absence of documentation in the files. However, during final 

discussions with the CPA Comptroller’s office at the conclusion of the audit, comptroller 

personnel produced the disbursement documentation and the approval documentation that we 

had identified as missing. 

Recommendations, Management Comments, and Audit 

Response 

We recommend that the Director of the Iraq Reconstruction Management Office, the successor to 

the CPA, require: 

1. The Facilities Management Office review all outstanding receipts for borrowed assets 

and determine where the assets are located. Ensure that the personnel signed as being 
7 

responsible for the assets have not redeployed and that the locations of the assets are 

known. 

2. The Facilities Management Office provide the Ministry of Culture with hand receipts for 

seized assets signed out by individuals or organizations. 

3. The Comptroller’s office ensure seized and vested payment files contain documentation 

approving the use and disbursement of funds. 

Management Comments. We received comments on the draft report from the CPA Facilities 

Property Manager, the CPA Deputy Comptroller, and the Office of the Secretary of Defense 

(OSD). The CPA Facilities Property Manager and the CPA Deputy Comptroller concurred with 

the findings and recommendations. The management comments are shown at Appendix B. 

Officials of the OSD provided additional comments to the draft report, which were considered in 

the preparation of the final report. We have synopsized management comments from the CPA 

Facilities Property Manager and the CPA Deputy Comptroller in the two paragraphs below. 

• CPA Facilities Property Manager. “We concur with recommendation 1 which is in 

line with actions that are already underway. All assets are now being inventoried and 

accounted for in accordance with Army Regulation 735-5, Policies and Procedures for 

Property Accountability and NMF-I FRACO 801, OIF Property Accountability 

Procedures. Assets removed from the storage warehouse were issued on hand receipts. 

Those hand receipts will be reviewed and determination of the location of those assets 

will be confirmed. These assets will either be returned to control of the Facilities 

Management Office for turn over to the Iraqi Ministry of Culture or an updated hand 

receipt for the item will be obtained, noting the location of each asset and person 

responsible for it.” In response to Recommendation 2: “FMO has turned over all assets 

to the Ministry of Culture or will provide the Ministry with a current hand receipt for any 

assets that remain signed out.”

• CPA Deputy Comptroller. “Although the CPA-IG originally did not find all the 

required documentation, we are pleased to note that the CPA-IG noted by the conclusion 

of the audit all information requested of the Comptroller’s office was provided by the 

conclusion of the audit. Furthermore, we have implemented corrective action and concur 

with Audit Recommendation 3.” 

Audit Response. Management comments addressed the issues raised in the findings and actions 

planned and taken should correct the problems. 
8 

Appendix A. Scope and Methodology 

We performed this audit from May 2004 through June 2004, in accordance with generally 

accepted government auditing standards. 

We reviewed the following Coalition Provisional Authority (CPA) Orders and Memorandums: 

• CPA Memorandum Number 7, “Delegation of Authority Under De-Baathification Order 

No. 1,” May 16, 2003 

• CPA Order Number 2, “Dissolution of Entities,” May 23, 2003 

• CPA Order Number 4, “Management of Property and Assets of the Iraqi Baath Party,” 

May 25, 2003 

• CPA Order Number 6, “Eviction of Persons Illegally Occupying Public Buildings,” June 

8, 2003 

• CPA Order Number 9, “Management and Use of Iraqi Public Property,” June 8, 2003 

• CPA Regulation Number 2, “Development Fund for Iraq,” June 10, 2003 

• CPA Regulation Number 3, “Program Review Board,” June 18, 2003 

Scope Limitation. Our scope was limited due to time and resource constraints and we were 

unable to visit projects funded by seized and vested assets due to security reasons.

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

audit. 
9 

Appendix B. Management Comments, Coalition 

Provisional Authority Facility Manager

July 19, 2004 

MEMORANDUM FOR DIRECTOR, IRAQ RECONSTRUCTION MANAGEMENT 

OFFICE 

SUBJECT: Management Comments for Draft Report, Audit of the Coalition Provisional 

Authority Control Over Seized and Vested Assets 

(Project No. D2004-DCAAF-0028) 

In response to the Coalition Provisional Authority Inspector General’s (CPA-IG) request for 

comments concerning the subject draft audit report, we generally concur with the reported 

findings for recommendations one and two that relate to the Facility Management Office (FMO) 

and we can demonstrate that actions were being carried out and are continuing in order to correct 

the findings related to FMO. Although we generally concur with the findings, we would like to 

provide specific comments on some of the findings that we believe need to be reported in the 

context that CPA’s operations were in a time of extreme exigency, austerity, and difficulty – a 

declared Combat Zone. 

While major combat operations ceased in May 2003 (as noted by the report), significant 

resources were still tied up in security operations. Therefore tasks such as inventorying seized 

assets were necessarily accorded lower priority when allocating limited resources. However, the 

FMO made every effort to secure the assets in warehouses and secure storage spaces until such 

time that adequate inventories listing could be compiled. While awaiting the resources to 

prepare inventory listings, the FMO was tasked with standing up the CPA as it began operations 

in Iraq. CPA order number nine authorized the use of seized assets provided the individuals or 

organizations using the assets were held responsible for those assets. The initial start up of the 

CPA demonstrated that procedures were needed to maintain accountability. Therefore the FMO 

implemented a hand receipt process to track accountability of seized assets. As noted in our 

detailed response to audit recommendation number one, additional accountability steps are 

currently underway. 

Recommendation 1. Management Comment: We concur with the recommendation, which is in 

line with actions that are already underway. As CPA and CJTF-7 transitioned to the State 

Department and MNF-I, a Property Accountability Task Force was initiated by the Transition 

Team to clean up the battlefield. All assets are now being inventoried and accounted for in 

accordance with Army Regulation 735-5, Policies and Procedures for Property Accountability 

and NMF-I FRACO 801, OIF Property Accountability Procedures. Assets removed from the 

storage warehouse were issued on hand receipts. Those hand receipts will be reviewed and 

determination of the location of those assets will be confirmed. These assets will either be 

returned to control of the Facilities Management Office for turn over to the Iraqi Ministry of 

Culture or an updated hand receipt for the item will be obtained, noting the location of each asset 

and person responsible for it. The estimated completion date for this action is September 30, 

2004. 
10 

Recommendation 2. Management Comment: Concur. FMO has turned over all assets to the 

Ministry of Culture or will provide the Ministry with a current hand receipt for any assets that 

remain signed out. The estimated completion date for this action is October 29, 2004, 

If you have any questions or concerns with our comments, please contact me at (318) 239-8982 

or by email at bartletts@orha.centcom.mil. 

Captain Stephen W.Bartlett, Sr., U.S. Navy 

CPA Facility Manager (Authority expired 28 June 2004) 
11 

Appendix B. Management Comments (cont) Deputy 

Comptroller, Iraq Reconstruction Management Office 

July 19, 2004 

INFORMATION MEMORANDUM 

UNCLASSIFIED 

TO: Dave Nash, Director, Iraq Reconstruction Management Office (IRMO) 

FROM: Gilbert Reed III, JASG-C Deputy Comptroller/Budget Officer 

SUBJECT: Coalition Provisional Authority Control Over Seized and Vested Assets 

(Project Number D2004-DCPAAF-0028) 

In response to the CPA-IG’s request for comments concerning the subject draft audit report, we 

concur with the reported finding and recommendation related to allocation and expenditure of 

seized and vested funds. Although the CPA-IG originally did not find all the required 

documentation, we are pleased to note that the CPA-IG noted by the conclusion of the audit all 

information requested of the Comptroller’s office was provided by the conclusion of the audit. 

Furthermore, we have implemented corrective action and concur with Audit Recommendation 3 

which states: We recommend that the Director of the Iraq Reconstruction Management Office, 

the successor to the Coalition Provisional Authority, require the Comptroller’s office to ensure 

seized and vested payment files contain documentation approving the use and disbursement of 

funds. 

These comments were collected and are being submitted by Iraq Reconstruction Management 

Office/Ministry of Finance/Office of Management and Budget. 

Gilbert Reed III, JASG-C Deputy Comptroller/Budget Officer 

914-360-6491 07/19/04 
12 

Appendix C. Acronyms 

CPA Coalition Provisional Authority 

DFI Developmental Fund for Iraq 

FMO Facilities Management Office 

OSD Office of the Secretary of Defense 

PRB Program Review Board 
13 

Appendix D. Report Distribution 

Office of the Secretary of Defense 

Under Secretary of Defense (Comptroller)/Chief Financial Officer 

 Director, Program Analysis and Evaluation 

 Deputy Chief Financial Officer 

 Deputy Comptroller (Program/Budget) 

Inspector General, Department of Defense 

Director, Defense Procurement and Acquisition 

Department of Defense, Iraq Support Group 

 Deputy for Policy 

Office of the Secretary of State 

Inspector General, Department of State 

Department of the Army 

Assistant Secretary of the Army, Acquisition, Logistics & Technology 

 Assistant Secretary of the Army for Policy and Procurement 

Auditor General, Department of the Army 

Other Defense Organizations

Director, Defense Contract Audit Agency 

Director, Iraq Project and Contracting Office 

Federal Government Organizations 

Office of Management and Budget 

Government Accountability Office 

Inspector General, Department of Commerce 

Inspector General, Health and Human Services 

Inspector General, U.S. Agency for International Development 

Congressional Committees and Subcommittees, Chairman and 

Ranking Minority Member 

Senate Committee on Appropriations 

Senate Subcommittee on Defense, Committee on Appropriations 

Senate Committee on Armed Services 

Senate Committee on Governmental Affairs 

Senate Committee on Foreign Relations 

House Committee on Appropriations 

House Subcommittee on Defense, Committee on Appropriations 

House Committee on Armed Services 

House Committee on Government Reform 

House Subcommittee on Government Efficiency and Financial Management, Committee on 

Government Reform 

House Subcommittee on National Security, Emerging Threats, and International Relations, 

Committee on Government Reform 

House Subcommittee on Technology, Information Policy, Intergovernmental Relations, and the 

Census, Committee on Government Reform 
14 

Appendix E. Audit Team Members 

The Financial Management Division, Office of the Assistant Inspector General for Auditing, 

Coalition Provisional Authority, prepared this report. Personnel of the Office of the Assistant 

Inspector General for Auditing, Coalition Provisional Authority, who contributed to the report, 

are listed below. 

John Betar 

Brian Flynn 

Robert Murrell 

William Whitehead 

Kevin Ellenberger 

Walter Bohinski 

David Griffin 

James Hartman 

Jeff Marshall 

Leona Brendt 

Troy Zigler