SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning

OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR AFGHANISTAN RECONSTRUCTION

U.S. Reconstruction Efforts in Afghanistan Would 

Benefit from a Finalized Comprehensive U.S. 

Anti-Corruption Strategy

August 5, 2010
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page i

OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR AFGHANISTAN RECONSTRUCTION

August 5, 2010

The Honorable Hillary Rodham Clinton 

U.S. Secretary of State 

The Honorable Karl W. Eikenberry 

U.S. Ambassador to Afghanistan 

General David Petraeus 

Commander, U.S. Forces-Afghanistan, and 

Commander, International Security Assistance Force

Dr. Rajiv Shah 

Administrator

U.S. Agency for International Development 

Earl Gast

USAID Mission Director to Afghanistan

This report discusses the results of the Office of the Special Inspector General for Afghanistan 

Reconstruction’s review of U.S. efforts to strengthen the anti-corruption capabilities of the Afghan 

government. It includes recommendations to finalize the draft U.S. anti-corruption strategy for 

Afghanistan and to consider increasing the level of assistance provided to key Afghan oversight 

institutions—particularly internal audit departments of Afghan government ministries.

A summary of this report is on page ii. This performance audit was conducted by the Office of the 

Special Inspector General for Afghanistan Reconstruction under the authority of Public Law No. 110-181

and the Inspector General Act of 1978, as amended. When preparing the final report, we considered 

comments from the U.S. Embassy in Kabul and USAID/Afghanistan. These comments indicated 

concurrence with our findings and recommendations. A copy of these comments is included in 

appendix V of this report. We also received technical comments on the draft report from the U.S. 

Embassy, USAID, and the Departments of Justice, Homeland Security, and Defense, which are 

incorporated, as appropriate, into the final report. Comments provided by CENTCOM, USFOR-A, and 

CSTC-A, although technical in nature, have been included as appendix VI of this report.

John Brummet

Assistant Inspector General for Audits

Office of the Special Inspector General 

 for Afghanistan Reconstruction
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page ii

SIGAR

Special Inspector General for Afghanistan Reconstruction

SIGAR Audit-10-15 August 2010

U.S. Reconstruction Efforts in Afghanistan 

Would Benefit from a Finalized 

Comprehensive U.S. Anti-Corruption Strategy

What SIGAR Reviewed

Fighting corruption and increasing accountability are important components of the U.S. reconstruction strategy for 

Afghanistan. This report by the Office of the Special Inspector General for Afghanistan Reconstruction (SIGAR) identifies

(1) U.S. assistance to help the Afghan government develop its anti-corruption capabilities and (2) the capacity of 

Afghanistan’s key anti-corruption institutions. To accomplish these objectives, we reviewed relevant U.S., Afghan, and 

international laws, conventions, standards, and development strategies. We also interviewed officials of the 

Departments of State, Defense, Treasury, and Justice, and the U.S. Agency for International Development (USAID), 

international organizations such as the World Bank and the United Nations Development Program, and various Afghan 

government institutions. We conducted our work in Kabul, Afghanistan, and Washington, D.C., from August 2009 to July

2010, in accordance with generally accepted government auditing standards. A detailed discussion of our scope and 

methodology is included in appendix I.

What SIGAR Found

Since 2002, the United States has appropriated more than $50 billion for reconstruction assistance in Afghanistan, and 

the Obama administration has recently submitted budget requests for an additional $20 billion to help the Afghan 

government build its capacity to defend itself and govern effectively. Whereas the majority of prior U.S. assistance 

bypassed the Afghan government by providing funds directly to contractors and nongovernmental organizations, the 

new U.S. funding approach calls for significantly more U.S. assistance to be channeled through the Afghan government. 

The success of this approach will depend to a large degree on the capacity of the Afghan government to manage U.S. 

reconstruction funds and protect them from waste, fraud, abuse, and other forms of corruption. Because corruption,

widely acknowledged to be a pervasive, systemic problem across Afghanistan, corrodes the Afghan government’s

legitimacy and undermines international development efforts, the United States has made strengthening the Afghan 

government’s capability to combat corruption a priority. Developing a more coordinated approach to build the capacity 

of Afghan oversight institutions becomes increasingly important as the U.S. government plans to provide much of its 

future reconstruction assistance to Afghanistan through the Afghan government. The U.S. Embassy has drafted a 

comprehensive anti-corruption strategy, and several U.S. agencies have assistance programs to help build the capacity 

of the Afghan government to combat corruption. However, the U.S. government has not yet approved the strategy to 

provide guidance to those agencies. Accordingly, the majority of U.S. assistance to Afghanistan has been provided 

without the benefit of such a strategy. While the Afghan government has established a number of anti-corruption 

institutions, they lack independence, audit authority, and capacity. U.S. anti-corruption efforts in Afghanistan have 

provided relatively little assistance to some key Afghan oversight institutions.

What SIGAR Recommends

To improve and direct U.S. anti-corruption efforts in Afghanistan and to help strengthen the capacity of Afghan 

government institutions to combat corruption and protect U.S. and other donor funds from waste, fraud, and abuse, 

SIGAR recommends that the U.S. Secretary of State:

1. Approve and implement the draft comprehensive U.S. anti-corruption strategy for reconstruction efforts in 

Afghanistan, and

2. Review key Afghan oversight institutions to determine whether the United States should provide them more 

assistance to strengthen their ability to combat corruption in Afghanistan and provide accountability over U.S. 

reconstruction funds channeled through the Afghan government.

The U.S. Embassy in Kabul and USAID/Afghanistan provided joint comments on a draft of this report. The comments 

reflected concurrence with and support for the report’s recommendations and outlined actions they have taken or will 

take to address both of the report’s recommendations.

For more information contact: SIGAR Public Affairs at (703) 602-8742 or PublicAffairs@sigar.mil
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page iii

TABLE OF CONTENTS

Background ...................................................................................................................................................2

A Finalized Comprehensive U.S. Anti-Corruption Strategy Is Needed to Help 

Build the Capacity of Afghan Oversight Institutions................................................................................3

Key Afghan Oversight Institutions Lack Adequate Independence, Audit 

Authority, and Capacity ...........................................................................................................................6

Conclusion.....................................................................................................................................................9

Recommendations......................................................................................................................................10

Comments...................................................................................................................................................10

Appendix I: Scope and Methodology.........................................................................................................12

Appendix II: U.S. Agencies and Multilateral Trust Funds With Anti-Corruption 

Programs and Activities In Afghanistan.................................................................................................13

APPENDIX III: Afghan Government Institutions With Significant AntiCorruption Responsibilities....................................................................................................................20

APPENDIX IV: Defining Corruption in Afghanistan.....................................................................................23

APPENDIX V: Comments From U.S. Embassy Kabul and USAID.................................................................24

APPENDIX VI: Comments from CENTCOM, USFOR-A, and CSTC-A............................................................26

ACRONYMS

ANDS Afghanistan National Development Strategy

ANSF Afghan National Security Force

ARTF Afghanistan Reconstruction Trust Fund

CAO Control and Audit Office

CENTCOM United States Central Command

CSTC-A Combined Security Transition Command-Afghanistan 

DEA Drug Enforcement Administration

HOO High Office of Oversight 

INL Bureau for International Narcotics and Law Enforcement Affairs

LOTFA Law and Order Trust Fund for Afghanistan

SIGAR Special Inspector General for Afghanistan Reconstruction 

USAID United States Agency for International Development

USFOR-A United States Forces-Afghanistan
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 1

U.S. Reconstruction Efforts in Afghanistan Would Benefit from a 

Finalized Comprehensive U.S. Anti-Corruption Strategy

Since 2002, the United States has appropriated more than $50 billion for reconstruction assistance in 

Afghanistan. In February 2010, the Obama administration submitted budget requests for an additional

$20 billion to help the Afghan government build its capacity to defend itself and govern effectively. The 

majority of U.S. assistance has been directly managed by U.S. agencies, bypassing the Afghan 

government. Consistent with a new donor approach adopted in January 2010, the United States plans 

to direct up to half of its future reconstruction assistance through Afghan government channels. 

However, this support is contingent on a reduction in corruption, among other things.

1

This report identifies (1) U.S. assistance to help the Afghan government develop its anti-corruption 

capabilities and (2) the capacity of Afghanistan’s key anti-corruption institutions. SIGAR has conducted 

several other audits to assess what the United States is doing to help build the capacity of Afghan 

institutions to prevent corruption and strengthen the rule of law within Afghanistan.

The success of 

this new funding approach will depend, to a large degree, on the capacity of the Afghan government to 

manage U.S. reconstruction funds and protect them from waste, fraud, abuse, and other forms of 

corruption. However, more than $50 billion in U.S. assistance has been provided for reconstruction in 

Afghanistan without the benefit of a comprehensive anti-corruption strategy and U.S. efforts in 

Afghanistan have provided relatively little assistance to some key Afghan oversight institutions.

2

To accomplish these objectives, we reviewed relevant U.S., Afghan, and international laws, conventions, 

standards, and development strategies. We interviewed officials of the Departments of State, Defense, 

Treasury, and Justice, and the U.S. Agency for International Development (USAID), international 

organizations such as the World Bank and the United Nations Development Program, and Afghan 

government institutions, and obtained information from the Department of Homeland Security. We 

conducted our work in Kabul, Afghanistan, and Washington, D.C., from August 2009 to July 2010, in 

 1 During a January 2010 multi-donor conference in London to discuss development assistance to Afghanistan, the 

United States, along with other members of the international donor community, committed to increase the 

percentage of reconstruction assistance delivered through the Afghan government to 50 percent in the next

2 years. This support was conditioned on the Afghan government’s progress in strengthening public financial 

management systems, reducing corruption, improving budget execution, and developing a financing strategy and 

government capacity to meet the goal. Conference participants confirmed their intention to establish a detailed 

roadmap with the Afghan government and to provide technical assistance to develop the government’s capacity to 

achieve its goal.

2 Two related audit reports were issued in December 16, 2009, and April 4, 2010, respectively. See SIGAR Report 

No. 10-2, Afghanistan’s High Office of Oversight Needs Significantly Strengthened Authority, Independence, and 

Donor Support to Become an Effective Anti-Corruption Institution and SIGAR Report No. 10-8, Afghanistan’s Control 

and Audit Office Requires Operational and Budgetary Independence, Enhanced Authority, and Focused 

International Assistance to Effectively Prevent and Detect Corruption.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 2

accordance with generally accepted government auditing standards and under the authority of Public 

Law No. 110-181 and the Inspector General Act of 1978, as amended. A detailed discussion of our scope 

and methodology is included in appendix I.

BACKGROUND

More than 30 years of conflict have weakened Afghan government institutions. The sheer size of 

international security and reconstruction assistance during the last few years has increased 

Afghanistan’s vulnerability to corruption, presenting a risk that could negate the efforts of the 

international community and the Afghan government to establish the institutional basis for good 

governance in Afghanistan. Transparency International’s Corruption Perception Index for 2009 ranked 

Afghanistan 179th out of 180 countries, making it—by that standard—the second most corrupt country in 

the world.3

Afghanistan’s constitution stipulates that the government is responsible for “maintaining public law and 

order and the elimination of administrative corruption.”

 

4

 Afghan leaders have publicly expressed a 

commitment to combat corruption within their country. For example, in February 2004 President Karzai 

signed—and in August 2008 the Afghan Parliament ratified—the United Nations Convention against 

Corruption, resulting in Afghanistan joining 139 other member states in a global fight against 

corruption.5

The Afghan government’s anti-corruption commitments are elaborated in the Afghanistan National 

Development Strategy (ANDS), both as part of its governance, rule of law, and human rights pillar, and 

as a cross-cutting theme toward the achievement of national development objectives. According to the 

ANDS, the Afghan government will focus on reducing administrative corruption, by increasing corruption 

monitoring, introducing additional programs to further limit potential corruption risks, and 

strengthening public complaints mechanisms. To help develop a national approach to fighting 

corruption, a presidential commission, chaired by Afghanistan’s Chief Justice, prepared a strategy of 

administrative reform and anti-corruption that evolved into a National Anti-Corruption Strategy. This

anti-corruption strategy was presented to President Karzai in 2008, after which he established the High 

Office of Oversight (HOO) to oversee the implementation of the strategy. In the Declaration of the 

International Conference in Support of Afghanistan held in Paris in June 2008, the Afghan government 

 The Convention introduces a comprehensive set of standards, measures, and rules that all 

countries can apply to strengthen their legal and regulatory regimes to fight corruption. It calls for 

preventive measures and the criminalization of the most prevalent forms of corruption in both public 

and private sectors. Further, the Convention made a major breakthrough by requiring member states to 

return assets obtained through corruption to the country from which they were stolen. 

 3 Transparency International’s Corruption Perceptions Index is based on 13 independent surveys given to countries 

throughout the world, and indicates the perceived level of public-sector corruption in a country/territory. 

However, not all surveys include all countries. The index’s stated confidence range indicates the reliability of the 

scores, and that—allowing for a margin of error—we can be 90 percent confident that the true score for 

Afghanistan lies within this range. According to the index, the most corrupt country in the world is Somalia.

4 Article 75 of the Constitution of Afghanistan.

5 According to the United Nations Office on Drugs and Crime’s website, Afghanistan became a signatory to the 

Convention on February 20, 2004, followed by parliamentary ratification on August 25, 2008.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 3

“reaffirmed its commitment to intensify actions to combat corruption and to take concrete steps to that 

effect.” This was followed by the London Conference in January 2010, during which President Karzai 

committed to strengthening his government’s anti-corruption program by, among other things,

empowering the HOO by increasing its independence and strengthening its powers. The London 

Conference was followed by a July 2010 conference in Kabul during which the Afghan government 

pledged to, among other things, submit an audit law to ensure the strengthening and the independence 

of the Control and Audit Office (CAO), Afghanistan’s supreme audit institution, which has audit authority 

over state and donor funds.

Since 2002, the United States has appropriated more than $50 billion for reconstruction assistance in 

Afghanistan. As part of that assistance, several U.S. agencies have designed significant programs or 

activities to directly or indirectly help strengthen the anti-corruption capabilities of Afghan government 

institutions. 

A FINALIZED COMPREHENSIVE U.S. ANTI-CORRUPTION STRATEGY IS NEEDED TO HELP BUILD 

THE CAPACITY OF AFGHAN OVERSIGHT INSTITUTIONS

Several U.S. agencies have implemented assistance programs that directly or indirectly help build the 

capacity of the Afghan government to combat corruption. A multi-agency working group based at the 

U.S. Embassy in Kabul has drafted a comprehensive anti-corruption strategy to provide guidance to 

those agencies to help improve the transparency and accountability of Afghan institutions to reduce 

corrupt practices and improve financial oversight, but the State Department has not yet approved the 

strategy. Developing a more coordinated approach to build the capacity of Afghan oversight institutions 

to fight corruption becomes increasingly important as the U.S. government plans to provide much of its 

future reconstruction assistance to Afghanistan through the Afghan government. Nevertheless, the 

draft U.S. anti-corruption strategy remains unapproved in Washington, D.C. Furthermore, U.S. agencies 

have provided relatively little assistance to key Afghan oversight institutions. 

Several U.S. Agencies Have Assistance Programs Designed to Directly or Indirectly Help the 

Afghan Government Combat Corruption

Because corruption corrodes the Afghan government’s legitimacy and undermines international 

development efforts, the U.S. government has made strengthening the Afghan government’s capability 

to combat corruption a priority. Although few U.S.-funded reconstruction programs are specifically 

designed to fight corruption in Afghanistan, a variety of programs contain significant anti-corruption 

elements. Based on reviews of documentation and interviews with U.S. government personnel, SIGAR 

has identified six U.S. departments or agencies with significant programs or activities designed to 

directly or indirectly help strengthen the anti-corruption capabilities of Afghan government institutions. 

These include the Departments of State, Treasury, Justice, Homeland Security, Defense, and USAID. In 

addition, the United States contributes to three multi-donor trust funds that provide funding for 

programs that support anti-corruption efforts in Afghanistan. 

Among other things, the State Department, through its Bureau for International Narcotics and Law 

Enforcement Affairs, focuses on strengthening the capacity of the Afghan Attorney General’s Office to 

better monitor, investigate, prosecute and appeal corruption cases. The Treasury Department provides 

technical assistance to help the Ministry of Finance improve its public financial management system and 

build the Central Bank’s capacity to identify and seize assets from terrorist organizations, narcotics 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 4

traffickers, and organized criminal groups. Justice Department efforts include assigning Assistant U.S. 

Attorneys, as well as employees of the Federal Bureau of Investigation, the Drug Enforcement 

Administration, and the U.S. Marshals Service, to train and mentor their Afghan counterparts. The 

Department of Homeland Security has established an attaché office at the U.S. Embassy to help the 

Afghan government develop its capacity to interdict, investigate, and prosecute individuals and 

organizations involved in bulk cash smuggling. The Defense Department, through its U.S. ForcesAfghanistan and Combined Security Transition Command-Afghanistan (CSTC-A), supports many of the 

efforts described above. CSTC-A provides advisors and mentors to senior officials at the Ministries of 

Interior and Defense, and also provides anti-corruption training to the Afghan National Police and 

Afghan National Army. USAID’s efforts to combat corruption in Afghanistan are largely focused on core 

governance and rule of law capacity development activities designed to strengthen transparency, 

accountability, and effectiveness at the national and sub-national levels of government.

See appendix II for more details concerning these U.S. programs or activities in Afghanistan with 

significant anti-corruption elements.

U.S. Government Lacks an Approved Comprehensive Anti-Corruption Strategy to Guide 

Agency Efforts in Afghanistan

Since August 2009, U.S. agencies have developed a variety of plans and strategies that discuss 

corruption issues in Afghanistan. Some of the recently developed plans and strategies include:

• The United States Government Integrated Civilian-Military Campaign Plan for Support to 

Afghanistan was issued in August 2009. This plan provides guidance from the U.S. Chief of 

Mission and the Commander of U.S. Forces-Afghanistan to U.S. personnel in Afghanistan. The 

plan represents the collaborative effort of all the U.S. government departments and agencies 

operating in Afghanistan and is based on close collaboration with the International Security 

Assistance Force and the United Nations Assistance Mission in Afghanistan to build effective 

civilian and military mechanisms for integrated assistance. To achieve its stated goal of helping 

the Afghan government obtain full responsibility for its own security and administration, the 

plan includes measures to ensure that U.S. assistance does not feed corruption or abuse of 

power in the Afghan government. Some of these measures include avoiding close association 

with corrupt officials and institutions and using leverage to change the behavior of those who 

seek personal gain over service to the Afghan people.

• In January 2010, the Department of State’s Special Representative for Afghanistan and Pakistan6

 6 In January 2009, President Obama and Secretary of State Clinton designated Richard Holbrooke as a Special Representative 

for Afghanistan and Pakistan (SRAP). In her remarks, Secretary Clinton said, “He will coordinate across the entire government 

an effort to achieve United States’ strategic goals in the region. This effort will be closely coordinated, not only within the State 

Department and, of course, with USAID, but also with the Defense Department and under the coordination of the National 

Security Council.”

issued a Regional Stabilization Strategy for Afghanistan and Pakistan that included a key 

initiative to “reduce corruption by strengthening institutions that can provide checks on 

government power.” This was to be done by improving financial oversight, building judicial 

capacity to investigate, prosecuting and removing corrupt officials, and empowering the Afghan 

public to participate in transparent and accountable governance. The goals of this strategy were 

to strengthen Afghan institutions to provide checks on government power and to tackle visible 

corruption so that the Afghan people can see that change is happening.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 5

In August 2009, a multi-agency anti-corruption working group based at the U.S. Embassy in Kabul, but 

comprised of representatives from a number of U.S. agencies in Washington and Kabul, worked to 

develop a comprehensive Anti-Corruption Strategy for Afghanistan. A draft strategy was approved by 

the U.S. Ambassador to Afghanistan in October 2009. However, comments from Washington, D.C., 

resulted in changes. Subsequently, events relating to the Afghan national conference in December 2009 

and the London Conference in January 2010 generated additional changes. The working group 

substantially revised the draft strategy again in March 2010, and the U.S. Ambassador to Afghanistan 

approved the revisions in April 2010. However, as of July 2010, the State Department in Washington 

had not approved the draft.

The most recent draft of the strategy includes four pillars designed to work in concert with international 

anti-corruption policies to help the Afghan government:

• Improve the transparency and accountability of its institutions to reduce corrupt practices

• Improve financial oversight

• Build judicial capacity to investigate, prosecute, punish, and remove corrupt officials from power

• Aid civil society organizations in educating and empowering the public to participate in

transparent and accountable governance

Among other things, the draft strategy focuses on (1) leveraging diplomatic and assistance tools to 

develop the political will to take fighting corruption seriously, (2) reforming civilian and military 

procurement practices, (3) achieving significant reform and independence of the High Office of 

Oversight, and (4) disclosing public information to highlight government anti-corruption actions and 

provide Afghan citizens additional resources to participate in accountable, transparent governance. 

The draft strategy also incorporates operating principles to help ensure that (1) the Afghan government 

leads the effort to develop and implement its anti-corruption strategy, (2) assistance is linked to 

improved governance using metrics agreed upon in advance with the Afghan government, and (3) U.S. 

assistance is coordinated with a number of other donors, including the United Kingdom’s Department 

for International Development, the United Nations Development Program, and the World Bank.

Further, the draft strategy provides guidance to help U.S. agencies improve accountability over 

reconstruction funds and fight corruption in Afghanistan by specifically:

• Revoking U.S. visas of corrupt Afghan officials, their families, and their colleagues.

• Certifying Afghan ministries that are capable of directly receiving U.S. assistance funds. 

• Auditing aid and development funds provided directly to the Afghan government. 

• Making greater use of electronic fund transfers in place of cash payments in U.S. government 

development activities. 

• Implementing measures to improve perceptions of U.S. government contracting, such as 

minimizing layers of subcontracting, creating more opportunities for Afghan organizations to 

receive direct grants, and comparing prices charged by contractors to market rates. 

• Identifying and vigorously prosecuting any U.S. or contractor personnel involvement in corrupt 

practices, such as taking or giving of kick-backs in the contracting process.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 6

The Government Performance and Results Act of 19937

Even though U.S. agencies have been heavily involved in Afghan reconstruction since 2002, the U.S. 

government did not begin developing an anti-corruption strategy for Afghanistan until 2009. A draft 

strategy was substantially completed by the end of 2009. However, as of July 2010, it had not yet been 

approved by the State Department. Officials at the U.S. Embassy in Kabul cited interagency discussions 

and modifications as reasons for the delay. As a result, more than $50 billion in U.S. assistance has been 

provided for reconstruction in Afghanistan without the benefit of a comprehensive anti-corruption 

strategy. Having a comprehensive anti-corruption strategy in place to guide agencies’ efforts becomes 

increasingly important as the U.S. government plans to provide much of its future reconstruction 

assistance to Afghanistan through the Afghan government.

and other best practices describe important

elements for implementing federal programs, such as leadership, agreed-upon standards, risk 

assessment, and a planning process that takes into account requirements and stakeholders. Taking a 

strategic approach to program implementation promotes transparency and helps ensure that a program 

is based on a sound plan that can achieve results and reduce potential risks to U.S. investments.

U.S. Plans to Increase Direct Assistance through the Afghan Government 

Since 2002, the United States has appropriated more than $50 billion for reconstruction assistance in 

Afghanistan. In February 2010, an additional $20 billion was requested to help the Afghan government 

build its capacity to defend itself and govern effectively. Whereas the vast majority of prior U.S. 

reconstruction assistance bypassed the Afghan government by providing funds directly to contractors 

and nongovernmental organizations, a new funding approach calls for channeling significantly more U.S. 

assistance through the Afghan government. 

During the January 2010 multi-donor conference in London to discuss development assistance to 

Afghanistan, the United States, along with other members of the international donor community, 

committed to increase the percentage of assistance delivered through the Afghan government to 

50 percent over the next 2 years. This change was in response to concerns that donor assistance spent 

outside the Afghan government system was less effective because it limited government ownership and 

failed to build the institutional capacity of the government to manage and implement its development.

However, donors at the London conference indicated this increase in direct assistance would be 

contingent on the Afghan government strengthening its public financial management systems, 

improving its budget execution, and reducing corruption.

KEY AFGHAN OVERSIGHT INSTITUTIONS LACK ADEQUATE INDEPENDENCE, AUDIT AUTHORITY, 

AND CAPACITY

In line with its publicly expressed commitments to combat corruption, the Afghan government has given 

a number of ministerial-level departments and offices a direct role in combating corruption. In 

particular, the HOO,the CAO, and internal audit departments of line ministries are key Afghan 

government oversight institutions with significant anti-corruption responsibilities.

8

 7 Public Law 103-62 (August 3, 1993).

However, as 

documented by SIGAR, USAID, and the World Bank, these institutions remain severely limited due to a 

lack of independence, audit authority, and capacity. 

8 Additional information on these and other Afghan institutions is included in appendix III.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 7

High Office of Oversight and Control and Audit Office

During a 2009 audit, SIGAR reported that the HOO suffered from serious shortcomings as an institution 

both in its operational capacity and the legislative framework on which it was based. These 

shortcomings seriously affected the HOO’s ability to effectively address its anti-corruption 

responsibilities. Despite initial efforts that generated limited progress, the HOO faced great challenges 

in building its capacity to fulfill its ambitious mandate. SIGAR concluded that development of the HOO’s 

human and operational capacity needed to be coupled with substantial legislative reform to provide 

“teeth” to the HOO’s mandate. Further, the audit found that the Afghan government had not invested 

the HOO with the appropriate authority or support to make it an effective oversight institution. In 

addition, SIGAR found that the HOO suffered from lack of qualified staff. Many of the HOO’s existing 

staff members had limited language and computer skills, and lacked capacity in program monitoring and 

evaluation, information gathering, and interviewing techniques. Although donor efforts to develop the 

HOO had benefited the institution during its first year of operation, the international community—and 

the U.S. government in particular—needed to improve coordination of assistance efforts and 

demonstrate more focused commitment and a greater sense of urgency regarding the HOO’s success. 

SIGAR’s 2010 audit of the CAO—Afghanistan’s Supreme Audit Institution with audit authority over all 

state entities within the central and provincial governments, as well as public enterprises and 

international donor funds—determined that, like the HOO, the CAO’s legislative framework was weak 

and did not provide it with sufficient independence or authority to serve as an effective anti-corruption 

institution. The CAO’s lack of independence interfered with its planning, reviewing, and reporting 

processes. For example, the head of the CAO, Afghanistan’s Auditor General, stated that the CAO was 

unwilling to take on audits that could be politically sensitive or that might be turned down by the Office 

of the President. In addition, Afghan law did not provide the CAO with the authority to demand access 

to necessary documents, officials, and premises or require audited entities to report on actions taken in 

response to CAO recommendations. Further, it did not require the CAO to report to the National 

Assembly or to publicly release its audit reports. Consequently, CAO’s reports often went 

unimplemented and unenforced. Despite significant assistance from the international community—

almost exclusively from the World Bank—SIGAR found that the CAO continued to suffer from severe 

internal capacity constraints, including a lack of qualified auditors. Even though the CAO had formally 

adopted the standards of the International Organization of Supreme Audit Institutions, due to lack of 

capacity, it had to rely on international advisors and contracted auditors to ensure that its audits 

complied with those standards. Finally, unclear mandates resulted in conflicting responsibilities, 

particularly with regard to Afghanistan’s Ministry of Finance. Many of the CAO’s existing staff members 

had limited language and computer skills and lacked capacity in program monitoring and evaluation, 

information gathering, and interviewing techniques. To conduct audits of donor funds in accordance 

with international standards, the CAO depends on international advisors provided by the World Bank.

Internal Audit Departments of Afghan Ministries

Internal auditing is a necessary component of the Afghan government’s capacity to deter fraud and 

corruption and safeguard Afghan and donor assets and is a basic requirement of an accountable 

financial management system. 

The Ministry of Finance is responsible for the management and execution of the Afghan national 

budget, the major portion of which is financed by international donor assistance—including from the 

United States. The internal audit department of the Ministry of Finance is an independent, objective 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 8

assurance and consulting office designed to bring a systematic, disciplined approach to evaluating and 

improving the effectiveness of the ministry’s risk management, control, and governance processes. A 

2009 USAID assessment of the Ministry of Finance noted improvement in the capacity of its internal 

audit department but indicated that it could further benefit from additional support to help build the

capacity of its staff. It recommended exploring the possibility of funding study tours, seminars, 

workshops, scholarships, and other training opportunities. Another 2009 USAID assessment stated that 

a corruption prevention agenda for the health and education sectors in Afghanistan needed to include 

the development of complaints intake and internal audit capacities to more systematically identify 

instances and areas of corruption. The same assessment noted that assistance for developing internal 

auditing skills had helped improve central government operations but that little of this effort had

reached governing bodies below the national level that are responsible for managing and executing local 

budgets. 

A 2008 World Bank assessment of Afghanistan’s public financial management performance gave the 

Afghan government’s internal audit function a low rating, particularly within the line ministries.9

U.S. Government Has Provided Limited Assistance to Key Afghan Oversight Institutions

 

According to the assessment, the capacity for internal audit in Afghan line ministries was weak. Their 

work did not meet any recognized professional standard, and there was little follow-up of audit 

recommendations. The World Bank recommended that formal academic and professional training in 

auditing should be made available for internal audit staff of line ministries. Further, it indicated that 

most internal audit manuals were outdated and needed to be revised based on modern internal audit 

practices that take into account the country’s current context. In addition, USAID’s Economic Growth 

and Governance Initiative directly links Afghanistan’s weak audit capacity with governmental corruption.

Despite the important role Afghan oversight institutions have in combating corruption in Afghanistan 

and providing accountability over U.S. reconstruction funds, only a relatively small percentage of U.S. 

funding has been employed to help build the capacity of these institutions. SIGAR audits of U.S. efforts 

to help strengthen the HOO and the CAO found that less than $1.2 million in U.S. assistance had been 

provided to those two key Afghan oversight institutions prior to 2010. In comparison, donors from the 

international community had committed to provide more than $20 million in assistance to those same 

institutions.

U.S. assistance for the HOO has been provided principally through USAID. USAID has budgeted more 

than $1 million through October 2009 to assist the HOO with start-up costs, computer support, training, 

equipment, media projects, and advisors. The international donor community, on the other hand, has 

demonstrated a more significant interest in and commitment to the HOO. The United Nations 

Development Program has committed $7.3 million over 3 years for HOO support through its 

Accountability and Transparency project,

10

 9 World Bank’s “Afghanistan Public Financial Management Performance Assessment,” dated May 2008.

which provides the HOO with advisors, security, and rent for 

office space and vehicles. 

10 UNDP’s Accountability and Transparency project is supported by contributions from the United Kingdom, 

Norway, and Italy.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 9

USAID is the only U.S. agency that has provided direct assistance to the CAO. However, USAID’s 

assistance to the CAO has totaled only $112,472 from November 2007 to January 2010, and was used 

primarily to fund conference and training attendance for a limited number of CAO staff. In contrast, the 

World Bank and UNDP have collectively provided the CAO with more than $13.5 million in assistance 

since 2004.

One reason for such minimal assistance from the United States, as explained above, is due to the lack of 

independence of these key oversight institutions. For example, a 2009 USAID-funded assessment of 

corruption in Afghanistan stated that the lack of independence of the CAO was a factor in donors 

choosing not to provide the level of support needed to fully professionalize CAO operations. Further, 

the draft U.S. anti-corruption strategy indicates that U.S. agencies should consider assisting the CAO’s 

external audit capacities only if it becomes independent. Another contributing factor may have been 

that corruption in Afghanistan was not always a focused concern. For example, the HOO Deputy 

Director General indicated that anti-corruption was not a big issue prior to 2009 and that there was no 

clear U.S. government strategy for addressing anti-corruption. With increased attention given to 

corruption in Afghanistan by world leaders and the media, there has been more of a focus on the HOO, 

and its role in fighting corruption, within the U.S. Embassy community in Kabul. 

In response to SIGAR’s findings and recommendations regarding the HOO and the CAO, the U.S. 

government has agreed to address the issues identified in the two audit reports. USAID has indicated 

that it plans to provide up to $30 million over 3 years to support the HOO and the U.S. Embassy plans to 

work with the CAO, Afghan government stakeholders, and international donors to formulate and 

implement a capacity development plan for the CAO. While these are positive steps that should help 

strengthen the capabilities of the HOO and the CAO, there are indications that other key Afghan 

oversight institutions—particularly the internal audit departments of Afghan government ministries—

suffer from some of the same challenges. 

CONCLUSION

Since 2002, the United States has appropriated more than $50 billion for reconstruction assistance in 

Afghanistan and the Obama administration has recently submitted budget requests for an additional

$20 billion to help the Afghan government build its capacity to defend itself and govern effectively. 

Whereas the majority of prior U.S. assistance bypassed the Afghan government by providing funds 

directly to contractors and nongovernmental organizations, the new approach calls for significantly 

more U.S. assistance to be channeled through the Afghan government. However, the success of this 

approach will depend to a large degree on the capacity of the Afghan government to manage U.S. 

reconstruction funds and protect them from waste, fraud, abuse, and other forms of corruption. 

Because corruption, widely acknowledged to be a pervasive, systemic problem across Afghanistan,

corrodes the Afghan government’s legitimacy and undermines international development efforts, the 

United States has made strengthening the Afghan government’s capability to combat corruption a 

priority. However, the majority of U.S. reconstruction assistance to Afghanistan has been provided 

without the benefit of an approved comprehensive U.S. anti-corruption strategy.

The Afghan government has given a number of ministerial-level departments and offices a direct role in 

combating corruption. In particular, the HOO,the CAO, and internal audit departments of ministries are 

key Afghan government oversight institutions with significant anti-corruption responsibilities. However, 

these institutions remain severely limited due, in part, to the lack of political will on the part of the 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 10

Afghan government, and to the lack of independence, audit authority, and capacity. Despite the 

important role Afghan oversight institutions have in combating corruption in Afghanistan and providing 

accountability over U.S. reconstruction funds, only a relatively small percentage of U.S. funding has been 

employed to help build the capacity of these institutions. However, in line with recommendations from 

prior SIGAR audits, USAID is currently in the procurement stage of a plan to increase assistance to the 

HOO and is developing a plan to increase assistance to the CAO. In addition, although SIGAR has not 

conducted extensive audit work on the internal audit departments of Afghan ministries, we believe that 

they are key Afghan government oversight institutions that could play a critical role in combating 

corruption and protecting U.S. and other donor funds from waste, fraud, and abuse. Consequently, the 

U.S. government would benefit from helping to ensure the capacity of those institutions as well.

RECOMMENDATIONS

To improve and direct U.S. anti-corruption efforts in Afghanistan and to help strengthen the capacity of 

Afghan government institutions to combat corruption and protect U.S. and other donor funds from 

waste, fraud, and abuse, SIGAR recommends that the U.S. Secretary of State:

1. Approve and implement the draft comprehensive U.S. anti-corruption strategy for 

reconstruction efforts in Afghanistan.

2. Review key Afghan oversight institutions, particularly the internal audit departments of Afghan 

line ministries, to determine whether the United States should provide them more assistance to 

strengthen their ability to combat corruption in Afghanistan and provide accountability over U.S. 

reconstruction funds channeled through the Afghan government.

COMMENTS

The U.S. Embassy in Kabul and USAID/Afghanistan provided joint comments on a draft of this report. 

The comments are included in appendix V. In their comments, the Charge d’ Affaires, Coordinating 

Director for Rule of Law and Law Enforcement, Coordinating Director for Development and Economic 

Affairs, and USAID Mission Director indicated concurrence with and support for the report’s 

recommendations. The comments outlined actions to address the report’s recommendations, including: 

• Finalization of a comprehensive U.S. anti-corruption strategy in Afghanistan during the current 

calendar quarter; and 

• Development of a formal assessment process for Afghan line ministries and other governmental 

institutions.

The U.S. Embassy and USAID noted that the draft strategy had been approved by the U.S. Ambassador 

to Afghanistan on April 10, 2010, and sent to Washington, D.C., where it is awaiting approval of the 

Special Representative for Afghanistan and Pakistan. The comments further indicated that the U.S. 

Mission in Afghanistan anticipated that the strategy would be finalized by September 30, 2010, and that 

implementation of the draft strategy was already underway.

The U.S. Embassy and USAID also indicated support, in principle, for our recommendation to review key 

Afghan oversight institutions to determine whether to provide additional assistance to strengthen their 

ability to combat corruption and increase accountability for donor funds. The comments indicated that 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 11

USAID had already extended technical assistance to the CAO and announced a program to provide 

grants to promote Afghan civil society institutions. Further, the comments stated that USAID, in 

conjunction with the Department of State and other agencies, was developing a formal process to assess 

Afghan line ministries and other governmental institutions. However, the comments also noted that 

providing support to the internal audit departments of Afghan line ministries was problematic due to 

the unclear nature of internal audit responsibilities under current Afghan law. According to the 

comments, the U.S. government included resolution of this issue as a benchmark under the Afghanistan 

Reconstruction Trust Fund Incentive Program. The U.S. Treasury Department is also engaged with the 

Afghan government to help resolve this issue. 

In the comments, it was noted that SIGAR recommended that the U.S. government should invest in 

technical assistance for internal audit. As a point of clarification, SIGAR actually recommended that the 

review of Afghan oversight institutions should include the internal audit departments of Afghan line 

ministries to determine if more assistance was warranted to strengthen their ability to combat 

corruption and ensure accountability for U.S. reconstruction funds channeled through the Afghan 

government.

The U.S. Embassy in Afghanistan, along with USAID and the Departments of Justice, Homeland Security, 

and Defense, also provided technical comments to the draft report, which have been incorporated, as 

appropriate, into the final report. Comments by CENTCOM, USFOR-A, and CSTC-A, although technical in 

nature, have been included as appendix VI of this report.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 12

APPENDIX I: SCOPE AND METHODOLOGY

This report discusses the results of the Office of the Special Inspector General for Afghanistan 

Reconstruction’s review of U.S. and other donor efforts to strengthen the anti-corruption capabilities of 

the Afghan government. 

To review U.S.-funded programs designed to strengthen the capabilities of Afghan institutions to help 

reduce corruption in Afghanistan, we reviewed documentation from and conducted interviews with 

responsible officials from the U.S. Departments of State, Defense, Treasury, and Justice, and the U.S. 

Agency for International Development (USAID) in Washington, D.C., and Kabul, Afghanistan. Within 

those departments, we also held discussions with Department of State’s Bureau of International 

Narcotics and Law Enforcement Affairs, Special Representative for Afghanistan and Pakistan, and the 

U.S. Embassy-Kabul; Department of Justice’s Federal Bureau of Investigation and U.S. Marshals Service; 

and Department of Defense’s U.S. Forces-Afghanistan and Combined Security Transition CommandAfghanistan. We also obtained information from the Department of Homeland Security. A particularly 

useful source of information was a March 2009 report from a USAID-funded assessment of corruption in 

Afghanistan. To help assess the effectiveness of U.S. anti-corruption efforts from the Afghan point of 

view, we spoke with officials from the Ministry of Finance, the Ministry of Interior, the High Office of 

Oversight, and the Control and Audit Office.

To identify Afghan government institutions with significant anti-corruption responsibilities, we reviewed 

documentation from and conducted interviews with responsible officials from the U.S. Departments of 

State, Defense, Treasury, and Justice, and USAID in Washington, D.C., and Kabul, Afghanistan. We also 

reviewed documentation from and interviewed officials with the World Bank, United Nations 

Development Program, and United Nations Office on Drugs and Crime. To gain an understanding of 

anti-corruption efforts from the Afghan point of view, we spoke with officials from the Ministry of 

Finance, the Ministry of Interior, the High Office of Oversight, and the Control and Audit Office. We also 

reviewed documentation relating to the United Nations Convention against Corruption, the Asia 

Development Bank, and the Afghanistan National Development Strategy.

This report is part of a series of audits conducted by SIGAR to assess what the United States is doing to

help build the capacity of Afghan institutions to prevent corruption and strengthen the rule of law within 

Afghanistan. We conducted our work in Kabul, Afghanistan, and Washington, D.C., from August 2009 to 

July 2010 in accordance with generally accepted government auditing standards. These standards

require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on our audit 

objectives. The performance audit was conducted by SIGAR under the authority of Public Law No. 

110-181, and the Inspector General Act of 1978, as amended. 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 13

APPENDIX II: U.S. AGENCIES AND MULTILATERAL TRUST FUNDS WITH ANTI-CORRUPTION 

PROGRAMS AND ACTIVITIES IN AFGHANISTAN

U.S. Department of State - U.S. Embassy-Kabul

• Support for Central Ministries – The Economic Section of the Embassy supports anti-corruption 

efforts on a policy level with central ministries in Kabul. For example, this section encourages 

Afghan compliance with an International Monetary Fund program to reduce customs revenue 

leakage and supports efforts to strengthen banking supervision. 

• Support for Ministry of Interior – The Political and Political-military Sections of the Embassy 

support anti-corruption efforts at the policy level in many of their relationships with Afghan 

ministries and Parliament. For example, they have worked with other donors and the Ministry of 

the Interior to identify senior officials in the Ministry who were judged to be corrupt. A number 

of those officials have since been removed from their positions. 

• Justice Sector Support Program – The Bureau for International Narcotics and Law Enforcement 

Affairs (INL) strengthens the capacity of the Attorney General’s Office to monitor, investigate, 

prosecute, and appeal cases of corruption more efficiently, effectively, and fairly. To this end, 

the Bureau, with support from other U.S. and international law enforcement entities, is creating 

and will continually train and mentor an Anti-Corruption Unit within the Attorney General’s 

Office to consist of a specialized core of vetted prosecutors (and supporting staff) to investigate 

and bring to trial high-level cases of corruption. This unit will be based at the Major Crimes Task 

Force and has received funding from the Bureau. 

U.S. Department of Treasury

• Support for Ministry of Finance – The U.S. Department of Treasury has worked with the Ministry 

of Finance to improve the promulgation and enforcement of government regulation. Several 

International Monetary Fund program commitments and prior actions to increase revenue –

such as the collection of taxes from the state airline and the audit of the state fuel importer –

touch directly on the uniform application of law. Treasury provides technical assistance in 

support of Afghanistan’s public financial management reform efforts to help develop an 

efficient and effective public financial management system and increase the capacity of the 

Ministry of Finance to ensure better and more transparent management of public finances. 

• Support for the Central Bank – Treasury also supports efforts to combat illicit financial activity in 

Afghanistan by providing technical assistance to Afghanistan’s Central Bank to build capacity in 

anti-money laundering and terrorist financing, supervise the formal and informal financial 

sectors, and develop the capacity of financial intelligence analysts, financial crime investigators, 

and prosecutors to identify, investigate, prosecute, and seize assets from terrorist organizations, 

narcotics traffickers, and organized criminal groups. 

U.S. Department of Justice

• Justice Sector Support Program – The Department of Justice contributes to this program by 

vetting and training prosecutors and supporting staff for the Anti-Corruption Unit within the 

Afghanistan Attorney General’s Office. Two Assistant U.S. Attorneys were assigned to help 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 14

establish the Anti-Corruption Unit, and three more are expected to assist the unit by the end of 

2010.

• Criminal Justice Narcotics Task Force – The Department of Justice also has two Assistant U.S. 

Attorneys in Afghanistan to help mentor the Criminal Justice Narcotics Task Force, which has 

nationwide jurisdiction over major narcotics cases, including drug-related corruption cases. 

Three more Assistant U.S. Attorneys are expected to assist the Task Force by the end of 2010.

• Criminal Law Working Group – The Department of Justice attorneys in Afghanistan also work 

with the international community’s Criminal Law Working Group, which is currently working on 

amendments to the Criminal Procedure Code, including ways to streamline the investigation and 

prosecution of corruption. 

• Major Crimes Task Force – The Federal Bureau of Investigation vets, mentors, and provides 

training for the task force’s Corruption Investigation Unit (a joint initiative between the Ministry 

of Interior and National Directorate Service). The mission of the unit is to conduct corruption 

investigations of high-level Afghan government officials and then feed cases to the prosecutors 

at the Anti-Corruption Unit within the Afghanistan Attorney General’s Office.

Federal Bureau of Investigation 

• Afghan Judicial Security Unit – The U.S. Marshals Service, with funding support from INL, has 

provided guidance, training, and equipment to the Afghan Judicial Security Unit and assisted 

them in their transition to a new location adjacent to the U.S.-funded $11 million Counter 

Narcotics Justice Center, which now houses the Central Narcotics Tribunal and the investigators 

and prosecutors of the Counter-Narcotics Justice Task Force. Specifically, the U.S. Marshals 

Service has trained officers of the Judicial Security Unit in personal security details and executive 

protection. In addition, the U.S. Marshals Service has convinced the Ministry of the Interior to 

increase number of Judicial Security Unit officers and is in the process of conducting a more 

comprehensive assessment of a variety of courts throughout Afghanistan.

U.S. Marshals Service

• Counter-Narcotics Police of Afghanistan – The Drug Enforcement Administration (DEA) mentors 

a variety of vetted units within the Counter-Narcotics Police of Afghanistan that conduct 

significant drug trafficking and drug trafficking-related corruption investigations. DEA also plays 

a significant role in the Afghan Threat Finance Cell and conducts a variety of counter-drug 

operations with the U.S. military and the Afghan National Security Forces.

Drug Enforcement Administration

U.S. Department of Homeland Security

The Department of Homeland Security recently established an Immigration and Customs Enforcement 

attaché office at the U.S. Embassy in Kabul to help the Afghan government interdict, investigate, and 

prosecute individuals and organizations involved in bulk cash smuggling. To help combat the problem of 

corruption as it relates to U.S. donor assistance funds and the smuggling of bulk currency out of 

Afghanistan, the Department of Homeland Security is proposing a currency tracking program to trace 

the source of exported funds and exploit the intelligence gained through U.S. and Afghan partners. 

Special agents will partner with the Ministry of Interior, Central Bank authorities, and the Customs 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 15

Department under the Ministry of Finance to coordinate this financial tracking, recording, and 

exploitation initiative. The special agents will mentor Afghan partners through enforcement actions 

occurring, initially at the Kabul International Airport, and later expanding to other airports and border 

crossing points.

U.S. Department of Defense

USFOR-A, in coordination with the U.S. Embassy-Kabul, provides support for the following efforts:

U.S. Forces-Afghanistan (USFOR-A)

• Finance Sector – developing the concept of a Joint Illicit Finance Task Force in Kabul to integrate 

counternarcotics and counter-threat finance activities enabling strategic analysis, assessments, 

and case packaging, to address the linked issues of illicit financing, money laundering, and 

government corruption. 

• Major Crimes Task Force – establishing a U.S./Afghan Corruption Investigation Unit within the 

Afghan Major Crimes Task Force. 

• Attorney General’s Office – supporting the Afghanistan Attorney General’s Anti-Corruption 

Investigative Unit. 

• Justice Sector – assisting the Afghan corrections sector, including efforts to build capacity within 

the justice infrastructure, to strengthen the court systems, to expand and enhance legal 

education, and to mentor members of the Counternarcotics Justice Task Force. 

• Provincial Reconstruction Teams – sponsoring joint civil-military training for provincial 

reconstruction teams and ensuring that new civilians are trained on, and have access to, U.S. 

government provincial and district support plans for their areas.

In addition, U.S. Forces-Afghanistan has launched the following task forces in response to corruption 

issues:

• Task Force Spotlight – Launched in June 2010, this task force’s initial focus is to enforce 

compliance of U.S.-contracted private security companies operating in Afghanistan with existing 

requirements involving individual arming authority, biometric registration, and serious incident 

reporting. The task force also plans to evaluate policy, help develop more effective contracting

procedures, and continue to assist Ministry of Interior efforts to improve regulation of private 

security companies.

• Task Force 2010 – Already underway, this task force is projected to be fully operational in

August 2010. It plans to bring together an international civilian and military team to develop 

greater visibility on select sub-contracts. The task force focuses on four core competencies, 

including intelligence, contracting, forensic auditing, and criminal investigation. 

CSTC-A focuses on the development of ministerial systems and enduring institutions. Specifically, the 

Command seeks to develop systems within the Ministries of Interior and Defense to deter, identify, and 

prevent corruption. The desired outcome is a legitimate Afghan National Police and Afghan National 

Combined Security Transition Command-Afghanistan (CSTC-A)
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 16

Army that are based on accountability, transparency, rules and standards, compliance, and 

enforcement.

CSTC-A provides advisors and mentors to senior officials in support of the ministerial development and 

institutional training mission at the Ministries of Interior and Defense, respectively. Furthermore, the 

Command recently increased the number of advisors to each ministry’s Inspector General, procurement, 

and finance department. These additional advisors will assist their Afghan counterparts in establishing 

internal controls and oversight that will provide reasonable assurance that programs are executed 

according to applicable laws and regulations.

The Command supports rule of law initiatives and anti-corruption plans that are required by Afghan 

Presidential Decree for submission to the High Office of Oversight. The Ministry of Defense recently 

approved the plan for the Afghan National Army and the Ministry of Interior’s plan for the Afghan 

National Police is pending signature. CSTC-A supports these plans through the following initiatives:

• Anti-corruption training - The Command’s anti-corruption training program currently trains a 

significant portion of the Afghan National Security Force (ANSF) and is completing plans that will 

reach the entire force. The Ministry of Interior is in the process of instituting a code of conduct 

that will apply to all Afghan National Police and will be incorporated into their training.

• Electronic funds transfer for ANSF salary payments – The Command worked with the ministries 

and national banks to shift from paying salaries in cash to an electronic funds transfer system. 

Ninety-five percent of the Afghan National Army is currently enrolled in this system and 

77 percent of the Afghan National Police are enrolled. Further, the Command is testing a cell 

phone payment system in remote areas that lack banking services.

• Support to the Major Crimes Task Force – The Command has provided $17.9 million in 

operational support for the task force.

• Personnel asset inventory – The Command initiated a personnel inventory across the entire 

Afghan National Police to specifically identify police personnel throughout Afghanistan. This will 

help deter the collection of ghost salaries and excess funds for food and equipment. The first 

phase will collect the data on-site throughout the country and is 90 percent complete. Phase II 

will begin the analysis of actual data.

• Lottery appointments – The Command has encouraged the use of a lottery system for personnel 

assignments in the Afghan National Army. A lottery system encourages transparency and 

prevents personal connections from influencing decisions on a soldier’s assignment. This 

process has been used very successfully with recent graduates from the National Military 

Academy of Afghanistan and Medical Officer Basic Course.

• Afghan First – The Command has aggressively pursued procurement of goods produced within 

Afghanistan. Purchasing goods directly from Afghan manufacturers reduces corruption that 

occurs through middlemen in the contracting stream and the corruption associated with cross 

border transport of goods. For example, CSTC-A deals directly with several Afghan boot 

manufacturers for purchase of boots for ANSF and is considering adding other appropriate 

products to the Afghan First program.

• Anti-corruption directive to advisers – The CSTC-A Commanding General requires that all 

advisers receive anti-corruption training as part of their general advisor training. It is the duty of 

all CSTC-A personnel to report ANSF misconduct and criminal acts through their chain of 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 17

command. These reports are reviewed at the highest levels within the Command and are acted 

upon accordingly.

U.S. Agency for International Development (USAID)

USAID’s efforts to combat corruption in Afghanistan are largely focused on core governance and rule of 

law capacity development activities designed to strengthen transparency, accountability, and 

effectiveness at the national and sub-national levels of government.

• Strategic Support to Islamic Republic of Afghanistan Program – Through this program, USAID has 

provided critical start-up assistance to the High Office of Oversight. USAID has assisted with 

salaries for senior staff and funding for information technology systems, as well as support for 

training and outreach. 

• Afghan Civil Service Support – This program supports an Afghan-led effort to increase the 

effectiveness of ministries by reforming internal operational systems and instituting best 

practices and common Afghan standards. The objectives of this program are to (1) raise the skill 

levels of Afghan civil servants; (2) modernize, institutionalize, and harmonize administrative 

systems across ministries; and, (3) institutionalize a system for civil service training within the 

Afghan government.

• Office of the President/Support for the Center of Government – This assistance program 

(provided through a grant to the Afghan government and a cooperative agreement with the Asia 

Foundation) that has supported basic public administration capacity development, including 

financial management, human resources management, information technology, strategic 

communications, and other critical capacity development. 

• Afghanistan Rule of Law Program – This program addresses the judicial system and has provided 

training for more than 1,000 judges, supported the development of systems for case 

management, tracking, and open information for courts. It also worked to develop a code of 

ethics for judges. 

• Justice Sector Development Program – This new program is designed to build upon the 

Afghanistan Rule of Law Program to assist the Supreme Court’s ability to monitor and discipline 

judges, collect statistics on case flow, and make them publicly available. It will also design and 

implement a mechanism for enforcing the Judicial Code of Conduct. 

The following are additional anti-corruption activities that USAID has recently initiated or plans to 

initiate in the near future:

• Helped the Afghan government, Afghanistan’s High Office of Oversight (HOO) and others, to 

develop a strong anti-corruption policy, as presented by the Afghan government at the January 

2010 London Conference.

• Helped the Afghan government draft a Presidential Decree, signed by President Karzai on 

March 18, 2010, that provides significantly expanded investigative powers to the HOO; makes 

illegal political interference and obstruction of justice; provides the HOO with seconded judicial 

police; makes false personal asset declarations punishable administratively and criminally; 

requires the Ministry of Justice to review all laws and sanctions related to anti-corruption to 

make sure they exist and are appropriate to the crime; and requires the HOO to put in place 

within 90 days of signature an Anti-corruption Monitoring and Evaluation Committee of 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 18

prominent Afghans and international experts, to track the government's progress in the fight 

against corruption, as well as international assistance, and its impact on corruption.

• Assists the HOO in drafting an Executive Order that will require each ministry or agency of the 

Afghan government to prepare an anticorruption action plan with its top three priorities, which 

the HOO will be responsible for monitoring.

• Prepared draft terms of reference for the Anti-corruption Monitoring and Evaluation Committee. 

Initially approved by the HOO, they are being circulated for comment in the international 

community. USAID also drew up a list of potential international membership for the HOO's 

selection.

• Developed a new program of assistance for the HOO, consisting of up to $30 million over 3 years, 

which is in the process of being placed into operation. The project team, which USAID expects 

to be operational in August 2010, will support the HOO in carrying out its expanded mandate.

• Conducted discussions for providing assistance to the Control and Audit Office (CAO) through 

USAID’s "Economic Governance and Growth Initiative," and is planning for the Bureau of 

Supreme Audit in Iraq to visit Afghanistan in the near future to discuss the challenges of 

establishing a supreme audit institution in a conflict environment.

• Established a joint committee with U.S. Forces-Afghanistan and International Security Assistance 

Force on Contractor Vetting for Corruption. The first meeting was held April 17, 2010. The 

committee’s purpose is to arrive at a common system, with a common set of data, to vet 

international and Afghan prime- and subcontractors, to the extent possible, for their possible 

engagement in corrupt practices. The goal is to have the majority of U.S. government

contractual spending in Afghanistan covered by this new system.

• Preparing guidance to all civilians at Provincial Reconstruction Teams on "10 Things You Can Do 

to Fight Corruption." This will be linked to the corruption guidance initiative of the Department 

of State.

U.S. Participation in Multilateral Trust Funds

• The Afghanistan Reconstruction Trust Fund is a partnership between the international 

community and the Afghan government for the improved effectiveness of the reconstruction 

effort. Since 2002, 30 donors have contributed more than $3 billion, making ARTF the largest 

contributor to the Afghan budget—for both operating costs and development programs. ARTF’s 

support for national priority programs, for operating costs of government operations, and for 

the policy reform agenda is contributing to the achievement of the Afghanistan National 

Development Strategy goals, which include the promotion of transparency and accountability of 

reconstruction assistance. The United States has contributed more than $400 million to this 

trust fund from 2002 through 2009. 

• The Law and Order Trust Fund for Afghanistan was established by the United Nations 

Development Program to provide a mechanism for coordinating contributions from donors with 

the principle priority to cover police salaries and pursue other activities in accordance with 

project priorities. Specific areas for collaboration with anti-corruption projects such as the 

UNDP’s Accountability and Transparency project have been identified. Further, the trust fund is 

planning to establish eight regional offices to monitor donor contributions to the Afghan 

National Police by provincial audit inspection teams. The United States is the single largest 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 19

contributor, having committed $207 million since April 2008. The trust fund is nationally 

managed through the Ministry of Interior and is governed by UNDP’s financial rules and 

regulations. 

• The Counter-Narcotics Trust Fund, established in October 2005, is a multi-donor funding source 

that contributes to fulfilling objectives of the Afghan government’s National Drug Control 

Strategy—one of six cross-cutting issues cited in the Afghanistan National Development Strategy. 

The key principles behind the trust fund are to provide additional resources for the Afghan 

government’s counter-narcotics efforts through the national development budget, thus 

enabling the Afghan government to have greater ownership over implementation of its counternarcotics strategy. The United States has committed $15.1 million to the fund, the vast majority 

of which funded the Good Performers Initiative to support provinces that achieve sustained 

progress toward poppy elimination or remain poppy free by providing them financial resources 

to fund their priority development projects.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 20

APPENDIX III: AFGHAN GOVERNMENT INSTITUTIONS WITH SIGNIFICANT ANTI-CORRUPTION 

RESPONSIBILITIES

High Office for Oversight 

The High Office of Oversight (HOO) was created by Presidential Decree in July 2008 to oversee and 

coordinate the implementation of both the National Anti-Corruption Strategy and administrative 

procedural reform. The HOO has not been invested with investigative or prosecutorial powers, but is

empowered to monitor the progress of legal cases related to corruption in the appropriate law 

enforcement agencies and to ensure that action is being taken by those institutions. HOO leadership 

consists of a Director General who is appointed by the President. The HOO has established internal 

units with distinct but interrelated functions related to oversight, administrative reform, capacity 

development, and public awareness. 

Control and Audit Office

The Control and Audit Office (CAO) is responsible for auditing the financial matters of the Afghan 

government and is also mandated to identify deficiencies and inadequacies in public administration. 

The CAO ensures the implementation of systems and procedures and provides standards to the internal 

inspection and audit departments of ministries and agencies. The CAO can also make recommendations 

to improve laws and procedures. The Office provides external audits as “appropriate” to government 

clients; to date, these have been limited. The CAO and the Internal Audit Department in the Ministry of 

Finance have an ongoing disagreement over which agency has authority to oversee audits in ministries 

and departments, as authorized by the Public Financial Management Law, which provides for the 

establishment of internal auditors in each ministry.

Anti-Corruption Unit of the Attorney General’s Office 

The Anti-Corruption Unit is a specialized prosecution unit of the Attorney General’s Office. The Unit has 

prosecutors specializing in corruption investigations, primary court, appellate court, and the Supreme 

Court. All unit prosecutors are under the same director, who reports to the Attorney General. This 

vertical structure should reduce potential interference from other units and help guard against 

information leaks. The unit is connected with the Major Crimes Task Force, which is expected to provide 

significant case referrals.

Major Crimes Task Force

The Major Crimes Task Force is a partnership through which U.S. and international law enforcement 

agencies mentor Afghan counterparts by providing investigative and legal assistance. Afghanistan’s 

Minister of the Interior has indicated that he foresees the Major Crimes Task Force to be the prototype 

organization for the Afghan version of the U.S. Federal Bureau of Investigation. The task force includes a 

Corruption Investigation Unit whose mission is to conduct corruption investigations of high-level Afghan 

government officials. Although a new facility for the task force was inaugurated in February 2010, the 

task force had already achieved its first high-profile corruption arrest in October 2009. 
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 21

Anti-Corruption Tribunal

The Afghan Ministry of Justice has established the Anti-Corruption Tribunal to handle significant 

corruption cases, including cases from the provinces. By January 2010, the Afghan government had

appointed 11 justices to this new body, which was designed to combat abuse of power, while also 

encouraging and supporting Afghan efforts to remove and prosecute corrupt officials. 

Central Narcotics Tribunal

The Central Narcotics Tribunal has exclusive nationwide jurisdiction over significant narcotics cases

(i.e., cases involving more than 2 kilograms of heroin, morphine, or cocaine; more than 10 kilograms of 

opium; and more than 50 kilograms of hashish or precursors chemicals.) The Tribunal is housed in the

$11 million U.S.-funded Counter-Narcotics Justice Center.

Ministry of Finance’s Internal Audit Department

The Internal Audit Department of the Ministry of Finance is an independent, objective assurance and 

consulting activity designed to improve Ministry of Finance operations. It helps the ministry to 

accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the 

effectiveness of risk management, control, and governance processes.

Afghan National Police

The Afghan National Police is responsible for the initial “discovery” of crimes, such as corruption. After 

any unit of the police starts a case, the Criminal Investigation Department may investigate the case up to 

3 days after it is initiated, determining whether to refer the case to the Attorney General’s Office for 

possible prosecution.

National Directorate of Security

The National Directorate of Security has the mandate of countering organized crime, which can include

corruption. For corruption cases, the directorate is confined to gathering information and making 

referrals to the Attorney General’s Office, HOO, and the Police. Allegations involving high-level Afghan 

officials are then submitted to the President who decides on any further action.

Independent Administrative Reform and Civil Service Commission 

The Independent Administrative Reform and Civil Service Commission is responsible for human 

resources across the Afghan government. It has established human resource management systems, 

policies, and processes for the civil service, and is managing reforms to provide salary upgrades based 

on job descriptions and performance for selected civil service positions. The commission has also 

developed merit-based recruiting and promotion systems and procedures, which it is rolling out to the 

provincial level. These apply to all civil service positions in line ministries as well as the sub-national 

government. The commission has established an ambitious goal of training 16,000 civil servants, most 

of which work in provincial and district centers.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 22

High-Level Anti-Corruption Commission

The High-Level Anti-Corruption Commission, chaired by President Karzai, provides guidance and 

oversight to the HOO through monthly meetings to push ministries and departments into building anticorruption capacity, integrate actions across the government, and prosecute corrupt actions. 

Commission members include the Second Vice President, Chief Justice, Minister of Interior, Minister of 

Justice, Attorney General, National Security Advisor, Director General of the Administrative Affairs and 

Cabinet Secretariat, General Director of the Department of National Security, Chair of the Independent 

Administrative Reform and Civil Service Commission, Director General of the Independent Department 

for Local Governance, as well as the General Director and Deputy General Director of the HOO. 

Afghanistan Independent Human Rights Commission

The Afghanistan Independent Human Rights Commission focuses on the social and economic rights of 

Afghan citizens, but may also receive corruption complaints. Corruption falls under the commission’s 

mandate since it, by definition, violates human rights. The commission is not authorized to investigate 

complaints that relate to corruption, but may compile the information and forward it to the Attorney 

General’s Office for investigation. 

Parliamentary Commission on Judicial and Justice Affairs, Administrative Reform, and Anticorruption

The Parliamentary Commission on Judicial and Justice Affairs, Administrative Reform and AntiCorruption is charged with overseeing anti-corruption agencies and efforts and has the duty of 

proposing laws to combat corruption. According to a USAID-funded assessment, the commission meets 

irregularly, does not have a focused agenda, and is minimally effective.

Independent Electoral Commission

Afghanistan plans to hold a series of elections to select members of Parliament, governors, mayors, 

district heads, and provincial councils. These elections will be managed by the Independent Electoral 

Commission, which is responsible for doing so in a transparent and accountable way.

Internal Audit Departments of Line Ministries

Several Afghan line ministries have operating internal audit departments. However, according to a 

recent World Bank assessment, the internal audit work for most line ministries, except in the Ministry of 

Finance, is not done to any recognized professional standard, and there is little follow-up of audit 

recommendations.

Anti-corruption Monitoring and Evaluation Committee 

At the January 2010 London conference, the Afghan government agreed to invite Afghan and other anticorruption experts to participate in an ad hoc monitoring and evaluation mission. Its purpose will be to 

develop clear and objective benchmarks for progress and prepare periodic reports on national and 

international activity for the Afghan president, the National Assembly, and the Afghan people, as well as 

the international community.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 23

APPENDIX IV: DEFINING CORRUPTION IN AFGHANISTAN

Corruption is commonly defined throughout the world as the abuse of public position for private gain. 

Specific forms of corruption vary, but can include bribery, extortion, cronyism, nepotism, patronage, 

graft, and embezzlement. Afghan law lists 18 specific acts or crimes committed by government officials 

that would be considered as corruption, but does not include some types of corruption common in 

other parts of the world. For example, international representatives in Afghanistan have bemoaned the 

fact that the definition of corruption, as outlined in current Afghan law, does not mention nepotism or 

simony (the buying or renting of official positions). Nor does the Afghan Civil Service Code define what

constitutes a conflict of interest for civil servants or address the issue of making false claims.

According to a March 2009 USAID-funded assessment, corruption in Afghanistan exists on two levels: 

corruption of lower-level government officials and corruption of senior-level officials and their political 

allies or extended families. Identified drivers of lower-level corruption in Afghanistan include a limited 

supply of goods coupled with rising prices, while low government salaries can tempt government 

officials to seek illegal income through corrupt practices. USAID reports that senior-level corruption is 

particularly prevalent in Afghan construction and security industries, where the investment structure 

supports contracting with a limited pool of firms. According to USAID, contract awards are often 

controlled by upper-level officials in the Afghan government or the National Assembly, which can also 

lead to corruption.

According to the USAID assessment, efforts to fight corruption efforts generally fall under two 

categories—prevention and enforcement. Prevention efforts include the identification and mitigation of 

vulnerabilities that allow corruption to take place and the reduction of opportunities to commit 

corruption. An example would be a recent Afghan government project to simplify the vehicle 

registration process by reducing the number of steps required to register vehicles. The concept was to 

eliminate unnecessary interactions between the public and government officials that could lead to the 

demand for or payment of bribes. The number of registration steps was reportedly reduced from 51 to 

5. The World Bank has conducted a number of vulnerability-to-corruption assessments in Afghanistan 

that have identified areas of risk within various sectors. Enforcement efforts deal with rule-of-law 

systems to identify, try, and punish those who commit corrupt acts. In Afghanistan, the discovery of 

crime is the duty of the police, and prosecution of crimes the duty of attorney general’s office. Special 

tribunals have been established to help ensure that high-level corruption cases are adjudicated in a 

timely and proper manner. Proponents of enforcement efforts suggest that dealing harshly with corrupt 

officials also acts as a deterrent by causing potential wrongdoers to resist the temptation to commit 

corrupt acts to avoid similar punishment.

Interestingly, according to the USAID assessment, Afghans also believe that international assistance 

causes corruption in Afghanistan due to inefficiencies in high-cost delivery through international 

organizations, nongovernmental organizations, and contractors. Afghan perceptions of international 

“corruption” criticize perceived levels of high pay and overheads for contractors, consultants, and 

advisors as a form of corruption, irrespective of whether the applicable rules were followed in 

contracting. Further, the Afghan government views much of this assistance as corrupt simply because 

the resources are channeled outside the national budget and outside of their control. This “external 

budget” is a target of criticism regardless of whether outright corruption is involved.
SIGAR Audit-10-15 Anti-Corruption/Strategy and Planning Page 24

APPENDIX V: COMMENTS FROM U.S. EMBASSY KABUL AND USAID
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APPENDIX VI: COMMENTS FROM CENTCOM, USFOR-A, AND CSTC-A
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(This report was conducted under the audit project code SIGAR-007A).
SIGAR’s Mission The mission of the Special Inspector General for 

Afghanistan Reconstruction is to enhance oversight of 

programs for the reconstruction of Afghanistan by 

conducting independent and objective audits, inspections, 

and investigations on the use of taxpayer dollars and 

related funds. SIGAR works to provide accurate and 

balanced information, evaluations, analysis, and 

recommendations to help the U.S. Congress, U.S. agencies, 

and other decision-makers to make informed oversight, 

policy, and funding decisions to:

• improve effectiveness of the overall reconstruction 

strategy and its component programs;

• improve management and accountability over funds 

administered by U.S. and Afghan agencies and their 

contractors;

• improve contracting and contract management 

processes;

• prevent fraud, waste, and abuse; and

• advance U.S. interests in reconstructing 

Afghanistan.

Obtaining Copies of SIGAR 

Reports and Testimonies

To obtain copies of SIGAR documents at no cost, go to 

SIGAR’s Web site (www.sigar.mil). SIGAR posts all 

released reports, testimonies, and correspondence on its 

Web site.

To Report Fraud, Waste, and 

Abuse in Afghanistan 

Reconstruction Programs

To help prevent fraud, waste, and abuse by reporting 

allegations of fraud, waste, abuse, mismanagement, and 

reprisal contact SIGAR’s hotline:

• Web: www.sigar.mil/fraud

• Email: hotline@sigar.mil

• Phone Afghanistan: +93 (0) 700-10-7300

• Phone DSN Afghanistan 318-237-2575

• Phone International: +1-866-329-8893

• Phone DSN International: 312-664-0378

• U.S. fax: +1-703-604-0983

Public Affairs Public Affairs Officer

• Phone: 703-602-8742

• Email: PublicAffairs@sigar.mil

• Mail: SIGAR Public Affairs

400 Army Navy Drive

Arlington, VA 22202