OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

(703) 428-1100 or PublicAffairs@sigir.mil Special Inspector General for Iraq Reconstruction 

Summary of Report: SIGIR 11-010 

Why SIGIR Did This Study 

In June 2007, the Multi-National Corps–Iraq 

(MNC-I) began using Commander’s Emergency 

Response Program (CERP) funds to hire former 

insurgents and their passive supporters to guard 

checkpoints, buildings, and key parts of 

neighborhoods in Iraq. Known as the Sons of 

Iraq (SOI) program, the effort has been credited 

with helping reduce the overall levels of 

violence in Iraq. During the course of the 

program, MNC-I spent approximately $370 

million drawn from fiscal year 2007-2009 

CERP funds. Past SIGIR reports have identified 

weaknesses in the management of CERP funds. 

Our reporting objectives for the SOI program 

are to determine (1) the program’s contribution 

to reducing violence in Iraq, (2) the 

effectiveness of financial management controls, 

and (3) the status of GOI efforts to integrate SOI 

personnel into Iraqi ministries. 

What SIGIR Recommends 

The Secretary of Defense should direct the 

Under Secretary of Defense (Comptroller) to 

revise CERP guidance to include direction on 

when related projects should be managed as a 

program with clearly defined objectives, 

implementing regulations, and metrics for 

assessing results. 

Management Comments and Audit 

Response 

SIGIR received written comments from the 

Office of the Secretary of Defense 

(Comptroller). The comments stated that DoD 

has revised its Financial Management 

Regulation to manage CERP as a program, and 

CERP Program Managers have oversight of the 

individual projects. The letter also cites other 

specific sections of the regulation that provide 

guidance on the program. SIGIR acknowledges 

DoD’s improvements. However, SIGIR’s 

recommendation is directed at field-level 

management of CERP. At this level, the SOI 

program was not run as an integrated program. 

Rather it was managed as 779 independent 

projects with no overarching management 

structure. SIGIR is seeking field-level direction 

about when related projects should be managed 

as a program. Consequently, we do not consider 

the DoD comments to be responsive to our 

recommendation. 

January 28, 2011 

SONS OF IRAQ PROGRAM: RESULTS ARE UNCERTAIN AND 

FINANCIAL CONTROLS WERE WEAK

What SIGIR Found 

Insufficient quantifiable program data, coupled with the inability to 

segregate possible SOI effects from other factors, precluded SIGIR from 

drawing empirically reliable conclusions about the program’s contribution to 

the reduction in violence in Iraq that began in the late summer of 2007. 

MNF-I officials and commanders we spoke with stated that they believe SOI 

was an important factor in reducing violence and provided a number of 

anecdotal examples in support of their opinions. However, it is not possible 

to draw more definitive conclusions about the program’s effects. 

Specifically, there was no comprehensive plan for SOI with specific goals, 

metrics or milestones from which to measure the individual or collective 

impact of the effort. Additionally, there was no requirement for 

commanders to document what SOI groups achieved or for any other 

organization to assess overall program impact in areas such as reductions in 

insurgent attacks. Given the absence of detailed information on SOI effects 

and the reality of many other factors affecting the levels of violence in Iraq 

during the same time period, such as the influx of large numbers of 

additional U.S. forces during the Surge, SIGIR is unable to draw reliably 

supportable empirical conclusions about the full extent of SOI contributions 

in this area. 

Overall, SIGIR found the MNF-I exercised weak financial controls over its 

cash payments to the SOI. SIGIR found that payments were often made 

directly to the SOI leader rather than to individual SOI members. In 

addition, in some files, the pay agent simply provided the same amount of 

money each month without determining how many SOI were actually 

working and for how many hours they ostensibly worked during the month. 

For example, for a four-month project estimated to cost $331,200, the pay 

agent simply automatically provided $82,800 each month for a total of 

$331,200. In the few instances where payments were made to individual 

SOI members, the payments were usually lower than estimated. For 

example, in one project file, 545 SOI members were on the official registry, 

but only 454 signed the pay roster and collected their salaries. This reduced 

actual costs 17% from an estimated $62,884 to $52,384. Furthermore, key 

financial control documentation including cash controls, receipts, and 

vouchers were usually missing from project files. 

Since assuming full control of the SOI program in April 2009, the GOI has 

faced difficulties in managing the program, properly paying the SOI, and 

integrating SOI into Iraqi ministries. The GOI promised to employ 95,120 

SOI members but to date has provided offers to only 39,224. Additionally, it 

has not offered any jobs since November 2009. The GOI has paid the SOI 

members on time only 42% of the time. According to USF-I, the perception 

of broken promises and GOI indifference has eroded public confidence, 

furthered SOI distrust of the GOI, and increased fear of insurgent influence 

over SOI. While the GOI has made progress during a period where they 

were unable to form a government, such problems raise questions if the GOI 

can maintain reconciliation with the SOI. 

 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

January 28, 2011 

MEMORANDUM FOR U.S. SECRETARY OF DEFENSE 

UNDER SECRETARY OF DEFENSE (COMPTROLLER) 

SUBJECT: Sons of Iraq Program: Results Are Uncertain and Financial Controls Were Weak 

(SIGIR 11-010)

We are providing this audit report for your information and use. The report discusses the Sons of 

Iraq program, a U.S. Forces–Iraq Commander’s Emergency Response Program. We performed 

this audit in accordance with our statutory responsibilities contained in Public Law 108-106, as 

amended, which also incorporates the duties and responsibilities of inspectors general under the 

Inspector General Act of 1978. This law provides for independent and objective audits of 

programs and operations funded with amounts appropriated or otherwise made available for the 

reconstruction of Iraq, and for recommendations on related policies designed to promote 

economy, efficiency, and effectiveness and to prevent and detect fraud, waste, and abuse. This 

audit was conducted as SIGIR Project 1004. 

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: U.S. Secretary of State 

U.S. Ambassador to Iraq 

Commander, U.S. Central Command 

Commanding General, U.S. Forces–Iraq 

S i l I t G l f I R t ti
Table of Contents 

Table of Contents i

Introduction 1

Background 1

Objectives 4

Sons of Iraq May Have Contributed to Reducing Violence, but Lack of 

Documentation Precludes Drawing Empirically Based Conclusions 5

MNC-I Cites the SOI Program as a Factor in Reducing Violence 5

Lack of Project Documentation Precludes Drawing Empirically Based Conclusions 7

Weak Financial Controls and Documentation of Cash Payments 11

SOI Payments Were Not Based on Documented Services Provided 11

Project Files Lacked Required Financial Documentation 12

GOI Takes Management Control of SOI, but Challenges Remain in 

Integrating SOI into Iraqi Ministries 15

GOI Assumes Full Management Responsibility for SOI 15

Payments by Government of Iraq to SOI Consistently Late 18

Conclusions and Recommendations 20

Conclusions 20

Recommendation 21

Management Comments and Audit Response 22

Appendix A—Scope and Methodology 23

Appendix B—Acronyms 26

Appendix C—Audit Team Members 27

Appendix D—Management Comments 28

Appendix E—SIGIR Mission and Contact Information 30
1 

Sons of Iraq Program: Results Are Uncertain and 

Financial Controls Were Weak 

SIGIR 11-010 January 28, 2011

Introduction 

In September 2006, enemy-initiated attacks in Iraq had reached some of the highest levels since 

the U.S. invasion in March 2003. These attacks, initiated primarily by members of Al-Qaeda in 

Iraq (AQI), were against both Iraqi citizens and Coalition Forces. At the same time, Coalition 

Forces found that citizens in Anbar Province were reacting very strongly against the violence. 

Hoping to take advantage of the backlash, Coalition Forces met with groups and tribes, some of 

whom previously worked with AQI to convince them to work as allies against AQI. Ultimately 

this dialog led to a program called the Sons of Iraq (SOI). 

In June 2007 the Multi-National Corps–Iraq (MNC-I) began using Commander’s Emergency 

Response Program (CERP) funds to hire passive supporters and former insurgents to guard 

checkpoints, buildings, and key parts of neighborhoods. The SOI program, in combination with 

other events, most notably the 2007 surge of U.S. forces into Iraq, has been credited with helping 

reduce the overall levels of violence. During the course of the program, MNC-I spent 

approximately $370 million of fiscal year 2007 through 2009 CERP funds. Past SIGIR reports 

have identified weaknesses in the management of CERP funds, and SIGIR investigators have 

conducted numerous criminal investigations of individual misconduct related to CERP-funded 

activities. In one example, in December 2009, a U.S. Army Captain pled guilty to stealing 

approximately $690,000, primarily SOI funds. Given the large amount of funding, the 

previously reported management weaknesses, the burgeoning CERP-related criminal cases, and 

the risk associated with giving large amounts of funds to former insurgents, SIGIR initiated a 

review of the SOI program. 

MNC-I provided the overall program coordination for CERP in Iraq for the Multi-National 

Force–Iraq at the time the SOI program was undertaken in 2007. MNC-I and the Multi-National 

Force–Iraq were reorganized into U.S. Forces-Iraq (USF-I) on January 1, 2010. Therefore, USFI is the current responsible command for addressing matters discussed in this report. However, 

we continue to refer to MNC-I and MNF-I in this report since they were the organizations that 

approved and implemented these projects. 

Background 

The Commander’s Emergency Response Program 

In May 2003, the Coalition Provisional Authority formalized the CERP in Iraq, authorizing U.S. 

field commanders to use available funds to respond to urgent humanitarian, relief, and 

reconstruction requirements within their areas of responsibility. The funds were to be used to 

execute programs that immediately assisted indigenous populations and achieved “focused 
2 

effects.” Initial funding for CERP came from seized Iraqi assets and the Development Fund for 

Iraq.1

 As stated in SIGIR’s October 2010 Quarterly Report, as of September 2010, CERP 

allocations for Iraq from U.S.-appropriated funds had reached an estimated $3.79 billion.2 While 

CERP is intended for small-scale, urgent humanitarian relief and reconstruction projects 

benefiting the Iraqi people, larger scale projects may be undertaken if approved by appropriate 

Department of Defense (DoD) officials. 

CERP is governed by statutes, a financial management regulation, and a standard operating 

procedure guide. The statutes provide congressional direction and the funding level for CERP. 

The DoD provides detailed implementation guidance to commanders through the DoD Financial 

Management Regulation.3 MNC-I, headquartered in Baghdad, provided the overall program 

coordination for CERP in Iraq for the Multi-National Force-Iraq. 

The primary operational guidance for using CERP is a MNC-I standard operating procedure 

guide titled Money as a Weapons System (MAAWS) that provides direction on implementing 

CERP projects and identifies categories of CERP projects that are permissible. At the creation of 

the SOI program, one category of permissible projects was “protective measures,” which allowed 

for the hiring of temporary civilian contract guards to enhance the durability and survivability of 

critical infrastructure. In 2008 the MAAWS added Sons of Iraq as an allowable project under 

the “protective measures” category, and in January 2009 MNC-I added an additional CERP 

category called “Temporary Contract Guards for Critical Infrastructure,” specifically for groups 

like the SOI. 

Sons of Iraq Program 

As discussed, in September 2006, enemy-initiated attacks in Iraq had reached the highest levels 

since the U.S. invasion in June 2003, and to a large extent the attacks were attributed to AQI. 

While numerous tribes had been supporting AQI, the increased attacks on their citizens, 

particularly in Anbar Province, caused the tribes to begin turning away from associating with and 

supporting AQI. In what was called the “Anbar Awakening,” local groups throughout Anbar 

province worked with both Coalition and Iraqi Security Forces to fight AQI and bring security to 

their neighborhoods. DoD credits these groups with improving the security in the region. 

In January 2007, the U.S formally announced a new strategy for its war effort. The strategy 

entailed sending an additional 20,000 troops to Iraq, increasing the size of Iraqi Security Forces, 

and increasing support to tribes willing to help Iraqis fight AQI. Key to the counterinsurgency 

principles was the positioning of many troops into communities where they would help Iraqis 

protect the population and work more closely with local Iraqis. 

According to MNF-I, the experience with the Anbar Awakening became a model for exploiting 

the rift between insurgent groups and the population. Wanting to take better advantage of the 

Anbar Awakening and to complement the new U.S. strategy, in June 2007, MNC-I began 

 

1

 In May 2003, the United Nations Security Council Resolution 1483 established the Development Fund for Iraq as a 

means to channel revenue from Iraqi oil sales, unencumbered oil-for-food deposits, and repatriated Iraqi assets to the 

relief and reconstruction efforts for Iraq. 

2

 SIGIR currently has an audit underway to determine the status of CERP funds. 

3

 The Under Secretary for Defense (Comptroller) is responsible for the DoD Financial Management Regulation. 
3 

awarding CERP critical infrastructure security contracts to leaders, including sheiks, to provide 

security at key locations such as guard checkpoints, buildings, and key parts of neighborhoods. 

The concept of using critical infrastructure security contracts to change former insurgents and 

passive supporters into active supporters of the U.S. counter-insurgency effort eventually became 

known as the Sons of Iraq program.4 USF-I has been working with the Iraqi government to 

transition SOI members into the Iraqi Security Forces or other government jobs. 

MNC-I provided direction in implementing the program through military orders. These orders 

provided specific requirements including the following: 

 SOI must be locally screened and vetted, take a pledge of loyalty, and have their names 

entered into biometric databases. 

 SOI roles and responsibilities will be limited. For example, coalition forces are not 

allowed to arm or provide ammunition to the SOI; and SOI are only allowed to operate in 

their designated sectors in a defensive posture and not wear Iraqi Security Forces 

uniforms. 

 Multi-National Divisions must report the number of SOI being paid as well as the 

numbers entered into biometric databases. 

In preparation for the transfer of the program to the GOI between July and August 2008, the 

MNF-I entered the name of each individual on an SOI contract into a database called the 

Personal Asset Inventory. The database was created by MNF-I in order to better quantify the 

numbers of SOI for acceptance by the GOI. At the time, there were approximately 779 

individual SOI agreements covering almost 100,000 SOI in 9 provinces in Iraq. The sheer 

numbers of agreements and personnel in the SOI program made SOI one of the largest DoD 

contracts for static security. 

Figure 1 shows SOI strength from June 2007 to February 2009. 

 

4

 Between June 2007 and February 2008, MNF-I called these groups “Concerned Local Citizens.” For purposes of 

this report, we are using “Sons of Iraq.” The Daughters of Iraq program is separate from the Sons of Iraq program 

and is not a part of this review. 
4 

Figure 1—SOI Numbers from June 2007 to February 2009 

Source: USF-I presentation of monthly SOI numbers. 

In October 2008, MNF-I began transferring control of 51,135 Baghdad-based SOI to GOI 

control. At that time, the USF-I role became one of monitoring, advising, and assisting. 

Currently, USF-I reports on activities involving SOI across the country and works with cognizant 

GOI agencies. These include the Implementation and Follow-up Committee for National 

Reconciliation, which has responsibility for SOI transition; and the Office of Disarmament, 

Demobilization, and Reintegration, which has responsibility for pay. In addition, individual 

USF-I divisions continue to report on the status of SOI in their area and engage with both Iraq 

and SOI officials. 

Objectives 

Our reporting objectives for our review of the Sons of Iraq program are to determine (1) the 

program’s contribution to reducing violence in Iraq, (2) the effectiveness of financial 

management controls, and (3) the status of GOI efforts to integrate SOI personnel into Iraqi 

ministries. For a discussion of the audit scope and methodology and a summary of prior 

coverage, see Appendix A. For a list of acronyms used, see Appendix B. For the audit team 

members, see Appendix C. For management comments, see Appendix D. For the SIGIR 

mission and contact information, see Appendix E. 

 
5 

Sons of Iraq May Have Contributed to Reducing 

Violence, but Lack of Documentation Precludes 

Drawing Empirically Based Conclusions

In April 2008, the MNF-I reported that the SOI program, in conjunction with the implementation 

of counterinsurgency principles, the 2007 addition of 20,000 U.S. troops and 100,000 Iraqi 

Security Forces, and Moqtada al-Sadr’s 2007 announced cease fire, were the four factors that 

reduced violence in Iraq.5

 MNF-I credited the SOI with the discovery of weapons and 

explosives caches, and also concluded that the SOI program was cost effective. According to 

MNF-I, the SOI program enabled Coalition Forces to identify and disarm more improvised 

explosive devices (IEDs), and the savings from vehicles not lost to IEDs were greater than the 

costs of the SOI contracts. 

While SIGIR does not dispute the examples provided by MNF-I of SOI accomplishments, 

SIGIR’s ability to draw more definitive conclusions about the program is limited because there 

was no comprehensive plan with specific goals, metrics, estimated costs, milestones for 

completion, or organizations accountable for assessing project outcomes for the SOI program. 

Moreover, there was no requirement for local commanders to document what their SOI 

contingents achieved. Given the absence of such information coupled with the difficulty in 

segregating the effect of the SOI from other factors such as the influx of large numbers of 

additional U.S. forces, SIGIR is unable to measure effects against the specified program goals 

and metrics. 

MNC-I Cites the SOI Program as a Factor in Reducing Violence 

Current and former officials provided SIGIR anecdotal examples to support their conclusion that 

the program was a success and a key factor in reducing violence in Iraq. Military and GOI 

officials we spoke with noted that the SOI program was one of the key components in improving 

the security situation in Iraq. In addition, commanders stated that, in their opinion, the program 

was one of the most effective uses of CERP. 

The SOI provided intelligence on the location of insurgent groups and weapons caches, acted as 

a force multiplier by freeing U.S. and Iraqi forces to perform other operations; denied insurgent 

groups a recruitment pool; and, in some cases, began to cooperate with the Iraqi Security Forces. 

Moreover, MNF-I has previously noted that a clear indicator of SOI success is that they are 

targeted by the insurgents. Specific examples of success that MNF-I officials provided include 

the following: 

 The SOI members were recruited from the local population and used their knowledge of 

insurgent weapons caches to support U.S. goals. For example, in June 2007, SOI in 

Diyala told U.S. forces where 261 improvised explosive devices were located. 

 

5

 Moqtada al-Sadr is the leader of the Sadrist movement, which includes the Shi’a extremist militia Jaysh al-Mahdi. 
6 

 The SOI members, with knowledge of their neighborhoods, were able to identify 

insurgents and their locations. One commander we spoke with noted that he took action 

specifically in response to an SOI report that provided insurgent locations. 

 The SOI provided local security that allowed Iraqi Security Forces and Coalition Forces 

to deny AQI and other insurgent groups freedom of movement. For example, in the 

Rashid area of Iraq, one commander estimated that insurgent attacks led to approximately 

500 deaths a month. After the SOI program, these groups were unable to operate, leading 

to a 50-60 percent drop in violence in his area

 The salaries paid to the SOI denied a recruitment pool to insurgent groups. According to 

one former U.S. commander, his area was infiltrated by Shia insurgent groups who 

recruited individuals with promises of pay and other benefits. However, the insurgent 

group’s ability to recruit significantly decreased when the SOI program began paying 

salaries to individuals who otherwise might have joined these groups. 

 Some SOI members began working with the Iraqi Security Forces. For example, one 

commander we spoke with stated that with the help of Coalition Forces, the SOI in his 

area built a working relationship with the Iraqi Security Forces. 

Additional information that supports SOI success is the number of attacks conducted against 

SOI. At their peak in the spring of 2008, there were about 100 attacks per month with about 75 

SOI killed. According to USF-I, while attacks against SOI have decreased over time, these 

attacks were more targeted at leaders rather than members. Figure 2 shows the attacks and 

ensuing casualties from January 2008 to October 2010. 
7 

Figure 2—Attacks, Wounded in Action, and Killed in Action SOI from January 

2008 to October 2010 

Source: USF-I. 

Lack of Project Documentation Precludes Drawing Empirically 

Based Conclusions 

Despite MNC-I’s position that the SOI program was successful, we found little documentation 

on the program’s successes and accomplishments. According to USF-I, this is partly due to the 

fact that USF-I did not retain all MNC-I data. MNC-I did not develop an overall master plan for 

the execution and management of the SOI program prior to program implementation. While 

SIGIR found some elements of a master plan including goals, objectives, and milestones within 

fragmentary orders, other elements including estimated costs, metrics, or organizations 

accountable for assessing project outcomes could not be found. While the program received 

constant attention from senior MNF-I leadership, in written responses to questions posed by 

SIGIR, USF-I stated, “it does not appear that initially there was a great deal of centralized 

control or a grand, coalition-wide strategy.” 

Based on discussions with former MNF-I officials and a review of MNC-I guidance, planning 

was accomplished through a series of documents developed at different points in time. For 

example, initial guidance was provided through fragmentary orders that listed the goals, 

objectives, and program constraints. The fragmentary orders also required units to report the 

numbers of SOI and the number entered into biometric databases. As the program matured, 

guidance regarding transfer to the GOI was sent out in fragmentary orders. However, SIGIR 

could not find any information or any guidance or orders requiring that information be collected 

during the course of the program regarding the direct impact of the SOI. 
8 

The MAAWS similarly did not require the development of comprehensive plans for CERP 

projects. To some degree, the need for plans is identified in a Center for Army Lessons Learned 

handbook on CERP, titled Commander’s Emergency Response Program: Tactics, Techniques, 

and Procedures (March 2008). However, the handbook presents this more as a suggestion than a 

requirement. 

SIGIR has previously reported that while the lack of a comprehensive plan may be appropriate 

for small projects, planning becomes more necessary as the size and complexity of projects 

increases. SIGIR believes that this is the case for the SOI. In SIGIR’s prior report we identified 

significant issues regarding the management of a collection of 46 CERP construction projects at 

the Baghdad Airport valued at $35.5 million, and recommended that the Secretary of Defense 

direct the Under Secretary of Defense (Comptroller) to revise CERP guidance to include a 

requirement that a project implementation plan be developed for large-scale projects. 6 USF-I, 

however, did not agree. At issue is whether multiple related projects constitute a program. In 

the case of the SOI, there were 779 separate SOI agreements valued at approximately $370 

million. In SIGIR’s view, related projects of this size and cost constitute a program and require 

comprehensive planning and documentation of accomplishments. 

SOI Accomplishments Were Not Documented 

SIGIR conducted a review of 98 SOI project files and found little information on project 

accomplishments or successes. Changes to MAAWS made late in the program required 

commanders to develop metrics for measuring program accomplishments in 4 of these files, but 

our review of project files found that these metrics were missing. 

Project documentation in the SOI files we reviewed generally contained financial documents and 

a few generic documents describing the responsibilities of each party. These included signed 

memoranda of agreement between the project purchasing officer and the contractor and a 

statement of work or description of the scope of work required. The documents we reviewed 

also identified the number of SOI that were to be provided, the amount each person was to be 

paid, and the work that was to be performed, along with implementing requirements such as “all 

weapons used by contractor will be registered by serial number with the CF [Coalition Forces],” 

and “Contractor and all hired employees must be registered into the [biometric data base].” 

Various Scope of Work statements we reviewed also generally contained processes for 

overseeing the agreements. For example, one Scope of Work statement we reviewed included 

the following: 

 Contractor will provide the Coalition Forces a by-name daily manning status report 

detailing the strength, location, and shifts of all security forces at each of the designated 

critical infrastructure sites. The contracting officer’s representative and partnering unit 

commander may make no-notice inspections to confirm the contractor’s report. 

 

6 Commander’s Emergency Response Program: Projects at Baghdad Airport Provided Some Benefits, but Waste 

and Management Problems Occurred; SIGIR 10-013, April 26, 2010. 
9 

 Contractor is responsible for providing Coalition Forces a daily list of all personnel who 

are present for duty. This list will be used to determine what security guards are paid on 

a weekly basis. 

 Any person receiving pay from the contractor will have his identity verified against his 

entry in the biometric database. 

 The Contractor must submit an invoice which should include both a list of all employees 

and the hours worked and an itemized list of all costs incurred with the work of securing 

the designated infrastructure for the designated period of time. Once the partnering 

Coalition Force verifies the security responsibilities have been carried out satisfactorily, 

payment will be made. 

SIGIR’s review of the 98 SOI project files found only 1 file that contained any documentation 

that indicates that an effort was made to verify or confirm that the agreed-upon services were 

performed. In general, there were no daily manning status reports, no attendance reports, and no 

documents that verified that the security responsibilities were carried out. For the one project 

with documentation, the commander noted that the SOI members fully complied with the terms 

and conditions of the contract, and that spot checks by the brigade validated this. In addition, the 

commander noted that the SOI presence deterred insurgent groups from conducting illegal acts, 

thus reducing violence. 

In interviews SIGIR conducted with commanders who had knowledge of SOI activities, we were 

told that the commanders monitored the SOI to ensure they performed in accordance with the 

Statement of Work but that they did not document their oversight in project files. Commanders 

we spoke with, for example, noted that while patrolling their designated areas they would 

corroborate that the SOI were at their agreed-upon location and that the number of SOI paid to 

be at the site were present. In other cases, commanders noted that while they maintained this 

information they did not include it in the CERP project files. One commander informed us that 

he had maintained such documentation in unit files, but he was unable to find the information 

when he later returned to Iraq. 

SIGIR does not dispute the examples provided by MNC-I of SOI accomplishments. The 

examples and interviews from Anbar Province, in particular, are persuasive. However, the 

examples cited provide little insight into how widespread the successes were or their causes. 

With 779 separate agreements taking place in 9 provinces, it is possible that the successes and 

the reasons for the successes differ by area. For example, it is unclear if the successes in 

Baghdad were similar to those in Anbar. With no documentation as to what occurred or why, it 

is not possible to glean any lessons learned, or to broadly conclude that the program in its 

entirety was successful according to the program’s goals and objectives. 

In January 2009, MNC-I amended the MAAWS to require metrics for individual projects over 

$50,000. Of the 98 project files SIGIR reviewed, these requirements applied to 4. However, 

SIGIR’s review found that none of the 4 files contained the required performance metrics. 

SIGIR found a few project files that contained documents stating that the particular SOI had a 

positive impact on security but the documents had no metrics or other information detailing how 

the assessments were made. 
10 

MNF-I provided information that showed that as the numbers of SOI increased, violence in Iraq 

decreased. However, the information provided did not isolate the effects of SOI independently 

of the other factors MNF-I cites as contributing to the decrease in violence. In addition, 

classified studies attempted to measure the SOI’s effectiveness, but were unable to do so due to a 

lack of information. 
11 

Weak Financial Controls and Documentation of Cash 

Payments 

Overall, SIGIR found the MNC- I exercised weak financial controls over its cash payments to 

the SOI. In SIGIR’s review of 98 SOI project files, SIGIR found that payments were often made 

directly to an SOI leader to distribute instead of to the individual SOI members directly, without 

any means of verifying that each SOI received his salary. In addition, the MNC-I often simply 

provided the same amount of money each month without determining how many SOI were 

actually working during that period. In some instances where payments were made to individual 

SOI members, the payments were lower than the original agreed-upon estimate. Furthermore, 

key financial control documentation including cash controls, receipts, and vouchers were often 

missing from the project files. 

SOI Payments Were Not Based on Documented Services Provided 

Although 97 of the 98 SOI project files reviewed contained no information on whether the SOI 

actually provided the services required by the Memorandum of Agreement, payments were made 

nonetheless. Payments without support raise questions about whether the program was actually a 

fee-for-services agreement or had some other purpose. At a minimum it indicates that payments 

were possibly made for services that were not rendered and to personnel who may not have 

actually been working. Further, payments were often made directly to the SOI leader rather than 

to the individuals. According to USF-I and MNC-I officials involved with the program, units 

either gave payments directly to an SOI leader as a sign of trust or did so because they could not 

take the time to pay each SOI member individually. In most cases, there was no attempt to 

determine the exact number of persons eligible to receive payments each month. According to 

USF-I, providing payments directly to SOI members was physically impossible, and in a combat 

situation and would have been an extremely high security risk to bring SOI members together in 

such a large group. 

SIGIR found that in 35 of the 98 project files reviewed that MNC-I routinely paid the full 

estimated amount for SOI services in the area. For example, Multi-National Division–South 

approved a $248,800 SOI project and later expanded the project by an additional $82,800 

bringing the total to $331,200. This was to cover the salaries of 345 SOI for four months. 

Payments were made once a month, and each payment was $82,800. This would be justified 

only if, over a four-month period, not one SOI member missed a single day of his assigned work. 

Further, the cash was provided to the SOI leader without any documentation verifying the 

number of SOI paid. In another example, MNF-I estimated the cost of the planned SOI activities 

at $494,208. Once again, the amount disbursed to the SOI leader was exactly $494,208. Aside 

from the internal control weakness indicated by this practice, it also raises concerns about 

whether or not services were validated by MNC-I. 

When we discussed the lack of documentation and the practice of paying the SOI leader instead 

of individual SOI members, MNC-I and GOI officials agreed that the practice had its risks and 

that in the cases where actual costs equaled estimated costs, MNC-I likely paid more than 

warranted by the Memorandum of Agreement. Since taking control of the program, the GOI has 
12 

refused to provide payments to SOI leaders. Payments are made by the GOI on specified pay 

days and directly distributed to verified SOI members. One former U.S. commander in charge of 

about 100 SOI discussed the difficulties in paying his SOI and said that the SOI leader would 

attempt to hire substitutes who had not been cleared or vetted so that he could collect the full 

amount of funds agreed to. The commander rejected these replacements since they had not been 

cleared. In one of the SOI projects that SIGIR reviewed, Multi-National Division–Baghdad 

found that Baghdad SOI leaders on three contracts hired and paid approximately 198 more SOI 

than the contracted amount. In this case, SOI leaders distributed the funds to the SOI members. 

According to project records, the unit in charge of these SOI encouraged the over-hiring by 

providing SOI identification cards to all of the SOI members that the leaders hired. These SOI 

worked from October through December 2008, when the GOI had assumed control of the units, 

and therefore expected the GOI to pay them. But since they were not part of a U.S. contract, the 

GOI refused. As a result, in February 2009, Multi-National Division–Baghdad spent an 

additional $163,803 to pay these SOI. This overpayment could have been avoided had the unit 

executing the contract conducted stronger oversight and paid the SOI members directly, rather 

than providing the funds directly to the SOI leader. 

Our file review did find two instances where units validated the number of SOI members 

working at the time of payment. In each case the amount paid was less than the estimated 

payroll. For example, one brigade required each SOI member to sign a pay roster before 

receiving their salary. In this case, 545 SOI were on the official registry but only 454 signed the 

pay roster and collected their salaries. Thus, the overall amount expended that month was 

reduced by about 17% from an estimated $62,884 to $52,384. Similarly, another brigade 

estimated that it would cost $167,904 for 165 SOI for the period of employment. However, 

when it paid the SOI members directly, the brigade found it had only 149 SOI members and the 

final amount disbursed was $150,804. 

Interviews with MNC-I commanders who oversaw SOI activities also found that when payroll 

money was given directly to SOI representatives instead of to the individual members, the 

representatives sometimes kept some of the money. Multiple commanders told SIGIR that when 

they would ask individual SOI members how much money they received from their unit leader, it 

was usually less than the full salary agreed upon by Coalition Forces and the SOI leader. 

However, these commanders noted that in Iraq it was acceptable and expected that the SOI 

leader would receive funds above what was agreed to and speculated that this would happen 

regardless of whether or not funds were disbursed directly to the SOI leader or to each SOI 

member. This lack of control over money once it is disbursed is endemic to Iraq and can have 

unforeseen consequences. One commander told us that he believed that it was likely that some 

portion of the U.S. payments to the SOI was provided to a local insurgent group as protection 

money. 

Project Files Lacked Required Financial Documentation 

Although USF-I and U.S. Army Central Command were able to provide 98 of the requested 105 

project files, SIGIR found that those files generally did not contain all the MAAWS-required 

financial and SOI project documentation. SIGIR judgmentally selected these files based on the 

fiscal year, major subordinate command, and dollar value; then analyzed the files to determine if 

they contained the documents required in the MAAWS guidance. Since MAAWS requirements 
13 

changed over time, SIGIR used the MAAWS guidance that was in use at the time each project 

took place. 

As shown in Table 1, significant amounts of required documentation were missing from the files. 

Among the most significant missing documents are Receipts (31% missing), and Statements of 

Agent Officer’s Account (89% missing). As mentioned earlier, in December 2009, a U.S. Army 

Captain pled guilty to stealing approximately $690,000 in SOI funds. Receipts and Statements 

of Agent Officer’s Account are important internal control documents that ensure funds are used 

appropriately. The files were also missing documents that showed that the officials in charge of 

purchasing and paying for goods and services were authorized to do so and had the requisite 

training to exercise these responsibilities. For example, purchasing officers and paying agents 

are required to receive appointment letters and records of appointment certifying that the project 

purchasing officers and paying agents received proper authorization for their positions and 

agreed to the responsibilities involved, including necessary training. These documents were 

missing from 83% of the files we reviewed. In addition, the MNC-I found that prior to fiscal 

year 2009, the Multi-National Force–West did not comply with the MAAWS requirement for a 

Commander’s Closure Memorandum which documents that the commander reviewed and 

approved the project, that it is complete and adhered to guidelines in the MNC-I MAAWS and 

applicable fragmentary orders. Table 1 shows the results of SIGIR’s review. 
14 

Table 1—Results of SIGIR File Review 

MAAWS Requirement 

Number 

Required In File Not in File

Percent In 

File

Percent Not 

in File 

Letter of Justification 98 89 9 91 9

Purchase Request & 

Commitment 98 96 2 98 2

Proposal or Statement of 

Work 98 74 24 76 24

Receipts (SF 44, SF 1351, 

SF 1449, or SF 1034) 98 68 30 69 31

Statement of Agent 

Officer’s Account (DD 

Form 1081) 

98 5 93 5 95

Commander’s Clearance 98 72 26 73 27

MSC Comptroller 

Clearance 98 50 48 51 49

Legal Review 69 49 20 71 29

Project Purchasing 

Officer/Pay Agent 

Appointment 

98 17 81 17 83

Project Purchasing 

Officer/Pay Agent Training 25 4 21 16 84

CERP Project File 

Checklist 45 13 32 29 71

Total 923 537 386 58% 42%

Source: SIGIR analysis of SOI files, August 2010. 

In addition to the missing required documents, the files also did not always contain other 

information needed to validate that funds provided to the SOI were put to their intended use. For 

example, there was limited information to demonstrate that funds provided to the SOI to 

purchase equipment were used appropriately. In one case MNC-I provided funds to the SOI to 

purchase radios, generators, and vehicles, but the files contained no receipts or other 

documentation to show the items were purchased. Additional examples include a brigade that 

gave the SOI $121,800 to purchase seven trucks; and a unit that gave the SOI $56,036 in cash to 

purchase vests, radios, ladders, air conditioning units, generators, and spot lights. In neither case 

did the file contain any receipts or other documentation to show the items had been purchased. 

 
15 

GOI Takes Management Control of SOI, but 

Challenges Remain in Integrating SOI into Iraqi 

Ministries 

Beginning in October 2008, the GOI progressively assumed full management responsibility of 

SOI. It took control of Baghdad SOI first, and by April 2009, the GOI had completed transfer of 

program control in all provinces. This is only a first step, however, to the successful integration 

of SOI into Iraqi ministries, a goal that is proving difficult to meet. The GOI promised to 

provide employment for 95,120 SOI members but to date it has provided offers to only 39,224. 

Additional SOI transitions into Iraqi ministries have been halted since November 2009. The 

GOI has also faced problems in paying the SOI on time. According to USF-I, the perception of 

broken promises and GOI indifference have eroded confidence, furthered SOI distrust of the 

GOI, and increased fear of insurgent influence over SOI. While the GOI has made progress 

during a period where they were unable to form a government, such problems raise questions 

about the GOI’s ability to reconcile with the SOI. 

GOI Assumes Full Management Responsibility for SOI 

The transfer of management control of SOI to the GOI started in October 2008. The transfer 

process was preceded by a complete inventory, called the Personnel Asset Inventory, of every 

contracted SOI member in Iraq, followed by a registration process. The registration process 

entailed GOI and MNF-I jointly recording relevant information on each SOI member and 

reporting it to the Iraqi Security Forces. The GOI then compared the registration information to 

that in the Personnel Asset Inventory. The process resulted in 95,120 SOI verified as eligible for 

transfer. Figure 3 provides an overview of the numbers of SOI in each province after the joint 

registrations. 

 
16 

Figure 3—Number of Registered Sons of Iraq by Province (April 2009) 

Source: USF-I. 

Although the GOI committed to employ the SOI, it has fallen behind in offering positions. 

While initial plans were to have all the SOI in jobs by late 2009, about 42% (39,224) are 

currently employed. The GOI plan was to place 20% of the SOI in the Iraqi Security Forces and 

the other 80% into other ministries. However, all hiring was halted in December 2009 so that the 

SOI could provide security for the Iraqi elections. The GOI planned to resume hiring after the 

March 2010 elections but as of December 2010 had not offered any additional jobs. According 

to USF-I, delays in transition were driven by security concerns during the long and difficult 

process of government formation. The SOI are seen as adding to the Iraqi Security Forces’ 

ability to protect Iraqi citizens, and the GOI was concerned over the impact on security of 

removing the majority of SOI from their security duties during this time period. Table 2 presents 

the numbers of SOI who received jobs in the Iraqi Security Forces and Ministries by province. 
17 

Table 2—Status of SOI Transitions to Ministry and Iraqi Security Forces 

Positions—October 2008 to December 2010 

Province Ministry ISF

Total 

Transitioned SOI Total a

Percent 

Transitioned

Baghdad 30,476 6,804 37,280 50,425 73.9

Salah Al-Din 0 1,481 1,481 10,051 14.7

Ninewa 0 0 0 1,255 0.0

Tameem 0 0 0 8,811 0.0

Diyala 0 463 463 8,688 5.3

Wassit 0 0 0 929 0.0

Qadissiya 0 0 0 1,858 0.0

Babylon 0 0 0 7,342 0.0

Anbar 0 0 0 4,044 0.0

Total 30,476 8,748 39,224 93,403 41.9%

Notes: 

a While the original SOI total was 95,120, according to USF-I, 1,717 have left the program. 

Source: USF-I data collected from the Government of Iraq. 

Two problems facing the GOI are that some SOI members are not accepting the positions 

offered, and others are not qualified for ministry-level jobs. According to USF-I reports, some 

jobs being offered by the GOI are menial labor, such janitor, driver, or guard that some SOI 

members view as beneath them. One ministry official, for example, received feedback that the 

SOI did not like “pushing brooms” and taking orders and wanted jobs that involved having 

weapons and giving orders. In addition, a study conducted in December 2009 of transitioned 

SOI found that most respondents were dissatisfied with their ministerial assignment. According 

to USF-I, the ability of the GOI to absorb the SOI into ministerial positions that they are 

qualified to serve in and that they would agree to continues to be a concern. 

The GOI has developed a draft plan to continue transitions. According to USF-I, the initial focus 

of the GOI plan is to hire SOI members for security positions, such as the Iraqi Police or 

infrastructure security. USF-I has previously encouraged the GOI to place SOI members in the 

oil pipeline and electricity police, where both the GOI and provincial leaders have acknowledged 

a significant shortfall. In addition, some SOI members could be hired to gather intelligence. 

Hiring for employment by the ministries would continue based on the education and skill level of 

an individual SOI member, and those too old to serve would be offered a retirement package. 

 
18 

Payments by Government of Iraq to SOI Consistently Late 

Since October 2008, when the GOI assumed control of the program, it has been consistently late 

in providing pay to the SOI. In some provinces, the MNF-I had to continue making payments 

after the transfer because the GOI was not prepared to. 

As shown in Table 3, between October 2008 and December 2010, the GOI paid SOI salaries on 

time only about 42% of the time. From October 2008 to April 2010, payments were considered 

“on-time” in a province if its SOI were fully paid by the end of the month following the services 

rendered. Starting in May 2010, the definition of “on-time” was changed to the middle of the 

month following the services rendered.

Table 3—Timeliness of Sons of Iraq Payments by Province—October 2008 to 

December 2010 

Province Late On Time Total Percent Late Percent On Time

Baghdad 19 8 27 70.4 29.6

Diyala 15 9 24 62.5 37.5

Babylon 14 9 23 60.9 39.1

Wassit 13 9 22 59.1 40.9

Anbar 15 7 22 68.2 31.8

Ninewa 10 12 22 45.5 54.6

Tameem 11 11 22 50.0 50.0

Qadissiya 7 8 10 52.4 47.6

Salah Al-Din 11 10 10 58.1 41.9

Total 115 83 198 58.1% 41.9%

Source: SIGIR analysis of USF-I pay data from October 2008 to December 2010. 

In four provinces, the GOI was initially unable to begin paying the SOI after program transfer, 

and MNC-I had to pay the SOI with CERP funds. In Babylon, Wassit, and Anbar provinces, the 

MNC-I paid the SOI for one additional month, and in Qadasiyah, the MNF-I paid for an 

additional four months. 

These delays have created frustration amongst remaining SOI. For example, in June 2010, USF-I 

received reports of SOI leaving their checkpoints in both Anbar and Kirkuk due to pay delays. 

According to a USF-I official who monitors GOI progress, the delays could be causing the SOI to 

lose trust in the GOI and feel abandoned by the U.S. USF-I officials are concerned that delays 

could result in SOI returning to insurgent groups. While USF-I has received anecdotal reports 

that small numbers of SOI are joining insurgents, SOI leaders have claimed that this is false. 

 
19 

According to USF-I officials, the GOI took steps to expedite SOI payments. For example, prior 

to April 2010, the Ministry of Finance could not disburse funds until the Ministry of Interior 

allocated those funds. The Ministry of Interior was taken out of the approval process because it 

caused significant delays in making allocation decisions. From September 2010 to December 

2010, the GOI improved its timeliness to 75% on time. In addition, the draft GOI budget has 

included funding for the SOI including equalizing pay at $300 for all SOI. As the SOI transition 

into GOI ministries, the funds will be transferred to each ministry’s budget. 

 
20 

Conclusions and Recommendations 

Conclusions 

SIGIR has previously reported on the difficulties it encountered in attempting to evaluate CERP 

programs. Particularly problematic was the lack of clear guidance on exactly what the programs 

or specific projects were supposed to achieve, the absence of metrics to evaluate impact, 

insufficient field command project management and oversight, and the lack of supporting project 

financial and other documentation. Consequently, SIGIR was often unable to determine if a 

CERP project achieved its goal, or was conducted in an efficient and effective manner. These 

problems were magnified in the CERP SOI program. In this case, the U.S. military was tasked 

with implementing a major counterinsurgency effort, namely integrating insurgents into the 

peacekeeping efforts of the Iraqi government, by using a CERP project structure that was clearly 

not intended for a country-wide program such as the SOI program. As a result, the SOI effort 

lacked necessary high-level direction, management, and assessment processes. Instead, field 

commanders managed SOI as 779 individual efforts. The result was that there were insufficient 

internal controls and unknown results at both the project and program levels. 

Although the SOI program is described as a sort of “quid pro quo” in which the SOI provided 

services in exchange for support and money, the files provide almost no evidence of what the 

SOI did. Even though the Scope of Work statements in the files that we reviewed outlined an 

oversight structure, only 1 of the 98 files we reviewed contained any documentation that showed 

the SOI actually performed the agreed-upon services. Basic documentation, such as attendance 

information, was missing from most files. In 63 files commanders reduced payments to SOI 

members who did not report for work, indicating some oversight. However, commanders in 

charge of 35 of the 98 projects paid the full amount provided in the agreement to one individual 

who then was supposed to disburse the money to individual SOI. In these cases, there was no 

evidence that anyone but this one individual received any payments, which in many cases 

amounted to hundreds of thousands of dollars. This leaves one with the impression that many 

local commanders were not concerned about the services delivered. 

Compounding our assessment difficulties are continuing problems with CERP recordkeeping. 

Prior SIGIR reports have highlighted serious recordkeeping deficiencies, and this review found 

that recordkeeping at both the MNC-I level and the local level continues to be poor. About 42% 

of the documents that should have been in the files were missing. Most significantly, the files 

did not contain key documents necessary to ensure that CERP funds were not stolen or misused, 

such as payment receipts. 

As a result of these problems, it is not possible to assess the effectiveness of the SOI program. 

Aside from testimonial evidence from field commanders that provides examples of how the SOI 

program, in their judgment, contributed to reductions in violence, there is little else on which to 

base a conclusion. This lack of data goes beyond documenting the number of weapon caches or 

IEDs identified by the SOI. It is about documenting the reasons for any successes or failings. 

The program is widely portrayed as exploiting an ideological rift between the SOI and the 

insurgents. But with activities ongoing at 779 locations, in 9 provinces, and involving Sunnis, 

Shia, nationalists, Bathists, and others, it is highly probable that other factors, such as providing 
21 

employment, played a role as well. Without information on what actually occurred and why, any 

lessons learned–along with DoD’s ability to effectively replicate a similar program in another 

contingency–are lost. 

Integrating the SOI into the Iraqi government also continues to be a concern. While USF-I 

appears to have worked diligently and in good faith with the GOI to persuade it to hire the SOI, 

its influence is limited. In the end, acceptance of the SOI by the Iraqi government is a political 

issue. 

Recommendation 

The Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to revise 

CERP guidance to include direction on when related projects should be managed as a program 

with clearly defined objectives, implementing regulations, and metrics for assessing results. 
22 

Management Comments and Audit Response 

The Office of The Secretary of Defense (Comptroller) provided a written response to our report 

in which it agreed with the intent of our recommendation. The letter stated that the DoD 

Financial Management Regulation, Volume 12, Chapter 27, “Commander’s Emergency 

Response Program (CERP),” was revised and published in January 2009. It goes on to say that 

the CERP is managed as a program, and CERP Program Managers have oversight of the 

individual projects. The letter also cites other specific sections of the regulation that provide 

guidance on the program. 

SIGIR acknowledges that DoD has made large-scale improvements to its Financial Management 

Regulation and that at the DoD level CERP is run as a program. However, SIGIR’s 

recommendation is directed at field-level management of CERP. At this level, the SOI program 

was not run as an integrated program. Rather it was managed as 779 independent projects with 

no overarching management structure. SIGIR is seeking field-level direction about when related 

projects should be managed as a program. Consequently, we do not consider the DoD 

Comptroller’s comments to be responsive to our recommendation. The DoD Comptroller’s 

comments are printed in their entirety in Appendix D. 

 
23 

Appendix A—Scope and Methodology 

Scope and Methodology 

In December 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated 

Project 1004 to examine the Sons of Iraq (SOI) program. SIGIR’s reporting objectives are to 

determine (1) the program’s contribution to reducing violence in Iraq, (2) the effectiveness of 

financial management controls, and (3) the extent to which the GOI is effectively integrating SOI 

personnel into Iraqi ministries. 

This audit was performed by SIGIR 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. SIGIR conducted its work during April through November 2010 in 

Baghdad, Iraq; Atlanta, Georgia; and Arlington, Virginia. 

To determine the program’s contributions to reducing violence in Iraq, we reviewed historical 

records of the program in the possession of USF-I. This included both classified and unclassified 

briefings, reports, and data. Furthermore, we reviewed fragmentary orders issued by MultiNational Corps–Iraq. Using this information, we interviewed current and former U.S. and GOI 

officials involved with the program during its implementation and with the ongoing transition. 

In our interviews we used a standard set of questions posed regarding guidance, oversight, 

program effectiveness, and controls. We also spoke with one SOI leader in the Baghdad area. 

To determine the extent to which the GOI is effectively integrating SOI personnel into the Iraqi 

ministries, we reviewed SOI program records and reviewed pay and transition data maintained 

by USF-I. Furthermore, we reviewed USF-I surveys and atmospheric reports of SOI transitioned 

to the GOI. We also spoke with U.S. and GOI officials involved with the transition. 

To evaluate the effectiveness of financial management controls, we judgmentally selected 107 

Commander’s Emergency Response Program (CERP) project files based on information 

provided by USF-I. For each fiscal year, we first selected files based on the major subordinate 

command that issued the SOI agreement, and then selected the highest-value agreements. Files 

were split between Iraq and U.S. Army Central Command, Georgia. While we selected 107 files 

originally, our review found that 7 were not related to SOI, and U.S. Army Central Command, 

and USF-I could not locate 2 files. We compared documentation in 98 SOI project files to 

requirements in the Money as a Weapons System (MAAWS) guidance. To ensure that we 

applied the correct criteria to individual SOI projects, we used the MAAWS guidance that was in 

place during the execution of the project. 

The audit was conducted 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. 
24 

Use of Computer-processed Data 

To achieve the assignment’s objectives, we extensively relied on computer-processed data 

contained in MNC-I’s CERP project tracker. We assessed the reliability of this data, including 

relevant general controls, and found that it did not provide a full accounting of all CERP funds 

spent for the SOI program. Nonetheless, we tested the data and believe that it is sufficiently 

reliable to be used in meeting the assignment’s objectives. To estimate disbursements, we took 

information from the CERP project tracker and provided it to the Defense Finance and 

Accounting Service, who provided disbursements for the SOI program from fiscal years 2007 

through 2009. 

Internal Controls 

In conducting the review, we assessed certain internal controls to administer and oversee CERP 

projects and funds. Specifically, we examined the internal and management control procedures 

and documents that MNF-I and MNC-I require and use to manage CERP. 

Prior Coverage 

We reviewed the following reports by SIGIR, the Government Accountability office, and U.S. 

Army Audit Agency. 

Special Inspector General for Iraq Reconstruction 

Commander’s Emergency Response Program: Projects at Baghdad Airport Provided Some 

Benefits, but Waste and Management Problems Occurred; SIGIR 10-013, 4/26/2010.

Commander’s Emergency Response Program: Hotel Construction Completed, but Project 

Management Issues Remain, SIGIR 09-026, 7/26/2009.

Commander’s Emergency Response Program: Muhallah 312 Electrical Distribution Project 

Largely Successful, SIGIR 09-025, 7/23/2009. 

Commander’s Emergency Response Program in Iraq Funds Many Large-scale Projects, 

SIGIR 08-006, 1/25/2008. 

Management of the Commander’s Emergency Response Program in Iraq for Fiscal Year 2006, 

SIGIR 07-006, 4/26/2007. 

Management of the Commander’s Emergency Response Program for Fiscal Year 2005, 

SIGIR 05-025, 1/23/2006. 

Management of the Commanders’ Emergency Response Program for Fiscal Year 2004, 

SIGIR 05-014, 10/13/2005. 

Government Accountability Office 

Military Operations: Actions Needed to Better Guide Project Selection for Commander's 

Emergency Response Program and Improve Oversight in Iraq, GAO-08-736R, 6/23/2008. 
25 

U.S. Army Audit Agency 

Commander’s Emergency Response Program: Multi-National Forces–Iraq Summary Report, 

A-2010-0097-ALL, 5/4/2010. 

Commander’s Emergency Response Program: Multi-National Force-West, A-2009-0182-ALL, 

8/18/2009. 

Commander’s Emergency Response Program: Multi-National Division-North, A-2009-0169-

ALL, 7/28/2009. 

Commander’s Emergency Response Program: Multi-National Division-Baghdad, A-2009-0119-

ALL, 6/8/2009. 

 
26 

Appendix B—Acronyms 

Acronym Description 

AQI Al Qaeda in Iraq 

CERP Commander’s Emergency Response Program 

DoD Department of Defense 

GOI Government of Iraq 

IED Improvised Explosive Device 

MAAWS Money as a Weapons System 

MNC-I Multi-National Corps–Iraq 

MNF-I Multi-National Force–Iraq 

SIGIR Special Inspector General for Iraq Reconstruction 

SOI Sons of Iraq 

USF-I U.S. Forces–Iraq 

 
27 

Appendix C—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: 

Daniel Chen 

Whitney Miller 

Hayden Morel 

James Shafer 

Nadia Shamari 

 
28 

Appendix D—Management Comments 
29 

 
30 

Appendix E—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 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Deborah Horan 

Office of Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0817 

Email: PublicAffairs@sigir.mil