SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

July 29, 2011 

LETTER FOR SECRETARY OF STATE 

U.S. AMBASSADOR TO IRAQ 

SECRETARY OF DEFENSE 

COMMANDER, U.S. CENTRAL COMMAND 

COMMANDING GENERAL, U.S. FORCES–IRAQ 

SUBJECT: Monitoring Responsibilities for Serious Incidents Involving Private Security 

Contractors Once U.S. Military Forces Leave Iraq Have Not Been Determined 

(SIGIR 11-019) 

In September 2007, Blackwater, Inc., a private security contractor (PSC) under contract with the 

Department of State (DoS), was involved in an incident that resulted in the death of 17 Iraqi 

civilians. As a result of the incident and its repercussions, the Department of Defense (DoD) and 

DoS took actions to improve their coordination and oversight of PSCs involved in serious 

incidents.1 In April 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) 

reported on the DoD system for reporting, investigating, and remediating serious incidents 

involving PSCs in Iraq.2 Because of the planned withdrawal of U.S. military forces from Iraq in 

December 2011, SIGIR reviewed the U.S. government’s current and planned oversight of PSCs 

in that country. In April 2011, SIGIR reported on the relationship between the U.S. Army Corps 

of Engineers’ Gulf Region District’s reconstruction activities and its security contract 

requirements with Aegis Defense Services, Limited.3

SIGIR’s objectives for this report were to determine (1) changes in the serious incident reporting 

and investigating system since SIGIR’s 2009 report, (2) plans for the system after U.S. military 

forces leave Iraq, and (3) coordination of serious incidents with the Government of Iraq (GOI). 

SIGIR also followed up on the status of recommendations in its April 2009 report. SIGIR will 

be issuing separate reports on the current status of those recommendations. 

SIGIR performed this audit under the authority of Public Law 108-106, as amended, which also 

incorporates the duties and responsibilities of inspectors general under the Inspector General Act 

of 1978 and in furtherance of a mandate in Section 842 of the National Defense Authorization 

Act for 2008, Public Law 110-181, pertaining to contracts for the performance of security and 

reconstruction functions in Iraq. SIGIR encountered significant constraints imposed by DoS’ 

Bureau of Diplomatic Security. The Bureau was unresponsive to SIGIR’s requests for 

 

1

 According to DoD guidance a serious incident includes, but is not limited to, “any damage of equipment or injury 

to persons, attacks, any weapons discharge, criminal acts, traffic accidents, incidents involving ISF [Iraqi Security 

Forces] and any incident believed to have possible strategic or operational impact. Incidents where aggressive 

personal behavior and share the road policies are violated shall be reported.” 

2 Opportunities To Improve Processes for Reporting, Investigating, and Remediating Serious Incidents Involving 

Private Security Contractors in Iraq, SIGIR 09-019, 4/30/2009. 3 Gulf Region District Is Adjusting Its Aegis Security Contract Requirements for Changes in Reconstruction 

Activities in Iraq, SIGIR 11-015, 4/27/2011. 
2 

information. This adversely affected the report and limited its scope, methodology, and our 

ability to accomplish audit objectives. SIGIR also incurred significant delays from the U.S. 

Central Command in obtaining information and access to military personnel due to the lengthy 

process the Command required SIGIR to use. These constraints and delays are described further 

in Appendix A to this report. 

SIGIR found that the system for reporting and investigating serious incidents involving U.S. 

government PSCs has changed little since SIGIR’s 2009 report. Moreover, DoD’s system is 

projected to remain unchanged through the end of December 2011, when U.S. military forces 

plan to leave Iraq. We were told by U.S. military officials that the predominant types of serious 

incidents have changed over the last few years from attacks and shots fired to traffic accidents 

and harassments at checkpoints. Our review of serious incidents reported from September 2010 

through May 2011 confirmed that the majority of reported incidents are traffic accidents and 

incidents at checkpoints. 

The system’s future is less certain as responsibilities for monitoring the activities of DoD PSCs 

has not been fully determined and may be disestablished, even though U.S.-funded PSCs will 

continue to support DoD and DoS organizations and the U.S. Agency for International 

Development. We could not determine DoS’ plans for its PSCs that currently report their 

missions and serious incidents through DoD’s system, because DoS would not provide us with 

that information. 

U.S. agencies are coordinating serious incidents that involve their PSCs with the GOI. Guidance 

requires that DoD PSCs report their serious incidents to U.S. military authorities and to the local 

police for incidents involving Iraqi nationals. We were told by U.S. military officials responsible 

for overseeing PSC reporting that they rely on the PSCs to report their incidents to the local 

police. We were also told that U.S. military and Embassy personnel periodically meet with GOI 

officials to discuss PSC operations and serious incidents. This was confirmed by an official with 

the GOI’s Ministry of Interior who expressed satisfaction with U.S. government efforts to inform 

the ministry. 

Background 

For purposes of reporting and investigating serious incidents, PSCs operating in Iraq are 

categorized by tiers, based on the organization for which they are working. The U.S. Embassy’s 

Regional Security Office (RSO) is responsible for coordinating the missions of DoS PSCs that 

directly support the Chief of Mission. These are referred to as Tier I PSCs that provide services 

to DoS under the Worldwide Personal Protective Services contracts. The missions of DoS 

private security contractors and subcontractors who indirectly support the Chief of Mission 

(referred to as Tier II) are coordinated through DoD channels.4

 Serious incidents involving Tier 

I PSCs are reported directly to the RSO, whereas serious incidents involving Tier II PSCs are 

reported to the RSO through DoD channels. The RSO is responsible for investigating incidents 

involving Tier I and Tier II contractors and subcontractors. 

 

4

 For example, PSCs supporting contractors, subcontractors, and grantees working for DoS agencies and the U.S. 

Agency for International Development are considered Tier II PSCs. 
3 

DoD relies on the Contractor Operations Cells (CONOC) throughout Iraq to coordinate the 

missions of DoS Tier II PSCs; DoD PSCs (referred to as Tier III); and PSCs who support foreign 

embassies, commercial enterprises, and others in Iraq (referred to as Class C).5 The CONOC is 

also responsible for gathering, assembling, and distributing information on serious incidents 

involving the Tier II and Tier III PSCs. DoD also relies on the Armed Contractor Oversight 

Branch (ACOB) to receive serious incident reports from the CONOC and ensure that all serious 

incidents involving DoD Tier III PSCs are reported, tracked, and investigated. Both the CONOC 

and ACOB are under U.S. Forces–Iraq (USF-I), which is in U.S. Central Command’s chain of 

command. Figure 1 shows the serious incident reporting process. 

Figure 1—Serious Incident Reporting Process 

Source: SIGIR developed from DoS and USF-I guidance (6/2011). 

 

5

 Class C PSCs are not required to coordinate their missions with or report their serious incidents to U.S. military 

forces although they are encouraged to do so. Neither DoD nor DoS has the responsibility for investigating 

incidents involving Class C PSCs. 
4 

System for Reporting and Investigating Serious Incidents Has 

Changed Little Since 2009 and Is Projected To Remain Unchanged 

Through 2011 

The system for reporting and investigating serious incidents has changed little since 2009 and is 

projected to continue as is through 2011. According to RSO officials, DoS’ guidance to its PSCs 

is contained in a policy directive issued in May 2008.6

 Basically, that guidance specifies that 

Tier I PSCs are to report their serious incidents to the RSO, which is responsible for 

investigating those incidents, if needed. Tier II PSCs are required to report their serious 

incidents to the CONOC and RSO, and the RSO is responsible for investigating those serious 

incidents as well, if needed. According to RSO officials, and as shown in Figure 1, reporting by 

Tier II PSCs has changed slightly in that they are now required to report their serious incidents 

only to the CONOC. 

Current USF-I guidance for Tier III PSCs operating in Iraq concerning reporting and 

investigating serious incidents is contained in Appendix 20 to Annex C of USF-I Operations 

Order 11-017

, hereafter referred to as “Appendix 20.” Our comparison of the current guidance 

with the guidance in effect at the time of our April 2009 report shows that key provisions 

pertaining to the reporting and investigating processes and the responsibilities of organizations in 

those processes have not materially changed. The following examples illustrate these processes 

and responsibilities: 

 Tier III PSCs who are involved in, observe, or suspect a serious incident are to 

immediately alert the CONOC of the incident, submit an initial report within four hours, 

and conduct an internal investigation of the incident and submit a final incident report 

within 96 hours. The PSCs are also to report serious incidents to the requiring activity 

for whom they are performing work and to the contracting officer and contracting officer 

representative for the contracts under which they are performing. The incident reports 

are to include such information as who, what, when, and where of each incident; the 

contract number; and contact information on the contracting officer representative. 

 The CONOC is to refer all serious incidents involving Tier II PSCs to the RSO and all 

serious incidents involving Tier III PSCs to ACOB. ACOB is to ensure that incidents 

involving Tier III PSCs are reported, tracked, and investigated. 

 The government organizations receiving the PSCs’ services, hereafter referred to as the 

requiring activities, are to review the Tier III PSCs’ final incident reports, determine if 

they sufficiently document the relevant facts, and whether further investigations are 

necessary. If the final reports are sufficient, the requiring activities must determine 

whether disciplinary or corrective actions are needed, and report the results to ACOB. If 

the PSCs’ reports are insufficient, the requiring activities must appoint investigating 

officers or refer the matters to investigative authorities. ACOB is to ensure the requiring 

activities are aware of and are fulfilling their responsibilities. 

 

6 U.S. Embassy Baghdad Policy Directive for Armed Private Security Contractors, 5/11/2008. 7

 Entitled “Armed Contractor Oversight.” 
5 

 ACOB is to maintain a list of all PSCs operating in Iraq under a U.S. government 

contract and a copy of all endorsed serious incident reports, investigative reports, and 

corrective action reports pertaining to Tier III PSCs. 

According to ACOB officials, the predominant types of reported incidents have changed over the 

last few years from attacks and shots fired to traffic accidents and harassments at checkpoints. 

Our review of the serious incidents reported from September 1, 2010 to May 31, 2011 found that 

the top six serious incidents recorded were road traffic accidents, checkpoint incidents, 

improvised explosive devices, vehicle breakdown, negligent discharge of firearms, and indirect 

fire. There were other incidents that were less frequent, such as stone throwing, small arms fire, 

medical injuries, compound searches, grenade attacks, and lost weapons. 

In our previous report, the predominant types of serious incidents (reported from February 24, 

2008 through February 28, 2009) were incidents involving road traffic accidents, improvised 

explosive devices, graduated force responses, negligent discharges of firearms, and small arms 

fire. Figure 2 illustrates the number and types of incidents for a 9-month period from 2010-2011. 

Figure 2—Serious Incidents by Type and Month (9/2010 through 5/2011) 

Note: 

Other incidents include stone throwing, small arms fire, medical injuries, compound searches, grenade attacks, and lost weapons. 

Source: SIGIR developed from ACOB database (June 2011). 

As the figure above shows, traffic accidents and checkpoint incidents far exceed any other type 

of serious incidents reported by PSCs to the CONOC. Specifically, traffic accidents and 

checkpoint incidents accounted for 57% of all incidents reported over the period September 1, 

2010 through May 31, 2011. In our previous report, checkpoint incidents accounted for only 2% 

of all incidents reported, while traffic accidents accounted for 22% of all incidents reported over 

the period February 24, 2008 through February 28, 2009. 
6 

We found that some improvements to the reporting and investigating processes recommended in 

SIGIR’s April 2009 report are no longer relevant because of changes in the serious incident 

reporting processes or other factors. For example, we recommended that the CONOC and RSO 

periodically compare serious incident data for Tier II PSCs, because these PSCs were previously 

required to report their incidents to both organizations, and there were differences in the 

organizations’ incident databases. This will no longer be an issue because Tier II PSCs are to 

report their incidents only to the CONOC. 

We found that other recommendations had not been implemented despite concurrence from the 

Multi-National Force–Iraq, USF-I’s predecessor. For example, we recommended that the MultiNational Force–Iraq task supporting organizations to identify all PSC subcontractors that support 

DoD contracts. Appendix 20 states that ACOB is responsible for maintaining and updating the 

list of PSCs operating under a U.S. government contract or subcontract. We were told by an 

ACOB official that ACOB’s list of DoD PSCs comprises PSCs which have requested arming 

authority. We were also told by an ACOB official that the Defense Contract Management 

Agency has been assigned the responsibility for tracking all DoD PSCs. Defense Contract 

Management Agency personnel told us they track only PSCs for which they have been assigned 

administrative responsibility. 

According to ACOB officials, CONOC and ACOB operations are to continue through December 

2011 although there will be reductions in the number and size of CONOC operations as U.S. 

military forces in Iraq decline. ACOB officials told us that the CONOC operates with 31 

contractor personnel from 4 locations. The number of contractor personnel and locations will 

decline through the remainder of calendar year 2011 and may be disestablished at the end of the 

year. The number of personnel in ACOB has already been reduced to two full-time personnel 

from three in 2009, with one devoted to managing PSC arming authority. The ACOB may be 

disestablished when USF-I withdraws from Iraq in December 2011. 

Responsibilities for Monitoring U.S. Government PSCs Once U.S. 

Military Forces Leave Iraq Have Not Been Determined 

We were told by RSO officials that the RSO has no plans to assume the responsibilities currently 

performed by the CONOC or ACOB once U.S. military forces leave Iraq, even though PSCs 

working for DoD and DoS agencies and the U.S.Agency for International Development will be 

operating in Iraq after 2011. We requested further information from DoS on its plans for the 

coordination of Tier II missions and the reporting of Tier II serious incidents once U.S. military 

forces leave Iraq but did not receive that information, despite repeated requests. 

ACOB officials told us that the Office of Security Cooperation–Iraq (OSC-I) has agreed to 

monitor its PSCs but the decision concerning which organization(s) will monitor the 

performance of other DoD PSCs has not been made. OSC-I is scheduled to begin operations on 

October 1, 2011 and will be responsible for managing the U.S. Foreign Military Sales and 

International Military Education and Training programs in Iraq. Although we requested to speak 

with individuals who might be familiar with OSC-I’s role and responsibility with regard to 

monitoring PSCs, U.S. Central Command did not honor that request. 
7 

U.S. Military and Embassy Are Coordinating Serious Incidents with 

Government of Iraq 

U.S. agencies in Iraq are coordinating serious incidents with the GOI. We were told by RSO 

officials that USF-I and RSO representatives meet with GOI officials to discuss issues related to 

PSCs, and the meetings sometimes result in additional GOI guidance or directions that are 

passed on to PSCs. According to the officials, the meetings have been primarily about 

administrative issues pertaining to PSC operations, such as the need for specialized PSC license 

tags and weapons licenses. The officials stated that it is difficult for PSCs to comply fully with 

Iraqi laws and regulations, because the GOI is constantly changing requirements. Also, the GOI 

issues directives, but it does not have the resources to implement those directives. For example, 

PSCs are supposed to have license tags that clearly identify them as PSCs, but the factory that 

was supposed to produce those tags has not yet produced them. 

The December 2007 Memorandum of Agreement between DoD and DoS on U.S. government 

PSCs states that the U.S. Embassy and Multi-National Forces–Iraq will coordinate in the 

notification of the GOI as soon as possible after a serious incident occurs. Our attempts to get 

further information on this notification process from DoS officials proved unsuccessful. 

Appendix 20 states that PSCs involved in incidents involving local nationals or involved in shots 

fired at or near local nationals will report such incidents to the local Iraqi police as soon as 

possible and, at a minimum, if security conditions permit, PSCs should stop and exchange details 

with local nationals/police/army involved in the incident. According to ACOB officials, they 

rely on the PSCs to report incidents involving local nationals to the Iraqi police. ACOB officials 

stated that reports of serious incidents received from PSCs and that involve Iraqi civilians, 

police, and/or property damage are stripped of sensitive information (such as passport number), 

translated, and forwarded to the Ministry of Interior’s equivalent of ACOB. Also, about once a 

month, ACOB personnel meet with the commanding general of the Iraqi Ministry of Interior’s 

equivalent of ACOB to discuss incidents and issues pertaining to U.S. government PSCs. The 

officials stated that many meetings revolve around issues pertaining to the retrieval of PSC 

weapons and equipment confiscated at Iraqi police and military checkpoints. The officials 

further stated that the Iraqis’ as well as the PSCs’ lawyers are usually involved in discussions 

pertaining to serious incidents. 

We spoke with the commanding general of the Iraqi Ministry of Interior’s equivalent of ACOB 

who told us that he is very satisfied with the U.S. government’s efforts to inform his ministry of 

serious incidents involving Iraqi civilians, property damage, and security forces. He confirmed 

that his office receives copies of serious incidents and that U.S. government officials periodically 

meet with him to discuss issues pertaining to PSCs. He indicated that the Ministry is currently 

discussing devising a system to track PSC movements and to provide assistance to PSCs 

involved in serious accidents. 

Conclusions 

The current oversight system of U.S. government PSCs was established to guard against serious 

incidents that could embarrass the U.S. government or have serious consequences for U.S.-Iraq 

relations. We were told that discussions are underway between U.S. military and DoS officials 
8 

concerning future roles and responsibilities of U.S. government organizations to remain in Iraq 

after December 2011. We have not been privy to the effects of those discussions. However, in 

other countries where the U.S. has diplomatic missions, the Chief of Mission is ultimately 

responsible for the activities of U.S. government executive agencies in those countries and 

communicating and coordinating with the host government. Although we could not obtain 

complete information concerning the reporting and investigating of serious incidents once U.S. 

military forces leave Iraq, it appears no single U.S. organization in Iraq will be responsible for 

overseeing the actions of U.S.-funded PSCs and resolving any serious incidents with the GOI 

involving PSCs if the Chief of Mission does not fill the role. 

Recommendation 

Because the Chief of Mission is responsible for the activities of all U.S. government executive 

agencies in Iraq once U.S. military forces leave the country, we recommend that the Chief of 

Mission be made expressly responsible for establishing a system to monitor all U.S. government 

PSCs operating in country and the incidents in which they are involved. 

Management Comments and Audit Response 

USF-I’s ACOB concurred with SIGIR’s draft report. ACOB’s response provided information 

that supports statements previously provided to SIGIR. For example, the Chief of Mission will 

track Tier 1 movements, and OSC-I will track their own PSCs. It stated that the ACOB duties 

and responsibilities will transfer to OSC-I no later than October 2011. It leaves open the 

question of whether the OSC-I ACOB responsibilities will include tracking all serious incidents 

involving DoD contracted PSCs. For comments from USF-I’s ACOB, see Appendix E. 

The USF-I Inspector General provided a response for SIGIR’s consideration. The Inspector 

General stated: 

USF-I continues to support SIGIR in making information and personnel available for 

their audit in the most expeditious manner. SIGIR auditors had unremitted support 

from USF-I in order to fulfill their data collection requirements. 

USF-I staff work within the Command and its subordinate units through the RFI 

[Request for Information] and FRAGO [Fragmentary Order] systems which enable 

proper staffing and follow through on all requests. The RFI and FRAGO processes 

ensure consistency in staffing, timeliness, and accuracy of all requests. Thus all audit 

agencies receive timely and precise information as a result of this process. 

SIGIR enjoys a strong and mutually supportive relationship with USF-I, and USF-I personnel 

spend significant time and effort to support SIGIR’s requests for information. SIGIR is very 

appreciative of USF-I’s support. Despite that support, SIGIR has not consistently had direct 

access to USF-I personnel who are responsible for the programs and issues SIGIR is auditing. 

Moreover, although the intent of the RFI and FRAGO systems may be to ensure that audit 

agencies receive timely and precise information, SIGIR believes the systems did not work as 

intended on this audit. It is for these reasons that SIGIR will work with USF-I to try to resolve 

issues that adversely impact and impair SIGIR’s independence and cause unnecessary delays to 

SIGIR’s audits. For comments from USF-I’s Inspector General, see Appendix F. 
9 

DoS did not provide SIGIR with comments on a draft of this report in time to consider in 

preparing the final report. Any comments received by SIGIR from DoS on this report will be 

discussed in SIGIR’s next semi-annual report to the Congress. 

- - - - 

We appreciate the courtesies extended to the SIGIR staff. For additional information on the 

report, please contact Glenn D. Furbish, Assistant Inspector General for Audits (Washington, 

DC), (703) 604-1388/ glenn.furbish@sigir.mil or Jason Venner, Principal Deputy Assistant 

Inspector General for Audits (Washington, DC), (703) 607-1346/ jason.venner@sigir.mil. 

Stuart W. Bowen, Jr. 

Inspector General 

cc: Assistant Secretary, Bureau of Diplomatic Security 
10 

Appendix A—Scope and Methodology 

Scope and Methodology 

In August 2010, the Special Inspector General for Iraq Reconstruction (SIGIR) announced 

Project 1019 to review the U.S. government’s oversight of private security contractors in Iraq. 

SIGIR’s objectives for this report are to determine (1) changes in the serious incident reporting 

and investigating system since SIGIR’s 2009 report, (2) plans for the system after U.S. military 

forces leave Iraq, and (3) coordination of serious incidents with the Government of Iraq. SIGIR 

performed this audit (1) under the authority of Public Law 108-106, as amended, which also 

incorporates the duties and responsibilities of inspectors general under the Inspector General Act 

of 1978 and (2) in furtherance of a mandate in Section 842 of the National Defense 

Authorization Act for 2008, Public Law 110-181, pertaining to contracts for the performance of 

security and reconstruction functions in Iraq. SIGIR conducted its work from November 2010 

through June 2011, primarily from its headquarters in Arlington, Virginia. 

We conducted this audit in accordance with Government Auditing Standards8

, except for general 

standard 3.10, External Impairments. Generally accepted government auditing 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. Certain 

inappropriate external impairments to our independence limited the scope of our audit, as 

discussed in more detail below. 

Section 3.10 of Government Auditing Standards requires that audit organizations must be free 

from external impairments to independence. The section states that, under certain conditions, 

auditors may not have complete freedom to make an independent and objective judgment, 

thereby adversely affecting the audit. The section specifically cites the following conditions 

under subsections (a) and (d): (a) external interference or influence that could improperly limit 

or modify the scope of an audit or threaten to do so and (d) externally imposed restrictions on 

access to records, government officials, or other individuals needed to conduct the audit. 

SIGIR believes that significant constraints imposed by the Department of State’s (DoS) Bureau 

of Diplomatic Security and delays imposed by U.S. Central Command impaired its independence 

and limited its scope, methodology, and ability to fully accomplish its audit objectives. SIGIR is 

required by law to inform the Secretaries of State and Defense and SIGIR’s oversight 

committees in the Congress, whenever requested information or assistance is unreasonably 

refused or not provided. See Public Law 108-106, Section 3001(h). As a result of DoS’ 

constraints, SIGIR will be reporting this impairment to the Secretary of State and to SIGIR’s 

oversight committees in Congress. SIGIR will not be reporting the delays imposed by U.S. 

Central Command because the Command has agreed to work with SIGIR to resolve these issues. 

The following paragraphs describe our scope and methodology and the constraints and delays 

encountered. 

 

8 Government Accounting Standards: July 2007 Revision, GAO-07-731G, July 2007. 
11 

To determine changes in the serious incidents reporting and investigation system since SIGIR’s 

2009 report, we compared current guidance issued by U.S. Forces–Iraq (USF-I) and the U.S. 

Embassy to private security contractors and discussed with officials of those organizations their 

implementation of that guidance. 

To determine plans for the system after U.S. military forces leave Iraq, we discussed with USF-I 

and U.S. Embassy Regional Security Office (RSO) officials the status of those plans. After an 

initial discussion with RSO officials, we were told that all additional information and follow-up 

questions would have to be cleared through DoS’ Bureau of Diplomatic Security. Our repeated 

attempts to obtain additional information from the Bureau were unsuccessful. For example, at 

the request of the Bureau’s audit liaison, we provided a detailed list of questions and issues 

which we wanted to discuss with Bureau officials. We offered to meet with Bureau officials to 

discuss the questions and issues. Despite our efforts, Bureau officials never responded to our 

requests for meetings or information. 

To determine coordination of serious incidents with the Government of Iraq (GOI), we reviewed 

USF-I and U.S. Embassy guidance pertaining to coordination with the GOI. We also discussed 

coordination mechanisms with USF-I officials and RSO officials. In addition, we discussed with 

a GOI official, whose office is responsible for overseeing the activities of private security 

contractors, the information that office receives from the U.S. government on serious incidents 

involving U.S. contracted private security contractors. As stated above, our attempts to obtain 

further information from RSO officials were stymied by the Bureau of Diplomatic Security, 

which never responded to our requests. 

The U.S. Central Command imposed a process that delayed our access to records and USF-I 

officials, and that adversely affected our audit. They required that all requests for information 

from USF-I be in writing and channeled through the Command and that all information in 

response to our requests flow through the Command. All requests for meetings and discussions 

with USF-I officials also had to be channeled through the Command and in writing. A two-week 

response time was imposed on every request for information and meeting, even follow-up or 

clarifying questions for previously discussed issues. This seriously delayed our ability to ask 

clarifying questions about data provided. SIGIR believes that the Command’s process impaired 

our independence and limited our scope, methodology, and ability to fully accomplish our audit 

objectives. 

Use of Computer-processed Data 

The computer-processed data of serious incidents was obtained from the Armed Contractor 

Oversight Branch (ACOB), USF-I. It was the most complete data available and used by ACOB 

to manage serious incidents. Moreover, it is used for illustrative purposes and is not critical to 

SIGIR’s conclusions or recommendation. 

Internal Controls 

Because of the limitations placed on SIGIR’s work, we were able to perform only a limited 

review of internal controls relevant to our audit objectives. 
12 

Prior Coverage 

We reviewed the following SIGIR reports: 

Gulf Region District Is Adjusting Its Aegis Security Contract Requirements for Changes in 

Reconstruction Activities in Iraq, SIGIR 11-015, 4/27/2011.

Opportunities To Improve Processes for Reporting, Investigating, and Remediating Serious 

Incidents Involving Private Security Contractors in Iraq, SIGIR 09-019, 4/30/2009. 

Oversight of Aegis’s Performance on Security Services Contracts in Iraq with the Department of 

Defense, SIGIR 09-010, 1/14/2009. 

 
13 

Appendix B—Acronyms 

Acronym Description 

ACOB Armed Contractor Oversight Branch 

CONOC Contractor Operations Cells 

DoD Department of Defense 

DoS Department of State 

GOI Government of Iraq 

OSC-I Office of Security Cooperation–Iraq 

PSC Private Security Contractor 

RSO Regional Security Office 

SIGIR Special Inspector General for Iraq Reconstruction 

USF-I U.S. Forces–Iraq 
14 

Appendix D—Audit Team Members 

This report was prepared and the audit conducted under the direction of Glenn D. Furbish, 

Assistant Inspector General for Audits, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Michael A. Bianco 

Robert L. Pelletier 

Nadia Shamari 
15 

Appendix E—USF-I ACOB Comments 
16 

Appendix F—USF-I Inspector General Comments 
17 

Appendix G—SIGIR Mission and Contact Information 

SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, and 

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective: 

 oversight and review through comprehensive audits, 

inspections, and investigations

 advice and recommendations on policies to promote 

economy, efficiency, and effectiveness

 deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse

 information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the American 

people through Quarterly Reports

Obtaining Copies of SIGIR 

Reports and Testimonies

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

SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

 Web: www.sigir.mil/submit_fraud.html

 Phone: 703-602-4063

 Toll Free: 866-301-2003

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

Affairs 

Mail: Office of the Special Inspector General 

for Iraq Reconstruction 

 2530 Crystal Drive 

 Arlington, VA 22202-3940 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Deborah Horan 

Director of Public Affairs 

Mail: Office of the Special Inspector General 

for Iraq Reconstruction 

 2530 Crystal Drive 

 Arlington, VA 22202-3940 

Phone: 703-428-1217 

Fax: 703-428-0817 

Email: PublicAffairs@sigir.mil