SIGAR

SPECIAL INSPECTOR GENERAL

FOR AFGHANISTAN RECONSTRUCTION

2530 Crystal Drive

Arlington, VA 22202

www.sigar.mil

FRAUD, WASTE, OR ABUSE MAY BE REPORTED TO SIGAR’S HOTLINE

By phone: Afghanistan

Cell: 0700107300

DSN: 318-237-3912 ext. 7303

All voicemail is in Dari, Pashto, and English.

By phone: United States

Toll-free: 866-329-8893

DSN: 312-664-0378

All voicemail is in English and answered during business hours.

By fax: 703-601-4065

By email: sigar.hotline@mail.mil

By Web submission: www.sigar.mil/investigations/hotline/report-fraud.aspx
Cover photo credit: Getty Images

PAKTIKA

KHOWST

TAKHAR

BADAKHSHAN

BAGHLAN

BAMYAN

FARYAB

WARDAK

KUNAR

KUNDUZ

NURISTAN

NANGARHAR

FARAH

NIMROZ

HELMAND

KANDAHAR

URUZGAN

ZABUL

GHOR

GHAZNI

BALKH

BADGHIS

KABUL

KAPISA

PAKTIYA

LOGAR

LAGHMAN

JOWZJAN

PARWAN

SAR-E PUL

HERAT

DAYKUNDI

SAMANGAN

PANJSHIR
Special Inspector General

for

Afghanistan Reconstruction

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

Corruption in Conflict: Lessons from the U.S. Experience in Afghanistan is 

the first in a series of lessons learned reports planned to be issued by the Special 

Inspector General for Afghanistan Reconstruction (SIGAR). The report examines 

how the U.S. government—primarily the Departments of Defense, State, Treasury, 

and Justice, and the U.S. Agency for International Development—understood the 

risks of corruption in Afghanistan, how the U.S. response to corruption evolved, 

and the effectiveness of that response. The report identifies lessons to inform 

U.S. policies and actions at the onset of and throughout a contingency operation 

and makes recommendations for both legislative and executive branch action.

Our analysis reveals that corruption substantially undermined the U.S. mission in 

Afghanistan from the very beginning of Operation Enduring Freedom. We found 

that corruption cut across all aspects of the reconstruction effort, jeopardizing 

progress made in security, rule of law, governance, and economic growth. We 

conclude that failure to effectively address the problem means U.S. reconstruction 

programs, at best, will continue to be subverted by systemic corruption and, at 

worst, will fail. 

SIGAR began its lessons learned program, in part, at the urging of General John 

Allen, Ambassador Ryan Crocker, and others who had served in Afghanistan. 

This report and those that will follow comply with SIGAR’s legislative mandate 

to provide recommendations to promote economy, efficiency, effectiveness, and 

leadership on policies to prevent and detect waste, fraud, and abuse, as well as 

to inform Congress and the Secretaries of State and Defense about problems and 

deficiencies relating to reconstruction and the need for corrective action. 

Unlike other inspectors general, Congress created SIGAR as an independent 

agency, not housed inside any single department, and it is thus able to provide 

independent and objective oversight of Afghanistan reconstruction projects and 

activities. SIGAR is the only inspector general focused solely on the Afghanistan 

mission, and the only one devoted exclusively to reconstruction issues. While 

other inspectors general have jurisdiction over the programs and operations 

of their respective departments or agencies, SIGAR has jurisdiction to conduct 

audits and investigations of all programs and operations supported with 

U.S. reconstruction dollars, regardless of the agency involved. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

Because SIGAR is the only inspector general with the authority to look across 

the entire reconstruction effort, it is uniquely positioned to identify and address 

whole-of-government lessons learned. As Corruption in Conflict has done, future 

lessons learned reports will synthesize not only the body of work and expertise 

of SIGAR, but also that of other oversight agencies, government bodies, current 

and former officials with on-the-ground experience, academic institutions, and 

independent scholars. Future reports will focus on other key aspects of the 

reconstruction effort and will document what the U.S. government sought to 

accomplish, assess what it achieved, and evaluate the degree to which these 

efforts helped the United States reach its strategic goals in Afghanistan. The 

reports will contain recommendations to address the challenges stakeholders face 

in ensuring efficient, effective, and sustainable reconstruction efforts, not just in 

Afghanistan, but in future conflict zones. 

SIGAR’s lessons learned program comprises subject matter experts with 

considerable experience working and living in Afghanistan, aided by a team of 

experienced research analysts. In producing its reports, SIGAR also uses the 

significant skills and experience found in its Audits, Investigations, and Research 

and Analysis Directorates, and the Office of Special Projects. I want to express 

my deepest appreciation to the research team that produced this report, and 

thank them for their dedication and commitment to this project. I also want to 

thank all of the individuals—especially the agency officials, academics, subject 

matter experts, and others—who provided their time and effort to contribute to 

this report. It is truly a collaborative effort meant to not only observe problems, 

but also to learn from them and apply reasonable solutions to improve future 

reconstruction efforts.

I believe the lessons learned reports will be a key legacy of SIGAR. Through these 

reports, we hope to reach a diverse audience in the legislative and executive 

branches, at strategic and programmatic levels, both in Washington, D.C. and 

in the field. By leveraging our unique interagency mandate, we intend to do 

everything we can to make sure the lessons from the United States’ largest 

reconstruction effort are identified, acknowledged, and, most importantly, 

remembered and applied to reconstruction efforts in Afghanistan, as well as to 

future conflicts and reconstruction efforts elsewhere in the world. 

John F. Sopko 

Special Inspector General 

for Afghanistan Reconstruction
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

TABLE OF CONTENTS

EXECUTIVE SUMMARY i

INTRODUCTION 1

What Is Corruption? 2

Systemic Corruption, a Dilemma for 

Anticorruption Efforts 4

Measuring Corruption 5

Corruption Has Increased from Pre-2001 Levels 6

Why Should U.S. Policymakers Care About 

Corruption in a Conflict Environment? 10

Possible Reasons the U.S. Government Failed 

to See the Problem 12

A Framework for Anticorruption Efforts 13

PART ONE

Failure to Fully Appreciate the Corruption 

Threat: 2001–2008 15

A Focus on Counterterrorism, Political Transition, 

and Reconstruction 16

Emerging But Insufficient Appreciation for the 

Corruption Threat 20

Limited U.S. Efforts to Address Corruption 23

Donors Begin to Consolidate Thinking on 

Anticorruption, But Still Face Obstacles 26

Summary: Obstacles to Advancing an 

Anticorruption Agenda 28

PART TWO 

A Call to Action: 2009–2010 31

A New Strategy and Reinvigorated 

Counterinsurgency Effort 32

Corruption Increasingly Seen as a Critical Threat 33

High-Water Mark for U.S. Anticorruption Efforts 39

The Salehi Arrest: A Major Setback 43

The Near-Collapse of Kabul Bank: 

Fraud on an Unprecedented Scale 44

Summary: Dilemmas for U.S. 

Anticorruption Efforts 45
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

PART THREE

A Limited U.S. Government Response to 

Corruption: 2010–2014 47

Competing High-Level Priorities 48

Corruption Seen as a Serious Threat to 

the Mission 49

U.S. Efforts to Encourage Afghan Reform 

and Accountability 52

International Donor Engagement 61

Efforts to Improve Oversight of U.S. Assistance 63

Summary: A Lack of Political Commitment 

and Misperceptions of Leverage 67

CONCLUSIONS 71

LESSONS 75

RECOMMENDATIONS 81

Legislative Recommendations 81

Executive Branch Recommendations 83

APPENDIX A: METHODOLOGY 87

APPENDIX B: ABBREVIATIONS 90

APPENDIX C: SURVEY DATA ON CORRUPTION 93

APPENDIX D: STRATEGIES AND PLANS: 2009–2010 94

APPENDIX E: U.S. AND ISAF ORGANIZATIONS 95

APPENDIX F: AFGHAN ANTICORRUPTION ORGANIZATIONS 98

ENDNOTES 100

SELECT BIBLIOGRAPHY 130

ACKNOWLEDGMENTS 150
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

ILLUSTRATIONS

FIGURE 1: Share of Respondents Who Said Corruption Was a Major Problem in Daily Life 6

FIGURE 2: Share of Respondents Who Had Contacted Government Officials and Reported 

Experiencing Corruption 7

FIGURE 3: U.S. Appropriated Reconstruction Funding Compared to Afghanistan’s GDP 9

FIGURE 4: U.S. Appropriated Reconstruction Funding for Afghanistan Shown 

as a Percentage of Afghan GDP 51

TABLE 1: Categories of Corruption 3

TABLE 2: Afghanistan’s Corruption Rankings 5

FIGURES

TABLES
i SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

EXECUTIVE SUMMARY

This report draws important lessons from the U.S. experience with corruption 

in Afghanistan since 2001. These lessons are relevant for ongoing efforts in 

Afghanistan, where the United States will remain engaged in coming years 

and continue to face the challenge of corruption. The United States may also 

participate in future efforts to rebuild other weak states emerging from protracted 

conflict. It is vital that anticorruption lessons from Afghanistan inform and 

improve these efforts.

When U.S. military forces and civilians entered Afghanistan in 2001 in the 

aftermath of the 9/11 attacks, they were immediately faced with the difficult task 

of trying to stabilize a country devastated by decades of war and poverty. Against 

that background, the U.S. government did not place a high priority on the threat 

of corruption in the first years of the reconstruction effort. By 2009, however, 

many senior U.S. officials saw systemic corruption as a strategic threat to the 

mission. Ambassador Ryan Crocker, who re-established U.S. Embassy Kabul soon 

after 9/11 and again led the embassy from 2011 to 2012, concluded in an interview 

for this report that “the ultimate point of failure for our efforts ... wasn’t an 

insurgency. It was the weight of endemic corruption.”1

This report examines how the U.S. government—primarily the Departments of 

Defense (DOD), State, Treasury, and Justice, and the U.S. Agency for International 

Development (USAID)—understood the risks of corruption in Afghanistan, how 

the U.S. response to corruption evolved, and the effectiveness of that response. 

The report identifies five main findings from which we draw lessons and 

recommendations to improve current and future contingency operations: 

1. Corruption undermined the U.S. mission in Afghanistan by fueling 

grievances against the Afghan government and channeling material 

support to the insurgency.

2. The United States contributed to the growth of corruption by injecting 

tens of billions of dollars into the Afghan economy, using flawed oversight 

and contracting practices, and partnering with malign powerbrokers.

3. The U.S. government was slow to recognize the magnitude of the problem, 

the role of corrupt patronage networks, the ways in which corruption 

threatened core U.S. goals, and that certain U.S. policies and practices 

exacerbated the problem. 

4. Even when the United States acknowledged corruption as a strategic 

threat, security and political goals consistently trumped strong 

anticorruption actions.

5. Where the United States sought to combat corruption, its efforts 

saw only limited success in the absence of sustained Afghan and 

U.S. political commitment. 
SIGAR ii I CORRUPTION IN CONFLICT I SEPTEMBER 2016

In the early years of the reconstruction, DOD, State, and USAID did not fully 

appreciate the potential for corruption to threaten the security and statebuilding missions in Afghanistan. The United States was focused on pursuing 

al-Qaeda and the Taliban, shepherding a political transition process, and 

meeting reconstruction needs. The United States partnered with warlords and 

their militias to pursue its counterterrorism mission. When these strongmen 

and other elites gained positions of power in the Afghan government, they often 

engaged in rampantly corrupt activities. The U.S. government also failed to 

recognize that billions of dollars injected into a small, underdeveloped country, 

with limited oversight and strong pressures to spend, contributed to the growth 

of corruption. 

By 2005, U.S. agencies were alarmed by worsening corruption, yet their concerns 

did not translate into coherent, sustained action. Meanwhile, Afghan government 

efforts to fight corruption were half-hearted. The dilemma was that combating 

corruption required the cooperation and political will of Afghan elites whose 

power relied on the very structures anticorruption efforts sought to dismantle. 

In 2009, innovative efforts by the Afghan Threat Finance Cell (ATFC), a U.S. unit 

formed to track and stop terrorist financing, revealed an interdependent web of 

connections between corrupt Afghan officials, criminals, drug traffickers, and 

insurgents. U.S. civilian and military leaders became increasingly concerned that 

corruption was fueling the insurgency by financing insurgent groups and stoking 

grievances that increased popular support for these groups. There was also 

recognition that the U.S. government was contributing to corruption through its 

partnerships with malign powerbrokers and limited oversight of its contracts. In 

response, anticorruption became a key element of U.S. efforts in Afghanistan. The 

United States created or supported many entities—such as the Combined Joint 

Interagency Task Force Shafafiyat, Task Force 2010, and the Government of the 

Islamic Republic of Afghanistan’s (GIROA) Major Crimes Task Force—to better 

understand corrupt networks, prevent U.S. money from funding the enemy, and 

build Afghan institutional capacity to tackle corruption. 

This surge in awareness and activity came up against the reality of entrenched 

criminal patronage networks that involved high-level Afghan officials. Two major 

events in 2010—the arrest on corruption charges and subsequent release of 

an aide to President Hamid Karzai, and the near-collapse of Kabul Bank due to 

massive fraud by politically connected bank shareholders—demonstrated both 

the extent of corruption and the weakness of Afghan political will to stop it. 

From 2010 onward, U.S. agencies saw corruption as a serious threat to the 

mission in Afghanistan. The United States continued to support Afghan 

institutional reform and capacity-building, pressed for judicial actions and better 

financial oversight, pursued limited forms of aid conditionality, and strengthened 

civil society organizations and the media. U.S. agencies also improved contractor 

vetting and prevented at least some U.S. funds from reaching insurgent groups 

via corruption. While these efforts had some success, they were not unified by an 

overarching strategy and were largely tactical. 
iii SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

At the same time, the U.S. government was pursuing other high-level goals, 

including the transition of security responsibility from the coalition to Afghan 

forces, a strategic partnership agreement (SPA) and a bilateral security agreement 

(BSA) with the Afghan government, and political reconciliation with the Taliban. 

U.S. officials had to make difficult judgment calls on how much political capital to 

invest in pressing the Afghan government on corruption while trying to maintain 

access to the Karzai administration to move other important priorities forward. 

Often, policymakers perceived tradeoffs between fighting corruption and making 

progress on these other goals.

Although the lack of Afghan cooperation on anticorruption stymied many 

U.S. efforts, the United States could have more aggressively brought pressure 

to bear upon GIROA and politically connected individuals. Faced with systemic 

corruption, the U.S. government generally failed to use more aggressive tools such 

as the revocation of visas, strict conditionality on aid, and prosecutions of corrupt 

Afghan officials with dual U.S. citizenship.

It is impossible to know whether such steps might have generated more Afghan 

political commitment to address corruption or whether they would have reduced 

Afghan cooperation on other U.S. objectives. What we do know is, the Taliban 

continue to pose a security threat, corruption remains a source of profound 

frustration among the population, and the National Unity Government has 

struggled to make headway against corruption.

Lessons

The U.S. government can learn vital lessons from its experience with corruption in 

Afghanistan. This report identifies six lessons to inform U.S. policies and actions 

at the onset of and throughout a contingency operation.

1. The U.S. government should make anticorruption efforts a top priority in 

contingency operations to prevent systemic corruption from undermining 

U.S. strategic goals. 

2. U.S. agencies should develop a shared understanding of the nature and 

scope of corruption in a host country through political economy and 

network analyses.

3. The U.S. government should take into account the amount of assistance 

a host country can absorb, and agencies should improve their ability to 

effectively monitor this assistance. 

4. The U.S. government should limit alliances with malign powerbrokers and 

aim to balance any short-term gains from such relationships against the 

risk that empowering these actors will lead to systemic corruption.

5. U.S. strategies and plans should incorporate anticorruption objectives into 

security and stability goals, rather than viewing anticorruption as imposing 

tradeoffs on those goals. 

6. The U.S. government should recognize that solutions to endemic 

corruption are fundamentally political. Therefore, the United States should 

bring to bear high-level, consistent political will when pressing the host 

government for reforms and ensuring U.S. policies and practices do not 

exacerbate corruption. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 iv

Recommendations

To address corruption risks to U.S. strategic objectives in current and future 

contingency operations, SIGAR recommends the following legislative and 

executive branch actions. 

Legislative Recommendations

1. Congress should consider enacting legislation that makes clear that 

anticorruption is a national security priority in a contingency operation 

and requires an interagency anticorruption strategy, benchmarks, and 

annual reporting on implementation. 

2. Congress should consider enacting legislation that authorizes sanctions 

against foreign government officials or their associates who engage 

in corruption. 

3. Congress should consider requiring DOD, State, USAID, and other relevant 

executive agencies to establish a joint vendor vetting unit or other 

collaborative effort at the onset of any contingency operation to better vet 

contractors and subcontractors in the field. 

Executive Branch Recommendations

4. The NSC should establish an interagency task force to formulate policy 

and lead strategy on anticorruption in contingency operations. 

5. At the onset of any contingency operation, the Intelligence Community 

should analyze links between host government officials, corruption, 

criminality, trafficking, and terrorism. This baseline assessment should be 

updated regularly. 

6. DOD, State, USAID, and the Intelligence Community should each 

designate a senior anticorruption official to assist with strategic, 

operational, and tactical planning at headquarters at the onset of and 

throughout a contingency operation.

7. DOD, State, and USAID should each establish an Office for Anticorruption 

to provide support, including advice on anticorruption methods, 

programming, and best practices, for personnel in contingency operations. 

8. The President should consider amending Executive Order 13581, which 

authorizes the listing of transnational criminal organizations on Treasury’s 

Office of Foreign Assets Control (OFAC) Specially Designated Nationals 

list, to include individuals and entities who have engaged in corruption and 

transferred the proceeds abroad. 

9. In international engagements related to contingency operations, the U.S. 

government should bring high-level political commitment to bear against 

corruption to ensure anticorruption is a priority from the outset for the 

host government and international and regional partners. 

10. The State Department should place a high priority on reporting on 

corruption and how it threatens core U.S. interests, consistent with new 

anticorruption initiatives by the department and recommendations in the 

2015 Quadrennial Diplomacy and Development Review (QDDR). 

11. DOD, State, USAID, Treasury, Justice, and the Intelligence Community 

should increase anticorruption expertise to enable more effective 

strategies, practices, and programs in contingency operations. 

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 1

INTRODUCTION

This report draws important lessons from the U.S. experience with corruption 

in Afghanistan since 2001. These lessons are relevant for ongoing efforts in 

Afghanistan, where the United States will remain engaged in coming years 

and continue to face the challenge of corruption. The United States may also 

participate in future efforts to rebuild other weak states emerging from protracted 

conflict. It is vital that anticorruption lessons from Afghanistan inform and 

improve these efforts.

When U.S. military forces and civilians entered Afghanistan in 2001 in the 

aftermath of the 9/11 attacks, they were immediately faced with the difficult task 

of trying to stabilize a country devastated by decades of war and poverty. Against 

that background, the U.S. government did not place a high priority on the threat of 

corruption in the first years of the reconstruction effort. By 2009, however, many 

senior U.S. officials saw systemic corruption as a strategic threat to the mission.

This report examines how the U.S. government—primarily the Departments of 

Defense (DOD), State, Treasury, and Justice, and the U.S. Agency for International 

Development (USAID)—understood the risks of corruption in Afghanistan, how 

the U.S. response evolved, and the effectiveness of that response. The report 

identifies five main findings:

U.S. Marine Corps photo
SIGAR I CORRUPTION IN CONFLICT I 2 SEPTEMBER 2016

1. Corruption undermined the U.S. mission in Afghanistan by fueling 

grievances against the Afghan government and channeling material 

support to the insurgency.

2. The United States contributed to the growth of corruption by injecting 

tens of billions of dollars into the Afghan economy, using flawed oversight 

and contracting practices, and partnering with malign powerbrokers.

3. The U.S. government was slow to recognize the magnitude of the problem, 

the role of corrupt patronage networks, the ways in which corruption 

threatened core U.S. goals, and that certain U.S. policies and practices 

exacerbated the problem. 

4. Even when the United States acknowledged corruption as a strategic 

threat, security and political goals consistently trumped strong 

anticorruption actions.

5. Where the United States sought to combat corruption, its efforts 

saw only limited success in the absence of sustained Afghan and 

U.S. political commitment. 

The report is laid out in seven sections. This section introduces concepts and 

issues that are important for understanding the story that follows, including 

a definition of corruption, recent trends in corruption and perceptions of 

it among Afghans, why corruption matters in conflict environments, and a 

framework for anticorruption efforts. The subsequent narrative sections are 

divided into three time periods: 2001 to 2008, 2009 to 2010, and 2010 to 2014. 

These sections chronologically trace how U.S. agencies viewed the corruption 

problem in Afghanistan, how they sought to address it, and obstacles encountered 

in doing so. The above five findings emerged from this historical narrative.

After a brief conclusion, the next section draws six important lessons to 

inform current and future U.S. reconstruction efforts and the final section 

provides recommendations for policymakers and practitioners—in Congress 

and the executive branch—to address corruption from the beginning of a 

contingency operation. 

What Is Corruption?

To appreciate the threat of corruption, U.S. officials must have an accurate 

understanding of what corruption is and how it manifests itself in a given 

environment. This report uses a widely accepted definition of corruption, 

“the abuse of entrusted authority for private gain.”2

 Where corruption permeates 

a state system, it is not merely a matter of individual malfeasance, but rather 

a larger, systemic problem. As the 2005 USAID Anticorruption Strategy

highlighted, corruption in the public sector cannot realistically be addressed 

in isolation from corruption within political parties, businesses, associations, 

nongovernmental organizations (NGO), and society at large. The strategy also 

recognized “gray” areas of corrupt behavior, noting that “not all illegal activities 

are corruption, and not all forms of corruption are illegal.”3

The above definition reflects the fact that people can engage in corrupt acts not 

only for personal gain, but also to benefit their families or a broader community.4

This is particularly relevant to Afghanistan’s kinship-based society, where the 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 3

gains from corruption often benefit not just an individual, but a family, clan, tribe, 

or ethnic group. 

Table 1 defines the most common categories of corruption. 

Experts often make the distinction between petty and grand corruption, though 

corruption can occur along a continuum between the two.5

 Petty corruption 

refers to smaller-scale, everyday abuse of power by low- and mid-level officials, 

for example, the requirement to pay a bribe for access to goods or services. 

Grand corruption involves “exchanges of resources, access to [economic] rents, 

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

of elite operatives and supporters.”6

 Acts of grand corruption typically involve 

TABLE 1: CATEGORIES OF CORRUPTION

Category of 

corruption Description

Bribery The offering, promising, giving, accepting, or soliciting of an advantage as 

an inducement for an action which is illegal, unethical, or a breach of trust. 

Inducements can take the form of gifts, loans, fees, rewards, or other advantages 

(e.g., taxes, services, donations, favors).

Clientelism An unequal system of exchanging resources and favors based on an exploitative 

relationship between a wealthier or more powerful “patron” and a less wealthy or 

weaker “client.”

Collusion A secret agreement between parties, in the public or private sector, to conspire 

to commit actions aimed to deceive or commit fraud with the objective of illicit 

financial gain.

Embezzlement When a person holding office in an institution, organization, or company 

dishonestly and illegally appropriates, uses, or traffics the funds and goods they 

have been entrusted with for personal enrichment or other activities.

Extortion Act of using, either directly or indirectly, one’s access to a position of power or 

knowledge to demand unmerited cooperation or compensation as a result of 

coercive threats.

Facilitation 

Payment

A small bribe, also called a facilitating, speed, or grease payment, made to 

secure or expedite the performance of a routine or necessary action to which the 

payer has legal or other entitlement.

Fraud The offense of intentionally deceiving someone in order to gain an unfair or illegal 

advantage (financial, political, or other).

Grand 

Corruption

The abuse of high-level power that benefits the few at the expense of the many, 

and causes serious and widespread harm to individuals and society.

Nepotism A form of favoritism based on acquaintances and familiar relationships, whereby 

someone in an official position exploits his power and authority to provide a 

job or favor to a family member or friend, even though he may not be qualified 

or deserving.

Patronage A form of favoritism in which a person is selected, regardless of qualifications or 

entitlement, for a job or government benefit due to affiliations or connections.

Petty 

Corruption

Everyday abuse of entrusted power by public officials in their interactions with 

ordinary citizens, who often are trying to access basic goods or services in places 

like hospitals, schools, police departments, and other agencies.

State Capture A situation where powerful individuals, institutions, companies, or groups 

within or outside a country use corruption to influence a nation’s policies, legal 

environment, and economy to benefit their own private interests. 

Source: Transparency International, Anticorruption Glossary, http://www.transparency.org/glossary. 
SIGAR I CORRUPTION IN CONFLICT I 4 SEPTEMBER 2016

large sums of money. For example, a senior official may receive a kickback in 

exchange for directing a lucrative government contract to a favored company. 

Grand corruption can also include the manipulation of policies, institutions, and 

procedures, enabling high-level officials to benefit at the expense of the public 

good; this is sometimes referred to as “political corruption.”7

Systemic Corruption, a Dilemma for Anticorruption Efforts

Many Afghan and international observers have asserted that corruption in 

Afghanistan, by at least 2009, had become systemic, or pervasive and entrenched.8

 In 

2010, U.S. Embassy Kabul reported that in a meeting with senior U.S. officials, Afghan 

National Security Advisor Dr. Rangin Dadfar Spanta said “corruption is not just a 

problem for the system of governance in Afghanistan; it is the system of governance.”9

In such an environment, government leaders and private citizens who are connected 

at high political levels can seek to maintain their control over resources and levers 

of power through their abuse of entrusted authority. This poses a dilemma for any 

attempt to prevent or combat corruption: Tackling systemic corruption demands 

cooperation from political leaders whose dominance may rely on the very power 

structures anticorruption efforts seek to dismantle. These leaders thus have every 

reason to block reform; their interest lies in maintaining the corrupt system that 

benefits them, as well as larger identity groups with which they associate. 

In situations where corruption is systemic, as in Afghanistan, it is important to 

acknowledge the false dichotomy of petty versus grand corruption. That 

framework, while useful for understanding different levels of corruption, can 

obscure the fact that corruption is vertically integrated. Petty corruption is 

directly linked to grand corruption, as powerbrokers at the top use state 

institutions (for example, the police, courts, customs, and procurement systems) 

to extract resources from the bottom.10

A key mechanism of this integrated structure is the purchase of public positions. 

Numerous reports and interviews note that often, “government employment 

is purchased rather than earned.”11 For example, a 2007 study by the Afghan 

NGO Integrity Watch Afghanistan (IWA) described a “bazaar economy” in which 

“every position, favor, and service can be bought and sold.”12 The study cited 

“the strong and interwoven spider web of illicit networks, which are closely 

collaborating from district to provincial and central level,” and these networks’ 

abilities to effectively block reform.13 According to a former mid-level Afghan 

government official, ministers and deputy ministers sought to control access not 

to all positions, but to the most lucrative subordinate positions, such as certain 

posts in major cities, border security posts, and senior positions in provinces and 

districts that grow poppies or have mines.14 This upward flow of money and power 

victimizes ordinary people, while enriching a few.

Tackling systemic corruption demands cooperation 

from political leaders whose dominance may rely on 

the very power structures anticorruption efforts seek 

to dismantle. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 5

Measuring Corruption

Because corruption is often hidden behavior, it is difficult to measure in any 

country. In Afghanistan, this problem is magnified by the dearth of economic and 

other information, 30 years of conflict, and logistical, social, and cultural 

challenges to collecting reliable data or conducting methodologically sound 

surveys.15 This report therefore relies on a combination of survey data, 

international indices, and interviews to attempt to understand the scope of 

corruption in Afghanistan.

Available survey data provide imperfect but 

helpful indicators about Afghan perceptions of 

and experiences with corruption. Appendix C 

presents data from IWA, the Asia Foundation 

(TAF), and International Security Assistance 

Force (ISAF) surveys on experiences and 

perceptions of corruption. The data suggest 

that, since 2001, Afghans have consistently 

and increasingly perceived corruption as one 

of their biggest problems, rivaled only by 

insecurity and unemployment. 

Various governance and business indices 

for Afghanistan also point to high levels of 

corruption. The World Bank’s Worldwide 

Governance Indicators shows Afghanistan in 

the bottom 4 percent of nations for “control 

of corruption” from 2002 through 2013.16 The 

World Bank’s 2005 Investment Climate in 

Afghanistan, which identified key constraints 

to growth, reported “nearly 58 percent of 

surveyed firms cited corruption as a major 

or severe problem, just behind access to 

land and electricity. Firms reported paying 

an average 8 percent of sales as bribes, 

more than four times the average reported 

in neighboring Pakistan.”17 In addition, since 

2011, Afghanistan has consistently ranked 

as one of the three most corrupt countries 

in the world in Transparency International’s 

annual Corruption Perceptions Index. Table 2 

illustrates these findings. 

Petty corruption is directly linked to grand corruption, 

as powerbrokers at the top use state institutions (for 

example, the police, courts, customs, and procurement 

systems) to extract resources from the bottom.

TABLE 2: AFGHANISTAN’S 

CORRUPTION RANKINGS

World Bank

Transparency 

International

2001 - -

2002 196 of 197 -

2003 195 of 199 -

2004 198 of 206 -

2005 203 of 206 117 of 159

2006 199 of 206 -

2007 205 of 207 172 of 180

2008 205 of 207 176 of 180

2009 208 of 210 179 of 180

2010 209 of 211 176 of 178

2011 209 of 212 180 of 183

2012 206 of 210 174 of 176

2013 206 of 210 175 of 177

2014 196 of 209 172 of 175

2015 - 166 of 168

Source: SIGAR analysis of World Bank 

data; The World Bank, “Worldwide 

Governance Indicators: Control 

of Corruption,” The World Bank 

Databank, 2002–2014; Transparency 

International, “Corruption Perceptions 

Index,” 2005, 2007–2015.

Note: The data reflect Afghanistan’s 

international ranking among select 

countries. The number of countries 

included in these rankings changes 

from year to year based on the 

availability of reliable data.
SIGAR I CORRUPTION IN CONFLICT I 6 SEPTEMBER 2016

Corruption Has Increased from Pre-2001 Levels 

Corruption is not a new phenomenon in Afghanistan.18 As a 2005 cable from 

U.S. Embassy Kabul explained, “Garden-variety corruption—the use of public 

office for private gain and the greasing of palms to secure delivery of government 

services—has been a hallmark of daily life here for many centuries. The highly 

informal and relationship-based nature of Afghan society, including a strong element 

of nepotism, has reinforced this.”19 Similarly, a 2007 joint paper on corruption in 

Afghanistan, prepared by several major donor organizations, stated that before 

2001, “in practice, nepotism, patronage, and clientelism were widespread.”20

Within this context, however, numerous international and Afghan reports—

consistent with the survey data and indices described above—indicate that the 

scale of corruption in the post-2001 period has increased above previous levels.21

The 2005 embassy cable asserted, “There is a general consensus that Afghan 

corruption has swelled to unprecedented levels since Zahir Shah’s overthrow 

in 1973—and especially after the Taliban regime’s rollback in 2001.”22 A 2009 

assessment commissioned by the Organization for Economic Cooperation and 

Development (OECD) warned that “corruption has soared to levels not seen in 

previous administrations.”23

There was also evidence of a shift in how Afghan society viewed corruption, from 

stigmatizing bribes to tacitly condoning them. Afghan business leaders told 

U.S. embassy officials in 2011 that bribery and corruption were “pervasive, 

accepted, and arguably even encouraged” at that time, whereas in previous years, 

greater shame had been attached to these behaviors.24 Figures 1 and 2 illustrate 

the rise in perceptions of corruption in Afghanistan, according to TAF surveys.

Key drivers of corruption after 2001 have been continuing insecurity, weak 

systems of accountability, the drug trade, a large influx of money, and poor 

oversight of contracting and procurement related to the international presence.

Note: The survey question was, “Please tell me whether you think that corruption is a major 

problem, a minor problem, or no problem at all ... in your daily life.” The graph represents the 

respondents who reported that corruption was a major problem.

Source: The Asia Foundation, A Survey of the Afghan People, Explore Data Tool, 2006–2015.

FIGURE 1: Share of respondents who said corruption was a major problem 

in daily life

0%

25%

50%

75%

100%

0%

25%

50%

75%

100%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

61.1%

42.1%
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 7

Drivers within the State and Society

The Afghan people have suffered for decades in an environment of uncertainty, 

insecurity, grinding poverty, weak governance, and war. All of these factors 

can undermine the rule of law and enable corruption to flourish. A 2015 UK 

Department for International Development (DFID) study reviewed the empirical 

literature on factors contributing to corruption and concluded that corruption 

tended to be particularly strong in “neo-patrimonial systems” where:

• There is weak separation of the public and private spheres, which results 

in the widespread private appropriation of public resources.

• Vertical (e.g., patron-client) and identity-based (e.g., kinship, ethnicity, 

religion) relationships have primacy over horizontal (e.g., citizen-to-citizen 

or equal-to-equal) and rights-based relationships.

• Politics are organized around personalism or “big man” syndrome, 

reflected in the high centralization of power and patron-client relations 

replicated throughout society.25 

Post-2001 Afghanistan embodies many of the factors identified by the DFID 

study: Lines are often blurred between public and private interests, as 

government officials engage in drug trafficking and cultivate their own patronage 

networks; social and political structures have historically been characterized 

by relationships based on language, tribe, region, and ethnicity; and the Bonn 

Conference in 2001 established a highly centralized state system in a country 

with historically weak capacity at the center.26

The Afghan government’s 2008 National Anti-Corruption Strategy identified 

specific factors driving or enabling corruption, including weak institutional 

Note: The survey question was, “Whenever you have contacted government officials, how often 

in the past year have you had to give cash, a gift, or perform a favor for an official?” The graph 

represents the sum of respondents who reported experiencing corruption in all cases, most cases, 

or isolated cases. People who had not contacted government officials were excluded from this data.

Source: The Asia Foundation, A Survey of the Afghan People, Explore Data Tool, 2006–2015.

0%

25%

50%

75%

100%

0%

25%

50%

75%

100%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

39.8%

55.4% 61.6%

63.7%

FIGURE 2: Share of respondents who had contacted government ofcials 

and reported experiencing corruption

Respondents who reported experiencing corruption in the judiciary

Respondents who reported experiencing corruption in the customs ofce
SIGAR I CORRUPTION IN CONFLICT I 8 SEPTEMBER 2016

capacity, legislative and regulatory frameworks, and enforcement; non-meritbased hiring; low salaries of public servants; and a dysfunctional judicial system.27

Other factors included tribal rivalries and power struggles, the cash-based 

economy, expanding drug trade, and burdensome administrative procedures that 

presented many opportunities to extract bribes.

Many of these causes of corruption can also be seen as symptoms of corruption, 

acting and reacting in a harmful feedback loop. Weak governance allows 

opportunities for corruption to occur.28 As corrupt networks grow more 

entrenched, its members resist the development of accountability systems that 

would strengthen governing institutions and threaten the corrupt practices upon 

which the network’s survival depends. In addition, as corruption diverts resources 

away from the state, it undermines the ability of government to deliver goods and 

services to the public. 

Ongoing uncertainty about security and limited economic opportunities created 

strong incentives for Afghans—particularly those within criminal patronage 

networks—to focus on the near-term. A “short-term maximization-of-gains 

mentality” developed, anticipating the eventual cessation of money flows from 

the international military and reconstruction effort.29 This dynamic is described in 

academic literature as a collective-action problem: Participants try to maximize 

their self-interest when there is a shared expectation of corruption. In this frame, 

“individuals will opt to behave in corrupt ways because the costs of acting in a more 

principled manner far outweigh the benefits, at least at the individual level.”30

Drivers Emanating from the International Intervention

To understand why corruption became so pervasive and entrenched after 

2001, it is important to also look at the international community’s security 

and reconstruction efforts, which entailed an enormous influx of money, 

weak oversight of contracting and procurement practices, and short timelines. 

After 2001, opportunities for corruption expanded as the amount of money in the 

economy grew from millions to billions of dollars. Many of those funds were licit, 

arriving via civilian and military contracts. At their peak in fiscal year (FY) 2012, 

DOD contract obligations for services in Afghanistan, including transportation, 

construction, base support, translation/interpretation, and private security, totaled 

approximately $19 billion, just under Afghanistan’s 2012 gross domestic product 

(GDP) of $20.5 billion.31 From FY 2007 to 2014, these contract obligations totaled 

more than $89 billion.32 The full amount of these contracts was not spent in 

Afghanistan; for example, some portion of a contract with a U.S. firm would be 

injected into the U.S., not Afghan, economy. Nevertheless, these amounts indicate 

that huge sums, relative to the Afghan economy, flowed into the country.33

The inflows of foreign aid were also large compared to the size of the Afghan 

economy. As defined and tracked by the OECD, official development assistance 

(ODA) disbursed to Afghanistan rose from $2.1 billion in 2003 to a peak 

of $6.8 billion in 2011; Afghanistan’s GDP was $4.6 billion in 2003, and $17.9 billion 

in 2011.34 According to a 2009 OECD report, international assistance accounted for 

roughly half of Afghanistan’s lawful economy.35
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 9

Figure 3 shows that U.S. appropriated reconstruction assistance often approached 

or exceeded Afghanistan’s GDP. 

In addition, illicit money flows increased after 2001 through the growth of the 

drug trade. State’s Bureau of International Narcotics and Law Enforcement (INL) 

estimated Afghanistan’s poppy cultivation increased nearly seven-fold between 

2002 and 2014.36 In 2005, the International Monetary Fund (IMF) attributed an 

estimated 40 to 60 percent of Afghanistan’s GDP to narcotics.37

The influx of money from aid and military contracts was not always accompanied 

by strong oversight. Controls were sometimes insufficient to prevent 

embezzlement, bribery, fraud, and other forms of corruption—by both Afghan 

and international actors—that drained resources from the reconstruction effort.38

As a former senior U.S. official described the problem: 

In a conflict environment, oversight is difficult, but our 

systems of accountability are also poor. So when you push 

large amounts of money through and there’s no way to pull it 

back, it creates an incentive for corruption. The environment 

in which you are operating shifts and corrupt actors create 

ways to bleed the system for all it is worth, because they know 

the money will keep flowing no matter what they do, and they 

can make more by being corrupt than non-corrupt .... This is a 

Note: Funds for most reconstruction accounts are normally disbursed one to five years after they 

are appropriated. U.S. appropriated reconstruction funding includes categories usually excluded in 

OECD’s ODA reporting, such as military aid funded through the Afghanistan Security Forces Fund.

Source: SIGAR, Quarterly Report to the United States Congress, January 30, 2016, p. 187; SIGAR, 

Quarterly Report to the United States Congress, October 30, 2014, pp. 202-203; World Bank, World 

Development Indicators: GDP at market prices (current U.S. dollars), World Bank Databank, accessed 

July 12, 2016.

Gross Domestic Product of Afghanistan ($Billions)

U.S. Appropriated Reconstruction Funding for Afghanistan ($Billions)

FIGURE 3: U.S. Appropriated Reconstruction Funding Compared to 

Afghanistan’s GDP

0

$5

$10

$15

$20

$25

0

$5

$10

$15

$20

$25

$4.13

$1.07

$19.20

$5.95

20152014201320122011201020092008200720062005200420032002
SIGAR I CORRUPTION IN CONFLICT I 10 SEPTEMBER 2016

dynamic we have to change if we want to use our money well 

and effectively achieve our goals. U.S. officials on the ground 

have to be appropriately authorized and encouraged to pull 

money back if it is not being used well, and these decisions 

need to be politically supported in Washington.39

Another former U.S. official recalled that the United States and donors “began 

working almost immediately with NGOs and other third parties and created a 

plethora of parallel institutions. This drove confusion and undermined the state. 

It also created vast opportunities for rent-seeking behavior on the part of NGOs 

and contractors.”40 Rent-seeking is a term of art used by economists and others to 

mean the accrual of personal benefits through actions in the political arena.41

U.S. and other international agencies were also under pressure to spend money 

quickly for three main reasons: Spending money was seen as its own metric of 

progress, large expenditures justified further appropriations from legislatures at 

home, and insecurity drove the need to do things quickly.42 The 2011 final report 

of the congressionally mandated Commission on Wartime Contracting in Iraq 

and Afghanistan noted the risks of spending quickly. For example, the report 

cited a USAID agricultural program in southeastern Afghanistan that expanded 

within a few weeks from $60 million to $360 million, resulting in rampant waste 

and fraud.43

Why Should U.S. Policymakers Care About Corruption 

in a Conflict Environment? 

Ambassador Ryan Crocker, who re-established U.S. Embassy Kabul soon after 

9/11 and again led the embassy from 2011 to 2012, concluded in an interview 

for this report that “the ultimate point of failure for our efforts ... wasn’t an 

insurgency. It was the weight of endemic corruption.”44

Policymakers should care about corruption because it can have devastating 

consequences for a state and society, threaten security and the rule of law, 

and undermine public trust in institutions. In Afghanistan, the erosion of state 

legitimacy weakened the government’s ability to enlist popular support against the 

insurgency.45 ISAF survey data suggest corruption was a catalyst for Afghans to 

support the Taliban; between 2010 and 2012, survey respondents ranked corruption 

as one of the “top three reasons why some Afghans choose to support the Taliban 

instead of the Government of Afghanistan.”46 Corruption also undercut the viability 

of the state itself, as government officials not only exploited their positions to 

extract resources from the population and foreign presence, but worse, repurposed 

state institutions to engage in organized crime, thus driving insecurity.47

Security sector corruption had particularly dire consequences. Corruption within 

Afghan security ministries and the Afghan National Security Forces (ANSF) 

undermined combat readiness and effectiveness, as well as cohesion of the army 

and police.48 This “hollowing out” of security institutions had direct implications 

for U.S. and NATO policy in Afghanistan: The schedule to transition security 

responsibility from international to Afghan forces depended on the condition of 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 11

Afghan forces. Corruption undercut the readiness and effectiveness of both the 

Afghan National Army (ANA) and Afghan National Police (ANP).49

The U4 Anticorruption Resource Center at the Christian Michelsen Institute in 

Norway found that corruption within the security sector can lead to increased levels 

of crime and armed violence; the population feeling insecure, vulnerable, and 

distrustful of security services; the purchase of unnecessary equipment, which 

wastes resources that might have been used for legitimate purposes; and reduced 

operational effectiveness through poor equipment or inadequately trained staff.50

Some reports suggest corruption has been a motivating factor for Afghans joining 

the insurgency.51 The Taliban’s annual Eid al-Fitr statements highlight government 

corruption, while other propaganda has attempted to capitalize on corruption and 

injustice as sources of alienation.52

Economically, corruption chokes growth by draining revenue from the national 

treasury, discouraging direct foreign investment, and distorting the terms of 

trade.53 The USAID 2005 Anticorruption Strategy noted that “crony lending and 

weak supervision misallocate credit and may lead to banking sector collapse,” a 

phenomenon that occurred in Afghanistan in 2010 with the near-collapse of Kabul 

Bank. 54 In addition, corruption creates uncertainty for firms regarding costs and 

the consistent implementation of the rule of law. Together, these effects erode 

the government’s fiscal stability and chances for sustained economic growth. 

The World Bank’s 2005 Investment Climate in Afghanistan stated corruption 

was “threatening to foreign investors or Afghans returning from overseas who 

do not have powerful patrons or understand the system.”55 Corruption also adds 

a financial burden on ordinary Afghans. It discourages the formalization and 

expansion of small-scale economic ventures because of fears of becoming visible 

targets for corrupt officials.

Abusive strongmen were sometimes legitimized and empowered through their 

appointments to positions of authority and responsibility by President Hamid 

Karzai. In such positions, they sought to consolidate their power base by rewarding 

their followers with government positions and gaining access to lucrative contracts 

connected to the military and aid agencies.56 These men repressed rival groups and 

ordinary citizens through illegal land grabs, economic marginalization, and human 

rights violations.57 In the instances where the Afghan state was seen as being in 

collusion with or controlled by these strongmen, the government was no longer 

viewed as an honest broker, but complicit in and the source of injustices.

By extension, because the international donor community, including the United 

States, supported the government, Afghans saw international actors as complicit 

“The ultimate point of failure for our efforts ... 

wasn’t an insurgency. It was the weight of 

endemic corruption.”

—Ambassador Ryan Crocker
SIGAR I CORRUPTION IN CONFLICT I 12 SEPTEMBER 2016

in corruption.58 Afghans also witnessed the U.S. failure to adequately monitor 

contractors associated with the reconstruction effort. Corruption and waste 

drained away benefits that were intended to accrue to the Afghan population. 

Afghans knew this, and it undermined their faith in the international effort.59

Possible Reasons the U.S. Government Failed to See the Problem

This report traces the U.S. government’s delay in grasping the extent of the 

corruption problem and its threat to the security and stability missions. The 

report does not explore in detail the reasons why bureaucracies get things wrong 

or fail to understand the consequences of their actions. Nevertheless, several 

factors help to explain why U.S. agencies took years to fully diagnose the threat 

of corruption:

• Lack of access to accurate information: Information deficits pose 

a perennial problem for policymakers and practitioners in conflict 

environments and are central to the principal-agent conundrum.60

As one public administration scholar explained, “The principal seeks 

information from agents working on its behalf. The agents have 

incentives to hide information from the principal. In the Afghan context, 

the [U.S. government] is the principal and the agents are the myriad 

contractors [and] NGOs implementing projects on its behalf.”61 In a 

conflict zone where U.S. officials do not have the ability to access or 

physically monitor the majority of projects, contractors and NGOs can 

easily withhold information about, for example, the quality of construction 

and materials used, subcontractors employed, or protection payments 

made to armed groups.62

• Organizational culture and institutional incentives to color field 

reports: Especially where the U.S. government has invested significant 

political capital in the outcome of an intervention (for example, by 

deploying thousands of U.S. service members and civilians), U.S. officials 

face powerful incentives to positively color their assessments of the 

situation on the ground. Pressures to report success up the chain of 

command in a civilian or military bureaucracy often outweigh the demand 

for truth-telling or accounts of failures. Further, once significant financial 

or other investments have been made, U.S. agencies cannot recover sunk 

costs and may be reluctant to abandon a program or effort, even if it 

proves less successful than anticipated.63

• Unrealistic expectations: To many policymakers and practitioners, 

Afghanistan represented an unstable and insecure environment with 

complex cultural, historical, political, and social dynamics. These 

factors made it difficult to craft appropriate timelines and expectations 

for assistance programs. Adding to the complexity, U.S. officials were 

hamstrung by short tours, frequent staff turnover, and lack of mobility to 

actually engage with implementing partners. These challenges exacerbated 

problems that can affect any development effort, such as programs poorly 

suited to the environment, ill-considered attempts to transplant programs 

that are successful in other contexts, and “fast track” institution building, 

despite limited evidence of success.64 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 13

Together, these and other factors facilitated misperceptions about corruption 

in Afghanistan. The incentive structure did not encourage U.S. officials to 

report on waste, fraud, and abuse, or on weaknesses in oversight; there were 

“few incentives for spending less money more effectively over time.” Nor were 

contractors or NGOs, who benefitted from the largesse of the security and statebuilding effort, incentivized to report such weaknesses.65

A Framework for Anticorruption Efforts

Anticorruption activities aim to prevent or control corruption. In Afghanistan, 

these efforts fell into two categories. 

The first category consists of activities directed at the Afghan government and 

society to promote reform, accountability, and transparency. These include 

institutional reform and capacity building, improving judicial capabilities for 

investigations and prosecutions, improving financial oversight, and strengthening 

civil society organizations and the media. To work toward these objectives, 

State Department and other officials applied diplomatic pressure on the Afghan 

government and took some measures to condition the provision of aid on host 

government performance. DOD, State, USAID, Treasury, and Justice also pursued 

programmatic initiatives to move the anticorruption agenda forward. 

The second category of anticorruption activities consists of those directed 

internally, that is, toward U.S. policies and practices. The focus here is on 

improving management of contracting systems and aid programs to ensure they 

do not contribute to corruption. In Afghanistan, DOD, State, and USAID took 

steps to try to ensure contractors and subcontractors, who were bidding on and 

implementing assistance programs and military contracts, were not engaged in 

bribe-taking, embezzlement, collusion, extortion, or other forms of corruption. 

To be successful, work in either category must be grounded in an understanding 

of the nature and scope of corruption in a particular environment. Political 

economy and network analyses are crucial to revealing how corruption occurs. 

These analyses should look comprehensively at who is engaging in corruption; 

their family, business, and political ties and interests; the licit and illicit financial 

networks they use; the larger power structures that protect them; and institutional 

weaknesses and vulnerabilities. In Afghanistan, such analyses revealed a strong 

nexus of corruption, narcotics trafficking, criminality, and the insurgency. This 

complexity made the issue difficult to solve and required the close coordination 

of the military, diplomatic, development, and law enforcement communities. 

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 15

PART ONE

Failure to Fully Appreciate the Corruption Threat: 

2001–2008

In the early years of the post-2001 U.S. reconstruction effort, some U.S. officials 

recognized corruption could undermine the Afghan state’s legitimacy and drain 

resources from it. However, there was not sufficient appreciation for the threat 

corruption posed to the long-term U.S. goal of a peaceful, stable Afghanistan. With 

other pressing needs—to pursue al-Qaeda and the Taliban, prevent a humanitarian 

disaster, shepherd a political transition process, and begin basic reconstruction—

anticorruption was not a top priority for U.S. policymakers and practitioners. 

By mid-decade, that began to change. Aid programs and military contracts were 

increasing, the drug economy was expanding, and security had deteriorated. 

In 2005, U.S. Embassy Kabul reported that corruption was “a major threat” to 

Afghanistan’s future, and fighting corruption was “fundamental to the success 

of U.S. policy in Afghanistan.”66 In 2006, a high-level DOD briefing assessed 

corruption was feeding a “crisis in governance” and proposed a strategy for 

strengthening Afghan governance.67 Despite these calls, however, there was no 

cohesive, consistent response to corruption; U.S. anticorruption efforts lacked 

sustained political commitment, strategies, expertise, and resources. 

ISAF Public Affairs photo
SIGAR I CORRUPTION IN CONFLICT I 16 SEPTEMBER 2016

A central conundrum was that fighting corruption required the cooperation of 

Afghan elites whose power relied on the very structures that anticorruption 

efforts sought to dismantle. These elites included warlords, returned members of 

the Afghan diaspora, and other powerbrokers whom the United States supported 

to achieve security and stability goals. The United States thus strengthened 

corrupt elements of the system at the same time it sought to control them. 

U.S. officials also failed to recognize the extent to which massive inflows of money 

related to military and aid contracts, paired with weak oversight and contracting 

practices, were drivers of corruption. 

A Focus on Counterterrorism, Political Transition, 

and Reconstruction

Operation Enduring Freedom and the U.S. Engagement with Warlords 

The United States’ immediate post-9/11 imperative was to defeat al-Qaeda and 

deny it the chance to regroup.68 The initial stages of the military campaign in 

Afghanistan, Operation Enduring Freedom (OEF), were designed for a light 

U.S. footprint; officials worried that a large-scale military operation would 

provoke popular resistance and could turn into a quagmire.69 U.S. leaders also 

believed that counterterrorism goals could be pursued by using limited numbers 

of ground troops, combined with airpower and partnering with Afghan forces.70

Further, the Pentagon did not have logistics in place for an immediate, large-scale 

deployment of U.S. troops.71

In 2001, a U.S. military partnership with Afghan warlords—local and regional 

strongmen who commanded private militias, some of whom were collectively 

known as the Northern Alliance—was a logical consequence of OEF’s 

intentionally light footprint and need for proxy fighting forces. Warlord militias 

constituted the organized, friendly armed forces available at the time.72 With 

approximately $1 billion to fund operations, the CIA channeled money, food, 

ammunition, and other means of support to the warlords and their militias.73

Small teams of joint CIA and U.S. special operations forces worked closely 

with the militias to kill and drive out al-Qaeda and the Taliban.74

The Northern Alliance militias had been fighting the Taliban for years. At the 

same time, however, the warlords and their men had committed horrific human 

rights abuses against fellow Afghans, especially during the ruinous civil war 

from 1992 to 1996. Human Rights Watch and Amnesty International had each 

documented indiscriminate attacks on civilians, intentional targeting of civilians, 

murders, abductions, rapes, forced labor, and looting of homes.75 According to 

a 2004 survey by the Afghan Independent Human Rights Commission (AIHRC), 

94 percent of Afghans surveyed thought that it was very important or important 

that people responsible for injustices were held accountable. The AIHRC made 

recommendations for bringing abusers to justice and removing them from 

government service.76

In addition to human rights atrocities, the warlords were also involved in 

fundamentally corrupt behaviors. They had survived 20 years of conflict 

by engaging in drug trafficking, arms smuggling, land grabbing, and illegal 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 17

checkpoints, activities which they conducted with impunity in the absence of 

a recognized central government. In the post-2001 era, these same activities 

proliferated and became prime examples of corruption.77

Bonn and Post-Bonn: Warlords and Strongmen Gain Power 

in the Nascent State

Two months after OEF began, the international donor community and Afghan 

leaders convened in Bonn, Germany, to decide the immediate political future of 

Afghanistan. The warlords’ relationships with U.S. forces afforded many of them 

and their proxies seats at the negotiation table.78 In addition, warlord commander 

Marshal Mohammed Fahim’s forces had taken control of Kabul.79 This gave the 

mainly non-Pashtun group of warlords political leverage at Bonn. 

A profound dilemma emerged for the U.S. government as warlords began to 

acquire significant political power in the nascent Afghan state: Should the United 

States support political accommodation of the warlords to reduce the risk of 

armed rebellion, or keep warlords out of government because, once inside, they 

might interfere with the emergence of a legitimate, functioning state?80 When 

Hamid Karzai formed an interim government at the end of 2001, he appointed 

many regional warlords to senior positions in the central government and the 

subnational administration. Scholar Antonio Giustozzi assessed that of the 

first 32 provincial governors appointed in 2002, “at least twenty were militia 

commanders, warlords or strongmen. Smaller militia commanders also populated 

the ranks of the district governors.”81 The United States and its international 

partners, despite concerns about past crimes and abuses by these men, largely 

supported the appointments.82

The U.S. National Security Council (NSC) was engaged on the issue of keeping 

potential opponents to the Afghan central government in check, as was President 

Karzai. Declassified documents and interviews suggest the NSC pursued a set 

of policies referred to as the “warlord strategy.”83 According to a former senior 

DOD advisor, “The warlord strategy [was] essentially to engineer a series of deals 

with the warlords in which they would agree to demobilize their private armies in 

exchange for some kind of political role in the government—provided they would 

operate by the rules of the new Afghanistan.”84 In these early years, many warlords 

who had been previously identified as human rights abusers attained high-level 

posts: Marshal Fahim as Defense Minister, Ismail Khan as Minister of Energy 

and Water, Gul Agha Sherzai as Minister of Urban Development Affairs and two 

provincial governor posts, and others.85 These posts entrenched “their power 

and ability to use the state—and the international donor community—to extract 

resources for their patronage networks.”86

A senior DOD advisor recounted how a crisis brewed in October 2004 as former 

Northern Alliance commanders began conspiring against Karzai. According 

to the advisor, U.S. Ambassador to Afghanistan Zalmay Khalilzad met with 

several warlords and told them that “if they were acting against the Bonn 

process,” the U.S. government would not work with them. Khalilzad negotiated a 

governance agreement securing the warlords’ commitment to the demobilization, 

disarmament, and reintegration (DDR) process.87
SIGAR I CORRUPTION IN CONFLICT I 18 SEPTEMBER 2016

Yet, despite the attempts to co-opt the warlords, the DDR process failed to 

defang them.88 Warlords largely maintained their military power through which 

they continued to terrorize the population, engage in illegal land grabs, and set 

up illegal checkpoints, thus preventing the Afghan state from establishing a 

monopoly on the use of force.89 A former UN official recalled that many warlords 

created private security companies and maintained their militias as part of 

these companies, which U.S. and NATO troops then employed. Private security 

forces were also in high demand by construction and transportation contractors 

employed by international entities. As private companies, the armed militia forces 

were not under the jurisdiction of the Ministry of Defense and the DDR process 

did not apply to them.90

In the 1990s, the Taliban had partly been motivated by, and drew their initial 

popular support from, the goal of restoring order and ending the corrupt and 

predatory behavior of warlord rule.91 As the insurgency gained steam after the 

first years of OEF, the Taliban again employed this rallying cry against the Karzai 

administration, and the warlords and commanders who were associated with it.92

Michael Semple, a former UN official in Afghanistan and deputy to the European 

Union (EU) Special Representative in Afghanistan, noted the Taliban “fed upon 

[the coalition’s] mistakes ... and our failure to rein in the alienating practices of 

the people in the mid-level of the new establishment.”93

The problem of malign powerbrokers serving in government was compounded 

by the 2005 parliamentary elections. An Afghanistan Research and Evaluation 

Unit (AREU) report highlighted how warlords and criminals were legitimized by 

their election to the National Assembly. The report noted the National Assembly 

included “40 commanders still associated with armed groups, 24 members who 

belong to criminal gangs, 17 drug traffickers, and 19 members who face serious 

allegations of war crimes and human rights violations.”94

The U.S. government applauded Afghanistan on the success of its elections. And 

yet, according to the AREU report, local media reporting suggested a widespread 

perception among Afghans that the elections were “marred by weak candidate 

vetting, fraud, and intimidation.”95 The gap between U.S. praise and the public’s 

perceptions suggests the U.S. government either poorly judged the elections or 

was reluctant to point out their flaws.

In addition to the warlords, a newer class of politically connected strongmen 

emerged. These men were not field commanders or former mujahedin, but 

rather gained power and wealth through their connection to the international 

community, especially the United States. They mobilized their own militias 

and commanded strong loyalty from the army or police, while benefiting from 

access to foreign militaries and aid agencies. At the same time, these strongmen 

strengthened their links to the drug trade, smuggling, and criminal networks.96 

One scholar described the cycle:

Political access gave privileged entry to bid for contracts from 

the foreign militaries, donors, international aid organizations, 

and the government, or to obtain a government license for 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 19

businesses that served the international presence. Windfalls 

from contracts financed the politics of patronage that further 

enhanced the power and status of the agents involved and 

bought further access.97

One oft-cited example is Ahmed Wali Karzai, President Karzai’s half-brother 

and a leading member of the Karzai family, who built a “powerful empire” in 

Kandahar Province by developing control and influence over private security 

forces, contracting firms, and real estate.98 Wali Karzai formed alliances with 

strongmen who controlled transit routes and commercial and military networks. 

Through his access to the administration in Kabul, which appointed provincial 

and district officials, he was able to dominate Kandahar’s provincial and local 

government. The result was “the local population [saw] the government as 

an exclusive oligarchy devoted to its own enrichment and closely tied to the 

international coalition.”99

Ahmed Wali Karzai illustrates the perceived tradeoffs between security, stability, 

and accountability. Multiple journalists reported he had been a paid CIA asset 

for years. Despite his suspected involvement in the opium trade, land grabbing, 

and other illicit activities, he was deemed a vital security partner. There was 

reportedly little appetite within the CIA to hold him accountable, lest doing so 

jeopardize this critical relationship.100

In summary, political accommodation likely helped to neutralize some warlords. 

But many experts and U.S. officials acknowledge that this early and sustained 

support for warlords was ultimately damaging to long-term peace and stability 

in Afghanistan. By legitimizing warlords with political and financial support, the 

United States helped to empower a class of strongmen at the local and national 

levels who had conflicted allegiances between their own power networks and 

the Afghan state.101 Indirectly, the United States helped to lay a foundation 

for continued impunity of malign actors, weak rule of law, and the growth of 

corruption. Although U.S. agencies recognized the dangers of aligning with 

warlords, they did not fully appreciate the risks this posed to the mission 

in Afghanistan.

Civilian and Military Contracting: Establishing Perverse Incentives 

Three factors explain how U.S. money helped to fuel corruption in Afghanistan: 

the enormous influx of money relative to the size of the economy, weak oversight 

of contracting and procurement, and short timelines. Although these factors 

intensified after 2008 as more money and people flowed into the country, the 

structure of the problem emerged in the 2001 to 2008 period. 

Many former U.S. officials and experts who spent time in Afghanistan point 

to systemic problems with the way assistance was delivered. A former senior 

U.S. official described how a USAID office in Kabul did not have the capacity 

to manage many small projects because each one took as much time as one 

large project. The result was that large contracts went to large contractors, 

who subcontracted to smaller companies, who subcontracted to Afghan NGOs, 

who subcontracted to local contractors.102 The former official claimed that the 
SIGAR I CORRUPTION IN CONFLICT I 20 SEPTEMBER 2016

overhead for each of these levels absorbed 20 percent of the budget, and provided 

a hypothetical situation to explain further: 

The local engineer hired to implement the project knows his 

incentives. Everyone is under pressure to spend money, so 

he can inflate his budget. He can get second-rate materials 

because no one will check the work (or he can likely pay off 

inspectors). He will hire family to do the work. He, and every 

other contractor, is graded not on quality but on how many 

schools he builds, because ... this is the metric demanded in 

Washington. Therefore, he has little incentive to coordinate 

with local communities, other donors, or the local government. 

Just get the schools built so he can get the next contract. In 

addition, he doesn’t know how long the money will continue 

to flow, and he has many people in his family and community 

depending on him and telling him that it is his responsibility to 

make money now to support the rest of them when things go 

bad again. So, even for honest contractors, the incentives are 

for expensive, shoddy, uncoordinated, quickly built schools. 

And that is often what we got.103

In an interview for this report, Ambassador Ryan Crocker lamented the effects of 

an overwhelmingly large amount of assistance, amid pressures to spend quickly: 

I always thought Karzai had a point, that you just cannot put 

those amounts of money into a very fragile state and society, 

and not have it fuel corruption. You just can’t .... You need 

to have corruption framing everything you propose to do, in 

terms of development and reconstruction, and to overcome 

the instinctive American urge to do a whole lot and to do it 

tomorrow, to understand that if you try to do that, not only 

are there fundamental capacity questions ... but that you will 

inevitably be fueling large-scale corruption.”104

Another former U.S. official spoke to the same problems. Kirk Meyer, who served 

in Afghanistan for five years and directed a counterterrorist finance cell, said that 

by the time a local contractor received money to build a project, he “didn’t have 

enough money to build the road, plus pay the Taliban, plus pay the corrupt officials 

who usually took about 20 percent of every development project. So basically, the 

contractors didn’t build the projects or they built them shoddily, and because the 

projects were in contested areas, nobody verified whether they were built.”105

From 2001 to 2008, these dynamics characterized an aid delivery and contract 

system that would later be overwhelmed by even higher levels of assistance, and 

by greater political pressure to spend quickly and demonstrate progress. 

Emerging But Insufficient Appreciation for the Corruption Threat

Reviews of planning documents from 2001 to 2004 and interviews with former 

officials suggest there was inadequate appreciation within DOD, State, and USAID 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 21

for the long-term threat that corruption posed to U.S. goals in Afghanistan.106

Security, political stability, and immediate reconstruction needs took priority over 

the slow, iterative work of building good governance and the rule of law, including 

combating corruption. This was partly a function of the Bush administration’s 

aversion to “nation-building,” as the administration looked to the UN and other 

donors to take on the responsibility of shaping a new post-Taliban social order 

and public institutions.107 One senior U.S. official recalled the perceived tradeoffs 

between security objectives and anticorruption, saying that U.S. agencies did not 

want to aid and abet corruption, but national security was the higher priority. He 

recalled a pragmatic willingness to work with unsavory powerbrokers in order to 

pursue U.S. counterterrorism objectives, with the assumption that eventually, the 

United States would hold the malign powerbrokers to account—only that rarely, if 

ever, happened.108 Similarly, a former senior State official said, “If you want to get 

bad guys, you work with anyone and everyone to help you do that—even if they 

fundamentally act against your economic goals.”109

Nevertheless, there is evidence that some U.S. officials were attuned to the 

threat of corruption. According to a senior Treasury official and two USAID 

representatives who served in Kabul, their agencies harbored early concerns 

about the risks of not addressing corruption in Afghanistan.110 In addition, the 

Afghanistan Freedom Support Act of 2002 authorized programs “designed to 

combat corruption and other programs for the promotion of good governance.”111

It was several years, however, before U.S. agencies developed programs geared 

specifically toward reducing corruption. 

By mid-decade, Provincial Reconstruction Teams (PRT) in Afghanistan 

were reporting sporadically on police corruption, illegal police checkpoints, 

extrajudicial killings, and local warlords maintaining private militias while serving 

in government positions. There were also reports on warlords’ links to the drug 

trade, smuggling, and criminal networks.112 Embassy Kabul reported on Afghan 

police who were unable to pursue politically connected individuals and complex 

power struggles among provincial officials and militia commanders.113

In 2005, the embassy voiced louder concerns. A cable entitled “Confronting 

Afghanistan’s Corruption Crisis” summarized the embassy’s assessment:

Several factors have turned Afghan corruption in recent years 

from a customary practice into a major threat to the country’s 

future. Many of our contacts fear that narcotics could be the 

factor that causes corruption to spin out of control. They also 

see international aid and necessary USG/Coalition engagement 

with some unsavory figures as perpetuating the problem .... 

In the short term, President Karzai must take the moral high 

ground by removing corrupt officials .... The U.S. Mission 

is already taking steps to fight corruption .... The stakes are 

high, since fighting corruption is fundamental to the success of 

U.S. policy in Afghanistan.114
SIGAR I CORRUPTION IN CONFLICT I 22 SEPTEMBER 2016

The cable explained that some Afghans “imagine that the U.S. government and 

coalition could use their considerable influence more forcefully to deal with 

corrupt Afghan officials and their wrongdoing.”115 Similarly, one of Ambassador 

Ronald Neumann’s main recommendations to Washington at the end of his tenure 

in 2007 was to push “the Afghan government harder on issues of corruption and 

good governance.”116

DOD officials also became more attuned to corruption as a threat to the success 

of counterinsurgency operations in 2005 and 2006. Ambassador Neumann 

reported that, during a December 2005 visit to Kabul, Secretary of Defense 

Donald Rumsfeld noted that “Afghanistan was plagued by corruption and bad 

governance.”117 In the summer of 2006, a senior DOD official was tapped to 

review U.S. policy in Afghanistan and assessed that corruption was feeding 

a “crisis in governance.”118 The official briefed Rumsfeld that corruption was now 

a security issue:

Enormous popular discontent is building against corrupt and 

ineffective governance, undermining Karzai’s political standing, 

weakening the legitimacy of the new political order, and 

creating a vacuum of power in the south and other areas that 

the Taliban can exploit.119

The official claimed that a consensus existed “among key Afghan leaders and 

international officials on the nature of the problem.” The brief given to Rumsfeld 

described current reform efforts and further actions needed to monitor the 

performance of local and national government bodies and prosecute “selected bad 

actors—abusive police chiefs, spoilers, and officials involved in the drug trade—

as an example to others.” The brief also called for the United States to assume a 

“de facto lead role” in mobilizing a comprehensive judicial reform program.120

Shortly thereafter, in December 2006, the U.S. Army issued Field Manual 3-24, 

Counterinsurgency, known as the COIN manual. This publication explicitly aimed 

to offer principles and guidelines for forces fighting insurgencies in Afghanistan 

and Iraq.121 The manual stated, “The primary objective of any COIN operation is 

to foster development of effective governance by a legitimate government.”122

It repeatedly warned that corruption threatens counterinsurgency efforts by 

eroding public trust in the host nation government and thus undermining the 

state’s legitimacy. The doctrine detailed several historical examples where 

corruption had posed a serious and even fatal threat to COIN efforts: Chiang 

Kai-shek’s counterinsurgency against Mao Zedong in China, the British 

counterinsurgency in Malaysia, and the U.S.-trained South Vietnamese military.123

In addition, the COIN manual noted that weak oversight could undermine the 

mission, calling for commanders to “supervise contracted personnel to ensure 

they do not undermine achieving COIN objectives.”124

At USAID, concerns about corruption in Afghanistan also rose during this 

time. In 2004, the agency undertook a comprehensive assessment of Afghan 

corruption, which the embassy described as informing USAID anticorruption 

programming.125 In early 2005, USAID headquarters articulated a new strategy to 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 23

combat corruption globally, which included incorporating anticorruption activities 

across the agency’s work.126 In parallel, USAID’s mission in Afghanistan noted that 

“government institutions at all levels are weak ... and are tainted by high levels 

of corruption.”127

During the 2001 to 2008 period, U.S. agencies frequently viewed corruption in 

the context of the drug trade, which was seen as the insurgency’s main funding 

source.128 Some Afghan officials themselves engaged in trafficking and accepted 

bribes at transit points, or were pressured to limit or stop interdiction and 

eradication operations.129 State’s 2005 International Narcotics Control Strategy 

Report expressed confidence that “most officials” at the national level were not 

engaged in the drug trade, but that drug-related corruption at the subnational 

level was pervasive.130 Just two years later, however, State’s counternarcotics 

strategy for Afghanistan identified narco-corruption at all levels of the Afghan 

government and called for greater anticorruption efforts, including U.S. assistance 

to the Afghan Attorney General’s Office.131 U.S. law enforcement agencies largely 

addressed corruption as one aspect of counternarcotics activities. 

Limited U.S. Efforts to Address Corruption 

In this early period, DOD, State, USAID, Treasury, and Justice undertook few 

initiatives focused explicitly on fighting corruption. Yet several efforts—in the 

areas of financial management, institutional reform, and law enforcement—

addressed broader issues of governance and the rule of law and were relevant to 

later, more deliberate attempts to fight corruption. 

U.S. Development Assistance 

Establishing a functioning public financial management system in Afghanistan 

was a relatively early reconstruction goal.132 The aim was to institutionalize 

a set of measures necessary to maintain a stable and effective financial 

environment.133 This included providing technical assistance and training to the 

Ministry of Finance (MOF) and establishing internal controls at the Central Bank 

(Da Afghanistan Bank or DAB).134

In 2003 and 2006, respectively, USAID and Treasury began providing technical 

advisors to DAB’s Financial Supervision Department (FSD).135 The FSD was 

responsible for “ensuring the health of the banking sector by controlling the 

issuance of licenses” and “regulating Afghanistan’s commercial banks and 

other financial institutions.”136 Other USAID programs aimed to incorporate 

transparency, the state of “being open in the clear disclosure of information, rules, 

plans, processes and actions,” when helping to stand up Afghan ministries and 

other institutions.137

USAID’s Afghanistan Strategic Plan 2005–2010 articulated the agency’s policy 

approach to corruption in Afghanistan for the first time. It identified ongoing 

measures to combat corruption and noted these would “ultimately weaken 

warlords, leading to increased security in the regions.”138 The measures included 

support to civil society and media; strengthening banking supervision, land titling 

and tenure procedures, and oversight institutions; training prosecutors; improving 

democratic processes; encouraging private sector competition; and civil service 
SIGAR I CORRUPTION IN CONFLICT I 24 SEPTEMBER 2016

reform.139 Other programmatic efforts included reducing the chances for 

corruption in the levying and collection of customs revenue at border crossings 

by streamlining the valuation of imports.140

The strategic plan, however, mainly described existing efforts that had broader 

goals than anticorruption, for example, good governance, civil society and 

media development, and economic growth. The plan appeared to fit existing 

programs within the anticorruption agenda. It reflected a technical approach to 

anticorruption and failed to address two fundamental aspects of the corruption 

problem: how U.S. contracting and procurement in Afghanistan had set up 

perverse incentive structures that created opportunities for corruption and the 

deeply political nature of corruption in Afghanistan. As a result, the document did 

not consider how better oversight of U.S. assistance might reduce corruption or 

the extent to which technical anticorruption efforts could succeed if the Afghan 

government itself did not cooperate in such efforts. 

Diplomatic Pressure

By mid-decade, State, DOD, and USAID began to grapple more with the problem 

of corruption. Embassy Kabul worked with international partners to lobby Karzai 

“to remove a number of key officials implicated in corruption and other 

wrongdoing.”141 This was an area of important but uneven progress.142 For 

example, the president and chief executive officer of Afghan Telecom, 

Afghanistan’s state-owned communications company, was fired in part due to 

corruption charges that centered on a fuel contract for a corporate vehicle fleet.143

In a 2006 briefing for Secretary Rumsfeld, a senior DOD official noted that 

Lieutenant General Karl Eikenberry, commander of Combined Forces CommandAfghanistan, had “worked successfully with President Karzai to appoint better 

governors in Zabul, Uruzgan, and Helmand Provinces, and the new appointees 

have performed better and improved security conditions.”144

On the other hand, U.S. and international insistence on replacing corrupt officials 

backfired in some cases. For example, President Karzai had granted the Helmand 

provincial governorship to Sher Mohammed Akhundzada, whose clan had aligned 

with Karzai while Karzai and his family were in exile in Pakistan. Akhundzada 

took an inclusive approach to governance, distributing key security offices 

across tribal lines to ensure broad-based support.145 But under Akhundzada, the 

provincial police acted as little more than a militia controlled by him, facilitating 

a large narcotics network in the central Helmand River Valley and abusing the 

local population.146 In late 2005, U.S. forces allegedly found a large stash of 

[The plan] reflected a technical approach to 

anticorruption and failed to address two fundamental 

aspects of the corruption problem: how U.S. 

contracting and procurement in Afghanistan had 

set up perverse incentive structures that created 

opportunities for corruption and the deeply political 

nature of corruption in Afghanistan.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 25

opium when they raided the governor’s compound.147 The international donor 

community, particularly the UK, with U.S. support, demanded the removal of 

Akhundzada. Karzai complied and, careful to avoid alienating a powerful clan, 

appointed Akhundzada to the Upper House of Parliament. The abrupt removal 

of Akhundzada from Helmand triggered political instability in the province and 

allowed the Taliban to emerge even stronger than before.148 Thus, the outcome 

was that a likely narcotics trafficker gained a seat in Parliament and the 

insurgency regained a foothold in the province. 

Uruzgan Provincial Governor Jan Mohammad Khan, commonly known as JMK, 

presents an example of a similar policy backfire. At the insistence of the Dutch, 

JMK, who was accused of corruption and involvement in the drug trade, was 

removed from his governorship.149 But JMK was then made advisor to President 

Karzai and remained a major powerbroker in the province.150 Moreover, JMK was 

replaced by his nephew, Matiullah Khan, who became a close ally of U.S. forces, and 

whose actions and policies were arguably no different than those of his uncle.151

In some cases, corrupt or abusive powerbrokers were nominally marginalized 

but continued to exert influence and damage reform efforts. The 2006 briefing 

for Secretary Rumsfeld noted a trend of “former governors and police 

chiefs who have used militias or other devices to undermine their reformoriented successors.”152

Legal and Institutional Reform

In this early period, the international donor community’s anticorruption efforts 

centered on helping GIROA build a legal and institutional framework for 

anticorruption and devise a national strategy to address the problem. Donor 

countries, including the United States, but often with European allies and 

multilateral organizations in the lead, lent political and technical support for 

reform within GIROA. 

In late 2003, President Karzai established the General Independent Administration 

for Anticorruption (GIAAC) to create and implement the government’s 

anticorruption policy. Its mandate included investigation of corruption, which 

created a conflict over jurisdiction with the Attorney General’s Office (AGO). 

The GIAAC struggled because it lacked a clear mandate, political support, and 

institutional capacity.153 Then in 2006, Karzai’s appointment of Izzatullah Wasifi—

who had been convicted in the United States on drug charges—as director of the 

GIAAC catalyzed concern about the Karzai administration’s lack of seriousness 

on corruption. Donor pressure eventually led to Wasifi’s transfer to another 

government position; the GIAAC simply dissolved.154 In mid-2008, the High 

Office of Oversight and Anticorruption (HOO) was established as the successor 

to the GIAAC, but it too struggled under poor leadership, lack of political support 

and independence, and limited resources.155

In his 2004 inauguration address, Karzai vowed to “root out corruption [and] stop 

the abuse of public funds.”156 The same year, GIROA signed the UN Convention 

against Corruption (UNCAC), a major international agreement that defined norms 

and standards to which each signatory must adhere.157 Nevertheless, genuine 
SIGAR I CORRUPTION IN CONFLICT I 26 SEPTEMBER 2016

Afghan leadership on the issue was elusive; GIROA failed to take concrete steps 

to combat corruption.158 One anticorruption expert on Afghanistan characterized 

the dynamic: “Donors would push the Afghan government to do something about 

corruption. GIROA would say, ‘Yes,’ but then turn around and say, ‘You need us, 

so don’t push.’”159

In the security sector, the U.S. Forces-Afghanistan (USFOR-A) Combined 

Security Transition Command-Afghanistan (CSTC-A) began working with the 

Ministry of Interior (MOI) in 2006 on a reform plan for the MOI and ANP.160

CSTC-A implemented a new training and equipping program for 62,000 national 

and border police.161 Yet, there were setbacks. As Karzai leaned more heavily on 

powerful former warlords, he agreed to 14 senior police appointments suggested 

by Marshal Fahim, all 14 of whom were connected to criminal networks. This 

severely undermined the reform program at MOI and illustrated how robust 

U.S. reform efforts could be virtually undone by Afghan political leaders.162

These tentative institutional reform efforts were thus stymied by a lack of Afghan 

political commitment, weak capacity, and strong incentives for officials to 

continue to engage in corrupt behavior.163

Law Enforcement and Oversight

Law enforcement efforts to combat corruption moved forward primarily in the 

context of counternarcotics. Established in 2005, the Criminal Justice Task Force 

(CJTF) was a joint operation of the Afghan Ministries of Interior and Justice, the 

Supreme Court, and the AGO, coordinated by the Ministry of Counternarcotics. 

The United States, UK, UN Office on Drugs and Crime (UNODC), and other 

donors supported the unit. The CJTF was created to prosecute mid- and high-level 

drug-related cases, but its mandate was soon expanded to include narcoticsrelated corruption cases.164 State’s INL funded U.S. Department of Justice (DOJ) 

prosecutors to mentor and train Afghan prosecutors at the CJTF, which was later 

also known as the Counternarcotics Justice Center (CNJC).165

To address corruption by U.S. and other non-Afghan nationals, U.S. law 

enforcement agencies and military investigators stood up the International 

Contract Corruption Task Force (ICCTF) in 2006.166 This body coordinated 

investigation and prosecution of contract fraud, with the goal of building cases 

that could be prosecuted in U.S. courts.167 The FBI also sent a legal attaché to 

Kabul to address leads within the FBI’s jurisdiction.168

By the end of this time period, there was increasing concern about waste, fraud, 

and abuse of U.S. reconstruction funds. Congress created the Office of the 

Special Inspector General for Afghanistan Reconstruction (SIGAR) in 2008 to 

provide independent and objective oversight of U.S. reconstruction activities 

in Afghanistan.169

Donors Begin to Consolidate Thinking on Anticorruption, 

But Still Face Obstacles

At the London Conference in 2006, donors and GIROA agreed to the “Afghanistan 

Compact,” which for the first time provided the Afghan government with 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 27

measurable benchmarks and target dates for anticorruption steps. These included 

ratification of the UN Convention against Corruption and national legislation 

that conformed to international norms and standards as outlined therein; review 

and reform of oversight procedures relating to corruption; reforms of key justice 

sector institutions; and more arrests and prosecutions of drug traffickers and 

corrupt officials.170 Other benchmarks were set for the professionalization of 

the security forces and disbandment of illegal armed groups; reform of the civil 

service, elections, and judicial sector; improvements to the land registration 

system and settling land disputes; protection of human rights; improved financial 

management at the national and provincial levels; and supervision of banking. 

The compact also laid out benchmarks for transparency and accountability to 

improve aid effectiveness by both the Afghan government and international 

donor community.171

The compact benchmarks were highly ambitious, given Afghanistan’s 

development challenges and a deteriorating security situation.172 The compact 

lacked prioritization and likely reflected unrealistic expectations of donors 

eager to demonstrate progress and a host government anxious to comply. The 

benchmarks also embodied the dilemma around anticorruption: They covered 

many areas of reform, but largely depended on the political commitment of 

Afghan leaders who had a vested interest in maintaining the status quo. By 2008, 

the lack of Afghan progress toward meeting the initial benchmarks elicited 

frustration within the donor community.173

The 2009 OECD report noted that in London, some donors had advocated for 

“concrete anticorruption benchmarks” in the compact, but the United States 

and UN supported the Afghans’ preference for softer benchmarks.174 Other 

former U.S. officials and international experts supported this observation that 

anticorruption in Afghanistan was still not a high priority for the United States, 

despite growing concern about corruption’s impact.175

After the 2006 London Conference, donors focused on helping the Afghan 

government devise a comprehensive strategy to fight corruption. The World 

Bank, Asian Development Bank, DFID, UN Development Program (UNDP), and 

UNODC collaborated to write “Fighting Corruption in Afghanistan” in 2007.176

The paper identified modest signs of progress, including GIROA’s recognition 

of corruption as a critical issue, some progress in public administration, better 

fiduciary standards and improved management of state assets, initial efforts to 

establish checks and balances on executive power, streamlining of administrative 

processes, and some efforts to prosecute corruption cases.177 The paper suggested 

a broad roadmap for action against corruption, highlighting the need for greater 

commitment by GIROA to fight corruption; a clearer institutional framework 

for anticorruption; better understanding of the context, problems, actors, and 

dynamics of corruption in Afghanistan; corruption assessments for key sectors, 

agencies, and functions; cross-cutting reforms; a national anticorruption strategy; 

and a harmonized approach by the international donor community, while ensuring 

GIROA leadership.178 The roadmap helped to inform the Afghan government’s 

anticorruption strategy within the larger Afghanistan National Development 

Strategy (ANDS), a multi-sectoral development plan for 2008 to 2013. 
SIGAR I CORRUPTION IN CONFLICT I 28 SEPTEMBER 2016

At the same time, Karzai formed a high-level government committee chaired by 

Chief Justice Abdul Salam Azimi and tasked it with identifying the root causes 

of corruption and providing recommendations.179 The committee’s final report, 

released in mid-2008, provided detailed administrative steps each ministry 

could take to reduce its vulnerability to corruption.180 However, an Afghan 

anticorruption expert said that the recommendations were seen as an antiquated, 

bureaucratic response to a problem of a different nature and scale.181

Despite increasing donor attention to corruption issues, poor coordination and 

competing political priorities of donor countries hampered efforts. The lead 

nation approach devised in 2002 provided a division of labor for donor countries, 

but also fractured the reconstruction effort and enabled donors to pursue their 

own, sometimes divergent, priorities.182 The 2009 OECD report assessed that 

anticorruption efforts to date had succeeded in establishing some consensus 

around the corruption problem and setting specific benchmarks, but in terms of 

concrete impact, had amounted to little more than window-dressing.183 Donor 

responses to corruption were also constrained by poor message unity and the 

challenge of the sheer number of international players.184 Donors’ calls for 

anticorruption commitments by the Afghans were not always “communicated 

with clear expectations of concrete actions.”185

Summary: Obstacles to Advancing an Anticorruption Agenda

In the first seven years of the reconstruction effort, the U.S. government did not 

view anticorruption as a top priority; rather, counterterrorism, political stability, 

and reconstruction objectives took precedence. By virtue of its military alliances 

and political support, the United States inadvertently helped to empower malign 

powerbrokers. Once in government, these individuals strengthened and expanded 

their patronage networks. In an environment of weak rule of law, they could 

engage in the drug trade and other criminal enterprises. Meanwhile, surveys 

indicated that the Afghan population was alienated by an increasingly corrupt 

government, which in turn undermined popular support for the state, as well 

as for the international actors backing the state. 

There was an inherent tension between ambitious plans for a technocratic, 

capable state governed by the rule of law, and the approach the U.S. government 

and President Karzai pursued of a “messy mix” of “unsteady formal institutions, 

influenced if not dominated by powerful informal rules and organizations.”186

This mix stemmed from the lack of a national monopoly on the use of force 

and the resources to impose one. The international donor community’s inability 

to impose and enforce the rule of law made the fight against corruption a 

steep climb.

By 2006, the international donor community was trying to chart a path forward 

for preventing and combatting corruption. Though donors acknowledged a few 

signs of progress by GIROA, many people thought that progress paled in the face 

of Afghanistan’s corruption challenge and the lack of meaningful Afghan political 

commitment to tackle the issue.187
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 29

While certain individuals and offices within the U.S. government took an interest 

in corruption, U.S. agencies did not pursue anticorruption as a top priority in 

Afghanistan. In later years, as greater resources were devoted to the mission 

overall, U.S. officials would develop a more sophisticated understanding of the 

links among corrupt government officials, the drug trade, criminals, and insurgent 

groups—and come to appreciate corruption as a strategic threat. Together, the 

increase in resources and deeper understanding of corrupt networks would 

prompt greater U.S. efforts to combat corruption in Afghanistan. 

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 31

PART TWO 

A Call to Action: 2009–2010 

U.S. attention to corruption in Afghanistan surged in 2009 and 2010 as 

U.S. officials became increasingly concerned about three issues: (1) Corruption 

was fueling the insurgency by financing insurgent groups and reinforcing 

grievances that led to greater popular support of the groups, (2) corruption was 

undermining the legitimacy of the Afghan state, and (3) the United States itself 

was contributing to corruption through limited oversight of its aid and military 

contracting, and by partnering with malign powerbrokers. As a result of these 

insights, as well as increased numbers of personnel and resources dedicated to 

Afghanistan, anticorruption became a key element of U.S. activities in the country. 

A flurry of strategies for tackling corruption were drafted, and several U.S. and 

ISAF entities were formed to better understand the nexus of corruption, drugs, 

crime, and insurgency; prevent terrorist financing; and improve oversight of U.S. 

contracting. These efforts, however, were not unified by a comprehensive strategy.

This surge in awareness and activity came up against the reality of entrenched 

criminal patronage networks that involved high-level Afghan officials who did not 

share U.S. objectives. Two major events in 2010—the arrest on corruption charges 

and prompt release of a key Karzai aide, and the near-collapse of Kabul Bank 

due to massive fraud by politically connected bank executives—demonstrated 

White House photo
SIGAR I CORRUPTION IN CONFLICT I 32 SEPTEMBER 2016

that Afghan leaders were not committed to fighting corruption. These events 

also called into question the scope of U.S. leverage over the Afghan government. 

U.S. officials had to weigh how much political capital to invest in anticorruption 

efforts, while trying to maintain access to the Karzai administration to move other 

U.S. priorities forward. 

A New Strategy and Reinvigorated Counterinsurgency Effort 

As President Barack Obama took office in January 2009, U.S. policymakers were 

shifting their attention from Iraq to Afghanistan; the Afghan insurgency had gained 

strength.188 The rise in Afghan insecurity had occurred despite a near-doubling 

of U.S. military forces between late 2004 and late 2008 (from 18,300 to 32,500).189

Over the same four-year period, coalition troop numbers had increased from 

8,500 to 31,400, and Afghan security forces (army and police) had grown from 

57,000 to about 148,000.190 With 155 fatalities, 2008 also marked the deadliest year 

for U.S. forces in Afghanistan.191 The new administration immediately initiated 

an interagency review of U.S. policy in Afghanistan and Pakistan that aimed to 

integrate U.S. policy toward the two countries and better address the terrorist 

threat emanating from the region.192

At the unveiling of the new Afghanistan-Pakistan (Af-Pak) strategy in March 2009, 

President Obama reiterated that the core goal of the United States was to 

“disrupt, dismantle, and defeat al-Qaeda in Pakistan and Afghanistan, and to 

prevent their return to either country in the future.”193 To achieve that goal, 

the strategy identified a handful of key objectives, including “promoting a 

more capable, accountable, and effective” Afghan government and developing 

“increasingly self-reliant” Afghan security forces. At the heart of the strategy was 

“executing and resourcing an integrated civilian-military counterinsurgency” 

effort.194 This eventually translated into a surge in both people and assistance to 

Afghanistan, which increased the resources available to address corruption. 

Between April and October of 2009, U.S. military forces in Afghanistan increased 

by about 21,000 to a total of approximately 66,000.195 In December 2009, the 

deployment of 30,000 more military personnel was announced and, by the height 

of the surge in March 2011, there was a total of 99,800 troops.196 The military surge 

was also accompanied by an increase in the U.S. civilian effort; the “civilian surge” 

was intended to build Afghan government capacity at the national and local 

levels.197 In January 2009, 320 civilians were serving in Afghanistan under Chief 

of Mission authority, with an additional 394 civilian personnel under DOD 

supervision in the country. By December 2011, civilians under Chief of Mission 

authority had jumped to 1,142, while the number of DOD civilian personnel rose 

to 2,929.198

Parallel to the surge of military and civilian personnel, U.S. foreign assistance 

to Afghanistan increased. Total U.S. reconstruction assistance appropriated 

for Afghanistan in FY 2009 was $10.39 billion. In FY 2011, that number rose to 

$16.65 billion.199 The flow of money into Afghanistan also increased with higher 

military contractual obligations to sustain the expanded U.S. troop presence. In 

FY 2007, DOD contract obligations for Afghanistan were $3.7 billion; in FY 2011, 

they were $17.79 billion.200
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 33

Corruption Increasingly Seen as a Critical Threat

By 2009, there was growing awareness and alarm within the U.S. government 

about the pervasiveness of corruption in Afghanistan.201 USAID’s assessment of 

corruption in Afghanistan warned of “networks of corrupt practices and people 

that reach across the whole of government to subvert governance.”202 According 

to investigative journalist and author Bob Woodward, the CIA was reporting 

“a staggering level of corruption, inaction and snarled intelligence relationships.”203 Embassy Kabul reported on complaints of rampant corruption in the 

provinces and within central ministries, as well as Karzai’s vulnerability due to 

perceived corruption.204 One embassy cable cautioned, “Official corruption and 

the money flowing from the drug trade are perhaps as likely as is the insurgency 

to undo our efforts in Afghanistan.”205 The cable went on to urge, “We will need to 

weigh in politically with top Afghan officials to generate the political will to take 

action against some of the corrupt/criminal individuals identified.”206

This shift in awareness was partially due to published surveys of Afghan 

perceptions of corruption. Several NGOs, international organizations, and ISAF 

accumulated survey data showing that Afghans were increasingly concerned 

about systemic corruption. A survey conducted in late 2009 by IWA indicated 

Afghans saw corruption as the third-biggest problem in the country, after 

insecurity and unemployment. IWA estimated the average value of a bribe was 

$156, a stunning 31 percent of per capita annual income. The survey results 

suggested corruption was getting worse; in 2009, the total value of bribes 

nationwide was estimated to be twice what Afghans paid in 2007.207 A nationwide 

ISAF survey in September 2010 found 80.6 percent of respondents believed 

corruption affected their daily lives.208 From 2006 through 2010, annual surveys by 

TAF found more than 74 percent of respondents believed corruption was a major 

problem in Afghanistan.209

Surveys in Afghanistan have been criticized for a variety of methodological 

weaknesses, such as the effect of security on obtaining a representative sampling, 

problems in how questions are asked and results aggregated, and allegations 

of forged responses.210 Yet, surveys are one of the only proxies available for 

measuring the extent of corruption and Afghan perceptions of the issue. Further, 

regardless of their shortcomings, they elevated the profile of the problem of 

corruption. Survey reports indicated to policymakers that endemic corruption was 

alienating the population from the same government the international community 

was trying to support. 

“Official corruption and the money flowing from the 

drug trade are perhaps as likely as the insurgency 

to undo our efforts in Afghanistan .... We will need 

to weigh in politically with top Afghan officials to 

generate the political will to take action against some 

of the corrupt/criminal individuals identified.”

—U.S. Embassy Kabul
SIGAR I CORRUPTION IN CONFLICT I 34 SEPTEMBER 2016

U.S. government documents increasingly cited corruption as generating 

widespread disenchantment with the government and support for the insurgents’ 

cause.211 Several reports described ordinary Afghans’ complaints of corrupt 

provincial and district officials, fraud involving development funds, and nepotism 

in which “incompetent or warlord types” were appointed to government 

posts.212 The police were seen as highly corrupt and extorted citizens at illegal 

checkpoints, and officials charged bribes for transporting goods across the 

border.213 One of the major findings of a 2009 field report prepared for DFID was 

that respondents consistently cited “government corruption and partisanship at 

provincial and district level[s] ... as a major reason for supporting the Taliban and 

Hizb-i Islami.” The report assessed that people turned to the Taliban as a way of 

expressing opposition to the government.214

Adding to these alarm bells, the Afghan presidential elections in September 2009 

were marred by massive fraud facilitated by election officials.215 The Electoral 

Complaints Commission, which had a majority of UN-appointed international 

commissioners, ultimately threw out nearly 25 percent of the votes. The corrected 

results required a runoff between Karzai and Abdullah, but Abdullah withdrew on 

the grounds that he “did not want to provoke a confrontation with Karzai or risk 

partisan violence, even though he feared the runoff would bring a repeat of the 

fraud that marred the first presidential poll.”216

The election controversy undermined the credibility of Karzai, the UN, and 

the international donor community regarding corruption. The UN and donor 

community were discredited in the eyes of many Afghans for failing to remedy 

systemic flaws in an electoral process they had put in place, and for ultimately 

supporting a Karzai victory, despite his likely role in the election fraud.217 As noted 

by Sarah Chayes, former special assistant to ISAF commander General Stanley 

McChrystal, this support for Karzai “was profoundly destructive to a rule of law 

principle.”218 On the other hand, the fraud-ridden elections appeared to toughen 

the new Obama administration’s resolve to address high-level corruption in the 

Afghan government. 

Corruption Funding the Insurgency

Parallel to these developments, U.S. officials were arriving at a crucial insight: 

U.S. money was flowing to the insurgency via corruption. This realization was the 

result of new efforts to trace the insurgency’s funding sources. In 2008, the White 

House assembled the Afghan Threat Finance Cell (ATFC), modeled on a similar 

unit in Iraq.219 The ATFC’s objective was “to identify and help disrupt the material 

and financial funding streams that were supporting the Taliban and other terrorist 

organizations.”220 Under Drug Enforcement Administration (DEA) leadership, with 

Treasury and DOD co-deputies, the unit began operations in late 2008. Initially, 

the ATFC’s mandate did not specifically include corruption.221 However, from 

the beginning of its operations, the ATFC’s analyses shed light on a complex 

and interdependent web of corruption among GIROA officials, drug traffickers, 

transnational criminals, and insurgent and terrorist groups.222 As Kirk Meyer, the 

DEA special agent who led the ATFC from 2008 to 2011, stated:
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 35

Everybody was in the money game to some degree. You 

had corrupt Afghan officials; you had bad actors in the 

Afghan business and financial sector, the Taliban and drug 

traffickers, all of whom were frequently acting in tandem .... 

The connections would spider out and connect to other illicit 

areas .... We started collecting this information and getting a 

very holistic view of what was going on.223

In August 2009, Commander, ISAF (COMISAF) General McChrystal’s 

“Initial Assessment” of the conflict drew similar conclusions. The assessment 

stated, “There are no clear lines separating insurgent groups, criminal networks 

(including the narcotics networks), and corrupt GIROA officials. Malign actors 

within GIROA support insurgent groups directly, support criminal networks that 

are linked to insurgents, and support corruption that helps feed the insurgency.”224

Meyer and a former deputy director of the ATFC said there was an appetite for the 

unit’s reporting at the highest levels of the U.S. government; a small NSC working 

group took interest in the ATFC, ensuring it had the resources it needed and that 

senior officials in Washington knew about its activities.225 Meyer recalled, “We 

started reporting on [corruption] because nobody else was really doing in-depth 

reporting on the problem. We started getting requests for the reporting ... from 

high-level officials in Washington,” and from Embassy Kabul and ISAF.226 Meyer 

stated, “People were shocked by how bad this situation was and who was 

involved in it.”227 This suggested U.S. policymakers had an incomplete 

understanding of how corruption manifested itself in Afghanistan. On the other 

hand, the ATFC’s findings might also have reflected the worsening of corruption 

over time. If the latter was true, U.S. officials had no empirical means of 

measuring the magnitude of corruption in previous years.

Agencies Prioritize the Corruption Threat 

Stemming from a growing body of evidence that corrupt networks were 

channeling support to the Taliban, a consensus began to emerge among DOD, 

State, and USAID that corruption was undermining core U.S. goals by materially 

fueling the insurgency and turning the population against the Afghan government. 

In short, corruption posed a strategic threat to the mission.

For the U.S. military, the notion that corruption undermined the Afghan state’s 

legitimacy went to the core of COIN doctrine. As described in the COIN manual, 

a central tenet of COIN operations is to bolster the host government’s legitimacy 

and capability, such that it can provide security and rule of law to enable the 

delivery of services and economic growth.228 To the extent corruption undermined 

“We started reporting on [corruption] because 

nobody else was really doing in-depth reporting on 

the problem .... People were shocked by how bad the 

situation was and who was involved in it.”

—Kirk Meyer
SIGAR I CORRUPTION IN CONFLICT I 36 SEPTEMBER 2016

the state’s legitimacy and capability by eroding public confidence in the 

government and hollowing out institutions, it posed a potentially fatal threat to 

COIN efforts. 

In this context, the 2009 Integrated Civilian-Military Campaign Plan for 

Support to Afghanistan, a joint document of the U.S. Embassy Kabul and 

USFOR-A, pointed to corruption as a driver of insecurity: “The insurgency is 

fueled by ... a thriving narcotics industry, illicit finance, corruption at all levels of 

government, and a variety of other criminal enterprises.”229 Similarly, General 

McChrystal’s “Initial Assessment” of the conflict articulated two principal threats 

to the success of the mission: (1) insurgent groups and (2) a crisis of confidence in 

the Afghan government “that springs from the weakness of GIROA institutions, 

the unpunished abuse of power by corrupt officials and power-brokers, a 

widespread sense of political disenfranchisement, and ... lack of 

economic opportunity.”230

DOD recognized the Taliban and other insurgents were not the coalition forces’ 

only enemies. A more amorphous threat emanated from the very government 

the coalition sought to bolster and defend. Further, McChrystal’s assessment 

noted the Afghan public perceived ISAF as complicit in the failure to hold local 

corrupt officials accountable, thus “undermin[ing] ISAF’s ability to accomplish its 

mission.”231 The document declared, “ISAF can no longer ignore or tacitly accept 

abuse of power, corruption, or marginalization.”232

Similar messages were appearing across the U.S. government. In his 2009 speech 

on the Af-Pak strategy, President Obama said, “We cannot turn a blind eye to 

the corruption that causes Afghans to lose faith in their own leaders. Instead, 

we will seek a new compact with the Afghan government that cracks down on 

corrupt behavior, and sets clear benchmarks ... for international assistance.”233

Special Representative for Afghanistan and Pakistan (SRAP) Richard Holbrooke 

noted in 2009 that corruption was undermining the government and serving as a 

“huge recruiting opportunity for the Taliban.”234 In mid-2010, a U.S. Embassy Kabul 

cable titled “Advancing Our Anticorruption Strategy” reported:

[Corruption’s] harmful impact on Afghan public attitudes 

toward a government either unwilling or unable to control the 

pervasive petty corruption that permeates every activity, is 

General McChrystal’s “Initial Assessment” of the 

conflict articulated two principal threats to the 

success of the mission: (1) insurgent groups and 

(2) a crisis of confidence in the Afghan government 

“that springs from the weakness of GIROA 

institutions, the unpunished abuse of power by 

corrupt officials and power-brokers, a widespread 

sense of political disenfranchisement, and ... lack of 

economic opportunity.”
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 37

real and debilitating ... and the corrosive effect on governance 

at the highest levels by patronage networks often financed 

by narco-trafficking and other criminal activity endangers 

the legitimacy of the Afghan government and fuels the 

insurgency.235

If the foregoing concerns revolved around the effects of corruption and 

their impact on the U.S. mission, concerns also deepened about the fact that 

U.S. policies and practices were partly to blame for the growth of corruption. In 

2009 and 2010, the emerging concern was that poor U.S. oversight, procurement, 

and contracting practices were enabling corrupt behavior. Without sufficient 

controls on U.S. funds, millions of dollars in U.S. reconstruction funds for 

Afghanistan were being wasted.236

Congressional concern about the potential for waste, fraud, and abuse of 

U.S. funds in Iraq and Afghanistan was the impetus for taking a closer look 

at DOD, State, and USAID procurement and contracting practices. Congress 

established the Commission on Wartime Contracting in Iraq and Afghanistan, 

an independent, bipartisan body charged with examining federal contracting 

for reconstruction, logistics, and security in both countries, and providing 

recommendations to Congress to improve contracting processes.237 In June 2009, 

the commission issued its first interim report, which singled out the risks of 

corruption in Commander’s Emergency Response Program (CERP) projects and 

provided detailed examples of exorbitant costs in contracting.238 That same year, 

General McChrystal issued his assessment and a USAID report noted that poor 

oversight could enable corruption, but did not emphasize improving oversight of 

U.S. funds.239

Then in November 2009, an article in the Nation reported that DOD trucking 

contractors in Afghanistan were routinely making protection payments for safe 

passage through insecure areas in order to supply U.S. troops in the field.240

The article spurred intense congressional interest, and a House subcommittee 

began to examine the military supply chain, specifically the “host nation trucking 

contract.” The majority staff of the subcommittee issued a June 2010 report, 

Warlord, Inc.: Extortion and Corruption along the U.S. Supply Chain in 

Afghanistan, concluding: 

1. Security for the U.S. supply chain was principally provided by warlords.

2. The highway warlords ran a protection racket.

3. Protection payments for safe passage were a significant potential source of 

funding for the Taliban.

4. Unaccountable supply chain security contractors fueled corruption and 

undermined U.S. COIN strategy.

5. DOD lacked effective oversight of these contractors.

6. Trucking contractors had warned DOD about protection payments for safe 

passage, to no avail.241 

The Warlord, Inc. report was the U.S. government’s wake-up call that the failure 

to manage and oversee logistics contracting was fueling corruption in Afghanistan 
SIGAR I CORRUPTION IN CONFLICT I 38 SEPTEMBER 2016

and helping to fund the enemy. The report focused on the security of the 

supply chain; a related issue was the vulnerability of commodities, such as fuel 

(see box 1). 

Another 2010 congressional staff report, Mystery at Manas: Strategic Blind Spots 

in the Department of Defense’s Fuel Contracts in Kyrgyzstan, echoed the same 

theme. DOD had awarded two contracts for the supply of fuel to a transit center 

in Manas, Kyrgyzstan, a hub for U.S. troops and supplies going to Afghanistan. 

There were allegations of corruption from 2002 to 2010 so serious that they helped 

foment two revolutions in Kyrgyzstan; the Kyrgyz public believed the United 

States used the fuel contracts to bribe two Kyrgyz presidents.242

As a result of the two congressional staff reports and others, momentum built 

for the reform of U.S. contracting in contingency operations. U.S. government 

agencies operating in Afghanistan, particularly DOD and USAID, took a hard look 

at their practices. 

Fuel is “liquid gold” in Afghanistan—easy to steal and sell on the black 

market. No single commodity has been as important to the reconstruction 

effort in Afghanistan as fuel, and no commodity has been at such risk of 

being stolen or wasted.243 As of September 2014, the Defense Logistics 

Agency had supplied more than 2.5 billion gallons of fuel to support 

U.S. personnel and Afghan security forces, at a cost of more than 

$12 billion.244

The theft of fuel has mainly occurred during fuel truck movements.245

Because DOD outsourced fuel deliveries to Afghan companies, it often 

lost visibility of and control over subcontracted fuel trucks between their 

departure from a loading facility and arrival at their destination.246 Trucks 

were often short of fuel upon arriving at a base, and drivers attempted 

to bribe base personnel to sign paperwork certifying that a full load was 

delivered. In other cases, trucks arrived with a full load, but drivers sought 

to have only a portion of the fuel offloaded, leaving some fuel in the tank 

to be taken off base and sold. 

Almost all the large fuel theft schemes investigated by SIGAR included 

U.S. military personnel and, in some cases, contract civilian personnel. 

The personnel either signed falsified paperwork or were complicit in 

creating false documents that purported to authorize trucks to take fuel 

and deliver it elsewhere. 

Fuel theft not only robs U.S. taxpayers and damages the reconstruction 

effort, but military operations can be jeopardized when needed fuel 

is stolen or otherwise diverted. Impending operations may force a 

commander to accept what fuel he can and forgo accountability processes 

to ensure mission success. Stolen fuel and associated profits can also 

wind up in the hands of insurgent groups. 

BOX 1: “FUELING” CORRUPTION
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 39

High-Water Mark for U.S. Anticorruption Efforts

An invigorated U.S. response to corruption arose from the increasing concern 

in 2009–2010 that corruption posed a critical threat to core U.S. goals. The 

White House, DOD, State, USAID, Justice, and Treasury became more engaged 

on the issue and devoted more resources to it.247 The agencies sought to tackle 

corruption in different ways, but all broadly aimed to prevent funds from going to 

the insurgency; boost the legitimacy and viability of the Afghan state; and improve 

oversight of contracting and development assistance. 

Strategies and Plans to Fight Corruption

Multiple strategies, each with elements related to anticorruption, were drafted in 

2009 and 2010, as ISAF, USFOR-A, NSC, DOD, State, USAID, and NATO undertook 

distinct but intertwined planning efforts.248 Appendix D provides an overview 

of the most relevant documents and their key proposed actions. The strategies 

shared several broad themes:

• Building GIROA capacity to provide more transparent, accountable 

governance and financial oversight, and to investigate and prosecute 

corrupt officials

• Increasing political will to fight corruption and undertake reforms

• Supporting civil society and the media to increase popular demand for 

combating corruption

• Ensuring contracting procedures do not facilitate or enable 

corrupt activities249 

At the same time, the various strategy documents were generated at different 

levels and by different actors, and were not unified or integrated. Embassy Kabul 

set out to craft a comprehensive interagency anticorruption strategy. 

The embassy’s April 2010 draft U.S. Government Anticorruption Strategy for 

Afghanistan was the most thorough articulation of U.S. anticorruption goals to 

date. It emphasized the points of agreement outlined above and, more specifically, 

called for leveraging diplomatic, legal, and development assistance tools to 

increase political will to fight corruption and support GIROA in implementing 

its anticorruption strategy. The draft strategy urged U.S. support for reform 

of the High Office of Oversight (GIROA’s anticorruption body) and addressed 

U.S. oversight of contracting, calling for the reform of U.S. and ISAF contracting 

procedures “to ensure they ... are transparent, and do not fund the activities of 

corrupt officials and powerbrokers.”250 The strategy recommended reducing layers 

of subcontracting, providing more direct grants to Afghan organizations, initiating 

a “fair price” scheme, and barring firms controlled by corrupt individuals from 

receiving U.S. government contracts.251

Despite grave concerns about corruption during this time, State never approved 

the embassy’s draft. A senior State Department official said the lack of an 

approved strategy did not hinder U.S. anticorruption efforts at the time because, 

in practice, the embassy used the draft strategy as authoritative guidance.252

Nevertheless, a 2010 SIGAR report concluded that U.S. anticorruption efforts 
SIGAR I CORRUPTION IN CONFLICT I 40 SEPTEMBER 2016

would benefit from an approved strategy intended to strengthen Afghan capacity 

to fight corruption.253

Establishing Ad Hoc Organizations

On the heels of these strategy documents, the United States created ad hoc 

U.S. and ISAF entities to respond in different ways to the challenge of corruption, 

including the U.S. role in exacerbating it. These organizations, shown in appendix 

E, included the ISAF Anticorruption Task Force (ACTF), Combined Joint 

Interagency Task Force Nexus (CJIATF-Nexus), Task Force 2010 (TF-2010), 

Task Force Spotlight (TF-Spotlight), U.S. Central Command (CENTCOM) 

Vendor Vetting Cell (VVC), USAID Vendor Support Unit, CJIATF-Shafafiyat 

(Shafafiyat), and the Coordinating Director for Rule of Law and Law Enforcement 

Office (CD/ROLLE). 

Several of these organizations were created to improve visibility on the flow of 

U.S. contracting dollars. Vendor vetting efforts sought to better identify who in the 

contracting chain received U.S. funds and, if any were known to be affiliated with 

insurgent groups, to cut them out of U.S. contracts. In the process, organization 

members learned a great deal about the criminal patronage networks that 

siphoned away donor funds and reduced Afghan domestic revenue. 

The first two organizations, the ACTF and CJIATF-Nexus, primarily focused on 

providing information that enabled targeting and interdicting corrupt networks.254

TF-2010, TF-Spotlight, and the vendor vetting units were geared toward oversight 

and vetting of contractors, including private security contractors; TF-2010 

also supported targeting for sanctions, law enforcement, and investigations.255

These bodies helped to develop within U.S. agencies a deeper understanding 

of corruption, its effects, and how U.S. practices were partly to blame for its 

increase. Though agencies saw the need to better coordinate their activities, 

successful coordination sometimes occurred in an ad hoc manner.256 Moreover, 

these various tactical efforts, though somewhat successful individually, were not 

unified at the political level by a consistent, systematic approach to the problem.

CJIATF-Nexus, ATFC, TF-2010, TF-Spotlight, and Shafafiyat assembled a body of 

knowledge about networks engaged in corruption. Their work provided civilian 

and military decision makers with a more complete picture of the corruption 

challenge, including insights on the intersection of corruption, the drug trade, 

crime, and the insurgency. For military forces, this knowledge led to revisions to 

operation plans and fragmentary orders that formally “elevated [anticorruption] to 

a distinct line of operation in the campaign plan.”257

A senior State Department official noted that when the military became more 

involved in anticorruption, it brought personnel and analysis that civilian agencies 

simply could not match.258 Though embassy reporting had articulated the threat 

as early as 2005, buy-in from DOD and ISAF catalyzed a broader response to 

corruption in 2009.259 Most of the intelligence, law enforcement, and contracting 

oversight bodies were formed and led by DOD. By contrast, no State or USAID 

civilian staffing effort on anticorruption issues approached the scale of the 

military effort. On the other hand, while ISAF and USFOR-A committed significant 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 41

numbers of personnel to address the corruption challenge, a DOD report on 

anticorruption efforts in Afghanistan concluded that many of the relevant 

personnel lacked necessary expertise.260

A positive lesson is that as the U.S. response to corruption evolved, offices and 

organizations built on each other’s work and spawned new efforts. For example, 

ATFC’s identification of vendors as malign actors prompted the creation of 

CENTCOM’s Vendor Vetting Cell.261 The Warlord, Inc. report led to the creation 

of TF-2010.262 Because ATFC had no contract specialists on staff, it would pass 

contractor information to TF-2010 for follow-up action.263 And when discrete 

efforts appeared to contain redundancies and pose potential coordination 

challenges, new bodies like Shafafiyat and CD/ROLLE were created to integrate, 

oversee, and achieve synergy among the disparate efforts.264

Improving Oversight of Contracting 

In 2010, the creation of TF-2010 and CENTCOM’s VVC were flagship efforts to 

better oversee DOD procurement and contracting in Afghanistan. TF-2010 was 

formed “to better understand the impact of contracting, especially the flow of 

contracting dollars at the sub-contractor level,” ultimately to ensure U.S. dollars 

did not flow to criminal or insurgent groups.265 The task force reviewed existing 

transportation, logistics, and security contracts and contracting procedures, and 

included experts in forensic auditing, criminal investigation, and contracting.266

It also had a link to the FBI, which supplied an “action arm” for criminal contract 

practices with a nexus to the United States.267

CENTCOM established the VVC at its headquarters in Tampa, Florida. This unit 

was tasked with vetting contract awards or options equal to or greater than 

$100,000 to non-U.S. vendors in Afghanistan and Iraq, with the aim of minimizing 

the risk “that insurgents or criminal groups could use U.S. contracting funds to 

finance their operations.”268

Further, COMISAF General David Petraeus issued COIN Contracting Guidance

in September 2010.269 The guidance sought to ensure that money, as a key tool in 

the counterinsurgency campaign, was used to empower ordinary Afghan people, 

not malign or corrupt individuals or organizations.270 The guidance acknowledged 

that spending large amounts of money quickly and with insufficient oversight 

could “unintentionally fuel corruption, finance insurgent organizations, strengthen 

criminal patronage networks, and undermine our efforts in Afghanistan.”271 In 

order to mitigate those risks, recommendations included understanding the role 

of contracting in COIN, including the requirement to vet vendors and contractors. 

State and USAID issued similar contracting guidance in November 2010.272

Supporting Afghan Institutions

DOJ increased its efforts to introduce more effective Afghan law enforcement 

measures to prosecute cases of corruption. This required building up the Afghan 

justice system, which was weak and had a reputation for endemic corruption. 

U.S. programs aimed to train and mentor specialized units in different Afghan 

justice institutions, including drug enforcement, special investigations, and special 

prosecutions. Ultimately, these interventions had limited success, but revealed a 
SIGAR I CORRUPTION IN CONFLICT I 42 SEPTEMBER 2016

fundamental flaw: The Afghan government was so deeply enmeshed in corrupt 

and criminal networks that dismantling them would mean dismantling major 

pillars of support for the government itself.

DOJ helped the Afghan government stand up two important law enforcement 

bodies: the Major Crimes Task Force (MCTF) within the MOI and the 

Anticorruption Unit (ACU) in the Attorney General’s Office. MCTF, established by 

the Federal Bureau of Investigation (FBI) with funding from DOD, was intended 

to build Afghan capacity in high-level investigations of and arrests in corruption, 

kidnapping, and organized crime.273 In 2009, U.S. Embassy Kabul saw MCTF as its 

“flagship anticorruption program.”274 In parallel, ACU was set up to prosecute 

high-level corruption.275 The FBI vetted the Afghans working in both units.276

DOJ saw initial success in building technical capacity within these Afghan bodies. 

DOJ attorneys and State’s INL successfully trained and mentored prosecutors.277

MCTF specialists, drawn from the Afghan MOI and National Directorate for 

Security (NDS), were trained by FBI and DEA agents. After only a year, MCTF had 

200 trained investigators who had opened 83 cases, 43 of which involved highlevel corruption, made 21 arrests, and obtained 9 convictions.278 One important 

success involved the commander of the Border Police in Herat Province, Brigadier 

General Malham Pohanyar. Working with the MOI’s Sensitive Investigations Unit 

(SIU), a drug enforcement body mentored by DEA, MCTF helped to build a case 

against Malham for bribes he collected from drugs and weapons traffickers. 

Malham was arrested, tried, convicted, and sentenced to 10 years in jail.279

By 2009, Treasury, DEA, and Department of Homeland Security (DHS) 

Immigration and Customs Enforcement (ICE) officials helped form the Financial 

Transactions and Reports Analysis Center of Afghanistan (FinTRACA) to identify 

and evaluate suspicious financial transactions. FinTRACA served as the Central 

Bank’s financial intelligence unit.280 Embassy Kabul reported in 2010 that DHS/

ICE and other international law enforcement agencies had given the unit high 

marks.281 A 2011 IMF report, however, found that “major shortcomings ... remain 

in [FinTRACA’s] current functioning.”282

To be effective, these law enforcement and financial entities required political 

support from the highest levels of the Afghan government. In 2010, two major 

corruption events demonstrated that Afghan leadership was not committed 

to moving the anticorruption agenda forward. These events—the arrest on 

corruption charges and prompt release of a Karzai aide, and the near-collapse of 

Kabul Bank due to massive fraud by politically connected bank executives and 

shareholders—called into question the limits of both U.S. leverage and Afghan 

political commitment in the fight against corruption. 

The Afghan government was so deeply enmeshed in 

corrupt and criminal networks that dismantling them 

would mean dismantling major pillars of support for 

the government itself.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 43

The Salehi Arrest: A Major Setback

In January 2010, Afghan investigators raided the offices of the New Ansari Money 

Exchange, a money transfer firm (hawala) that moved money into and out of 

Afghanistan. New Ansari was suspected of moving billions of dollars out of 

Afghanistan for Afghan government officials, drug traffickers, and insurgents.283

Investigators estimated that as much as $2.78 billion was taken out of Afghanistan 

by New Ansari couriers from 2007 to 2010.284 U.S. law enforcement and 

intelligence personnel worked closely with the MCTF and SIU on the case. In the 

course of the investigation, a wiretap recorded an aide to Karzai, Mohammad Zia 

Salehi, soliciting a bribe in exchange for obstructing the investigation into New 

Ansari. Reportedly, after U.S. officials played some of the wiretaps for an advisor 

to Karzai, the advisor approved Salehi’s arrest.285

In late July 2010, the MCTF arrested Salehi.286 Within hours of the arrest, President 

Karzai ordered Salehi’s release and the case was eventually dropped.287 Karzai 

quickly moved to exert more control over Afghan anticorruption units, including 

by restricting the work of U.S. and European officials who served as mentors.288

The New York Times reported that Salehi, who had once worked for notorious 

warlord Rashid Dostum, was “being paid by the Central Intelligence Agency, 

according to Afghan and American officials.”289 If true, this would suggest a 

U.S. intelligence agency was paying an individual as an intelligence asset even as 

U.S. law enforcement agencies were building a major corruption case against him.

Barnett Rubin, Afghanistan expert and former senior advisor to SRAP Holbrooke, 

noted that in making such payments for information and collaboration, the CIA was 

carrying out the mission to defeat al-Qaeda. Rubin also acknowledged, however, 

that by Afghan law, these payments constituted illegal corruption. As he noted in a 

New Yorker article, “One part of U.S. policy corrupted Afghan officials while other 

parts tried to investigate and root out corruption. Given the interest that defined the 

mission, concerns about corruption did not trump those of covert action.”290

According to former U.S. officials, the Salehi incident had a chilling effect on 

U.S. efforts to prosecute serious corruption cases. The ATFC had worked on the 

Salehi case as a “test case” for prosecuting high-level corruption.291 When it backfired, 

this demonstrated to U.S. officials not only that Afghan political commitment to fight 

corruption was absent, but that the political elite were willing to powerfully resist the 

U.S. push for accountability. Indeed, the Karzai administration reduced the authority 

of the MCTF and ACU. The Afghan AGO routinely declined offers from DOJ to train 

prosecutors, and the MOI put limits on U.S. cooperation with the MCTF.292

“One part of U.S. policy corrupted Afghan officials 

while other parts tried to investigate and root out 

corruption. Given the interest that defined the mission, 

concerns about corruption did not trump those of 

covert action.”

—Barnett Rubin
SIGAR I CORRUPTION IN CONFLICT I 44 SEPTEMBER 2016

By the time of Salehi’s arrest and release, a pattern had been established: Highlevel Afghan officials who were suspected of corruption often evaded arrest or 

prosecution. For example, ATFC and SIU investigators had been preparing a 

bribery case against Sediq Chekari, the former Minister for Hajj and Religious 

Affairs. According to the former director of the ATFC, U.S. officials had targeted 

Chekari because the United States wanted a high profile case—and U.S. officials 

judged it would be difficult for Karzai to protect someone who was stealing 

money from Hajj pilgrims, taking bribes from hotels in Mecca and Medina, and 

embezzling money from the ministry.293 In addition, Chekari had been a critic of 

Karzai. But the day he was to be arrested, the Deputy Attorney General (DAG) 

received a call from Karzai’s chief of staff, who ordered the DAG to allow Chekari 

to leave the country. Chekari fled to the UK. Following this, the ATFC helped 

FinTRACA recover more than $1 million of stolen money.294

In another example, Hajji Rafi Azimi, the vice chairman of a bank closely 

connected to New Ansari, was allegedly a key player in Chekari’s corrupt 

scheme. Though Afghan prosecutors sought to arrest Azimi, political interference 

prevented them from doing so.295 A U.S. official was quoted in the New York Times

in 2010 as saying the Obama administration was “pushing some high-level public 

corruption cases right now, and [Afghan government officials] are just constantly 

stalling and stalling and stalling.”296

A 2010 Washington Post article cited a shift of viewpoint at the White House 

toward the idea that serious corruption cases should be broached with Karzai 

privately to avoid public confrontations that could sour cooperation on a host of 

other issues.297 This hesitation at high levels of the U.S. government to push too 

hard on corruption issues was confirmed in several interviews with former senior 

U.S. officials, one of whom noted, “We can’t be in the business of undermining the 

government we were supporting.”298 Another former senior official said, “There 

were a million things we were trying to do, and all of them depended on the Karzai 

regime as an effective partner.”299

The Near-Collapse of Kabul Bank: Fraud on an 

Unprecedented Scale

In July 2010, a second, much larger crisis began to unfold. Sherkhan Farnood was 

the chairman of Kabul Bank, at the time Afghanistan’s largest private bank, and a 

major financier of Karzai’s presidential campaign. Farnood confided in the ATFC 

that the bank was in serious financial trouble.300 There were two rival factions in 

the bank struggling for control; Farnood led one faction, while CEO Khalilullah 

Ferozi led the other. President Karzai’s brother, Mahmoud Karzai, and First Vice 

President Fahim’s brother, Haseen Fahim, sided with Ferozi.301 Farnood began 

cooperating with U.S. officials, likely seeking an edge over the rival group.302

Farnood admitted the bank operated as a massive pyramid scheme; hundreds of 

millions of dollars had been fraudulently lent to fictitious companies, with no loan 

ever paid off. These hundreds of millions benefitted politically connected Afghan 

shareholders. Meanwhile, U.S. government funds for ANA and ANP salaries 

regularly moved through the bank. The bank used those funds to cover customers’ 

withdrawals whenever it had inadequate reserves. This practice masked the 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 45

fact that its reserves were constantly diminishing, while ordinary Afghan 

citizens’ deposits were used to fund the fraudulent loans.303 Two of the principal 

beneficiaries of the fraudulent loans were Mahmoud Karzai and Haseen Fahim.304

In September 2010, Kabul Bank nearly collapsed as publicity around the bank’s 

insolvency led to a panic among its depositors and more than $180 million 

was withdrawn.305

Ultimately, the extent of the theft was estimated to be roughly $982 million.306

As a portion of GDP, this amount would be equivalent to nearly $1 trillion in the 

U.S. economy. The international community, including the United States, was 

shocked at the brashness and scale of the theft. In subsequent years, the Kabul 

Bank scandal remained at the top of the agenda for donors’ engagement with the 

Afghan government. The latter repeatedly failed to take adequate steps to recover 

assets and hold accountable the bank executives and shareholders, who were 

politically connected at the highest levels.

Summary: Dilemmas for U.S. Anticorruption Efforts

Overall, in 2009 and 2010, U.S. agencies began to develop a more sophisticated 

understanding of systemic corruption and the threat it posed to the mission 

in Afghanistan. The U.S. government also recognized that its own spending 

exacerbated the problem. As a result, agencies stepped up efforts to build 

Afghan capacity to investigate and prosecute corruption cases, and established 

organizations to improve U.S. contracting practices. 

The Salehi and Kabul Bank events, however, demonstrated that when Afghan 

political commitment to fight corruption really mattered, such commitment failed 

to materialize. The United States’ most significant anticorruption capacity-building 

efforts to date ran up against entrenched criminal patronage networks whose 

interests ran counter to U.S. objectives. 

Corruption thus presented the United States with a profound dilemma. The 

U.S. COIN strategy rested on building a credible Afghan government, able to 

protect and deliver services to its citizens. However, corruption eroded not 

only the state’s legitimacy, but its very capacity to function. And any successful, 

sustainable fight against corruption needed the full participation—and ideally, 

leadership—of GIROA. 

Therefore, U.S. officials grappling with corruption faced three key questions: 

(1) How much political capital should they invest in pressuring the Afghans for 

reform, while maintaining access to the Karzai administration? (2) How should 

they pragmatically invest in anticorruption efforts when leaders within the Afghan 

government were actively undermining those efforts? (3) How could they best 

leverage other U.S. government tools to make progress against corruption? These 

dilemmas would shape the U.S. experience in countering corruption in the 2010 to 

2014 period.

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 47

PART THREE 

A Limited U.S. Government Response to 

Corruption: 2010–2014 

The U.S. government saw corruption as a serious threat to its mission in 

Afghanistan. In the wake of the Salehi arrest and Kabul Bank scandal, there 

was greater U.S. appreciation of the extent of corruption and the absence of 

Afghan political commitment to address it. At the same time, the United States 

was focused on high-level goals related to counterterrorism, the long-term 

U.S.-Afghan relationship, and reconciliation with the Taliban. U.S. officials had 

to weigh how much political capital to invest in pressing the Afghan government 

on corruption versus pursuing other goals; there was concern that pushing too 

hard on corruption might alienate Karzai and jeopardize his cooperation on 

security issues. 

Even as the Afghan government resisted U.S. efforts to combat corruption, the 

United States supported institutional reform and capacity building, pressed for 

judicial actions and better financial oversight, and strengthened civil society 

organizations and the media. In terms of mitigating the U.S. contribution 

to corruption, DOD and USAID vetted contractors and, along with State, 

implemented contracting guidance to reduce opportunities for corruption. 

U.S. Marine Corps photo
SIGAR I CORRUPTION IN CONFLICT I 48 SEPTEMBER 2016

Overall, these efforts had some success, but were largely tactical; they were 

not unified by an overarching strategy or backed by sustained, high-level 

U.S. political commitment. 

Competing High-Level Priorities 

From 2010 to 2014, several high-level U.S. priorities required political 

cooperation from the Karzai administration. The United States sought to 

maintain good relations with the Afghan leadership to ensure continued access 

for counterinsurgency and counterterrorism operations. This was particularly 

important at the height of the military surge in March 2011, which saw nearly 

100,000 U.S. troops in Afghanistan.307

Then, in June 2011, President Obama announced that U.S. forces would 

significantly draw down in Afghanistan, handing over security responsibilities 

to Afghan security forces by 2014.308 The U.S. government became focused 

on “transition,” the process of withdrawing troops and preparing for the shift 

of security responsibilities. Training and equipping the ANSF to combat the 

insurgency was a key part of the U.S. exit strategy; as the ANSF took the lead in 

operations, U.S. and international forces could gradually take a back seat.309 This 

process required close coordination with Afghan civilian and military leadership. 

U.S. agencies were trying to advance these priorities in partnership with the 

Afghan government. Yet the fragile U.S. relationship with Karzai had reached 

a low point amid deep concerns—emanating from the executive agencies 

and Congress—about widespread corruption and impunity within the 

Karzai administration.310

The U.S. government sought a strategic partnership agreement (SPA) with 

the Afghan government to provide the framework for a strong, post-transition 

relationship. A key pillar of the SPA was the initiation of negotiations on a 

bilateral security agreement (BSA) to define the terms of the U.S. troop presence 

after 2014.311 Signed in May 2012, the SPA underscored “the crucial importance 

of the fight against corruption.”312 U.S. commitments to support Afghanistan’s 

development and security were “matched by Afghan commitments to strengthen 

accountability, transparency, [and] oversight.”313

Negotiations around the BSA, however, became contentious, snagging on 

disagreements over security and financial guarantees for Afghanistan, and issues 

of jurisdiction for U.S. forces. Despite consensus backing from Afghan elites on 

a draft agreement presented at a November 2013 consultative loya jirga, Karzai 

refused to sign the draft, citing sovereignty concerns.314

In December 2013, SRAP James Dobbins testified before Congress that Karzai’s 

refusal to sign the BSA was a cause for deep concern. Without a BSA, there was 

no clarity on the future of the U.S. military presence in Afghanistan. Further, 

the agreement was critical to bolster Afghan confidence in the international 

community’s commitment to Afghanistan as the country prepared for presidential 

elections in 2014; ensure fulfillment of pledges of assistance that NATO and nonNATO nations had made at key international conferences; and signal to U.S. allies 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 49

and partners, other countries in the region, and the Taliban that the United States 

would not abandon Afghanistan.315 These factors put enormous pressure on 

U.S. officials to conclude the BSA. The agreement was not signed, however, until 

Ashraf Ghani and Abdullah Abdullah assumed power in September 2014.316

During this time, the United States also sought to explore political reconciliation 

with the Taliban. No matter how well U.S. forces trained the ANSF, many argued 

that the surest path to security and stability in Afghanistan was a political 

settlement to end the violence.317 In 2011, Secretary of State Hillary Clinton 

announced a “diplomatic surge” to support an Afghan-led reconciliation 

process.318 From mid-2011 to March 2012, the State Department pursued direct 

talks with the Taliban in an effort to open the door for negotiations between 

the Afghan government and Taliban representatives.319 To support this effort, 

the United States needed to preserve a working relationship with Karzai and 

ensure Afghan buy-in. 

From 2010 to 2014, a series of international donor conferences—in Kabul, London, 

Bonn, and Tokyo—shaped donor-Afghan relations. Reducing corruption was a 

persistent theme, along with the need for Afghan ownership of the security and 

development agenda, and a drive to narrow or further prioritize the development 

agenda. Each conference produced mutual commitments from GIROA and 

donors in governance and rule of law, security, economic development, and aid 

effectiveness. Most importantly for the anticorruption agenda, the conferences 

produced ever more specific benchmarks for Afghan progress on anticorruption, 

and donor funds were loosely tied to progress on those benchmarks.320

At the same time, the Kabul Bank crisis dominated donor discussions with 

GIROA officials on corruption issues. Many of the anticorruption actions that 

donors, including the United States, pushed the Afghan government to take 

were related to dealing with the theft of nearly $1 billion from Kabul Bank’s 

depositors, including prosecution of the individuals responsible (who were 

politically connected at the highest levels) and recovery of the stolen assets. In 

general, the Afghan government responded tepidly to these donor concerns.321

Frustrations over GIROA’s lack of cooperation on both Kabul Bank and broader 

law enforcement efforts damaged the U.S.-Afghan relationship and undercut 

hopes the Afghan government might take meaningful steps to fight corruption. 

Corruption Seen as a Serious Threat to the Mission

In early 2013, an Embassy Kabul update on anticorruption efforts declared, 

“Corruption remains arguably the most formidable obstacle to a stable 

Afghanistan, especially as the country moves past transition and into the post-2014 

era.”322 In 2014, General John Allen, recently retired from his position as COMISAF, 

testified before a subcommittee of the Senate Foreign Relations Committee. 

Reading from a letter he intended to send to the new Afghan president, Allen said: 

Acknowledging that the United States and the West bear some 

responsibility for the state of corruption in Afghanistan, the 

great challenge to Afghanistan’s future is not the Taliban or 

Pakistani safe havens or even an incipiently hostile Pakistan. 
SIGAR I CORRUPTION IN CONFLICT I 50 SEPTEMBER 2016

The existential threat to the long-term viability of modern 

Afghanistan is corruption. For too long, we focused our 

attention solely on the Taliban ... They are an annoyance 

compared to the scope and the magnitude of corruption with 

which you must contend.323

Anticorruption also gained prominence in light of serious concerns about 

the fiscal sustainability of the Afghan state. Based on World Bank economic 

projections for the Afghan economy, donors feared that as international forces left 

the country and foreign aid levels sharply declined, the country’s economy, fueled 

by military and aid inflows, would collapse.324 Corruption was seen as a large drain 

on the national treasury, a drain that Afghanistan could ill afford.

From 2010 to 2014, a variety of reports highlighted the same theme: Poor 

oversight of civilian and military procurement and contracting processes (in 

both aid delivery and sustaining the warfighting effort) was allowing massive 

corruption to occur, undermining the mission and resulting in significant losses of 

U.S. government funds.325 Other reports indicated the need for greater scrutiny of 

security contractors to determine whether they were affiliated with insurgent or 

criminal groups, or posed a risk of diverting funds to such groups.326

The Commission on Wartime Contracting in Iraq and Afghanistan’s final report 

to Congress, Transforming Wartime Contracting, was released in August 2011. 

The report examined contracting related to reconstruction assistance and military 

sustainment costs. It opened with the “conservative” estimate that “at least $31 

billion, and possibly as much as $60 billion, has been lost to contract waste and 

fraud in America’s contingency operations in Iraq and Afghanistan.”327 The report 

argued that “criminal behavior and blatant corruption sap dollars from what could 

otherwise be successful project outcomes and, more disturbingly, contribute to a 

climate in which huge amounts of waste are accepted as the norm.”328

The Commission also stressed the risks of spending too much money too quickly, 

noting that “rapidly pouring large amounts of money into Afghanistan’s local 

economy, which has limited absorptive capacity, has contributed to inflation, 

distorted normal economic activity, and encouraged fraud and corruption.”329

Box 2 and figure 4 more fully address the concept of absorptive capacity and 

its relationship to corruption, as derived from multiple sources and SIGAR’s 

own analysis.

“The existential threat to the long-term viability of 

modern Afghanistan is corruption.”

—General John Allen
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 51

In the development community, the concept of “absorptive capacity” generally 

refers to the “amount and form of international aid and attention that recipient 

institutions and societies can receive without suffering significant social, 

economic, or political disruptions.”330 In other words, “absorptive capacity sets 

limits on the productive potential of aid.”331 Scholar Robert Lamb describes a 

useful metaphor for understanding the concept:

Place a dry sponge on a dry table and pour water onto the sponge 

from a pitcher. Pour too much water and the table gets wet after 

the sponge reaches capacity; pour too little water and the sponge 

does not consume as much water as it could; pour too quickly and 

the table gets wet even before the sponge reaches capacity. Some 

sponges absorb more water than others; a dry sponge absorbs 

water less quickly than does a damp sponge. Most sponges get 

larger as they absorb the water. All have limits to the quantity and 

rate of absorption.332

Afghanistan’s ability to absorb and effectively use assistance funds has been 

a significant concern in the debate over the scale and rate of reconstruction 

assistance.333 In Afghanistan, spillover from more than $100 billion in 

reconstruction assistance contributed to pervasive corruption, illicit activity, and 

other adverse effects that distorted economic norms and undermined state 

legitimacy.334 Integrity Watch Afghanistan founder and former director Lorenzo 

Delesgues stressed that “staying within absorption limits is Development 101.”335

BOX 2: ABSORPTIVE CAPACITY

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 51

Note: The aid saturation point is the theoretical point at which a state has reached its capacity 

for absorbing aid. Aid provided beyond that point may be counterproductive. The red line shows 

U.S. reconstruction funding as a percentage of Afghan GDP over time (see figure 3, p. 18). The 

grey area reflects the generally accepted range of aid saturation, typically 15 to 45% of GDP (see 

endnote 339).

Source: SIGAR Lessons Learned Program analysis of: SIGAR, Quarterly Report to the United States 

Congress, January 30, 2016, p. 187; SIGAR, Quarterly Report to the United States Congress, 

October 30, 2014, pp. 202–203; World Bank, World Development Indicators: GDP at market prices 

(current U.S. dollars), World Bank Databank, accessed July 12, 2016.

FIGURE 4: U.S. Appropriated Reconstruction Funding for Afghanistan Shown 

as a Percentage of Afghan GDP

TYPICAL POINT OF AID SATURATION

0%

20%

40%

60%

80%

100%

120%

0%

20%

40%

60%

80%

100%

120%

20152014201320122011201020092008200720062005200420032002
SIGAR I CORRUPTION IN CONFLICT I 52 SEPTEMBER 2016

BOX 2: ABSORPTIVE CAPACITY (CONTINUED)

U.S. Efforts to Encourage Afghan Reform and Accountability

U.S. anticorruption efforts sought to improve the Afghans’ capacity for and 

commitment to fighting corruption. Appendix F provides a list of the Afghan 

government organizations the United States assisted and supported as part 

of these efforts. Broadly, U.S. efforts fell into the four key areas described in 

Embassy Kabul’s 2010 draft anticorruption strategy: 

• Improving the transparency and accountability of Afghan government 

institutions to reduce corrupt practices

• Building Afghan judicial capacity in investigations and prosecutions 

• Improving financial oversight 

• Helping the Afghan government and civil society boost demand for 

accountable governance341 

The shortcoming of this approach, however, was that it emphasized technical 

fixes rather than a concerted, high-level effort to address the political roots of 

corruption. U.S. agencies tended to do what they knew how to do best: support 

and advise on bureaucratic reform and capacity-building. The U.S. government 

was less adept, however, at addressing the fundamentally political nature of the 

corruption problem.342 This required assessing what drove corrupt behavior, 

particularly by political leaders who established a tone and culture of impunity, 

and determining how to change the incentive structures for those engaged in 

corruption.343 Furthermore, capacity-building efforts would be useless in the 

long term without Afghan political commitment to keep newly trained police, 

investigators, prosecutors, judges, and auditors in positions of responsibility, 

able to operate without political interference.344

However, as a World Bank report on Afghanistan’s post-2014 economic and 

political transition observed, high inflows of aid incentivized waste and corruption 

and impeded the building of a more effective Afghan state.336 An empirical multination study also found that high levels of international aid tended to increase 

corruption, while low levels reduced corruption.337

Common reference to “absorptive capacity” suggests there is a model to 

determine a country’s absorptive limits. This is not the case. A UN report 

concluded, “To date, there has been very little systematic effort either to define 

the key drivers of absorptive capacity or to measure a country’s ability to absorb 

scaled-up foreign assistance.”338 In addition, establishing a causal link between 

oversaturation and adverse effect is difficult. Nevertheless, aid practitioners do 

employ informal estimates. Studies suggest that a state’s capacity to absorb 

aid can range from 15 to 45 percent of its GDP; states with weaker institutional 

capacity possess a lower threshold for aid saturation.339

For most of the 2002–2015 period, appropriated U.S. reconstruction assistance 

to Afghanistan surpassed 45 percent of Afghanistan’s GDP, reaching a high of 

105 percent in 2010 and never falling below 22 percent (see figure 4 on the 

previous page).340
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 53

In fact, the embassy’s draft strategy was upfront about this political dimension. 

The strategy stressed the importance of “leveraging diplomatic, legal, and 

development assistance tools to increase the political will (within the Afghan 

government, the U.S. government, and the international community) to take 

fighting corruption seriously.”345 However, in practice, shaping political will—

which might have included the use of more aggressive tools to bring political 

pressure to bear on Afghan leaders—did not always take priority over other 

U.S. objectives. 

The Kabul Bank Crisis: Attempts at Resolution 

The 2010 discovery of massive fraud at Kabul Bank exposed high-level 

corruption. The Afghan government was slow to take critical steps to recover 

stolen assets and prosecute the individuals responsible for the fraud.346

Senior U.S. officials repeatedly urged GIROA to pursue prosecutions 

and robust asset recovery, and grappled with how to leverage aid money 

in order to encourage reforms.347 These efforts were intensively coordinated 

with the rest of the international community.348 Meanwhile, however, 

Karzai publicly blamed the international community for the corruption of 

Afghan officials.349

Donor pressure on GIROA further escalated. The IMF, in renewing its Extended 

Credit Facility (ECF) program, proposed terms for reforming Afghanistan’s 

financial system and regulatory regime. By agreeing to the terms, GIROA would 

qualify for assistance financing under the ECF program. The Afghans initially 

refused the proposed terms. This prompted donors, including the United States, 

to delay disbursement of 85 percent of the total $933 million in donations to the 

Afghanistan Reconstruction Trust Fund (ARTF) in solar year 1390 (March 2011–

March 2012), until a new ECF agreement was approved.350

Negotiations over the IMF program pushed GIROA to take actions, albeit limited 

ones. By May 2011, the Afghan government had fulfilled some IMF demands, 

including placing Kabul Bank under receivership, invalidating shareholders’ 

claims on cash and assets, and initiating criminal investigations.351 GIROA also 

began asset recovery efforts. However, as the international community pressed 

for prosecutions and more robust asset recovery, the Afghan government failed 

to take meaningful actions.352

For a period in 2011, the issue appeared frequently on the U.S. NSC Deputies 

Committee’s agenda, according to a former senior U.S. official who was involved 

in the meetings.353 Embassy Kabul continued to monitor the Afghans’ progress on 

asset recovery and prosecutions and to press for follow-up.354 Then, as little to 

Capacity-building efforts would be useless in the 

long term without Afghan political commitment to 

keep newly trained police, investigators, prosecutors, 

judges, and auditors in positions of responsibility, 

able to operate without political interference.
SIGAR I CORRUPTION IN CONFLICT I 54 SEPTEMBER 2016

no progress was forthcoming, the issue fell off the Deputies Committee’s agenda, 

according to the same official.355

According to a senior Treasury official, during negotiations over the new ECF 

program, many donor countries expressed concern to the IMF that proposed 

benchmarks exceeded what the Afghan government could bear.356 Two other 

U.S. officials indicated the IMF eventually diluted its terms in response to 

U.S. urging, so GIROA could meet the terms and donor funding could resume.357

In November 2011, the Executive Board of the IMF finally approved a three-year, 

$133.6 million loan under the ECF. The IMF conditioned the agreement on several 

structural changes to Afghanistan’s banking and financial sectors, which involved 

further resolution of the Kabul Bank crisis and steps to ensure better governance 

and accountability in the banking system. The ECF arrangement also prompted the 

release of $100 million in ARTF funds, and an announcement by Secretary Clinton 

that the United States would resume its funding of the ARTF.358 Ultimately, the 

Afghan government suffered no major consequences, in terms of financial support 

from donors, for its failure to hold accountable and recover significant assets from 

the politically connected individuals who had defrauded the Afghan people. 

In 2012, the Afghan Supreme Court indicted 21 defendants in the Kabul Bank 

case. Charges ranged from money laundering, public corruption, and fraud to 

dereliction and negligence by regulators and bank officials.359 Later that year, in 

a major public inquiry into the Kabul Bank scandal, a joint Afghan/international 

anticorruption body determined that the indictment excluded many key 

beneficiaries and participants in the scheme and that “the major factor impeding 

the criminal investigation process is political interference.”360 In March 2013, 

the Special Tribunal for the Bank convicted the two leaders of the fraud, exchairman Sherkhan Farnood and ex-CEO Khalilullah Ferozi, for breach of 

trust. The men were sentenced to five years in prison and ordered to return a 

combined $808 million. The tribunal failed, however, to issue guilty verdicts for 

the more serious crimes of money laundering, embezzlement, and forgery, which 

would have carried sentences up to 20 years and provided a basis for orders to 

confiscate their assets.361

At the same time, the U.S. government showed a lack of political commitment. 

When it became clear the Afghan government was not willing to undertake true 

reform—because it involved taking action against people connected to the highest 

levels of political power—the U.S. government failed to use all its available 

tools to incentivize steps toward resolution. U.S. officials could have insisted on 

stronger corrective actions by GIROA before supporting agreement on a new 

IMF program. DOD, State, and USAID could have conditioned more significant 

security and development assistance on tangible, measurable progress. State, in 

consultation with other agencies, might have pursued revocation of visas against 

corrupt Afghan officials and their families, and more robust U.S. law enforcement 

actions against corrupt Afghans with dual U.S. citizenship.

Katherine Dixon, the director of Transparency International’s Defence 

and Security Programme and a former UK government official, observed, 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 55

“The international community held all the cards, but the individuals on the ground 

representing [the community] felt small in comparison to the power wielded by 

warlords and because they knew how much they needed Afghanistan to work.”362

During the Kabul Bank crisis, this misperception of leverage was perhaps at play. 

Donors, including the United States, were eager to move beyond the crisis and 

resume prior assistance spending levels. The aid community was driven by good 

intentions to ensure the most vulnerable Afghans who benefited from foreign aid 

did not suffer because of corrupt actors. The corollary, however, was that the 

international community missed an opportunity to incentivize reform that might 

have, in the long run, also greatly benefited the Afghan population. 

Institutional Reform for Transparency and Accountability

From 2010 through 2014, U.S. efforts focused on supporting and pressing for 

reform within Afghan institutions. State, USAID, DOD, Treasury, and Justice 

provided training and mentoring, budgetary support, and equipment to various 

Afghan institutions.363 In their engagements with Afghan leaders, senior U.S. 

civilian and military officials focused on specific steps to reduce corruption and 

hold individuals accountable.364

These efforts contributed to important, tangible progress, such as increased 

Afghan capacity to identify, prosecute, and punish corrupt officials, and to some 

degree, a demonstrated willingness to do so.365 In early 2013, Embassy Kabul 

reported that GIROA “and other key stakeholders in Afghan society (notably 

civil society and the media), with encouragement from Embassy Kabul and 

various concerned members of the international community, have taken steps 

in significant areas to increase transparency, promote legitimate commerce, 

and reduce opportunities for extortion and graft.”366 These “incremental but 

concrete” steps included customs department reform and streamlined customs 

procedures, a new draft mining law, anticorruption commitments by MOI, and 

civil service reforms for merit-based hiring.367

Nevertheless, initially hopeful examples of progress often resulted in mixed or 

negligible effects. Progress sometimes unraveled when Afghan officials blocked or 

undid prior actions, or failed to follow through on commitments.368 For example, 

U.S. officials pressed for Afghanistan to implement the Extractive Industries 

Transparency Initiative (EITI) standards, designed to improve governance through 

the full publication and verification of company payments and government 

revenues from extractive industries. In 2010, Afghanistan committed to implement 

these standards.369 Yet, the mining law that was eventually passed in 2014 had 

serious weaknesses. Global Witness, a leading international NGO active in the 

extractives sector, called the law “a threat to stability” and judged it was likely to 

“fuel conflict and corruption instead of development.”370

At the same time, high turnover of U.S. civilian and military staff meant 

U.S. institutional memory was weak and efforts were not always informed by 

previous experience. In addition, capacity-building efforts were sometimes 

fragmented and lacked a vision for systemic change.371 For instance, one Afghan 

anticorruption expert noted that U.S. agencies often hosted workshops and 

training that lasted only a few days, with limited follow-up. He suggested that a 
SIGAR I CORRUPTION IN CONFLICT I 56 SEPTEMBER 2016

more fruitful approach might have been to establish a standing institute to train 

auditors, attorneys, investigative police, and others for years, rather than days.372

One of the United States’ significant anticorruption efforts during this time 

period was to help GIROA build an independent, effective anticorruption 

institution. In 2008, President Karzai had established the High Office of 

Oversight to oversee and coordinate GIROA’s anticorruption efforts. The HOO 

was empowered to conduct preliminary inquiries of corruption allegations.373

One of its priority tasks was to enforce asset declarations by senior Afghan 

officials.374 In 2010, USAID helped the Afghan government draft a Presidential 

Decree to strengthen the HOO’s independence and oversight authority.375

As interest in anticorruption rose and a SIGAR audit of the HOO urged 

more U.S. support for the office, USAID launched a project, Assistance to 

Afghanistan’s Anticorruption Authority (4A), in 2010 to provide $27 million over 

three years to increase institutional capacity within the HOO.376

The capacity-building project for the HOO, however, underscored that 

institutional reform did not work without political will. Despite heavy donor 

investment in building the HOO’s capacity, it suffered from a lack of 

independence, poor leadership, and alleged internal corruption; the HOO 

appeared unwilling or unable to carry out its mandate.377 USAID sharply reduced 

funding for the HOO, ultimately redirecting most of the funding to support civilsociety efforts.378 When Karzai appointed Azizullah Lodin as director of the HOO 

after Lodin had been implicated in the 2009 election fraud, the United States and 

other donors grew increasingly disillusioned with the HOO.379

In another case, the U.S. government backed down on an important reform 

issue “to avoid a confrontation with the Afghan Government,” according to a 

U.S. Senate staff report.380 At the 2010 Kabul Conference, GIROA committed to 

pass an improved audit law as part of its efforts to strengthen public financial 

management. U.S. agencies wanted the law to legalize the Afghan Ministry of 

Finance’s (MOF) central role in conducting audits of the ministries. The law 

eventually passed by Parliament, however, centralized audit authority within 

a very weak institution, the Control and Audit Office; the law removed the 

critical audit function from the MOF at a time when more U.S. funds were 

planned to be provided directly to the Afghan government.381 The Treasury 

Department and many at Embassy Kabul believed the new law was insufficient. 

Nevertheless, the U.S. government took the official position of accepting the 

law, which was linked to the disbursement of $17 million in ARTF funds.382

Thus, the opportunity to send a strong message to GIROA by placing firm 

conditionality on funds was largely lost. Later, through direct negotiations with 

the Afghan government, U.S. officials succeeded in carving out a way for the 

MOF to continue to track funds.383

In line with concerns about GIROA’s fiscal sustainability, clamping down on 

corruption in the areas of Afghan customs and border protection was seen as 

crucial for increasing revenue.384 Yet a 2014 SIGAR audit found that USAID’s 

efforts to develop GIROA’s capacity to assess and collect customs revenue 

through streamlining and automating customs processes saw very limited 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 57

success, due in part to unwillingness by the Afghan Customs Department 

to accept sweeping reform of customs security and payment. Instead, these 

reforms were scaled down and implemented over several years, thereby limiting 

their impact.385 The audit concluded that without greater Afghan political 

commitment to anticorruption measures, customs revenue would remain highly 

vulnerable to corrupt actors.386

In support of judicial reform, the United States sought to raise prosecutors’ 

salaries in the Attorney General’s Office. At $70 to $100 per month, prosecutors’ 

wages were below the average police salary. Afghan officials in Kabul and 

the provinces cited low pay as creating strong incentives for prosecutors to 

demand or accept bribes and hindered the recruitment and retention of qualified 

prosecutors.387 For years, Attorney General Mohammad Ishaq Aloko stalled 

on implementing pay and grade reform that Karzai had mandated in order to 

set appropriate salaries and use merit-based, transparent hiring processes.388

High-level U.S. interventions by Ambassador Eikenberry and General Petraeus 

in 2011 helped prompt limited, but ultimately inadequate, progress.389 In early 

to mid-2011, the Afghan government drafted its National Priority Program

5, Law and Justice for All that included accelerated pay and grade reform at 

the AGO.390 Later that year, the reform was formally approved, but Aloko only 

superficially implemented it, maintaining a non-merit-based hiring system.391

In the fall of 2012, Embassy Kabul chose to concentrate on three areas where 

it judged U.S. anticorruption efforts could have maximum impact: Kabul Bank 

and the strengthening of financial supervision, borders and customs reform, 

and rule of law and building institutional capacity.392 The Deputy Ambassador 

convened weekly working groups to provide guidance on priorities, arrange 

high-level engagements as needed, and synchronize efforts with international 

partners politically, programmatically, and in terms of messaging.393 To date, this 

was the highest level at which the embassy regularly convened stakeholders 

on corruption issues. The Deputy Ambassador provided participants with clear 

direction on how to pursue objectives and held them accountable for doing 

so.394 According to a former participant, the working groups became a forcing 

function for action. However, military personnel were not included, damaging 

civilian-military coordination on corruption issues. In addition, the groups did 

not address U.S. contract oversight issues.395

Judicial Capacity and Law Enforcement Actions 

Despite the Kabul Bank and Salehi events, U.S. officials continued to press 

for investigation and prosecution of corruption cases.396 In addition to the 

prosecution of individuals responsible for fraud at Kabul Bank, one major 

case on which the United States pushed for action was that of Ghulam Qawis 

Abu Bakr, the Kapisa Provincial Governor.397 Abu Bakr had allegedly received 

a $200,000 bribe in exchange for a contract to build a cell tower.398 He was 

suspended as governor, reportedly after COMISAF General Petraeus presented 

Karzai with evidence of Abu Bakr’s collusion with the Taliban.399

Overall, Afghan officials resisted U.S. pressure. The AGO was notorious for 

not following through on corruption cases referred to it, including cases the 
SIGAR I CORRUPTION IN CONFLICT I 58 SEPTEMBER 2016

HOO director and deputy director claimed involved embezzlement, forgery, 

and bribes ranging from $1,000 to more than $100 million that implicated 

sitting ministers.400 In other cases, the lack of training, resources, security, 

and expertise undermined the effectiveness of judicial bodies. For example, 

anticorruption tribunals established in Kabul and the provinces to hear 

corruption cases ultimately proved ineffective due to these challenges.401

Training and mentoring of Afghan justice sector officials was a significant part 

of U.S. anticorruption efforts.402 DOJ’s Senior Federal Prosecutors Program 

began mentoring a counternarcotics task force and later trained and advised the 

AGO, ACU, MCTF, the Antiterrorism Prosecution Department (ATPD), and—to 

a lesser extent—other justice sector elements of the Afghan government from 

2005 to 2014, at a cost of nearly $23 million.403 The program aimed to reform 

Afghan criminal law and build the capacity of the ACU to effectively combat 

public corruption. A 2014 SIGAR audit on rule of law efforts in Afghanistan 

found DOJ officials noted anecdotally they had made some progress in building 

the capacity of the ACU, but “their efforts ... were eventually ignored due to 

the Afghan government’s lack of political will to allow corruption cases to be 

prosecuted.”404 DOJ officials also cited the Karzai administration’s interference 

in specific cases. Eventually, DOJ dramatically reduced its involvement with the 

ACU and continued only minor activities.405

The Supreme Court’s internal affairs unit, the Control and Monitoring 

Department (CMD), was not directly supported by the United States but 

was lauded for its effectiveness at times.406 The unit served as the primary 

oversight body for judges, court staff, and certain prosecutors. Embassy Kabul 

reported that, despite challenges, the CMD was successful and exhibited “good 

leadership and staff and a remarkable record in misconduct and corruption 

cases involving judges.”407 Between 2006 and 2011, the CMD oversaw 

185 arrests and 795 disciplinary actions of judges and court staff. Of the 

62 judges arrested, 50 were tried and convicted. Another 726 judges received 

administrative reprimands or censure.408 In 2012, the embassy reported 

the CMD was “still the most effective governmental body in rooting out 

corruption.”409 Yet, the CMD never received formal mentoring from the United 

States. A former Justice attaché in Kabul stated the CMD was successful 

because its honest, capable director focused on low- to mid-level officials 

rather than high-level cases that might draw political attention. The attaché 

also believed the CMD benefitted from the absence of international advisors 

interfering in its activities.410

An Afghan anticorruption expert said that later, the CMD became known for 

extorting money from judges and for its role in consolidating a corrupt network of 

judges. The new chief justice dismantled the unit in 2015.411

Financial Oversight 

Most U.S. efforts on financial oversight from 2010 to 2014 were diplomatic, 

not programmatic. Before the Kabul Bank scandal, USAID and Treasury had 

provided technical assistance to the Central Bank’s Financial Supervision 

Department.412 The Kabul Bank crisis revealed grave weaknesses in the FSD’s 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 59

ability to conduct robust oversight. Without strengthening that oversight, the 

risk of another banking crisis remained.413

However, no U.S. assistance to the Central Bank continued beyond mid-2011. In 

March 2011, President Karzai banned U.S. government advisors from working 

with the bank; Treasury and USAID ended their technical assistance programs 

there. Treasury officials told SIGAR they decided to discontinue technical 

assistance because of a hostile work environment for their advisors, incorrect 

Afghan government statements blaming U.S. advisors for the Kabul Bank crisis, 

and a belief that continued assistance would not be effective.414 Both agencies 

established conditions under which they would be willing to resume assistance, 

including the reform of Afghanistan’s banking and anti-money laundering/

countering the financing of terrorism (AML/CFT) laws, Afghanistan’s IMF ECF 

program being on track, no involvement of former Kabul Bank shareholders 

in the banking sector, clear communication from GIROA that advisors would 

be welcomed, and confidence that engagement would support a viable Central 

Bank and financial-sector strengthening plan.415

These conditions indicated the difficulties Treasury and USAID faced in working 

with the banking sector after the Kabul Bank scandal. To date, while USAID has 

not resumed such assistance, Treasury signed a memorandum of understanding 

with the Afghan Finance Minister in March 2015 to provide financial capacity 

building to GIROA and technical assistance to the Central Bank.416

Civil Society and the Media

U.S. support to civil society organizations and the media was a consistent 

component of the anticorruption strategies developed in 2009 and 2010 

and, in practice, took several forms from 2010 through 2014. This support 

aimed to help civil society (as well as the Afghan government) “educate and 

empower the public to expect and participate in transparent and accountable 

governance, to counter the culture of impunity,” according to a 2010 embassy 

cable.417 According to a former embassy official, U.S. support to civil society 

organizations (CSO) focused on helping CSOs develop their vision, providing 

advice on legal issues and organizational management, and providing funding.418

In media development, USAID programs funded independent Afghan media and 

provided training in journalism practices and investigative skills.419 In practice, 

the small number of Afghan CSOs dedicated to anticorruption-related work 

resulted in a limited number of programs.420

One significant U.S. contribution to a civil society program specific to 

anticorruption was a USAID grant to Integrity Watch Afghanistan. Starting in 

2007, IWA promoted social accountability by enabling local communities to 

monitor construction projects in their villages, with the aim of ensuring the 

projects were built to specifications and completed successfully.421 A scholar 

who studied this civic initiative applauded its value in helping to ensure 

recipients benefited from reconstruction efforts and empowering people to hold 

government officials, contractors, ISAF officials, and donors accountable.422

The scholar noted, however, that local monitors often had difficulty accessing 

information on projects, including the identity of prime contractors and 
SIGAR I CORRUPTION IN CONFLICT I 60 SEPTEMBER 2016

subcontractors, specifications, and materials used—and that greater 

transparency on projects could facilitate grassroots monitoring efforts.423

By repurposing funds from the 4A project that had been intended for the 

HOO, USAID undertook several other initiatives. Working with the Afghan 

Independent Bar Association, USAID helped to establish a walk-in legal clinic 

where victims of administrative corruption could obtain advice on how to 

seek redress. USAID also supported the Afghan Civil Society Coalition Against 

Corruption (AfCAC), a group of 60 organizations that worked to ensure 

transparency and strengthen government accountability and responsiveness.424

Former 4A funds also helped to establish the Parliamentary Anticorruption 

Caucus (PACC) of female parliamentarians who took on corruption-related 

legislation in both houses of the Afghan National Assembly, with notable 

success in the passage of an Access to Information law.425

Embassy Kabul’s Public Affairs Section and USAID funded investigative 

journalism, including that focused on corruption. One project supported Kabul 

Debate Live, which provided nationwide television broadcasts on issues such 

as the Kabul Bank crisis, the economy, and corruption. Another project sought 

to raise awareness of corruption through a national civic education and media 

campaign that disseminated anticorruption messages through television spots, 

radio dramas, cell phone videos, posters, leaflets, TV serials, workshops, radio 

spots, an anticorruption guide book, newspaper articles, and billboards.426

While it is difficult to measure the impact of U.S. support to civil society 

organizations and the media, it is reasonable to conclude that such efforts have 

helped to strengthen these important agents for change. An emerging Afghan 

civil society is increasingly focused on exposing and combating corruption. As 

Special Inspector General John Sopko told the Atlantic Council in March 2014, 

“Afghanistan has a growing number of organizations and individuals dedicated to 

exposing corruption and fostering the rule of law. It has a robust media that has 

highlighted and reflected Afghan dissatisfaction with corruption.”427 These civil 

society actors can help to build demand within Afghan society for action against 

corruption, as well as exert pressure on the government for reform. 

U.S. Agencies Working at Cross-Purposes

While U.S. and Afghan government objectives largely diverged when it came 

to fighting corruption, the U.S. government exhibited conflicting objectives 

internally, as well. In mid-2013, the New York Times reported the CIA had been 

delivering “bags of cash” to the Afghan government. For more than a decade, 

tens of millions of dollars were reportedly “packed into suitcases, backpacks 

and, on occasion, plastic shopping bags” and dropped off at the offices of 

President Karzai.428 Mr. Karzai described the money as “nothing unusual” and 

“an easy source of petty cash.”429 Referred to as “ghost money” by Karzai’s 

deputy chief of staff from 2002 to 2005, the cash was ostensibly to “guarantee 

the agency’s influence at the presidential palace.” However, despite the CIA’s 

purported objectives, the article noted that “much of the CIA’s money goes to 

paying off warlords and politicians, many of whom have ties to the drug trade 

and, in some cases, the Taliban.”430
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 61

The story elicited a sharp congressional response. Senator Bob Corker (R-TN), 

ranking member of the Senate Committee on Foreign Relations, wrote a letter 

to the White House requesting an explanation of the alleged policy. In his

letter, Corker wrote that the cash payments, if true, indicated an “incoherent” 

U.S. policy toward Afghanistan.431 In a follow-up letter to President Obama, 

after Karzai confirmed the payments, Corker emphasized that “these secret 

payments lack any kind of accountability, encourage the very kind of corruption 

we’re trying to prevent in Afghanistan, and further undermine U.S. taxpayers’ 

confidence in our government.”432

While some Afghan officials reportedly described these payments as “essential 

to [Karzai’s] ability to govern,” the money also bolstered the same patronage 

networks that U.S. officials had been struggling unsuccessfully to dismantle.433

Following the wave of criticism directed at the alleged payments, U.S. press 

reports indicated Karzai responded by noting he had been assured by the CIA’s 

station chief that the agency would continue making the payments, adding, 

“If tomorrow the State Department decides to give us such cash, I’d welcome 

that, too.”434

International Donor Engagement

The Monitoring and Evaluation Committee

The development of formal structures and mechanisms to monitor Afghan 

progress and hold GIROA to its anticorruption commitments was an important 

component of U.S. anticorruption efforts. The formation of the Independent 

Joint Anti-Corruption Monitoring and Evaluation Committee (MEC) was a 

particularly important innovation. When Karzai issued an executive decree 

inviting the international community to form the MEC in 2010, he was fulfilling 

commitments he had made at the 2010 London Conference.435

The MEC had six members: three international and three Afghan. The 

international members were required to be experienced anticorruption experts 

and were selected by an international nomination committee; the Afghans were 

local eminent persons selected by the President. The MEC’s mandate was to 

create anticorruption benchmarks for the Afghan government and international 

community, as well as to independently monitor and evaluate progress in 

meeting those goals through quarterly meetings in Kabul. The MEC published 

a semiannual progress report and quarterly recommendations for improving or 

refining anticorruption efforts.436

In mid-2012, Embassy Kabul reported the “prevailing view in the [international 

donor community] is that the MEC seems to be having an anticorruption 

effect, and may be the only game in town about which that can be said.”437

The MEC maintained a public focus on corruption issues, highlighted issues 

within the ministries, suggested solutions, and tracked progress. The MEC 

identified corruption within a particular sector and made recommendations 

as to how weaknesses could be addressed, and by whom. It then sent these 

recommendations to the respective Afghan ministries, set deadlines, and 

followed up.438
SIGAR I CORRUPTION IN CONFLICT I 62 SEPTEMBER 2016

By 2014, MEC successes included issuing the report of its public inquiry into 

the Kabul Bank crisis and maintaining public attention on implementation of 

its related recommendations.439 The MEC also brought attention to alleged 

corruption in the Law and Order Trust Fund for Afghanistan (LOTFA) and 

advanced the investigation into graft at the Dawood National Military Hospital.440

A further success was the MEC’s analysis of 38 of the 146 anticorruption 

provisions of Presidential Decree 45 on governance and corruption, including 

tracking substantive implementation actions by relevant GIROA departments.441

The MEC was a successful model for enhancing transparency and bringing 

pressure to bear on GIROA, while also providing technical benchmarks 

and reforms for both donors and the government. The MEC’s virtue was 

independence and technical expertise; however, this virtue became a liability in 

that it had no statutory authority to act and received uneven political support 

from the Afghan government. The MEC could make strong recommendations, 

but had no power to ensure their implementation. Following the formation of 

the National Unity Government in September 2014, however, President Ashraf 

Ghani and Chief Executive Abdullah Abdullah set a tone of greater support for 

the MEC’s work. According to the MEC’s March 2015 semiannual report, after a 

series of meetings with Ghani and Abdullah, MEC officials observed a “dramatic 

improvement” in the responsiveness of Afghan government offices to implement 

MEC recommendations.442

On-Budget versus Off-Budget Assistance

Donors and GIROA differed in their thinking about appropriate mechanisms 

of aid delivery. They often disagreed whether “on-budget” or “off-budget” 

assistance was more susceptible to corruption or other leakages. On-budget 

assistance is defined as development assistance (either from bilateral 

contributions or multilateral trust funds) that is channeled through the Afghan 

government’s core budget.443 Off-budget assistance is executed through 

contracts, grants, and cooperative agreements that remain outside the Afghan 

budget and beyond the reach of Afghan officials, theoretically providing more 

control to donors.444 Thus, when donors harbored concerns about corruption 

and weak capacity in the host government, they often favored off-budget aid 

mechanisms.445

As aid levels rose, Afghan leaders increasingly criticized off-budget assistance 

for encouraging parallel structures—entities outside government that competed 

for and managed development projects—which distorted resource allocation, 

led to redundancy, and siphoned talented Afghan employees away from the 

government.446 In addition, off-budget assistance denied GIROA the opportunity 

to exercise its budgetary and oversight processes and to “own” projects in 

terms of operations and maintenance. Off-budget assistance thus undermined 

capacity-building efforts and local ownership.447 Furthermore, as donors grew 

more aware of systemic corruption issues, they realized off-budget mechanisms 

could fuel corruption, too.448
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 63

London, Kabul, and Tokyo Conferences Loosely Tie Aid to 

Better Governance

At international conferences in London and Kabul in 2010 and Tokyo in 2012, 

donors committed to sustain high levels of funding in return for commitments 

by the Afghan government on governance and economic reform, to include 

fighting corruption.449 Donors pledged to align 80 percent of their funding with 

GIROA development priorities (as articulated in National Priority Programs), 

and to work toward directing 50 percent of their assistance on-budget. These 

funding commitments represented a soft form of conditionality, allowing donors 

flexibility in their assessments of GIROA’s progress toward its commitments.450

The 2012 Tokyo Conference produced a more detailed Tokyo Mutual 

Accountability Framework (TMAF) for tracking progress on mutual 

commitments. TMAF represented an evolution in incentivizing Afghan 

accountability by establishing more specific conditions for assistance. The 

framework laid out indicators for monitoring the Afghan government’s 

performance in five major areas of development and governance. Several of the 

indicators were anticorruption-related, including annual asset declarations of 

senior public officials, asset recovery and accountability related to the Kabul 

Bank crisis, strengthened banking supervision, and greater accountability and 

transparency in customs and tax systems.451

In a Senior Officials Meeting (SOM) in July 2013, the United States announced 

an “incentive fund” of $175 million in assistance over two years, of which 

$75 million was tied to progress in TMAF benchmarks.452 Of the $75 million, 

$15 million was later made available to the Afghan government due to progress 

in elections-related benchmarks, which was the priority area donors stressed 

at the SOM.453 Another $15 million was disbursed because GIROA developed 

a draft provincial budgeting policy. However, progress in the other three 

TMAF areas—governance, rule of law, and human rights; integrity of public 

finance and commercial banking; and inclusive and sustained growth and 

development—was deemed insufficient to disburse the remaining $45 million.454

Anticorruption-related benchmarks fell mainly within the first two of these 

three areas. Embassy Kabul judged that although the non-disbursed funds were

a small amount relative to total development assistance, “the government will 

acutely feel the loss.”455

Efforts to Improve Oversight of U.S. Assistance

During the 2010 to 2014 period, U.S. attempts to improve oversight of its own 

contracting and procurement practices gained momentum. The main goals were 

to prevent U.S. money from funding insurgent groups, stop U.S. practices from 

creating opportunities for corruption, and safeguard U.S. resources. 

DOD Initiatives

ISAF’s 2010 COIN Contracting Guidance called upon commanders to 

understand how contracting with corrupt powerbrokers could undermine 

the mission and to establish systems to vet contractors. It also directed 

commanders to follow best contracting practices, ensure transparency and 

accountability, and invest in oversight.456
SIGAR I CORRUPTION IN CONFLICT I 64 SEPTEMBER 2016

Operating under USFOR-A, Task Force 2010 exposed information on the 

prime and subcontractor levels of fraud, waste, and abuse, thus building a 

more sophisticated picture of the contracting environment. A DOD report on 

corruption in Afghanistan described the task force’s main activities: TF-2010 

supported vetting of contractors; provided intelligence and information needed 

to pursue UN sanctions on selected targets; informed decisions on actions such 

as suspension and debarment of selected contractors from U.S. bases, asset 

forfeiture, and counter-pilferage; and identified GIROA personnel for key leader 

engagements.457 One former task force official recalled that in a review of 3,000 

DOD contracts, TF-2010 “found that 18 percent of contract money went to the 

Taliban, [the Haqqani network], and other insurgent groups.”458

TF-2010 regularly reached out to dozens of organizations, including the ATFC, 

ISAF Joint Command (IJC), Shafafiyat, and law enforcement bodies, including 

“anyone with anything to do with contracts, intelligence, or law enforcement.”459

The task force also engaged with the UN Assistance Mission in Afghanistan 

(UNAMA) and NGOs with expertise on corruption, including Global Witness, 

IWA, and Transparency International.460

TF-2010 initially looked only at DOD contracts; however, as it saw the same 

actors repeatedly involved in international contracting, it started to work with 

other U.S. agencies. According to a former member of TF-2010, State and USAID 

headquarters in Washington had reservations about Embassy Kabul and USAID 

Kabul sharing contractor information with the task force, but on the ground 

in Kabul, there was quiet cooperation. The former task force member noted, 

and a second echoed, that “all the important vendors were working across 

different agencies. So State or USAID would ask us for information on a vendor. 

We helped them avoid some bad ones.”461 While important, this information 

sharing was not formalized, and seemed to rely on personal relationships. A 

former USAID vendor vetting official and a former director of the ATFC both 

stressed that the U.S. government should also share vendor information with 

its international partners.462

TF-2010 achieved some success in punishing corrupt contractors. 

A Congressional Research Service report found that as of October 2011, the 

task force had helped to recover more than 180,000 pieces of equipment worth 

over $170 million, and suspended or debarred more than 120 companies or 

individuals.463 On the other hand, the DOD report on corruption in Afghanistan 

found that TF-2010’s success in improving visibility at the prime contractor level 

was not mirrored at the subcontractor level.464

According to the former TF-2010 member, the unit found it difficult to hold 

contractors accountable, stating that DOD suspension and debarment 

officers preferred to find a settlement for cases, particularly when companies 

mounted well-financed defenses. One such case in early 2011 was Watan Risk 

Management, a firm owned by Rahullah Popalzai, one of the host nation trucking 

contractors excoriated in the Warlord, Inc. congressional staff report. Popalzai 

reportedly was able to pay lawyers tens of millions of dollars to fight potential 

suspension and debarment and to intimidate U.S. suspension and debarment 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 65

officials. The task force member noted, Watan “got nothing more than slaps on 

the wrist.”465

Task Force 2010 provided information to the Tampa-based CENTCOM Vendor 

Vetting Cell. The cell was formed in 2010 to vet vendors with existing contracts 

“to address immediate corruption and illicit funding concerns.”466 A 2011 

Government Accountability Office (GAO) report found that the backlog of 

unvetted vendors continued to grow due to inadequate vetting resources. GAO 

also noted weaknesses in the failure to routinely vet subcontractors.467 DOD 

informed SIGAR that in more recent years, the VVC has assessed vendors for 

the level of risk they pose to U.S. or coalition forces, and identified a higher 

percentage of vendors as high or extremely high risk—resulting in vendors 

being prevented from receiving U.S. funds and contracts.468 DOD reported that 

during FY 2015, the VVC “identified a total of 147 vendors before contract award 

as being High or Extremely High force protection risk, due to insurgent or 

criminal network activity or facilitation. The dollar figure of pre-award contracts 

prevented for these 147 vendors is $292 million.”469 While it is impossible 

to quantify precisely, some portion of this amount was likely connected to 

corrupt networks.

In the FY 2012 National Defense Authorization Act, Congress responded directly 

to the threat of DOD contracting funds going to insurgents or others who 

opposed U.S. and coalition forces. Section 841, Prohibition on Contracting 

with the Enemy in the United States Central Command Theater of Operations, 

permits DOD to authorize a head of a contracting activity (HCA) to restrict, 

terminate, or void a DOD contract, grant, or cooperative agreement with 

an entity or individual determined to be actively supporting an insurgency 

or otherwise opposing U.S. or coalition forces in the CENTCOM theater 

of operations.

470

To implement Section 841, TF-2010 assembled an information package on a 

suspect entity or individual and conducted preliminary intelligence and legal 

analyses. A series of ISAF coordinating bodies then reviewed the information 

package before submitting it to CENTCOM for approval. If CENTCOM granted 

approval, a Section 841 notification letter listing the entities and individuals 

was sent to the HCA with a request for the HCA to restrict, terminate, or void 

contracts with those listed. The HCA would then determine if there was a 

contract with the entity or individual and respond to CENTCOM with actions 

taken on the contract.471

While Section 841 enabled DOD to prevent a contract, grant, or cooperative 

agreement from going to any entity that supports the insurgency or opposes 

U.S. or coalition forces, there were weaknesses identified in the process. 

A SIGAR audit found that HCAs relied on prime contractors to “determine 

whether they have awarded subcontracts to persons or entities with Section 841 

designations” because HCAs did not have visibility over those subcontracts. At 

the same time, however, prime contractors were not required to certify their 

subcontractors were not Section 841 designees. This gap in oversight made it 

difficult for DOD to fully implement the authorities provided by Section 841.472
SIGAR I CORRUPTION IN CONFLICT I 66 SEPTEMBER 2016

TF-2010’s mission and activities evolved after 2012, as new leadership arrived, 

personnel rotations took place, and the unit moved to Qatar. The task force 

became more heavily focused on vetting contractors to ensure force protection 

on bases.473 According to two former members, institutional knowledge and 

relationships that previous staff had built across agencies and with international 

and civil society organizations largely disappeared.474

State and USAID Initiatives 

Embassy Kabul and USAID contracting guidance stressed “the importance 

of robust oversight in Mission procurement and contracting actions to help 

ensure U.S. government funds do not support malign actors such as insurgents, 

corrupt powerbrokers, and criminal patronage networks.”475 Embassy Kabul also 

proposed a U.S. government-wide Acquisition Accountability Office–Afghanistan 

(AAOA) to coordinate civilian and military agencies’ procurement actions. 

Prompted by a 2010 SIGAR audit that highlighted the challenge of monitoring 

spending across myriad U.S. agencies, the proposal sought to empower an 

AAOA to “collect and manage data from all U.S. contracting and development 

agencies,” including data on contractors and subcontractors, promote best 

practices, coordinate among all contracting and development agencies, and 

more.476 A State Department response to the embassy implied that the function 

was better performed in Washington, and the proposed office might impinge on 

statutory requirements.477 The proposed office was never established. 

In a more successful move toward improved oversight, USAID launched the 

Accountable Assistance for Afghanistan (A3) initiative in the fall of 2010, in 

response to a Senate report on U.S. assistance to Afghanistan. The A3 report 

“provided detailed research into how best to protect USAID development funds 

from being diverted from their intended use.” Based on this research, the report 

made 31 recommendations related to award mechanisms, vetting, financial 

controls, and project oversight.478

USAID took steps to implement these recommendations, including participating 

in working groups with Afghan, ISAF, and NATO partners on assistance 

accountability; establishing a Vetting Support Unit (VSU) in February 2011, 

which by July was vetting “all new contracts, grants, cooperative agreements 

and their sub-awards with a value of $150,000 or more ... as well as [all] 

private security company contracts;” and sharing vetting results with DOD and 

others.479 USAID reported to SIGAR that from 2011 through mid-2016, USAID’s 

Kabul mission had vetted 7,139 requests, of which 334 were cancelled and 300 

deemed ineligible. 

“Where significant government corruption exists, the 

key is for the international community to present itself 

as standing with the interests of the people.”

—Katherine Dixon
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 67

These cancelled or forestalled contracts amounted to approximately $668 million 

in U.S. funds.480

VSU efforts were initially intended to ensure U.S. funds did not support corrupt 

powerbrokers, among other malign actors.481 However, according to one former 

USAID vendor vetting official, the unit stopped vetting for corruption after its 

first year of operation.482 In a June 2011 report, GAO determined that the VSU 

might face limitations similar to those seen by CENTCOM’s vetting unit. GAO 

urged that State, DOD, and USAID all share their respective vetting information 

through a formal mechanism to ensure the practice endured.483 While State, 

DOD, and USAID set up an informal mechanism to share vendor information, 

State never stood up its own formal vetting unit.

Summary: A Lack of Political Commitment 

and Misperceptions of Leverage 

The Salehi arrest and Kabul Bank crisis forced the U.S. government to choose 

between maintaining a hard line against corruption or retreating in the face of 

the realization that fighting corruption would either require even more political 

capital than anticipated, or be largely futile in the absence of Afghan political 

will. The U.S. government chose to do the latter, judging that there was a greater 

chance of progress on other priorities if it avoided direct attacks on corrupt 

power structures. Agencies turned their attention to more technical approaches 

to the problem. U.S. officials appeared to calculate that focusing on corruption 

within Karzai’s government could alienate the president and jeopardize the SPA, 

BSA, and reconciliation. 

But targeting only low- to mid-level corruption was not sufficient. The tone was 

set by how the international donor community addressed corruption at the top, 

which was critical to building trust with Afghan society. As Katherine Dixon of 

Transparency International noted, “Where significant government corruption 

exists, the key is for the international community to present itself as standing 

with the interests of the people.”484

The perception of limited U.S. leverage over Afghan leaders manifested itself in 

various ways. U.S. officials supported new IMF benchmarks that were softer 

than those initially sought; negotiations on the BSA took precedence over 

U.S. concerns about corruption; DOJ essentially ended its mentoring and 

training of Afghan law enforcement entities; and Treasury and USAID withdrew 

their technical advisors from the Central Bank. Although anticorruption 

The U.S. government underestimated the leverage 

it had over the Afghan government and politically 

connected individuals. While the lack of Afghan 

cooperation on anticorruption stymied many U.S. 

efforts, the United States could have more aggressively 

brought pressure to bear by conditioning security and 

development assistance on tangible progress.
SIGAR I CORRUPTION IN CONFLICT I 68 SEPTEMBER 2016

remained on the embassy’s agenda, U.S. activities and goals in this area reflected 

low expectations of progress. Certainly, much of the blame for such little 

progress against corruption rests squarely with Afghan leaders who failed to 

meet benchmarks for reform or hold the most corrupt actors accountable.485

At the same time, however, the U.S. government underestimated the leverage 

it had over the Afghan government and politically connected individuals.486

While the lack of Afghan cooperation on anticorruption stymied many 

U.S. efforts, the United States could have more aggressively brought pressure to 

bear by conditioning security and development assistance on tangible progress. 

U.S. agencies might have developed a cohesive strategy for increasing the costs 

for Afghan political leaders to support a corrupt system, including pursuing 

revocation of visas against corrupt Afghan officials and their families; pursuing 

more robust U.S. law enforcement actions against corrupt Afghans with dual 

U.S. citizenship; and making seizures in the United States of the proceeds of 

Afghan corruption. 

The U.S. failure to fully employ these tools suggests U.S. officials believed that 

using them carried too high a risk of jeopardizing more direct security and 

counterterrorism objectives, such as ensuring a continued international troop 

presence and maintaining control of battlefield detainees. These judgment calls 

reflected the primary U.S. policy objective in Afghanistan: to disrupt, dismantle, 

and defeat al-Qaeda and its safe havens in Pakistan, and to prevent their return 

to Pakistan or Afghanistan. The problem was that corruption continued to pose 

a security threat in its own right and threatened U.S. security and stability goals. 

If the United States had devoted more resources to studying and understanding 

the issue of corruption, it might have recognized the threat of systemic 

corruption to its core security goals before corrupt networks became 

entrenched and much harder to tackle. It was not until 2010 that U.S. agencies 

initiated systematic efforts to map corruption in, for example, Shafafiyat and to 

vet contractors through TF-2010 and vendor vetting units. Although these efforts 

prevented some U.S. contracts from going to malign actors, they proved too 

little, too late to dismantle corrupt networks. 

It is impossible to know how employing all available tools might have 

compromised U.S. goals for the SPA, BSA, the security transition process, 

and reconciliation. What we do know, however, is that the Taliban insurgency 

remains a serious threat to security and stability in Afghanistan.487 During the 

2014 presidential elections, Ashraf Ghani told the Guardian that “the Afghan 

public is sick and tired of corruption; we are not going to revive the economy 

without tackling corruption root, stock, and branch.”488 Perception surveys 

continue to show corruption as a major source of frustration for the Afghan 

population.489 The World Bank’s Worldwide Governance Indicators show slight 

improvement in Afghanistan’s “control of corruption” as of 2014, but the country 

remains in the bottom six percent of all countries ranked.490 While demonstrating 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 69

“The Afghan public is sick and tired of corruption; we 

are not going to revive the economy without tackling 

corruption root, stock, and branch.”

—President Ashraf Ghani

a desire to tackle corruption and achieving some successes, the National Unity 

Government has struggled to make headway against entrenched, corrupt 

networks. And, the United States is maintaining a sizeable troop presence in 

Afghanistan, in contrast to earlier plans for a near-complete withdrawal.

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 71

CONCLUSIONS

Our study of the U.S. experience with corruption in Afghanistan finds:

1. Corruption undermined the U.S. mission in Afghanistan by fueling 

grievances against the Afghan government and channeling material 

support to the insurgency.

2. The United States contributed to the growth of corruption by injecting 

tens of billions of dollars into the Afghan economy, using flawed oversight 

and contracting practices, and partnering with malign powerbrokers.

3. The U.S. government was slow to recognize the magnitude of the problem, 

the role of corrupt patronage networks, the ways in which corruption 

threatened core U.S. goals, and that certain U.S. policies and practices 

exacerbated the problem. 

4. Even when the United States acknowledged corruption as a strategic 

threat, security and political goals consistently trumped strong 

anticorruption actions.

5. Where the United States sought to combat corruption, its efforts 

saw only limited success in the absence of sustained Afghan and 

U.S. political commitment. 

U.S. Army National Guard photo
SIGAR I CORRUPTION IN CONFLICT I 72 SEPTEMBER 2016

These findings underscore that the U.S. government should have viewed 

anticorruption as an essential part of its security, political, and development 

goals from the start of the contingency operation. As Ambassador Crocker noted 

in an interview for this report, “The corruption lens has got to be in place at 

the outset, and even before the outset, in the formulation of reconstruction and 

development strategy, because once it gets to the level I saw ... it’s somewhere 

between unbelievably hard and outright impossible to fix.”491 Yet, policymakers 

tended to perceive tradeoffs between fighting corruption and making progress on 

other important goals. As a result, security and political goals repeatedly trumped 

strong anticorruption actions. Corruption grew so pervasive and entrenched that 

it came to pose a threat to the entire security and state-building mission. 

Our observations also highlight that the U.S. government played a role in the 

growth of corruption. The United States should have assessed aid saturation 

levels and practiced better oversight of contracting and procurement. 

The United States and its international partners wielded great influence in the 

choices they made about whom to partner with, do business with, and support. 

Yet the U.S. government supported or tolerated malign powerbrokers who shared 

a narrow set of U.S. interests and who simultaneously undermined broader, 

long-term goals. Furthermore, the U.S. diplomatic, military, intelligence, and 

development communities were not always aligned in their objectives vis-à-vis

these actors.

The U.S. response to endemic corruption also failed to address the fundamentally 

political nature of the problem. U.S. anticorruption efforts were not unified by 

a cohesive strategy to reduce the incentives for political leaders to support a 

corrupt system, without which, institutional reform could not be sustained.

In Afghanistan today, corruption remains an enormous challenge to security, 

political stability, and development. The findings of this report are relevant for not 

only ongoing U.S. efforts in Afghanistan, but also those of our allies and the GhaniAbdullah administration. In his address to a joint meeting of the U.S. Congress in 

March 2015, President Ghani spoke candidly: “Nearly forty years of conflict [have] 

produced a country where corruption permeates our government. Until we root 

out this cancer, our government will never generate the trust to win the hearts 

of our people or the trust of your taxpayers.”492

“The corruption lens has got to be in place at the 

outset, and even before the outset, in the formulation 

of reconstruction and development strategy, because 

once it gets to the level I saw ... it’s somewhere between 

unbelievably hard and outright impossible to fix.”

—Ambassador Ryan Crocker
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 73

Since its creation in September 2014, the National Unity Government has pursued 

several anticorruption initiatives. One of Ghani’s first official actions as president 

was to direct Afghan government officials to immediately reopen the Kabul Bank 

case, recover stolen funds, hold accountable those involved in the theft, and 

move ahead with privatizing the successor New Kabul Bank.493 Another move 

against corruption related to a $1 billion Afghan Ministry of Defense (MOD) 

fuel contract. In early 2015, SIGAR briefed President Ghani on its investigation 

into contractor collusion, price fixing, and bribery in the award of the contract. 

Ghani immediately cancelled the contract and suspended those MOD officials 

purportedly involved in the corruption. Ghani established the National 

Procurement Commission, which he chairs, to review large contracts and provide 

high-level oversight.494

The Ghani-Abdullah administration has also sought to reinvigorate the Major 

Crimes Task Force. In May 2016, Ghani announced both the establishment of a 

specialized anticorruption court and plans to strengthen the MCTF to support 

anticorruption investigations. The Anti-Corruption Justice Center will bring 

together MCTF investigators, AGO prosecutors, and judges to combat serious 

corruption. The center aims to have its first case before the October 2016 

conference in Brussels co-hosted by the European Union and the Government 

of Afghanistan. Ghani also issued a decree to create the Higher Council on 

Governance, Justice, and the Fight Against Corruption. The council will oversee 

the drafting and implementation of a national anticorruption strategy.495

These are promising steps. Nevertheless, preventing and fighting corruption in 

Afghanistan are generational goals. Progress will likely continue to be uneven 

and incremental. For instance, despite the efforts of President Ghani and Chief 

Executive Abdullah, there has been no significant progress in Kabul Bank asset 

recoveries; efforts to counter corruption within the army and police have suffered 

from political conflict between Ghani and Abdullah; the Anti-Corruption Unit 

of the AGO faces obstacles prosecuting high-level corruption; and, according to 

DOD, the MCTF’s effectiveness will continue to be limited by external factors, 

such as AGO corruption and political pressure.496

The fact that corruption remains such a great challenge to the Afghan state 

and to the goals of its international supporters highlights Ambassador Crocker’s 

urgent call for “the corruption lens” to inform reconstruction planning 

from the very beginning.”497 This is one of the core lessons that flows from 

the U.S. experience with corruption in Afghanistan, and underlies all the lessons 

and recommendations of this report.

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 75

LESSONS 

Based on the foregoing narrative and findings, this section distills lessons 

learned from the U.S. experience with corruption in Afghanistan. These 

lessons should inform reconstruction efforts at the onset of and throughout 

contingency operations.

Lesson 1. The U.S. government should make anticorruption efforts a top 

priority in contingency operations to prevent systemic corruption from 

undermining U.S. strategic goals. 

Corruption significantly undermined the U.S. mission in Afghanistan by damaging 

the legitimacy of the Afghan government, strengthening popular support for the 

insurgency, and channeling material resources to insurgent groups. Surveys and 

anecdotal evidence indicate that corrupt officials at all levels of government 

victimized and alienated the Afghan population. Substantial U.S. funds found their 

way to insurgent groups, some portion of which was due to corruption. 

Corruption also undermined faith in the international reconstruction effort. The 

Afghan public witnessed limited oversight of lucrative reconstruction projects by 

the military and aid community, leading to bribery, fraud, extortion, and nepotism, 

as well as the empowerment of abusive warlords and their militias. Public trust 

USAID/Afghanistan photo
SIGAR I CORRUPTION IN CONFLICT I 76 SEPTEMBER 2016

in the U.S.-led intervention eroded, as international aid agencies, contractors, and 

ISAF were seen as complicit in the corrupt behavior of the Afghan government.

The U.S. government did not sufficiently appreciate early on these potentially 

devastating consequences of corruption and did not mount an effective strategy to 

mitigate against corruption. Short tours and frequent turnovers of U.S. civilian and 

military officials, coupled with the lack of specialized anticorruption expertise, 

led to poor institutional knowledge of the complex risks of corruption and 

inconsistent attempts to address it. 

By the time U.S. agencies invested resources in understanding the nexus of 

corrupt officials, criminals, drug traffickers, and insurgents, and sought to prevent 

U.S. funds from reaching them, these networks were deeply entrenched and 

extremely difficult to dismantle. 

Lesson 2. U.S. agencies should develop a shared understanding of the 

nature and scope of corruption in a host country through political 

economy and network analyses.

In Afghanistan, the United States was slow to acknowledge the systemic and 

entrenched nature of corruption, which in turn delayed its awareness of how 

corruption threatened core U.S. goals. The Afghan Threat Finance Cell (ATFC), 

put in place in late 2008, was arguably the first organization to understand the 

nexus of corruption, criminality, narcotics, and the insurgency by tracking money 

flows and using network analysis. The unit relied on DOD, Justice, and Treasury 

personnel and expertise, and communicated its findings across agencies in Kabul 

and Washington. As a result of the ATFC’s and others’ work, by 2009 U.S. officials 

were increasingly concerned about the corruption threat and the need for 

strong anticorruption efforts. Executive branch agencies established several 

organizations, conducted studies, and pursued programs to address different 

aspects of corruption. 

A critical first step to understanding the corruption threat was for U.S. agencies 

to jointly conduct high-level, thorough political economy analyses of criminal 

patronage networks and their associated money flows. Such analyses laid the 

groundwork for a common understanding of the problem and identified potential 

allies and obstacles.

Lesson 3. The U.S. government should take into account the amount of 

assistance a host country can absorb, and agencies should improve their 

ability to effectively monitor this assistance. 

Tens of billions of dollars injected into the Afghan economy, combined with the 

limited spending capacity of the Afghan government, increased opportunities for 

corruption. This was exacerbated by poor oversight and contracting practices 

by donors and the pressure to spend budgets quickly. For most of the 2002–2014 

period, appropriated U.S. reconstruction assistance to Afghanistan surpassed 

45 percent of Afghanistan’s GDP, reaching a high of 105 percent in 2010 and 

never falling below 22 percent (see figure 4, p. 51).498 According to a 2009 OECD 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 77

report, international assistance accounted for roughly half of Afghanistan’s lawful 

economy.499 The Afghan government could not manage such inflows given staffing 

and skills constraints, lack of experience in mid- to senior-level management, and 

inadequate regulatory and internal controls.

The amounts also exceeded the oversight capacity of the U.S. military and 

civilian agencies due to insecurity and lack of mobility, staffing shortages, lack 

of contract management expertise, and numerous layers of subcontractors who 

were beyond the reach of contract monitors. U.S. officials often could not ensure 

a project was completed sufficiently or at all. These weaknesses opened the door 

to widespread corruption.

Not until 2010 was a more systematic effort made to address how the 

U.S. government itself contributed to corruption in Afghanistan. For example, 

U.S. departments and agencies, particularly DOD, established procedures for 

vetting contractors. DOD, State, and USAID issued contracting guidelines specific 

to counterinsurgency environments. These efforts succeeded in preventing some 

U.S. funds from benefitting corrupt and criminal actors. Nevertheless, by 2010, 

corruption was so pervasive and entrenched that vetting activities did little to 

resolve the overall problem. 

Lesson 4. The U.S. government should limit alliances with malign 

powerbrokers and aim to balance any short-term gains from such 

relationships against the risk that empowering these actors will lead to 

systemic corruption.

Early on, the United States allied with Afghan warlords—many of whom had 

committed war crimes and grave human rights abuses against fellow 

Afghans—to seek their help in eliminating al-Qaeda and remnants of the Taliban. 

Many warlords were brought into government, where they continued their abuses, 

maintained private militias, and had links to narcotics, smuggling, and criminal 

networks. With a weak central government and no fear of law enforcement, 

the warlords gained impunity. Over time, their criminal patronage networks 

became more entrenched. The warlords did not “self-correct” upon entering 

government; rather, they sought to maximize private gains within a system 

lacking accountability.

U.S. agencies, particularly those in the military and intelligence communities, 

relied on these warlords for different reasons, including historical relationships, 

intelligence, information, political needs in Kabul or the provinces, and as 

security force multipliers or force protectors. Their association with the United 

States empowered them and provided access to lucrative contracts related to 

the reconstruction effort and military presence. U.S. partnerships with such 

individuals gave the Afghan population the impression the United States tolerated 

corruption and other abuses, seriously undercutting U.S. credibility. 
SIGAR I CORRUPTION IN CONFLICT I 78 SEPTEMBER 2016

Lesson 5. U.S. strategies and plans should incorporate anticorruption 

objectives into security and stability goals, rather than viewing 

anticorruption as imposing tradeoffs on those goals. 

While recognizing the short timelines imposed by U.S. domestic political realities, 

policymakers must acknowledge the likelihood of an extended engagement 

and therefore place greater priority on long-term governance objectives. In 

Afghanistan, the United States repeatedly allowed short-term counterterrorism 

and political stability priorities to trump strong anticorruption actions. 

Policymakers tended to believe that confronting the corruption problem—for 

instance, by taking a hard stand against corrupt acts by high-level 

officials—would impose unaffordable costs on the U.S. ability to achieve security 

and political goals. 

But in the long term, this was a false choice. In fact, corruption grew so 

pervasive that it ultimately threatened the security and reconstruction mission 

in Afghanistan. In 2009, U.S. officials became increasingly concerned about 

corruption and began to mount a more energetic response. That response, 

however, ran up against deeply entrenched, corrupt networks, and an Afghan 

government resistant to meaningful reform—as illustrated by the Salehi arrest 

and release, and the Kabul Bank crisis. Both events demonstrated the vast scale 

of corruption and the complete lack of Afghan political commitment to address it. 

The U.S. reaction was to soften its own political commitment to fighting 

corruption. U.S. officials spoke out strongly against corruption and consistently 

pressed the Afghan government for reforms, but applied the greatest diplomatic 

leverage to achieving security or stability priorities like concluding a bilateral 

security agreement and managing the security transition, rather than imposing 

stiff sanctions against corrupt actors. Moreover, interviews and press reports 

revealed that not all U.S. agencies shared the same objectives with regard to 

fighting corruption, specifically alleging the CIA maintained relationships with 

some corrupt individuals as assets, while other agencies sought to investigate 

and prosecute those same individuals. This lack of coherence in the overall 

U.S. approach to corruption undermined U.S. efforts to fight it. 

Lesson 6. The U.S. government should recognize that solutions to endemic 

corruption are fundamentally political. Therefore, the United States 

should bring to bear high-level, consistent political will when pressing the 

host government for reforms and ensuring U.S. policies and practices do 

not exacerbate corruption. 

Fighting systemic corruption requires inherently political solutions. The 

U.S. government must be prepared to invest political capital in encouraging a host 

government to carry out critical corruption-related reforms. It must also have the 

political will to provide resources for necessary oversight of U.S. assistance, and 

to hold back such assistance when it proves ineffective. 

Senior officials interviewed for this report, as well as many government, 

academic, and think-tank entities, argue that the U.S. response to corruption 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 79

in Afghanistan failed to address the fundamentally political nature of the 

problem, concentrating its efforts on overly technical approaches. For example, 

U.S. agencies succeeded in building the capacity of some Afghan police, 

investigators, prosecutors, judges, and auditors to counter corruption, but these 

newly trained officials often could not put their skills to good use due to political 

interference. U.S. capacity-building efforts were not embedded within a long-term 

strategy for reducing the incentives for Afghan political leaders to engage in or 

support a corrupt system. 

Although the U.S. Embassy in Kabul drafted a coherent anticorruption strategy 

that called for strong U.S. political commitment, it was never approved. Former 

senior officials said the draft strategy guided their efforts for many months, but in 

the longer term, it appeared to have little effect. 

SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 81

RECOMMENDATIONS

These recommendations suggest actions that can be undertaken by Congress 

or executive branch agencies to institutionalize the lessons learned from the 

U.S. experience in Afghanistan. At the same time, however, the recommendations 

cannot substitute for the tough political choices required when U.S. government 

officials are confronted with endemic corruption. 

When assessed in hindsight, the numerous pressures facing policymakers in 

Afghanistan may have led to short-sighted choices and hard-won lessons. The 

recommendations below aim to provide better policies, organizations, analytical 

tools, information, and staffs to future policymakers faced with the difficult 

decisions inherent in reconstruction efforts in contingency operations. 

Legislative Recommendations

1. Congress should consider enacting legislation that makes clear 

that anticorruption is a national security priority in a contingency 

operation and requires an interagency anticorruption strategy, 

benchmarks, and annual reporting on implementation. 

Aga Khan Foundation photo
SIGAR I CORRUPTION IN CONFLICT I 82 SEPTEMBER 2016

This legislation should: 

• Require federal agencies (i.e., DOD, State, USAID, and others) to 

develop an interagency anticorruption strategy for a contingency 

operation and provide it to Congress.

• Require the Executive Branch to establish and enforce clear, 

measurable anticorruption benchmarks as a regular condition for 

the disbursement of reconstruction assistance. 

• Mandate annual reporting to Congress on the implementation and 

effectiveness of the anticorruption strategy and on the need for 

any adjustments.

2. Congress should consider enacting legislation that authorizes 

sanctions against foreign government officials or their associates 

who engage in corruption. This legislation should:

• Authorize the President to impose U.S. entry and property 

sanctions against any foreign government official or senior 

individual associated with the official who is responsible for, or 

complicit in, corrupt activities.

• Require annual reporting by the President to Congress on each 

foreign person sanctioned, the type of sanctions imposed, the 

reason for their imposition, and a description of any facts that 

warrant suspension of sanctions.

3. Congress should consider requiring DOD, State, USAID, and other 

relevant executive agencies to establish a joint vendor vetting 

unit or other collaborative effort at the onset of any contingency 

operation to better vet contractors and subcontractors in the field.

Such legislation should: 

• Authorize a head of contracting activity (HCA) or the Chief 

of Mission to restrict, terminate, or void a contract, grant, or 

cooperative agreement with an entity or individual determined 

to be engaged in corrupt activities that threaten U.S. national 

security interests.

• Require that intelligence analyses of corrupt patronage networks 

inform decisions to exclude individuals and entities from eligibility 

for the award of contracts.

• Provide personnel with adequate access to the classified systems 

and other databases used to vet contractors and subcontractors.

• Ensure units are staffed sufficiently and have appropriate 

procedures to avoid bottlenecks in contract 

management processes.

• Recommend that vetting units also coordinate closely with 

U.S. allies operating in the host country to share information on 

contractors and subcontractors, and to exclude individuals or 

businesses that may pose a threat. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 83

Executive Branch Recommendations 

4. The NSC should establish an interagency task force to formulate 

policy and lead strategy on anticorruption in contingency 

operations. The task force should encourage NSC principals to 

factor in the threat of corruption when deciding on and planning 

such missions. It should include representatives from DOD, State, USAID, 

Treasury, Justice, DHS, and the Intelligence Community, who together will 

establish anticorruption policy and corruption-related assessment tools 

and coordinate implementation across agencies. The task force should be 

led by a senior official appointed by the President, reporting directly to 

the National Security Advisor. The task force should have a corresponding 

presence in theater and a budget to meet its staffing and other resource 

needs. The task force should also engage with outside, independent 

experts. The task force should:

• Establish a policy and implementation framework for addressing 

the impact of corruption on U.S. national security objectives in 

conflict zones.

• Create a standard assessment tool to be used by agencies in 

the initial phases of contingency operation planning to evaluate 

drivers of corruption, the potential for corrupt powerbrokers to 

capture state functions, the role foreign assistance might play in 

exacerbating corruption, and the risks to mission goals. 

• Establish an interagency framework for assessing spending 

levels, including covert activities, and preventing U.S. aid and 

procurement dollars from overwhelming a national economy and 

creating conditions conducive to corruption. 

• Determine requirements for oversight and control mechanisms 

that must be in place from the outset to ensure accountability for 

U.S. expenditures.

• Identify diplomatic and other types of leverage to exert influence 

on or hold accountable corrupt host nationals, including U.S. entry 

and property sanctions and anti-money-laundering tools.

• Recommend budget reforms that would allow more flexible 

budgeting in contingency environments to reduce “use or lose” 

pressures to spend money quickly. These reforms may include 

greater use of multi-year appropriations, more flexible contracting 

mechanisms, and increased use of multilateral trust funds. 

• Coordinate and de-conflict intelligence operations with other 

agencies’ goals and activities in country.

• Set priorities for U.S. political and programmatic interventions to 

advance institutional accountability in such sectors as banking 

and security.

5. At the onset of any contingency operation, the Intelligence 

Community should analyze links between host government 

officials, corruption, criminality, trafficking, and terrorism. This 

baseline assessment should be updated regularly.
SIGAR I CORRUPTION IN CONFLICT I 84 SEPTEMBER 2016

Intelligence agencies should:

• Conduct detailed analyses of underlying social, economic, and 

political factors that facilitate or drive corruption within the 

host nation.

• Analyze familial, ethnic, and political associations of elites, their 

economic interests, their licit and illicit financial networks, and 

their geographic spheres of influence.

• Provide this analysis to designated senior officials in the 

NSC, DOD, USAID, State, Treasury, Justice, and DHS who are 

responsible for policy, strategy, and planning.

• Provide this analysis to officials within Treasury’s Office of 

Foreign Assets Control (OFAC), in connection with the Specially 

Designated Nationals list.

• Identify U.S. points of leverage that could most effectively prevent 

or counter corrupt behavior. 

6. DOD, State, USAID, and the Intelligence Community should each 

designate a senior anticorruption official to assist with strategic, 

operational, and tactical planning at headquarters at the onset of 

and throughout a contingency operation. For DOD, the individual 

should be a flag or general officer; for the civilian agencies, a senior 

executive, or political appointee. These individuals should have prior 

specialized training and expertise in anticorruption. When planning is 

completed and as a contingency operation gets under way, they should be 

under a long-term commitment to serve in the field. Senior anticorruption 

officers should have responsibility to: 

• Ensure the development and implementation of an integrated 

interagency anticorruption strategy throughout the duration of the 

contingency operation.

• Conduct regular joint contingency operation corruption 

risk assessments.

• Provide expert opinion to the NSC and agencies on U.S. actions 

against local high-level corrupt actors, including analysis of likely 

success or failure.

• Identify points of leverage which agencies might use to address 

corruption, and assist in the execution.

• Coordinate with allies and multilateral institutions to work toward 

maximum unity of effort in policy, programs, and messaging 

on corruption. 

• Conduct regular outreach to and share information with key civil 

society organizations who work on human rights, civil rights, 

anticorruption, and related issues. 

7. DOD, State, and USAID should each establish an Office 

for Anticorruption to provide support, including advice on 

anticorruption methods, programming, and best practices, for 

personnel in contingency operations. Each office should:
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 85

• Develop and share information on and assessments of the forms of 

host country corruption that pose the most immediate, costly, and 

mission-critical threats.

• Collect and consolidate best practices and research in the field of 

anticorruption, including diplomatic, legal, and assistance tools. 

• Provide operational and programmatic guidance to field staff. 

• Coordinate anticorruption policies, programs, and practices with 

relevant interagency counterparts.

• Identify, track, and provide analysis on initiatives in fragile 

states—and in neighboring countries—that have been successful 

in addressing corrupt practices, such as aid conditionality, civil 

society strengthening, and transparency initiatives.

• Identify appropriate metrics to assess the risks to 

U.S. programs from corruption and the success or failure of 

U.S. anticorruption efforts.

8. The President should consider amending Executive Order 13581, 

which authorizes the listing of transnational criminal organizations 

on Treasury’s Office of Foreign Assets Control (OFAC) Specially 

Designated Nationals list, to include individuals and entities who 

have engaged in corruption and transferred the proceeds abroad. 

The revised authority should: 

• Amend Section 3(e) of Executive Order 13581 to expand the 

definition of a “significant transnational criminal organization” 

to include individuals and entities which are engaged in corrupt 

practices in conflict zones or during contingency operations.

• Align with and draw upon the Justice Department’s ongoing 

Kleptocracy Asset Recovery Initiative, to include setting conditions 

for implementation of the executive order. 

9. In international engagements related to contingency operations, 

the U.S. government should bring high-level political commitment 

to bear against corruption to ensure anticorruption is a priority 

from the outset for the host government and international and 

regional partners. In this respect, the U.S. government should:

• Emphasize the importance and priority the U.S. government 

attaches to the fight against corruption and the vulnerabilities to 

corruption observed in such environments.

• Set expectations in initial agreements with the host government 

regarding its anticorruption commitments and strategy.

• Collaborate with the host government to establish milestones or 

key indicators of progress.

• Work with international partners to establish anticorruption as 

a continuing priority and encourage partners to support the host 

government in carrying out its anticorruption commitments.

• Work with regional partners who have demonstrated success in 

fighting corruption in similar operating environments, to bring such 

partners’ experiences and best practices to bear.
SIGAR I CORRUPTION IN CONFLICT I 86 SEPTEMBER 2016

10. The State Department should place a high priority on reporting 

on corruption and how it threatens core U.S. interests, consistent 

with new anticorruption initiatives by the department and 

recommendations in the 2015 Quadrennial Diplomacy and 

Development Review (QDDR). Such reporting should:

• Present detailed analyses of underlying social, economic, and 

political factors that facilitate or drive corruption within the 

host nation.

• Describe the links between host government officials and 

corruption, criminality, trafficking, and terrorism. 

• Assess points of leverage that could most effectively prevent or 

counter corrupt behavior. 

• Include information derived from contact with civil society and 

the media.

• Be distributed widely among other relevant U.S. agencies.

11. DOD, State, USAID, Treasury, Justice, and the Intelligence 

Community should increase anticorruption expertise to enable 

more effective strategies, practices, and programs in contingency 

operations. Agencies should:

• Promote awareness of the impact of corruption among mid- and 

high-ranking officials by providing more extensive and specific 

training. At a minimum, this training should occur in professional 

education for senior officers, such as DOD’s Capstone and Pinnacle 

leadership courses, and training for ambassadors, deputy chiefs 

of mission, and senior intelligence professionals. Similar training 

for mid-level military officers, senior enlisted personnel, and midcareer civilians should also be considered. 

• Develop and introduce at the national war colleges a separate 

course on corruption, its implications for U.S. foreign policy and 

national security, and effective anticorruption efforts. 

• Offer a similar course on corruption and anticorruption at 

State’s Foreign Service Institute during key professional 

development milestones. 

• Include anticorruption instruction in pre-deployment training for 

military and civilian personnel en route to conflict zones.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 87

APPENDIX A

METHODOLOGY

SIGAR conducts its lessons learned program under the authority of Public Law 

110-181 and the Inspector General Act of 1978, as amended, and in accordance 

with the Council of the Inspectors General on Integrity and Efficiency’s Quality 

Standards for Federal Offices of Inspector General (commonly referred to as “the 

Silver Book”). These standards require that we carry out our work with integrity, 

objectivity, and independence, and provide information that is factually accurate 

and reliable. SIGAR’s lessons learned reports are broad in scope and based on 

a wide range of source material. To achieve the goal of high quality and to help 

ensure our reports are factually accurate and reliable, SIGAR’s lessons learned 

reports are subject to extensive review by subject matter experts and relevant 

U.S. agencies. 

The Corruption in Conflict research team consulted a wide array of sources, 

including publicly available material, interviews, and government agency 

documents. We also drew from SIGAR’s own work, embodied in quarterly reports 

to Congress, investigations, audits, inspections, and special project reports. 

Much of the research team’s documentary research focused on publicly available 

material, including reports by DOD, State, USAID, GAO, Congressional Research 

Service, congressional committees, and congressionally chartered commissions. 

The team also consulted declassified, archival material from a website maintained 

by former Secretary of Defense Donald Rumsfeld. These official sources were 

complemented by hundreds of nongovernmental sources, including books, think 

tank reports, journal articles, press reports, academic studies, international 

conference agreements, reports on perceptions surveys and other field research, 

and analytical reports by international and advocacy organizations. 

The research team also benefitted from SIGAR’s access to material that 

is not publicly available, including thousands of documents provided by 

U.S. government agencies. The Department of State provided unclassified and 

classified cables, internal memos and briefings, opinion analysis reports, and 

planning and programmatic documents. DOD provided documents and answered 

questions regarding anticorruption-related organizations the department 

created or participated in. USAID provided internal planning and programmatic 

documents, and answered questions regarding USAID anticorruption activities in 

Afghanistan. Researchers also reviewed hundreds of documents obtained from 

the U.S. Army Center of Military History. A body of classified material, including 

U.S. embassy cables and intelligence reports, provided helpful context. As an 

unclassified document, however, this report makes no use of such material. In one 

case, however, at SIGAR’s request, the State Department declassified a cable from 
88 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

the U.S. Embassy in Kabul, which was particularly important to SIGAR’s analysis; 

that cable is cited in the report. 

While the documentary evidence tells its own story, it cannot substitute for 

the experience, knowledge, and wisdom of people who participated in the 

Afghanistan reconstruction effort. The research team interviewed more than 

80 individuals with direct and indirect knowledge of facts on the ground that 

affected U.S. engagement on corruption. Individuals interviewed included 

U.S., Afghan, and other international experts from academia, think tanks, NGOs, 

and government entities, as well as current and former U.S. civilian and military 

officials at the National Security Council, intelligence agencies, USAID, and 

the Departments of Defense, State, Treasury, and Justice. The team also drew 

from dozens of interviews conducted by other SIGAR researchers and auditors. 

Further, Transparency International’s Defence and Security Programme graciously 

shared transcripts of selected interviews completed for its report, Corruption: 

Lessons from the International Mission in Afghanistan. 

Interviews provided invaluable insight on the thinking and assumptions behind 

decisions, debates within and between agencies, and frustrations that spanned 

years, but often remained unwritten. Due, in part, to the politically sensitive 

nature of the topic of corruption, a majority of the interviewees wished to 

remain anonymous. For those still working in government, confidentiality was 

particularly important. Therefore, to preserve anonymity, our interview citations 

often cite a “senior U.S. official” or “senior State Department official.” We 

conducted most interviews in person in the Washington, DC area or by telephone; 

however, we also interviewed individuals during research trips to Kabul, Boston, 

New York City, Brussels, Bergen, London, Oslo, and Copenhagen. We performed 

our documentary research in SIGAR’s offices in Arlington, Virginia.

Corruption in Conflict reflects careful, thorough consideration of the wide 

range of sources; however, it is not an exhaustive treatment of the topic. Given 

the timeframe and scale of U.S. engagement in Afghanistan, the ambiguity in 

perceptions about corruption, and the paucity of empirical data on levels of 

corruption, the report does not aim to fully address how thousands of U.S. civilian 

and military officials dealt with corruption on a daily basis since 2001. Rather, the 

report focuses on certain key events and provides context on the manifestation 

of corruption in Afghanistan, relevant U.S. policies and initiatives, and competing 

U.S. priorities. From these, we derive lessons and recommendations to inform 

current and future contingency operations.

The report underwent an extensive process of peer and agency review. First, 

we sought feedback on a draft of the full report from seven subject matter 

experts; four additional subject matter experts reviewed the draft lessons and 

recommendations. The experts included Americans, Afghans, and Europeans, 

all of whom had substantial experience working on or in Afghanistan. These 

reviewers provided significant, detailed comments on the report, which we 

incorporated, as possible. The draft was then shared with another group of 

subject matter experts, including current and former U.S. government officials 

who shared their personal perspectives. Seven members of this group convened to 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 89

discuss the report with the research team. Both rounds of review helped sharpen 

and improve the report’s analysis and conclusions. 

Finally, the Departments of Defense, Justice, State, and Treasury, and USAID were 

given an opportunity to review and comment on the report. The research team 

received helpful and substantive comments from Defense, Justice, State, and 

Treasury. In addition, we met with State Department representatives to receive 

their feedback on the report firsthand. After revising the report in response to 

agencies’ concerns and insights, we shared a near-final draft with the agencies for 

a second round of review. Although we incorporated agencies’ comments where 

appropriate, the analysis, conclusions, and recommendations of this report remain 

SIGAR’s own.

The report focuses mainly on the 2001 to 2014 time period. When we began 

our research in early 2015, the National Unity Government had existed for less 

than six months. Analysis of the period following the Karzai administration was 

constrained by limited documentary evidence and the difficulty of determining 

trends or drawing useful conclusions from a relatively short time span. However, 

SIGAR and external subject matter experts consulted by SIGAR believe 

corruption is no less an obstacle to reconstruction and stability today than it was 

in 2014. 
90 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

APPENDIX B

4A Assistance to Afghanistan's Anticorruption Authority

A3 Accountable Assistance for Afghanistan

AAOA Acquisition Accountability Office-Afghanistan

ACP Anticorruption Program

ACT Anticorruption Tribunal

ACTF ISAF Anticorruption Task Force

ACU Anticorruption Unit

ADB Asian Development Bank

AfCAC Afghan Civil Society Coalition Against Corruption

AGO Attorney General's Office

AIBA Afghan Independent Bar Association

AIHRC Afghan Independent Human Rights Commission

AMDEP Afghanistan Media Development and Empowerment Project

AML/CFT Anti-Money Laundering/Countering the Financing of Terrorism

ANA Afghan National Army

ANDS Afghanistan National Development Strategy

ANP Afghan National Police

ANQAR Afghanistan Nationwide Quarterly Assessment Research

ANSF Afghan National Security Forces

AREU Afghanistan Research and Evaluation Unit

ARTF Afghanistan Reconstruction Trust Fund

ASOP Afghanistan Social Outreach Program

ATFC Afghan Threat Finance Cell

BSA Bilateral Security Agreement

CAO Control and Audit Office

CD/ROLLE Coordinating Director for Rule of Law and Law Enforcement Office

CENTCOM U.S. Central Command

CIA Central Intelligence Agency

CID Criminal Investigations Division

CJIATF Combined Joint Interagency Task Force

CJTF Criminal Justice Task Force

CMD Control and Monitoring Department

CN Counternarcotics

CNJC Counternarcotics Justice Center

CNP Counternarcotics Police

CSO Civil Society Organizations

ABBREVIATIONS
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 91

CSTC-A Combined Security Transition Command-Afghanistan

CWC Commission on Wartime Contracting in Iraq and Afghanistan

DAB Da Afghanistan Bank (Central Bank)

DAG Deputy Attorney General

DC Deputies Committee, National Security Council

DDR Demobilization, Disarmament, and Reintegration

DEA Drug Enforcement Administration

DFID UK Department for International Development

DHS Department of Homeland Security

DOD Department of Defense

DOJ Department of Justice

ECF Extended Credit Facility

EITI Extractive Industries Transparency Initiative

EU European Union

FATF Financial Action Task Force

FBI Federal Bureau of Investigation

FinTRACA Financial Transactions and Reports Analysis Center of Afghanistan

FSD Financial Supervision Department

GDP Gross Domestic Product

GIAAC General Independent Administration for Anticorruption

GIROA Government of the Islamic Republic of Afghanistan

HCA Head of a Contracting Agency

HOO High Office of Oversight and Anticorruption

ICCTF International Contract Corruption Task Force

ICE Immigration and Customs Enforcement

ICTAWG International Community Transparency and Accountability Working Group

IJC ISAF Joint Command

IMF International Monetary Fund

INL Bureau of International Narcotics and Law Enforcement

IROL Interagency Rule of Law Office

ISAF International Security Assistance Force

IWA Integrity Watch Afghanistan

JMK Jan Mohammad Khan

JSU Judicial Security Unit

LOTFA Law and Order Trust Fund for Afghanistan

MCTF Major Crimes Task Force

MEC Independent Joint Anti-Corruption Monitoring and Evaluation Committee 

MOF Ministry of Finance

MOI Ministry of Interior

NATO North Atlantic Treaty Organization

NDS National Directorate for Security

NGO Nongovernmental Organization

NSC National Security Council
92 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

ODA Official Development Assistance

OECD Organization for Economic Cooperation and Development

OEF Operation Enduring Freedom

OSD-P Office of the Under Secretary of Defense for Policy

OTI Office of Transition Initiatives

PACC Parliamentary Anticorruption Caucus

PRT Provincial Reconstruction Team

PSC Private Security Companies

QDDR Quadrennial Diplomacy and Development Review

RC Regional Command

SFPP Senior Federal Prosecutors Program

SIGAR Special Inspector General for Afghanistan Reconstruction

SIU Sensitive Investigations Unit

SOM Senior Officials Meeting

SPA Strategic Partnership Agreement

SRAP Special Representative for Afghanistan and Pakistan

TAF The Asia Foundation

TF Task Force

TMAF Tokyo Mutual Accountability Framework

UN United Nations

UNAMA UN Assistance Mission in Afghanistan

UNCAC UN Convention Against Corruption

UNDP UN Development Programme

UNODC UN Office of Drugs and Crime

USAID U.S. Agency for International Development

USFOR-A U.S. Forces-Afghanistan

VSU Vetting Support Unit

VVC Vendor Vetting Cell
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 93

Survey Data on Corruption

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

The Asia Foundation

% of respondents who experienced 

corruption when interacting with the 

customs office

39.8% 34.2% 36.4% 38.0% 42.0% 52.6% 48.6% 56.8% 47.4% 61.6%

% of respondents who experienced 

corruption when interacting with the 

Afghan National Police

53.0% 42.9% 39.9% 46.8% 49.0% 53.8% 48.5% 52.2% 45.1% 53.5%

% of respondents who experienced 

corruption when interacting with the 

judiciary

55.4% 47.8% 49.1% 51.7% 51.9% 62.5% 59.9% 62.0% 54.8% 63.7%

% of respondents who describe 

corruption as a major problem in their 

daily lives

42.1% 47.1% 50.7% 52.8% 54.8% 56.3% 56.1% 54.4% 62.4% 61.1%

% of respondents who describe 

corruption as a major problem in 

Afghanistan as a whole

77.3% 74.2% 75.8% 76.0% 75.8% 75.6% 78.8% 76.1% 75.7% 76.5%

% of respondents who describe 

corruption as one of the top two 

problems facing Afghanistan as a whole

18.7% 16.2% 13.6% 16.9% 27.3% 21.2% 24.5% 27.3% 28.4% 24.3%

ANQAR

% of respondents who feel the 

Government does very poorly or a little 

poorly at reducing corruption in the 

Government

- - 60.3% 64.2% 59.1% 61.8% 56.2% 53.9% - -

% of respondents who strongly or 

somewhat agree that corruption is a 

serious problem in the government

- - 88.4% 85.5% 88.4% 90.0% 84.9% 83.4% - -

% of respondents who say there is 

corruption in the state court system

- - 82.6% 84.6% - 85.5% - - - -

% of respondents who say that corruption 

affects their daily lives

- - - 78.4% 82.1% 87.8% 78.3% 79.1% - -

% of respondents who say that corruption 

in the Central Government is greater than 

one year ago

- - - - 30.6% 38.2% 38.5% - - -

Rank of corruption in list of reasons why 

Afghans choose to support the Taliban 

instead of the Government of Afghanistan

- - - - 2nd 1st 2nd - - -

Integrity Watch

Average value of bribe U.S. $ (GDP per 

capita [p/c]) 

- - - - 192 

(570) 

= 34% 

GDP 

p/c

- 191 

(691) 

= 28% 

GDP 

p/c

- 240 

(634) 

= 38% 

GDP 

p/c

-

Biggest concern for Afghans—Corruption 

(1st, 2nd, 3rd)

- - - - 3rd - 3rd - 2nd -

Source: SIGAR analysis of data from the Asia Foundation (TAF), “A Survey of the Afghan People,” Explore Data Tool, 2006–2015; 

Integrity Watch Afghanistan (IWA), “National Corruption Survey 2010,” 2010, p. 10; IWA, “National Corruption Survey 2014,” 2014, 

pp. 3, 61 (GDP per capita numbers were taken from the World Bank, http://data.worldbank.org/indicator/NY.GDP.PCAP.CD); COMISAF, 

Afghanistan Nationwide Quarterly Assessment Research (ANQAR), quarterly surveys. Data used was from September of each year.

APPENDIX C
94 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

APPENDIX D

Strategies and Plans: 2009–2010

Strategy 

or Plan

Agency/

Body Objectives Anticorruption Elements

Date 

Drafted

Assessment 

of 

Corruption in 

Afghanistan500

USAID501 Contained a recommended “Strategy 

for USAID Anticorruption Assistance,” 

which discussed standing up the HOO; 

agendas for prevention, education, and 

enforcement; USAID “Do No Harm” 

precepts; USAID and U.S. government 

management; and GIROA-donor 

coordination.502

Strategy focused on targeted programming, 

improved conditionality, strengthened Afghan 

leadership, and an engaged citizenry.503

March 

2009504

Anticorruption 

Action Plan for 

Afghanistan505

SRAP506 To “improve transparency, reduce 

corruption and the perception thereof, 

in order to increase Afghans’ confidence 

in their government; demonstrate visible 

gains to advance COIN efforts in the 

short-term.”507

Proposed implementation included strengthening 

accountability in police and judicial bodies, 

U.S. advocacy for prosecution of corrupt figures, 

support for civil service reform, determining 

how donor funds contribute to corruption, and 

developing guidelines for field commanders to 

address corruption.508

May 

2009509

Access 

to Justice 

Strategy510

Embassy 

Kabul511

To increase support for the justice sector 

at all levels (law enforcement, law reform, 

capacity-building of the justice sector 

institutions and personnel, and the 

legislative process). One of four impact 

areas was to improve anticorruption 

efforts, including support of anticorruption 

institutions and task forces.512

Included supporting the development of 

anticorruption investigation and prosecution 

capability, efforts to identify and combat illicit 

finance, work on drafting effective legislation, 

and capacity-building of Afghan rule of law 

institutions.513

June 

2009514

Integrated CivMil Campaign 

Plan515

USFOR-A, 

Embassy 

Kabul516

To provide overall guidance for U.S. civilian 

and military “efforts and resources.”517

Stated that U.S. personnel should identify and 

target those key people engaging in corrupt 

behavior and providing material support to the 

insurgency, use U.S. leverage to change corrupt 

behavior, expand accountable and transparent 

governance, and reduce corruption within 

ANSF.518

August 

2009519

U.S. 

Government 

Rule of Law 

Strategy for 

Afghanistan520

SRAP521 To focus U.S. rule of law assistance on 

programs that would offer Afghans access 

to fair and transparent justice and help 

eliminate Taliban justice and defeat the 

insurgency; to help increase the Afghan 

government’s legitimacy and improve 

perceptions among Afghans by promoting 

a culture that valued the rule of law.522

Recommended capacity-building in the formal 

justice sector, U.S. pressure on GIROA to take 

steps against high-level political interference, 

improved vetting procedures for senior 

appointments, support for a judicial security 

force to protect prosecutors and judges, and 

increased pay for prosecutors and judges. SIGAR 

found that by 2012, the strategy no longer 

reflected the operating environment and was 

outdated.523

September 

2009524

U.S. 

Government 

Anticorruption 

Strategy for 

Afghanistan 

(draft)525

Embassy 

Kabul526

(2010 version) To strengthen Afghan 

institutions to provide checks on 

government power, positively influence the 

behavior of corrupt officials, and tackle 

visible corruption so the Afghan people 

could see that change was occurring. 

Focused on improving transparency and 

accountability of Afghan institutions, 

increasing financial oversight, building 

judicial capacity, encouraging public 

demand for better governance, and 

increasing support for civic education, civil 

society, and the media.527

Intended to focus diplomatic, legal, and 

development assistance tools to increase the 

political will of GIROA, U.S., and international 

community to fight corruption; increase support 

to GIROA for implementing its anticorruption 

strategy and reform of the HOO; and reform 

U.S. and ISAF contracting procedures. 

Never received approval from Washington. 

Informally adopted by embassy as guidance for 

anticorruption efforts.528

October 

2009, 

revised 

in April 

2010529
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 95

APPENDIX E

U.S. and ISAF Organizations with Anticorruption Objectives

Organization Lead Agency Mandate Highlights

Start and End 

Dates

ISAF Anticorruption 

Task Force (ACTF)530

DOD, ISAF531 To target corrupt actors532 A working group of people from 

existing organizations at ISAF 

and Embassy that had equities 

in anticorruption. ACTF was 

formalized into a Deputy Chief 

of Staff command (Shafafiyat) 

directly under COMISAF.533

September 

2009 to 

September 

2010534

Afghan Threat Finance 

Cell (ATFC)535

DEA lead, with Treasury and 

DOD co-deputies536

To identify and disrupt 

financial networks related 

to terrorism, the Taliban, 

narcotics trafficking and 

corruption, and to provide 

threat finance expertise and 

actionable intelligence to the 

Chief of Mission, USFOR-A 

Commander, and ISAF537

Illuminated the complexity and 

extent of corrupt networks in 

Afghanistan by identifying malign 

actors and the nexus among 

corrupt government officials, 

drug traffickers, and criminal 

and insurgent groups. The cell 

worked with Afghan units on 

several major corruption-related 

cases.538

November 

2008 to 

2014539

Combined Joint 

Interagency Task 

Force–Nexus (CJIATFNexus)540

USFOR-A, ISAF541 To provide actionable 

information on networks 

that threatened the stability 

of GIROA, with focus on 

narcotics production and 

corruption542

Enabled military and law 

enforcement operations that 

focused on interdicting and 

disrupting networks.543

2009 to 

unknown544

International Contract 

Corruption Task Force 

(ICCTF)545

FBI. By 2009, added 

representation from DOD 

IG/DCIS, State, State OIG, 

SIGIR, USAID, Army CID, Air 

Force OSI, SIGAR, and NCIS. 

By 2010, included Afghan 

participation from MOI, MOJ, 

and NDS546

To identify contract corruption 

involving U.S. or Afghan 

interests and develop 

criminal cases that may be 

prosecuted in the U.S. or 

Afghan judicial venues547

Enabled agencies to take a more 

coordinated approach to contract 

corruption.548

2006 to 

present549

Task Force 2010550 USFOR-A551 To understand the impact 

of contracting and the flow 

of contracting money at the 

sub-contractor level, to help 

combat corruption552

“Influenced U.S. contractingrelated actions through 

vendor vetting and targeted 

effects against nefarious 

entities operating in 

Afghanistan.”553Reviewed 

transportation, logistics, and 

security contracts.554 Included 

experts in forensic auditing, 

criminal investigation, and 

contracting.555

July 2010 to 

present556

Task Force Spotlight557 USFOR-A558 To enforce private security 

contractor (PSC) compliance 

with requirements; help 

improve the regulation of 

PSCs; and evaluate policy, 

help develop more effective 

contracting procedures, and 

assist Afghan MOI efforts to 

regulate PSCs559

Provided increased coordination 

and oversight of U.S. and 

ISAF contracting processes 

and sought to ensure that 

international resources did not 

inadvertently strengthen criminal 

networks or insurgent groups.560

June 2010 

until the end of 

2011, when it 

was subsumed 

by CJIATFShafafiyat561
96 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

Organization Lead Agency Mandate Highlights

Start and 

End Dates

CENTCOM Vendor 

Vetting Cell (VVC)562

DOD563 To vet contract awards to nonU.S. vendors in Afghanistan 

and Iraq, with the aim of 

minimizing the risk “that 

insurgents or criminal groups 

could use U.S. contracting 

funds to finance their 

operations”564

Initially vetted vendors with 

existing contracts.565 GAO found 

a growing backlog of unvetted 

vendors, and weaknesses in the 

failure to vet subcontractors.566

The VVC later expanded its 

capacity to vet, and identified a 

greater percentage of vendors 

as high risk, resulting in vendors 

being prevented from receiving 

U.S. funds and contracts.567

August 2010 

to present568

USAID Vetting Support 

Unit (VSU)569

USAID570 To vet prospective nonU.S. contract and assistance 

recipients (i.e., implementing 

partners) in Afghanistan 

with the aim of countering 

“potential risks of U.S. 

funds being diverted to 

support criminal or insurgent 

activity”571

Initially intended to ensure 

U.S. funds did not support 

corrupt powerbrokers, among 

other bad actors.572 A former 

USAID vetting official said 

the unit stopped vetting for 

corruption after its first year.573

A 2011 USAID mission order 

established a vetting threshold 

of $150,000.574

January 2011 

to present575

Combined Joint 

Interagency Task 

Force–Shafafiyat 

(Shafafiyat)576

DOD, ISAF577 To promote a common 

understanding of the 

corruption problem, plan and 

implement anticorruption 

efforts, and integrate 

USFOR-A anticorruption 

activities with those of key 

partners578

Worked with Afghans and key 

leaders to develop a common 

understanding of the problem 

as a basis for joint action. 

Assessed that sustained 

engagement generates the 

political will necessary to 

address the threats of corruption 

and organized crime.579

September 

2010 to 

October 

2014580

Combined Joint 

Interagency Task 

Force–Afghanistan 

(CJIATF-A)581

DOD, ISAF582 To synchronize and focus 

strategic counter-corruption, 

counternarcotics, counterthreat finance, and “No 

Contracting with the Enemy” 

activities in order to deny 

resources to malign actors 

and enhance transparency 

and accountability within 

GIROA583

Created as an umbrella 

organization. According to 

DOD, by 2014, “personnel 

turnover and bad organizational 

changes (moving Shafafiyat from 

CJIATF-A to CSTC-A/NTM-A) at 

CJIATF-A made it an irrelevant 

organization.” Under Resolute 

Support, CJIATF-A dissolved and 

Shafafiyat became Essential 

Function 2 (Transparency, 

Accountability and Oversight).584

October 2012 

to October 

2014585

Rule of Law and 

Law Enforcement 

Directorate (ROL/LE)586

State (embassy offices) INL, 

DOJ, FBI, DEA, DHS, U.S. 

Marshals Service, and Rule 

of Law and Anticorruption 

elements of USAID; working 

with USFOR-A and ISAF587

To improve coordination 

and substantially enhance 

U.S. effectiveness in 

supporting the Afghan 

government’s provision of 

fair, transparent, and efficient 

justice588

Led all U.S. civilian and military 

rule of law programs, including 

anticorruption.589 ROL/LE 

was also meant to improve 

civilian-military coordination of 

justice sector assistance.590 A 

reorganization in 2011 created 

the Interagency Rule of Law 

Office (IROL), which was then 

merged in 2013 under another 

office.591

2010 to 

2013592
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 97

Organization Lead Agency Mandate Highlights

Start and 

End Dates

Rule of Law Deputies 

Committee593

Embassy Kabul, USFOR-A, and 

ISAF (plus INL, USAID, DOJ, 

FBI, DEA, the U.S. Marshals 

Service, DHS, CSTC-A, IJC, and 

CJIATF-435)594

To ensure unity of effort 

among all agencies working 

to improve Afghan adherence 

to the rule of law and Afghan 

law enforcement capacity595

Served as a decision- and 

policy-making body for rule 

of law issues, including 

counternarcotics, anticorruption, 

and law enforcement. In 

addition to U.S. participants, the 

committee included non-voting 

representatives from other 

embassies and the UN.596

Summer 2010 

to unknown597

International 

Community 

Transparency and 

Accountability Working 

Group (ICTAWG)598

UNAMA and U.S. 

representatives cochaired, but included all 

international actors involved in 

anticorruption599

To share information on 

anticorruption regarding 

political engagement with 

GIROA and messaging. Not a 

decision-making body600

Improved information sharing 

among donors.601

2010 to 

present602
98 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

APPENDIX F

U.S. Support to Afghan Government Organizations with an Anticorruption Role

Organization Mandate

U.S. Agency 

Leading 

Support Support Provided Analysis/Notes

Dates of 

Support

High Office of 

Oversight and 

Anticorruption 

(HOO)603

To lead GIROA’s 

anticorruption efforts, 

including overseeing 

and coordinating the 

implementation of GIROA’s 

national strategy to fight 

corruption604

USAID605 Helped GIROA draft a new 

law to strengthen the HOO’s 

independence and oversight 

authority. Also launched a 

capacity-building project.606

Struggled to overcome 

administrative hurdles 

and gain political support. 

Embassy Kabul withheld 

most of planned funding.607

2010 to 

2013608

Control and 

Audit Office 

(CAO)609

To conduct audits over 

all state entities within 

central and provincial 

governments, and over 

donor funds received by 

Afghan treasury610

USAID611 Covered costs of conference 

and training attendance.612

The CAO’s legislative 

framework was considered 

weak and did not provide 

sufficient independence or 

authority for it to serve as 

an effective anticorruption 

institution.613

November 

2007 to 

January 

2010614

Major Crimes 

Task Force 

(MCTF)615

To conduct criminal 

investigations of 

corruption, organized 

crime, and kidnapping; 

a vetted unit. 

Provided cases to the 

Anticorruption Unit616

FBI, DEA, 

State INL, DOJ, 

DOD (with the 

UK’s Serious 

Organized 

Crime Agency 

[SOCA])617

FBI and DEA special agents 

trained and mentored MCTF 

staff. DOJ helped GIROA 

complete an enabling law for 

the MCTF.618 FBI constructed a 

facility to house the unit.619

Developed notable 

investigative capacity, but 

its success was constrained 

by the failure of the judicial 

system to prosecute cases, 

as well as lack of Afghan 

political support.620

2009 to 

present621

Anticorruption 

Unit (ACU), 

Attorney 

General’s Office 

(AGO)622

To develop and prosecute 

cases against individuals 

suspected of violating 

anticorruption statutes; a 

vetted unit623

State INL, 

USAID, DOJ624

Provided mentoring, training, 

and support to prosecutors 

and judges.625

Success in building the 

ACU’s capacity, but due 

to lack of political will by 

GIROA to empower the 

unit and prosecute highlevel corruption cases, the 

ACU ultimately had limited 

effect.626

August 

2009 to 

unknown627

Anticorruption 

Tribunal (ACT)628

To handle significant 

corruption cases from 

Kabul and provinces629

Embassy ROL 

Office, DOJ, 

State, USAID630

Supported judges and 

provided mentoring and 

support to judges.631

In 2011, judges “lacked 

uniform sentencing 

standards, received little 

training, used rudimentary 

case management systems, 

lacked effective security, 

and work[ed] in inadequate 

facilities.”632

November 

2010 to 

unknown633

Sensitive 

Investigations 

Unit (SIU)634

To carry out counternarcotics investigations 

using intelligence 

developed by a unit within 

the counter-narcotics 

police; a specially vetted 

unit635

DEA636 Trained and equipped, 

including enabling access to a 

legal wiretapping capability.637

The SIU often identified 

corrupt officials as a result 

of its high-level narcotics 

investigations and routinely 

partnered with other 

organizations, including the 

ATFC.638

2007 to 

unknown639

Criminal 

Investigations 

Division (CID) of 

the Ministry of 

Interior640

To lead investigations of 

national interest, including 

cases with international 

links, and organized and 

white-collar crime641

DHS/

Immigration 

and Customs 

Enforcement 

(ICE)642

Trained investigators.643 The CID investigators 

uncovered a major case 

of human smuggling and 

bribery involving a senior 

government official.644

December 

2010 to 

unknown645
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 99

Organization Mandate

U.S. Agency 

Leading 

Support Support Provided Analysis/Notes

Dates of 

Support

Afghan Judicial 

Security Unit 

(JSU)646

To provide security for 

the Supreme Court, ACU, 

Counter-Narcotics Court, 

and at-risk judges and 

prosecutors647

U.S. Marshals 

Service648

Trained JSU officers.649 As of 2011, the JSU 

operated in Kabul and 

planned to extend coverage 

to the Supreme Court and 

other major cities.650

2010 to 

unknown651

Financial 

Supervision 

Department 

(FSD), 

Afghanistan 

Central Bank 

(DAB)652

To ensure the health of 

the banking sector and 

regulate commercial 

banks and other financial 

institutions653

Treasury, 

USAID654

Provided technical advisors.655 The Kabul Bank crisis 

revealed weaknesses in the 

FSD’s ability to regulate the 

banking sector and enforce 

its supervision function. 

Karzai then banned U.S. 

advisors from working with 

the DAB.656

2003 

(USAID) 

and 2006 

(Treasury) 

to 2011657

Financial 

Transactions 

and Reports 

Analysis Center 

(FinTRACA), 

Afghanistan 

Central Bank 

(DAB)658

To identify suspicious 

financial transactions and 

alert law enforcement; 

served as DAB’s financial 

intelligence unit659

Treasury, DHS/

ICE, DEA660

Assisted FinTRACA in 

strengthening Afghan 

information and evidencegathering capacity to identify 

and target illicit finance 

networks.661

DHS/ICE and other 

international law 

enforcement agencies 

gave the unit high marks 

in 2010. However, a 2011 

IMF report found major 

shortcomings remained in its 

functioning.662

2009 to 

present663

Joint 

Independent 

Anticorruption 

Monitoring 

and Evaluation 

Committee 

(MEC, an 

international 

body with 

GIROAappointed 

Afghan 

membership)664

To develop anticorruption 

recommendations and 

independently monitor, 

evaluate, and report on 

anticorruption efforts 

by GIROA and the 

international community665

State, USAID666 Provided technical assistance 

(wrote the MEC’s terms 

of reference) and political 

support, along with other 

donors, UNAMA, and 

GIROA.667

Considered a model for 

enhancing transparency and 

bringing pressure to bear on 

GIROA668

March 

2010 to 

present669
100 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

ENDNOTES

1 Ryan Crocker, SIGAR interview, January 11, 2016.

2 This definition appears in the USAID Anticorruption Strategy: A Mandatory Reference for ADS 

Chapter 200, January 2005, p. 8, and closely parallels other international organizations’ definitions. 

See also Transparency International, “What Is Corruption,” http://www.transparency.org/whatis-corruption/ (accessed August 2, 2016); World Bank, Helping Countries Combat Corruption: 

The Role of the World Bank, September 1997; Norwegian Agency for Development Cooperation, 

Anticorruption Approaches: A Literature Review, January 2009, p. 40.

3 USAID, USAID Anticorruption Strategy, p. 8.

4 Ibid.

5 Norwegian Agency for Development Cooperation, Anticorruption Approaches, p. 41; DFID, Why 

Corruption Matters: Understanding Causes, Effects and How to Address Them, January 2015, pp. 

12-13. “Petty” is sometimes used interchangeably with “administrative” or “bureaucratic” corruption, 

as “political” is sometimes used synonymously with “grand” corruption.

6 USAID, USAID Anticorruption Strategy, p. 8.

7 Norwegian Agency for Development Cooperation, Anticorruption Approaches, p. 41; Transparency 

International, “FAQs on Corruption: How Do You Define Corruption?” http://www.transparency.org/

whoweare/organisation/faqs_on_corruption (accessed August 2, 2016). 

8 USAID, Assessment of Corruption in Afghanistan, prepared under contract with Checchi and 

Company Consulting, Inc. and the Louis Berger Group, Inc., March 1, 2009, p. 4; ADB, DFID, UNDP, 

UNODC, and the World Bank, Fighting Corruption in Afghanistan: A Roadmap for Strategy and 

Action, February 16, 2007, pp. 7-8, 18; Karen Hussman, Working towards common donor responses 

to corruption: Joint donor responses vis-à-vis corruption in Afghanistan: Myth or reality?, 

OECD, October 18, 2009, p. 3; World Bank, The Investment Climate in Afghanistan: Exploiting 

Opportunities in an Uncertain Environment, December 30, 2005, pp. vii-viii, 21; IWA, Afghans’ 

Experience of Corruption, 2007, pp. 9-10; U.S. Embassy Kabul, “NSA Spanta Stresses That the 

Corruption ‘Elephant’ Needs To Be Tackled Together,” Kabul 5184 cable, October 2, 2010.

9 U.S. Embassy Kabul, “NSA Spanta,” Kabul 5184 cable, October 2, 2010.

10 Sarah Chayes, Thieves of State: Why Corruption Threatens Global Security (New York, NY: W. 

W. Norton, 2015), pp. 58-62, 112; Katherine Dixon, Director of Defence and Security Programme, 

Transparency International, and former UK government official, email to SIGAR, March 7, 2016.

11 USAID, Assessment of Corruption in Afghanistan, p. 8; see also IWA, Afghans’ Experience of 

Corruption, p. 10; Tim Sullivan and Carl Forsberg, Confronting the Threat of Corruption and 

Organized Crime in Afghanistan: Implications for Future Armed Conflict, PRISM, vol. 4, no. 4, p. 

160; Paul Fishstein and Andrew Wilder, Winning Hearts and Minds? Examining the Relationships 

Between Aid and Security in Afghanistan, Feinstein International Center, Tufts University, 2011, p. 

46; Christopher D. Kolenda, former senior advisor to the Under Secretary of Defense for Policy and 

former strategic advisor to three COMISAFs, SIGAR interview, April 5, 2016.

12 IWA, Afghans’ Experience of Corruption, p. 10.

13 Ibid, p. 10; see also Transparency International, Corruption Threats and International Missions: 

Practical Guidance for Leaders, Defence and Security Programme, September 2014, p. 23.

14 Former mid-level Afghan government official, SIGAR interview, April 7, 2016.

15 Sarah Chayes, “In Afghanistan, It’s Not All in the Numbers,” Carnegie Endowment for International 

Peace, December 3, 2012. See also Fishstein and Wilder, Winning Hearts and Minds?, p. 75, for 

discussion of the complex social, cultural, and political challenges to conducting objective research 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 101

in Afghanistan. This point is also supported by ADB, DFID, UNDP, et al., Fighting Corruption in 

Afghanistan, p. 4.

16 World Bank, Worldwide Governance Indicators: Afghanistan, http://databank.worldbank.org/data/

reports.aspx?source=Worldwide-Governance-Indicators (accessed March 17, 2016). Data for 2014 

shows a slight improvement, with Afghanistan ranked in the bottom 6.25 percent of countries. 

17 World Bank, The Investment Climate in Afghanistan, pp. vii-viii.

18 Seth G. Jones, In the Graveyard of Empires: America’s War in Afghanistan (New York, NY: W. W. 

Norton, 2010), p. 10. For a fuller historical discussion of state-building and corruption in Afghanistan, 

see also joint paper by the ADB, DFID, UNDP, et al., Fighting Corruption in Afghanistan, p. 4. 

19 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 2. 

20 ADB, DFID, UNDP, et al., Fighting Corruption in Afghanistan, p. 4. 

21 Ibid, pp. 3, 7; Hussman, Working towards common donor responses to corruption, p. 3; Hesta 

Groenewald, Hammering the Bread and the Nail: Lessons from Counter-Terror, Stabilisation, and 

Statebuilding in Afghanistan, Saferworld, January 2016, pp. ii, 9; Joint Staff, Joint and Coalition 

Operational Analysis, Operationalizing Counter/Anticorruption Study, February 28, 2014, pp. 9-13; 

Saeed Parto, Corruption and Development Aid: Necessary Evil or Curable Disease?, Afghanistan 

Public Policy Research Organization, June 1, 2015, p. 2; former international official, SIGAR 

interview, June 5, 2015.

22 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 2.

23 Hussman, Working towards common donor responses to corruption, p. 3.

24 U.S. Embassy Kabul, “SRAP Grossman Roundtable Discussion with Afghan Business and Commerce 

Leaders,” Kabul 3170 cable, May 28, 2011; see also Parto, Corruption and Development Aid, June 1, 

2015, p. 2. 

25 DFID, Why Corruption Matters, pp. 27-28.

26 The Recovery & Development Consortium, “A Strategic Conflict Assessment of Afghanistan,” 

by Sultan Barakat, et al., University of York, November 2008, pp. 24-25; Barnett R. Rubin, The 

Fragmentation of Afghanistan (New Haven, CT: Yale University Press, 2nd ed., 2002), pp. 22-

32; Thomas Barfield, Afghanistan: A Cultural and Political History (Princeton, NJ: Princeton 

University Press, 2010), pp. 7-8.

27 GIROA, “National Anti-Corruption Strategy, Afghanistan National Development Strategy, AntiCorruption, 1387-1391 (2007/08-2012/13),” February 2008, p. 1.

28 ADB, DFID, UNDP, et al., Fighting Corruption in Afghanistan, p. 3.

29 Sullivan and Forsberg, Confronting the Threat of Corruption, pp. 160-161; see also Fishstein and 

Wilder, Winning Hearts and Minds?, p. 46. 

30 DFID, Why Corruption Matters, p. 16; see also Alina Mungiu-Pippidi et al., Contextual Choices 

in Fighting Corruption: Lessons Learned, Report 4/2011, Norwegian Agency for Development 

Cooperation (study carried out by the Hertie School of Governance in Berlin), July 2011, p. 7.

31 Congressional Research Service, Department of Defense Contractor and Troop Levels in 

Iraq and Afghanistan: 2007-2015, R44116, December 1, 2015, pp. 1, 8; World Bank, World 

Development Indicators: GDP at market prices, World Bank Databank, http://databank.

worldbank.org/data/reports.aspx?Code=NY.GDP.MKTP.CD&id=af3ce82b&report_name=Popular_

indicators&populartype=series&ispopular=y# (accessed March 11, 2016).

32 Congressional Research Service, Department of Defense Contractor and Troop Levels, R44116, 

December 1, 2015, pp. 1, 8.

33 This distinction is sometimes described as the amount of money spent in versus on Afghanistan. 

SIGAR has not found any reliable data for such figures. 
102 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

34 OECD Development Assistance Council, “Afghanistan: Beneficiary View—Official Development 

Assistance (ODA),” www.aidflows.org (accessed May 12, 2016); World Bank, World Development 

Indicators: GDP at market prices, World Bank Databank. 

35 Hussman, Working towards common donor responses to corruption, p. 3; see also Astri Suhrke, 

When More is Less: The International Project in Afghanistan (New York, NY: Columbia University 

Press, 2011), p. 119, which cites an IMF calculation of foreign aid to Afghanistan in FY 2009-2010 as 

equivalent to 49.5 percent of GDP (IMF, Sixth Review Under the Arrangement Under the Poverty 

Reduction and Growth Facility, Request for Waiver of Nonobservance of a Performance Criterion, 

Modification and Performance Criteria, and Rephrasing and Extension of the Arrangement, IMF 

Country report No. 10/22, January 2010, p. 19). The Hussman report does not define “international 

assistance.” 

36 U.S. Department of State, 2002 International Narcotics Control Strategy Report, Country Report 

on Afghanistan, March 1, 2003, pp. VII-3; U.S. Department of State, 2015 International Narcotics 

Control Strategy Report, Country Report on Afghanistan, March 2015, p. 93.

37 U.S. Department of State, International Narcotics Control Strategy Report, Country Report on 

Afghanistan, March 2005, p. 265; see also IMF, Staff-Monitored Program, IMF Country Report No. 

04-110, April 2004, pp. 6, 27; IMF, 2004 Article IV Consultation and Second Review Under the StaffMonitored Program–Staff Report; Staff Statement; Public Information Notice on the Executive 

Board Discussion; and Statement by the Executive Director for the Islamic State of Afghanistan, 

IMF Country Report No. 05/33, February 2005, p. 6.

38 GIROA, “National Anti-Corruption Strategy,” February 2008, pp. 1, 12; Transparency International, 

Corruption: Lessons from the International Mission in Afghanistan, February 2015, pp. 25, 

41; SIGAR, Inquiry Letter: UNDP oversight of LOTFA program to fund the Afghan National 

Police, SIGAR-14-99-SP, October 6, 2014; Jennifer Murtazashvili, Gaming the State: Consequences 

of Contracting Out State Building in Afghanistan, Central Asian Survey, 2015; Anthony H. 

Cordesman, “How America Corrupted Afghanistan: Time to Look in the Mirror,” Center for Strategic 

and International Studies, revised September 9, 2010, pp. 2, 5.

39 Former senior U.S. official, SIGAR interview, December 11, 2015.

40 Jennifer Murtazashvili, academic expert on Afghanistan, email to SIGAR, March 5, 2016; see also 

Groenewald, Hammering the Bread and the Nail, pp. iii, 38.

41 David R. Henderson, “Rent Seeking,” The Concise Encyclopedia of Economics, http://www.econlib.

org/library/Enc/RentSeeking.html (accessed June 10, 2016). 

42 Hussman, Working towards common donor responses to corruption, pp. 3, 5; CWC, Transforming 

Wartime Contracting: Controlling costs, reducing risks, August 2011, pp. 71, 134; Fishstein and 

Wilder, Winning Hearts and Minds?, pp. 4-5; former senior U.S. official, SIGAR interview, December 

11, 2015; Combating Terrorism Archive Project, “Interview with Kirk Meyer, Former Director of the 

Afghan Threat Finance Cell,” April 2, 2014.

43 CWC, Transforming Wartime Contracting, pp. 71, 134.

44 Crocker, SIGAR interview, January 11, 2016.

45 Sullivan and Forsberg, Confronting the Threat of Corruption, p. 160; Antonio Giustozzi, Koran, 

Kalashnikov and Laptop (New York, NY: Oxford University Press, 2009), p. 19.

46 COMISAF, Afghanistan Nationwide Quarterly Assessment Research (ANQAR) Survey Data, quarterly 

survey, data used is from September of each year, see also appendix C for a table of the survey data.

47 CJIATF-Shafafiyat, response to SIGAR quarterly report data call, September 18, 2011, p. 1-2; 

Giustozzi, Koran, Kalashnikov and Laptop, pp. 18-19; Dixon, email to SIGAR, March 7, 2016.

48 Sullivan and Forsberg, Confronting the Threat of Corruption, pp. 162-163; SIGAR, Quarterly Report 

to the United States Congress, January 30, 2015, p. 24; DOD, Report on Progress toward Security 

and Stability in Afghanistan, November 2013, p. 92; Mary Beth Goodman and Trevor Sutton, 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 103

“Tackling Corruption in Afghanistan: It’s Now or Never,” Center for American Progress, March 17, 

2015, p. 4; Cordesman, “How America Corrupted Afghanistan,” pp. 4-5.

49 Dixon, email to SIGAR, March 7, 2016; Jodi Vittori, former ISAF official, email to SIGAR, May 15, 

2016. Vittori described the effects of corruption on Afghanistan’s security sector: military budgets 

were diverted to personal use by politicians or military leaders; overpriced contracts and/or 

uncompleted contracts drained resources; forces received poor quality equipment or no equipment; 

non-merit-based promotions produced poor leadership; and inflated troop numbers included “ghost 

soldiers,” leading to inaccurate assumptions about force strength and capability. 

50 U4 Anticorruption Resource Centre, Christian Michelsen Institute, “Corruption in justice and 

security,” May 2011, p. 6. 

51 Sarah Ladbury, Testing Hypotheses on Radicalisation in Afghanistan: Why Do Men Join the 

Taliban and Hizb-I Islami? How Much Do Local Communities Support Them?, DFID, September 

2009, p. 17; David Rohde and David E. Sanger, “How a ‘Good War’ in Afghanistan Went Bad,” New 

York Times, August 12, 2007; Chayes, Thieves of State, p. 152.

52 Council on Foreign Relations, “The Taliban: A CFR InfoGuide Presentation,” n.d., p. 21. 

53 USAID, USAID Anticorruption Strategy, p. 6; World Bank, The Investment Climate in Afghanistan, 

p. 21.

54 USAID, USAID Anticorruption Strategy, p. 6.

55 World Bank, The Investment Climate in Afghanistan, p. 21.

56 Giustozzi, Koran, Kalashnikov and Laptop, pp. 16-17.

57 Fishstein and Wilder, Winning Hearts and Minds?, pp. 30-31, 45; Human Rights Watch, BloodStained Hands: Past Atrocities in Kabul and Afghanistan’s Legacy of Impunity, July 6, 2005, p. 

3; U.S. Embassy Kabul, “The Land Mafia of Nangarhar: Property Disputes Hamper Governance and 

Development Efforts in Eastern Afghanistan’s Largest Province,” Kabul 1057 cable, April 3, 2011, pp. 

1-2; Suhrke, When More is Less, pp. 53, 80.

58 Stephen Carter and Kate Clark, No Shortcut to Stability: Justice, Politics, and Insurgency in 

Afghanistan, Chatham House, December 2010, p. 28; Groenewald, Hammering the Bread and the 

Nail, p. 39; General Stanley McChrystal, COMISAF’s Initial Assessment, memorandum to Secretary 

of Defense Robert Gates, August 30, 2009, p. [2-9].

59 Murtazashvili, email to SIGAR, March 5, 2016; former senior U.S. official, SIGAR interview, 

December 11, 2015.

60 In his Nobel Prize lecture, economist Joseph E. Stiglitz said, “The problem is to provide incentives 

for those so entrusted to act on behalf of those who they are supposed to be serving—the standard 

principal-agent problem.” Stiglitz, Information and the Change in the Paradigm in Economics, 

Nobel Prize Lecture, December 8, 2001, p. 523. 

61 Jennifer Murtazashvili, “What Drives Misperceptions and Mismanagement of Foreign Aid in Conflict 

Zones?”, unpublished paper, March 13, 2016, pp. 1-2.

62 Combating Terrorism Archive Project, “Interview with Kirk Meyer”; U.S. House of Representatives, 

Committee on Oversight and Government Reform, Subcommittee on National Security and Foreign 

Affairs, Report of the Majority Staff, Warlord, Inc.: Extortion and Corruption Along the U.S. Supply 

Chain in Afghanistan, June 2010, p. 3; CWC, Transforming Wartime Contracting, August 2011, 

p. 33. 

63 Anthony Downs, Inside Bureaucracy (Santa Monica, CA: RAND Corporation, 1964), pp. 6, 9-13; 

Suhrke, When More is Less, pp. 4-5, 10-11.

64 Murtazashvili, “What Drives Misperceptions and Mismanagement of Foreign Aid in Conflict Zones?” 

pp. 4-5; Lant Pritchett, Michael Woolcock, and Matt Andrews, Capability Traps? The Mechanisms of 

Persistent Implementation Failure, Center for Global Development, Working Paper 234, December 

2010, pp. 6, 41-43.
104 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

65 Fishstein and Wilder, Winning Hearts and Minds?, p. 5; Murtazashvili, email to SIGAR, March 

5, 2016; Transparency International, Corruption: Lessons from the International Mission in 

Afghanistan, February 2015, pp. 25, 31-32.

66 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 1.

67 Marin Strmecki, “Afghanistan at a Crossroads: Challenges, Opportunities, and a Way Ahead,” a 

briefing in the Rumsfeld Papers, August 17, 2006, p. 36-37. 

68 George W. Bush, “Defeating the Terrorist Threat to the United States,” National Security Presidential 

Directive-9, October 25, 2001, p. 1.

69 Donald Rumsfeld, “Strategic Thoughts,” Memo for President George W. Bush, September 30, 2001, p. 

1; Barnett Rubin, “Saving Afghanistan,” Foreign Affairs, January 2007, p. 65; Jones, In the Graveyard 

of Empires, pp. 117-118, 131; Ahmed Rashid, Descent into Chaos: The United States and the Failure 

of Nation Building in Pakistan, Afghanistan, and Central Asia (New York, NY: Penguin Books, 

2009), p. 61.

70 Paul Wolfowitz, “Using Special Forces on ‘Our Side’ of the Line,” Memo to Secretary of Defense 

Donald Rumsfeld, September 23, 2001, p. 2; Donald Rumsfeld, “Strategic Thoughts,” Memo 

for President George W. Bush, September 30, 2001, p. 1; Donald Rumsfeld, “U.S. Strategy in 

Afghanistan,” Memo to Undersecretary of Defense for Policy Doug Feith with edits from Rumsfeld, 

October 30, 2001, pp. 3-4; Jones, In the Graveyard of Empires, p. 117.

71 Rashid, Descent into Chaos, p. 61.

72 Ibid, p. 62; Suhrke, When More is Less, p. 15; Wolfowitz, “Using Special Forces on ‘Our Side’ of the 

Line,” p. 1.

73 Rumsfeld, “U.S. Strategy in Afghanistan,” p. 2; Rashid, Descent into Chaos, p. 62.

74 Rumsfeld, “U.S. Strategy in Afghanistan,” p. 3; Jones, In the Graveyard of Empires, pp. 90-

91; Congressional Research Service, Special Operations Forces (SOF) and CIA Paramilitary 

Operations: Issues for Congress, RS22017, August 3, 2009, p. 2. The Rumsfeld document describes a 

draft plan for these operations; the Jones book recounts how such operations occurred.

75 Human Rights Watch, Blood-Stained Hands: Past Atrocities in Kabul and Afghanistan’s Legacy 

of Impunity, July 6, 2005, pp. 3-5; Afghanistan Justice Project, “Violations of International Human 

Rights and Humanitarian Law during the period of the Islamic State of Afghanistan (ISA), 1992-1996, 

and by the United Front, 1996-1998” in Afghanistan Justice Project, Casting Shadows: War Crimes 

and Crimes against Humanity: 1978-2001, 2005, pp. 61-62; Amnesty International, “UK: Afghan 

Warlord should be investigated,” press release, August 1, 2000, pp. 1-2; Amnesty International, 

Afghanistan: Making Human Rights the Agenda, November 1, 2001, p. 8.

76 AIHRC, A Call for Justice: A Report on National Consultations on Transitional Justice in 

Afghanistan, January 2005, pp. 51-52, 75.

77 Rubin, “Saving Afghanistan,” pp. 64, 69, and 77; Michael Bhatia and Mark Sedra, Afghanistan, 

Arms and Conflict: Armed groups, disarmament and security in a post-war society (New York, 

NY: Routledge, 2008), p. 178; Rustam Qobil, “At the mercy of Afghanistan’s warlords,” BBC Uzbek 

Service, November 28, 2012, http://www.bbc.com/news/magazine-19983266 (accessed July 19, 2016).

78 Dipali Mukhopadhyay, Warlords, Strongmen Governors, and the State in Afghanistan (New York, 

NY: Cambridge University Press, 2014), p. 25.

79 Barnett Rubin, Central Asia Wars and Ethnic Conflicts–Rebuilding Failed States, UNDP Human 

Development Report Office, February 2004, p. 20; Barnett Rubin, interview by Nermeen Shaikh, 

The Asia Society, n.d., p. 2; Donald P. Wright, A Different Kind of War: The United States Army 

in Operation Enduring Freedom October 2001—September 2005 (Fort Leavenworth, KS: Combat 

Studies Institute Press, U.S. Army Combined Arms Center, 2010), p. 97.

80 Former senior DOD advisor, SIGAR interview, October 19, 2015; Elizabeth Rubin, “Karzai in His 

Labyrinth,” New York Times Magazine, August 4, 2009.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 105

81 Giustozzi, Koran, Kalashnikov, and Laptop, p. 16; see also Sullivan and Forsberg, Confronting the 

Threat of Corruption, pp. 159-160.

82 Groenewald, Hammering the Bread and the Nail, pp. iii, 9; Giustozzi, pp. 16-17.

83 NSC, Afghanistan Interagency Operations Group (AIOG), Afghanistan Status: Executive SummaryYear End 2004, December 2004 (declassified December 1, 2008), p. 7; former senior DOD advisor, 

SIGAR interview, October 19, 2015; Condoleezza Rice, “‘Accelerating Success in Afghanistan’ in 

2004: An Assessment,” memorandum for the White House and Cabinet, Washington, DC, January 18, 

2005, p. 2; Donald Rumsfeld, “Warlords,” memo to Paul Wolfowitz, April 1, 2002; Donald Rumsfeld, 

“Karzai’s Strategy on Warlordism,” memo to Gen. John Abizaid, September 15, 2003.

84 Former senior DOD advisor, SIGAR interview, October 19, 2015; see also former senior NSC official, 

SIGAR interview, July 14, 2015; Stephen Hadley, former National Security Advisor, SIGAR interview, 

September 16, 2015.

85 Former senior NSC official, SIGAR interview, September 14, 2015; former senior DOD advisor, 

SIGAR interview, October 19, 2015; Matthieu Aikins, “The Master of Spin Boldak,” Harper’s 

Magazine, December 2009, pp. 55, 62.

86 Groenewald, Hammering the Bread and the Nail, p. 9.

87 Former senior DOD advisor, SIGAR interview, October 19, 2015. 

88 Robert Finn, SIGAR interview, October 22, 2015.

89 Human Rights Watch, “Just Don’t Call It a Militia:” Impunity, Militias, and the “Afghan Local 

Police,” September 2011, pp. 48, 67; U.S. Department of State, 2004 Country Report on Human 

Rights: Afghanistan, February 28, 2005, pp. 9, 12.

90 UN official, SIGAR interview, July 31, 2015.

91 Alex Strick van Linschoten and Felix Kuehn, Separating the Taliban from al-Qaeda: The Core of 

Success in Afghanistan, New York University Center on International Cooperation, February 2011, 

p. 3; Anand Gopal, The Battle for Afghanistan: Militancy and Conflict in Kandahar, New America 

Foundation, November 2010, p. 7; Carter and Clark, No Shortcut to Stability, p. 13.

92 Carter and Clark, No Shortcut to Stability, p. 20; see also Strmecki, “Afghanistan at a Crossroads,” p. 

36.

93 Michael Semple, “Negotiating with the Taliban: Is Reconciliation Possible in Afghanistan and 

Pakistan?”, U.S. Institute of Peace, Washington, DC, July 10, 2014.

94 Andrew Wilder, A House Divided? Analysing the 2005 Afghan Elections, AREU, December 2005, p. 

14.

95 Ibid, pp. 35-36.

96 Groenewald, Hammering the Bread and the Nail, p. 8; Aikins, “The Master of Spin Boldak,” pp. 53, 

60, 62; Suhrke, When More Is Less, pp. 135-136.

97 Suhrke, When More Is Less, p. 135.

98 Carl Forsberg, “Private Security Contracting and the Counterinsurgency Mission in Afghanistan,” 

testimony before the U.S. House of Representatives Committee on Oversight and Government 

Reform, Subcommittee on National Security and Foreign Affairs, hearing on “Investigation of 

Protection Payments for Safe Passage along the Afghan Supply Chain,” June 22, 2010, pp. 2-3.

99 Ibid, p. 3; see also Subcommittee on National Security and Foreign Affairs, Warlord, Inc., p. 24.

100 Bob Woodward, Obama’s Wars (New York, NY: Simon & Schuster Paperbacks, 2010), p. 66; Dexter 

Filkins, “Despite Doubt, Karzai Brother Retains Power,” New York Times, March 30, 2010; Dexter 

Filkins, Mark Mazzetti, and James Risen, “Brother of Afghan Leader Said to Be Paid by C.I.A.,” New 

York Times, October 27, 2009; Joshua Partlow and Kevin Sieff, “Ahmed Wali Karzai, Half Brother of 

Afghan President, Killed by Trusted Confidant,” Washington Post, July 12, 2011; Dion Nissenbaum, 

“Afghanistan War: Convoy Security Deal to Benefit Karzai’s Brother,” Christian Science Monitor, 

May 23, 2010. 
106 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

101 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, pp. 1, 9-10; U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 

3681 cable (declassified by U.S. Department of State on December 11, 2015, at SIGAR’s request), 

September 15, 2005, pp. 2-3; Suhrke, When More is Less, pp. 14-15; Sarah Chayes, The Punishment 

of Virtue: Inside Afghanistan After the Taliban (New York, NY: Penguin Press, 2006), pp. 227-228; 

Carter and Clark, No Shortcut to Stability, pp. vii-ix; Jones, In the Graveyard of Empires, pp. 130-

131; UN official, SIGAR interview, July 31, 2015.

102 Former senior U.S. official, SIGAR interview, December 11, 2015; see also Chayes, Thieves of 

State, pp. 44-45; Kim Barker, “Letter from Kabul: Solving Afghanistan’s Problems,” Foreign Affairs, 

November 30, 2009; Combating Terrorism Archive Project, “Interview with Kirk Meyer”; Fishstein 

and Wilder, Winning Hearts and Minds?, p. 44; Shaazka Beyerle (author of Curtailing Corruption: 

People Power for Accountability and Justice [Boulder, CO: Lynne Rienner Publishers, Inc., 2014]), 

SIGAR interview, September 24, 2015.

103 Former senior U.S. official, SIGAR interview, December 11, 2015.

104 Crocker, SIGAR interview, January 11, 2016.

105 Combating Terrorism Archive Project, “Interview with Kirk Meyer.”

106 Former senior NSC official, SIGAR interview, July 14, 2015; senior USAID official, SIGAR interview, 

August 24, 2015; former intelligence officer, SIGAR interview, December 8, 2015; Crocker, SIGAR 

interview, January 11, 2016; State Department, U.S. Mission to Afghanistan, Mission Performance 

Plan FY 2006, April 12, 2004, p. 27.

107 George W. Bush, “President’s News Conference,” October 11, 2001, http://georgewbush-whitehouse.

archives.gov/news/releases/2001/10/20011011-7.html (accessed August 4, 2016); Suhrke, When More 

Is Less, pp. 23-24. 

108 Senior U.S. official, SIGAR interview, August 24, 2015.

109 Former senior State Department official, SIGAR interview, June 1, 2015.

110 Senior Treasury Department official, SIGAR interview, October 1, 2015; senior U.S. official, SIGAR 

interview, August 24, 2015; former senior USAID official, SIGAR interview, August 24, 2015.

111 Afghanistan Freedom Support Act of 2002, 22 USC § 7513 (a)(5)(b). 

112 U.S. Embassy Kabul, “Herat: Aid and Trade,” Kabul 541 cable, February 29, 2004, pp. 3, 5, 8; U.S. 

Embassy Kabul, “PRT Badghis,” Kabul 5180 cable, December 20, 2005, pp. 2, 4. Consisting of both 

civilian and military personnel, Provincial Reconstruction Teams (PRT) were designed to improve an 

area’s stability by building host nation capacity, legitimacy, and effectiveness.

113 U.S. Embassy Kabul, “Herat: Aid and Trade,” Kabul 541 cable, February 29, 2004, p. 4; U.S. Embassy 

Kabul, “Ghor Province: Anatomy of a Power Struggle,” Kabul 1876 cable, June 22, 2004, p. 2.

114 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 1.

115 Ibid, p. 3.

116 Ronald Neumann, The Other War: Winning and Losing in Afghanistan (Washington, DC: Potomac 

Books, 2009), p. 109.

117 Neumann, The Other War, p. 47.

118 Strmecki, “Afghanistan at a Crossroads,” p. 36; Donald Rumsfeld, “Strmecki,” a memorandum given 

to Eric Edelman, Rumsfeld Papers, May 18, 2006.

119 Strmecki, “Afghanistan at a Crossroads,” p. 36.

120 Ibid, pp. 36-39. 

121 U.S. Department of the Army, Counterinsurgency, December 2006, foreword.

122 Ibid, p. 1-21.

123 Ibid, pp. 5-7, 6-21 to 6-22, and 8-10.

124 Ibid, p. 8-18.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 107

125 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 5.

126 USAID, USAID Anticorruption Strategy, pp. 1-2, 16, 23-24.

127 USAID, USAID/Afghanistan Strategic Plan 2005-2010, May 2005, p. 5.

128 Neumann, The Other War, pp. 61-62; State Department, U.S. Counternarcotics Strategy for 

Afghanistan: Compiled by the Coordinator for Counternarcotics and Justice Reform in 

Afghanistan, Ambassador Thomas A. Schweich, August 2007, pp. 15, 30, 53.

129 State Department, U.S. Counternarcotics Strategy for Afghanistan, August 2007, pp. 8, 15, 31; 

Matthieu Aikins, “Our Man in Kandahar,” Atlantic, November 2011, pp. 4-5; Matthieu Aikins, “The 

Master of Spin Boldak,” Harper’s Magazine, December 2009, pp. 54, 60, 62. 

130 State Department, 2005 International Narcotics Control Strategy Report, Afghanistan Country 

Report, March 2005, p. 267.

131 State Department, U.S. Counternarcotics Strategy for Afghanistan, pp. 15, 64. 

132 GAO, Afghanistan Reconstruction: Despite Some Progress, Deteriorating Security and Other 

Obstacles Continue to Threaten Achievement of U.S. Goals, GAO-05-742, July 2005, p. 26; USAID, 

USAID/Afghanistan Strategic Plan 2005-2010, May 2005, pp. 7-8; USAID official, SIGAR interview, 

May 5, 2015; former senior U.S. official, SIGAR interview, December 11, 2015.

133 GAO, Afghanistan Reconstruction: Despite Some Progress, GAO-05-742, p. 26.

134 SIGAR, Afghanistan’s Banking Sector: The Central Bank’s Capacity to Regulate Commercial Banks 

Remains Weak, SIGAR 14-16-AR, January 2014, pp. 6-8; GAO, Afghanistan Reconstruction: Despite 

Some Progress, GAO-05-742, p. 26.

135 SIGAR, Afghanistan’s Banking Sector, SIGAR 14-16-AR, pp. 6-8.

136 Ibid, p. 4.

137 Transparency International, The Anticorruption Plain Language Guide, July 2009, p. 44; USAID’s 

Anticorruption Projects Database provides a complete listing of projects, implemented between 2007 

and 2013, that USAID identified as having distinctive project interventions to reduce corruption or 

promote government integrity, accountability, and transparency and ultimately result in reducing 

opportunities to corruption. This database can be found at: https://www.usaid.gov/data/dataset/

b2cd92f6-e8bb-447b-9720-510222a80d0b (accessed August 2, 2016). 

138 USAID, USAID/Afghanistan Strategic Plan 2005-2010, May 2005, p. 5.

139 Ibid, pp. 12-13.

140 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 5; 

SIGAR, Afghan Customs: U.S. Programs Have Had Some Successes, but Challenges Will Limit 

Customs Revenue as a Sustainable Source of Income for Afghanistan, SIGAR 14-47-AR, April 2014, 

p. 12.

141 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (declassified 

by U.S. Department of State on December 11, 2015, at SIGAR’s request), September 15, 2005, p. 5.

142 U.S. Embassy Kabul, “Afghanistan Ninth Meeting of the JCMB September 10,” Kabul 2572 cable, 

September 20, 2008, p. 4; U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 

3681 cable (declassified by U.S. Department of State on December 11, 2015, at SIGAR’s request), 

September 15, 2005, pp. 4, 5.

143 U.S. Embassy Kabul, “Afghan Telecom Chief Fired for Corruption,” Kabul 229 cable, January 23, 

2007.

144 Strmecki, “Afghanistan at a Crossroads,” p. 36.

145 Suhrke, When More Is Less, pp. 106-107.

146 Jeffrey Dressler, Counterinsurgency in Helmand, Institute for the Study of War, January 2011, p. 26.

147 Suhrke, When More Is Less, p. 107; Damien McElroy, “Afghan Governor Turned 3,000 Men Over to 

Taliban,” Telegraph, November 20, 2009, p. 2.
108 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

148 Dressler, Counterinsurgency in Helmand, pp. 32-33; Suhrke, When More Is Less, p. 107; McElroy, 

“Afghan Governor Turned 3,000 Men Over to Taliban.”

149 Jack Healy and Abdul Waheed Wafa, “Karzai Advisor Is Killed at Kabul Home,” New York Times, July 

17, 2011.

150 Susanne Schmeidl, The Man Who Would be King: The Challenge to Strengthen Governance in 

Uruzgan, Netherlands Institute of International Relations Clingendael, 2010, pp. 34-35.

151 Human Rights Watch, World Report 2012: Afghanistan, January, 2012, p. 291; Rafael Epstein and 

Jeremy Kelly, “All Afghan roads lead to Khan,” The Sydney Morning Herald, June 18, 2011.

152 Strmecki, “Afghanistan at a Crossroads,” p. 38.

153 UNDP, Institutional Arrangements for Combating Corruption in Afghanistan: Analysis and 

Recommendations—A Preliminary Report, September 2, 2007, pp. 11-12, 14-15, 18-20; Hussmann, 

Working towards common donor responses to corruption, p. 4.

154 Former international official, SIGAR interview, June 5, 2015; Declan Walsh, “How Anticorruption 

Chief Once Sold Heroin in Las Vegas,” Guardian, August 27, 2007; Ken Ritter, “Afghan 

Anticorruption Chief a Convicted U.S. Felon,” New York Times, March 11, 2007.

155 SIGAR, Afghanistan’s High Office of Oversight Needs Significantly Strengthened Authority, 

Independence, and Donor Support to Become an Effective Anticorruption Institution, SIGAR 

10-2-AR, December 16, 2009, p. ii. The HOO was created by Afghanistan’s Law on Overseeing 

the Implementation of the Anticorruption Strategy and is covered in further detail in subsequent 

sections of this report.

156 John Lancaster, “At Inauguration, Karzai Vows Action on Tough Issues,” Washington Post, December 

8, 2004; President Hamid Karzai, “Inaugural Speech: English Translation,” December 7, 2004.

157 UN, “UN Convention Against Corruption,” 2004; UN, “United Nations Convention Against 

Corruption: Signature and Ratification Status as of 1 December 2015.” 

158 Hussmann, Working towards common donor responses to corruption, p. 4. 

159 Nils Taxell, anticorruption expert, SIGAR interview, July 3, 2015.

160 GAO, Afghanistan Security: U.S. Programs to Further Reform Ministry of Interior and National 

Police Challenged by Lack of Military and Personnel and Afghan Cooperation, GAO-09-280, March 

2009, pp. 2-3.

161 Strmecki, “Afghanistan at a Crossroads,” pp. 27-28.

162 Ibid, p. 22. 

163 Nils Taxell, anticorruption expert, SIGAR interview, July 3, 2015; UN official, SIGAR interview, 

July 31, 2015.

164 UN Office on Drugs and Crime, “Afghanistan Counter Narcotics Criminal Justice Task Force 

Becomes Operational,” 28 July 2005.

165 State Department International Narcotics and Law Enforcement, Southwest Asia: INSCR 2005 

Volume I, March 2005, p. 267. 

166 FBI, “Mission Afghanistan: Contract Corruption, Part 3: Holding Americans Accountable in a War 

Zone,” April 26, 2011. Members of the ICCTF included the FBI, Special Inspector General for Iraq 

Reconstruction, DOD Criminal Investigative Service, Army Criminal Investigation Command, 

Department of State Office of Inspector General, USAID Office of Inspector General, Air Force Office 

of Special Investigations, Naval Criminal Investigative Service, and SIGAR.

167 Ibid.

168 FBI, response to SIGAR quarterly report data call, December 23, 2008.

169 National Defense Authorization Act for Fiscal Year 2008, Pub. L. No. 110-181, § 1229, p. 378. 

170 London Conference on Afghanistan, The Afghanistan Compact, 31 January–1 February 2006, pp. 7-8.

171 Ibid, pp. 6-8, 11-12. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 109

172 Robert Lamb and Kathryn Mixon, Rethinking Absorptive Capacity: A New Framework Applied to 

Afghanistan’s Police Training Program, Center for Strategic and International Studies, June 2013, 

pp. v, 50.

173 U.S. Embassy Kabul, “Afghanistan—JCMB VII Discusses an Integrated Strategy and CounterNarcotics February 5 and 6, 2008,” Kabul 461 cable, February 25, 2008, pp. 2, 7; Joint Coordination 

and Monitoring Board, Report to JCMB VII, 7th JCMB Meeting, February 6, 2008, pp. 10, 13; Thomas 

Ruttig, “A meaningful Afghanistan conference needs civil society involvement,” Afghanistan Analysts 

Network, November 25, 2009, pp. 1-2.

174 Hussmann, Working towards common donor responses to corruption, p. 4.

175 Carter and Clark, No Shortcut to Stability, p. vii-ix; Transparency International, Corruption: Lessons 

from the International Mission in Afghanistan, February 2015, pp. 30–31; Sarah Chayes, Senior 

Associate, Carnegie Endowment for International Peace, SIGAR interview, May 26, 2015.

176 ADB, DFID, UNDP, et al., Fighting Corruption in Afghanistan, February 16, 2007, p. 1.

177 Ibid, pp. 14-17.

178 Ibid, p. 2. Vulnerability to Corruption Assessments (VCA) are conducted by many U.S. and 

international agencies and donors. The purpose is to develop “concrete insights regarding forms 

of corruption, sources, implications, extent, and vulnerabilities to corruption in particular sectors, 

agencies, and functions in order to develop practical prevention measures.” (World Bank, Fighting 

Corruption in Afghanistan: Summaries of VCAs, May 2009, p. 5.)

179 UNDP, Institutional Arrangement for Combatting Corruption in Afghanistan: Analysis and 

Recommendations, Preliminary Report and Final Draft, February 9, 2007, p. 10; High Office 

of Oversight and Anticorruption, “About Corruption,” http://anti-corruption.gov.af/en/page/1736 

(accessed August 2, 2016); Civil-Military Fusion Centre, Corruption and Anticorruption Issues in 

Afghanistan, February 2012, p. 10.

180 GIROA, Strategy and Policy for Anticorruption and Administrative Reform, March 2008, p. 7; 

UNDP, Anticorruption Strategies: What Works, What Doesn’t and Why?, 2014, p. 58.

181 Yama Torabi, committee member of the Independent Joint Anti-Corruption Monitoring and 

Evaluation Committee (MEC) and former executive director of Integrity Watch Afghanistan, email to 

SIGAR, March 5, 2015.

182 Former NSC Senior Director for Afghanistan (2007-2009), email to SIGAR, March 3, 2016.

183 Hussmann, Working towards common donor responses to corruption, pp. 1, 6.

184 Ibid, p. 1; former senior UN official, SIGAR interview, August 26, 2015.

185 Hussmann, Working towards common donor responses to corruption, p. 1.

186 Dipali Mukhopadhyay, Warlords as Bureaucrats – The Afghan Experience, Carnegie Endowment 

for International Peace, August 2009, p. 2.

187 ADB, DFID, UNDP, et al., Fighting Corruption in Afghanistan, February 16, 2007, pp. 14-17; U.S. 

Embassy Kabul, “Afghanistan—JCMB VII,” Kabul 461 cable, February 25, 2008, p. 7.

188 Defense Intelligence Agency, Charts for SIGAR: Violence by Province 2002 to 2014, FDO 10695-15, 

provided to SIGAR on April 29, 2015.

189 Congressional Research Service, The Cost of Iraq, Afghanistan, and Other Global War on Terror 

Operations Since 9/11, RL33110, December 8, 2014, pp. 82, 84. 

190 Brookings Institution, Afghanistan Index: Tracking Progress and Security in Post-9/11 

Afghanistan, March 31, 2016, pp. 5-6. 

191 White House, Office of the Press Secretary, “Remarks by the President on a New Strategy for 

Afghanistan and Pakistan,” March 27, 2009; Defense Casualty Systems Analysis (DCAS), “Conflict 

Casualties, Operation Enduring Freedom (OEF) Casualties By Month,” U.S. Department of Defense, 

updated February 8, 2016, https://www.dmdc.osd.mil/dcas/pages/report_oef_month.xhtml (accessed 

August 2, 2016).
110 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

192 NSC, White Paper on the Interagency Policy Group’s Report on U.S. Policy Toward Afghanistan 

and Pakistan, March 2009, p. 6; Barack Obama, “Remarks by the President on a New Strategy for 

Afghanistan and Pakistan,” March 27, 2009, pp. 1-2.

193 Barack Obama, “Remarks by the President on a New Strategy for Afghanistan and Pakistan,” March 

27, 2009, p. 2; see also NSC, White Paper of the Interagency Policy Group’s Report on U.S. Policy 

toward Afghanistan and Pakistan, p. 1.

194 NSC, White Paper of the Interagency Policy Group’s Report on U.S. Policy toward Afghanistan and 

Pakistan, p. 2.

195 DOD, Report on Progress toward Security and Stability in Afghanistan, October 2009, p. 6.

196 Barack Obama, “The Way Forward in Afghanistan,” transcript of speech given at West Point, 

December 1, 2009; Congressional Research Service, Department of Defense Contractor and Troop 

Levels In Iraq and Afghanistan, R44116, p. 3.

197 DOD, Report on Progress toward Security and Stability in Afghanistan, October 2009, p. 9; NSC, 

White Paper of the Interagency Policy Group’s Report on U.S. Policy toward Afghanistan and 

Pakistan, pp. 3, 6.

198 GAO, Afghanistan: Improvements Needed to Strengthen Management of U.S. Civilian Presence, 

GAO-12-285, February 2012, pp. 12, 17.

199 SIGAR, Quarterly Report to the United States Congress, January 30, 2012, pp. 12, 14.

200 Congressional Research Service, Department of Defense Contractor and Troop Levels in Iraq and 

Afghanistan, R44116, p. 8.

201 Congressional Research Service, Afghanistan: U.S. Rule of Law and Justice Sector Assistance, 

R41484. November 9, 2010, p. 2.

202 USAID, Assessment of Corruption in Afghanistan, p. 4.

203 Woodward, Obama’s Wars, p. 66.

204 U.S. Embassy Kabul, “Afghanistan/Counternarcotics: Governors and Ministers Support Sustainable 

Poppy Eradication,” Kabul 156 cable, January 21, 2009; U.S. Embassy Kabul, “Agriculture Roundtable 

with Deputy Secretary Lew and MAIL Minister Mohammed Asif Rahimi,” Kabul 3049 cable, October 

1, 2009; U.S. Embassy Kabul, “Ghani, Abdullah Debate Economy—Without Karzai,” Kabul 2363 cable, 

August 15, 2009.

205 U.S. Embassy Kabul, “Implementing the President’s Vision of Rule of Law in Afghanistan,” Kabul 

1700 cable, July 1, 2009, p. 3. 

206 U.S. Embassy Kabul, “Implementing the President’s Vision,” Kabul 1700 cable, July 1, 2009, p. 3.

207 IWA, Afghan Perceptions and Experiences of Corruption: A National Survey, 2010, p. 10.

208 DOD, Report on Progress toward Security and Stability in Afghanistan, November 2010, p. 62.

209 The Asia Foundation, Afghanistan in 2006: Survey of the Afghan People, October 2006, p. 14; The 

Asia Foundation, Afghanistan in 2007: Survey of the Afghan People, September 2007, p. 23; The 

Asia Foundation, Afghanistan in 2008: Survey of the Afghan People, October 2008, p. 59; The Asia 

Foundation, Afghanistan in 2009: Survey of the Afghan People, October 2009, p. 70; The Asia 

Foundation, Afghanistan in 2010: Survey of the Afghan People, October 2010, p. 85.

210 Ladbury, Testing Hypotheses on Radicalisation in Afghanistan, p. 10; Chayes, “In Afghanistan, It’s 

Not All in the Numbers,” pp. 1-2.

211 U.S. Embassy Kabul and USFOR-A, The U.S. Government Integrated Civilian-Military Campaign 

Plan for Support to Afghanistan, August 2009, pp. 1-2; McChrystal, COMISAF’s Initial Assessment, 

pp. [2-5], [2-9]; U.S. Senate Committee on Foreign Relations, Afghanistan’s Narco War: Breaking the 

Link Between Drug Traffickers and Insurgents, August 10, 2009, p. 11.

212 Ladbury, Testing Hypotheses on Radicalisation in Afghanistan, p. 18; McChrystal, COMISAF’s 

Initial Assessment, pp. [2-5], [2-9]; U.S. Senate Committee on Foreign Relations, Afghanistan’s 

Narco War: Breaking the Link Between Drug Traffickers and Insurgents, p. 11.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 111

213 McChrystal, COMISAF’s Initial Assessment, p. [2-9]; U.S. Embassy Kabul, “2007 in Review,” Kabul 71 

cable, January 7, 2008, pp. 2, 5; U.S. Embassy Kabul, “PRT Badghis,” Kabul 5180 cable, December 20, 

2005, pp. 2-4; Congressional Research Service, Wartime Contracting in Afghanistan: Analysis and 

Issues for Congress, R42084, November 4, 2011, p. 6.

214 Ladbury, Testing Hypotheses on Radicalisation in Afghanistan, p. 7. According to the U.S. 

Department of State, Hezb-i Islami is “a political and paramilitary organization in Afghanistan 

founded in 1976 by Afghan warlord Gulbuddin Hekmatyar.” An offshoot called Hezb-i Islami 

Gulbuddin (HIG) has “espoused virulently anti-U.S. ideologies, and supports making Afghanistan 

an Islamic state rooted in sharia.” (U.S. Department of State, Office of the Spokesperson, Media 

Note: Rewards for Justice–Reward Offers for Information on Hezb-e Islami Gulbuddin (HIG) 

Terrorists, February 26, 2015.) 

215 Martine van Bijlert, Who Controls the Vote? Afghanistan’s Evolving Elections, Afghan Analyst 

Network, May 2010, pp. 1, 6.

216 Pamela Constable, “Abdullah withdraws from Afghan runoff election,” Washington Post, November 

2, 2009; see also Democracy International, U.S. Election Observation Mission to the Afghanistan 

Presidential and Provincial Council Elections 2009, revised and updated August 2010, p. 3; UN 

Assistance Mission in Afghanistan, “ECC Makes Decisions on Fraudulent Ballots and Complaints,” 

October 20, 2009. 

217 International Crisis Group, “Afghanistan: Elections and the Crisis of Governance,” Crisis Group Asia 

Briefing No. 96, November 25, 2009, pp. 1-2; Noah Coburn and Anna Larson, “Electing the Peace?: 

Afghanistan’s Fast-Track Democracy,” in Derailing Democracy in Afghanistan: Elections in an 

Unstable Political Landscape (New York, NY: Columbia University Press, 2014), p. 156.

218 Chayes, SIGAR interview, May 26, 2015.

219 Combating Terrorism Archive Project, “Interview with Kirk Meyer”; former Deputy Director, Afghan 

Threat Finance Cell, SIGAR interview, June 17, 2015.

220 Combating Terrorism Archive Project, “Interview with Kirk Meyer.” 

221 Former Deputy Director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015; Combating 

Terrorism Archive Project, “Interview with Kirk Meyer.”

222 Dexter Filkins, “The Afghan Bank Heist,” New Yorker, February 14, 2011; former Deputy Director, 

Afghan Threat Finance Cell, SIGAR interview, June 17, 2015.

223 Combating Terrorism Archive Project, “Interview with Kirk Meyer.”

224 McChrystal, COMISAF’s Initial Assessment, pp. [2-9], [2-10].

225 Former Deputy Director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015; Combating 

Terrorism Archive Project, “Interview with Kirk Meyer.”

226 Combating Terrorism Archive Project, “Interview with Kirk Meyer.”

227 Ibid; see also Barnett Rubin, “What I Saw in Afghanistan,” New Yorker, July 1, 2015.

228 U.S. Department of the Army, Counterinsurgency, p. [1-1].

229 U.S. Embassy Kabul and USFOR-A, The U.S. Government Integrated Civilian-Military Campaign 

Plan for Support to Afghanistan, August 2009, p. 13.

230 McChrystal, COMISAF’s Initial Assessment, p. [2-5].

231 Ibid, p. [2-9]; see also DOD, Report on Progress toward Security and Stability in Afghanistan, April 

2010, p. 46.

232 McChrystal, COMISAF’s Initial Assessment, p. [2-10].

233 White House, Office of the Press Secretary, “Remarks by the President on a New Strategy for 

Afghanistan and Pakistan,” March 27, 2009. 

234 White House, Office of the Press Secretary, “Press Briefing by Bruce Riedel, Ambassador Richard 

Holbrooke, and Michele Flournoy on the New Strategy for Afghanistan and Pakistan,” March 27, 

2009.
112 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

235 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy-Corrected Copy,” Kabul 

4016 cable, August 28, 2010.

236 CWC, At What Cost? Contingency Contracting in Iraq and Afghanistan: Interim Report, June 

2009, pp. 26, 28, 39.

237 CWC, Transforming Wartime Contracting, p. 1; National Defense Authorization Act for Fiscal Year 

2008, Pub. L. No. 110-181, § 841.

238 CWC, At What Cost, p. 86.

239 McChrystal, COMISAF’s Initial Assessment, p. [2-10]; USAID, Assessment of Corruption in 

Afghanistan, p. 51.

240 Aram Roston, “How the U.S. Funds the Taliban,” Nation, November 11, 2009.

241 Subcommittee on National Security and Foreign Affairs, Warlord, Inc., pp. 2-4. 

242 U.S. House of Representatives, Committee on Oversight and Government Reform, Subcommittee 

on National Security and Foreign Affairs, Report of the Majority Staff, Mystery at Manas: Strategic 

Blind Spots in the Department of Defense’s Fuel Contracts in Kyrgyzstan, December 2010, p. 2.

243 John F. Sopko, SIGAR, testimony Before the Subcommittee on National Security, Homeland 

Defense, and Foreign Operations, Committee on Oversight and Government Reform, U.S. House of 

Representatives, September 13, 2012, p. 4. Fuel theft in Afghanistan will be more fully addressed in 

an upcoming SIGAR report on the topic.

244 Defense Logistics Agency, “DLA Energy—Fuel Sales in Afghanistan,” February 18, 2015.

245 U.S. Army Materiel Command, Memorandum on “Fuels Technical Letter (FTL) 13-02, Operation 

Enduring Freedom Petroleum Accountability and Reporting Procedures,” December 2012.

246 Kenneth Hudak, “Lengthening the Tether of Fuel in Afghanistan,” Army Sustainment Magazine, 

March–April 2013; U.S. Transportation Command, “USTRANSCOM Justification for Other than Full 

and Open Competition National Afghan Trucking (NAT) Service,” June 25, 2014, p. 2.

247 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

August 28, 2010.

248 GAO, The Strategic Framework for U.S. Efforts in Afghanistan, GAO-10-655R, June 15, 2010, pp. 3, 

5-7.

249 USAID, Assessment of Corruption in Afghanistan, March 2009, pp. 26-27, 33, 49; Office of the 

Special Representative for Afghanistan and Pakistan, Anticorruption Action Plan for Afghanistan, 

May 21, 2009, pp. 1-4; U.S. Embassy Kabul, “Supporting COIN—Increasing Access to Justice in 

Afghanistan,” Kabul 1573 cable, June 20, 2009, pp. 1-4; U.S. Embassy Kabul and USFOR-A, The U.S. 

Government Integrated Civilian-Military Campaign Plan for Support to Afghanistan, August 

2009, pp. 7, 27-28; U.S. Embassy Kabul, U.S. Government Rule of Law Strategy for Afghanistan, 

September 2009, pp. 1-3; U.S. Embassy Kabul, U.S. Government Anticorruption Strategy for 

Afghanistan, October 2009, pp. 1-2; U.S. Embassy Kabul, U.S. Government Anticorruption Strategy 

for Afghanistan, April 2010, pp. 1-2.

250 U.S. Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, April 2010, pp. 1-2.

251 Ibid, p. 10. 

252 Senior State Department official, SIGAR interview, January 14, 2016.

253 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, August 5, 2010, p. ii.

254 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, pp. 4, 22-23, 26; Chayes, Thieves of State, pp. 51, 64.

255 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement, GAO-11-355, June 

2011, pp. 3, 8-9; Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/

Anticorruption Study, p. 27. 

256 Thomas Creal, international forensic accountant, SIGAR interview, March 23, 2016; Gert Berthold, 

former Task Force 2010 forensic operations program manager, SIGAR interview, October 6, 2015. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 113

257 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, pp. 22-25.

258 Senior State Department official, SIGAR interview, January 14, 2016.

259 U.S. Embassy Kabul, “Confronting Afghanistan’s Corruption Crisis,” Kabul 3681 cable (redacted), 

September 15, 2005; McChrystal, COMISAF’s Initial Assessment, p. [2-10].

260 DOD, response to SIGAR data call, December 12, 2015, pp. 2-4; Joint Staff, Joint and Coalition 

Operational Analysis, Operationalizing Counter/Anticorruption Study, p. 15.

261 Former Deputy Director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015.

262 Creal, SIGAR interview, March 23, 2016; Berthold, SIGAR interview, October 6, 2015.

263 Former deputy director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015.

264 Senior State Department official, SIGAR interview, January 14, 2016; former ISAF official, SIGAR 

interview, December 16, 2015.

265 Matthew Chlosta, “New task force stands up to combat contract corruption,” ISAF Public Affairs 

Office, n.d.; GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, June 2011, p. 8. 

266 Berthold, SIGAR interview, October 6, 2015; Chlosta, “New task force stands up to combat 

contract corruption.”

267 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” p. 4. 

268 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 9.

269 ISAF, COMISAF’s Counterinsurgency (COIN) Contracting Guidance, September 8, 2010.

270 Ibid.

271 Ibid, p. 1.

272 Karl Eikenberry, “Contracting Oversight in Counterinsurgency (COIN) Strategy,” Memo to All 

Mission Personnel, U.S. Embassy Kabul, November 3, 2010; SIGAR, Contracting with the Enemy: 

DOD Has Limited Assurance that Contractors with Links to Enemy Groups Are Identified and their 

Contracts Terminated, SIGAR 13-6-AR, August 2013, p. 3.

273 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy;” FBI, “Mission 

Afghanistan, Part 2: The Major Crimes Task Force,” April 22, 2011.

274 U.S. Embassy Kabul, “Major Crimes Task Force–A Key Element of the Road Map for Fighting 

Corruption and Serious Crimes in Afghanistan,” Kabul 3419 cable, October 26, 2009, p. 1. 

275 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a 

Finalized Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 13.

276 FBI, “Mission Afghanistan, Part 2: The Major Crimes Task Force,” April 22, 2011; FBI, “Mission 

Afghanistan Video: Major Crimes Task Force,” November 2010, https://www.fbi.gov/news/videos/

major-crimes-task-force (accessed August 2, 2016).

277 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 5.

278 Ibid, p. 2.

279 Ibid.

280 Ibid, p. 4. FinTRACA became a member of the Egmont Group of Financial Intelligence Units in 2010 

(IMF, Islamic Republic of Afghanistan: Detailed Assessment Report on Anti-Money Laundering 

and Combating the Financing of Terrorism, IMF Country Report No. 11/317, November 2011, p. 9).

281 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 4.

282 IMF, Islamic Republic of Afghanistan: Detailed Assessment Report on Anti-Money Laundering 

and Combating the Financing of Terrorism, IMF Country Report No. 11/317, November 2011, p. 9. 

283 Dexter Filkins and Mark Mazzetti, “Karzai Aide in Corruption Inquiry is Tied to CIA,” New York 

Times, August 25, 2010; Department of the Treasury, “Treasury Designates New Ansari Money 

Exchange,” Press Release, February 18, 2011.
114 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

284 Department of the Treasury, “Treasury Designates New Ansari Money Exchange,” Press Release, 

February 18, 2011; Filkins, “The Afghan Bank Heist,” New Yorker; Matthew Rosenberg, “Afghanistan 

Money Probe Hits Close to the President,” Wall Street Journal, August 12, 2010.

285 Filkins, “The Afghan Bank Heist,” New Yorker; Chayes, Thieves of State, p. 142.

286 Chayes, Thieves of State, p. 140; Kirk Meyer, former director of the Afghan Threat Finance Cell, 

email to SIGAR, March 6, 2016.

287 Filkins and Mazzetti, “Karzai Aide in Corruption Inquiry is Tied to CIA,” New York Times; Matthew 

Rosenberg, “U.S. Treasury Blacklists Afghan Money Courier,” Wall Street Journal, February 20, 2011.

288 Matthew Rosenberg and Maria Abi-Habib, “Afghanistan Blunts Anticorruption Efforts,” Wall Street 

Journal, September 12, 2010.

289 Filkins and Mazzetti, “Karzai Aide in Corruption Inquiry is Tied to CIA.”

290 Rubin, “What I Saw in Afghanistan.”

291 Chayes, Thieves of State, p. 141; Berthold, SIGAR interview, October 6, 2015.

292 Rosenberg and Abi-Habib, “Afghanistan Blunts Anticorruption Efforts”; SIGAR, Rule of Law in 

Afghanistan: U.S. Agencies Lack a Strategy and Cannot Fully Determine the Effectiveness of 

Programs Costing More Than $1 Billion, SIGAR 15-68-AR, July 2015, pp. 13, 19.

293 Meyer, email to SIGAR, March 6, 2016; regarding the kickback scheme, see also U.S. Embassy Kabul, 

“Court Reaches Guilty Verdict in Hajj Corruption Case,” Kabul 1944 cable, May 25, 2010, pp. 1-2.

294 Meyer, email to SIGAR, March 6, 2016; U.S. Embassy Kabul, “Afghanistan: Advancing Our 

Anticorruption Strategy,” Kabul 4016 cable, September 12, 2010.

295 Filkins and Mazzetti, “Karzai Aide in Corruption Inquiry is Tied to CIA.” 

296 Ibid.

297 Rajiv Chandrasekaran, “Karzai Rifts Prompts U.S. to Reevaluate Anticorruption Strategy in 

Afghanistan,” Washington Post, September 13, 2010. 

298 Former SRAP official, SIGAR interview, August 27, 2015; Treasury Department official, SIGAR 

interview, July 27, 2015; State Department officials, SIGAR interview, December 16, 2015.

299 Former senior U.S. official, SIGAR interview, December 11, 2015.

300 Arne Strand, Elite Capture of Kabul Bank: Corruption, Grabbing, and Development, Christian 

Michelsen Institute, 2014, p. 180; Combatting Terrorism Project, “Interview with Kirk Meyer”; Meyer, 

email to SIGAR, March 6, 2016.

301 Meyer, email to SIGAR, March 6, 2016.

302 Former senior legal policy advisor at the MEC, SIGAR interview, March 1, 2016; Meyer, email to 

SIGAR, March 6, 2016.

303 Combating Terrorism Archive Project, “Interview with Kirk Meyer.” 

304 Matthew Rosenberg, “Audit Says Kabul Bank Began as ‘Ponzi Scheme,’” New York Times, 

November 26, 2010.

305 U.S. Embassy Kabul, “Kabul Bank: September 5 Street Observations,” Kabul 4282 cable, September 

7, 2010; Dexter Filkins, “Depositors Panic Over Bank Crisis in Afghanistan,” New York Times, 

September 2, 2010; Matthew Rosenberg and Maria Abi-Habib, “Karzai Kin Asks U.S. to Bolster His 

Bank,” Wall Street Journal, September 3, 2010.

306 MEC, “Kabul Bank Follow-up Report,” October 2, 2014.

307 Congressional Research Service, Department of Defense Contractor and Troop Levels, R44116, p. 3.

308 White House, Office of the Press Secretary, “Remarks by the President on the Way Forward in 

Afghanistan,” June 22, 2011.

309 Hillary Clinton, “Remarks by Secretary of State Hillary Clinton Launch of the Asia Society’s Series of 

Richard C. Holbrooke Memorial Addresses,” February 18, 2011; DOD, Report on Progress Toward 

Security and Stability in Afghanistan, October 2011, p. 14.

310 Rubin, “What I Saw in Afghanistan”; Chandrasekaran, “Karzai Rift Prompts U.S. to Reevaluate 

Anticorruption Strategy in Afghanistan.”
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 115

311 White House, “Enduring Strategic Partnership Agreement Between the United States of America 

and the Islamic Republic of Afghanistan,” May 2, 2012, p. 3; White House, “Fact Sheet: The U.S.-

Afghanistan Strategic Partnership Agreement,” May 1, 2012.

312 White House, “Enduring Strategic Partnership Agreement Between the United States of America and 

the Islamic Republic of Afghanistan,” May 2, 2012, pp. 6-7.

313 White House, “Fact Sheet: The U.S.-Afghanistan Strategic Partnership Agreement,” May 1, 2012; 

White House, “Enduring Strategic Partnership Agreement Between the United States of America and 

the Islamic Republic of Afghanistan,” May 2, 2012, p. 7.

314 U.S. Embassy Kabul, “Scenesetter for CODEL McKeon, March 7-12,” Kabul 469 cable, March 2, 

2013, p. 3; David Zucchino, “Karzai reportedly seeks Obama letter on Afghan civilian casualties,” 

LA Times, November 18, 2013; James Dobbins, “Testimony before the House Foreign Affairs 

Committee,” Hearing on “Afghanistan 2014: Year of Transition,” December 11, 2013.

315 James Dobbins, “Hearing before the House Foreign Affairs Committee,” hearing on “Afghanistan 

2014: Year of Transition,” December 11, 2013; see also SIGAR, Quarterly Report to the United States 

Congress, January 30, 2014, p. 4.

316 Sudarsan Raghavan and Karen DeYoung, “U.S. and Afghanistan Sign Vital, Long-Delayed Security 

Pact,” Washington Post, September 30, 2014.

317 The Century Foundation, Afghanistan: Negotiating Peace: The Report of the Century Foundation 

International Task Force on Afghanistan and its Regional and Multilateral Dimensions, March 31, 

2011, p. 3; Hamish Nixon and Caroline Hartzell, Beyond Power Sharing: Institutional Options for 

an Afghan Peace Process, U.S. Institute of Peace, Christian Michelsen Institute, and Peace Research 

Institute Oslo, December 9, 2011, p. 5.

318 Clinton, “Remarks by Secretary of State Hillary Clinton Launch of the Asia Society’s Series of 

Richard C. Holbrooke Memorial Addresses,” p. 2.; U.S. Embassy Kabul, Afghanistan, Public Affairs 

Office, “SRAP Marc Grossman Afghan Media Roundtable Transcript,” March 5, 2011. 

319 Marc Grossman, “Lessons from Negotiating with the Taliban,” Yale Global Online, October 8, 2013; 

see also Karen DeYoung, “U.S. Speeds Up Direct Talks with Taliban,” Washington Post, May 16, 2011. 

320 Kabul International Conference on Afghanistan, A Renewed Commitment by the Afghan 

Government to the Afghan People, a Renewed Commitment by the International Community 

to Afghanistan, July 20, 2010, pp. 2-4, 7; London Conference, Afghan Leadership, Regional 

Cooperation, International Partnership, January 28, 2010, pp. 5-7; International Afghanistan 

Conference in Bonn, Afghanistan and the International Community: From Transition to the 

Transformation Decade, December 5, 2011, p. 2; Tokyo Conference on Afghanistan, The Tokyo 

Declaration, Partnership for Self-Reliance in Afghanistan: From Transition to Transformation, 

July 8, 2012, p. 4.

321 U.S. Embassy Kabul, “Zakhilwal Blames the IMF for Failure to Finalize Agreement,” Kabul 2912 

cable, May 16, 2011, p. 1; U.S. Embassy Kabul, “Afghan Attorney General Details Kabul Bank 

Investigation,” Kabul 5558 cable, August 10, 2011, pp. 1-2; U.S. Embassy Kabul, “Ambassador and 

Arsala Address Ulama Statement, Tokyo and Governance,” Kabul 519 cable, March 4, 2012, pp. 1-2; 

U.S. Embassy Kabul, “Tokyo Framework and Incentive Fund Updates following Joint Coordination 

and Monitoring Board (JCMB) Meeting,” Kabul 584 cable, February 6, 2014, pp. 1, 3; SIGAR, 

Quarterly Report to the United States Congress, April 30, 2014, pp. 9, 167-168.

322 U.S. Embassy Kabul, “Anticorruption in Afghanistan: Moving the Ball Forward,” Kabul 736 cable, 

February 25, 2013, p. 1.

323 John Allen, testimony before the U.S. Senate Foreign Relations Subcommittee on Near Eastern and 

South and Central Asian Affairs, hearing on “A Transformation: Afghanistan Beyond 2014,” April 30, 

2014, p. 28.

324 World Bank, Afghanistan Economic Update, October 2011, pp. 13-15; Tokyo Conference on 

Afghanistan, The Tokyo Declaration: Partnership for Self-Reliance in Afghanistan: From 
116 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

Transition to Transformation, July 8, 2012, pp. 4, 8; World Bank, Transition in Afghanistan: 

Looking Beyond 2014, November 18, 2011, p. 1.

325 U.S. Senate Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, S. 

Prt. 112-21 (2011), pp. 15-16; Subcommittee on National Security and Foreign Affairs, Warlord, Inc., 

pp. 3-4; GAO, Foreign Operations: Key Issues for Congressional Oversight, GAO-11-419T, March 

3, 2011, pp. 5-6, 8; Fishstein and Wilder, Winning Hearts and Minds?, p. 62; Joint Staff, Joint and 

Coalition Operational Analysis, Operationalizing Counter/Anticorruption Study, p. 12.

326 U.S. Senate Committee on Armed Services, Inquiry into the Role and Oversight of Private Security 

Contractors in Afghanistan, S. Rep. No. 111-345 (2010), p. 35.

327 CWC, Transforming Wartime Contracting, p. 1. 

328 Ibid, p. 1. 

329 Ibid, p. 29; see also McChrystal, COMISAF’s Initial Assessment, p. [2-18]; U.S. Senate Committee 

on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, S. Prt. 112-21, p. 13; 

Congressional Research Service, Wartime Contracting in Afghanistan, R42084, p. 2; Groenewald, 

Hammering the Bread and the Nail, p. iii.

330 Lamb and Mixon, Rethinking Absorptive Capacity, p. ix. 

331 François Bourguignon and Mark Sundberg, Absorptive Capacity and Achieving the MDGs, United 

Nations University Research Paper No. 2006/47, May 2006, p. 4. 

332 Lamb and Mixon, Rethinking Absorptive Capacity, p. 1. 

333 Lamb and Mixon, Rethinking Absorptive Capacity, pp. v, ix; Joel Brinkley, “Money Pit: The 

Monstrous Failure of U.S. Aid to Afghanistan,” World Affairs Journal, January/February 2013, 

p. 2; Ben Arnoldy, “Afghanistan War: USAID Spends Too Much, Too Fast to Win Hearts and Minds,” 

Christian Science Monitor, July 28, 2010, pp. 2-3.

334 SIGAR, Quarterly Report to the United States Congress, April 30, 2014, p. 5; Joint Staff, Joint and 

Coalition Operational Analysis, Operationalizing Counter/Anticorruption Study, pp. 1, 12.

335 Arnoldy, “Afghanistan War: USAID Spends Too Much,” Christian Science Monitor, p. 3.

336 World Bank, Transition in Afghanistan: Looking Beyond 2014, November 18, 2011, p. 1.

337 DFID, Why Corruption Matters, p. 26.

338 Bourguignon and Sundberg, Absorptive Capacity and Achieving the MDGs, p. 1. 

339 Jonathan Beynon, “Poverty Efficient Aid Allocations–Collier/Dollar Revisited,” Overseas 

Development Institute, November 2003, p. 6; Paolo de Renzio, “Increased Aid vs Absorptive 

Capacity: Challenges and Opportunities Towards 2015,” Institute of Development Studies, vol. 36, 

no. 3, September 2005, p. 22; Michael Clemens and Steven Radelet, “Absorptive Capacity: How Much 

Is Too Much?” in Challenging Foreign Aid: A Policymaker’s Guide to the Millennium Challenge 

Account, Center for Global Development, 2003, pp. 134-136; Reda Abou Serie, Laban Ayiro, Marlon 

Brevé Reyes, et al., “Absorptive Capacity: From Donor Perspectives to Recipients’ Professional 

Views,” paper commissioned by the Education for All Global Monitoring Project, United Nations 

Education, Scientific, and Cultural Organization, 2009, pp. 5-6.

340 SIGAR, Quarterly Report to the United States Congress, January 30, 2016, p. 187; SIGAR, Quarterly 

Report to the United States Congress, October 30, 2014, p. 202-3; World Bank, World Development 

Indicators: GDP at market prices, World Bank Databank.

341 U.S. Embassy Kabul, Draft Anticorruption Strategy, March 2010, p. 1.

342 Dixon, email to SIGAR, March 7, 2016; Sullivan and Forsberg, Confronting the Threat of Corruption, 

p. 161. 

343 Dixon, email to SIGAR, March 7, 2016; Sullivan and Forsberg, Confronting the Threat of Corruption, 

pp. 166-167.

344 Former official in the Afghan Attorney General’s Office, SIGAR interview, October 21, 2015.

345 U.S. Embassy Kabul, Draft Anticorruption Strategy, p. 1.

346 SIGAR, Quarterly Report to the United States Congress, January 30, 2016, pp. 143-147.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 117

347 U.S. Embassy Kabul, “Zakhilwal Blames the IMF,” Kabul 2912 cable, May 16, 2011, p. 2; U.S. Embassy 

Kabul, “Afghan Attorney General,” Kabul 5558 cable, August 10, 2011, pp. 1-2; U.S. Embassy 

Kabul, “Ambassador and Arsala,” Kabul 519 cable, March 4, 2012, p. 2; Canadian development 

official, SIGAR interview, February 18, 2016; former U.S. Embassy Kabul official, SIGAR interview, 

February 25, 2016.

348 U.S. Embassy Kabul, “Joint Coordination and Monitoring Board Quarterly Meeting: Focus on 

Kabul Process Follow-up and Afghan-led Transition,” Kabul 3833 cable, November 20, 2010, pp. 4-5; 

Canadian development official, SIGAR interview, February 18, 2016.

349 Alissa Rubin, “Karzai Says Foreigners are Responsible for Corruption,” New York Times, 

December 11, 2011.

350 SIGAR, Afghanistan’s Banking Sector, SIGAR 14-16-AR, p. 5.

351 MEC, Report of the Public Inquiry into the Kabul Bank Crisis, November 15, 2012, p. 13; U.S. 

Embassy Kabul, “Zakhilwal Blames the IMF,” Kabul 2912 cable, May 16, 2011, p. 1.

352 MEC, Report of the Public Inquiry into the Kabul Bank Crisis, November 15, 2012, pp. 13-14; 

SIGAR, Quarterly Report to the United States Congress, April 30, 2014, p. 10.

353 Former senior U.S. official, SIGAR interview, December 11, 2015.

354 U.S. Embassy Kabul, “Zakhilwal Blames the IMF,” Kabul 2912 cable, May 16, 2011, p. 2; U.S. Embassy 

Kabul, “Afghan Attorney General,” Kabul 5558 cable, August 10, 2011, pp. 1-2; U.S. Embassy Kabul, 

“Ambassador and Arsala,” Kabul 519 cable, March 4, 2012, p. 2.

355 Former senior U.S. official, SIGAR interview, December 11, 2015.

356 Senior Treasury Department official, SIGAR interview, October 1, 2015.

357 Treasury Department official, SIGAR interview, July 27, 2015; former U.S. Embassy Kabul official, 

SIGAR interview, February 25, 2016.

358 IMF, “Press Release: IMF Executive Board Approves US$133.6 Million Arrangement Under the 

Extended Credit Facility for the Islamic Republic of Afghanistan,” November 15, 2011; SIGAR, 

Quarterly Report to the United States Congress, January 30, 2012, pp. 131-132; Alissa Rubin, “Afghan 

Deal with IMF Will Revive Flow of Aid,” New York Times, October 6, 2011.

359 U.S. Embassy Kabul, “Anticorruption in Afghanistan,” Kabul 736 cable, February 25, 2013, p. 2.

360 MEC, Report of the Public Inquiry into the Kabul Bank Crisis, pp. 14-15.

361 SIGAR, Quarterly Report to the United States Congress, April 30, 2013, pp. 126-127. As of January 

2016, Kabul Bank Receivership reported $250.9 million of actual recoveries and $569.2 million total 

recoveries comprisingcash, forgiven debts, assets recovered/seized, and amounts still owed by 12 

major debtors who signed loan-repayment agreements. The Afghan government’s methodology for 

calculating “total recoveries,” however, is unclear, and it has been unable to compel full repayment 

from Farnood and Ferozi. The Kabul Bank Receivership said its main challenge in recovering cash 

and assets was inadequate pressure on borrowers to repay their debts, primarily because so many 

had significant political ties or allies. (SIGAR, Quarterly Report to the United States Congress, 

January 30, 2016, pp. 145-146.)

362 Dixon, email to SIGAR, March 7, 2016.

363 SIGAR, Quarterly Report to the United States Congress, January 30, 2014, pp. 83, 101, 118-119, 133-

134.

364 Ken Yamashita, former Mission Director, USAID Afghanistan, SIGAR interview, March 29, 2016; 

senior State Department official, SIGAR interview, April 26, 2016; former U.S. Embassy Kabul official, 

SIGAR interview, September 15, 2015.

365 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010. 

366 U.S. Embassy Kabul, “Anticorruption in Afghanistan,” Kabul 736 cable, February 25, 2013, p. 1.

367 Ibid, pp. 2-5.
118 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

368 SIGAR, Quarterly Report to the United States Congress, January 30, 2014, pp. 11, 136; former senior 

legal policy advisor at the MEC, SIGAR interview, March 1, 2016.

369 SIGAR, Afghanistan’s Mineral, Oil, and Gas Industries: Unless U.S. Agencies Act Soon to Sustain 

Investments Made, $488 Million in Funding is at Risk, SIGAR 15-55-AR, April 2015, pp. 19, 21.

370 Global Witness, “Gaps in new Afghan mining law pose a threat to stability,” August 19, 2014; see also 

Mary Beth Goodman and Trevor Sutton, “Tackling Corruption in Afghanistan: It’s Now or Never,” 

Center for American Progress, March 17, 2015, p. 11; and IRIN News, “Afghan mining law ‘could 

strengthen armed groups,’” August 28, 2014. 

371 GAO, Foreign Operations: Key Issues for Congressional Oversight, GAO-11-419T, pp. ii, 8-9; 

Congressional Research Service, Wartime Contracting in Afghanistan, R42084, p. 5.

372 Torabi, email to SIGAR, March 5, 2015.

373 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 20; USAID, Annex 1: Alternative 

Courses of Action for the High Office of Oversight, n.d., p. 1; SIGAR, Afghanistan’s High Office of 

Oversight, SIGAR 10-2-AR, p. 2.

374 SIGAR, Afghanistan’s High Office of Oversight, SIGAR 10-2-AR, p. 3.

375 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 17.

376 USAID, “Assistance for Afghanistan’s Anti-Corruption Authority (4A) Project: Annual Report – Year 

2,” October 28, 2012, p. 8; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a 

Finalized Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 9.

377 U.S. Embassy Kabul, “Rule of Law in Afghanistan: HOO Chairman Lodin Continues Public Campaign 

against Corruption,” Kabul 4620 cable, July 26, 2012; SIGAR, U.S. Reconstruction Efforts in 

Afghanistan Would Benefit from a Finalized Comprehensive U.S. Anticorruption Strategy, SIGAR 

10-15-AR, p. 6.

378 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; senior U.S. official, 

SIGAR interview, March 29, 2016.

379 Lianne Gutcher, “Afghanistan’s Anticorruption Efforts Thwarted at Every Turn,” Guardian. July 19, 

2011. 

380 U.S. Senate Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, 

S. Prt. 112-21, p. 19.

381 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; see also U.S. Senate 

Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, S. Prt. 112-21, 

p. 19.

382 U.S. Senate Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, 

S. Prt. 112-21, p. 19.

383 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015.

384 U.S. Embassy Kabul, “Anticorruption in Afghanistan,” Kabul 736 cable, February 8, 2013; SIGAR, 

Afghan Customs, SIGAR 14-47-AR, p. 1.

385 SIGAR, Afghan Customs, SIGAR 14-47-AR, p. 12.

386 Ibid, p. 16. 

387 U.S. Embassy Kabul, “Afghanistan: Attorney General Responds Positively to International Requests 

to Accelerate Vital Pay and Grade Reform,” Kabul 744 cable, February 8, 2011, p. 3; see also U.S. 

Embassy Kabul, “Afghanistan: Bamyan Governor Optimistic about Transition, but Formal Rule of 

Law Remains a Work in Progress,” Kabul 4790 cable, July 24, 2011.

388 U.S. Embassy Kabul, “Meeting with Attorney General Aloko on Anticorruption Efforts,” Kabul 2248 

cable, April 13, 2011; former Department of Justice attaché in Kabul, email to SIGAR, February 2, 

2016.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 119

389 U.S. Embassy Kabul, “Afghanistan: Attorney General Responds Positively,” Kabul 744 cable, 

February 8, 2011. These high-level efforts included a joint letter from Ambassador Eikenberry and 

General Petraeus to President Karzai, and persistent pressure on senior Afghan officials, in concert 

with other donors.

390 U.S. Embassy Kabul, “Consultations on Justice Sector National Priority Program,” Kabul 5038 cable, 

July 27, 2011, p. 1. In 2011, Afghan ministries were drafting National Priority Programs (NPP) to 

define the Afghan government’s top governance and development priorities. Each NPP was put 

forward to donors for approval as a joint Afghan-international plan. “Law and Justice for All” was 

GIROA’s NPP for the justice sector and included many anticorruption elements.

391 U.S. Embassy Kabul, “Rule of Law in Afghanistan: Progress Despite the Challenges,” Kabul 

8608 cable, December 18, 2011; former Department of Justice attaché in Kabul, email to SIGAR, 

February 2, 2016.

392 U.S. Embassy Kabul, “Anticorruption in Afghanistan,” Kabul 736 cable, February 25, 2013, p. 1.

393 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; U.S. Embassy Kabul 

documents: Anticorruption in Afghanistan: Recent Successes, February 25, 2013, p. 1; Kabul Bank 

Working Group Matrix and Engagement Strategy, February 23, 2013; Anti-corruption Rule of Law 

Engagement Strategy, February 24, 2013; and Borders Working Group and Engagement Strategy, 

February 23, 2013. 

394 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2105; senior State Department 

official, SIGAR interview, April 26, 2016.

395 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015.

396 U.S. Embassy Kabul, Anticorruption Rule of Law Engagement Strategy, February 24, 2013, p. 5.

397 State Department officials, SIGAR interview, December 16, 2015.

398 Associated Press, “Afghanistan government corruption remains despite President Karzai’s pledge to 

root out graft probes,” NY Daily News, October 11, 2011. 

399 Adam Goldman and Heidi Vogt, “Despite Karzai’s Pledge, Government Graft Eludes Prosecution,” 

Washington Times, October 12, 2011, p. 1. 

400 U.S. Embassy Kabul, “Afghanistan: Head of High Office of Oversight Lodin Discusses Concerns, 

Priorities and Frustration with Prosecutions,” Kabul 2494 cable, May 6, 2011, p. 1; U.S. Embassy 

Kabul, “The Afghan Supreme Court’s Control and Monitoring Department: A Rare Island of 

Anticorruption Integrity,” Kabul 4674 cable, July 18, 2011, p. 2; U.S. Embassy Kabul, “Rule of Law in 

Afghanistan: HOO Chairman Lodin,” Kabul 4620 cable, July 26, 2012, p. 1.

401 U.S. Embassy Kabul, “Rule of Law in Afghanistan: Administrative Anticorruption Tribunals Struggle 

to Curb Official Graft,” Kabul 8786 cable, December 21, 2011, p. 1.

402 SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, Appendix II, p. 29. Justice Department’s 

Rule of Law program was $22.8 million. The total expended by State, Justice, DOD, and USAID was 

$1.084 billion.

403 SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, pp. 11, 30.

404 Ibid, pp. 12-13.

405 Ibid, p. 13.

406 Former Department of Justice attaché in Kabul, email to SIGAR, February 2, 2016; U.S. Embassy 

Kabul, “The Afghan Supreme Court’s Control and Monitoring Department,” Kabul 4674 cable, July 18, 

2011, pp. 2-3.

407 U.S. Embassy Kabul, “The Afghan Supreme Court’s Control and Monitoring Department,” Kabul 4674 

cable, July 18, 2011, p. 1. 

408 Ibid, pp. 1-2.

409 U.S. Embassy Kabul, “Rule of Law in Afghanistan: Judicial Official on Corruption and Potential New 

Judges,” Kabul 2216 cable, April 30, 2012, p. 1.

410 Former Department of Justice attaché in Kabul, email to SIGAR, February 2, 2016.
120 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

411 Torabi, email to SIGAR, March 5, 2016; former Department of Justice attaché in Kabul, email to 

SIGAR, February 2, 2016.

412 SIGAR, Afghanistan’s Banking Sector, SIGAR 14-16-AR, pp. 6-7.

413 Ibid, p. 10.

414 Ibid, pp. 7-8; senior Treasury Department official, SIGAR interview, October 1, 2015.

415 SIGAR, Afghanistan’s Banking Sector, SIGAR 14-16-AR, pp. 7-8. 

416 GIROA Ministry of Finance, “Finance Minister and U.S. Treasury Secretary Sign MOU on Financial 

Capacity Building and Technical Assistance,” Press Release, March 30, 2015. 

417 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 6; Joint Staff, Joint and Coalition Operational Analysis, Operationalizing 

Counter/Anticorruption Study, pp. 21, 25.

418 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015.

419 USAID Afghanistan, Performance Evaluation: Afghanistan Media Development and Empowerment 

Project (AMDEP), April 3, 2012, p. 1.

420 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015. 

421 IWA, “CBM—Infrastructures,” December 29, 2014. IWA reported that by the end of 2014, local 

monitors had looked at approximately 900 projects in 35 districts within 7 provinces. Currently 

SIGAR has a cooperative agreement with IWA to conduct site visits, including inspections and 

engineering assessments of U.S.-funded projects.

422 Beyerle, Curtailing Corruption, pp. 169-185. 

423 Beyerle, SIGAR interview, September 24, 2015.

424 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; U.S. Embassy Kabul, 

“UNDP Describes Rule of Law Projects,” Kabul 6182 cable, August 25, 2011, p. 2.

425 SIGAR, Quarterly Report to the United States Congress, April 30, 2013, p. 129.

426 SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, pp. 32, 34.

427 John F. Sopko, SIGAR, “Remarks Prepared for Delivery,” Atlantic Council, Washington, DC, 

March 20, 2014; see also Goodman and Sutton, “Tackling Corruption in Afghanistan,” p. 9.

428 Matthew Rosenberg, “With Bags of Cash, C.I.A. Seeks Influence in Afghanistan,” New York Times, 

April 28, 2013. 

429 Matthew Rosenberg, “Karzai Says He Was Assured C.I.A. Would Continue Delivering Bags of Cash,” 

New York Times, May 4, 2013.

430 Rosenberg, “With Bags of Cash, C.I.A. Seeks Influence in Afghanistan.”

431 U.S. Senator Bob Corker, letter to President Barack Obama, May 2, 2013.

432 U.S. Senator Bob Corker, “Corker Continues to Seek Explanation from President Obama for Secret 

U.S. Cash Payments to Afghan President,” Bob Corker for United States Senate, May 14, 2013, http://

www.corker.senate.gov/public/index.cfm/news-list?ID=2FAB6CE1-C617-4C4B-8F11-7302E11E9158 

(accessed August 2, 2016).

433 Rosenberg, “Karzai Says He Was Assured C.I.A. Would Continue Delivering Bags of Cash.”

434 Ibid.

435 President Hamid Karzai, “Presidential Decree on Effective Combat against Corruption,” Presidential 

Decree No. 61, March 18, 2010, p. 2; London Conference, Afghan Leadership, Regional Cooperation, 

International Partnership, January 28, 2010.

436 MEC, “About Us—Mandate,” http://www.mec.af/#about-us (accessed August 2, 2016); U.S. Embassy 

Kabul, “Rule of Law in Afghanistan: MEC Visit Brings New Members and Focus on International 

Community,” Kabul 4752 cable, July 31, 2012. 

437 U.S. Embassy Kabul, “Rule of Law in Afghanistan: MEC Visit,” Kabul 4752 cable, July 31, 2012.

438 U.S. Embassy Kabul, “Monitoring and Evaluation Committee Discusses Ways Forward in 

Anticorruption,” Kabul 7226 cable, October 13, 2012, p. 1.

439 U.S. Embassy Kabul, “Anticorruption in Afghanistan,” Kabul 736 cable, February 25, 2013.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 121

440 U.S. Embassy Kabul, “Rule of Law in Afghanistan: MEC to Follow up on ‘Lessons Learned’ from 

Kabul Bank,” Kabul 2766 cable, May 26, 2012.

441 MEC, Report on the Implementation of Anticorruption Related Elements of Presidential Decree 45, 

March 13, 2013, p. 3. 

442 Torabi, email to SIGAR, March 5, 2016; MEC, Seventh Six-Month Report, March 4, 2015, ep. 3. 

443 USAID Office of Inspector General, Audit of USAID/Afghanistan’s On-Budget Funding Assistance 

to the Ministry of Public Health, Audit Report F-306-11-004-P, September, 2011, p. 1; SIGAR, Direct 

Assistance: USAID Has Taken Positive Action to Assess Afghan Ministries’ Ability to Manage 

Donor Funds, but Concerns Remain, SIGAR 14-32-AR, January 2014, p. 1. On-budget assistance 

is distributed in three ways: direct (bilateral) assistance, through host country contracts and 

government-to-government awards; contributions to multi-donor trust funds (such as ARTF, LOTFA, 

and Afghanistan Security Forces Fund); and direct budget support. 

444 John F. Sopko, “Challenges Affecting U.S. Foreign Assistance to Afghanistan,” testimony before the 

House Committee on Oversight and Government Reform, SIGAR 13-10T, April 10, 2013, p. 1.

445 U.S. Senate Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, 

S. Prt. 112-21, p. 18.

446 Mohammad M. Stanekzai, “Afghanistan: Not Lost, But Needs More Attention,” U.S. Institute of Peace 

briefing, June 2008, pp. 5-6. 

447 U.S. Senate Committee on Foreign Relations, Evaluating U.S. Foreign Assistance to Afghanistan, 

S. Prt. 112-21, pp. 18-19, 25. SIGAR found no analysis of whether on-budget or off-budget assistance 

is more susceptible to corruption.

448 Ibid, pp. 18-19.

449 Kabul International Conference on Afghanistan, Conference Communique, July 20, 2010, p. 2; 

London Conference, Afghan Leadership, Regional Cooperation, International Partnership, January 

28, 2010; The Tokyo Declaration, Partnership for Self-Reliance in Afghanistan: From Transition to 

Transformation, July 8, 2012, p. 4.

450 Kabul International Conference on Afghanistan, Conference Communique, pp. 2-3. 

451 Tokyo Mutual Accountability Framework, adopted at the Tokyo Conference on Afghanistan, July 8, 

2012, pp. 2-4.

452 U.S. Embassy Kabul, “Tokyo Framework and Incentive Fund,” Kabul 584 cable, February 6, 2014, p. 

4. The bilateral incentive program was divided into two tranches, one of $75 million in FY 2012 funds 

and one of $100 million in FY 2013 funds. The latter tranche was intended to be discussed with the 

new government, with an expectation of new metrics. 

453 U.S. Embassy Kabul, “Tokyo Framework and Incentive Fund,” Kabul 584 cable, February 6, 2014, 

pp. 2-4.

454 SIGAR, Quarterly Report to the United States Congress, April 30, 2014, pp. 163-164; SIGAR, HighRisk List, December 2014, p. 23. 

455 U.S. Embassy Kabul, “Tokyo Framework and Incentive Fund,” Kabul 584 cable, February 6, 2014, 

p. 4.

456 ISAF, COMISAF’s Counterinsurgency Contracting Guidance, September 8, 2010.

457 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 27.

458 Berthold, SIGAR interview, October 6, 2015.

459 Ibid.

460 Creal, SIGAR interview, March 23, 2016.

461 Berthold, SIGAR interview, October 6, 2015; Creal, SIGAR interview, March 23, 2016.

462 Meyer, email to SIGAR, March 6, 2016; former USAID vendor vetting official, SIGAR interview, 

December 8, 2015.
122 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

463 Congressional Research Service, Wartime Contracting in Afghanistan, R42084, p. 10. Suspensions 

and debarments are “actions taken by U.S. agencies to exclude companies or individuals from 

receiving federal contracts or assistance because of misconduct.” They are considered an important 

tool for ensuring that agencies award contracts only to responsible entities. As of the end of 

December 2015, “the efforts of SIGAR to utilize suspension and debarment to address fraud, 

corruption, and poor performance in Afghanistan [had] resulted in a total of 129 suspensions, 374 

finalized debarments, and 28 special entity designations of individuals and companies engaged in 

U.S. funded reconstruction projects.” (SIGAR, Quarterly Report to the United States Congress, 

January 30, 2016, pp. 36-37.)

464 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 27.

465 Berthold, SIGAR interview, October 6, 2015.

466 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 14.

467 Ibid, pp. 14-16.

468 DOD, response to SIGAR data call, December 2, 2015, pp. 5-6.

469 Ibid, p. 6.

470 SIGAR, Contracting with the Enemy, SIGAR 13-6-AR, p. 2. 

471 Ibid, p. 4.

472 Ibid, p. 8.

473 Task Force 2010 member, SIGAR interview, March 7, 2016; former USAID vendor vetting official, 

SIGAR interview, December 8, 2015.

474 Former Task Force 2010 member in Kabul, SIGAR interview, October 6, 2015; Task Force 2010 

member, SIGAR interview, March 7, 2016; Creal, SIGAR interview, March 23, 2016. 

475 U.S. Embassy Kabul, “Proposed USAID/Kabul Vetting Support Unit,” Kabul 372 cable, January 22, 

2011.

476 U.S. Embassy Kabul, “Establishing Greater Acquisition Accountability in Afghanistan,” Kabul 2058 

cable, April 9, 2011.

477 State Department, “Cooperation to Achieve Greater Assistance Oversight,” State 45622 cable, 

May 11, 2011.

478 U.S. Embassy Kabul, “Accountable Assistance for Afghanistan (A3): Corrected Copy 2,” Kabul 4054 

cable, July 5, 2011.

479 U.S. Embassy Kabul, “Proposed USAID/Kabul Vetting,” Kabul 372 cable, January 22, 2011; U.S. 

Embassy Kabul, “Accountable Assistance,” Kabul 4054 cable, July 5, 2011.

480 USAID, email to SIGAR, June 28, 2016.

481 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 20; former USAID vendor 

vetting official, SIGAR interview, December 8, 2015.

482 Former USAID vendor vetting official, SIGAR interview, December 8, 2015.

483 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, pp. 15, 25-26.

484 Dixon, email to SIGAR, March 7, 2016.

485 Senior State Department official, SIGAR interview, January 14, 2016; Crocker, SIGAR interview, 

January 11, 2016.

486 Meyer, email to SIGAR, March 6, 2016; Dixon, email to SIGAR, March 7, 2016.

487 DOD, Enhancing Security and Stability in Afghanistan, December 2015, pp. 1-2.

488 Emma Graham-Harrison, “Ashraf Ghani: the intellectual president who can now put theory into 

practice,” Guardian, September 26, 2014.

489 The Asia Foundation, Afghanistan in 2015: Survey of the Afghan People, November, 2015, p. 10; 

Transparency International and Integrity Watch Afghanistan, National Integrity System Assessment: 

Afghanistan 2015, 2015, p. 14.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 123

490 World Bank, Worldwide Governance Indicators: Afghanistan, http://databank.worldbank.org/data/

reports.aspx?source=Worldwide-Governance-Indicators (accessed March 17, 2016).

491 Crocker, SIGAR interview, January 11, 2016.

492 Ashraf Ghani, “Afghan President Ashraf Ghani Address to Joint Meeting of Congress,” Washington, 

DC, March 25, 2015, http://www.rs.nato.int/article/transcripts/afghan-president-ashraf-ghani-addressto-joint-meeting-of-congress.html (accessed July 27, 2016).

493 SIGAR, Quarterly Report to the United States Congress, October 30, 2014, p. 66.

494 SIGAR, Quarterly Report to the United States Congress, July 30, 2015, pp. 56, 60.

495 SIGAR, Quarterly Report to the United States Congress, July 30, 2016, pp. 150, 153.

496 SIGAR, Quarterly Report to the United States Congress, January 30, 2016, pp. 144-145, 154; SIGAR, 

Quarterly Report to the United States Congress, July 30, 2015, p. 156.

497 Crocker, SIGAR interview, January 11, 2016.

498 SIGAR, Quarterly Report to the United States Congress, January 30, 2016, p. 187; SIGAR, Quarterly 

Report to the United States Congress, October 30, 2014, p. 202-3; World Bank, World Development 

Indicators: GDP at market prices, World Bank Databank.

499 Hussman, Working towards common donor responses to corruption, p. 3; see also Suhrke, When 

More is Less, p. 119, which cites an IMF calculation of foreign aid to Afghanistan in FY 2009-2010 as 

equivalent to 49.5 percent of GDP (IMF, Sixth Review Under the Arrangement Under the Poverty 

Reduction and Growth Facility, IMF Country Report No. 10/22, January 2010, p. 19). The Hussman 

report does not define “international assistance.” 

500 USAID, Assessment of Corruption in Afghanistan. 

501 Ibid, p. 1.

502 Ibid, p. 28.

503 Ibid, pp. 26-27.

504 Ibid.

505 Office of the Special Representative for Afghanistan and Pakistan, Anticorruption Action Plan for 

Afghanistan, May 21, 2009.

506 Ibid, p. 1.

507 Ibid.

508 Ibid, pp. 1-2.

509 Ibid, p. 1.

510 U.S. Embassy Kabul, “Supporting COIN—Increasing Access to Justice in Afghanistan,” Kabul 1573 

cable, June 20, 2009, p. 1.

511 Ibid, p. 1.

512 Ibid.

513 Ibid, p. 4.

514 Ibid, p. 1.

515 U.S. Embassy Kabul and USFOR-A, The U.S. Government Integrated Civilian-Military Campaign 

Plan for Support to Afghanistan, August 2009.

516 Ibid, p. i.

517 Ibid, p. 1.

518 Ibid, pp. 5, 7-8, and 13.

519 Ibid, title page.

520 State Department, U.S. Government Rule of Law Strategy for Afghanistan, September 2009. 

521 SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, p. i.

522 State Department, U.S. Government Rule of Law Strategy for Afghanistan, September 2009, p. 1.

523 Ibid, pp. 6-7; SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, p. 5.

524 State Department, U.S. Government Rule of Law Strategy for Afghanistan, September 2009, p. 1.
124 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

525 U.S. Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, October 2009; U.S. 

Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, April 2010.

526 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 5.

527 U.S. Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, April 2010, p. 1.

528 Ibid, pp. 1-2; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 5; senior State Department 

official, SIGAR interview, January 14, 2016.

529 U.S. Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, October 2009; U.S. 

Embassy Kabul, U.S. Government Anticorruption Strategy for Afghanistan, April 2010; SIGAR, 

U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized Comprehensive U.S. 

Anticorruption Strategy, SIGAR 10-15-AR, p. 5.

530 DOD, response to SIGAR data call, December 2, 2015, p. 2. For staffing, the ACTF used existing 

assets from ISAF. 

531 Ibid, p. 2.

532 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption Study, 

pp. 22-23.

533 DOD, response to SIGAR data call, December 2, 2015, p. 2.

534 Ibid, p. 2. Organization was transformed into CJIATF-Shafafiyat.

535 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption Study, 

p. 5.

536 Former Deputy Director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015.

537 U.S. Department of the Treasury, “Fact Sheet: Combating the Financing of Terrorism, Disrupting 

Terrorism at its Core,” Press Release; former Deputy Director, Afghan Threat Finance Cell, SIGAR 

interview, June 17, 2015.

538 Former Deputy Director, Afghan Threat Finance Cell, SIGAR interview, June 17, 2015.

539 Ibid.

540 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 4.

541 Ibid.

542 Ibid.

543 Ibid.

544 Ibid.

545 Kevin L. Perkins, Assistant Director, Criminal Investigative Division, FBI, “Statement Before the 

Commission on Wartime Contracting in Iraq and Afghanistan,” May 24, 2010, p. 1.

546 Ibid, p. 2; U.S Embassy Kabul, “Updated Text: Rule of Law in Afghanistan: Ongoing U.S.G Efforts to 

Address Huge Needs,” Kabul 1606 cable, May 6, 2010, p. 8.

547 U.S Embassy Kabul, “Updated Text: Rule of Law in Afghanistan: Ongoing U.S.G Efforts,” Kabul 1606 

cable, May 6, 2010, p. 8.

548 FBI, “Mission Afghanistan: Contract Corruption, Part 3: Holding Americans Accountable in a War 

Zone,” April 26, 2011.

549 Kevin L. Perkins, Assistant Director, Criminal Investigative Division, FBI, “Statement Before 

the Commission on Wartime Contracting in Iraq and Afghanistan,” May 24, 2010, p. 1; SIGAR, 

Investigations Directorate website, https://www.sigar.mil/investigations/ (accessed August 3, 2016).

550 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 4. 

551 Chlosta, “New task force stands up to combat contract corruption.”

552 Ibid. 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 125

553 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 4. 

554 Berthold, SIGAR interview, October 6, 2015.

555 Chlosta, “New task force stands up to combat contract corruption.”

556 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 4; DOD, response to SIGAR data call, December 2, 2015, p. 3.

557 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 15.

558 Ibid.

559 Ibid.

560 DOD, Report on Progress toward Security and Stability in Afghanistan, October 2011, p. 89.

561 Joint Staff, Joint and Coalition Operational Analysis, Operationalizing Counter/Anticorruption 

Study, p. 5; former ISAF official, SIGAR interview, December 16, 2015. 

562 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 9. This CENTCOM unit is 

referred to at various times as the vendor vetting reachback cell, vendor assessment cell, and vendor 

vetting cell. This report adopts the latter.

563 Ibid.

564 Ibid.

565 Ibid, p. 14.

566 Ibid, pp. 14-16.

567 DOD, response to SIGAR data call, December 2, 2015, pp. 5-6.

568 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 9; DOD, response to SIGAR 

data call, received on December 2, 2015, p. 4.

569 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, pp. 18-19; former USAID 

vendor vetting official, SIGAR interview, December 8, 2015.

570 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, pp. 18-19.

571 GAO, Operational Contract Support: Actions Needed to Address Contract Oversight, GAO-11-771T, 

June 30, 2011, p. 13.

572 GAO, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors, GAO-11-355, p. 20; former USAID vendor 

vetting official, SIGAR interview, December 8, 2015.

573 Former USAID vendor vetting official, SIGAR interview, December 8, 2015.

574 GAO, Operational Contract Support, GAO-11-771T, p. 13.

575 Ibid; former USAID vendor vetting official, SIGAR interview, December 8, 2015.

576 DOD, response to SIGAR data call, December 2, 2015, p. 2. Shafafiyat used existing assets from ISAF, 

then imported personnel as it grew. Shafafiyat had a staff of approximately 50, which varied over 

time. 

577 DOD, Report on Progress toward Security and Stability in Afghanistan, November 2010, p. 62.

578 Ibid.

579 CJIATF-Shafafiyat, Response to SIGAR quarterly report data call, September 8, 2011, p. 2. 

580 DOD, response to SIGAR data call, December 2, 2015, p. 2. Shafafiyat became “Essential Function 2 

(EF2)” when ISAF changed its mission from Operation Enduring Freedom to Resolute Support.

581 DOD, response to SIGAR data call, December 2, 2015, p. 2. CJIATF-A used existing assets from ISAF, 

with some new staff brought in, and had a staff of 12 people.

582 John Campbell, “Advance Policy Questions for General John C. Campbell, USA Nominee to 

Commander, International Security Assistance Force and Commander, United States Forces 

Afghanistan,” submitted to U.S. Senate Armed Services Committee, July 10, 2014, p. 4.

583 Ibid.

584 DOD, response to SIGAR data call, December 2, 2015, pp. 2-3.

585 Ibid, p. 2.
126 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

586 U.S. Embassy Kabul, “Update on Stand-Up of New Rule of Law Structure,” Kabul 4110 cable, 

August 30, 2010, p. 1.

587 Ibid, pp. 1-2.

588 Ibid, p. 1. 

589 Ibid, p. 2.

590 Senior State Department official, SIGAR interview, January 14, 2016.

591 Kristine Ziems, “U.S. Government Rule of Law Policy Coordination and Agency Programs,” The Rule 

of Law in Afghanistan–A Primer for Practitioners: Volume 1, Prepared for the U.S. Department 

of State Bureau of International Narcotics and Law Enforcement Affairs’ Office of Afghanistan and 

Pakistan, February 2014, pp. 4-5.

592 U.S. Embassy Kabul, “Update on Stand-Up,” Kabul 4110 cable, August 30, 2010, p. 2; Ziems, “U.S. 

Government Rule of Law Policy Coordination and Agency Programs,” pp. 4-5. IROL was set to close 

in June 2014, and a small team in the U.S. Embassy Political Affairs Section was expected to focus 

on anticorruption, among other issues.

593 U.S. Embassy Kabul, “Update on Stand-Up,” Kabul 4110 cable, August 30, 2010, p. 2.

594 Ibid; Ziems, “U.S. Government Rule of Law Policy Coordination and Agency Programs,” February 

2014, pp. 2-3.

595 U.S. Embassy Kabul, “New Structure to Support Rule of Law Efforts,” Kabul 2483 cable, July 1, 2010, 

pp. 2-3.

596 U.S. Embassy Kabul, “Update on Stand-Up,” Kabul 4110 cable, August 30, 2010, p. 2; Ziems, “U.S. 

Government Rule of Law Policy Coordination and Agency Programs,” pp. 2-3. 

597 U.S. Embassy Kabul, “Update on Stand-Up,” Kabul 4110 cable, August 30, 2010, p. 1; Ziems, “U.S. 

Government Rule of Law Policy Coordination and Agency Programs,” p. 3.

598 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; see also Civil-Military 

Fusion Centre, Corruption and Anticorruption Issues in Afghanistan, p. 14.

599 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015. 

600 Ibid.

601 Ibid.

602 Ibid.

603 DOD, Report on Progress toward Security and Stability in Afghanistan, April 2011, p. 79. 

604 Ibid; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 20. 

605 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, pp. 9, 17.

606 Ibid, pp. 17-18.

607 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; senior U.S. official, 

SIGAR interview, March 29, 2015; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit 

from a Finalized Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 7. 

608 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015.

609 SIGAR, Afghanistan’s Control and Audit Office Requires Operational and Budgetary 

Independence, Enhanced Authority, and Focused International Assistance to Effectively Prevent 

and Detect Corruption, SIGAR 10-8-AR, p. 1.

610 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, pp. 3, 7; SIGAR, Afghanistan’s 

Control and Audit Office, SIGAR 10-8-AR, p. 4.

611 SIGAR, Afghanistan’s Control and Audit Office, SIGAR 10-8-AR, p. 15.

612 Ibid.

613 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 7. In 2013, the Control and Audit 
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 127

Office was renamed the Supreme Audit Office, see also, MEC, “Backgrounder: MEC considers 

further strengthening of the Supreme Audit Office to be necessary,” June 1, 2014, p. 1. 

614 SIGAR, Afghanistan’s Control and Audit Office, SIGAR 10-8-AR, p. 15.

615 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 2. 

616 Ibid; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 14.

617 SIGAR, U.S. Agencies Have Provided Training and Support to Afghanistan’s Major Crimes Task 

Force, but Reporting and Reimbursement Issues Need to be Addressed, SIGAR 11-12-AR, July 19, 

2011, p. 2; U.S. Embassy Kabul, “Major Crimes Task Force–A Key Element of the Road Map for 

Fighting Corruption and Serious Crimes in Afghanistan,” Kabul 3419 cable, October 26, 2009, p. 2. 

618 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 2; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from 

a Finalized Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 14; DOD, Report 

on Progress toward Security and Stability in Afghanistan, April 2011, p. 76. The task force had a 

Corruption Investigation Unit and Technical Investigative Unit, which consisted of specialists from 

the Afghan Ministry of the Interior and the National Directorate of Security.

619 U.S. Embassy Kabul, “Major Crimes Task Force–A Key Element of the Road Map for Fighting 

Corruption and Serious Crimes in Afghanistan,” Kabul 3419 cable, October 26, 2009, p. 1. 

620 U.S. Embassy Kabul, “Interior Minister Mohammadi on Prison Searches, APPF and MCTF,” Kabul 

1466 cable, March 26, 2012, p. 2; U.S. Embassy Kabul, “Major Crimes Task Force–A Key Element 

of the Road Map for Fighting Corruption and Serious Crimes in Afghanistan,” Kabul 3419 cable, 

October 26, 2009, p. 3. 

621 SIGAR, U.S. Agencies Have Provided Training and Support to Afghanistan’s Major Crimes Task 

Force, but Reporting and Reimbursement Issues Need to be Addressed, SIGAR 11-12-AR, July 19, 

2011, p. 1; ISAF Public Affairs Office, “CJIATF-Afghanistan Signs MOU with Major Crimes Task 

Force,” August 14, 2013. FBI and other international law enforcement partners had withdrawn their 

personnel from the MCTF by the end of 2012. The MCTF signed a memorandum of understanding 

with CJIATF-A in August 2013 to use the information developed through the MCTF’s criminal 

investigations to feed ISAF’s military efforts.

622 Civil-Military Fusion Centre, Corruption and Anticorruption Issues in Afghanistan, p. 41. 

623 Ibid; SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p. 20. Prosecutors specialized in 

corruption investigations and received its cases from MCTF referrals.

624 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 5; SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, p. 13.

625 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 5.

626 SIGAR, Rule of Law in Afghanistan, SIGAR 15-68-AR, p. 13.

627 Ibid. 

628 SIGAR, U.S. Reconstruction Efforts in Afghanistan Would Benefit from a Finalized 

Comprehensive U.S. Anticorruption Strategy, SIGAR 10-15-AR, p 21.

629 Ibid.

630 DOD, Report on Progress toward Security and Stability in Afghanistan, April 2011, p. 79.

631 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 5; DOD, Report on Progress toward Security and Stability in Afghanistan, 

April 2011, p. 79.

632 U.S. Embassy Kabul, “Rule of Law in Afghanistan: Administrative Anticorruption Tribunals,” Kabul 

8786 cable, December 21, 2011, p. 1.
128 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

633 DOD, Report on Progress toward Security and Stability in Afghanistan, April 2011, p. 79.

634 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 2.

635 DOD, Report on Progress toward Security and Stability in Afghanistan, April 2011, p. 102.

636 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, pp. 2-3.

637 Ibid.

638 Ibid, p. 2; Combating Terrorism Archive Project, “Interview with Kirk Meyer.”

639 Combating Terrorism Archive Project, “Interview with Kirk Meyer.”

640 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 3.

641 GAO, Afghanistan Security, GAO-09-280, p. 35.

642 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 3.

643 Ibid.

644 Ibid.

645 Mark Koumans, Deputy Assistant Secretary for International Affairs, statement before the House 

Committee on Homeland Security Subcommittee on Oversight, Investigations, and Management, 

“Denying Safe Havens: Homeland Security’s Efforts to Counter Threats from Pakistan, Yemen, and 

Somalia,” June 3, 2011; U.S. Immigration and Customs Enforcement, “Afghan Students complete 

DHS law enforcement course in Georgia,” News Release, June 21, 2013.

646 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 5.

647 Ibid; U.S. Embassy Kabul, “Afghanistan: Barriers to Bringing Formal Justice to the Districts: Lack of 

Security; Low Prosecutor Pay; Lack of Housing,” Kabul 726 cable, February 8, 2011, p. 2.

648 U.S. Embassy Kabul, “Afghanistan: Barriers to Bringing Formal Justice to the Districts,” Kabul 726 

cable, February 8, 2011.

649 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, p. 5. 

650 U.S. Embassy Kabul, “Afghanistan: Barriers to Bringing Formal Justice to the Districts,” Kabul 726 

cable, February 8, 2011, p. 2.

651 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016, September 

12, p. 5.

652 SIGAR, Afghanistan’s Banking Sector, SIGAR 14-16-AR, pp. 6-8.

653 Ibid, p. 4.

654 Ibid, pp. 6-8.

655 Ibid.

656 Ibid, pp. 7, 10.

657 Ibid, pp. 6-8. In March 2015, Treasury signed a memorandum of understanding with the Afghan 

Finance Minister to restart support for capacity building to GIROA and technical assistance to DAB; 

see also GIROA Ministry of Finance, “Finance Minister and U.S. Treasury Secretary Sign MOU on 

Financial Capacity Building and Technical Assistance,” Press Release, March 30, 2015. 

658 U.S. Embassy Kabul, “Afghanistan: Advancing our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010, p. 4.

659 Ibid.

660 Ibid.

661 Ibid, p. 5.
SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016 129

662 Ibid, p. 4; IMF, Islamic Republic of Afghanistan: Detailed Assessment Report on Anti-Money 

Laundering and Combating the Financing of Terrorism, IMF Country Report No. 11/317, 

November 2011, p. 9.

663 U.S. Embassy Kabul, “Afghanistan: Advancing Our Anticorruption Strategy,” Kabul 4016 cable, 

September 12, 2010.

664 MEC, http://www.mec.af/ (accessed August 3, 2016). 

665 Ibid. 

666 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015. 

667 Ibid.

668 U.S. Embassy Kabul, “Rule of Law in Afghanistan: MEC Visit,” Kabul 4752 cable, July 31, 2012, p. 3; 

MEC, Report on the Implementation of Anticorruption-Related Elements of Presidential Decree 45, 

March 13, 2013, p. 3; Torabi, email to SIGAR, March 5, 2016.

669 Former U.S. Embassy Kabul official, SIGAR interview, September 15, 2015; see also the website for 

the MEC at http://www.mec.af/ (accessed August 2, 2016).
130 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

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150 SIGAR I CORRUPTION IN CONFLICT I SEPTEMBER 2016

ACKNOWLEDGMENTS

SIGAR acknowledges the invaluable contributions to this report from scores 

of individuals. 

We thank William Byrd, Senior Expert at the U.S. Institute of Peace; Sarah 

Chayes, Senior Associate at the Carnegie Endowment for International Peace; 

Katherine Dixon, Director of Transparency International’s Security and Defence 

Programme; Drago Kos, Chairman of the OECD Working Group on Bribery and 

former Commissioner on the Joint Independent Anticorruption Monitoring and 

Evaluation Committee (MEC); Kirk Meyer, former Director of the Afghan Threat 

Finance Cell; Jennifer Murtazashvili, Assistant Professor, Graduate School of 

Public and International Affairs at the University of Pittsburgh; Yama Torabi, 

former Director of Integrity Watch Afghanistan and current MEC chairman; and 

Scott Worden, former Director of SIGAR’s Lessons Learned Program and currently 

Director for Afghanistan and Central Asia Programs at the U.S. Institute of Peace. 

In addition, we thank our peer reviewers and acknowledge the more than 80 

individuals who gave generously of their time and allowed us to interview them 

at length. We are grateful for the contributions of all those at the Department 

of State, especially the Office of the Special Representative for Afghanistan 

and Pakistan; Department of Defense, Office of the Under Secretary of Defense 

for Policy; Department of Justice; and Department of Treasury who provided 

comments, both officially and informally. 

Report Staff

Kate Bateman, Senior Analyst and Lead Writer

Nikolai Condee-Padunov, Research Analyst

Kim Corthell, Acting Lessons Learned Program Director

Brittany Gates, Research Analyst 

Matthew Rubin, Research Analyst

James Wasserstrom, Strategy Advisor and Team Lead

Elizabeth Young, Editor
Cover photo credit: Getty Images

PAKTIKA

KHOWST

TAKHAR

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KUNDUZ

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FARAH

NIMROZ

HELMAND

KANDAHAR

URUZGAN

ZABUL

GHOR

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BALKH

BADGHIS

KABUL

KAPISA

PAKTIYA

LOGAR

LAGHMAN

JOWZJAN

PARWAN

SAR-E PUL

HERAT

DAYKUNDI

SAMANGAN

PANJSHIR
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