SYRIA HUMANITARIAN 

ASSISTANCE

Implementing Partners 

Have Assessed Some 

Risks of Providing Aid 

inside Syria, but U.S. 

Agencies Could Improve 

Fraud Oversight

Statement of Thomas Melito, Director, International 

Affairs and Trade

Testimony 

Before the Subcommittee on the Middle 

East and North Africa, Committee on 

Foreign Affairs, House of

Representatives

For Release on Delivery 

Expected at 2:00 p.m ET

Thursday, July 14, 2016

GAO-16-808T

United States Government Accountability Office
Letter

Page 1 GAO-16-808T 

Chairman Ros-Lehtinen, Ranking Member Deutch, and Members of the 

Subcommittee:

Thank you for the opportunity to discuss our work on the delivery of U.S. 

humanitarian assistance to people inside Syria. The conflict in Syria has 

created a complex humanitarian challenge. As of May 2016, the United 

Nations (UN) reported that 13.5 million people inside Syria have been 

affected by the conflict and are in need of humanitarian assistance, such 

as food, shelter, and medicine. Since the start of the conflict in March 

2011, the United States, through the Department of State (State) and the 

U.S. Agency for International Development (USAID), has provided over 

$5 billion in humanitarian assistance, about half of which has been 

provided for assistance to people inside Syria. USAID provides funds to 

UN organizations and also works through nongovernmental organizations 

(NGO) inside Syria, while State works through three main partners—two 

UN organizations and one public international organization. U.S. 

humanitarian assistance is part of a broader international response. Since 

2013, the United States has consistently led global funding efforts—for 

example, the United States provided more than a quarter of the total 

international funding for the 2015 Syria humanitarian response.

My testimony summarizes our 2016 report on the delivery of U.S. 

humanitarian assistance to people inside Syria, which is being released 

today.1 In this report, we examine humanitarian assistance provided by 

State, USAID, and their implementing partners to people inside Syria, 

including (1) factors affecting delivery of such assistance; (2) the extent to 

which State, USAID, and their partners have assessed risks to the 

programs; and (3) implementation of controls to mitigate identified risks 

and ensure appropriate financial oversight of humanitarian assistance 

projects. To determine factors affecting delivery of assistance, we 

conducted a content analysis of monthly United Nations Secretary 

General (UNSG) reports on the humanitarian situation in Syria to 

categorize and summarize observations contained in the reports. We also 

interviewed cognizant officials. To determine the extent to which State, 

USAID, and their partners have assessed risks to the programs, and to 

evaluate implementation of controls to mitigate risks and ensure 

 1

GAO, Syria Humanitarian Assistance: Some Risks of Providing Aid inside Syria 

Assessed, but U.S. Agencies Could Improve Fraud Oversight, GAO-16-629 (Washington, 

D.C., July 14, 2016).

Letter
Page 2 GAO-16-808T 

appropriate financial oversight of assistance, we selected a 

nongeneralizable sample of 12 of 52 fiscal year 2015 State and USAID 

funding instruments2 from 9 different implementing partners and 

evaluated the risk assessments and control activities associated with the 

funding instruments.

Our review resulted in the following findings. First, several factors 

complicate the delivery of humanitarian assistance to people inside Syria. 

Second, U.S. agencies and implementing partners have assessed some 

risks of delivering humanitarian assistance inside Syria, but most partners 

have not assessed risks of fraud. Lastly, partners have implemented 

controls to mitigate certain risks of delivering humanitarian assistance 

inside Syria, but U.S. agencies could improve their oversight of these 

programs. As a result, we made several recommendations to State and 

USAID to improve financial oversight. 

We identified three key factors that affect delivery of humanitarian 

assistance to people inside Syria. First, the increasingly violent and 

widespread Syrian conflict has hindered effective delivery of humanitarian 

assistance. Based on our analysis of monthly UNSG reports on the 

situation inside Syria, as well as interviews with officials providing 

assistance to Syria based both inside and outside of the country, 

humanitarian assistance is routinely prevented or delayed from reaching 

its intended target due to shifting conflict lines, attacks on aid facilities and 

workers, an inability to access besieged areas, and other factors related 

to active conflict (see fig. 1).

 2

For the purposes of this report, we use the term “funding instrument” to refer to 

assistance instruments that are used to transfer money, property, or services to 

accomplish a public purpose. Grants, cooperative agreements, and voluntary contributions 

are all types of funding instruments that the U.S. government uses to provide 

humanitarian assistance to people inside Syria.

Several Factors Affect 

the Delivery of 

Humanitarian 

Assistance to People 

inside Syria
Page 3 GAO-16-808T 

Figure 1: Damage to Health Facilities in Syria after Aerial Attack, Tel Shehab, Dara’a Province (left) and Al Khaf, Rural 

Damascus (right)

Second, administrative procedures put in place by the Syrian government 

have delayed or limited the delivery of humanitarian assistance, 

according to UNSG reports. These reports detail multiple instances of 

unanswered requests for approvals of convoys, denial or removal of 

medical supplies from convoys, difficulty obtaining visas for humanitarian 

staff, and restrictions on international and national NGOs’ ability to 

operate. As of May 2016, the UNSG reported that 4.6 million people 

inside Syria are located in hard-to-reach areas and more than 500,000 of 

those remain besieged by Islamic State of Iraq and Syria, the government 

of Syria, or non-State armed opposition groups. The UN further reported 

that in 2015, only 10 percent of all requests for UN interagency convoys 

to hard-to-reach and besieged areas were approved and assistance 

delivered. In addition, according to implementing partner officials based in 

Damascus, Syria, even when these convoys were approved, the officials 

participating in delivering the assistance were subjected to hours-long 

delays.

Third, due to restrictions, USAID and State staff manage the delivery of 

humanitarian assistance in Syria remotely from neighboring countries. 

The U.S. government closed its embassy in Damascus, Syria, in 2012 

due to security conditions and the safety of personnel, among other 
Page 4 GAO-16-808T 

factors. In the absence of direct program monitoring, USAID and State 

officials noted that they utilize information provided by implementing 

partners to help ensure effective delivery of assistance and to help their 

financial oversight, including mitigating risks such as fraud, theft, 

diversion, and loss. However, USAID officials in the region explained to 

us that while partners provide data and information, their inability to 

consistently access project sites—due to factors such as ongoing fighting, 

bombing raids, and border closures—limited the extent to which partners 

could obtain and verify progress. Past audit work has shown challenges 

to such an approach, including cases of partners not fully implementing 

monitoring practices, resulting in limited project accountability. Further, 

USAID Office of Inspector General (OIG) has reported that aid 

organizations providing life-saving assistance in Syria and the 

surrounding region face an extremely high-risk environment, and that the 

absence of adequate internal controls, among other challenges, can 

jeopardize the integrity of these relief efforts and deny critical aid to those 

in need.

State, USAID, and their implementing partners have assessed some 

types of risk to their programs inside Syria, but most partners have not 

assessed the risk of fraud. Risk assessment involves comprehensively 

identifying risks associated with achieving program objectives; analyzing 

those risks to determine their significance, likelihood of occurrence, and 

impact; and determining actions or controls to mitigate the risk. In the 

context of Syria, such risks could include theft and diversion; fraud; 

safety; security; program governance; and implementing partner capacity 

risks.

Most of the implementing partners in our sample have conducted formal 

risk assessments for at least one type of risk, especially security risk, and 

several maintain risk registers that assess a wide variety of risks (see 

table 1). However, few implementing partners have conducted risk 

assessments for the risk of fraud (four of nine), or for the risk of loss due 

to theft or diversion (four of nine). According to GAO’s A Framework for 

Managing Fraud Risks in Federal Programs,

3 effective fraud risk 

 3

GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP

(Washington, D.C.: July 2015). 

U.S. Agencies and 

Their Implementing 

Partners Have 

Assessed Some 

Risks to Their 

Programs, but Most 

Partners Have Not 

Assessed Fraud 

Risks
Page 5 GAO-16-808T 

management involves fully considering the specific fraud risks the agency 

or program faces, analyzing the potential likelihood and impact of fraud 

schemes, and prioritizing fraud risks. In addition, risk assessment is 

essential for ensuring that partners design appropriate and effective 

control activities. Control activities to mitigate the risk of fraud should be 

directly connected to the fraud risk assessments and, over time, 

managers may adjust the control activities if they determine that controls 

are not effectively designed or implemented to reduce the likelihood or 

impact of an inherent fraud risk to a tolerable risk level.

Table 1: Selected Risks Identified in Risk Assessments Conducted by Implementing Partners in Our Sample

Risk Vulnerability

Number of implementing partners 

out of a total of 9 who conducted 

assessments for this type of risk 

Safety of 

personnel 

Road accidents, road banditry, and ambushes while driving are all 

safety risks for implementing partner personnel 7 

Security 

environment

Gathering of large crowds for distribution of humanitarian assistance 

can cause security risks for beneficiaries 8 

Loss due to theft 

or diversion

Diversion of humanitarian aid by armed groups or criminal elements

4 

Fraud

Remote management of programs can weaken internal controls and 

increase opportunities for fraud and waste 4

Source: GAO analysis of implementing partner documents. | GAO-16-808T

Although most of the implementing partners in our sample did not conduct 

assessments of the risk of fraud, there are elevated risks for fraud in U.S. 

funded humanitarian assistance projects for people inside Syria. 

According to officials at USAID OIG, they have four ongoing 

investigations of allegations of fraud and mismanagement related to 

programs for delivering humanitarian assistance to people inside Syria. 

Two of the investigations involve allegations of procurement fraud, 

bribery, and product substitution in USAID funded humanitarian crossborder programs related to procurements of non-food items. One of these 

investigations found that the subawardee of the implementing partner 

failed to distribute nonfood items in southern Syria, instead 

subcontracting the distribution to another organization, but nevertheless 

billed USAID for the full cost of the project. Additionally, the subawardee 

was reliant on one individual to facilitate the transfer of materials and 

salaries, and this individual was involved in the alteration and falsification 
Page 6 GAO-16-808T 

of records related to the distribution of the nonfood items. According to 

the USAID OIG, senior leadership at the subawardee was aware of these 

facts.4 Further, in May 2016, USAID OIG reported the identification of bidrigging and multiple bribery and kickback schemes related to contracts to 

deliver humanitarian aid in Syria, investigations of which resulted in the 

suspension of 14 entities and individuals involved with aid programs from 

Turkey. Without documented risk assessments, implementing partners 

may not have all of the information needed to design appropriate controls 

to mitigate fraud risks, and State and USAID may not have visibility into 

areas of risk, such as fraud and loss due to theft and diversion.

We found that partners in our sample had implemented controls to

mitigate certain risks of delivering humanitarian assistance inside Syria. 

For instance, many partners in our sample implemented controls to 

account for safety and security risks to their personnel and beneficiaries 

receiving assistance. Some partners identified aerial targeting of 

humanitarian aid workers and beneficiaries at distribution points as a 

major vulnerability and implemented controls to mitigate this risk, such as 

distributing goods to beneficiaries on overcast days and making door-todoor deliveries of aid packages. In addition, partners in our sample 

implemented controls to mitigate risks of fraud and loss within their 

operations. For example, officials from two implementing partners we 

interviewed in Amman, Jordan, stated that they conducted spot checks of 

assistance packages in warehouses to confirm the quantity of the 

contents and ensure that the quality of the items complied with the terms 

of the contract. According to another implementing partner, officials from 

its organization visit the vendor warehouses before signing contracts to 

verify that U.S. government commodity safety and quality assurance 

guidelines are met. However, the majority of controls to mitigate risks of 

fraud and loss were not informed by a risk assessment (see table 2).

 4

According to the USAID OIG, as result of OIG’s investigative findings, USAID decided to 

terminate the sub-award and reduce its planned funding to the prime implementer by 

$10,500,000. 

Partners Have 

Implemented Controls 

for Delivering 

Humanitarian 

Assistance inside 

Syria, but U.S. 

Agencies Could 

Improve Oversight
Page 7 GAO-16-808T 

Table 2: Selected Mitigating Control Activities That Responded to Identified Risks 

Risk Vulnerability Mitigating Activity 

Number of 

implementing partners 

out of a total of 9 who 

conducted 

assessments for this 

type of risk

Number of 

implementing partners

out of a total of 9 with 

control activities for 

this type of risk

Safety of personnel 

Road accidents, road 

banditry, and ambushes 

while driving are all 

safety risks for 

implementing partner 

personnel

Provide instruction to 

drivers on methods for 

taking evasive action and 

fleeing to safety 7 8

Security environment

Gathering of large 

crowds for distribution of 

humanitarian assistance 

can cause security risks 

for beneficiaries

Conduct door-to-door 

distribution—rather than 

distribution from a 

centralized location—in 

high-risk environments 8 9

Loss due to theft or 

diversion

Diversion of aid by armed 

groups or criminal 

elements

Obtain community 

acceptance through 

liaising with local 

councils; track and 

monitor supplies 4 9

Fraud

Remote management of 

programs can weaken 

internal controls and 

increase opportunities for 

fraud and waste 

Train new staff and 

existing staff on fraud 

awareness; triangulate 

data and information 

from monitoring in 

programmatic and 

financial operations 4 8

Source: GAO analysis of implementing partner documents. | GAO-16-808T

State and USAID have taken steps to oversee partner programs 

delivering humanitarian assistance inside Syria; nevertheless, 

opportunities to assess and mitigate the potential impact of fraud risks 

remain. U.S. officials cited a variety of oversight activities. For instance, 

State officials in the region conduct quarterly meetings with partners and 

collect information on programmatic objectives and on partner programs. 

State also has enhanced monitoring plans in place with its implementing 

partners to augment quarterly reporting with information on risks of 

diversion of assistance. Similarly, USAID officials in Washington, D.C.,

told us they screen proposals from partners to identify risk mitigation 

activities and USAID officials in the region noted they maintain regular 

contact with partners, attend monthly meetings with them, conduct 

random spot-checks of aid packages at warehouse facilities, and 

coordinate activities among partners to reduce or eliminate duplication or 

overlap of assistance. Moreover, according to USAID officials, the USAID 
Page 8 GAO-16-808T 

OIG has conducted fraud awareness training for officials in the region to 

improve their ability to detect fraud, such as product substitution, when 

they conduct spot-checks of aid packages at warehouse facilities. 

Further, in October 2015, USAID’s Office of U.S. Foreign Disaster 

Assistance hired a third party monitoring organization to review its 

projects in Syria. By February 2016, field monitors had conducted site 

visits and submitted monitoring reports to USAID, providing information 

on the status of projects and including major concerns that field monitors 

identified.

We found that fraud oversight could be strengthened. Based on our 

analysis, USAID’s third party monitoring contract and supporting 

documentation contain guidelines for verifying the progress of activities in 

Syria; however, they do not clearly instruct field monitors to identify 

potential fraud risks as they conduct site assessments of projects in Syria. 

Furthermore, the monitoring plan and site visit templates do not contain 

specific guidance on how to recognize fraud, and field monitors have not 

received the USAID OIG fraud awareness training, according to USAID 

officials. Leading practices in fraud risk management suggest evaluating 

outcomes using a risk-based approach and adapting activities to improve 

fraud risk management. This includes conducting risk-based monitoring 

and evaluation of fraud risk management activities with a focus on 

outcome measurement and using the results to improve prevention, 

detection, and response.

The monitoring plan associated with the contract contains guidelines for 

field monitors to document their assessment of the project at the 

completion of a site visit. However, it lacks specific guidelines to identify 

potential fraud risks during site visits. Additionally, the templates created 

by the third party monitoring organization to document site visits instruct 

monitors to verify the presence or absence of supplies and their quality, 

among other instructions, but lack specific fraud indicators to alert field 

monitors to collect information on and identify potential fraud. 

Furthermore, the monitoring plan contains a training curriculum for field 

monitors, which has several objectives designed to familiarize them with 

the protocols, procedures, and instruments used for data collection and 

reporting. However, the curriculum does not have specific courses for 

recognizing potential or actual instances of fraud that may occur on site. 

Given the opportunity for fraud that exists in humanitarian assistance 

programs, as well as the ongoing USAID OIG investigations, without 

instructions to specifically collect data on fraud and training to identify it, 

USAID may be missing an opportunity to assist in its activities to mitigate 

fraud risks and design appropriate controls.
Page 9 GAO-16-808T 

We made several recommendations in our report. To provide more 

complete information to assist the agencies in conducting oversight 

activities, State and USAID should require their implementing partners to 

conduct fraud risk assessments. In addition, USAID should ensure its 

field monitors (1) are trained to identify potential fraud risks and (2) collect 

information on them. State and USAID concurred with our 

recommendations.

Chairman Ros-Lehtinen, Ranking Member Deutch, Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions that you may have at this time.

For further information about this testimony, please contact Thomas 

Melito, Director, International Affairs and Trade at (202) 512-9601 or 

melitot@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this 

statement. GAO staff who made key contributions to this testimony are 

Elizabeth Repko (Assistant Director), Jennifer Young, Kyerion Printup, 

Justine Lazaro, Cristina Norland, Karen Deans, Kimberly McGatlin, Diane 

Morris, Justin Fisher, and Alex Welsh.

Our 

Recommendations 

and Agency 

Responses

GAO Contact and 

Staff 

Acknowledgments

(100974)
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