SYRIA 

HUMANITARIAN 

ASSISTANCE

Some Risks of 

Providing Aid inside 

Syria Assessed, but 

U.S. Agencies Could 

Improve Fraud 

Oversight

Report to Congressional Requesters 

July 2016

GAO-16-629

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-629, a report to 

congressional requesters

July 2016

SYRIA HUMANITARIAN ASSISTANCE

Some Risks of Providing Aid inside Syria Assessed, 

but U.S. Agencies Could Improve Fraud Oversight

Why GAO Did This Study

The conflict in Syria has created a 

complex humanitarian challenge, with 

an estimated 13.5 million people inside 

Syria in need of assistance. In 

response, the United States has 

provided more than $5 billion since 

2011 in humanitarian assistance, with 

about half supporting those inside 

Syria. Without an embassy in Syria, 

State and USAID oversee assistance 

remotely from neighboring countries. 

In this report GAO examines 

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. GAO 

selected a nongeneralizable sample of 

12 funding instruments involving 9 

implementing partners and analyzed 

the partners’ risk assessments and 

control activities, interviewed relevant 

officials, and conducted fieldwork in 

Jordan, where several implementing 

partners are based. 

What GAO Recommends

To provide more complete information 

to assist oversight activities, State and 

USAID should require their 

implementing partners to conduct fraud 

risk assessments. In addition, USAID 

should ensure its field monitors are 

trained to identify potential fraud risks

and collect information on them. State 

and USAID concurred with GAO’s 

recommendations.

What GAO Found

Delivery of U.S. humanitarian assistance to people inside Syria is complicated by 

three factors including a dangerous operating environment, access constraints, 

and remote management of programs. Active conflict creates a dangerous 

environment characterized by attacks on aid facilities and workers, and 

humanitarian organizations face difficulties accessing those in need. Additionally, 

U.S. agency officials must manage programs in Syria remotely, increasing risks

to the program, including opportunities for fraud. Despite these challenges, 

according to the U.S. Agency for International Development (USAID), U.S. 

humanitarian assistance has reached 4 million people inside Syria per month.

Examples of destruction to health facilities after aerial attacks

The Department of State (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. Of the 9 implementing partners in GAO’s 

sample of funding instruments, most assessed risks related to safety and 

security, but only 4 of 9 assessed fraud risks. Such an assessment is important 

as USAID’s Office of Inspector General (OIG) has uncovered multiple instances 

of fraud affecting U.S. programs delivering humanitarian assistance to Syria. In 

May 2016, USAID OIG reported that 1 of its active fraud investigations resulted in 

the suspension of 14 entities and individuals. Given the challenging environment 

in Syria, fraud risk assessments could help U.S. agencies better identify and 

address risks to help ensure aid reaches those in need.

Partners have implemented controls to mitigate certain risks, but U.S. agencies 

could improve financial oversight. For example, almost all partners in our sample 

have controls to mitigate safety risks and some use technology to monitor the 

transport of goods. Additionally, U.S. agencies have taken steps to oversee 

activities in Syria, such as quarterly meetings with partners and spot checks of 

partner warehouses. Further, in October 2015, USAID hired a third party monitor 

to improve oversight of its activities and help verify progress of its programs. 

However, the monitors’ training curriculum lacks modules on identifying fraud 

risks. Without such training, monitors may overlook potential fraud risks and miss 

opportunities to collect data that could help USAID improve its financial oversight.

View GAO-16-629. For more information, 

contact Thomas Melito at (202) 512-9601 or 

melitot@gao.gov.
Page i GAO-16-629 Syria Humanitarian Assistance

Letter 1

Background 3

Three Factors Complicate the Delivery of Humanitarian 

Assistance to People inside Syria 12

U.S. Agencies Do Not Require Comprehensive Risk Assessments 

from Implementing Partners and Most Partners Have Not 

Assessed Risks of Fraud 17

Partners Have Implemented Controls for Delivering Humanitarian 

Assistance inside Syria, but U.S. Agencies Could Improve 

Oversight 21

Conclusions 27

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comments from the Department of State 34

Appendix III Comments from the U.S. Agency for International Development 36

Appendix IV GAO Contact and Staff Acknowledgments 41

Tables

Table 1: Selected Risks Identified in Risk Assessments 

Conducted by Implementing Partners in Our Sample 20

Table 2: Selected Mitigating Control Activities That Responded to 

Identified Risks 22

Figures

Figure 1: Estimated Number of People inside Syria in Need of 

Humanitarian Assistance, 2012 through 2015 4

Figure 2: Total U.S. Funding Obligated toward Humanitarian 

Assistance for People Affected by the Syrian Conflict, as 

of February 2016 (Cumulative) 5

Contents
Page ii GAO-16-629 Syria Humanitarian Assistance

Figure 3: USAID and State Funding Obligated in Support of 

Humanitarian Assistance for People Affected by the 

Conflict in Syria, Fiscal Years 2012 to 2015 6

Figure 4: Percentages of Total International Funding in 2015 for 

the Main Types of Humanitarian Assistance Provided 

inside Syria 7

Figure 5: Top Ten International Donor Countries and 

Organizations Providing Humanitarian Assistance for the 

2015 Syria Response, as of July 2016 8

Figure 6: Operating Environment for Delivery of Humanitarian 

Assistance into Syria, as of June 2015 10

Figure 7: Damage to Health Facilities in Syria After Aerial Attack, 

Tel Shehab, Dara’a (left) and Al Khaf, Rural Damascus 

(right) 14

Figure 8: Contents of Food Parcel with Packing List and Medical 

Kit with Quick Response Code for Tracking 24

Abbreviations 

COSO Committee of Sponsoring Organizations of the Treadway

Commission 

FFP Office of Food for Peace

ISIS Islamic State of Iraq and Syria

NGO Nongovernmental organization 

OFDA Office of U.S. Foreign Disaster Assistance 

OIG Office of Inspector General 

PRM Bureau of Population, Refugees, and Migration 

QR Quick response 

UN United Nations

UNSG United Nations Secretary General 

USAID United States Agency for International Development 

WASH Water, sanitation, and hygiene

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-629 Syria Humanitarian Assistance

441 G St. N.W.

Washington, DC 20548

July 14, 2016

Congressional Requesters

The conflict in Syria has created a complex humanitarian challenge. In 

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. The United States is the largest international donor of 

humanitarian assistance for those affected by the Syrian conflict.

We were asked to review U.S. efforts to provide humanitarian assistance 

to individuals affected by the crisis in Syria. 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 identify factors affecting delivery of humanitarian assistance, we 

reviewed UN reports and conducted interviews with officials from State, 

USAID, and their implementing partners. We conducted a content 

analysis of monthly United Nations Secretary General 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 appropriate financial oversight of 

assistance, we selected a nongeneralizable sample of 12 of 52 fiscal year 

Letter
Page 2 GAO-16-629 Syria Humanitarian Assistance

2015 State and USAID funding instruments1 from 9 different 

implementing partners. Using these funding instruments, as well as the 

Standards for Internal Control in the Federal Government2 and the 

Committee of Sponsoring Organizations of the Treadway Commission 

(COSO) Internal Control-Integrated Framework,

3 we analyzed relevant 

documents related to risk assessment and control activities, including 

policies, procedures, and manuals. We also requested and reviewed risk 

assessments related to delivery of assistance to people inside Syria. We 

interviewed officials from State and USAID in Washington, DC, and 

officials from State and implementing partner organizations in Geneva, 

Switzerland. In addition, we met with officials from State, USAID, and 

implementing partner organizations in Amman, Jordan; and conducted 

telephone interviews with officials from USAID and implementing partner 

organizations in Ankara and Antakya, Turkey, to discuss their policies and 

practices regarding risk assessment and control activities. We also 

conducted site visits to warehouses in Jordan maintained by two of the 

implementing partners.

We conducted this performance audit from July 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

Those 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.

 1

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.

2

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). GAO recently revised and reissued Standards for 

Internal Control in the Federal Government, with the new revision effective beginning with 

fiscal year 2016. See GAO-14-704G (Washington, D.C.: September 2014).

3

Committee of Sponsoring Organizations of the Treadway Commission, Internal ControlIntegrated Framework (May 2013). 
Page 3 GAO-16-629 Syria Humanitarian Assistance

The ongoing conflict in Syria has created a serious humanitarian 

challenge. Syrians, as well as Palestinian and Iraqi refugees residing in 

Syria, have become increasingly vulnerable due to high levels of violence 

and insecurity, causing many to experience multiple displacements. As of 

May 2016, the UN reported that more than 4.8 million Syrians had fled the 

country and registered as refugees, 6.5 million people were internally 

displaced, and 13.5 million people inside Syria were in need of 

humanitarian assistance. In addition, millions of people inside Syria 

remain trapped in besieged and other hard-to-reach areas of the country 

where delivery of humanitarian assistance, including food, is rare or 

nonexistent.4 According to the UN, the number of people in need of 

humanitarian assistance inside Syria has risen steadily since 2012, as 

shown in figure 1.

 4

According to the UN, a besieged area is one surrounded by armed actors with the 

sustained effect that humanitarian assistance cannot regularly enter and civilians, 

including the sick and wounded, cannot regularly exit the area. A hard-to-reach area is 

one to which delivery of aid is difficult for any number of reasons, including active conflict. 

Background

Estimated Numbers of 

People in Need within 

Syria
Page 4 GAO-16-629 Syria Humanitarian Assistance

Figure 1: Estimated Number of People inside Syria in Need of Humanitarian Assistance, 2012 through 2015

U.S. funding obligated in support of humanitarian assistance for people 

affected by the conflict in Syria began in fiscal year 2012 and totaled just 

over $5 billion, as of February 2016, as shown in figure 2.

Funding for and Types of 

Humanitarian Assistance 

Provided
Page 5 GAO-16-629 Syria Humanitarian Assistance

Figure 2: Total U.S. Funding Obligated toward Humanitarian Assistance for People Affected by the Syrian Conflict, as of 

February 2016 (Cumulative)

Approximately half of obligated funding for humanitarian assistance for 

people affected by the Syrian conflict from fiscal year 2012 through fiscal 

year 2015 was provided to people inside Syria, while the other half was 

provided to support the more than 4.8 million people who have fled as 

refugees to neighboring countries.

The U.S. agencies and offices providing humanitarian assistance to 

people affected by the Syrian conflict include USAID’s Office of U.S. 

Foreign Disaster Assistance (OFDA) and Office of Food for Peace (FFP), 

and State’s Bureau of Population, Refugees, and Migration (PRM). From 

fiscal year 2012 through fiscal year 2015, USAID has obligated a majority 

of funding toward the response inside Syria—$1.7 billion for assistance 

inside Syria, and $694 million for assistance in the region. State has 

focused more on assistance to Syrian refugees in the region, providing 

$1.6 billion for refugees in the region and $547 million for assistance to 

people inside Syria, as reflected in figure 3.
Page 6 GAO-16-629 Syria Humanitarian Assistance

Figure 3: USAID and State Funding Obligated in Support of Humanitarian 

Assistance for People Affected by the Conflict in Syria, Fiscal Years 2012 to 2015

The United States and the international community provide funding for a 

range of humanitarian assistance inside Syria. In general, food, shelter, 

nonfood items, health and nutrition, and water, sanitation and hygiene are 

among the main types of humanitarian assistance provided inside the 

country, reflecting the most acute needs. According to USAID, as of 

February 2016, U.S. government assistance was reaching 4 million 

people inside Syria per month. Figure 4 illustrates the relative amounts of 

the main types of assistance provided.
Page 7 GAO-16-629 Syria Humanitarian Assistance

Figure 4: Percentages of Total International Funding in 2015 for the Main Types of Humanitarian Assistance Provided inside 

Syria

Inside Syria, USAID provides funds to UN organizations and also works 

through nongovernmental organizations (NGO), while State works 

through three main partners—two UN organizations and one public 
Page 8 GAO-16-629 Syria Humanitarian Assistance

international organization. Humanitarian assistance provided by the 

United States in response to the conflict in Syria is part of a broader 

international response. Since 2013, the United States has consistently led 

global funding efforts. For instance, the United States provided more than 

a quarter of the total international funding for the 2015 Syria humanitarian 

response. Figure 5 shows the top ten international donors to this effort in 

2015.

Figure 5: Top Ten International Donor Countries and Organizations Providing Humanitarian Assistance for the 2015 Syria 

Response, as of July 2016

In February 2012, the U.S. embassy in Syria suspended operations 

because of concerns over staff safety due to escalating violence. Since 

then, the U.S. government has coordinated Syria-related activities—

including nonlethal assistance, political transition assistance, and 

provision of humanitarian assistance—remotely from locations in Jordan 

Humanitarian Assistance 

Operations
Page 9 GAO-16-629 Syria Humanitarian Assistance

and Turkey through two interagency teams. The Southern Syria 

Assistance Platform, based in the U.S. embassy in Jordan, and the Syria 

Transition Assistance Response Team, based in the U.S. embassy and 3 

other locations in Turkey, coordinate between themselves and with other 

State and USAID representatives, U.S. embassies, the Department of 

Defense, the governments of Jordan and Turkey, and other regional and 

international entities. Along with the Southern Syria Assistance Platform 

and the Syria Transition Assistance Response Team, State officials and 

USAID Disaster Assistance Response Teams manage humanitarian 

programs for Syria in partnership with UN agencies, international NGOs, 

and national organizations.

Humanitarian assistance operations on the ground inside Syria are 

heavily influenced by the ongoing conflict, which began in March 2011 

when demonstrations turned into protests against the government of 

Bashar al-Assad. Over the past 5 years, the conflict has grown more 

complex as the number of participating armed actors has proliferated; 

they now include the Syrian government, non-state opposition groups, the 

Islamic State of Iraq and Syria (ISIS), and the al-Nusrah Front. In 

addition, a number of other countries, including Russia, Saudi Arabia, and 

Iran, have strategic interests in Syria and have been directly or indirectly 

involved in the conflict. In February 2016, the United States and Russia 

brokered a cessation of hostilities, excluding ISIS and the al-Nusrah 

Front. According to the UN, the reduction in violence following the 

cessation of hostilities agreement allowed for increased humanitarian 

assistance deliveries to hard-to-reach and besieged locations in Syria 

during the months of March and April 2016. However, according to State 

and USAID, persistent armed conflict and aerial attacks, including attacks 

on medical facilities, continue to negatively affect millions of Syrians, and 

the UN reports that the resumption of active conflict in several 

governorates has hindered the effective delivery of humanitarian 

assistance as well as people’s access to essential services.

State’s and USAID’s implementing partners contend with the multitude of 

actors as well as shifting conflict lines. In general, implementing partners 

operating out of neighboring countries, mainly Jordan and Turkey, cross 

the border into Syria to deliver assistance into opposition controlled 

areas. UN and international organizations operating from Damascus 

largely remain within Syrian government controlled areas, but may also 

utilize cross-line deliveries—traveling from the Syrian government 

controlled area through checkpoints into opposition controlled areas. 

According to USAID, its NGO implementing partners rarely utilize crossline deliveries. Figure 6 shows this complex operating environment.
Page 10 GAO-16-629 Syria Humanitarian Assistance

Figure 6: Operating Environment for Delivery of Humanitarian Assistance into Syria, as of June 2015

Financial oversight in humanitarian assistance programs includes 

managing program funds to ensure they are spent in accordance with 

funding instruments by, among other things, assessing financial risks and 

implementing controls to mitigate those risks, including controls to prevent 

fraud and losses due to theft and diversion. Standards for Internal Control 

in the Federal Government provides the overall framework for 

establishing and maintaining internal control in the federal programs. In 

Financial Oversight
Page 11 GAO-16-629 Syria Humanitarian Assistance

addition, the Committee of Sponsoring Organizations of the Treadway 

Commission (COSO) has issued an internal control framework that, 

according to COSO, has gained broad acceptance and is widely used 

around the world.5 Both frameworks include the five components of 

internal control: control environment, risk assessment, control activities, 

information and communication, and monitoring. Internal control generally 

serves as a first line of defense in safeguarding assets, such as food and 

nonfood items. In implementing internal control standards, management 

is responsible for developing the detailed policies, procedures, and 

practices to fit the entity’s operations and to ensure they are built into and 

are an integral part of operations.

 5

COSO was formed in 1985 to sponsor the National Commission on Fraudulent Financial 

Reporting, an independent, private sector initiative that studied the causal factors that can 

lead to fraudulent financial reporting and developed recommendations for public 

companies and their independent auditors, the U.S. Securities and Exchange Commission 

and other regulators, and educational institutions. In 1992, COSO issued Internal 

Control—Integrated Framework to help businesses and other entities assess and enhance 

their internal control. Since that time, COSO’s internal control framework has been 

recognized by regulatory standards setters and others as a comprehensive framework for 

evaluating internal control, including internal control over financial reporting. COSO 

updated its framework in May 2013 to enhance and clarify the framework’s use and 

application. 

Internal Control Framework

The internal control standards and 

framework prescribed for federal agencies, 

and those accepted by and widely used by 

organizations around the world, contain five 

components:

We focused on the risk assessment and 

control activities components to gauge the 

extent to which the Department of State, the 

U.S. Agency for International Development, 

and their implementing partners conduct risk 

assessments of humanitarian assistance 

into Syria and implement appropriate 

controls.

According to internal control standards 

prescribed for federal agencies, as well as 

those accepted by and widely used by 

organizations around the world, risk 

assessment and control activities involve, 

among other things:

• 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 risks.

Source: GAO; International Organization for 

Standardization; Committee of Sponsoring Organizations 

of the Treadway Commission. | GAO-16-629
Page 12 GAO-16-629 Syria Humanitarian Assistance

Effective delivery of U.S. humanitarian assistance to people inside Syria 

is complicated by three related factors—a dangerous operating 

environment, access issues, and remote management of programs. 

These factors can hinder the delivery of humanitarian assistance and, 

because U.S. agency officials must manage programs from outside of 

Syria, create challenges for financial oversight, such as increasing the 

opportunity for fraud and diversion.

The increasingly violent and widespread Syrian conflict has hindered 

effective delivery of humanitarian assistance. Based on our analysis of 

monthly UN Secretary General (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.

The years of conflict have led to shifting areas of control as armed groups 

claim and lose territory. In late May 2015, for example, after ISIS took 

over the city of Palmyra, it reportedly seized the Syrian Arab Red 

Crescent warehouse, which contained food assistance for 35,000 people 

and hygiene kits for 15,000. According to USAID officials, this 

represented the largest loss USAID has experienced delivering aid inside 

Syria. In addition, the proliferation of armed actors has made the conflict 

extremely complex. According to one NGO based in Amman and 

operating in Syria, conflict lines in southern Syria that had been stable for 

a number of years began shifting rapidly in February 2016 due to Russian

air strikes.

All UNSG reports from 2014 and 2015 include descriptions of 

indiscriminate aerial bombardment by government forces and 

indiscriminate shelling by armed opposition groups. Implementing partner 

officials based in Damascus, Syria, told us that they are constantly 

reaching out to contacts to determine the safety of planned delivery 

routes.

Humanitarian workers inside Syria must work within the insecure 

operating environment, affecting their ability to carry out their mission and 

placing their lives at risk. In addition, aid facilities are often indirectly 

impacted or directly targeted, leading to widespread damage. According 

Three Factors 

Complicate the 

Delivery of 

Humanitarian 

Assistance to People 

inside Syria

The Deterioration of the 

Security Environment 

Hinders Effective Delivery 

of Humanitarian 

Assistance
Page 13 GAO-16-629 Syria Humanitarian Assistance

to the UN reports, there are frequent instances of gunfire, car bombs, 

barrel bombs6

, rocket strikes, and mortar attacks near aid facilities; direct 

attacks on medical facilities and personnel; missing or detained 

humanitarian workers; and injury or death of humanitarian workers. In one 

instance, an air strike hit the Syrian Arab Red Crescent offices in Idlib, 

destroying ambulances and vehicles. The UN reported that, as a result, 

the capacity of the Red Crescent to provide first aid services in the city 

was curtailed. Medical facilities have also been attacked (see figure 7). 

Physicians for Human Rights reported that as of November 2015, there 

had been 336 attacks on 240 separate medical facilities and 697 medical 

personnel killed inside Syria. In addition, as of the April 2016 UNSG 

Report, a total of 87 humanitarian workers have been killed in Syria in the 

conflict. This includes 17 staff members of the UN, 53 staff members and 

volunteers of the Syrian Arab Red Crescent, 8 volunteers and staff 

members of the Palestinian Red Crescent Society, and 9 staff members 

of international NGOs.

 6

Barrel bombs are improvised, unguided bombs made from large, barrel-shaped metal 

containers packed with explosives and metal or other materials meant to increase 

fragment projection. According to State, the Syrian government has used them against the 

civilian population. 
Page 14 GAO-16-629 Syria Humanitarian Assistance

Figure 7: Damage to Health Facilities in Syria After Aerial Attack, Tel Shehab, Dara’a (left) and Al Khaf, Rural Damascus (right)

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. 

According to the UNSG reports, international NGOs face restrictions,

limiting their ability to partner with national humanitarian organizations, 

open suboffices, conduct missions, join interagency convoys, and 

undertake independent needs assessments. One organization told us that 

the Syrian government has effectively prohibited it from undertaking more 

permanent activities for displaced persons inside Syria, such as 

renovating and repairing community centers and other buildings. 

Furthermore, in early 2016 State reported that since the beginning of 

2015, the Syrian government had received 113 requests from the UN to 

deliver humanitarian aid, of which 13 had been approved and 

implemented.

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 ISIS, the government of Syria, or non-State armed 

opposition groups. Parties to the conflict heavily restrict or deny

humanitarian access to besieged areas, and people risk infectious 

Humanitarian 

Organizations Face 

Difficulties Accessing 

Those in Need
Page 15 GAO-16-629 Syria Humanitarian Assistance

disease, malnutrition, poor sanitation, and lack of medical care. For 

example, in early 2016, the UN estimated that the lives of roughly 42,000 

people remained besieged by government forces in the towns of Madaya 

and Buqayn, where, according to the UN, deaths from diseases 

associated with malnutrition had been reported. Furthermore, the UN 

reported that in 2015, only 10 percent of all requests for UN inter-agency 

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

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

Damascus, even when these convoys were approved, the officials 

participating in delivering the assistance were sometimes subjected to 

hours-long delays, stretching into the middle of the night.

State’s and USAID’s implementing partners also told us that they rarely 

operate inside ISIS controlled areas because they cannot ensure that 

they will be able to operate within the humanitarian principles of humanity, 

impartiality, neutrality, and operational independence.7 The UNSG reports 

contain multiple instances of ISIS blocking humanitarian and commercial 

access into and through areas under its control. For example, in 

November 2015, the UN reported that ISIS controlled and blocked 

humanitarian access to a stretch of highway leading to the western parts 

of Aleppo city. As a result, the UN was unable to deliver assistance to 

over 220,000 people.

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 in 2012 due to 

security conditions and the safety of personnel, among other factors. 

According to State and USAID officials, the inability to access Syria limits 

the visibility that staff have over the provision of humanitarian assistance, 

including program monitoring and financial oversight. USAID officials 

noted, for instance, that unlike humanitarian responses conducted in 

other countries, including those in conflict situations like Afghanistan or 

Iraq, USAID staff are unable to visit project sites in Syria and speak with 

program beneficiaries. USAID officials also acknowledged several gaps in 

their monitoring system due to remote management, such as verifying 

 7

The World Health Organization has been able to successfully carry out polio vaccination 

campaigns in ISIS controlled areas.

Remote Management 

Creates Challenges for 

Financial Oversight of 

Humanitarian Assistance 

Delivered inside Syria
Page 16 GAO-16-629 Syria Humanitarian Assistance

progress, obtaining comprehensive monitoring data on individual 

activities, and assessing the quality of monitoring data reported to USAID.

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. Similarly, staff from several USAID-funded 

implementing partners told us they were unable to access project sites in 

southern Syria, and relied on volunteers or paid NGO and subawardee 

staff to operate, monitor, and disseminate information on project status.

Past audit work has shown challenges to such an approach, including 

cases of partners not fully implementing monitoring practices, resulting in 

limited project accountability.8 Further, USAID Office of Inspector General 

(OIG) has reported that assistance projects implemented in developing 

countries are at significant risk of fraud, waste, and abuse, and further 

noted that those risks are multiplied when projects unfold during a 

disaster or military contingency. Specifically, the USAID OIG has noted 

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.

 8

For instance, in 2012, we reported that security restrictions and limited resources—

resulting in field monitoring constraints—weakened the ability of the World Food Program 

(WFP) to monitor its food distributions in Somalia, Kenya, and Ethiopia. In 2015, we 

reported that limited staff resources—such as USAID having two staff members in the field 

to oversee its Syria regional cash-based projects spread over five countries—and security 

constraints hindered financial oversight of cash-based food assistance projects. Similarly, 

an audit by the WFP OIG found that WFP had been able conduct only a quarter of 

planned verification activities in Syria due to security restrictions.
Page 17 GAO-16-629 Syria Humanitarian Assistance

State and USAID do not require implementing partners to conduct 

comprehensive risk assessments for humanitarian assistance delivered to 

people inside Syria, and while most partners assessed safety and

security risks associated with such programs, most did not assess 

financial risks, such as the risk of fraud. In the absence of such a 

requirement, USAID drafts memoranda highlighting potential risks for 

material support to terrorist groups and identifies the mitigation strategies 

implementing partners will use to reduce those risks. In addition, State 

asks its implementing partners to have internal control policies in place 

and report information on certain risks. U.S. humanitarian assistance 

programs in Syria have experienced instances of fraud, and without such 

formal assessments, implementing partners may not have all information 

needed to design appropriate controls to mitigate such risks. Moreover, 

U.S. agency officials charged with overseeing these programs may not 

have visibility into areas of risk, such as fraud and loss due to theft and 

diversion.

Neither USAID nor State requires implementing partners to conduct 

comprehensive risk assessments for humanitarian assistance to people 

inside Syria. 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. GAO’s Standards for 

Internal Control in the Federal Government and COSO’s internal control 

framework both state that entities should comprehensively identify risks at 

both the entity-wide and activity levels.

While USAID requires implementing partners operating humanitarian 

assistance programs to people inside Syria to assess certain types of 

risk, it does not require these partners to create and maintain a 

comprehensive risk assessment for all relevant risks—which in this 

context could include theft and diversion; fraud; safety; security; program 

governance; and implementing partner capacity risks. USAID’s Office of 

Food for Peace (FFP) and Office of U.S. Foreign Disaster Assistance 

(OFDA) require some implementing partners to create a Safety and 

Security Plan, which addresses security threats and vulnerabilities related 

to program locations and provides information such as contingency 

U.S. Agencies Do Not 

Require 

Comprehensive Risk 

Assessments from 

Implementing 

Partners and Most 

Partners Have Not 

Assessed Risks of 

Fraud

U.S. Agencies Do Not 

Require Comprehensive 

Risk Assessments for 

Humanitarian Assistance 

to People inside Syria
Page 18 GAO-16-629 Syria Humanitarian Assistance

planning and risk mitigation measures.9 Moreover, in response to a GAO 

recommendation, FFP updated its program guidance in March 2015 to 

state that partners applying to conduct cash transfer and voucher-based 

food assistance programs should include in their applications an 

assessment of the risk of fraud or diversion. According to USAID, this 

represents a requirement that cash transfer and voucher-based food 

assistance programs conduct a fraud risk assessment, although it does 

not apply to all types of food assistance or to assistance provided through 

OFDA.10 In the absence of a requirement for all implementing partners to 

conduct comprehensive risk assessments, USAID noted that it works 

closely with partners to ensure accountability and to ensure that 

assistance is reaching beneficiaries. For instance, according to USAID, 

while USAID does not have Syria-specific policies and guidance 

regarding risk assessments related to fraud, it has noted fraud risks in its 

Syria program related to the procurement process and partners have 

worked to address them. Relatedly, USAID officials noted that USAID has 

also implemented a process for documenting risks associated with 

programs in Syria through drafting memoranda highlighting potential risks 

for material support to terrorist groups and identifying the mitigation 

strategies implementing partners will use to reduce those risks.

State’s humanitarian assistance to people inside Syria is funded through 

voluntary contributions to public international organizations, and neither 

the funding instruments for these contributions nor State’s Federal 

Assistance Policy Directive11 require the implementing partner to conduct 

comprehensive risk assessments specifically related to the assistance.12

While there is not a requirement, according to State, it has established 

framework agreements with its implementing partners emphasizing the 

 9 According to USAID, they cannot require public international organizations to submit 

Safety and Security Plans.

10In 2015, FFP amended its program guidance to strongly encourage implementing 

partners delivering all types of food assistance to conduct risk assessments for fraud, but 

stopped short of making it a requirement.

11U.S. Department of State Federal Assistance Policy Directive, U.S. Department of State 

Office of the Procurement Executive A/OPE, January 14, 2016.

12State’s Federal Assistance Policy Directive requires bureaus, offices, and posts to 

conduct risk assessments for assistance provided to foreign public entities, and to create 

monitoring plans using the results of the risk assessments, but these requirements do not 

apply to funding provided through voluntary contributions. 
Page 19 GAO-16-629 Syria Humanitarian Assistance

commitment of the partner to internal controls, including risk 

management. For example, State officials noted that the framework 

agreement for one of its implementing partners is updated every two 

years and tracks the progress of the organization’s efforts to develop 

enterprise risk management. According to State, the basis of State’s 

funding arrangements is that partner organizations should follow their 

own internal requirements for risk assessments, not only for State funding 

but for all contributions. However, the voluntary contribution agreements 

between State and these implementing partners do not reference the 

framework agreements or require comprehensive risk assessments. 

Moreover, acknowledging the need for additional information from 

partners operating in Syria, State has agreements with its implementing 

partners, called enhanced monitoring plans, asking implementing 

partners to regularly provide information on current conditions, including 

assessments of the risks of diversion and harm to staff. While collecting 

additional information on certain risks, the enhanced monitoring plans do 

not require implementing partners to conduct comprehensive risk 

assessments.

All of the implementing partners in our sample have policies, procedures, 

or guidance related to conducting risk assessment for their programs to 

provide humanitarian assistance into Syria, including safety and security 

checklists, risk registers, and other tools for conducting various types of 

risk assessments. Nearly all of implementing partners in our sample 

(seven of nine) have policies, procedures or guidance specifically aimed 

at assessing risks of fraud, such as antifraud policies, procurement 

manuals, and risk assessment procedures for subawards.

Similarly, most of the implementing partners have conducted formal risk 

assessments for at least one type of risk, and several maintain risk 

registers that assess a wide variety of risks. For example, one 

implementing partner maintains a risk register that is updated on a 

quarterly basis and contains an analysis of ten categories of risk, such as 

funding, program governance, and logistics. Another partner based in 

Damascus has a risk register which, according to the partner, assesses 

28 different risks. As shown in table 1, most implementing partners have 

conducted risk assessments for staff safety risks (seven of nine) or 

security risks (eight of nine). However, few implementing partners have 

Most Implementing 

Partners Have Identified 

and Assessed Safety and 

Security Risks to Effective 

Aid Delivery inside Syria, 

But Most Have Not 

Assessed Risk of Fraud
Page 20 GAO-16-629 Syria Humanitarian Assistance

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, 13 effective 

fraud risk 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-16-629

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. For 

instance, in the second half of fiscal year 2015, the USAID OIG received 

47 complaints reporting waste, fraud, and abuse in USAID programs 

related to the crises in Syria and Iraq. According to officials at the 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 

 13GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP 

(Washington, D.C.: Jul. 2015). 
Page 21 GAO-16-629 Syria Humanitarian Assistance

allegations of procurement fraud, bribery, and product substitution in 

USAID funded humanitarian cross-border programs related to 

procurements of non-food items. One of the 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 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.14 Further, in May 2016, USAID 

OIG reported the identification of bid-rigging 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.

Implementing partners in our sample have developed and implemented 

controls over their programs delivering humanitarian assistance to people 

inside Syria. Despite these controls, the inability of some partners to 

consistently access areas in Syria and directly monitor programs has 

created challenges for oversight. To help address these issues, U.S. 

agencies have taken some steps to oversee partner programs; 

nevertheless, opportunities to assess and mitigate the potential impact of 

fraud risks remain.

 14According to the 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 22 GAO-16-629 Syria Humanitarian Assistance

Implementing partners in our sample have developed and implemented 

controls over their programs that deliver humanitarian assistance to 

people inside Syria. For those partners that had conducted risk 

assessments, these controls generally responded to risks they had 

identified. See table 2.

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-16-629

We found that partners in our sample had implemented controls to 

account for safety and security risks to their personnel and beneficiaries 

receiving assistance in Syria. For example, some implementing 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 to door deliveries of aid packages. Another partner 

with field sites in Damascus identified the risk of ambush as a 

vulnerability and provided its drivers with instructions on taking evasive 

actions and fleeing to safety.

Partners in our sample had also implemented controls to mitigate risks of 

fraud and loss within their operations; however, the majority of these 

Partners Have Developed 

and Implemented Controls 

to Mitigate Risks
Page 23 GAO-16-629 Syria Humanitarian Assistance

efforts were not informed by a risk assessment. Four of the nine partners 

in our sample conducted cross-border delivery operations from 

neighboring countries such as Turkey or Jordan and, therefore, procured 

goods in the host country or the region and warehoused them prior to 

transport into Syria. Officials from two implementing partners we 

interviewed in Amman 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. In addition, partners used documentation such as 

packing slips and waybills to verify the contents of shipments. Once 

parcels arrived at warehouses in Syria, partners we interviewed stated 

that staff used technology, such as geotagged photographs, to document 

the arrival and contents of the shipment. Nonetheless, these partners 

stated that the lack of visibility over the assistance while in transit in Syria, 

and managing the projects remotely from Jordan, were risks to their 

operations and therefore required mitigating actions. Furthermore, 

partners we interviewed that relied on transporters to deliver assistance 

within Syria mitigated the risk of loss—including loss due to theft by the 

Syrian Army or armed opposition groups at checkpoints—by shifting 

liability to the transporter and only paying for parcels that were delivered 

to the intended destinations. According to one of the partners, the shift of 

liability to the transporter has limited the instances of diversion, although 

we did not confirm this.

Partners also implemented controls to mitigate fraud risks during the 

distribution process. For example, partners developed criteria for 

identifying and selecting eligible beneficiaries, and compiled this 

information into beneficiary lists to assist the process. Examples of people 

meeting selection criteria included internally displaced people, people 

with disabilities, and female heads of household. In addition, partners 

mentioned working with local councils to develop beneficiary lists. 

Officials at a partner organization we interviewed stated that during the 

distribution process, staff crosschecked the names of beneficiaries on the 

list with identification provided by the beneficiary, and then relayed that 

information to the partner’s field office in Jordan for verification. Officials 

added that this method for verifying beneficiaries was an ongoing 

process, as the lists sometimes changed due to the movement of people.
Page 24 GAO-16-629 Syria Humanitarian Assistance

Two implementing partners that we visited in Jordan, who delivered food 

and medical supplies, among other types of assistance in southern Syria, 

provide examples of the types of controls implemented.

• Emergency food items. By 2015, USAID had awarded roughly $50 

million to an international NGO to deliver emergency food items to 

beneficiaries in southern Syria. We visited the organization’s 

warehouse and observed officials randomly select parcels for 

inspection to verify the quantity and quality of the contents.

• Medical supplies. In fiscal year 2015, USAID awarded about $16

million through a cooperative agreement to an international NGO to 

deliver medical supplies and equipment in southern Syria to support 

health-related infrastructure, such as clinics, among other types of aid 

and services. In Jordan, we visited their warehouse where supplies 

were received, checked for quality, affixed with quick response (QR) 

codes, and packaged, as shown in figure 8.15

Figure 8: Contents of Food Parcel with Packing List and Medical Kit with Quick Response Code for Tracking

 15QR code stands for “quick response code,” a bar code that can be used for monitoring 

and tracking inventory.
Page 25 GAO-16-629 Syria Humanitarian Assistance

State and USAID have taken steps to oversee partner programs 

delivering humanitarian assistance inside Syria. State officials noted that 

State conducts 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. State officials also told us that they ask partners 

to notify them upon discovering incidents of diversion. For example, one 

implementing partner provided frequent updates to State on losses it 

sustained from its transporters until the issue was resolved.

Similarly, USAID officials provided information on several measures taken 

to oversee programs implemented by partners. For example, USAID 

officials we spoke with in Washington explained that officials screen 

proposals from prospective partners to identify those that have 

appropriate measures to mitigate risks and operate in a hazardous 

environment such as Syria. They added that USAID officials in the region 

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. USAID officials in the region also 

receive quarterly reports from partners to monitor progress before 

submitting them to USAID headquarters for additional review. USAID also 

noted that it has implemented an informal biweekly reporting system for 

all partners to provide reports notifying USAID of any challenges or 

potential risks facing the partner in the preceding two weeks. According to 

USAID officials in Washington, USAID officials in the region are the 

immediate officials to oversee programs and detect incidents of fraud; 

and, USAID officials in the region explained that the USAID 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 OFDA 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, 

U.S. Agencies Have Taken 

Steps to Oversee Partner 

Programs but Could 

Strengthen Fraud 

Oversight

Steps Taken to Oversee 

Partner Programs
Page 26 GAO-16-629 Syria Humanitarian Assistance

providing information on the status of projects and including major 

concerns that field monitors identified.

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. For example, the guidelines in the 

monitoring plan instruct field monitors to use color-coded indicators, one 

of which states that issues at a project site require immediate attention 

and action, such as highly significant implementation problems, fraud, 

diversion, or other highly concerning findings. While fraud is mentioned 

with the indicator, it is presented as one of several examples of highly 

concerning findings to document, and could potentially be overlooked by 

the field monitor. 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 the quality of them, among 

other instructions. For example, templates we reviewed related to water 

and sanitation projects instructed field monitors to verify that water was 

delivered to a location, and that water quality tests had been conducted, 

when applicable, among other things. However, the template lacks 

specific 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. For example, training 

categories in the curriculum include basic monitoring and verification 

vocabulary, sampling of records and other secondary data, and color 

coding issues of concern. However, the curriculum lacks specific courses 

for recognizing potential or actual instances of fraud that may occur on 

Fraud Oversight Could Be 

Strengthened
Page 27 GAO-16-629 Syria Humanitarian Assistance

site. Additionally, USAID officials told us that the field monitors supporting 

the third party monitoring contract had not received fraud awareness 

training from USAID OIG, which has been provided to other implementing 

partners with which USAID works to provide humanitarian assistance to 

people in Syria. 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.

The ongoing conflict in Syria has created a complex humanitarian 

emergency. As the largest donor, the United States has taken a leading 

role in providing humanitarian assistance to alleviate the suffering of 

individuals inside Syria who are affected by the conflict and delivers 

assistance to millions per month. Given the significant challenges of 

providing humanitarian assistance in a conflict zone, as well as State and 

USAID’s inability to directly monitor programs inside Syria, the importance 

of financial oversight—which includes conducting risk assessments to 

identify, analyze, and respond to risks and implementing appropriate 

controls—is elevated. Despite the fact that fraud has been detected in 

these assistance programs, most of the partners in our sample did not 

assess fraud risks. Further, while USAID’s third party monitoring contract 

provides a mechanism to gather additional information about its programs 

in Syria, providing clearer instructions to collect data on and training to 

recognize fraud risks may better assist USAID in its efforts to mitigate 

fraud. In the absence of such activities, fraudulent practices may go 

unnoticed or take longer to detect. In addition, State and USAID may not 

have visibility into areas of risk needed to effectively oversee programs 

and provide reasonable assurance that humanitarian assistance funding 

is being used for its intended purpose—to assist individuals in desperate 

need inside Syria.

To improve the financial oversight of U.S. programs to provide 

humanitarian assistance to people inside Syria, we recommend that the 

USAID Administrator take the following four actions:

• Update guidance to require non-governmental organizations to 

conduct risk assessments addressing the risk of fraud.

• Use risk assessments submitted by implementing partners to inform 

USAID oversight activities, for example, using information from 

Conclusions

Recommendations for 

Executive Action
Page 28 GAO-16-629 Syria Humanitarian Assistance

assessments to ensure that control activities for programs are 

designed to mitigate identified risks.

• Ensure that field monitors in Syria are trained on assessing and 

identifying potential fraud risks.

• Instruct the third party monitoring organization monitoring OFDA 

programs in Syria to modify the site visit forms to include specific 

guidance for documenting incidents of potential fraud.

To ensure that State has a comprehensive understanding of the risks 

facing its implementing partners providing humanitarian assistance to 

people inside Syria, we recommend that the Secretary of State take the 

following action:

• Include in its voluntary contribution agreements with implementing 

partners a requirement that the partner conduct risk assessments 

addressing the risk of fraud.

We provided a draft of this report to State and the USAID for review and 

comment. State and USAID provided written comments that are 

reproduced in appendix II and appendix III. State and USAID also 

provided technical comments, which we incorporated as appropriate.

In its written comments on our report, State concurred with our 

recommendation. State noted risk assessment initiatives that it has in 

place with its implementing partners, and indicated that it would include 

provisions in future voluntary contribution agreements with its 

implementing partners that refer to risk assessment requirements, 

including fraud.

USAID also concurred with our recommendations, noting it has 

developed checklists to address fraud mitigation and will soon update its 

guidance to require its implementing partners to submit fraud mitigation 

plans to USAID. Related to our recommendation to provide training to 

field monitors, USAID noted that its third party monitoring in Syria is not 

intended to serve an auditing function or investigate allegations of fraud, 

but noted that USAID could work with the third party monitor to ensure 

that its field monitors are trained in methods to identify fraud risks. We 

agree that the field monitors do not audit the program, but they provide a 

crucial on the ground presence in areas unavailable to U.S. government 

employees. Based on USAID’s comments, we clarified the language of 

this recommendation. 

Agency Comments 

and Our Evaluation
Page 29 GAO-16-629 Syria Humanitarian Assistance

We are sending copies of this report to appropriate congressional 

committees, the Secretary of State, the Administrator of USAID, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.

If you or your staffs should have any questions about this report, please 

contact me 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 report. GAO staff who made key contributions to this 

report are listed in appendix IV.

Thomas Melito

Director, International Affairs and Trade
Page 30 GAO-16-629 Syria Humanitarian Assistance

List of Requesters

The Honorable Ileana Ros-Lehtinen

Chairman

The Honorable Ted Deutch

Ranking Member

Subcommittee on the Middle East and North Africa

Committee on Foreign Affairs

House of Representatives

The Honorable Gerald E. Connolly

House of Representatives

The Honorable Ron DeSantis

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-16-629 Syria Humanitarian Assistance

You asked us to review U.S. efforts to provide humanitarian assistance to 

individuals affected by the conflict in Syria. In this report we examine 

humanitarian assistance provided by the Department of State (State), the 

U.S. Agency for International Development (USAID), and 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 identify factors affecting delivery of humanitarian assistance, we 

conducted a content analysis of all monthly United Nations Secretary 

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

March 2014, when the reports began, through December 2015, to 

categorize and summarize observations contained in the reports. The 

reports, which are submitted to the Security Council pursuant to 

Resolution 2139 (2014), provide information on the humanitarian situation 

in Syria and on the implementation of the key elements of Resolution 

2139, including the extent to which the parties to the conflict are allowing 

humanitarian relief organizations to access people in need inside the 

country. We also conducted interviews with officials from State 

(Population, Refugees, and Migration), and USAID (the Office of U.S. 

Foreign Disaster Assistance and Food for Peace), in Washington, D.C.; 

and we interviewed USAID and implementing partner officials based in 

Antakya and Ankara, Turkey. In addition, we traveled to Geneva, 

Switzerland, and Amman, Jordan to interview officials from State, USAID, 

and implementing partner organizations.

To determine the extent to which State, USAID, and their partners have 

assessed risks to the programs, we selected a nongeneralizable sample 

of 12 fiscal year 2015 State and USAID funding instruments, out of a total 

of 52 funding instruments, from 9 different implementing partners. 

Specifically, we obtained a list of all funding instruments from State and 

USAID based on the following criteria: (1) The funding instrument was 

awarded by State’s Bureau of Population, Refugees and Migration, or 

USAID’s Office of U.S. Foreign Disaster Assistance or Office of Food for 

Peace; (2) the funding instruments were obligated in fiscal year 2015; and 

(3) the implementing partner was based in Syria or a neighboring country 

from which cross-border operations into Syria were conducted. While the 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-16-629 Syria Humanitarian Assistance

results of our review of funding instruments cannot be generalized to the 

entire list, they present a mix of instrument dollar values, implementing 

partners and their locations, and types of humanitarian assistance.1 Using 

these funding instruments, as well as the Standards for Internal Control in 

the Federal Government2 and the Committee of Sponsoring 

Organizations of the Treadway Commission (COSO) internal control 

framework, we analyzed relevant documents from each of the 

organizations related to risk assessment, including policies, procedures, 

and manuals.3 We also requested and reviewed risk assessments related 

to delivery of assistance to people inside Syria. We interviewed State and 

USAID officials in Washington, DC; and officials from State and 

implementing partner organizations in Geneva, Switzerland. We also met 

with officials from State, USAID, and implementing partner organizations 

in Amman, Jordan; and conducted telephone interviews with officials in 

Antakya and Ankara, Turkey, to discuss their policies and practices 

regarding risk assessments.

To evaluate implementation of controls to mitigate risks and ensure 

appropriate financial oversight of assistance, we used our 

nongeneralizable sample of 12 fiscal year 2015 State and USAID funding 

instruments, as well as the Standards for Internal Control in the Federal 

Government and the COSO internal control framework, to analyze 

relevant documents from each of the organizations related to control 

activities, including policies, procedures, and manuals.4 To determine the 

extent to which U.S. agencies are overseeing the activities of 

implementing partners, we interviewed officials from State and USAID in 

Washington, D.C. and Amman, Jordan. We also reviewed USAID’s 

contract with the third party monitoring organization, and supporting 

documentation, such as the monitoring plan, site visit template, and a 

complete monitoring report for February 2016. We interviewed officials 

 1 After discussion with the USAID Office of Inspector General (OIG), we decided to 

remove funding instruments under investigation by the USAID OIG from our sample. We 

replaced these funding instruments with additional instruments. 

2 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: Nov. 1999). 

3 Committee of Sponsoring Organizations of the Treadway Commission, Internal ControlIntegrated Framework (May 2013). 

4 GAO/AIMD-00-21.3.1.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-16-629 Syria Humanitarian Assistance

from State, and USAID in Washington, DC, and officials from State and 

implementing partner organizations in Geneva, Switzerland. In addition, 

we met with officials from State, USAID, and implementing partner 

organizations in Amman, Jordan; and conducted telephone interviews 

with officials from USAID and implementing partner organizations in 

Ankara and Antakya, Turkey, to discuss their policies and practices 

regarding control activities. We also conducted site visits to warehouses 

in Jordan maintained by two of the implementing partners.

We conducted this performance audit from July 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

Those 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.
Appendix II: Comments from the Department 

of State

Page 34 GAO-16-629 Syria Humanitarian Assistance

Appendix II: Comments from the Department 

of State
Appendix II: Comments from the Department 

of State

Page 35 GAO-16-629 Syria Humanitarian Assistance
Appendix III: Comments from the U.S. Agency 

for International Development

Page 36 GAO-16-629 Syria Humanitarian Assistance

Appendix III: Comments from the U.S. 

Agency for International Development

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix.
Appendix III: Comments from the U.S. Agency 

for International Development

Page 37 GAO-16-629 Syria Humanitarian Assistance
Appendix III: Comments from the U.S. Agency 

for International Development

Page 38 GAO-16-629 Syria Humanitarian Assistance

See comment 1.
Appendix III: Comments from the U.S. Agency 

for International Development

Page 39 GAO-16-629 Syria Humanitarian Assistance
Appendix III: Comments from the U.S. Agency 

for International Development

Page 40 GAO-16-629 Syria Humanitarian Assistance

The following is GAO’s comment on the U.S. Agency for International 

Development’s letter dated June 30, 2016.

1. Related to our recommendation to provide training to field monitors, 

USAID noted that its third party monitoring in Syria is not intended to 

serve an auditing function or investigate allegations of fraud, but noted 

that USAID could work with the third party monitor to ensure that its 

field monitors are trained in methods to identify fraud risks. We agree 

that the field monitors do not audit the program, but they provide a 

crucial on the ground presence in areas unavailable to U.S. 

government employees. Based on USAID’s comments, we clarified 

the language of this recommendation. 

GAO Comments
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 41 GAO-16-629 Syria Humanitarian Assistance

Thomas Melito, (202) 512-9601, or melitot@gao.gov

In addition to the contact named above, Elizabeth Repko (Assistant 

Director), Jennifer Young, Justine Lazaro, Cristina Norland, Kyerion 

Printup, Karen Deans, Kimberly McGatlin, Diane Morris, Justin Fisher, 

and Alex Welsh made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact:

Staff 

Acknowledgments:

(100190)
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