GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

United States Government Accountability Office

Washington, DC 20548 

July 12, 2004 

Congressional Committees 

Subject: Treasury Continues Its Formal Process to Promote U.S. Policies at the 

International Monetary Fund

Congress has shown considerable interest in legislating U.S. policies regarding the 

International Monetary Fund (IMF or the Fund). Currently, the administration is 

charged with responding to dozens of legislative mandates related to the Fund, 

including advocacy for certain Fund policies, instructions for U.S. voting positions on 

Fund assistance to borrower countries, and requirements to report to Congress on 

various aspects of U.S. participation in the Fund. 

In 2003, we reported that the United States had 67 legislative mandates prescribing 

U.S. policy goals at the Fund. These mandates covered a wide range of policies, 

including combating terrorism, human rights, international trade, and weapons 

proliferation. As an international organization, the Fund is generally exempt from 

U.S. law. However, Congress can seek to influence IMF policy by directing the 

Secretary of the Treasury to instruct the U.S. Executive Director to pursue certain 

policy considerations or vote in a particular way on IMF programs or assistance to 

specific countries as part of his duties within the Board of the Fund.1

In 2000, Congress directed us to assess the Department of the Treasury’s efforts in 

advancing U.S. legislative mandates at the Fund. The Consolidated Appropriations 

Act for Fiscal Year 20002 requires us to report annually on the extent to which IMF 

practices are consistent with U.S. policies as set forth in federal law. In January 2001, 

we reported that the Treasury Department instituted a formal process in 1999 to 

systematically promote congressionally mandated policies at the Fund. We also 

found that while Treasury had had some influence over Fund policies, it was difficult 

to attribute the adoption of a policy within the Fund solely to the efforts of any one 

 

1

The Executive Board oversees the day-to-day business of the Fund. The Board is comprised of 24 

executive directors who are appointed or elected by member countries or by groups of member 

countries. The President appoints, with the advice and consent of the Senate, the U.S. Executive 

Director to represent the United States on the Board. 

2

P.L. 106-113 sec. 504 (e). 
Page 2 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

member because the Fund generally makes decisions on the basis of consensus.3 In 

February 2003, we provided an update on (1) the status of the U.S. Treasury’s process 

for advancing congressional mandates at the Fund and (2) the number of U.S. 

legislative mandates concerning the Fund. This report provides a similar update for 

2004. 

Results in Brief 

The U.S. Treasury continues to maintain a formal process for advancing U.S. policies 

at the Fund. A Treasury task force facilitates coordination between Treasury and the 

U.S. Executive Director and identifies early opportunities to influence decisions of 

Fund members. Since our February 2003 report, the task force has continued to meet 

biweekly to identify opportunities to advance legislative mandates at the Fund. The 

task force has made several efforts to enhance the monitoring and promotion of 

mandates—for example, by focusing attention on countries not yet on the IMF 

Board’s calendar but that are likely to require Fund assistance. 

We have identified a total of 67 legislative mandates that prescribe U.S. policy goals 

at the IMF, the same number as in our February 2003 report. Although the total 

number remained the same, some mandates have expired since our February 2003 

report and others have been added. New mandates address policy issues such as the 

lifting of economic sanctions on Iraq, human rights in Burma, and development 

assistance for Tibet. Treasury continues to notify the U.S. Executive Director about 

new mandates through instruction letters. 

Background 

The Department of the Treasury has the lead role within the executive branch for 

formulating U.S. policy toward the Fund. The U.S. Executive Director is appointed 

by the President and pursues U.S. policy objectives through his/her membership in 

the Fund’s Executive Board. Treasury’s Office of International Affairs, with the 

Office of the U.S. Executive Director of the IMF, formulates, evaluates, and 

implements Treasury policy concerning U.S. participation in the IMF, including the 

policy positions and directives set forth in legislative mandates. 

The legislative mandates that set forth U.S. policy regarding the Fund cover a range 

of issues. Some of these, such as exchange rate policy and emerging issues, including 

combating terrorism, are core to the Fund’s mission. This report classifies mandates 

into one of two broad categories: “policy” mandates and “directed vote” mandates.4 

 

3

See U.S. General Accounting Office, International Monetary Fund: Efforts to Advance U.S. Policies 

at the Fund, GAO-01-214 (Washington, D.C.: Jan. 29, 2001) and U.S. General Accounting Office, 

Treasury Maintains a Formal Process to Advance U.S. Policies at the International Monetary Fund, 

GAO-03-401R (Washington, D.C.: Feb. 7, 2003).

4

Reporting mandates, which require Treasury to report to Congress on various issues related to U.S. 

participation in the Fund, constitute a third category of legislative mandates. This report does not 

cover reporting mandates because they generally are not related to advancing U.S. policy goals at the 

Fund. 
Page 3 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Policy mandates seek to foster or advocate a certain policy at the IMF by directing 

Treasury to instruct the U.S. Executive Director to use his/her “voice” and/or “vote” 

on behalf of the United States at the Executive Board to bring about a policy change 

at the Fund. For example, the U.S. Executive Director is directed to encourage the 

IMF to adopt internationally recognized worker rights by borrowing countries. 

Directed vote mandates are more prescriptive in that they instruct the United States 

to “oppose” or “vote against” loans or other IMF assistance to particular countries or 

categories of countries. For example, the U.S. Executive Director is directed to 

oppose financial assistance for a country that is not compliant with the military 

spending and audits mandate, as shown in enclosure I. 

Treasury Has a Systematic Process for Promoting U.S. Legislative Mandates 

Treasury continues to have a systematic process in place to advance U.S. legislative 

mandates at the Fund. As we reported previously,5

 Treasury created the Task Force 

on Implementation of U.S. Policy and Reforms in the IMF in March 1999 to strengthen 

the process by which the United States pursues its objectives at the IMF. In 

particular, the task force was to increase awareness among Treasury staff about the 

mandates and identify early opportunities to provide input to the U.S. Executive 

Director to influence decisions regarding IMF members’ programs and economic 

reviews. Treasury also continues to make available to all relevant staff annual 

updates of its comprehensive legislative mandates manual, which contains all 

mandates applicable to U.S. participation in the Fund. 

The task force includes staff-level representatives from the regional and functional 

offices within Treasury’s Office of International Affairs, Treasury’s Office of the 

General Counsel, and the U.S. Executive Director’s office. Task force members 

continue to meet biweekly to discuss how Treasury and the U.S. Executive Director 

can best apply legislative mandates, given a country’s economic circumstances.6

 

According to Treasury officials, the task force serves an important role as a 

mechanism to systematically remind Treasury officials of the need to address 

legislative mandates. Prior to each biweekly meeting, task force members review a 

tentative schedule of IMF Executive Board meetings for upcoming weeks to stay 

abreast of what countries will be discussed by the Board. Also, Treasury officials 

may prepare for the meetings by obtaining information about other opportunities to 

attempt to influence the IMF. For example, Treasury officials may hold discussions 

with Fund officials when an IMF mission is planned to a particular country as part of 

negotiations for a new or existing program or an economic review. 

At the task force meetings, members discuss opportunities to implement mandates of 

potential relevance for specific countries. The aim of the discussion is to identify the 

best opportunities to make a credible and convincing case for pursuing a mandate at 

 

5

GAO-01-214; GAO-03-401R. 

6

Although the task force helps facilitate coordination between Treasury officials and the U.S. 

Executive Director, it is not the final arbiter for determining the U.S. policy position toward the IMF on 

any given issue. The task force is not a review or approval mechanism to give Treasury sanction to 

pursue individual mandates. 
Page 4 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

a given time. Once agreement is reached on how to pursue a mandate, Treasury 

country officers collaborate with U.S. Executive Director staff and functional 

specialists to draft a policy position for the U.S. Executive Director. The policy 

position can take the form of input for a written statement or talking points for an 

oral statement to the Executive Board. The U.S. Executive Director pursues U.S. 

objectives, including the legislative mandates, through various channels at the Fund. 

For example, the U.S. Executive Director regularly makes oral or written statements 

to the Board to apprise it of U.S. policy objectives regarding requests from countries 

for new programs, Fund reviews of existing programs, and regular Fund reviews of 

all members’ economic policies. 

Since creating the task force, Treasury has made occasional modifications to 

reinforce its efforts to monitor and promote legislative mandates at the Fund. For 

example, in March 2001, the task force expanded its agenda to include not only 

countries scheduled for discussion by the IMF Board but also countries that may 

need a program over the next several months. This enabled task force participants to 

focus attention on countries not yet on the Board’s calendar. Since April 2004, 

Treasury officials have initiated efforts to make the task force more useful for 

participants by, for example, reorganizing the meeting agenda into a table format that 

clearly indicates which mandates are relevant to which countries. They also 

categorized the countries under discussion by differentiating those that currently 

have an IMF program from those that may need one. Treasury officials also stated 

that they plan to modify the meeting format to cover mandates and policy issues in 

greater depth. They will, for example, focus a meeting on a certain set of topics and 

invite those staff representatives whose work relates to these topics to attend. 

No Change in Number of U.S. Legislative Mandates Concerning the IMF 

The number of U.S. legislative mandates concerning the IMF has not changed since 

our February 2003 report. Through our legal analysis, supplemented by 

documentation obtained from the Department of the Treasury, we identified a total of 

67 legislative mandates as of June 2004, the same number of mandates we identified 

in our February 2003 report. Our list includes one legislative mandate that Treasury 

does not include in its own compendium. This mandate, passed in 1980, was 

intended to help promote a policy of diversification of foreign exchange assets. 

According to a Treasury official, Treasury does not include this mandate in its own 

compendium because it has determined that the mandate has been overtaken by 

subsequent events and is outdated. 

Although the total number of mandates remains the same, each year some mandates 

expire and others are added. For example, one expired mandate relates to indirect 

financing for countries including China and North Korea that was contained in a 2002 

annual appropriations act. This mandate expired when the appropriated funds to 

which it applied were no longer legally available. New mandates address policy 

issues such as lifting of economic sanctions on Iraq, human rights in Burma, and 

support for development assistance to Tibet. Treasury continues to provide annual 

notification letters concerning new mandates to the U.S. Executive Director’s office. 

These notification letters instruct the U.S. Executive Director to take appropriate 

actions with respect to IMF mandates. 
Page 5 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Enclosure I identifies all directed vote and policy mandates that prescribe U.S. policy 

goals at the IMF under current federal law. The enclosure briefly describes the broad 

policy objectives the mandates address and some of the actions required by the U.S. 

Treasury and the U.S. Executive Director. The mandates date from 1945 to 2004, with 

the majority enacted in the last decade. Some mandates address multiple policy 

issues, sometimes overlapping one another. Enclosure II identifies some policies that 

are addressed in multiple mandates.7

 For example, nine mandates pertain to trade 

and seven pertain to debt issues. 

Agency Comments and Our Evaluation 

We received written comments on a draft of this report from the Department of the 

Treasury, which are reprinted in Enclosure III. Treasury concurred with the facts 

presented in this report. Treasury reiterated its position that the extensive legislative 

mandates could potentially undermine its effectiveness and influence at the Fund. 

Scope and Methodology 

To describe the current process that Treasury has in place to advance congressional 

mandates at the IMF, we reviewed the list of topics discussed in the biweekly task 

force meetings from January 2003 to May 2004, which summarizes major issues 

relating to the mandates. To determine the current number of IMF mandates, we 

analyzed Treasury’s compilation of legislative mandates pertaining to the 

international financial institutions and documents obtained through our own legal 

research. In addition, we reviewed a February 2004 memorandum for distribution 

from Treasury to the U.S. Executive Director concerning new mandates and 

Treasury’s 2004 compilation of legislative mandates applying to international 

financial institutions. We used two criteria to identify the relevant laws for this 

review. These criteria were (1) any current law that explicitly directs the U.S. 

Executive Director to the IMF to use his vote at the IMF to achieve a policy goal and 

(2) any current law that seeks to have the U.S. Executive Director use his voice at the 

IMF to promote a U.S. policy or make a policy change. To address both objectives, 

we also interviewed officials in Treasury’s Office of International Affairs and the 

Office of the General Counsel. 

We conducted this review from May to July 2004 in accordance with generally 

accepted government auditing standards. 

- - - - 

We are sending copies of this report to other congressional committees, the Secretary 

of the Treasury, the Managing Director of the International Monetary Fund, and other 

interested parties. Copies will be made available to additional requesters. This 

report will be available at no charge on the GAO Web site at http://www.gao.gov. 

 

7

Within enclosures I and II, mandates shown in bold represent mandates added since our last report in 

February 2003. Some of these mandates simply replace older mandates that had expired, while others 

cover new topics. 
Page 6 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

If you have any questions about this report, please contact Joseph A. Christoff at 202-

512-8979 and Stephanie J. May at 202-512-6293. We can also be reached by e-mail at 

christoffj@gao.gov and mays@gao.gov, respectively. Zina Merritt, Suzanne Dove, 

Mary Moutsos, Ashley Alley, Mark Speight, and Lynn Cothern made contributions to 

this report. 

Joseph A. Christoff 

Director, International Affairs and Trade 

Stephanie J. May 

Managing Associate General Counsel 

General Counsel 

Enclosures – 2 
Page 7 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

List of Congressional Committees 

The Honorable Richard Lugar 

Chairman 

The Honorable Joseph R. Biden, Jr. 

Ranking Minority Member 

Committee on Foreign Relations 

United States Senate 

The Honorable Ted Stevens 

Chairman 

The Honorable Robert C. Byrd 

Ranking Minority Member 

Committee on Appropriations 

United States Senate 

The Honorable Mitch McConnell 

Chairman 

The Honorable Patrick J. Leahy 

Ranking Minority Member 

Subcommittee on Foreign Operations, 

 Export Financing, and Related Programs 

Committee on Appropriations 

United States Senate 

The Honorable Bill Young 

Chairman 

The Honorable David R. Obey 

Ranking Minority Member 

Committee on Appropriations 

House of Representatives 

The Honorable Michael G. Oxley 

Chairman 

The Honorable Barney Frank 

Ranking Minority Member 

Committee on Financial Services 

House of Representatives 
Page 8 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Enclosure I 

U.S. Legislative Mandatesa

 Concerning the IMF 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

1 22 U.S.C. 262d 

Oct. 3, 1977 

Human rights, 

international 

terrorism, 

religious 

freedom, and 

others, 

including 

nuclear material 

acquisition 

The Department of the Treasury shall instruct the U.S. Executive 

Director (USED) to oppose loans to countries whose governments 

engage in a pattern of gross violations of internationally recognized 

human rights or provide refuge to individuals committing acts of 

international terrorism by hijacking aircraft, unless such assistance is 

directed to serve basic human needs. Severe violations of religious 

freedom should be considered in determining if the country has 

engaged in gross violations of internationally recognized human 

rights. Further, Treasury is to instruct the USED to consider a list of 

concerns when carrying out his/her duties, including whether 

recipient countries are seeking to acquire unsafeguarded special 

nuclear material. 

Yes 

2 22 U.S.C. 262e 

Oct. 3, 1977 

Salaries and 

benefits of IMF 

employees 

The President shall direct the USED to take all appropriate actions to 

keep the compensation for IMF employees at a level comparable to 

the compensation provided employees of both private business and 

the U.S. government in comparable positions. 

No 

3 22 U.S.C. 262h 

Oct. 15, 1986 

Trade, mining, 

and surplus 

commodities 

Treasury shall instruct the USED to use his voice and vote on behalf 

of the United States to oppose any IMF assistance for the production 

or extraction of any commodity or mineral for export, if it is in surplus 

on world markets and if the export of such commodity or mineral 

would cause substantial injury to the U.S. producers of the same, 

similar, or competing commodity or mineral. 

Yes 

4 22 U.S.C. 262k 

Aug. 15, 1985 

Impact of 

country 

adjustment 

programs on 

industries and 

commodity 

markets 

Treasury shall instruct the USED to consider, when reviewing loans, 

credits, or other uses of IMF resources, the effect that country 

adjustment programs would have on individual industries’ sectors 

and international commodity markets including specific criteria to be 

considered as a basis for a vote against certain mining and related 

project proposals. 

No 

5 22 U.S.C. 262k-1 

Sept. 30, 1996 

Military 

spending and 

audits 

Treasury shall instruct the USED to use his voice and vote to oppose 

any loan, other than for basic humanitarian needs, to any country 

that the Secretary of the Treasury determines does not have in place 

a functioning system for reporting to civilian authorities audits of 

receipts and expenditures that fund activities of the armed and 

security forces and that has not provided to the IMF information 

about the audit process requested by the institution. 

Yes 

6 22 U.S.C. 262k-2 

Sept. 30, 1996 

Female genital 

mutilation 

Treasury shall instruct the USED to use his voice and vote to oppose 

any loan, other than for basic humanitarian needs, for any 

government that the Secretary of the Treasury determines has a 

known history of practicing female genital mutilation and has not 

taken steps to implement educational programs designed to prevent 

this practice. 

Yes 

7 22 U.S.C. 262n-3 

Oct. 21, 1998 

Trade barriers 

and agricultural 

commodities 

Treasury shall instruct the USED to use aggressively his voice and 

vote to vigorously promote policies to encourage the opening of 

markets for agricultural commodities and products by requiring 

recipient countries to make efforts to reduce trade barriers. 

No 

8 22 U.S.C. 262o-1 

Aug. 23, 1994 

Military 

spending and 

good 

governance 

Treasury shall instruct the USED to consider, when deciding whether 

to support a country’s loan program, the extent to which IMF 

borrowing countries have demonstrated a commitment to (1) 

providing accurate and complete data on military spending; (2) 

establishing good and publicly accountable governance, including to 

end excessive military involvement in the economy; and (3) to make 

substantial reductions in excessive military spending and forces. The 

USED shall promote a policy that seeks to channel funding toward 

growth and development priorities and away from unproductive 

No 
Page 9 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

expenditures, including military spending. 

9 22 U.S.C. 262o-2 

Oct. 21, 1998 

Transparency, 

debt, private 

sector, trade, 

crisis lending, 

exchange rates, 

labor, the 

environment, 

military 

spending, 

sound banking, 

social safety 

nets, good 

governance, 

corruption, the 

poor, and 

ethnic and 

social strife 

Treasury shall instruct the USED to use aggressively his voice and 

vote to enhance the general effectiveness of the IMF with respect to 

numerous issues, including exchange rate stability, trade 

liberalization, antitrust reform, core labor standards, social safety 

nets, sound banking principles, private sector burden-sharing, 

disclosure of market information, debt, crises lending, good 

governance, procurement reform, corruption and bribery, drugrelated money laundering, excessive military spending, ethnic and 

social strife, environmental protection, transparency, and 

microenterprise lending, especially to the world’s poorest heavily 

indebted countries. 

No 

10 22 U.S.C. 262p-4n 

Nov. 5, 1990 

Equal 

employment 

opportunities at 

the IMF 

Treasury shall instruct the USED to use his voice and vote to urge 

the IMF to adopt policies and procedures that ensure that the IMF 

does not discriminate against any person on the basis of race, 

ethnicity, gender, color, or religious affiliation in any determination 

related to employment. 

No 

11 22 U.S.C. 262p-4o 

Aug. 23, 1994 

Respect for 

indigenous 

peoples 

Treasury shall direct the USED to use his voice and vote to bring 

about the creation and full implementation of policies designed to 

promote respect for and full protection of the territorial rights, 

traditional economies, cultural integrity, traditional knowledge, and 

human rights of indigenous peoples. 

No 

12 22 U.S.C. 262p-4p 

Aug. 23, 1994 

Internationally 

recognized 

worker rights 

Treasury shall direct the USED to use his voice and vote to urge the 

IMF to adopt policies to encourage borrowing countries to guarantee 

certain internationally recognized worker rights and to include the 

status of such rights as an integral part of the policy dialogue with 

each country. In addition, the USED shall urge the IMF to establish 

formal procedures to screen projects and programs for any negative 

impact in a borrowing country with respect to those rights. 

No 

13 22 U.S.C. 262p-4q 

Apr. 24, 1996 

State support of 

international 

terrorism 

Treasury shall instruct the USED to use his voice and vote to oppose 

any loan for a country for which the Secretary of State has made a 

determination that it is a terrorist state. 

Yes 

14 22 U.S.C. 262p-4r 

Oct. 26, 2001 

Terrorism Treasury may instruct the USED to use aggressively the voice and 

vote of the U.S. to require an auditing of IMF disbursements to 

ensure that no funds are paid to persons who commit, threaten to 

commit, or support terrorism. In addition, if the President determines 

that a country has committed to take actions that contribute to efforts 

of the U.S. to respond to, deter, or prevent acts of international 

terrorism, Treasury may instruct the USED to use the voice and vote 

of the U.S. to support any loan or other use of IMF funds for such 

country. 

No 

15 22 U.S.C. 262p-6 

Nov. 29, 1999 

Debt relief Treasury should urge the IMF to complete a debt sustainability 

analysis by December 31, 2000, and determine eligibility for debt 

relief for as many countries under the modified Heavily Indebted 

Poor Countries Initiative as possible. Treasury should also instruct 

the USED to ensure that an external assessment of the Heavily 

Indebted Poor Countries Initiative takes place by December 31, 

2001. 

No 

16 22 U.S.C. 262p-7 

Nov. 29, 1999 

Extended 

Structural 

Adjustment 

Facility reform 

Treasury shall instruct the USED to use his voice and vote to 

promote the IMF’s establishment of poverty reduction policies and 

procedures to support countries’ efforts under programs developed 

and jointly administered by the World Bank and the IMF containing 

those components listed in the mandate. 

No 
Page 10 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

17 22 U.S.C. 262t 

Dec. 19, 1989 

Personnel 

practices at the 

IMF 

It shall be U.S. policy that no initiatives, discussions, or 

recommendations concerning the placement or removal of any 

personnel employed by the IMF shall be based on the political 

philosophy or activity of that individual. 

No 

18 22 U.S.C. 286e-8 

Oct. 10, 1978 

Treatment of 

creditors in debt 

rescheduling 

Treasury shall instruct the USED to seek to assure that no decision 

by the IMF departs from U.S. policy regarding the comparability of 

treatment of public and private creditors in cases of debt 

rescheduling where official U.S. credits are involved. 

No 

19 22 U.S.C. 286e-9 

Oct. 10, 1978 

Investment, 

employment, 

and basic 

human needs 

Treasury shall instruct the USED to encourage IMF staff to formulate 

economic stabilization programs that foster a broader base of 

productive investment and employment, especially in those 

productive activities that are designed to meet basic human needs. 

No 

20 22 U.S.C. 286e-11 

Oct. 10, 1978 

Countries 

harboring 

international 

terrorists 

Treasury shall instruct the USED to work in opposition to financing 

for countries either harboring international terrorists or failing to take 

measures to prevent acts of international terrorism. 

No 

21 22 U.S.C. 286k 

July 31, 1945 

International 

trade and 

economic 

stability 

In considering the policies of the United States in foreign lending, the 

USED shall give careful consideration to progress made in reaching 

agreement among nations to reduce restrictions on international 

trade and promote international economic stability. 

No 

22 22 U.S.C. 286s 

Oct. 7, 1980 

Basic human 

needs and 

economic 

adjustment 

programs 

The USED shall recommend and work for changes in IMF guidelines 

to ensure the effectiveness of economic adjustment programs by 

considering the effect the program will have on issues such as jobs 

and investment. The USED shall also work toward improved 

coordination among the IMF, the World Bank, and other appropriate 

institutions in this area. 

No 

23 22 U.S.C. 286u 

Oct. 7, 1980

Dollar-Special 

Drawing Rights 

substitution 

account 

Treasury shall encourage IMF member countries to negotiate a 

dollar-Special Drawing Rights substitution account in which equitable 

burden-sharing would exist among participants in the account. 

No 

24 22 U.S.C. 286v 

Oct. 7, 1980 

Membership for 

Taiwan in the 

IMF 

The USED shall notify the IMF that it is U.S. policy that Taiwan be 

granted appropriate membership in the IMF. 

No 

25 22 U.S.C. 286w 

Oct. 7, 1980 

Denial of 

membership for 

the Palestinian 

Liberation 

Organization 

The USED shall notify the IMF that it is U.S. policy that the 

Palestinian Liberation Organization not be given membership or 

other status at the IMF. 

No 

26 22 U.S.C. 286x 

Oct. 7, 1980 

Assistance to 

private sector of 

El Salvador, 

Nicaragua, and 

other nations 

The USED shall promote the use of IMF programs to assist the 

private sector in any nation, though particularly El Salvador and 

Nicaragua, in creating an environment that will stabilize a nation’s 

economy. 

No 

27 22 U.S.C. 286y 

Nov. 30, 1983

Exchange rate 

stability 

The USED shall work for adoption of policies in the IMF to promote 

exchange rate stability. Also, in determining a vote of assistance to 

any IMF borrower, the USED shall take into account whether the 

borrower’s policies are consistent with certain IMF requirements. 

No 

28 22 U.S.C. 286z 

Nov. 30, 1983 

Transparency Treasury shall instruct the USED to initiate discussions at the IMF 

and propose and vote for adoption of procedures to increase both 

the sharing of information among IMF members and the public 

dissemination of certain IMF information concerning international 

borrowing and lending. 

No 

29 22 U.S.C. 286aa 

Nov. 30, 1983 

Denial of 

lending to 

communist 

dictatorships 

Treasury shall instruct the USED to actively oppose any facility 

involving use of IMF credit by any communist dictatorship unless 

certain conditions are met. 

Yes 
Page 11 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

30 22 U.S.C. 286bb 

Nov. 30, 1983 

Elimination of 

predatory 

agricultural 

export 

subsidies 

Treasury shall instruct the USED to propose and work for the 

adoption of an IMF policy encouraging members to eliminate all 

predatory agricultural export subsidies that might result in the 

reduction of other member countries’ exports. 

No 

31 22 U.S.C. 286cc 

Nov. 30, 1983 

Trade, bank 

solvency, and 

external debt 

servicing 

The USED shall recommend and shall work for changes in IMF 

guidelines and policies that encourage countries to formulate 

economic adjustment programs that deal with their balance-ofpayment difficulties and external debt owed to private banks. The 

USED shall also oppose and vote against fund assistance for a 

country whose annual external debt services exceed 85 percent of its 

annual export earnings, unless Treasury can document why an 

exception should be given. 

Yes 

32 22 U.S.C. 286dd 

Nov. 30, 1983 

Bank bailouts 

and debt 

rescheduling 

Treasury shall instruct the USED to oppose and vote against any 

IMF drawing by a member country that would be used to repay loans 

imprudently made by banking institutions to a member country, and 

to ensure that the IMF encourages borrowing countries and banking 

institutions to renegotiate a rescheduling of debt that is consistent 

with safe and sound banking practices and the country’s ability to 

pay. 

Yes 

33 22 U.S.C. 286ee 

Nov. 30, 1983 

International 

lending and 

external 

indebtedness 

Treasury shall instruct the USED to propose that the IMF adopt 

policies with respect to international lending, including a policy to 

examine the trend and volume of external indebtedness of private 

and public borrowers in Article IV consultations. 

No 

34 22 U.S.C. 286ff 

Nov. 30, 1983 

IMF interest 

rates 

Treasury shall instruct the USED to propose and work for the 

adoption of IMF policies regarding the rate of remuneration paid on 

use of members’ quota subscriptions and the rate of charges on IMF 

drawings to bring those in line with market rates. 

No 

35 22 U.S.C. 286gg 

Nov. 30, 1983 

Elimination of 

trade and 

investment 

restrictions 

Treasury shall instruct the USED to consult with the IMF to reduce 

obstacles to and restrictions upon international trade and investment 

in goods and services, eliminate unfair trade and investment 

practices, and promote mutually advantageous economic relations. 

The USED shall also work to have the IMF obtain agreement with 

countries to eliminate certain unfair trade and investment practices 

and shall take a country’s progress into account in formulating its 

position on requests for loans for periodic financial disbursements. 

No 

36 22 U.S.C. 286kk 

Dec. 19, 1989 

Impact of IMF 

programs on 

the poor and 

the 

environment 

Treasury shall instruct the USED to seek policy changes at the IMF 

that will result in a review of policy prescriptions implemented by the 

IMF to determine both if IMF objectives were met and the social and 

environmental impacts of such prescriptions and the establishment of 

procedures to ensure that policy options that reduce the potential 

adverse impact on the poor or the environment are included in future 

economic reform programs. 

No 

37 22 U.S.C. 286ll 

Oct. 24, 1992 

IMF policy 

concerning 

transparency, 

the poor, and 

the 

environment 

Treasury shall instruct the USED to promote regularly and vigorously 

in program and quota increase discussions a variety of policy 

proposals including a proposal designed to alleviate poverty, 

promote policy audits in the areas of poverty and the environment, 

and allow public access to certain IMF information. 

No 

38 22 U.S.C. 286mm 

Oct. 24, 1992 

Measures to 

reduce military 

spending 

The USED shall use his voice and vote to urge the IMF to continue to 

develop an economic methodology to measure the level of military 

spending by every developing country. The USED shall also urge the 

IMF to provide annual reports that estimate the level of military 

spending by each developing country and urge the IMF to include in 

every Article IV consultation with such countries an analysis on this 

issue. 

No 

39 22 U.S.C. 286nn 

Nov. 29, 1999 

Debt reduction Treasury is authorized to instruct the USED to vote to approve the 

sale of gold such that proceeds can be used toward debt reduction 

for the Heavily Indebted Poor Countries Initiative. 

No 
Page 12 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

40 22 U.S.C. 286oo 

Nov. 6, 2000 

Short- and 

medium-term 

financing, 

misreporting, 

and premium 

pricing 

It is the policy of the United States to work to implement reforms in 

the IMF to achieve the following goals: primarily using short-term 

balance-of-payments financing, limiting the use of medium-term 

financing, introducing premium pricing for lending that is greater than 

200 percent of a member’s quota in the IMF, and redressing cases of 

misreporting of information in the context of IMF programs. 

No 

41 22 U.S.C. 2225 

Dec. 30, 1974 

Integration of 

women 

Treasury is requested to instruct the USED to encourage and 

promote the integration of women into the national economies of IMF 

member countries and into professional positions within the IMF 

organization. In addition, Treasury is to take any progress or lack of 

progress into account when making contributions to the IMF. 

No 

42 22 U.S.C. 2370a 

Apr. 30, 1994 

Expropriation of 

U.S. property 

Treasury shall instruct the USED to vote against any use of IMF 

funds for the benefit of any country that has, after 1956, nationalized 

or expropriated U.S. property without compensation or adequate 

arbitration, unless the funds are directed to programs that serve the 

basic human needs of the citizens of that country, or the President 

waives this prohibition on the basis of U.S. national interests. 

Yes 

43 22 U.S.C. 2656 note

(P.L. 107-228, sec. 

633, Sept. 30, 2002) 

East Timor Treasury shall instruct the USED to use the voice, vote, and 

influence of the United States to support economic and democratic 

development in East Timor. 

No 

44 22 U.S.C. 2799aa-1 

Apr. 30, 1994 

Nuclear 

transfers and 

illegal exports 

The U.S. government shall oppose the extension of any IMF loan or 

financial or technical assistance to any country that the President 

determines either delivers nuclear reprocessing equipment, material, 

or technology to any country or receives such equipment, materials, 

or technology from another country, or is a nonnuclear state that 

exports from the United States illegally any material, equipment, or 

technology that would contribute significantly to its ability to 

manufacture a nuclear explosive device and will be used for such a 

device. The President may waive application of this section with 

respect to India and Pakistan under certain conditions. (See P.L. 

106-79, sec. 9001.)

Yes 

45 22 U.S.C. 5605 

Dec. 4, 1991 

Sanctions 

against use of 

chemical and 

biological 

weapons 

The United States shall oppose, in accordance with 22 U.S.C. 262d, 

the extension of any loan or financial or technical assistance to any 

country that the President determines uses chemical or biological 

weapons either in violation of international law or against its own 

nationals. The President may waive application of this section under 

certain conditions.

Yes 

46 22 U.S.C. 6034 

Mar. 12, 1996 

Opposition to 

Cuban 

membership 

Treasury shall instruct the USED to use the voice and vote of the 

United States to oppose admission of Cuba as a member of the IMF 

until the President submits a determination that a democratically 

elected government is in power in Cuba. 

Yes 

47 22 U.S.C. 6302 

Apr. 30, 1994 

Nuclear 

nonproliferation

Treasury shall instruct the USED to use the voice and vote of the 

United States to oppose any use of IMF funds to promote the 

acquisition of unsafeguarded special nuclear material or the 

development, stockpiling, or use of any nuclear explosive device by 

any non-nuclear-weapon state. 

Yes 

48 22 U.S.C. 6445 

Oct. 27, 1998 

Religious 

freedom 

The President shall instruct the USED to oppose and vote against 

loans primarily benefiting a foreign government, agency, 

instrumentality, or official determined by the President to be a violator 

of religious freedoms. 

Yes 

49 22 U.S.C. 6713 

Oct. 21, 1998 

U.S. liability, 

confidential 

business 

information, 

and chemical 

weapons 

The United States shall oppose any IMF loan or financial or technical 

assistance to either a foreign government or any foreign person, 

officer, or employee of the Organization for the Prohibition of 

Chemical Weapons whose actions taken in the implementation of the 

Chemical Weapons Convention make the United States liable, or 

who knowingly divulge U.S. confidential business information, or in 

the case of a government, encourage or assist a person in making 

such disclosures. 

Yes 
Page 13 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

50 22 U.S.C. 6901 note

(P.L. 107-228, sec. 

616, Sep. 30, 2002) 

Tibet Treasury shall instruct the USED to use the voice and vote of the 

United States to support projects in Tibet, so long as the projects are 

designed in accordance with certain enumerated principles, such as 

that the project fosters self-sufficiency and self-reliance of Tibetans. 

No 

51 22 U.S.C. 7107 

Oct. 28, 2000 

Combat 

trafficking in 

persons 

The President will instruct the USED to vote against, and to use his 

best efforts to deny, any loan or other use of IMF funds for the 

subsequent fiscal year to a country that fails to comply or is not 

making significant efforts to bring itself into compliance with the 

minimum standards for the elimination of trafficking in persons. If

certain requirements are met, this mandate does not apply to 

humanitarian assistance, trade-related assistance, or development 

assistance and can be waived by the President if the continuation of 

assistance is in the national interest. 

Yes 

52 50 U.S.C. 1701 note 

(P.L. 103-160, sec. 

1511, Nov. 30, 1993 

& P.L. 104-208, sec. 

540, Feb. 12, 1996) 

Serbia or 

Montenegro 

Treasury shall instruct the USED to use the voice and vote of the 

United States to oppose any IMF assistance to the governments of 

Serbia or Montenegro, except for basic human needs or unless a 

proper waiver or certification is made. 

Yes 

53 P.L. 104-208, sec. 

570, Sep. 30, 1996 

Burma and 

human rights 

and democratic 

government 

Treasury shall instruct the USED to vote against any utilization of 

IMF funds for Burma until such time as the President certifies to 

Congress that Burma has made measurable and sustainable 

progress in improving human rights practices and implementing a 

democratic government in Burma, or the President waives the 

sanction by certifying to Congress that the sanction is contrary to 

U.S. national interests. 

Yes 

54 P.L.106-113, sec. 

504, Nov. 29, 1999 

IMF 

Operational 

Budget 

Treasury shall instruct the USED to use the voice and vote and 

influence of the U.S. to urge vigorously the IMF both to publish the 

operational budgets of the IMF on a quarterly basis, not later than 

one year after the end of the period covered by the budget, and to 

continue to forgo reimbursements of the expenses incurred by the 

IMF in administering the Enhanced Structural Adjustment Facility, 

until the Heavily Indebted Poor Countries initiative is terminated. 

No 

55 P.L. 107-99, sec. 4, 

Dec. 21, 2001 

Zimbabwe If the President certifies to the appropriate congressional committees 

that certain condition have been met in Zimbabwe, including the 

restoration of the rule of law and a commitment to equitable, legal, 

and transparent land reform, then the Treasury should direct the 

USED to propose to undertake financial and technical support for 

Zimbabwe, especially support that is intended to promote 

Zimbabwe’s economic recovery and development, the stabilization of 

the Zimbabwean dollar, and the viability of Zimbabwe’s democratic 

institutions. Until the President makes a certification, however, and 

except as may be required to meet basic human needs or for good 

governance, the Treasury shall instruct the USED to oppose and 

vote against any IMF loan, credit, or guarantee to the government of 

Zimbabwe or any cancellation or reduction of indebtedness owed by 

the government of Zimbabwe to the IMF. 

Yes 

56 P.L. 107-245, sec. 

6, Oct. 21, 2002 

Sudan After April 10, 2003, and every 6 months thereafter, if the President 

certifies that the government of Sudan has not engaged in good faith 

negotiations to achieve a permanent and just peace agreement, or 

has unreasonably interfered with humanitarian efforts in Sudan, then 

the Treasury shall instruct the USED to continue to vote against, and 

actively oppose, any extension of any IMF loan, credit, or guarantee 

to the government of Sudan. 

Yes 

57 50 U.S.C. 1701 

note (P.L. 108-61, 

sec. 5, Jul. 28, 

2003) 

Burmese 

Freedom and 

Democracy 

Act 

Treasury shall instruct the USED to oppose and vote against 

extending any IMF loan or financial or technical assistance to 

Burma until certain conditions are met, including that the SPDC 

has made substantial progress to end human rights violations, 

to implement a democratic government, and that Burma is not 

designated as a country that has failed demonstrably to adhere 

to its obligations under international counternarcotics 

agreements. 

Yes 
Page 14 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

58 P.L. 108-11, sec. 

1503, Apr. 16, 2003 

Lifting of Iraqi 

Sanctions 

Provisions of law that direct the United States government to 

vote against or oppose loans or other use of funds, including 

for financial or technical assistance, in the IMF for Iraq shall not 

be construed as applying to Iraq. 

No 

59 P.L. 108-199, sec. 

501, Jan. 23, 2004 

Compensation 

for the USED 

No funds appropriated by the Foreign Operations, Export Financing, 

and Related Programs Appropriations Act, 2004, may be made as 

payment to the IMF while the USED is compensated by the IMF at a 

rate that, together with the compensation the USED receives from 

the United States, is in excess of the rate provided for an individual 

occupying a position at level IV of the Executive Schedule under 5 

U.S.C. 5315, or while the alternate U.S. Director is compensated by 

the IMF at a rate in excess of the rate provided for an individual 

occupying a position at level V of the Executive Schedule under 5 

U.S.C. 5316. 

No 

60 P.L. 108-199, sec. 

514, Jan. 23, 2004 

Trade, mining, 

and surplus 

commodities 

Treasury shall instruct the USED to use the voice and vote of the 

United States to oppose any IMF assistance for the production or 

extraction of any commodity or mineral for export, if it is in surplus on 

world markets and if the assistance will cause substantial injury to 

the U.S. producers of the same, similar, or competing commodity. 

Yes 

61 P.L. 108-199, sec. 

531, Jan. 23, 2004 

Burma Treasury shall instruct the USED to oppose and vote against 

extending IMF loans or financial or technical assistance or any 

other utilization of IMF funds to and for Burma. 

Yes 

62 P.L. 108-199, sec. 

557, Jan. 23, 2004 

Zimbabwe Treasury shall instruct the USED to vote against any extension of 

any IMF loans to the government of Zimbabwe, except to meet basic 

human needs or to promote democracy, unless the Secretary of 

State determines and certifies to the Committees on Appropriations 

that the rule of law has been restored in Zimbabwe, including respect 

for ownership and title to property and freedom of speech and 

association. 

Yes 

63 P.L. 108-199, sec. 

558, Jan. 23, 2004 

Tibet Treasury shall instruct the USED to use the voice and vote of 

the United States to support projects in Tibet, if the projects do 

not provide incentives for migration and settlement of nonTibetans into Tibet or facilitate the transfer of ownership of 

Tibetan land and natural resources to non-Tibetans; are based 

on a thorough needs assessment; foster self-sufficiency of the 

Tibetan people and respect for Tibetan culture and traditions; 

and are subject to effective monitoring. 

No 

64 P.L. 108-199, sec. 

561, Jan. 23, 2004 

Cambodia Treasury should instruct the USED to use the voice and vote of the 

United States to oppose loans to the central government of 

Cambodia, except loans to support basic human needs. 

Yes 

65 P.L. 108-199, sec. 

570, Jan. 23, 2004 

Countries 

providing 

sanctuary to 

indicted war 

criminals 

Treasury shall instruct the USED to vote against any new project 

involving the extension of financial or technical assistance to any 

country whose authorities have failed, as determined by the 

Secretary of State, to take necessary and significant steps to 

apprehend and transfer to the International Criminal Tribunal for the 

former Yugoslavia all persons indicted by the Tribunal and to 

otherwise cooperate with the Tribunal. This section does not apply to 

humanitarian assistance and assistance for democratization. 

Yes 

66 P.L. 108-199, sec. 

571, Jan. 23, 2004 

User fees Treasury shall instruct the USED to oppose any loan, grant, strategy, 

or policy of the IMF that would require user fees or service charges 

on poor people for primary education or primary healthcare, including 

prevention and treatment efforts for Human Immunodeficiency 

Virus/Acquired Immune Deficiency Syndrome, malaria, tuberculosis, 

and infant, child and maternal well-being, in connection with the 

IMF’s financing program. 

Yes 

67 P.L. 108-199, sec. 

572, Jan. 23, 2004 

Serbia After March 31, 2004, Treasury should instruct the USED to support 

loans and assistance to the Yugoslavian government subject to 

certain conditions, including that the Yugoslavian government is 

taking steps consistent with the Dayton Peace Accord to end 

financial, political, security, and other support that served to maintain 

Yes 
Page 15 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Law and date of 

enactmentb

Subject matter Required actions 

Directed 

vote 

separate Republika Srpska institutions. With respect to such loans, 

22 U.S.C. 262k-1, which requires transparency of military budgets, 

shall not apply. 

Source: GAO. 

Notes: 

The information shown in this enclosure is based on a GAO analysis of policy and directed vote legislative 

mandates concerning the IMF. 

Mandates shown in bold represent mandates that were enacted since our last report in February 2003 and 

simply replace older mandates that had expired. Mandates shown in bold with a shaded background represent 

new mandates that were added in recent legislation since our February 2003 report. 

Mandates contained in FY 2004 Appropriations Acts remain in effect through January 31, 2004, under a 

continuing resolution (P.L. 108-35, Making Further Continuing Appropriations for the Fiscal Year 2004, and For 

Other Purposes). 

a

Treasury puts mandates in three broad categories: “policy,” “directed vote,” and “reporting”. Policy mandates 

direct the United States to foster or urge a certain policy at the IMF. Directed vote mandates instruct the United 

States to “oppose” or “vote against” loans or other IMF assistance. Reporting mandates are outside the scope of 

this report. 

b

This column reports the original date of enactment. However, many of these mandates were amended 

subsequent to this date. 
Page 16 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Enclosure II 

Examples of Broad Policies that Are Addressed in Multiple Lawsa 

Broad policy objective Law 

Administrative and personnel matters 22 U.S.C. 2225 (Dec. 30, 1974) 

22 U.S.C 262e (Oct. 3, 1977) 

22 U.S.C. 262t (Dec. 19, 1989) 

22 U.S.C. 262p-4n (Nov. 5, 1990) 

P.L. 108-199, sec. 501 (Jan. 23, 2004)

Banking 22 U.S.C. 286cc (Nov. 30, 1983) 

22 U.S.C. 286dd (Nov. 30, 1983) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Burma P.L. 104-208, sec. 570 (Sep. 30, 1996) 

50 U.S.C. 1701 note (P.L. 108-61, sec. 5 (July 28, 2003)) 

P.L. 108-199, sec. 531 (Jan. 23, 2004) 

Debt 22 U.S.C. 286e-8 (Oct. 10, 1978) 

22 U.S.C. 286cc (Nov. 30, 1983) 

22 U.S.C. 286dd (Nov. 30, 1983) 

22 U.S.C. 286ee (Nov. 30, 1983) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

22 U.S.C. 286nn (Nov. 29, 1999) 

22 U.S.C. 262p-6 (Nov. 29, 1999) 

Employment 22 U.S.C. 2225 (Dec. 30, 1974) 

22 U.S.C. 286e-9 (Oct. 10, 1978) 

Environment 22 U.S.C. 286kk (Dec. 19, 1989) 

22 U.S.C. 286ll (Oct. 24, 1992) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Exchange rate stability 22 U.S.C. 286y (Nov. 30, 1983) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Governance 22 U.S.C. 262o-1 (Aug. 23, 1994) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Human rights 22 U.S.C. 262d (Oct. 3, 1977) 

22 U.S.C. 262p-4o (Aug. 23, 1994) 

P.L. 104-208, Sec. 570 (Sept. 30, 1996) 

Investment 22 U.S.C. 286e-9 (Oct. 10, 1978) 

22 U.S.C. 286s (Oct. 7, 1980) 

22 U.S.C. 286gg (Nov. 30, 1983) 

Labor 22 U.S.C. 262p-4p (Aug. 23, 1994) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Poverty alleviation and education 22 U.S.C. 286kk (Dec. 19, 1989) 

22 U.S.C. 286ll (Oct. 24, 1992) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

22 U.S.C. 262p-7 (Nov. 29, 1999) 

P.L. 108-199, sec. 571 (Jan. 23, 2004)

Military spending and military audit 22 U.S.C. 286mm (Oct. 24, 1992) 

22 U.S.C. 262o-1 (Aug. 23, 1994) 

22 U.S.C. 262k-1 (Sept. 30, 1996) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Nuclear and chemical nonproliferation 22 U.S.C. 2799aa-1 (Apr. 30, 1994) 

22 U.S.C. 6302 (Apr. 30, 1994) 

22 U.S.C. 6713 (Oct. 21, 1998) 
Page 17 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Broad policy objective Law 

22 U.S.C. 5605 (Dec. 4, 1991) 

Religious freedom 22 U.S.C. 262d (Oct. 3, 1977) 

22 U.S.C. 6445 (Oct. 27, 1998) 

Serbia 50 U.S.C. 1701 note (P.L. 103-160, sec. 1511 (Nov. 30, 1993) & 

P.L. 104-208, sec. 540 (Feb. 12, 1996)) 

P.L. 108-199, sec. 572 (Jan. 23, 2004) 

Terrorism 22 U.S.C. 262d (Oct. 3, 1977) 

22 U.S.C. 286e-11 (Oct. 10, 1978) 

22 U.S.C. 262p-4q (Apr. 24, 1996) 

22 U.S.C. 262p-4r (Oct. 26, 2001) 

Tibet 22 U.S.C. 6901 note (P.L. 107-228, sec. 616 (Sep. 30, 2002)) 

P.L. 108-199, sec. 558 (Jan. 23, 2004) 

Trade 22 U.S.C. 286k (July 31, 1945) 

22 U.S.C. 286bb (Nov. 30, 1983) 

22 U.S.C. 286cc (Nov. 30, 1983) 

22 U.S.C. 286gg (Nov. 30, 1983) 

22 U.S.C. 262k (Aug. 15, 1985) 

22 U.S.C. 262h (Oct. 15, 1986) 

22 U.S.C. 262n-3 (Oct. 21, 1998) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

P.L. 108-199, sec. 514 (Jan. 23, 2004) 

Transparency 22 U.S.C. 286z (Nov. 30, 1983) 

22 U.S.C. 286ll (Oct. 24, 1992) 

22 U.S.C. 262o-2 (Oct. 21, 1998) 

Use of IMF resources 22 U.S.C. 286u (Oct. 7, 1980) 

22 U.S.C. 286ff (Nov. 30, 1983) 

22 U.S.C. 286oo (Nov. 6, 2000) 

Women’s issues 22 U.S.C. 2225 (Dec. 30, 1974) 

22 U.S.C. 262k-2 (Sept. 30, 1996) 

Zimbabwe P.L. 107-99, sec. 4 (Dec. 21, 2001) 

P.L. 108-199, sec. 557 (Jan. 23, 2004)

Source: GAO. 

Notes: 

The information shown in this enclosure is based on a GAO analysis of policy and directed vote legislative 

mandates concerning the IMF. 

Mandates shown in bold represent mandates that were enacted since our last report in February 2003. Some of 

these mandates simply replace older mandates that had expired, while other mandates cover new topics. 

a

Treasury puts mandates in three broad categories: “policy,” “directed vote,” and “reporting”. Policy mandates 

direct the United States to foster or urge a certain policy at the IMF. Directed vote mandates instruct the United 

States to “oppose” or “vote against” loans or other IMF assistance. Reporting mandates are outside the scope of 

this report. 

 
Page 18 GAO-04-928R Treasury Continues Its Formal Process to Promote U.S. Policies 

Enclosure III 

Comments from the Department of the Treasury 

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