GAO-04-276R UNRWA 

November 17, 2003 

The Honorable Mitch McConnell 

Chairman 

The Honorable Patrick Leahy 

Ranking Minority Member 

Subcommittee on Foreign Operations 

Committee on Appropriations 

United States Senate 

The Honorable Jim Kolbe 

Chairman 

The Honorable Nita M. Lowey 

Ranking Minority Member 

Subcommittee on Foreign Operations, Export Financing, and Related Programs 

Committee on Appropriations 

House of Representatives 

Subject: Department of State (State) and United Nations Relief and Works 

Agency (UNRWA) Actions to Implement Section 301(c) of the Foreign 

Assistance Act of 1961

Established in 1949 by the United Nations, UNRWA provides assistance to 

Palestinian refugees in the Middle East. UNRWA assistance is primarily 

education, health, and relief and social services. More than 4 million Palestinian 

refugees are eligible to receive these services in UNRWA’s five areas of 

operation—Jordan, Lebanon, Syria, the West Bank, and Gaza. 

In section 301(c) of the 1961 Foreign Assistance Act (PL 87-195) as amended, 

Congress has directed that “No contributions by the United States shall be made 

to [UNRWA] except on the condition that [UNRWA] take all possible measures to 

assure that no part of the United States contribution shall be used to furnish 

assistance to any refugee who is receiving military training as a member of the socalled Palestine Liberation Army or any other guerrilla type organization or who 

has engaged in any act of terrorism.” 

In 2003, Congress approved the Consolidated Appropriations Resolution, 2003 (PL 

108-7), section 580, which required the General Accounting Office (GAO) to report 

to the appropriations committees on State Department compliance with section 

301(c) of the 1961 Foreign Assistance Act and the implementation of procedures 

established to meet State standards for section 301(c). To fulfill this mandate, we

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-276R UNRWA 

are reporting on State Department actions and UNRWA’s implementation of 

procedures to address section 301(c). As agreed, we briefed your staff on our 

findings on November 6, 2003.1

 Enclosure I documents the information we 

presented to your staff. UNRWA and the Department of State provided technical 

comments on a draft of this briefing, which we incorporated as appropriate. 

Background 

UNRWA employs more than 24,000 staff. More than 90 percent of its staff are 

Palestinian refugees. UNRWA’s mission does not involve administering or 

policing refugee camps. Relevant civil authorities in each area of operations are 

responsible for camp administration and security. Approximately 1.3 million 

refugees live in such camps, while almost 2.8 million refugees do not live in 

camps. 

In calendar 2000-2002, UNRWA spent about $1 billion. During this period, the 

United States provided about $332 million to UNRWA. The State Department 

provided about $300 million during this period, while the U.S. Agency for 

International Development (USAID) granted UNRWA another $32 million. 

Summary 

State has taken actions to implement section 301(c). For example, State requires 

UNRWA to certify that in accepting each contribution from the United States, 

UNRWA is taking all possible measures to assure that U.S funds do not benefit 

terrorists or refugees receiving military training from guerrilla groups. State has 

also acted to improve monitoring by (1) placing a Refugee Coordinator in Amman, 

Jordan, whose main duty is to monitor UNRWA; (2) funding additional UNRWA 

international staff to inspect facilities; and (3) requesting that UNRWA report 

regularly on 301(c) compliance. State has also urged UNRWA to adopt a more 

formal monitoring program. However, State has not defined key terms used in 

section 301(c). 

UNRWA’s implementation of procedures to address section 301(c) is constrained 

by several factors. First, while it relies on host governments to review local job 

applicants for UNRWA employment in Jordan, Syria, and Lebanon, it does not 

have similar arrangements with authorities in the West Bank and Gaza, where 

UNRWA also lacks access to data on arrests of its local staff. Second, UNRWA 

uses international staff to inspect its facilities and requires non-UNRWA groups to 

obtain permission before using those facilities, but it has not been able to prevent 

armed incursions. Finally, UNRWA is constrained in determining if its 

 

1

 Section 580 required GAO to report to the committees by November 1, 2003. Although we were 

prepared to present our findings by that date, we agreed to your staff’s request that we defer our 

briefing to accommodate congressional deliberations on the supplemental appropriations bill. 
Page 3 GAO-04-276R UNRWA 

beneficiaries meet section 301(c) criteria, owing to concerns for its staff’s safety 

and its inability to verify beneficiary responses. 

Scope and Methodology 

To describe State Department actions, we reviewed State and USAID records for 

fiscal 1999-2003 and met with State and USAID officials in Washington, D.C.; 

Jerusalem; Tel Aviv, Israel; and Amman, Jordan. 

To describe UNRWA’s implementation of procedures, we reviewed UNRWA, 

State, and USAID documents. We also met with United States officials in 

Washington, Amman, and Jerusalem. We met with UNRWA management 

(including the directors of each of its five operating areas), staff, and beneficiaries 

in Jerusalem; in Bethlehem and Ramallah, in the Israeli-occupied West Bank; and 

in Amman, Jordan. In addition, we met with Israeli officials in Washington and 

Jerusalem and with Jordanian officials in Amman. 

We performed our review from April 2003 through October 2003 in accordance 

with generally accepted government auditing standards. 

We are sending copies of this report to the Honorable Colin Powell, Secretary of 

State, and to interested congressional committees. Copies will be made available 

to others upon request. In addition, this report will be available at no charge on 

our Web site at http://www.gao.gov. 

If you or your staff have any further questions regarding this assessment, please 

contact me at (202) 512-3149. Cheryl Goodman, Pierre Toureille, and Ella Mann 

also made key contributions to this report. 

David B. Gootnick 

Director, International Affairs and Trade 

Enclosure 
Enclosure I 

Page 4 GAO-04-276R UNRWA 

1

Department of State and 

United Nations Relief and Works Agency

Actions to Implement Section 301(c) of the 

Foreign Assistance Act of 1961

Briefing to the Staffs of 

The Senate Appropriations Subcommittee on Foreign Operations

The House Appropriations Subcommittee on Foreign Operations, 

Export Financing, and Related Programs

November 6, 2003

Source: GAO.
Enclosure I 

Page 5 GAO-04-276R UNRWA 

2

Table of Contents

• Introduction

• GAO Mandate and Objectives

• Results in Brief

• Background

• State Department Actions

• UNRWA’s Implementation of Procedures

• Attachments
Enclosure I 

Page 6 GAO-04-276R UNRWA 

3

Introduction

The United Nations Relief and Works Agency for Palestine Refugees in the Near East 

(UNRWA) provides assistance to Palestinian refugees. UNRWA employs more than 

24,000 staff; almost all are Palestinian. UNRWA facilities include medical clinics and 

schools where the United Nations (UN) flag and symbols are displayed. More than 4 

million Palestinian refugees are eligible to receive benefits in Jordan, Lebanon, Syria, 

the West Bank, and Gaza.

In section 301(c) of the 1961 Foreign Assistance Act, (PL-87-195) as amended, 

Congress has directed that: 

“No contributions by the United States shall be made to [UNRWA] except on the 

condition that [UNRWA] take all possible measures to assure that no part of 

the United States contribution shall be used to furnish assistance to any 

refugee who is receiving military training as a member of the so-called 

Palestine Liberation Army or any other guerrilla type organization or who 

has engaged in any act of terrorism.”
Enclosure I 

Page 7 GAO-04-276R UNRWA 

4

GAO Mandate and Objectives

The Consolidated Appropriations Resolution, 2003 (PL 108-7), section 580, requires 

GAO to report by November 1, 2003, on State Department compliance with section 

301(c) of the 1961 Foreign Assistance Act and the implementation of procedures 

established to meet State standards for section 301(c). 

Objectives:

• Describe actions taken by State to implement section 301(c).

• Describe UNRWA’s implementation of procedures established to meet 301(c).

(See attachment I for our scope and methodology.)
Enclosure I 

Page 8 GAO-04-276R UNRWA 

5

Results in Brief

The State Department has taken actions to implement section 301(c). It has required 

UNRWA to certify that it is taking all possible measures to assure that U.S funds do not 

benefit terrorists and those receiving military training from guerrilla groups. State has also 

acted to improve monitoring and urged UNRWA to adopt a more formal monitoring program. 

However, State has not defined key terms used in section 301(c).

UNRWA’s implementation of procedures to address section 301(c) is constrained by several 

factors. First, while UNRWA relies on host governments to review local job applicants in 

Jordan, Syria, and Lebanon, it does not have similar arrangements with authorities in the 

West Bank and Gaza, where it also lacks access to data on arrests of its local staff. Second, 

UNRWA uses international staff to inspect its facilities and requires non-UNRWA groups to 

obtain permission before using those facilities, but it has not been able to prevent armed 

incursions. Finally, UNRWA does not ask beneficiaries if they are terrorists, owing to 

concerns for its staff’s safety and its inability to verify beneficiary responses.
Enclosure I 

Page 9 GAO-04-276R UNRWA 

6

UNRWA’s Mission

In 1949, the United Nations established UNRWA to provide relief to Palestinian 

refugees. Palestinian refugees are defined as (1) persons who resided in Palestine 

from June 1946 to May 1948 and who lost home and livelihood owing to the 1948 ArabIsraeli conflict and (2) the children of male refugees.

UNRWA currently provides assistance in education, health, and relief and social 

services, among others. More than 4 million refugees are registered in UNRWA’s five 

areas of operation.

UNRWA’s mission does not involve administering or policing refugee camps; these are 

responsibilities of relevant civil authorities.

Background
Enclosure I 

Page 10 GAO-04-276R UNRWA 

7

UNRWA’s Areas of Operation

Figure 1: UNRWA’s Five 

Areas of Operation

Background

UNRWA operates in 

Jordan, Syria, Lebanon, 

and the Israeli-occupied 

areas of the West Bank 

and Gaza.

Source: UNRWA and GAO.
Enclosure I 

Page 11 GAO-04-276R UNRWA 

8

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

 Number of 

Refugees

Jordan Gaza West

Bank

Syria Lebanon

Registered

refugees in

camps:

1,301,689

Registered

refugees not

in camps:

2,780,611

Location of UNRWA-Registered Palestinian Refugees

Background

Source: UNRWA and GAO.

Figure 2: Location of UNRWA-Registered Refugees, as of June 30, 2003 

Totals
Enclosure I 

Page 12 GAO-04-276R UNRWA 

9

UNRWA Expenditures

During calendar 2000-2002, UNRWA 

spent about $1 billion, including $192.3 

million for projects and emergency efforts 

not included in its regular budget. 

Education accounted for about half of 

UNRWA’s spending.

During this period, the United States 

provided about $332 million to UNRWA.

• State contributed about $300 million. 

Its Population, Refugees, and 

Migration Bureau monitors the use of 

these funds.

• USAID granted UNRWA $32 million.

(See attachments II and III.)

Source: UNRWA and GAO.

Figure 3: UNRWA Expenditures, 2000-2002

Background

Health

15%

Education

48%

Relief & 

Social 

Services

8%

Other

11%

Non-Regular 

Budget

18%
Enclosure I 

Page 13 GAO-04-276R UNRWA 

10

UNRWA Staffing

Gaza

33%

West Bank

16%

Syria

12%

Lebanon

12%

Jordan

27%

Background

Figure 4: Percentage of UNRWA Staff Working in Each Area of Operation, as of June 30, 2003

Source: UNRWA and GAO.

Nearly half of UNRWA’s staff 

work in the West Bank and 

Gaza.

Almost all of UNRWA’s 24,300 

staff are Palestinians. About 

92 percent of the Palestinian 

staff are registered refugees.

UNRWA employs fewer than 

150 international (nonPalestinian) staff.
Enclosure I 

Page 14 GAO-04-276R UNRWA 

11

State Conditioned Contributions

State has attached the following condition to each contribution to UNRWA since 

January 1999: 

USAID includes very similar language in its grant agreements with UNRWA.

State Department Actions

It is fully understood and agreed that by accepting this contribution, UNRWA 

certifies that it is taking all possible measures to assure that no part of the 

United States contribution is being used to furnish assistance to any refugee 

who is receiving military training as a member of the so-called Palestine 

Liberation Army or any other guerrilla-type organization, or who has 

engaged in any act of terrorism.
Enclosure I 

Page 15 GAO-04-276R UNRWA 

12

State Acted to Improve Monitoring 

Since 1997, State has assigned a Refugee Coordinator in Amman, whose main duties 

include monitoring UNRWA.

In 2002, State contributed $1.41 million to increase the number of international 

Operations Support Officers in Gaza and the West Bank by 8 to a total of 14.

• Officers conduct unannounced inspections of facilities for any improper use 

(including terrorist-related) and guide UNRWA staff and supplies through 

checkpoints.

In 2003, at State’s request, UNRWA began providing State with 6-month reports on 

301(c) compliance, including information on 

• staff training and disciplinary matters, 

• the Operations Support Officer program, and 

• incursions into UNRWA facilities. 

State Department Actions
Enclosure I 

Page 16 GAO-04-276R UNRWA 

13

State Urged UNRWA to Establish a More Formal 

Monitoring Program

In a letter sent November 1, 2002, Assistant Secretary of State urged UNRWA’s 

Commissioner General to adopt a more formal monitoring system:

State Department Actions

The standard set by the 301(c) language...may necessitate UNRWA instituting 

new mechanisms to ensure adequate oversight....We would like to see 

UNRWA install a more formal program to ensure that its facilities, employees, 

and beneficiaries, to the extent possible, remain free of association with 

terrorism. UNRWA has taken some positive first steps...but could do still more.

The letter also included four specific suggestions for UNRWA to consider (see 

attachment IV).
Enclosure I 

Page 17 GAO-04-276R UNRWA 

14

State Has Not Defined Terms Used in Section 301(c)

State has not defined “all possible measures” or specified activities covered by 

“engaged in any act of terrorism.”

UNRWA officials expressed concerns to us about the phrase “all possible measures” 

because of

• UNRWA’s lack of access to information needed to identify terrorists,

• the possible targeting of UNRWA staff for retaliation, and

• potential conflict with UNRWA’s focus on providing relief.

In 2001, UNRWA proposed replacing “all possible measures” with a pledge that it would 

not “knowingly” aid terrorists or those receiving military training from guerrilla groups.

State rejected UNRWA’s proposal but did not define “all possible measures.”

State Department Actions
Enclosure I 

Page 18 GAO-04-276R UNRWA 

15

Host Governments and Civil Authorities Provide 

UNRWA Varying Support in Reviewing Job Applicants

UNRWA asks applicants for permanent staff positions if they have “been arrested, 

indicted, or summoned into court as a defendant in a criminal proceeding, or convicted, 

fined or imprisoned for the violation of any law.” 

UNRWA does not specifically ask local permanent staff applicants if they ever 

committed an act of terrorism or are receiving guerrilla training.

Jordan and Syria require UNRWA to agree to government vetting of local job 

applicants. UNRWA relies on Jordan, Syria, and Lebanon to verify applicant 

statements on past criminal actions.

UNRWA and civil authorities in the West Bank and Gaza have no such system for 

vetting applicants and verifying statements regarding criminal past.

UNRWA’s Implementation - Staff
Enclosure I 

Page 19 GAO-04-276R UNRWA 

16

UNRWA Monitoring of Staff Neutrality In Occupied 

Territories Constrained by Lack of Information

UNRWA’s policy is to discipline staff who violate the mandatory political neutrality 

pledge.

• The pledge includes restrictions on public speeches and political activities.

• Staff convicted in what UNRWA deems to be fair trials are subject to 

disciplinary action, including termination.

Implementation is constrained by lack of data concerning arrests and convictions.

• According to UNRWA and Israeli officials, Israel does not routinely respond to 

UNRWA inquiries concerning arrested UNRWA staff.

o Israeli officials cite security and other concerns.

• Israel did not inform UNRWA it had recently convicted three UNRWA staff on 

terrorist-related charges. 

o After learning of these cases from us, UNRWA sought additional 

information from Israeli authorities (see attachment V).

UNRWA’s Implementation - Staff
Enclosure I 

Page 20 GAO-04-276R UNRWA 

17

International Staff Help Monitor Facilities

Operations Support Officers spend about 40 percent of their time on 301(c)-related 

duties, including random and unannounced inspections of facilities in the West Bank 

and Gaza. Officers inspected 75.8 percent of UNRWA’s West Bank facilities and more 

than 85 percent of Gaza facilities over a 6-month period.

UNRWA’s Implementation - Facilities

Figure 5: Two Operations Support Officers at On our field visit, officers told us they had the Aida Girls School in the West Bank

not detected any terrorist use of UNRWA 

facilities.

UNRWA plans to phase out the program 

when the current uprising ends.

Source: GAO.
Enclosure I 

Page 21 GAO-04-276R UNRWA 

18

UNRWA Requires Approval for Use of Facilities but 

Cannot Prevent Incursions

The Commissioner General requires outside groups to 

apply for permission to use any UNRWA installation.

• However, in 2001, a Hamas leader spoke at an 

outside group’s event in an UNRWA facility 

without UNRWA’s knowledge. An UNRWA 

teacher in attendance was censured, in part 

because he did not inform UNRWA 

management.

UNRWA is unable to prevent armed incursions into its 

facilities and protests incursions by notifying police 

authorities.

• During the first 6 months of 2003, assailants 

occupied or attacked UNRWA facilities on nine 

occasions.

Source: GAO.

Figure 6: Aida Girls School in the 

West Bank after crossfire damage

UNRWA’s Implementation - Facilities
Enclosure I 

Page 22 GAO-04-276R UNRWA 

19

UNRWA Constrained in Determining if Beneficiaries 

Meet 301(c) Criteria

UNRWA staff do not ask beneficiaries if they have engaged in terrorism or are receiving 

guerrilla training. During our field visit,

• UNRWA’s legal staff told us that responses to such questions could not be 

verified and thus would not be useful, and

• UNRWA, U.S., and Israeli officials told us that UNRWA staff could be 

endangered by asking beneficiaries such questions.

UNRWA’s Implementation - Beneficiaries
Enclosure I 

Page 23 GAO-04-276R UNRWA 

20

UNRWA Says It Has No Evidence to Justify Denying 

Benefits

According to the Commissioner General, as of July 30, 2003, UNRWA has no evidence 

that would justify denying beneficiaries relief or humanitarian aid owing to terrorism.

UNRWA/Gaza has denied rehousing assistance to six families whose houses were 

apparently destroyed during bomb-making activities. However, it did not remove the 

families from its registry of eligible refugees or deny them other assistance.

UNRWA does not note terrorist convictions on refugee registration cards. Officials 

stated that they have not received information on terrorist-related convictions of 

beneficiaries. Social workers question applicants applying for hardship assistance but 

UNRWA relies on families seeking this assistance to volunteer data concerning 

imprisonment on any type of charge. 

UNRWA’s Implementation - Beneficiaries
Enclosure I 

Page 24 GAO-04-276R UNRWA 

21

Scope and Methodology

To determine actions the State Department has taken to implement section 301(c), we 

• reviewed State and USAID records for fiscal 1999-2003 and

• met with State and USAID officials in Washington, D.C.; Jerusalem; Tel Aviv; and Amman.

To describe UNRWA’s implementation of procedures established to meet 301(c), we

• reviewed UNRWA, State, and USAID documents;

• met with UNRWA management (including all five field office directors), staff, and 

beneficiaries in Jerusalem, Bethlehem, Ramallah, and Amman;

• met with U.S. officials in Washington, D.C.; Jerusalem; Tel Aviv; and Amman;

• met with Israeli officials in Jerusalem and Washington, D.C.; and

• met with Jordanian officials in Amman.

State and UNRWA provided technical comments on a draft of this briefing, which we incorporated 

where appropriate.

We performed our review from April 2003 through October 2003 in accordance with generally 

accepted government auditing standards.

Attachment I
Enclosure I 

Page 25 GAO-04-276R UNRWA 

22

Areas and Services to Which UNRWA Allocates Most 

of Its Budget

Attachment II

Figure 7: Allocation of UNRWA’s Education, Health, and Relief and Social Services Budget, 2002

Source: UNRWA and GAO.

0.0

10.0

20.0

30.0

40.0

50.0

60.0

U.S. Dollars,

in Millions

Gaza Jordan West

Bank

Lebanon Syria

Education

Health

Relief &

Social

Services
Enclosure I 

Page 26 GAO-04-276R UNRWA 

23

UNRWA’s Main Programs

Education

• Elementary and preparatory programs (98 percent of the students in 2001)

• Secondary school (Lebanon only) and vocational, technical, and teachertraining programs (2 percent of the students in 2001)

Primary Health Care

• Maternal, child health, and family planning 

• School health services and health education

• Outpatient services

• Prevention and control of diseases

• Dental care

Relief and Social Services

• Aid those who suffer acute socioeconomic hardship

• Promote self-reliance among the less advantaged, in particular, women, youth,

and the physically and mentally challenged 

Attachment III
Enclosure I 

Page 27 GAO-04-276R UNRWA 

24

State’s November 2002 Suggestions and UNRWA’s 

Responses

Attachment IV

• Issue explicit guidelines for staff to report compromises of UNRWA staff or 

facilities

o UNRWA did not respond in writing to this suggestion because it concluded that 

it did not need any additional reporting mechanisms.

• Sever connections with Gaza Youth Activity Centers because of ties to 

Palestinian radicals. 

o UNRWA responded that it would not collocate with the centers but would 

support specific projects.

• Make the Operations Support Officer program a permanent part of UNRWA’s 

monitoring program by including it in the regular budget. 

o UNRWA responded that officers would not be needed after the current 

emergency.

• Continue to make all efforts to meet with Israeli authorities.

o UNRWA responded that it would continue to do so.
Enclosure I 

Page 28 GAO-04-276R UNRWA 

25

Detainments and Convictions of UNRWA Staff

Israeli officials informed us on September 11, 2003, that at least 16 UNRWA staff were 

being detained for various security-related crimes. 

During our field visit, Israeli authorities told us that three UNRWA staff had recently 

been convicted in military courts of terrorism-related activities (see table 1). 

• UNRWA officials told us that they had not been informed of these convictions.

Table 1: Information on Convicted UNRWA Staff

Convicted on 8/31/03, 

sentenced to 32 months

Member of Hamas, possessed machine gun and 

transferred chemicals to assist bomb-maker

November 13, 2002

Convicted on 8/11/03, 

sentenced to 2.5 years

Member of Islamic Jihad, possessed materials 

that could be used for explosives

February 8, 2002

Convicted on 5/27/03, 

sentenced to 7.5 years

Possessed explosives, shot firearm, and threw 

firebombs at a public bus

June 22, 2001

Date of Arrest Criminal Activity Status

Source: UNRWA and Government of Israel data.

Attachment V

(320233)
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