U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Printing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2250 Mail: Stop SSOP, Washington, DC 20402–0001

22–654PDF 2005

SYRIA AND THE UNITED NATIONS OIL–FOR–FOOD

PROGRAM

JOINT HEARING

BEFORE THE

SUBCOMMITTEE ON OVERSIGHT AND 

INVESTIGATIONS

AND THE

SUBCOMMITTEE ON THE MIDDLE EAST 

AND CENTRAL ASIA

OF THE

COMMITTEE ON 

INTERNATIONAL RELATIONS 

HOUSE OF REPRESENTATIVES

ONE HUNDRED NINTH CONGRESS

FIRST SESSION

JULY 27, 2005

Serial No. 109–77

Printed for the use of the Committee on International Relations

(

Available via the World Wide Web: http://www.house.gov/international—relations 

(II)

COMMITTEE ON INTERNATIONAL RELATIONS 

HENRY J. HYDE, Illinois, Chairman 

JAMES A. LEACH, Iowa 

CHRISTOPHER H. SMITH, New Jersey, 

Vice Chairman 

DAN BURTON, Indiana 

ELTON GALLEGLY, California 

ILEANA ROS-LEHTINEN, Florida 

DANA ROHRABACHER, California 

EDWARD R. ROYCE, California 

PETER T. KING, New York 

STEVE CHABOT, Ohio 

THOMAS G. TANCREDO, Colorado 

RON PAUL, Texas 

DARRELL ISSA, California 

JEFF FLAKE, Arizona 

JO ANN DAVIS, Virginia 

MARK GREEN, Wisconsin 

JERRY WELLER, Illinois 

MIKE PENCE, Indiana 

THADDEUS G. MCCOTTER, Michigan 

KATHERINE HARRIS, Florida 

JOE WILSON, South Carolina 

JOHN BOOZMAN, Arkansas 

J. GRESHAM BARRETT, South Carolina 

CONNIE MACK, Florida 

JEFF FORTENBERRY, Nebraska 

MICHAEL MCCAUL, Texas 

TED POE, Texas 

TOM LANTOS, California 

HOWARD L. BERMAN, California 

GARY L. ACKERMAN, New York 

ENI F.H. FALEOMAVAEGA, American 

Samoa 

DONALD M. PAYNE, New Jersey 

ROBERT MENENDEZ, New Jersey 

SHERROD BROWN, Ohio 

BRAD SHERMAN, California 

ROBERT WEXLER, Florida 

ELIOT L. ENGEL, New York 

WILLIAM D. DELAHUNT, Massachusetts 

GREGORY W. MEEKS, New York 

BARBARA LEE, California 

JOSEPH CROWLEY, New York 

EARL BLUMENAUER, Oregon 

SHELLEY BERKLEY, Nevada 

GRACE F. NAPOLITANO, California 

ADAM B. SCHIFF, California 

DIANE E. WATSON, California 

ADAM SMITH, Washington 

BETTY MCCOLLUM, Minnesota 

BEN CHANDLER, Kentucky 

DENNIS A. CARDOZA, California 

THOMAS E. MOONEY, SR., Staff Director/General Counsel 

ROBERT R. KING, Democratic Staff Director 

(III)

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

DANA ROHRABACHER, California, Chairman 

EDWARD R. ROYCE, California 

JEFF FLAKE, Arizona, Vice Chairman 

MARK GREEN, Wisconsin 

MIKE PENCE, Indiana 

JOE WILSON, South Carolina 

WILLIAM D. DELAHUNT, Massachusetts 

HOWARD L. BERMAN, California 

EARL BLUMENAUER, Oregon 

ADAM B. SCHIFF, California 

GREGG RICKMAN, Subcommittee Staff Director 

GREGORY MCCARTHY, Professional Staff Member 

CLIFF STAMMERMAN, Democratic Professional Staff Member 

EMILY ANDERSON, Staff Associate

SUBCOMMITTEE ON THE MIDDLE EAST AND CENTRAL ASIA

ILEANA ROS-LEHTINEN, Florida, Chair 

STEVE CHABOT, Ohio, Vice Chair 

THADDEUS G. MCCOTTER, Michigan 

JOHN BOOZMAN, Arkansas 

CONNIE MACK, Florida 

JEFF FORTENBERRY, Nebraska 

JO ANN DAVIS, Virginia 

MIKE PENCE, Indiana 

KATHERINE HARRIS, Florida 

DARRELL ISSA, California 

GARY L. ACKERMAN, New York 

HOWARD L. BERMAN, California 

ELIOT L. ENGEL, New York 

JOSEPH CROWLEY, New York 

SHELLEY BERKLEY, Nevada 

ADAM B. SCHIFF, California 

BEN CHANDLER, Kentucky 

DENNIS A. CARDOZA, California 

YLEEM POBLETE, Subcommittee Staff Director 

MATT ZWEIG, Professional Staff Member 

DAVID ADAMS, Democratic Professional Staff Member 

LEE COHEN, Staff Associate 

(V)

C O N T E N T S 

Page

WITNESSES 

Ms. Elizabeth L. Dibble, Deputy Assistant Secretary, Bureau of Near Eastern 

Affairs, U.S. Department of State ...................................................................... 9

Mr. Dwight Sparlin, Director of Operations, Policy, and Support, Criminal 

Investigation Division, Internal Revenue Service ............................................. 14

Mr. Victor Comras, Attorney, Comras & Comras ................................................. 19

LETTERS, STATEMENTS, ETC., SUBMITTED FOR THE HEARING 

Ms. Elizabeth L. Dibble: Prepared statement ....................................................... 11

Mr. Dwight Sparlin: Prepared statement .............................................................. 16

Mr. Victor Comras: Prepared statement ................................................................ 20

(1)

SYRIA AND THE UNITED NATIONS

OIL–FOR–FOOD PROGRAM 

WEDNESDAY, JULY 27, 2005

HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS, AND

SUBCOMMITTEE ON THE MIDDLE EAST

AND CENTRAL ASIA, 

COMMITTEE ON INTERNATIONAL RELATIONS, 

Washington, DC. 

The Subcommittees met, pursuant to notice, at 10:33 a.m., in 

room 2172, Rayburn House Office Building, Hon. Dana Rohrabacher (Chairman of the Subcommittee on Oversight and Investigations) and Ileana Ros-Lehtinen (Chair of the Subcommittee on 

the Middle East and Central Asia) presiding. 

Mr. ROHRABACHER. I call this joint meeting of the Oversight and 

Investigations Subcommittee and the Middle East and Central Asia 

Subcommittee to order. 

This Subcommittee has held a number of hearings this year on 

the Oil-for-Food Program of the United Nations. This hearing, held 

jointly with the Middle East Subcommittee, will examine the role 

of Syria in the program. 

Let us note, to be fair, Syria is not the only country that has 

been involved with any questionable activities in the United Nations Oil-for-Food Program. This Subcommittee has already investigated other countries who have had very questionable involvement, and we will further investigate other countries as well in our 

investigation of the Oil-for-Food scandal. So this is just one of a series of hearings to look into a specific set of circumstances and details that we think need to be known by the public. 

Despite the historic enmity between Syria and Iraq, both of these 

countries managed to profit from the manipulation of the United 

Nations sanctions on Iraq. 

Today, we want to discuss two concerns: First, the actions of the 

Commercial Bank of Syria, which facilitated kickbacks for suppliers and kickbacks for the buyers of those who were involved in 

the U.N. Oil-for-Food Program. Again, let me note we have spent 

considerable time on the banks of other countries. Second, we will 

be looking at Syrian complicity in the purchase of weapons in direct violation of the United Nations guidelines at that time and in 

direct violation of the Oil-for-Food Program’s intent. 

Evidence suggests that CBS (Commercial Bank of Syria) was the 

recipient of the proceeds of more than $1.8 billion in oil sales from 

June 2000 to February 2003. These funds were deposited into accounts controlled by Iraq’s State Oil Marketing Organization 

2

(SOMO) at the Syrian bank (CBS). A trade protocol established between Syria and Iraq in 2000 was the basis for these ongoing 

transactions. 

Unseen, however, was an additional $1.2 billion in oil money that 

was at times put into another account at the CBS. These funds 

were used to pay for trade between the two countries, including 

weapons that were very likely used. In fact, some of these weapons 

could have very likely been used against American troops in Iraq. 

Part of this scheme included a procedure for these funds to be 

automatically transferred through a secretive route to the Central 

Bank of Iraq. In one case, Committee investigators spoke to an 

Iraqi courier that transported a payment worth millions of dollars 

in gold bars. He transported these gold bars via car back to Baghdad. One can only envision this transfer of money and gold bars in 

the trunk of an automobile being transferred from Damascus to 

Baghdad. It does create quite a picture. 

Treasury Department officials have told Congress in January 

that Syrian officials had thus far failed to return all of the Iraqi 

funds. 

Let us note that the funds that Iraq derived from this procedure 

were illegal, that the United Nations had a program that was being 

misused in which billions of dollars were actually taken from the 

Oil-for-Food Program for purposes that they did not intend, and 

that the Syrian officials, at least in January, had announced that 

all of those funds had not been reported. These topics will be the 

matter of discussion today. 

There needs to be a full accounting and a reappraisal of the Syrian cooperation with United States demands for the return of these 

funds. The cloak and dagger element of transferring gold bars from 

Damascus to Baghdad in the trunk of a car is certainly provocative, 

but we need some hard answers to where this money is today. 

While Syria acted as Iraq’s banker, some of its highest officials 

brokered military deals for Iraq and profited from these military 

deals. One source suggests that former Syrian Defense Minister 

Tlas received a regular ‘‘tribute payment’’ for his role in the deals 

between these two countries. Anything shipped had to receive his 

approval in order to be allowed through Syrian customs. 

Tlas’ son also received 10 to 15 percent kickbacks for contracts 

made through Iraq’s military industrial commission. In addition to 

Tlas—and I am going to mispronounce these names—Thualhima 

Shaleesh—I am sorry about that—Chief of the Presidential Bodyguard and cousin to Syrian President Assad also received these 

kickbacks for acting as an intermediary in military deals. 

Understanding these facts, Syria’s denials of its help to Iraq 

seem, let us say, to be a bit suspect, and we need to look at these 

denials today. I personally would like to have arranged this so we 

could have the Syrian Ambassador come and state his side, where 

we could question him about these things directly. Perhaps that 

can be arranged in the future. 

One must suspect that such help as Syria gave Iraq in the past 

may well be continuing today, perhaps in support of Iraq’s insurgency. So we are looking at what happened in the not-so-distant 

past. We certainly have to ask questions about what Iraq is doing 

today. 

3

Of course, we see the bloody consequences of the arming of Iraq 

going on even today. Perhaps some of the arms deals we are talking about today provided the weapons that are exploding on the 

streets of Baghdad, murdering both Americans and, of course, 

many, many Iraqi civilians. 

Today, the representatives of our State Department should tell 

us what the United States is doing to stop Syria from aiding the 

insurgents and destabilizing Iraq, whether there is substance to 

these charges, and to return the funds it helped Iraq steal from the 

Oil-for-Food Program. 

President Assad of Syria said in a recent New York Times interview that ‘‘when you talk about upgrading society, you talk about 

being open-minded.’’ well, I believe that we need to hear not just 

words, but we need to see deeds, and we believe that President 

Assad should demonstrate his open-mindedness and perhaps a 

commitment to another course other than that which was taken a 

few years ago and start seriously cooperating with the United 

States and answering questions like this in full. 

As I say, perhaps some of the questions that we raise today can 

be posed directly to the Syrian Ambassador, who is with us today, 

and to President Assad, and have some direct answers, and perhaps then we can hear another story. Perhaps there is a new trail 

being blazed or a new path being taken. What we do know and 

what we are going to document today is unacceptable decisions and 

activities that were going on that Syria was part and parcel to only 

a few short years ago. 

With that said, Mr. Delahunt, would you like to make an opening 

statement? 

Mr. DELAHUNT. Thank you, Mr. Chairman. 

I would welcome—I know that the Syrian Ambassador is present 

here, and I would note that for the record. 

I would also note that he has not been invited to testify, and I 

would hope and concur with you that you and I convene a hearing 

after we return from the summer district work period and invite 

him to testify. He will have, I am sure, an opportunity to review 

the testimony that is elicited today. 

Mr. ROHRABACHER. Would the gentleman yield for just a minute? 

Let me just note, I have never feared having anybody testify 

here, but I would hope if the Syrian Ambassador, or in the future 

anyone else who comes here to try to testify like this, and should 

have a right to express those opinions, then the Ambassador would 

expect a grilling. So it would be a very serious issue. I just wanted 

to add that. 

Mr. DELAHUNT. I know you are a good griller, Mr. Chairman. 

But, having said that, as you well know, for months I have been 

asking questions about the so-called trade protocols, which were 

formal written agreements between Saddam Hussein and the Governments of Syria, Turkey, Jordan, and Egypt for the direct purchase of Iraqi oil. They were obvious and blatant violations of the 

sanction regime imposed by the Security Council in the aftermath 

of the first Gulf War in 1991. 

The Security Council was aware of these trade protocols, but, 

rather than take any action, the Security Council looked the other 

4

way and did absolutely nothing, according to the information that 

we have heard today. 

I was particularly disturbed because, as one can see on this chart 

to my left, which uses figures that were provided by the President’s 

appointee, Charles Duelfer, these trade protocols earned Saddam 

over $8 billion of illegal revenue that he did not have to account 

for. It is particularly important to note, Mr. Chairman, that this is 

more than six times as much as he was able to skim off the Oilfor-Food Program. 

So when this hearing was first noticed as—and I am quoting 

from the notice sheet—‘‘Syria and the U.N. Oil-for-Food Program,’’ 

I presumed that it was about the Oil-for-Food Program and we 

should expect more testimony critical of the Secretary General and 

the United Nations Secretariat. But, of course, we would not focus 

on the role of the Security Council, because we have not done that 

today, despite the fact that we are a permanent member of that 

body. 

But after reviewing the statements of the witnesses and the IRS 

documents, I discovered, to my surprise, that at long last we were 

going to talk about these so-called trade protocols, but only with 

Syria. So I would suggest that this hearing would be more properly 

entitled ‘‘Syria’s Trade Protocol with Saddam’’ or, if that was unsatisfactory, ‘‘Syria’s Evasion of the U.N. Sanctions on Iraq.’’

But maybe some purpose is served by continuing to implicate the 

Oil-for-Food Program, despite the inaccuracy of doing so. Maybe we 

will have future hearings entitled ‘‘Jordan and the Oil-for-Food 

Program’’ or ‘‘Turkey and the Oil-for-Food Program’’ or ‘‘Egypt and 

the Oil-for-Food Program,’’ but somehow I doubt that, because they 

are our allies; they are our pals, whereas the Administration considers Syria, at least at this moment in time, to be our adversary. 

There seems to be an unwritten rule that we do not have any 

oversight on our friends or anything that might displease the Administration. Of course, in this particular case, both the Clinton 

and the Bush Administrations share equal responsibility, because 

both Administrations did nothing about the so-called trade protocols. No oversight, no criticism. 

Let me note that I believe that unless we practice equal opportunity in terms of our criticism, we lose our credibility and reinforce a perception that we only serve double standards. In the end, 

that makes us vulnerable to a charge of hypocrisy and does not 

serve our national security interests. 

Mr. ROHRABACHER. Thank you very much, Mr. Delahunt. 

This is a joint hearing between these two Subcommittees. Now 

I would like to recognize an opening statement from the distinguished Chair of the Subcommittee on the Middle East and Central 

Asia, and, I hope, perhaps Chair of the Full Committee someday. 

Ms. ROS-LEHTINEN. Thank you. 

Committee rules dictate who can be present, who can testify, and 

foreign government officials are precluded from testifying because 

they are not bound by U.S. laws. 

Further, Syria is classified as a state sponsor of terrorism and 

is facilitating terror attacks against Americans in Iraq and our coalition forces. I would hope that this Committee does not 

legitimatize the Syrian regime, as nice a buddy as the Syrian AmVerDate Mar 21 2002 14:38 Nov 01, 2005 Jkt 000000 PO 00000 Frm 00010 Fmt 6633 Sfmt 6633 F:\WORK\OI\072705\22654.000 HINTREL1 PsN: SHIRL
5

bassador might be of some Members, by providing a forum that is 

reserved for those that abide by and respect United States laws 

and United States interests. To provide such a forum to a terrorist 

is an affront to our American soldiers and to the Iraqi people. 

My stepson was deployed to Iraq yesterday, along with his 

fiancee. I don’t think that he or any of his Marine buddies would 

be very happy about having this Committee give a forum to a country that has been responsible for so much mayhem in the region. 

That is all I need to say about the Syrian Ambassador. 

Now, considering that we are talking about two state sponsors of 

terrorism, Iraq under Saddam Hussein and Syria, it is critical that 

we fully understand the scope of Syria’s involvement in the Oil-forFood debacle, that we identify the nature of its involvement, warning signs that it was circumventing sanctions and manipulating the 

process, and that we also identify where the United States went 

wrong. In this effort, perhaps we can avoid a repetition of past failures and mistakes. 

In 1996, the Oil-for-Food Program was instituted with the goal 

of providing food to impoverished Iraqis funded by the sale of Iraqi 

oil. Far from providing the Iraqi people its intended humanitarian 

assistance, this arrangement became astonishingly corrupt; the 

U.N. and foreign officials and governments systematically abusing 

the system and receiving hefty sums of money in kickbacks from 

the Iraqi regime. Thus, the Oil-for-Food Program became the biggest heist in recent history. While it involved thousands of participants in dozens of countries, it was the Syrian regime that provided Saddam with his most favored and profitable collaborator. 

In the fall of 2000, Saddam’s regime began illegally exporting oil 

via Syria. The Iraqi oil flowed through the Kirkuk pipeline, generating approximately $1 billion in profits for these terrorist regimes. 

Thus, the pipeline agreement not only revealed the true intentions 

of both Iraq and Syria to ignore U.N. sanctions and circumvent the 

Oil-for-Food mechanisms, but it provided them with the financial 

resources to engage in policies that were threatening global security. 

Iraq’s robust illicit trade with Syria was later augmented by the 

January 2001 so-called Iraq-Syria Free Trade Agreement. This 

agreement facilitated Iraq’s acquisition via Syria of sensitive military dual-use and other red-line items. 

The collusion between Iraq and Syria in the Oil-for-Food Program also resulted in 60 percent of Iraq’s earnings deposited in an 

Iraqi State Oil Marketing Organization account in the Commercial 

Bank of Syria, with 40 percent into a cash account at the SyriaLebanon Commercial Bank in Beirut. 

As our witnesses will describe today, the Commercial Bank of 

Syria played a central role in the circumvention of U.N. sanctions 

in laundering illicit Oil-for-Food profits and in facilitating the purchase by the Iraqi regime of prohibited items. 

Within this context, Mr. Comras’ testimony is of particular interest to the Members of our Subcommittees. In his written statement, he refers to the work of former Secretary Powell on the 

smart sanctions and strategies that would send a clear message 

that we would no longer tolerate open sanction violations such as 

those occurring in Syria. 

6

We would appreciate it if Secretary Dibble, who is representing 

the Department of State, would elaborate upon the steps taken by 

the United States against Syria, not just through the 661 Committee, but United States bilateral actions to bring about an end 

to the collaboration between these two rogue states, Iraq and Syria. 

In that vein, we would ask Secretary Dibble to discuss the May 

2004 designation of the Commercial Bank of Syria as a primary 

money laundering concern. 

As you know, it derived from President Bush’s Executive Order 

13338 implementing the provisions in the Syria Accountability and 

the Lebanese Sovereignty Restoration Act, as well as invoking section 311 of the USA PATRIOT Act, which requires United States 

financial institutions to sever correspondent accounts with the 

Commercial Bank of Syria because of money laundering concerns. 

Was the Commercial Bank of Syria’s involvement in the Oil-forFood scandal the sole variable considered? What other factors 

played a role in this determination? 

Further, while sanctions were threatened, they were not implemented at the time. Has the bank now been cut off from the U.S. 

financial system and from international financial markets? Does 

this include closing accounts not only with the corresponding U.S. 

banks but also security dealers and mutual fund providers? 

Given that Syria is a state sponsor of terrorism and a corrupt regime, as illustrated by its role in the Oil-for-Food scandal, is there 

any degree of confidence that the Syrian regime will comply with 

the specific steps outlined by the United States to address money 

laundering and terrorist financing concerns? 

Earlier this year, the Treasury Department sanctioned SES 

International, which was reportedly the primary facilitator for the 

transshipment of weapons and munitions as well as many other 

unauthorized goods through Syria into Iraq. Will additional, more 

rigorous designations or sanctions against the Syrian regime be 

considered by this Administration, either for their involvement in 

the Oil-for-Food scandal, their violations under the Syrian Accountability and Lebanese Sovereignty Restoration Act, or for money 

laundering and terrorist financing? 

Considering the roles of banks in Lebanon in the Oil-for-Food 

scandal, should we expect any punitive action to be undertaken 

against these Lebanese financial institutions? 

I would also appreciate it if our witnesses would comment on the 

possibility that former regime elements in Damascus are financing 

and coordinating the terrorist campaign in Iraq against the Coalition, the Iraqi Government, and innocent Iraqi civilians utilizing 

money and other assets garnered from its illicit trade and the Oilfor-Food Program. 

Despite American warnings, Damascus has reportedly continued 

to expedite the passage of jihadists into Iraq and members of other 

terrorist organizations. In addition, Syria continues to be a foremost supporter and weapons supplier of Hezbollah, a terrorist 

group active in Lebanon and throughout the world, that has been 

targeting and killing Americans and many others since the early 

1980s. 

I would like to bring these issues to the panelists’ attention and 

emphasize that lives, not just policies, are at stake in our efforts 

7

to stem the flow of Syrian terrorist financing, support for terrorists, 

and other nefarious activities, as illustrated through its role in the 

Oil-for-Food scandal. 

Our actions against the Syrian regime must reflect this reality. 

As I stated at the beginning of my remarks, we must heed the lessons of the Oil-for-Food debacle and related foreign policy miscalculations in order to avoid repeating them. Today’s hearing is an 

important step. 

Mr. ROHRABACHER. Thank you very much, Chairman RosLehtinen. 

Ranking Member Ackerman. 

Mr. ACKERMAN. Thank you very much. 

I will exercise the prerogative of injecting a personal note to 

Chairman Ros-Lehtinen as her colleagues, I believe, speaking for 

all of us, can understand how proud you must be, together with 

Dexter, of your stepson and his wife going off in uniform in the interests of our country and how both frightening and honorable 

those feelings must be. You and they certainly have our thoughts 

and our prayers, as do all of the men and women who serve our 

country, that they serve well and successful and come back 

healthy. We look forward to that day, hopefully soon. 

That being said, I want to in part recognize your talents and 

abilities, as did Chairman Rohrabacher, and say that some of us 

look forward to the day that you might indeed become the Ranking 

Member of the Full Committee. 

Let me thank Chairman Rohrabacher and Chairman RosLehtinen, together with our Ranking Member, Mr. Delahunt, for 

organizing the hearing. Given all the time that the Committee has 

spent on the Oil-for-Food Program, I think it is only fitting that we 

should finally turn to the source of the vast majority of Saddam’s 

ill-gotten billions, and that is smuggling. 

From November 2000 until the fall of Saddam’s Government, 

Iraq made an estimated—and these estimates differ—$2.8 billion 

by smuggling oil through Syria. As much as 250,000 barrels per 

day flowed through Syria at cut-rate prices, allowing the Syrians 

to refine the oil for domestic use and sell reserves of their own oil 

on the world market. We know this because of the Duelfer report 

and because of the work done by GAO (Government Accountability 

Office) on behalf of this Committee. 

But the interesting thing is we knew it was going on all the time 

and apparently did precious little to stop it. 

In 1990, after Iraq’s invasion of Kuwait, the United Nations Security Council imposed sanctions on Iraq prohibiting member 

states from buying and selling Iraq commodities except for food and 

medicine and established a committee to monitor the implementation and compliance with those sanctions. Members of the Security 

Council were members of the Sanctions Committee, so the United 

States was a member of the committee and had a responsibility to 

ensure that the sanctions were upheld. But instead of upholding 

the sanctions regime, we turned a blind eye as Iraq’s neighbors 

smuggled billions in Iraqi oil. The Sanctions Committee, which includes the United States, took note of Jordanian smuggling but 

took no action. 

8

In the case of Syria, according to GAO, ‘‘It is unclear what actions the Sanctions Committee or the United States took to stop 

the illegal exporting of oil to Syria.’’

I know, as has been pointed out, that former Secretary of State 

Powell went to the region early in 2001 in an attempt to sell Iraq’s 

nations on what he was calling smart answers. During that trip, 

he asked Syria’s then new President, Assad, to turn off the pipeline 

that was carrying Iraqi oil, and Assad pledged that he would. But 

the oil continued to flow, regardless of such pledges; and so much 

for the promises of Mr. Assad. 

So other than ask nicely for Syrian cooperation, we do not seem 

to have made it clear to Syria that stopping the smuggling was in 

any way important to us; and maybe that is because it wasn’t very 

important to us. As near as I can tell, what was important to us 

was preserving the sanctions regime and mitigating the economic 

harm inflicted on our allies and Iraq’s neighbors, specifically Turkey and Jordan. Syria was just an unintended beneficiary. 

Up until March 2003, that was our policy. It seems somewhat 

silly to be upset about it now in hindsight. 

Sure, it is important to document yet another case of Syrian perfidy and add it to the long list of grievances that we do have with 

Syria. But the question remains: What, if anything, should we do 

about it? For over a year now, the Administration has been threatening to sanction the Commercial Bank of Syria, one of the main 

actors on the financial end of the smuggling. Yet the Administration continues to delay imposition of those sanctions for reasons 

that are not quite clear to me and I suspect not clear to other 

Members. If we are going to hold Syria accountable for violating 

the sanctions before the war, doesn’t that mean we should hold 

other nations accountable as well? 

I don’t think that punishing Jordan and Turkey is a policy we 

should pursue. But if we are going to have a barbecue, I suggest 

we invite all of the Ambassadors of the states involved. 

From assisting the insurgency in Iraq, to continued meddling in 

Lebanese politics, to ongoing support for Palestinian terrorist organizations, there are plenty of reasons for us to be tough with Syria. 

The fact that they smuggled Iraqi oil before the war strikes me as 

among the least of them. 

I thank my colleagues for their efforts in organizing today’s hearing, and I look forward to the history lesson on Syrian smuggling. 

Mr. ROHRABACHER. Well, thank you very much. 

First of all, with your permission, instead of having your poster 

there for the entire hearing, could we have one of your staff take 

down the poster now? 

Thank you. 

Let us note again that there is a distinct difference between the 

United Nations and, as the poster indicated, the Oil-for-Food scandal, the oil and revenue that was received from that, and the revenue that was received from the direct smuggling operations to 

various countries like Syria and Turkey and Jordan. I don’t know 

why that system was set up and why that happened. Perhaps our 

witnesses will be able to give us some information as to what the 

rationale behind it was. 

9

We do know that President Clinton and Madeleine Albright were 

the initiators of that policy. It was not this Administration, but the 

Democratic Administration that preceded us that put that policy in 

place. I would only guess, and I would hope that this is something 

that our witnesses can talk about today, that perhaps there were 

policy reasons that we wanted Jordan and Turkey to be on our side 

in a potential showdown with Saddam Hussein, and perhaps that 

was necessary. Perhaps we didn’t have the resources to actually 

force Syria, which at that time, as Chairman Ros-Lehtinen has 

demonstrated very aptly with her statement, was in a very antiAmerican position and may still be until we see some changes of 

policy. 

This hearing is about what decisions were made in that regard, 

what we could do potentially to stop this smuggling, and what bad 

effects the smuggling had. So it does consider some of the requests 

that you have made, although not totally, of course. 

With that, I would like to recognize our witnesses. 

Our first witness is Elizabeth Dibble, Deputy Assistant Secretary 

of State in the Bureau of Near Eastern Affairs. Ms. Dibble came 

to this position in June 2004 after overseas assignments in Damascus, Islamabad, Tunis, and London. So she has been on the front 

lines and has some insights for us today. She is a career member 

of the Foreign Service. 

Dwight Sparlin is with the Internal Revenue Service; he is the 

Director of Operations, Policy and Support, Division of Criminal Investigations. Mr. Sparlin was named to this position in July 2003. 

He has been with the IRS since 1975, and he obviously understands the numbers and the players, as well as the international 

politics of all of these things. 

We appreciate both of you being here. 

Vic Comras retired from the State Department in 2001 with the 

permanent rank of Minister Counselor. He has had diplomatic 

postings in Africa, Europe and Canada. He also served in the State 

Department as Coordinator for Restitution of World War II assets. 

In May 2002, which is important to our hearing today, he was 

appointed by the United Nations Secretary-General, Kofi Annan, to 

serve as one of the five international monitors charged with overseeing and reporting on the implementation of the United Nations 

sanctions against al-Qaeda. 

With that said, Ms. Dibble, you may proceed. If you could summarize your testimony—I would ask that of all witnesses—then we 

will have ample time for dialogue and questions. You may proceed. 

STATEMENT OF MS. ELIZABETH L. DIBBLE, DEPUTY ASSISTANT SECRETARY, BUREAU OF NEAR EASTERN AFFAIRS, U.S. 

DEPARTMENT OF STATE 

Ms. DIBBLE. Thank you, Mr. Chairman. Thank you Madam 

Chairman, distinguished Members. 

I welcome the opportunity to appear before you today to discuss 

the role of the Syrian Government in the Oil-for-Food Program, 

United States efforts to ensure that frozen Iraqi assets in Syria are 

transferred to the Development Fund for Iraq and broader United 

States efforts to recover Iraqi assets. 

10

The Iraq-Syria Trade Protocol was signed in June 2000 in violation of U.N. Security Council Resolution 661. It was designed to enable the Iraqi regime to acquire goods, services, and cash outside 

of the U.N.-authorized and monitored Oil-for-Food Program. As the 

Congresswoman has noted, the Trade Protocol required the Syrian 

Government to deposit 60 percent of the crude oil payments into 

a trade account in the Commercial Bank of Syria in Damascus to 

support the purchases of Syrian and foreign products; and 40 percent went into a cash account at the Syria-Lebanon Commercial 

Bank in Beirut, which is a subsidiary of the Commercial Bank of 

Syria. 

In February 2001, when then Secretary Powell met with President Assad in Damascus, he stressed to President Assad the need 

to cut off Saddam Hussein’s ability to evade U.N. sanctions, and he 

specifically focused on the Iraqi-Syrian pipeline. President Assad 

assured him several times during their discussions that it was the 

Syrians’ plan to bring the pipeline—its contents and revenues generated from it—under the same kind of control as other elements 

of the U.N. sanctions regime. 

We also raised our concerns about these illicit oil exports with 

the U.N. Sanctions Committee. However, the Iraq-Syria Trade Protocol continued to function. 

According to estimates from Iraq’s State Oil Marketing Organization, known as SOMO, from June 2000 until July 2003, the IraqSyria Trade Protocol generated approximately $3.4 billion from the 

sale of illicit Iraqi crude oil and Iraqi petroleum products. 

In October 2003, the Syrian Government permitted investigators 

from the Treasury Department to review these accounts in the 

Commercial Bank of Syria. They found at that time that approximately $850 million had been left in the trade account. The Syrian 

Government, without authentication or authorization from SOMO, 

had paid out an estimated $580 million to Syrian companies in outstanding claims, leaving $266 million in Iraqi assets in the Commercial Bank in Syria. This is after the end of hostilities, obviously, 

in 2003. 

Although the Syrian Government repeatedly expressed its commitment to return these frozen assets to Iraq and to review pending and previously paid claims against the assets, no action was 

taken to transfer the assets. 

Together with the Treasury Department, the State Department 

has worked hard to press the Syrian Government to transfer this 

money, these frozen assets, to the Development Fund of Iraq for 

the benefit of the Iraqi people. 

The May 2004 designation by the Treasury Department of the 

Commercial Bank of Syria as an entity of ‘‘primary money laundering concern’’ under section 311 of the USA PATRIOT Act was 

based in part on Syria’s failure to transfer these assets. 

The U.S. Government has made the transfer of these assets one 

of the requirements for determining whether to implement the proposed section 311 sanction against the Commercial Bank of Syria. 

During their meetings with President Assad in September 2004 

and January 2005, respectively, then Assistant Secretary William 

Burns and then Deputy Secretary of State Richard Armitage 

11

stressed the need with President Assad for Syria to transfer the assets, to return them to the Iraqis. 

Together with the Treasury, the State Department and the Embassy in Baghdad have also worked closely with the Iraqi Government to support its efforts to recover the frozen assets. By the end of June 2005, Syria had transferred $121 million to the Development Fund for Iraq, $3.8 million from an undisputed 

account, $72 million from the cash account that had been held at 

the Syria-Lebanon Commercial Bank in Beirut, and $45 million 

from what was described as an overpaid claim. However, $262 million remains at the Commercial Bank of Syria. 

Despite some Syrian steps to improve its anti-money laundering 

and terrorist finance controls, the section 311 sanctions could be 

triggered if Syria does not follow through with the transfer of this 

remaining amount to the Development Fund for Iraq. 

With the Treasury Department in the lead, the State Department has worked hard to seek compliance with U.N. Security 

Council Resolution 1483 requiring U.N. member states to immediately freeze and transfer to the Development Fund for Iraq all 

funds or economic resources belonging to the previous Iraqi Government, to Saddam Hussein, and to others. The State Department, through our mission in New York at the U.N. and through 

our Embassies abroad, has mounted a full-scale diplomatic regime 

to designate certain individuals and entities for asset freeze. We 

have also worked closely with the Iraqi Government on an assets 

recovery strategy. 

Since the adoption of U.N. Security Council Resolution 1483, al- most $1.2 billion has been transferred to the Development Fund for 

Iraq. However, much more remains to be done. We estimate that 

there may be approximately another $1 billion in known frozen 

Iraqi assets that can potentially be recovered. The largest amounts 

of frozen Iraqi assets are in Lebanon, Switzerland, the U.K., and 

Syria. 

Mr. Chairman, Madam Chairwoman, I appreciate this opportunity to provide some background to the Subcommittees on Syria’s 

involvement in illicit oil trade with Iraq and our efforts to recapture Iraqi assets still held in Syria as well as frozen Iraqi assets 

elsewhere around the world. I would, of course, be happy to answer 

questions that you have. 

[The prepared statement of Ms. Dibble follows:]

PREPARED STATEMENT OF MS. ELIZABETH L. DIBBLE, DEPUTY ASSISTANT SECRETARY, 

BUREAU OF NEAR EASTERN AFFAIRS, U.S. DEPARTMENT OF STATE

Madam and Mr. Chairmen, distinguished members of the Committee, 

I welcome this opportunity to appear before you today to discuss the role of the 

Syrian government in the Oil-for-Food Program, U.S. efforts to ensure that frozen 

Iraqi assets in Syria are transferred to the Development Fund for Iraq, and broader 

U.S. efforts to recover Iraqi assets. 

Madam and Mr. Chairmen, 

In previous testimony before this and other Congressional committees investigating Oil-for-Food matters, my colleagues have described the various ways in 

which Saddam Hussein attempted to undermine the sanctions imposed by the UN 

Security Council on Iraq under Resolution 661 (1990) following Saddam’s invasion 

of Kuwait in August 1990. Given the focus of today’s hearing, it is important to note 

that Saddam’s efforts to evade the sanctions were facilitated through the cooperation and complicit involvement of various governments and parties outside Iraq. 

Among them was the Syrian government. 

12

Background on Oil for Food Program 

First, let me provide a little background on the Oil for Food Program. In 1996, 

the United Nations and Iraq established the Oil for Food (OFF) program to address 

growing concerns about the humanitarian situation in Iraq after international sanctions were imposed in 1990. The program’s intent was to allow the Iraqi government 

to use the proceeds of its oil sales to pay for food, medicine, and infrastructure 

maintenance, and, at the same time, prevent the regime from obtaining goods for 

military purposes. From 1997 through 2002, Iraq sold more than $67 billion in oil 

through the program and issued $38 billion in letters of credit to purchase commodities. The United Nations and the Security Council monitored and screened contracts that the Iraqi government signed with commodity suppliers and oil purchasers, and Iraq’s oil revenue was placed in a U.N.-controlled escrow account. 

However, the Saddam Hussein regime also circumvented the Oil-For-Food Program through illicit oil sales, including through trade protocols established with the 

governments of Syria, Jordan, and Turkey. The Duelfer Report, issued in September 

2004, estimated that Iraq earned almost $5 billion from all its protocols between 

2000 and the outbreak of hostilities in March 2003. 

The United States, with strong support from the United Kingdom, attempted to 

counter Saddam Hussein’s efforts to evade the requirements of the OFF. We often 

met with resistance by Member States, including some members of the UN Security 

Council and participants on the UNSC Committee that was established to monitor 

the OFF program, known as the ‘‘661 Committee. Saybolt, selected as the independent oil inspection agent of the United Nations through a competitive bid process, assisted the 661 Committee with the task of monitoring the quantity and quality of exports of Iraqi oil under the OFF Program. Through its work, Saybolt became 

aware of instances of the smuggling of oil outside the OFF Program. We reported 

those instances to the United Nations orally and, on occasion, in writing. In November 2000, Saybolt informed the United Nations of rumors that the oil pipeline to 

Syria had been put into operation. 

In February 2001, then Secretary Powell traveled to Damascus and met with 

President Asad. Secretary Powell stressed the need to cut off Saddam Husein’s ability to evade UN sanctions and specifically focused on the Iraqi-Syrian pipeline. 

President Asad assured him at three times during their discussions that it was their 

plan to bring the pipeline, what was going through that pipeline, and the revenues 

generated by that pipeline under the same kind of control as other elements of the 

UN sanctions regime. 

We brought this information about the Iraq-Syria pipeline to the 661 Committee, 

but we met with stiff resistance from other Committee members. During an October 

2002 meeting of the 661 Committee, we requested an explanation as to the apparent 

discrepancies between the amount of oil Syria produced domestically, the amount 

it consumed domestically, and the total annual volume of oil that Syria exported. 

The Syrian representative, a member at the time of the 661 Committee, with support from other delegations, questioned the reliability of the figures we quoted, 

which we had drawn from publicly available oil industry publications. The Syrian 

representative also stated that the pipeline was being used for ‘‘testing purposes,’’ 

rather than actual delivery of oil to Syria. Another delegation, seeking to deflect the 

focus on Syria, suggested the Committee’s work would be more effective if alleged 

sanctions violations were not considered singularly and in isolation, but rather were 

viewed in the relative context of other reports of non-compliance. 

Iraq was engaging in these unauthorized oil exports under the terms of a bilateral 

trade protocol with Syria, signed in June 2000, in violation of UNSCR 661. This 

trade protocol was designed to enable the Iraqi regime to acquire goods, services, 

and cash outside of the oil sales and purchases approved by the 661 Committee. 

Syrian-Iraqi Oil Transfers 

According to estimates from Iraq’s State Oil Marketing Organization (SOMO), 

from June 2000 until July 2003 the Iraq-Syria Trade Protocol generated approximately $3.4 billion from the sale of illicit Iraqi crude oil and Iraqi petroleum products. The trade protocol required the Syrian government to deposit 60% of the crude 

oil payments into a trade account in the Commercial Bank of Syria in Damascus 

to support the purchases of Syrian (and foreign) products, and 40% into a cash account at the Syria-Lebanon Commercial Bank in Beirut, a subsidiary of the Commercial Bank of Syria. Refined product payments also went to the cash account. 

In October 2003, the Syrian government permitted investigators from the Treasury Department to review these accounts at the Commercial Bank of Syria in Damascus. My colleague from the Treasury Department can provide more detailed information, but, in short, the investigators found that, at the end of major combat 

operations, approximately $850 million had been left in the trade account. However, 

13

the Syrian government, without authentication or authorization from SOMO, paid 

out an estimated $580 million to Syrian companies in outstanding claims; $266 million remained at the Commercial Bank of Syria, $262 million in the trade account 

and $3.8 million in accounts belonging to other Iraqi government entities, such as 

the Iraqi Airlines. The investigators also found that, as of September 2004, $72 million remained in 

the cash account at the Syria-Lebanese Commercial Bank (SLCB) in Beirut; the 

SLCB provided records showing that $816 million in authorized payments had been 

made from this account until 2003. 

U.S. Steps to Press Syria to Return Frozen Iraqi Assets 

In May 2004, the Treasury Department designated the Commercial Bank of Syria, 

and its subsidiary the Syria-Lebanese Commercial Bank in Beirut, as ‘‘primary 

money laundering concerns’’ pursuant to Section 311 of the USA PATRIOT Act. The 

Federal Register Notice announcing this designation proposed a ‘‘special measure’’ 

requiring U.S. financial institutions to sever correspondent banking relationships 

with the Commercial Bank of Syria and the Syria-Lebanese Commercial Bank. This 

designation was based, in part, on the Commercial Bank of Syria’s use ‘‘as a conduit 

for the laundering of proceeds generated from the illicit sale of Iraqi oil’’ and Syria’s 

failure to transfer the remaining proceeds, which were in frozen accounts at the 

Commercial Bank of Syria, to the Development Fund for Iraq, as required under UN 

Security Council resolution 1483 (2003). 

In May 2004, following Treasury’s designation of the Commercial Bank of Syria, 

the Syrian Finance Minister invited Treasury to send a team of experts to Syria to 

review Syrian banking practices. The State Department participated on the interagency delegation, led by Treasury, which traveled to Damascus in September 2004. 

Based on the team’s findings, Treasury’s then Assistant Secretary Zarate and Embassy Damascus later presented the Syrian government with a list of specific steps 

it needed to take to address our concerns about deficiencies in Syria’s anti-money 

laundering and terrorist finance controls, as well as a timetable for implementing 

them. One of the requirements specifically addressed the need for Syria to transfer 

the frozen Iraqi assets to the Development Fund for Iraq. 

In close coordination with Treasury, Embassy Damascus has consistently pressed 

the Syrian government to implement the required steps and has monitored its 

progress. In their respective visits to Damascus in September 2004 and January 

2005, then-Assistant Secretary Burns and then-Deputy Secretary Armitage specifically pressed President Asad to address our money laundering and terrorist financing concerns and to return the $266 million in frozen Iraqi assets to the Development Fund for Iraq. 

Treasury decided to postpone the implementation of the proposed sanction against 

the Commercial Bank of Syria—the severing of correspondent accounts between 

U.S. financial institutions and the Commercial Bank of Syria—pending Syrian actions on this list of requirements. 

Together with Treasury, the State Department and Embassy Baghdad have also 

worked closely with the Iraqi government to support its efforts to recover these frozen assets in Syria. 

In July 2004, then-Iraqi Prime Minister Allawi and Syrian President Asad met 

in Damascus and reportedly agreed to establish a joint technical committee to review the issue of frozen Iraqi assets and pending and previously-paid claims. However, no committee was established and the frozen assets remained at the Commercial Bank of Syria in Damascus. The Syrian government publicly and privately committed itself on several subsequent occasions to transferring the remaining assets 

and to reviewing both pending and previously-paid claims against those assets, but 

again no action was taken. 

The U.S. government has continued to press the Syrian government at every opportunity to transfer these assets to the DFI and to work with the Iraqi government 

to review pending and previously-paid claims. In January of this year, the Syrian 

government transferred $3.8 million to the DFI. In late June, apparently in connection with the timetable for implementing the Section 311 requirements, the SyriaLebanese Commercial Bank transferred the $72 million from the cash account to the 

DFI. At the same time, the Commercial Bank of Syria transferred $45 million from 

an overpaid claim. In total, the Syrian government has transferred $121 million to 

the DFI. 

However, $262 million still remains in the Commercial Bank of Syria. Following 

discussions between the Iraqi and Syrian Finance Ministers in early July, the Syrian government again committed to transferring this amount, but only upon receipt 

of formal instructions to do so from the Iraqi Finance Minister. We understand 

these instructions were just issued. Despite Syrian steps to improve its anti-money 

14

laundering and terrorist finance controls, the Section 311 sanctions could be triggered if Syria does not follow through with the transfer of this remaining amount 

to the DFI. 

Overall U.S. Assets Recovery Efforts 

UN Security Council resolution 1483, adopted on May 22, 2003, required that 

Member States immediately freeze and transfer to the Development Fund for Iraq 

all funds or economic resources belonging to the previous Iraqi government, to Saddam Hussein, or to other senior officials of the former Iraqi regime and their immediate family members, unless there were prior judicial, administrative, or arbitral 

liens or judgments against those assets. The U.S. has been at the forefront of this 

effort to identify individuals and entities for designation by the UN for assets freeze, 

with the State Department, through our Mission to the UN in New York and 

through our Embassies abroad, energetically reaching out and seeking cooperation 

from governments in cosponsoring submissions to the UN Sanctions Committee. We 

have gotten support on specific designations from countries ranging from the UK 

to Syria. So far, the UN Security Council Committee responsible for implementation 

of resolution 1483 has designated 83 Iraqi individuals and 206 Iraqi government entities for assets freeze pursuant to this resolution. 

With the Treasury Department at the lead, the U.S. has worked hard to seek compliance with this resolution. As a member of the Treasury-chaired inter-agency assets recovery working group, the State Department has mounted a full-scale diplomatic campaign to recover Iraqi assets abroad. Since the transfer of sovereignty to 

Iraq in June 2004, we have also worked closely with the Iraqi government on an 

assets recovery strategy and sent a State Department expert to Baghdad to share 

information on the amounts and whereabouts of the frozen assets. We have urged 

the Iraqi leaders to include this as a priority issue in their bilateral discussions with 

the relevant governments. 

Since the adoption of resolution 1483, almost $1.2 billion has been transferred to 

the DFI. (The U.S. transferred an additional $1.9 billion in Iraqi assets directly to 

Iraq for reconstruction.) More remains to be done. Of the additional frozen assets, 

some are subject to prior legal claims. However, we estimate that there may be another $1 billion in known frozen Iraqi assets that can potentially be recovered. The 

largest amounts of frozen Iraqi assets are in Lebanon, Switzerland, the UK, and 

Syria. 

We have repeatedly urged governments to transfer the Iraqi assets to the DFI as 

expeditiously as possible. 

Madam and Mr. Chairmen, I appreciate this opportunity to provide some background to the Subcommittee on Syria’s involvement in illicit oil trade with Iraq and 

our efforts to recapture the Iraqi assets still held in Syria, as well as frozen Iraqi 

assets elsewhere around the world. I would be happy to answer questions you may 

have.

Mr. ROHRABACHER. Thank you very much. We appreciate all of 

the hard work that you have done over your career. You are coming 

to us today with a treasure house of knowledge. We appreciate 

what you have done in the past, your service in the past, and that 

you are a resource to us today. 

Mr. Sparlin. 

STATEMENT OF MR. DWIGHT SPARLIN, DIRECTOR OF OPERATIONS, POLICY, AND SUPPORT, CRIMINAL INVESTIGATION 

DIVISION, INTERNAL REVENUE SERVICE 

Mr. SPARLIN. Thank you. 

Chairman Rohrabacher, Chair Ros-Lehtinen, Ranking Members 

Delahunt and Ackerman and distinguished Members of this Committee, thank you for this opportunity to discuss the Internal Revenue Service Criminal Investigation Division, or CI, contributions 

regarding our role in identifying and tracing the assets of the 

former Hussein regime for repatriation to the Iraqi people. 

During the spring of 2003, CI participated in the Treasury-led 

working group, along with other agencies, to locate assets that had 

either been removed by the former regime or that were not in 

15

Iraq’s control as a result of the various schemes used by the regime. The purpose of this working group was to identify the assets 

abroad, make diplomatic contacts with the countries that held the 

assets, and request the countries repatriate those assets back to 

the rightful control and ownership of the Iraqi people. 

As part of this working group, CI deployed 17 special agents 

from May 2003 to March of this year to Baghdad, 10 to identify 

and trace these assets, and 7 to target insurgency financing. Additional CI agents were assigned to jump teams created to follow 

international leads that were deployed by the CI agents in Iraq. 

Our mission was not to investigate the intricacies of Oil-for-Food. 

I will briefly summarize the information gathered by CI agents 

from interviews and documents reviewed during the meetings with 

the officials of the Iraqi State Oil Marketing Organization, known 

as SOMO, and the Commercial Bank of Syria. 

During October 2003, agents from CI and the Department of 

Homeland Security—specifically Immigrations and Customs Enforcement—traveled to Damascus, Syria, and other Middle Eastern 

and European countries to identify and trace assets for repatriation. The agents met with officials of SOMO and the Syrian banking community, who provided answers to questions and details of 

Iraqi records held at the Commercial Bank in Syria. 

The interviews and documents revealed an oil sales agreement 

between Iraq and Syria established in June 2000. As part of the 

mechanism to handle the funds generated from the sales of oil, the 

Commercial Bank of Syria created bank accounts for SOMO. The 

proceeds from oil sales were split into two accounts. Sixty percent 

of the revenue was placed into a trade account, and the remaining 

40 percent of the funds were deposited into the cash account at the 

Commercial Bank of Syria. 

Under the Syrian Trade Protocols, the former Hussein regime 

was required to use the money in the trade account to purchase 

goods from vendors and businesses in Syria. The Iraqi Government 

would negotiate contracts with Syrian companies to provide merchandise. Once the merchandise was received in Iraq and verified, 

SOMO would direct the Commercial Bank of Syria to pay specific 

amounts to a Syrian supplier from the trade account. 

The 40 percent cash account was set up with SOMO so that 

when the balance reached $1 million the funds were automatically 

transferred to the Syrian Lebanese Commercial Bank in Beirut, 

Lebanon. In addition to the automatic transfers, there were times 

when SOMO would send a letter directing the withdrawals of cash 

from the cash account. 

Eventually, the cash account funds were deposited into bank accounts at the Central Bank of Iraq, Rasheed Bank, and Rafidian 

Bank in Iraq. Additionally, currency was removed from the cash account at the Commercial Bank of Syria and transported via courier 

to various Iraqi Embassies or deposited into the vault at the Central Bank of Iraq. 

In March 2003, at the start of Operation Iraqi Freedom, the bank 

no longer received directions from SOMO and subsequently combined the trade and cash account without SOMO authorization. 

Syrian suppliers complained that they were owed large sums of 

16

money for merchandise shipped to Iraq for which they had not been 

paid. 

Subsequently, the Commercial Bank of Syria stated they paid ap- proximately $200 million out of the trade account to Syrian suppliers without SOMO authorization. The Commercial Bank of Syria 

would not provide copies of the approximately 370 contracts established between Syrian businessmen and Iraq under the Syrian 

Trade Protocol to substantiate the amounts paid to suppliers. 

SOMO officials accompanied CI and ICE (Immigration and Customs Enforcement) agents during the interviews with the Commercial Bank of Syria. According to preliminary accounting by SOMO, 

from June 2000 to July 2003, over $3.4 billion was generated from 

the sale of oil of Iraqi oil products. From June 2000 to February 

2003, under the Syrian Trade Protocol, over $1.8 billion was placed 

into the trade account; and over $1.2 billion was placed into the 

cash account at the Commercial Bank of Syria. 

SOMO’s audit of the accounts indicates that, after the trade and 

cash accounts were combined, over $1.7 million was paid out of the 

account with SOMO’s authority and over $578 million was paid out 

without SOMO’s authority, compared with the Commercial Bank of 

Syria’s estimates of only $200 million paid out. 

In July 2003, SOMO’s combined Commercial Bank of Syria trade 

and cash account was frozen, with over $261 million on deposit. 

I appreciate this opportunity to highlight the efforts of our special agents who worked under difficult conditions to identify and 

trace assets from the former Hussein regime and will be happy to 

answer any questions. 

[The prepared statement of Mr. Sparlin follows:]

PREPARED STATEMENT OF MR. DWIGHT SPARLIN, DIRECTOR OF OPERATIONS, POLICY, 

AND SUPPORT, CRIMINAL INVESTIGATION DIVISION, INTERNAL REVENUE SERVICE

INTRODUCTION

Chairman Rohrabacher and Mr. Delahunt, Chair Ros-Lehtinen and Mr. Ackerman, and distinguished members of the Subcommittees, I appreciate the opportunity to discuss the contributions of the Internal Revenue Service Criminal Investigation Division (IRS–CI) regarding Treasury’s responsibility to repatriate the 

funds of the former regime to the Iraqi people. 

My testimony today will only summarize information obtained by IRS–CI special 

agents as part of a joint working group with the Department of Defense, various 

intelligence agencies, State Department, Department of Homeland Security, and 

Treasury. 

The Department of Treasury, armed with executive orders and United Nations 

Resolutions, was tasked with identifying and tracing assets belonging to the former 

Hussein regime for repatriation to the Iraqi people. In this Treasury directed effort, 

IRS–CI partnered with the Department of Defense, Defense Intelligence Agency and 

other intelligence agencies, State Department, Department of Homeland Security 

and other Treasury bureaus to accomplish this mission. From May 2003 through 

March 2005 IRS–CI deployed 17 special agents to Baghdad to identify and trace assets belonging to the former Hussein regime as well as investigate insurgency financing. These agents worked with the Department of Defense to obtain the documents and perform interviews of individuals that had knowledge of the various 

methods used by the regime to obtain money for Iraq one of which was a program 

to generate money for oil. Additional IRS–CI agents were assigned to jump teams 

created to follow international leads that were developed by the special agents in 

Iraq. 

IRAQI ASSETS WORKING GROUP

During the spring of 2003, Treasury along with Department of Defense, Defense 

Intelligence Agency, State Department, IRS–CI, Department of Homeland Security, 

17

and other agencies, started a working group to locate assets that had been either 

removed by the former regime or that were not within Iraq’s control as a result of 

the various schemes used by the regime. The purpose of this working group was to 

identify the assets abroad; make diplomatic contacts with the countries that held 

the assets and request the countries repatriate those assets back to the rightful control and ownership of the Iraqi people. IRS–CI’s role in this working group was the 

identification and tracing of these assets. As part of this working group IRS–CI 

agents were sent to various countries worldwide including Syria. 

During the course of the IRS–CI’s efforts to identify and trace assets for repatriation, agents uncovered bank accounts in various countries that contained proceeds 

of oil sales from Iraq to those countries. We do not know the full universe of Iraqi 

assets amassed by Saddam Hussein and the former Government of Iraq, however, 

Treasury and IRS–CI’s financial investigation to date indicates that the former regime accumulated significant wealth from a complex web of financial activities. The 

information contained in this written statement is derived from interviews and documents reviewed during meetings with officials of the Iraqi State Oil Marketing Organization (SOMO) and Syrian Commercial Bank of Syria (CBS). 

SYRIAN TRADE PROTOCOL AND COMMERCIAL BANK OF SYRIA (CBS)

During October, 2003, Special Agents from IRS–CI and the Immigration and Customs Enforcement (ICE) traveled to Damascus, Syria, and other Middle Eastern and 

European countries to identify and trace assets for repatriation. The agents met 

with officials of the Iraqi State Oil Marketing Organization (SOMO) and officials of 

the Syrian banking community who provided answers to questions and details of 

Iraqi records held at CBS. The interviews and documents revealed an oil sales 

agreement between Iraq and Syria established in June 2000. As part of the mechanism to handle the funds generated from the sales of oil, the CBS created bank accounts for the SOMO. In Syria the proceeds from oil sales were split into two accounts. Sixty percent of the revenue was placed in a ‘‘trade account’’ at the CBS; 

the remaining funds (40%) were deposited into a ‘‘cash account’’ at the CBS. 

TRADE ACCOUNT

Under the Syrian protocols, the former Hussein regime was required to use the 

money in the trade account to purchase goods from vendors and businesses in Syria. 

The Iraqi government would negotiate contracts with Syrian companies to provide 

merchandise, once the merchandise was received in Iraq and verified, SOMO would 

direct the CBS by letter to pay a specific amount to a Syrian supplier from the trade 

account. The letter from SOMO contained two authorized signatures of SOMO officials and a ‘‘secret number’’ which identified the letter as official. 

CASH ACCOUNT

The 40% cash account was set up with a standing agreement with SOMO that 

when the account balance reached $1 million the funds were automatically transferred to an account at the Syrian Lebanese Bank in Beirut, Lebanon. These bank 

accounts were set up in the names of various companies or individuals. In addition 

to the automatic transfers there were times when SOMO would send a letter directing the withdrawal of cash from the cash account. The letter was sent by authorized 

officials from SOMO containing two signatures, a ‘‘secret number’’ and the names 

of the officials who were authorized to receive the cash. The letter was sent approximately ten days in advance of the officials showing up at the bank to receive the 

cash. Syrian banking officials stated that the cash pickups were sporadic and occurred approximately every two to three months. 

Eventually, the cash account funds were deposited into bank accounts in the Central Bank of Iraq, Rasheed Bank, or Rafidian Bank in Iraq. Additionally, currency 

was removed from the cash account and transported via diplomatic pouch to various 

Iraqi embassies or deposited into the vault at the Central Bank of Iraq. 

POST OPERATION IRAQI FREEDOM ACCOUNT ACTIVITY

In late March 2003, at the start of Operation Iraqi Freedom, the bank no longer 

received directions from SOMO. The last bank statement sent to SOMO was dated 

February 28, 2003. CBS combined the cash and trade account into one account. This 

was done without any authorization from SOMO. Syrian banking officials stated 

that the bank records are very clear and that the exact amount in each account at 

the time the accounts were merged is reflected in the bank statement. 

The reason the accounts were combined, according to CBS officials, was because 

numerous Syrian suppliers began complaining to the Federation of Syrian ChamVerDate Mar 21 2002 14:38 Nov 01, 2005 Jkt 000000 PO 00000 Frm 00023 Fmt 6633 Sfmt 6621 F:\WORK\OI\072705\22654.000 HINTREL1 PsN: SHIRL
18

bers of Commerce in May 2003 that they were owed large sums of money for merchandise shipped to Iraq for which they had not been paid. The Federation of Syrian 

Chambers of Commerce discussed this matter with the Syrian Ministry of Economy 

& Trade who ultimately decided to pay legitimate contracts held by Syrian companies from the Iraqi trade account because of their concern that many Syrian businesses would go bankrupt if the money was not paid. These contracts were submitted to Syrian banking officials who reviewed them personally before payment 

was made to the supplier. The Federation of Syrian Chambers of Commerce performed an independent audit of the contracts which had been paid to determine the 

validity of the contracts. Syrian bank officials commented that the suppliers provided various documents including contracts, shipping documents, country of origin 

and records showing the manufacturing and transportation of the goods to Iraq. 

These bank officials indicated that some suppliers did not have copies of the contracts but had sufficient documentation to justify payment of the contract. These 

same officials further explained that great care was taken in reviewing these requests for payment and that approximately $200 million had been paid out of the 

trade account to Syrian suppliers. These officials indicated that many of the suppliers who were paid had a history of supplying merchandise to Iraq and had previously been paid by authorized letter from SOMO. They further commented that 

many other Syrian supplier requests were not paid because they lacked documentation or were first time suppliers and may very well have legitimate claims for payment. Syrian officials estimated that the unpaid claims were approximately $200 

million. CBS froze all Iraqi accounts in July 2003 after receiving a letter from 

Gassan Al-Rafai, Syrian Minister of Economy & Trade, directing the freezing of the 

accounts. At that time the accounts contained $262,878,142 in the combined cash/

trade account and approximately $3,764,800 in various ministry accounts. 

IRAQI STATE OIL MARKETING ORGANIZATION (SOMO) OFFICIALS

SOMO officials accompanied IRS–CI and ICE agents during the interviews with 

CBS officials. SOMO compared all CBS bank records relating to the trade and cash 

account with SOMO records. SOMO’s audit of the accounts indicates considerably 

more money paid out than was stated by the CBS banking officials (SOMO figures 

of $578,552,720 compared to CBS estimates of $200 Million). A preliminary accounting by SOMO of what was generated, transferred out, paid out, and remains on deposit pertaining to the Syrian Trade Protocol between Iraq and Syria follows:

• From June 2000 until July 2003 a total of $3,449,528,207.33 was generated 

from the sale of Iraqi oil products, a majority of which was crude oil.

• From June 2000 until February 2003 a total of $1,801,246,959 was put into 

the CBS trade account under the Syrian Trade Protocol.

• From June 2000 until February 2003 a total of $1,200,831,306 was put into 

the CBS cash account and then wired shortly after deposit to a SOMO account in Beirut.

• Since March 2003 CBS combined the trade & cash accounts and a total of 

$447,449,942 has been paid into the CBS trade account from March sales and 

accrued payments.

• From March 2003 SOMO’s combined CBS trade & cash account held 

$842,143,630. Of this $1,712,720 was paid out of the account with SOMO’s 

authority and $578,552,720 was paid out without SOMO’s authority. (CBS 

would not provide copies of the approximate 370 contracts established between Syrian businessmen and Iraq under the Trade Protocol that could substantiate the $578,552,720 paid out of the trade account.)

• In October 2003 SOMO’s combined CBS trade & cash account held 

$261,878,142 which had been frozen in July 2003.

• Additionally there were six other accounts at CBS for the various Iraqi ministries that were titled: Iraqi Airline, Iraqi Embassy, Iraqi Interest Section, 

Iraqi Railroad, Iraqi Commercial Attache ́, and Iraqi Commercial Office. Approximately $3,764,800 in these accounts was frozen in July 2003. 

CONCLUSION

I appreciate this opportunity to provide information concerning IRS–CI efforts in 

the identification and tracing of assets belonging to the former Hussein regime for 

repatriation to the Iraqi people. I wish to thank the distinguished members for this 

opportunity to appear before you and I will be happy to answer any questions you 

may have.

19

Mr. ROHRABACHER. You know, in Congress we have tried to balance the budget for years and tried to get the numbers right. 

Thank you very much for sharing your expertise. Obviously, we 

need some help when it comes to understanding numbers. I appreciate that very much. 

Mr. ACKERMAN. We actually balanced it at one point, if you recall, Mr. Chairman. 

Mr. DELAHUNT. It was in the previous Administration. 

Mr. ROHRABACHER. That is right. I will have to admit that we 

did balance it at one point, and it was a great accomplishment of 

the Republican Congress. But we won’t get into that. 

Mr. ACKERMAN. It was the Hoover economy kicking in. 

Mr. ROHRABACHER. Mr. Comras. 

STATEMENT OF MR. VICTOR COMRAS, ATTORNEY, COMRAS & 

COMRAS 

Mr. COMRAS. Mr. Chairman, Madam Chairwoman, thank you 

very much for inviting me here to share with you my views regarding Syria and its role in circumventing the Oil-for-Food Program. 

My perspective is somewhat historical. During the 2000 and 2001 

time frame, I was asked by the State Department to help develop 

a new program of smart sanctions that might be used to reinvigorate the measures that we had imposed on Iraqi. I continued to do 

so until my retirement in 2001. 

Despite Syria’s engagement in Desert Storm, Syria never really 

went along with the Iraq sanctions. The sanctions were highly unpopular with the Syrians, and they felt no real compulsion to respect them. Their border with Iraq is porous, and there were substantial profits to be made. By the mid-1990s, relations between 

Iraq and Syria had warmed considerably. Neither side was going 

to let the Oil-for-Food Program get in the way of their own trade 

and geopolitical interests. 

In June 1997, right about the same time as the actual start of 

the Oil-for-Food Program, Syria invited in an Iraqi trade delegation 

and in July 1998, Syria signed a memorandum of understanding 

with Iraq to rebuild the Bayji-Kirkuk oil pipeline. That pipeline 

had been closed since the 1982 Iran-Iraq war and needed extensive 

repairs. This entailed a great investment by both parties and was 

a clear signal at that time that they had an eye on circumventing 

the Oil-for-Food Program. 

Oil began flowing through that pipeline in April 2000 and special 

incentives prompted Syria to maximize the flow as rapidly as possible. Syria would get the Iraqi oil at a $6 per barrel discount and 

would turn around and sell it at full commercial rates. This generated considerable revenue for both countries, and Iraq’s share 

went directly into special accounts in the Commercial Bank of 

Syria and elsewhere. Iraq earned some $3 billion under this arrangement. 

I do not think any of us should have been surprised by the findings of the Iraq Survey Group that numerous Syrian companies 

were in bed with the Iraqis. There were many indications of that 

early on. One Syrian company, SES International, which was just 

designated by the Treasury Department last month, played a major 

role in acquiring redline and other sensitive items for Iraq. That 

20

company is owned by a cousin and close friend of Bashir al-Assad, 

President of Syria. 

Syria got away with this, Mr. Chairman, Madam Chairwoman, 

because no one was willing to put any real pressure on them to 

stop. In my written statement, I provided you with some of the reasons why the United States failed to act. We were hung up on trying to replace the existing but failing sanctions with a new streamlined version. But any hope of gaining agreement on these new 

sanctions had to be built on our demonstrating that we meant business when it came to enforcing the old. 

While my State Department colleagues bought our proposal for 

a streamlined sanctions program, they rejected our strategy for 

achieving it. They maintained that the only way to convince the 

world to adopt fresh sanctions against Iraq was to scrap the old 

ones. There was just no stomach for hard-pressing the frontline 

states on compliance. 

But absent any attendant leverage, we were just unable to win 

Security Council support. The violators were just too comfortable 

with the old no-longer-enforced sanctions to buy into a new, reduced sanctions program, and by the time the Security Council finally seriously took up our sanctions proposal, which was about 9 

months after it was presented and after two Security Council 

delays, we were well on the road to a broader confrontation with 

Saddam Hussein. 

That is history. But what does that mean for today? Mr. Chairman, Madam Chairwoman, there has never been a real accounting 

of the money Iraq earned from these illicit deals. There are still 

vast amounts out there in Syria, Lebanon, the Middle East, and 

elsewhere. We can only believe that at least some of these funds 

are now supporting the insurgency in Iraq and perhaps terrorism 

farther afield. We must make an even greater effort today to track 

down these funds and those that engage so blatantly in these practices. 

Thank you, Mr. Chairman, Madam Chairwoman, Members of the 

Committee. 

[The prepared statement of Mr. Comras follows:]

PREPARED STATEMENT OF MR. VICTOR COMRAS, ATTORNEY, COMRAS & COMRAS

Thank you for giving me this opportunity to share my views and concerns regarding Syria and its role in undermining of the United Nation’s oil for food program. 

You have already given great attention to the oil for food program and how it was 

turned from providing the Iraqi people adequate and equitable access to civilian and 

humanitarian goods into a corrupted channel easily manipulated for the benefit of 

Saddam and his cronies. This process of corruption was, in part, the result of serious flaws in the program concept itself. But, much blame must also be placed on 

those responsible for its oversight, and those that sought to take advantage of the 

program for their own avarice, greed, or narrow political interests. Looking back, 

we can see clearly how Saddam Hussein and his cronies took advantage of the flaws 

in the program and how easy it was for him to find willing partners outside Iraq 

to help him bilk or otherwise circumvent it. 

My testimony today deals with Syria, and the role Syria played in undermining 

both the oil for food program and the underlying sanctions on Iraq. My knowledge 

stems from first hand experience in trying to put together a re-energized Iraq sanctions program during the 2000–2001 time frame. The failure of those efforts, I believe, inevitably contributed to the atmosphere which led to the Iraq War. 

The oil for food program, you will recall, was established within the context of 

broad internationally agreed sanctions against the Saddam Hussein regime. These 

sanctions were imposed following Iraq’s invasion of Kuwait. They were continued, 

21

after the Gulf War, in response to Saddam’s continuing aggressive posture, his support for international terrorism, his outrageous human rights abuses, and his attempts to acquire weapons of mass destruction. The rationale for these sanctions 

was clearly defined in UN Security Council Resolution 687 (1991) and reiterated 

and re-enforced in subsequent resolutions. 

When the oil for food program was first proposed in Security Council resolution 

706 of August 15, 1991 it laid out a simple and direct control mechanism. Iraq 

would be allowed to export up to $1.5 billion worth of oil during a six month period. 

Further allotments would be accorded for additional six month periods as warranted. Saddam rejected this program outright. He chose to hold his own people hostage and use their deteriorating humanitarian situation as a bargaining chip to 

press for sanctions removal. And this gambit, in time, resulted in increased international pressure on the US and other Security Council members to loosen the sanctions. Against this pressure, the Security Council agreed to restructure the oil for 

food program in 1996 to meet several of Saddam’s preconditions. These concessions 

left Saddam with the authority to allot oil lifting contracts and to pick and choose 

between humanitarian and civilian goods suppliers. And it gave him the tools he 

needed to corrupt the process. Nevertheless, at the time it was felt that resolution 

986 (1995) setting up the new oil for food program provided sufficient safeguards 

to impede any such overt manipulation. 

These safeguards were to be based on a close review of the bona fides of the oil 

lifting companies among which Saddam could choose. Special oil contract overseers 

and the 661 Committee were also to be responsible for validating each contract according to quantity and price. The funds generated were to be deposited in a special 

escrow account and disbursed only upon UN authorization. 

Iraq’s contracts for civilian and humanitarian goods were also made subject to 661 

committee review. And the goods imported against such contracts were supposed to 

be verified by a reliable UN appointed inspection service. In addition the multilateral interdiction force established at the time of the Gulf war was directed to intensify its patrol of Aqaba and the Persian Gulf to police against illicit Iraqi oil exports 

and other attempts to circumvent the program. This is what was planned. This is 

not what occurred! The basic controls so important to the maintenance of the program were, from the outset, loosely applied, or simply overlooked, and the front line 

states, to varying degrees, simply decided to ignore them. Saddam quickly gained 

the upper hand in manipulating and governing this operation. 

Even before the oil for food program was in place, Syria was showing ambivalence 

toward the oil for food program and sanctions itself. The sanctions were highly unpopular in Syria, and the Syrians felt little compulsion to respect them. Syria shares 

a 300 mile border with Iraq offering numerous opportunities for contraband and 

smuggling. Syria’s ports were unfettered by the MIF operations which covered Jordan’s Aqaba port and the Persian Gulf, and profits could be made. It’s not clear to 

what extend Hafez Al-Assad, who had his own axe to grind with Saddam, really 

frowned on this cross border trade. But, in any event, relations between Syria and 

Iraq were already warming when the oil for food program began. In June 1997 Syria 

opened new trade relations with Iraq and officially opened the three major border 

crossings points for trade. They also invited an exchange of trade delegations. In 

July 1998, Syria and Iraq signed a memorandum of understanding for the repair 

and reopening of the Banias—Kirkuk oil pipeline. That pipeline had been closed 

since the 1982 Iran-Iraq War and needed extensive rebuilding and repair. This entailed considerable investment by both parties, and was a clear signal that both already had an eye on circumventing the oil for food program. The pipeline actually 

began operating in April 2000 (although it was not officially opened until November 

2000). It quickly established itself as a major source of revenue, illicit or not, for 

both countries. Running at its full capacity, the pipeline could pump 200,000 to 

250,000 barrels per day, generating in excess of $1 billion a year. 

By the spring of 2000 UN sanctions on Iraq were unraveling. The sanctions were 

being violated openly and on a regular basis. The United States was under enormous international pressure to scrape or restructure them. Even our closest allies 

were critical of the unintended impact they were having on the Iraqi people. Three 

permanent Security Council members, France, Russia and China, were pushing for 

agreement on an expanded list of exempted items. They also wanted a significant 

reduction in the list of red-lined goods (sensitive dual use and military items) that 

could not be exported at all to Iraq. By September 2000, Russia threatened to resume direct cargo flights to Baghdad in violation of sanctions, and Syria, Algeria 

and other countries began regular air cargo service to Baghdad in violation of the 

sanctions. Ostensibly these planes carried only ‘‘humanitarian goods,’’ but no UN inspectors were present to verify them. 

22

In this climate of crumbling sanctions, Syria, in May 2000, took up an Iraqi offer, 

extended also to other Middle East countries, to negotiate a preferential trade protocol. In Syria’s case, this included special additional incentives involving the use 

of the Banias pipeline. The protocol was signed in Baghdad in May 29th, 2000. 

Under its terms, Syria would buy Iraqi oil at a $6.00 per barrel discount. The oil 

would ostensibly be for Syria’s own use, freeing up Syrian oil for export at full market rates and generating a comfortable profit. The excuse was that Jordan already 

enjoyed a special ‘‘wink of the eye’’ exemption to import Iraqi oil for local consumption. Iraq’s share of the funds generated by these transactions (which included the 

oil purchase price as well as ‘‘under-the-table kickbacks’’), would be deposited in special accounts designated by Iraq. Under the Protocol, 60% of these Iraq’s earnings 

would be deposited in a SOMO controlled account in the Commercial Bank of Syria. 

These funds would, ostensibly be used to buy Syrian goods or foreign-made items 

purchased through Syria. The remaining 40% would go into special accounts designated by Iraq authorities. These special accounts were maintained in Syria, Lebanon, Iraq and elsewhere. According to the Iraq Survey Group Report, some $2.8 

billion was retained by Iraq under this arrangement. And all of these funds were 

available for use to circumvent the sanctions and the oil for food program. 

The Syria Protocol Agreement was further expanded in January 2001 with the 

signing of a new Iraq-Syria Free Trade Agreement. This agreement completely 

flaunted the UN sponsored Iraq sanctions. And Syria began openly to export to Iraq 

a broad range of consumer goods (most of which were manufactured elsewhere). 

This extensive trade also provided a convenient cover for Iraq’s acquisition via Syria 

of sensitive military and dual use equipment. 

There were many indications during this period that Syria was cooperating with 

Iraqi defense and security agencies, and that Syrian companies were acting as 

fronts, or on behalf of Iraqi government entities wishing to acquire red-lined items. 

Many of these suspicions were borne out by the investigative work undertaken after 

the Iraq war by the Iraq Survey Group. We now know, for example, that Iraqi government security and military agencies were in regular contact with Syrian companies and that they used funds generated under the Iraq-Syria Trade Protocol, to circumvent the sanctions. According to the Survey Group Report, one Syrian company, 

SES International, alone received some $187 million in Iraq defense/security contracts. That firm reportedly served as the primary facilitator for the transshipment 

of weapons and munitions through Syria to Iraq. SES International is owned by 

Dhu al-Himma Shalish, a cousin and close personal friend of Syrian President 

Bashar al-Asad. The Survey Report notes that ‘‘Shalish traveled to Baghdad to coordinate shipments of weapons and sometimes received cash payments. At other 

times, the Iraqis reimbursed Shalish by transferring funds from their overseas accounts to an SES account in Syria.’’ The U.S. Treasury Department designated SES 

International, along with Shalish and several of his colleagues as sanctions violators 

only last month, on June 9, 2005. This designation ordering the freezing of their 

assets and bank accounts in the United States. US persons were also prohibited 

from dealing with them. However, it’s unclear whether any SES International or 

Shalish assets were ever located under U.S. Jurisdiction. 

There are numerous other examples contained in the Iraq Survey Group of complicity between the Iraqi military and intelligence services and high ranking Syrian 

government officials implicated in fronting for Iraq to obtain military equipment, 

munitions and other redlined items. Some we knew about, some we suspected, and 

some we didn’t. 

These financial and trade arrangements were in clear and direct violation of UN 

sanctions and the oil for food program. But, Syria got away with it. And they got 

away with it because nobody seemed to really care. No one was willing to take any 

action, or put any real pressure on Syria to stop. In fact, only months after Syria 

opened full trade with Iraq, in clear violation of the UN sanctions, and after the 

9/11 attacks, Syria was elected to serve on the Security Council. Syria received 160 

positive votes and had the unanimous support of the Asia/Middle East bloc in the 

UN General Assembly. She took her seat on the Security Council on January 2002. 

And even while on the Security Council, Syria continued to increase the amount of 

Iraqi oil pumped through the pipeline and to expand trade relations with Iraq in 

violation of the sanctions. 

On December 16, 2000, Colin Powell, just after being selected by President-Elect 

Bush to serve as Secretary of State, told a press conference that ‘‘re-energizing’’ the 

sanctions on Iraq would be among his first priorities. Secretary Powell traveled to 

Syria in February 2001 to discuss the Iraq sanctions and to press Syria for sanctions compliance. He obtained Bashir al-Assad’s promise to cap Iraq oil exports via 

Banias and to place the resulting funds in a UN approved escrow account. 

23

I was asked to follow up on this Powell visit and to develop a new streamlined 

or ‘‘smart’’ Iraq sanctions program. We were instructed to develop a program that 

would retain pressure on the Saddam regime, protect against his acquisition of 

WMD, and curtail his access to unregulated funds. We also had to be able to sell 

the program to the Perm 5, and the Security Council as a whole. We hoped to use 

this program to salvage the sanctions and retain real political and economic pressure on Saddam and his cronies. It was clear this would be a very difficult task and, 

even then, we would have to apply great pressure on the front line states—Syria, 

Jordan and Turkey—to comply. I worked on this project for the next six months, 

until I retired in September 2001. 

Together with NEA Assistant Secretary Ned Walker, I visited Amman, Damascus 

and Ankara in April 2001 for talks on the details of our new ‘‘smart sanctions’’ program. In Syria we met with Foreign Minister Farouk al-Shara. But al-Shara wasn’t 

interested in talking about sanctions. Instead, he lectured us for two hours on the 

Palestinian intifada and alleged Israeli injustices. I don’t think he expected anything to come from this diatribe. He used it as a diversion from talking about Iraq. 

For Syria had no intention of dampening its new profitable oil and contraband trade 

with Iraq. In fact, al-Shara reportedly used his own influence on Bashir al-Assad 

to assure that Syria would continue to move ahead with closer Iraq ties. With some 

sense of personal peril I still presented him our white paper. I also used the very 

few minutes he left to us to provide a short presentation on our proposals. ‘‘Come 

back and see me once you have UN Security Council approval,’’ he said and quickly 

left the room. 

Let me tell you what we had in mind. 

The package of sanctions my colleagues and I worked up was based on three assumptions:

1. Sanctions were critical to our policy of containing Iraq.

2. Sanctions should be directed principally at stop Saddam from hardening his 

military capabilities or from acquiring WMD.

3. The impact of the Sanctions impact should be directed at the Saddam regime 

itself while avoiding undue hardships on the Iraqi people.

The first element in our ‘‘smart sanctions’’ package was to fast track approval for 

civilian and humanitarian goods. Contract approval for such items could be expedited by using a ‘‘no objection’’ procedure. This would mean that most contracts 

would be approved within a few days after their submission. However, we also intended to institute new post shipment accounting and verification procedures to 

limit graft and kickbacks. Under our proposals, the 661 Committee would review 

only a short list of green line (dual use) items. Sensitive dual use and military items 

would be red-lined and turned down automatically. We expected these measures 

would reduce processing delays and mitigate the costs and burdens involved. 

An essential element of the program was to re-gain control over the funds generated by Iraqi oil sales. We hoped to do this by stamping out Saddam’s various oil 

for food pricing schemes. The eventual solution was to impose a retroactive oil pricing mechanism that eliminated lifting fees and built-in kickbacks. We also suggested a revision of the list of companies approved to lift Iraqi oil. We argued that 

the list should be pared down significantly to eliminate pure middle-men as well as 

companies we knew to have engaged in pricing schemes, graft or kickbacks. Companies on the list would be held accountable. 

We also directed our attention at the schemes Saddam had used to circumvent 

the Oil for Food program. Under our program the MIF would flex its muscles in 

the Persian Gulf to better inhibit Iraq’s ability to use that route to sneak oil out. 

The program we presented to Syria, Jordan and Turkey would have continued to 

permit them to receive Iraqi oil. However, the funds attributed to these transactions 

would have been placed in local escrow account to be administered jointly by the 

UN and local authorities. These funds could be used to purchase items in the local 

economy, including imported items. But the items purchased would be subject to 

verification and redlined items excluded. We also planned to establish special Sanctions Assistance Missions that would help control contraband moving across the borders. 

The first step in our proposed strategy to win support for these streamlined sanctions was to try and re-establish some credence behind enforcement of the current 

sanctions. It had to be clear that we would no longer tolerate open sanctions violations, such as those occurring in Syria. We suggested that Syrian and other firms 

fronting for Saddam cronies, or otherwise implicated in routine kickbacks to the 

Saddam regime, be designated pursuant to a new IEEPA executive order and that 

we seek agreement for designation also at the UN level. This approach had worked 

24

well in dealing with the Milosevic regime in Serbia. And such an approach would 

give us at least some leverage in selling the new sanctions package. We could trade 

off enforcement of the old sanctions for adoption of the new ‘‘smart sanctions’’ model. 

For my group it was clear that we would not be able to sell this new package if 

the front line states and others continued to believe that they faced no consequences 

for violating sanctions. Even Saddam Hussein indicated a preference for the old, 

broader sanctions system which he had already corrupted to the new proposals we 

were putting on the table. 

So. What happened? 

Our colleagues in the geographic and functional bureaus at the State Department 

liked our sanctions proposals, but dismissed our tactics. Our group wanted to press 

ahead with re-invigorating the old sanctions, while negotiating on the new ones. The 

powers that be preferred that we distance ourselves from the old sanctions which, 

they argued, had already been tainted as having caused undue suffering in Iraq. 

They maintained that the only way to convince the world to adopt a fresh sanctions 

approach was to forget about the old sanctions. They recommended that Secretary 

Powell focus attention only on the importance of stopping Saddam from obtaining 

WMD, and let the rest of the sanctions issues slip. And that is the line the Secretary 

took. In March 8, 2001, for example, he told the Senate Foreign Relations Committee:

‘‘We were being accused and we were taking on the burden of hurting Iraqi 

people, hurting Iraqi children, and we needed to turn that around. The purpose 

of these sanctions was to go after weapons of mass destruction. That’s what 

they were put in place for in the first instance back at the end of the Gulf War. 

. . . In order to make sure that that carried forward, we then had to take a 

look at the sanctions themselves. Were they being used to go after weapons of 

mass destruction and was that the way they were connected to our original 

goals, or, increasingly, were those sanctions starting to look as if they were 

hurting the Iraqi people? And it seems to me one approach to this was to go 

to those sanctions and eliminate those items in the sanctions regime that really 

were of civilian use and benefited people, and focus them exclusively on weapons of mass destruction and items that could be directed toward the development of weapons of mass destruction.’’

A second area of divergence was whether or not to hard press the front line states 

regarding their lack of compliance with the sanctions, particularly Iraq oil exports 

outside the oil for food program. Against our advice, the prevailing view was that 

we concentrate our efforts in gaining UN Security Council approval at the next regularly scheduled Iraq sanctions review session rather than press heads now on sanctions and oil for food violations. That Security Council meeting was scheduled for 

June 1, 2001. 

A third disagreement surfaced as to whether or not we should work out specific 

details regarding the procedures to be used to govern our proposed new local escrow 

account and trade procedures. Once again my small group was overruled. The decision was that we should keep our proposals as general as possible to facilitate winning Security Council approval. The details, they argued, could be filled in by a Security Council Committee thereafter. 

Absent any attendant leverage, such as threatened enforcement of the old sanctions, it proved exceedingly difficult to win Security Council approval for the new 

proposals. In fact, the only leverage seemed to be on the other side. We had allowed 

the old sanctions to pretty much collapse. We were now the ones that needed Security Council approval for the new measures. The old measures no longer carried any 

weight. China, Russia and France had us over a barrel, and they began to push for 

a much greater reduction in the list of so-called redlined items than we were willing 

to concede. And other members of the Security Council joined in demanding further 

details concerning the special preferential arrangements we had in mind for the 

front line states. Comfortable with the old (no longer enforced) sanctions, and faced 

with a threatened Russian veto, the Security Council simply postponed consideration of the new sanctions proposals. The agenda item was rescheduled for the next 

regular six month review of Iraq sanctions. That was to take place in November 

2001. And once again, at the November 2001 meeting, the decision was to push consideration back for another six months. The second Security Council postponement 

prompted me to write an opinion piece which was published by the Washington Post 

on December 31, 2001. I have attached a copy as an appendix to my written statement. By the time the Security Council got around to the issue again we were already well on the road to a broader confrontation with Saddam Hussein. 

I think we were all aware during this entire period, and right up to Operation 

Iraqi Freedom, that the sanctions were being left to deteriorate and that the oil for 

25

food program was operated as little more than a sham. Saddam continued to rake 

in money outside of the Oil for Food program and to spend it as he pleased. And 

the Kirkuk Banias pipeline continued to operate at full capacity right up to the outbreak of hostilities. 

Thank you, Mr. Chairman. 

APPENDIX TO WRITTEN TESTIMONY OF VICTOR D. COMRAS

SHOVING SADDAM BACK IN HIS BOX

washingtonpost.com 

By Victor D. Comras 

Monday, December 31, 2001; Page A17

While things have gone well in Afghanistan in recent weeks, in another arena, 

far from the war zone, the United States has suffered a serious setback in its efforts 

to fight terrorism and keep weapons of mass destruction out of terrorist hands. The 

U.N. Security Council once again has turned down Secretary of State Colin Powell’s 

call to recalibrate the sanctions on Iraq and make them an effective obstacle to Saddam Hussein’s program for producing weapons of mass destruction. 

Many argue that Iraq’s support for terrorism, mixed with its program for developing such weapons, poses an intolerable risk. Yet we have just agreed with the 

Russians that we can postpone for another six months taking steps to cut off Iraqi 

access to this weapons technology and equipment. (The delay is so we can renegotiate the list of items to be kept out of his hands, a matter supposedly decided 

months ago, when the United States first laid its new Iraq sanctions proposal before 

the Security Council—but apparently not yet to Russia’s satisfaction.) 

In the meantime, we have allowed the old sanctions on Iraq to disintegrate to the 

point at which Saddam Hussein’s regime is content to leave them in place rather 

than face sanctions that are pared down but might have some teeth. The current 

sanctions are not being well enforced, and they leave the Iraqi dictator with an almost open door to buy and bring in the technology and equipment he wants to 

strengthen and harden his military and capability for weapons of mass destruction. 

And there is much evidence that this is exactly what he is doing. 

Colin Powell committed himself to ‘‘re-energize’’ the Iraq sanctions when he joined 

the new administration last January. In March he told Congress we would push for 

a new sanctions package concentrating on items related to weapons of mass destruction—the stuff that really counts. We would begin, he said, by cutting off Iraq’s 

smuggling outlets through the Arab front-line states and controlling Saddam Hussein’s money flow. 

Powell traveled to the Mideast twice last spring to win agreement for this plan 

from the front-line states, which pledged to better monitor the flow of goods into 

Iraq and to cut off illegal oil exports from Iraq. But nothing was done. In fact, crossborder trade with Iraq increased, and Iraqi oil exports, with the help of the pipeline 

through Syria, expanded to record levels. 

The U.N. sanctions on Iraq had been decaying for years, and in the past year, 

they collapsed. This was in part because of U.S. neglect. This country signaled an 

abandonment of the old sanctions regime before it had a new regime in place. We 

relaxed pressure on Jordan, Syria and Turkey to curb trade with Iraq. And we gave 

France, Russia and China increased leverage over us to reduce the list of controlled 

items. U.S. failure was clear six months ago, when Russia derailed our new approach with a threatened veto. Since then, the United States has done little or nothing to strengthen its hand—no new initiatives with the front-line states, no work 

on methods for carrying things through, no new pressure on Russia. In fact, we put 

the issue on a back burner. Little surprise then, that we came out with the same 

results when the Security Council took up the matter again on Nov. 30, as it does 

every six months. 

The Sept. 11 attacks make it clear that terrorist states’ access to weapons of mass 

destruction poses the greatest threat to our national security. We cannot wait another six months. We have to decide now whether to choose a military option or to 

seek some flexibility and time by cutting off—or at least slowing—Saddam Hussein’s 

weapons program. 

We do not need a new Security Council resolution to do this. Existing U.N. sanctions resolutions give us more than enough authority to take the necessary steps—

resolutions binding on all states. We must make it clear to all that we view these 

measures as critical to our war on terrorism. 

The first step must be to inhibit Saddam Hussein’s ability to obtain funds or conduct financial transactions outside the U.N. oil-for-food system. Special attention 

26

should be focused on Iraq’s Rafidan Bank, which has branches in Jordan, Syria and 

Lebanon. It is an Iraqi government-controlled entity, long engaged in financial 

transactions that violate U.N. sanctions. 

We need to pressure Syria to stop acting as Iraq’s surrogate for exporting oil outside the U.N. system. The Syrian pipeline that reopened last year brings in more 

than 150,000 barrels of Iraqi oil per day. This is in addition to the Iraqi oil being 

trucked to Syria, Jordan and Turkey outside the U.N. program. It’s also time to 

place restrictions or punitive measures on any international oil company that circumvents the oil-for-food program. 

We must work more closely with our allies to define the core list of items with 

direct relevance to weapons of mass destruction. Exporting countries must adhere 

to new control procedures. And we must be able to verify overall compliance. We 

should press the European Union countries and others to ensure that adequate penalties are in place, including establishment of a ‘‘blacklist’’ of individuals and firms 

circumventing the new control measures. 

We cannot rely just on the work of the Multilateral Interdiction Force that patrols 

the Persian Gulf and the Gulf of Aqaba to stop U.N.-controlled goods from arriving 

in Iraq. Jordan, Syria and Turkey also must do their part to inspect items transshipped to Iraq from their countries. This is no easy task. We can help by providing 

the resources and technology for this effort. We should be able to rely on Turkey—

a NATO ally. If Jordan and Syria cannot filter these items, we (and our allies) must 

filter them before they get to Jordan or Syria. 

Our success inevitably will depend on our organizing ourselves to sustain interest 

in this program. We will have to constantly monitor, verify adherence and pester 

and persuade other countries to take the control measures seriously. 

Of course, we have another option. We can rely on direct military action in Iraq 

to take down Saddam Hussein’s weapons capabilities. But this course would have 

its own costs and consequences.

The writer, recently retired from the Foreign Service, coordinated the international 

enforcement of sanctions against Serbia.

Mr. ROHRABACHER. Thank you very much. 

I want to thank each of the witnesses for your contribution 

today. We have some very serious questions. I am going to start 

right off and begin with the very last point that was made in the 

testimony. 

I take it that what we are talking about is $3 billion that Iraq 

made and the profit that certain people in Iraq made from the 

deals with Syria that involved oil during that time period, and 

where that $3 billion is today, who is in charge of it, and what they 

are doing with that. Before Saddam Hussein was overthrown, the 

$3 billion profit was obviously under the control of people who were 

part of his inner clique; is that correct? 

Ms. DIBBLE. The $3.4 billion was the amount we estimate was 

generated by the protocol in those 3 years. And that is both to 

Syria and to Iraq. We know where a portion of that was. That is 

the money that is in the frozen accounts. But you are absolutely 

correct that there is other money out there. 

Mr. ROHRABACHER. We are talking about hundreds and hundreds 

of millions of dollars that we know are out there somewhere in 

some accounts that are controlled—common sense tells us now that 

they are still controlled by the followers, by the clique that was 

supportive of Saddam Hussein; thus controlled by people who hate 

everything we are trying to do in Iraq today in creating a new democracy in that country. Would that not be fair to say? 

Ms. DIBBLE. It is fair to say that there is a substantial amount 

of money out there. And I am afraid I can’t quantify it. And that 

some of that, yes, could definitely be used by former regime elements or the insurgency. We know that the insurgency and former 

regime elements do not have access to any of the frozen funds. We 

27

are fairly confident that those, because they are still frozen, are not 

being used. But you are correct in that there is other money out 

there. And I don’t know whether——

Mr. ROHRABACHER. In fact, the frozen funds could be returned to 

the new democratic Iraq and would be very helpful. But what we 

are also suggesting is that there is a lot of money that has been 

left over there and these murky transactions that were going on 

that are now still available to people who were supporting the Saddam Hussein regime and were opposing—let’s get down to brass 

tacks. Chairman Ros-Lehtinen’s stepson and stepdaughter have 

just gone over to defend this country. If they are wounded and are 

killed in action, this could have resulted from money that we are 

talking about today that was part of this Syrian agreement that 

now is being sent back to help the insurgency. Isn’t that a possibility? 

Ms. DIBBLE. That is—I would say, yes, that is a possibility. The 

Iraqi Government and the Syrian Government have been in discussions for the better part of a year on the return of the frozen assets. And earlier this week, the Iraqi Finance Minister sent a letter 

to his Syrian counterpart officially requesting in writing the return 

of the $262 million and establishing a system to deal with outstanding claims on both sides. Not just the Syrian claims, but 

claims by Iraqis. 

Mr. ROHRABACHER. But there is money that has not been identified, is that right, Mr. Comras? There are large sums of money out 

there. We do not know exactly where it is, but we know it is in the 

hands of evil people, because they were the ones who got the 

money as a part of their association with Saddam Hussein. 

Mr. COMRAS. Mr. Chairman, there are enormous sums out there. 

At the time of Desert Storm in the 1990–91 time frame, there were 

estimates that Saddam Hussein controlled some $7 billion of unknown funds overseas. That predated all of this. Since that time, 

he was able to acquire what has been estimated to be a fortune of 

from $10–40 billion available for his use. We still know very little 

about any of those funds. And so when it comes to the Syrian 

funds, we know that some of these funds were deposited in CBS. 

We know that some funds were sent at Iraq’s request into Lebanon 

and elsewhere. But at least a third of those funds are still unaccountable. And in addition to that, we have not accounted for any 

of the under-the-table funds or funds that passed hands through 

other kinds of transactions. 

Mr. ROHRABACHER. So right now, bank accounts in Syria and in 

Lebanon could hold up to billions of dollars and these billions of 

dollars are under the control of people who are associated with 

Saddam Hussein, part of his clique, part of his monstrous, murderous clique, let me add. I wouldn’t think that it would be irrational for us to conclude, Madam Chairwoman, that those funds are 

being filtered to those people who are financing this bloody insurgency that is going on in Iraq today. Would you say that that is 

a rational conclusion? 

Mr. COMRAS. I think that is a fair assumption, that at least part 

of these funds are being made available to support this insurgency 

and perhaps other terrorist activities. 

But it is a black hole, Mr. Chairman. We do not know. 

28

Mr. ROHRABACHER. Well, we have to make sure that our people 

there are free to use the force they need on the scene. But in order 

to back them up, we need to have an initiative aimed at the bank 

accounts that are the source, the mainspring, of the weapons that 

are being used against our own people. 

So I would like to thank all of you for illuminating us to this very 

important aspect of whether we are going to be successful in our 

endeavors in Iraq, whether our troops are going to be safe, and 

whether or not the people of Iraq are going to be able to institute 

their democracy rather than be murdered in the streets. 

What about right now? We know there are various terrorist organizations at play in the Middle East. Do we know of transfers of 

the money that we are talking about before the fall of Saddam 

Hussein or maybe during this time period that went to other terrorist organizations? Is there any evidence of other terrorist organizations that were financed by this money? 

Ms. DIBBLE. I am not aware of any evidence, Congressman. 

Mr. SPARLIN. No, we did not have access to all the contracts that 

were let to pay this money out of the accounts, so we were not able 

to follow exactly where that money went. 

Mr. COMRAS. Mr. Chairman, during our work in the United Nations as part of the monitoring group, we looked at various sources 

of funding and were aware of funds that had been placed into 

Rafidain Bank and that had been made available for suicide bombers and others in the Palestinian situation. 

Mr. ROHRABACHER. That came from what bank? From where, 

now? 

Mr. COMRAS. Rafidain Bank. 

Mr. ROHRABACHER. Where is that? 

Mr. COMRAS. Rafidain Bank had branches in Jordan and Egypt 

and other countries in the Middle East, and it was a bank controlled by Iraq, but since it did not directly relate to al-Qaeda, our 

mandate was limited and we did not pursue that information. 

Mr. ROHRABACHER. One last question and then I will turn it over 

to Mr. Delahunt. Some of the testimony of Mr. Sparlin indicated 

that there had been accountants who were unleashed to look at 

these figures. That indicated to me that there was some degree of 

cooperation with the Government of Syria, or at least the bank that 

permitted you to make that investigation. 

Is there some evidence that Syria, as compared to what its 

stance has been for a number of years—which Chairman RosLehtinen very accurately described—might be changing in how 

much Syrian cooperation we have had in this endeavor to find out 

about these funds? 

Mr. SPARLIN. Well, our focus in this effort was to identify and 

trace assets that could actually be repatriated back to Iraq and the 

Iraqi people. In that endeavor we worked with both SOMO officials 

and banking officials to look at the accounts that were set up. So 

there was some cooperation from both of those officials to identify 

the accounts. They provided some records, both SOMO and CBS, 

to verify this account existed and the trade protocols. We were able 

to identify the $261 million that was eventually frozen, but as far 

as tracing the funds and verifying the exact amounts and the dollar 

29

figures and where it went and who it went to, we did not have access to that information. 

Mr. ROHRABACHER. Did you make requests for access to information that you were denied by the Syrian Government? 

Mr. SPARLIN. Yes, yes. 

Mr. ROHRABACHER. How would you catalog or categorize the Syrian cooperation in the investigation, Ms. Dibble? 

Ms. DIBBLE. I think the Syrians have—while they have provided 

some information, some access, there is certainly much, much more 

that they could be doing and should be doing. And probably the 

statement could be more generalized to Syrian behavior across the 

board. There is a lot more they could be doing and should be doing 

that they are not. 

Mr. ROHRABACHER. Mr. Comras, from your vantage point? 

Mr. COMRAS. I do not have a feel, Mr. Chairman, for what is occurring right now. So I am reluctant to answer. The historical pattern was one where we got the brushoff every time we tried to 

raise these issues with the Syrians. 

Mr. ROHRABACHER. Well, let me note that, historically, the pattern that we have heard with Syria is an ‘‘F,’’ if you are going with 

grades that we used to get in school. What would you put if you 

give them a grade in terms of their cooperation; are they still Fs? 

How would you grade the Syrian cooperation? And then we will go 

to Mr. Delahunt. Down the line. 

Ms. DIBBLE. That is a tough question because you need to look 

at the various components—Lebanon, for instance, which is very 

much on the forefront now, and the agenda. Syria pulled out its 

military. It has uniformed troops, but we know that Syrian influence continues; Syria continues to interfere in Lebanese affairs. 

Mr. ROHRABACHER. We also know that the Prime Minister was 

assassinated by people associated——

Ms. DIBBLE. As you know, the United States recalled its Ambassador from Damascus in February after the assassination of former 

Prime Minister Hariri, and she remains in Washington now. 

Mr. ROHRABACHER. In terms of what we are investigating today, 

talking about the oil funds and the cooperation at that level on this 

particular investigation, would you give them a D, a C, an F? 

Ms. DIBBLE. Well. They haven’t returned the $262 million in frozen assets, so until they do that, that is not a passing grade in my 

book. 

Mr. ROHRABACHER. All right. 

Mr. Sparlin, what would you give them? 

Mr. SPARLIN. I may have to defer to my colleagues at State who 

have a great deal of experience in the world in the international 

arena. But it is true that we did not get all the documents that we 

asked for. 

Mr. COMRAS. I defer to my colleagues who have much more recent knowledge than I. 

Mr. ROHRABACHER. Well, thank you very much. Mr. Delahunt. 

Mr. DELAHUNT. Thank you all for the work that you do. And I 

would particularly note the fine work that was done by the IRS 

Criminal Investigation Division. I think the information is very 

solid. 

30

Do any of you disagree with the figures that were presented by 

Mr. Duelfer? And let me just read them to you as a result of these 

illicit deals that were consummated with the Saddam Hussein regime. And if you do, just interrupt me. Egypt, $33 million; Turkey, 

$710 million of illicit revenue because of this so-called trade protocol which was a direct buy-and-sell in violation of the sanctions 

regime imposed in 1991; Syria, $2.8 billion——

Ms. DIBBLE. Actually our figures are higher than that based on 

SOMO documents. The figures that we cited were $3.4 billion. 

Mr. DELAHUNT. So there is a disagreement between you and Mr. 

Duelfer there? 

Ms. DIBBLE. We are higher than he is. 

Mr. DELAHUNT. Jordan, $4.4 billion because of a side deal outside 

of the sanctions. Do you have any disagreement with any of those 

figures? No disagreement? 

Mr. Sparlin, let me note that I read your documents and there 

were some very remarkable narrations there. In a former life, I 

dealt with information, and I know that oftentimes it is 

uncorroborated and needs to be reviewed. But some of this is really 

startling. 

In your review, did any of your sources, upon scrutiny—was 

there found to be a lack of credibility? 

Mr. SPARLIN. I would say we did not have the opportunity to 

really scrutinize a lot of the information that was provided to us. 

We were there for a very short period of time, talked to a lot of 

people, looked at a number of records, and reported the information 

that was either told to us or was reflected in the records. Normally 

as a criminal investigator, we would go much further and look behind the records and the statements and find evidence to corroborate in more than one source whether it is accurate or not. And we 

did not have the opportunity to do that. 

Mr. DELAHUNT. You did not have that opportunity? Because one 

of the documents says the following about the illegal Iraqi oil trade 

with Egypt, and I found this really caught my attention: ‘‘The regime’’—meaning—and I am quoting from the IRS documents: ‘‘The 

regime established a program similar to that used in the central 

bank of Syria with Egyptian intelligence in 2002.’’

I mean, did Saddam Hussein’s regime have a deal with Egyptian 

intelligence? Do you feel confident in the validity and the authenticity of that statement that was part of your report? 

Mr. SPARLIN. I can only state that the four corners of the document can only speak for themselves. As far as any corroboration, 

I can’t verify that, no. 

Mr. DELAHUNT. That would be very disturbing. 

Mr. SPARLIN. Yes. 

Mr. DELAHUNT. And I would think, Mr. Chairman, that we would 

want to pursue that maybe through staff or refer it to the Department of State for its consideration. 

There are other documents, Mr. Sparlin, that seemed to indicate 

that Jordan worked closely with the Iraqi regime to undermine the 

sanctions also, both by buying oil and providing goods, including 

military hardware. One source—and again this comes from your 

documents—and I am quoting here: ‘‘King Hussein and King 

31

Abdullah knew of the deals. Some of the products were for the 

Iraqi military.’’

Then there is another source that says—and again I am quoting 

from your documents:

‘‘The King and Prime Minister would designate a company 

that would be used to facilitate the transfer of goods. This was 

a company that the King and Prime Minister created just for 

the purpose of conducting the exchange. When Iraq determined 

they wanted to purchase goods that were banned by the United 

Nations, Iraq would submit a list of goods to Jordan. The 

source said that this was a great deal for Jordan in that they 

were getting a huge volume of oil at a very cheap price, and, 

at the same time, Iraq was getting banned goods that they 

would not get otherwise.’’

This is very disturbing if it is accurate. Do you have an opinion 

as to the accuracy or the validity of that particular statement by 

this source? 

Mr. SPARLIN. Again, as an investigator, what that document reflects is information that was provided to us from the sources. 

Here, as in the other situations, we did not follow up; we did not 

have the resources to follow up and were not made aware of the 

information behind that to follow up upon. 

Mr. DELAHUNT. Well, let me ask Secretary Dibble: Have you had 

an opportunity or has someone in the State Department had an opportunity to review the work of the Criminal Investigation Division 

of the IRS? 

Ms. DIBBLE. I am not personally familiar with the work, so I 

really can’t comment. 

Mr. DELAHUNT. Are you hearing this information for the first 

time? 

Ms. DIBBLE. I haven’t seen it personally. I know that there are 

people in the State Department who have looked at this stuff in 

much more depth than I have. I am afraid I can’t comment on the 

specific allegations, on the veracity of them. 

Mr. DELAHUNT. Mr. Sparlin, is your team still operating? 

Mr. SPARLIN. We currently have just one person in Baghdad associated with the Embassy there. He is an attache with the Embassy in Baghdad. 

Mr. DELAHUNT. Well, I would hope that you could return to the 

former complement of some 17 investigators. 

Mr. SPARLIN. That was 17 over a period of time. And we are always working with our colleagues in State and the other agencies, 

Federal Government agencies, in evaluating the need for our resources. 

Mr. DELAHUNT. Because if this intelligence is correct, it is profoundly disturbing, and I would respectfully suggest, I believe, that 

we are compelled to pursue it so that we know who our friends are, 

who our allies are. 

Secretary Dibble, I think it was Mr. Comras who indicated that 

no one was pressing the frontline states about the enforcement—

I will put it this way—the lack of enforcement of the sanctions that 

were imposed by the Security Council. And it is my understanding 

that the first deal, call it trade protocol, was consummated between 

32

the Saddam Hussein regime and Jordan. Is that your understanding? 

Ms. DIBBLE. The trade protocol between Jordan and Iraq dates 

from 1983. 

Mr. DELAHUNT. 1983? 

Ms. DIBBLE. Yes. 

Mr. DELAHUNT. And in the aftermath of the Security Council 

sanctions, I would presume that that would obviate the 1983 trade 

protocol? 

Ms. DIBBLE. After the sanctions were put into place after the 

first Gulf War, three successive American Administrations took 

note of the notification of the Jordan-Iraq trade protocol to the 

U.N. 

Mr. DELAHUNT. Can you tell me what ‘‘taking note’’ means? 

Ms. DIBBLE. We were certainly aware of, if not all the details, the 

broad-brush aspects. Jordan, being a small country strategically located in the Middle East without its own petroleum resources, relied on trade with Iraq to supply its infrastructure. 

Mr. DELAHUNT. So what we are saying here is that we had supported, in the Security Council, a regime of sanctions, and we voted 

for it, obviously. 

Ms. DIBBLE. Yes. 

Mr. DELAHUNT. And we expected and anticipated that every nation would abide by that sanction regime; is that correct? 

Ms. DIBBLE. Yes. 

Mr. DELAHUNT. But Jordan did not, so we took note of it. 

Ms. DIBBLE. That is correct. 

Mr. DELAHUNT. You know, you mentioned—are we going to have 

a second round, Mr. Chairman? 

Mr. ROHRABACHER. Yes. 

Mr. DELAHUNT. Great. 

Mr. ROHRABACHER. If the witnesses can stay, we will have a second round. 

Mr. DELAHUNT. I think it is important that they do stay. 

Mr. ROHRABACHER. The Chairman is trying to be generous with 

time. 

Mr. Ackerman. 

Mr. ACKERMAN. The Chairman is indeed very generous and we 

noted that you haven’t run the clock. Appreciate it. 

I want to thank all three of our witnesses for the great job that 

they have done and continue to do, and for sharing with us so that 

we have a better understanding of what went on. I think it is more 

important, having learned somewhat of what had gone on, how we 

apply that to the future and what it means from a policy perspective, looking on into the future. And in doing that, I share the concern that has been raised by Mr. Delahunt. The real question is, 

we had a policy. Others did not conform to the policy. We are having a hearing blaming them for not conforming to the policy. My 

greater concern is why did we not care about our policy? Why did 

we choose to ignore it? Why, under successive Administrations 

since President Reagan, have we been ignoring our own policy? 

And why, suddenly, does it become so important to focus on one of 

several countries that violated our policy? 

33

The greater question is, if we had a policy, why did we not enforce it? If it was not important to us, why should we care that 

somebody else did not enforce it? We should care about all of the 

above. But specifically what we do have control over is not necessarily somebody else’s violations but our own nonchalant or deliberate decision not to enforce that. 

My understanding is that the prime beneficiary of the violations 

of the countries that we have mentioned was not Syria but Jordan; 

is that correct? It is an easy question. 

Mr. COMRAS. Mr. Chairman——

Mr. ACKERMAN. Mr. Comras? 

Mr. COMRAS. A little historical perspective, if I can, on the Jordan problem. Jordan was caught in an awkward situation at the 

time of the Gulf War. Their reliance on Iraq was great and there 

was a certain amount of trade that we all recognized had to continue. We were interested in keeping out from that trade those 

items that were particularly sensitive. And so we gained Jordan’s 

accord to place in Aqabah inspectors who were able to filter out the 

goods that were coming through that port and heading for Jordan 

and those that might eventually end up in Iraq. 

The problem was understood with respect to Jordan. There were 

some control aspects to it as we tried to contain it in a reasonable 

box. The same was true to a certain degree with Turkey, where 

most of the goods involved the transport of finished product petroleum that was moved through the Kurds’ intermediaries into Turkey in a local trade that provided local support for communities 

that had no other local support. 

The one big hole, however, was still Syria, where the goods came 

in and moved through where the oil was not just for the local economy, it was for export, and where Syria served as a major conduit 

into Iraq for which there was no real chance to filter, to look, or 

to see. And that always put Syria on the top of our list of concern 

with respect to the sanctions violations. Thank you. 

Mr. ACKERMAN. I appreciate that historical perspective. My question remains: The chief beneficiary, from a financial point of view, 

of all of these violations, regardless of who we were concerned or 

not concerned about, was Jordan. Next was Syria, and third was 

Turkey. Is that accurate? 

Ms. DIBBLE. If you are——

Mr. ACKERMAN. Add the dollars. 

Ms. DIBBLE. The numbers that we have for the trade protocols—

I mean if you are looking at the same time period, if you are look 

at 2000 to 2003, it was Syria, then Jordan, then Turkey, then 

Egypt. The protocol with Jordan dates from 1983, so it was put in 

place 17 years before the protocol with Syria. 

Mr. ACKERMAN. Because Jordan was benefiting for a longer period of time in greater numbers. And I appreciate the historical 

perspective and the commentary that you made, as well as Mr. 

Comras, and comments that were made before. Jordan has no oil. 

Their economy was heavily, heavily, heavily subsidized by the fact 

that Saddam Hussein gave them very, very, very cheap oil. We 

took note of that and, because of reasons that many deem appropriate, we chose to look the other way. But the fact remains that 

Jordan was a main transit place for supplies and trucks going in 

34

and out, many of which were never checked, that went through 

Jordan to Iraq and many trucks that came out. But Jordan was the 

chief beneficiary. 

Why, suddenly, with historical retrospect, do we decide to just 

focus on Syria? And I know there are good guys and there are bad 

guys and guys in between in various degrees, and we view Jordan 

as a good guy and Syria as a bad guy, and quite appropriately at 

this point. But what about United States policy? I was privileged, 

along with Representative Peter King of New York, to have been 

the Representatives of the Congress during the same year as delegates to the United Nations; and we, together with Congressman 

Issa, went up when President Bush made his first speech to the 

U.N., to the General Assembly, were briefed by Ambassador 

Negroponte, and met with a delegation that provided a luncheon 

for us. And when we were asking questions about this very subject, 

they were laughing. They said, ‘‘We do not call it Oil-for-Food, we 

call it Oil-for-Stuff,’’ and they all snickered. It seemed that everybody knew what was going on, and, when pressed, they said if you 

do not care, why should we? And that is my policy question. Is 

there an answer? 

Ms. DIBBLE. I think in partial answer to your question, the reason we are concerned about Syria now is the current situation, 

what is happening in Syria, what is happening along the border 

with Iraq. We do not have the same problems with Jordan or with 

Turkey in terms of support for the insurgency, support for former 

regime elements being harbored there. If you are talking about our 

current policy concerns, Syria is way up there. 

Mr. ACKERMAN. Yeah, but the point I made in my opening statement, if the Chairman would wait just another moment, is that we 

are using this policy that we chose to ignore to take a retrospective 

look at something based on the policy. Now, if you put a policy in 

place and you care about the policy, you have to enforce the policy. 

I mean, you cannot say that certain criminal elements are going for 

the economy so we won’t enforce the RICO (Racketeer Influenced 

and Corrupt Organizations) statutes against them, as opposed to 

others that are not good for the economy. It does not make any 

sense. 

If we are concerned about Syria today because of these reasons, 

I would suggest, Mr. Chairman, that we hold hearings on those 

things that we are concerned about; I think not sticking to our policy is a very important issue for us. 

Mr. ROHRABACHER. Thank you very much, Mr. Ackerman. 

We will have a very quick second round. Let us note that this 

policy was instituted during the last Administration with the full 

support of Madeleine Albright and the President. 

Mr. ACKERMAN. Will the Chairman yield on that point? 

Mr. ROHRABACHER. No, because you will have your shot in 1 

minute. Let me finish this particular point. Maybe our involvement 

in going in and kicking the Iraqi troops out of Kuwait was a decision we should or should not have made. But once it was made, we 

realized that the regime of Saddam Hussein was dedicated to 

harming the United States of America. Saddam Hussein, had he 

had his chance, would have harmed and did things not only to 

35

murder his own people by the hundreds of thousands, but he also 

had a strategy policy that made him an enemy of our country. 

In dealing with this enemy, the Chairman finds no reason to believe that we could not have a flexible policy that, for example, permitted the Jordanians, the Turks, and the Egyptians a little bit of 

leeway in the implementation of this policy so that those countries’ 

economies would not collapse and that radical elements in those societies would not come to the fore. That makes sense to me. Perhaps that is what Bill Clinton and Madeleine Albright had in mind 

when they made that policy decision; that these differentiations 

would be made. 

Then why is Syria different than Jordan, Turkey, and Egypt? I 

do not find any evidence that the Defense Minister in any of those 

countries was getting a kickback from military sales to Iraq. In 

fact, as things have worked out, perhaps it was a good idea to permit these countries a bit of leeway in following these regulations 

since the rules that were laid down did hurt Saddam Hussein. To 

permit these particular countries an avenue in which they would 

not create chaos within those societies was probably a good idea. 

Does someone have to be totally consistent in implementing a 

policy or strategy once it is stated to the public? I don’t think that 

that consistency is required of people who want to really see the 

outcome. I think if this same sort of demand for consistency was 

made during the Second World War, there might have been some 

serious problems with a lot of people losing their lives who need 

not have lost their lives. 

Unlike Egypt, Turkey, and Jordan, Syria was at that time involved with not only providing weapons to Saddam Hussein’s regime as a direct result of these exchanges, but also involved with 

supporting terrorist organizations. We will see whether or not 

Syria has turned over a new leaf or wishes to take a new direction. 

We will see by their actions. We will see if they return the $200 

million in Iraqi funds that now should go to Iraq, to the people of 

Iraq, rather than being kept in banks in Syria. But I would just 

suggest that we have had requests for hearings on this oil program, 

as you have asked about, but not just the Oil-for-Food Program, 

but the entire oil embargo. 

Let us mention also that during this oil embargo period, I 

heard—and I am not sure if my colleagues were involved in this—

over and over again from certain elements in our society that there 

are millions of Iraqi children dying and it is our fault. I remember 

that. It is our fault. 

Well, now we know how false that charge was, because Jordan, 

Iraq, Turkey, Egypt, and Syria were providing plenty of resources 

for Saddam Hussein, not to mention that the Oil-for-Food Program 

itself was providing Saddam Hussein with enormous resources to 

pay for the medicine, food, and humanitarian supplies needed for 

his people. However, that money was obviously spent to line the 

pockets of the clique who surrounded Saddam Hussein and also to 

provide weapons. 

We have heard some very, I would say, disturbing testimony 

today that perhaps some of that money, which you folks are the 

specialists in—I am very pleased with your testimony and grateful 

that you have illuminated it for us—still may be doing great evil 

36

in the world and great harm to the people of the United States, 

putting our own people at risk, and also providing funds that would 

end up exploding in the streets of Baghdad and murdering countless numbers of Iraqi civilians, which is consistent with those people who supported Saddam Hussein in the first place, murdering 

hundreds of thousands of their own people in cold blood when Saddam Hussein was in power. 

With that said, I am going to thank the panel, and I will give 

my colleagues a chance to make a last statement or last question. 

Mr. ACKERMAN. Thank you, Mr. Chairman. 

Mr. ROHRABACHER. Could we start with Mr. Delahunt first? 

Mr. ACKERMAN. Any way you would like to proceed. 

Mr. DELAHUNT. Yes, I thank my friend. And I can assure him 

that I never felt that it was the responsibility of the American people or the American Government for the starving children in Iraq. 

That clearly was the responsibility of Saddam Hussein. So I want 

to make sure that is made a matter of record, at least from this 

particular Member of Congress. 

I just would note that I can understand the need for flexibility. 

And I suggest maybe we have hearings on Syria, the relationship 

between Syria and the United States and the problems that currently exist between the two countries. That is fine. But just to select Syria out on this particular occasion opens us to charges of 

being selective and therefore hypocritical, because our pals and our 

allies are very much implicated in this issue. The so-called trade 

protocols, the deals. Jordan was into it up to their hips. 

If you accept the information and the raw intelligence that was 

provided by Mr. Sparlin and his teams, ‘‘King Hussein and King 

Abdullah knew of the deals’’—this is quoting from the IRS documents—‘‘and some of the products were for the Iraqi military.’’

And then we find another excerpt that says the regime, meaning 

Saddam Hussein, ‘‘established a program similar to that used in 

the central bank of Syria with Egyptian intelligence.’’

There are problems everywhere. And I think we should be equal 

opportunity critics, if you will. But we also have to accept our own 

responsibility. 

I think it was you, Mr. Comras, who said nobody was pressing 

the frontline states in terms of compliance with these sanctions. 

And by the way, my friend, this program was not initiated under 

the Clinton Administration, it was initiated under the first Bush 

Administration back in 1991. And I am willing to say that there 

is a responsibility on the part of successive Administrations, both 

Democratic and Republican. But let’s just be honest about it. We 

did not do anything. 

And I appreciate the need for flexibility. I know Jordan needed 

that oil, and you are right, Madam Secretary. But the reality is 

that we fought a war to free Saudi Arabia and Kuwait. They very 

well could have provided the oil for Jordan and met all of its energy needs and we did not have to do side deals. How much money 

did we spend? How many troops did we have in that first Gulf 

War? We did not have to go on and turn an eye, Mr. Chairman. 

The Saudis should have stood up and the Kuwaitis should have 

stood up and provided the energy needs that the Syrians, Jordanians, Turks, and Egyptians needed. 

37

So I concur with my friend that if there is a policy and we find 

ourselves honoring it in the breach, what message does that send 

to the rest of the world? And this hearing today and the issues that 

we are discussing here today really have nothing to do with the 

Oil-for-Food Program, because these side deals far exceeded the 

numbers—$8 billion according to Duefler—that was illegally put 

into the pockets of the Saddam Hussein regime. 

Now, I am going to conclude there. 

Mr. ROHRABACHER. I am not the only passionate one on this 

panel. 

Mr. Ackerman. 

Mr. ACKERMAN. Thank you, and thank everybody for their passion. It is an important issue. Sometimes you get a two-fer. If you 

do not like Syria and you don’t like the U.N., you have a hearing 

and beat up on both of them not having nothing to do with anything. That is reasonable. 

But I agree with Mr. Delahunt. And I will say it an umpteenth 

time. We should be looking forward to what our policy has to be, 

and why. I find it interesting that—well, I have a quick question 

that I did want to ask of Mr. Sparlin first. 

I was intrigued when you were talking about the Rafidain Bank 

and said that you had discovered that there were tie-ins with the 

suicide bombers in the Palestinian situation, but basically that was 

not within your portfolio, you did not pursue that. Is anybody in 

our Administration pursuing that finding? 

Mr. COMRAS. I am sorry; I believe that it was my comment. 

Mr. ACKERMAN. Mr. Comras, I’m sorry. 

Mr. COMRAS. I don’t know. Again, this was information that we 

received as monitors for the Security Council of the al-Qaeda and 

Taliban sanctions. 

Mr. ACKERMAN. So in searching and investigating the al-Qaeda 

stuff, it was discovered that there was, through the Rafidain Bank, 

money——

Mr. COMRAS. The Rafidain Bank was providing money for suicide 

bombers. 

Mr. ACKERMAN. And was that money for the suicide bombers followed through by anyone in the Administration? 

Mr. COMRAS. I can’t answer that. I don’t know. 

Mr. ACKERMAN. I would suggest, Mr. Chairman, that we jointly 

look into that. 

Mr. ROHRABACHER. What year was that? 

Mr. COMRAS. The information we received was in the 2002–2004 

time frame, but it related back to practices in the 2000–2001 time 

frame. 

Mr. ACKERMAN. Thank you. I think we have an obligation to follow through on that. 

Let me say with regard to the discussion that we have been having here among ourselves, it is interesting that my good friend, the 

Chairman, continuously seeks to define reasons to blame the Clinton Administration or former President Clinton and former Secretary Albright for all of the ills of the past and that this took place 

during their watch, and then he goes on to say, ‘‘Well, we have 

some good friends and we have to be flexible.’’ I don’t know if he 

is then saying that the Clinton policy was okay. 

38

But as Mr. Delahunt points out, this did not start during the 

Clinton Administration. It actually started before 1991. It was actually in August 1990 that the regime, under the Security Council, 

took place, and that was in the Bush I Administration and not 

Clinton. 

But I do not think it really matters because if the object of the 

hearing is to find who was at fault, then I don’t think we are doing 

ourselves a favor. What we must be doing in this Committee—and 

I fault this Committee—is we are not looking from a policy perspective with the historical perspective that is absolutely essential, crucial, critical, essential to how we get to where we want to go, to 

use that as a building block, and we are not moving forward outside of the blame game. 

Concerning the existing U.S. policy and whether we should have 

been flexible or could have been flexible, I can only draw on life experience. And this old social studies teacher would have had a very 

hard time in class finding four kids that were cheating on the exam 

and saying the good kids that were cheating were okay and only 

punish the bad kid that was cheating. I don’t know what message 

that would send to those people who wanted to be the teacher’s pet 

and to justify the whole thing by saying, ‘‘Well, the good kids would 

affect the future, they will have to go to college and get good jobs, 

and the bad kids are going to wind up as bad kids anyway.’’ I don’t 

think that it is wise to make exceptions like that and then retrospectively try to figure out why we did it. I think we know why we 

did it. 

I don’t know why we are doing what we are doing today. And I 

do thank the Chairman. The history that we have learned is very 

important. And I suggest we move forward from there and I thank 

the Chairman. 

Mr. ROHRABACHER. The last words are forward here. We try to 

be forward-looking as well as backward-looking. As I noted in the 

beginning, Ms. Dibble has spent a lifetime on the front lines in 

terms of foreign service. This Administration, of course, was criticized about not having as many alliances with various countries as 

we would hope to have had when entering such a conflict with 

Iraq, knowing that Saddam Hussein and his regime were an enemy 

of the United States, and knowing that they hated us for kicking 

them out of Kuwait. 

We need allies. In the real world of politics, geopolitics, it is not 

at all like it was with those kids cheating on the test. At times during World War II, we had to make an alliance with Joseph Stalin 

in order to defeat Adolf Hitler. That is what happens in real politics when you are faced with many thousands of lives being put on 

the line. I can only say that I think that the public needs to know 

about it. I think that the public needs to understand and look at 

these issues that have been presented to us today. 

I personally have no problem with the effort made to make sure 

that Jordan, Turkey, and Egypt were not sucked into sort of a positive relationship with Saddam Hussein. I do not have any problem 

with that. Especially knowing that our troops were eventually 

going to go into that country. We may not have acted totally consistently in this, but the public needs to know about your perspectives and decide for themselves. 

39

This has been a good hearing. I want to congratulate each of you 

for providing a very unique perspective to the whole issue. Each 

and every one of you really gave us an understanding of the depth 

of this issue and what the impact is today of those decisions that 

we made yesterday. 

Let us hope that as we look forward, Syria has a chance to 

change its policies, as other governments have changed their policies, and just say, Hey, we are going to go on a new path. To do 

that, one has to be truthful about one’s past. And I think that there 

has been a lot of good criticism that has been brought up today 

that Syria should account for and should take into consideration. 

Maybe they want to say now is the time to just say that was 

wrong, and we are going to go do something better in the future. 

If that happens we should all applaud that. But we have to see 

deeds. The first deed, as you said, is let’s return the money to the 

Iraqi people that legitimately belongs to them—that is a $200 million deed that would show some sincerity. 

Thank you all very much. I would like to say that this Committee is about to adjourn. Any Member of this Committee who 

would like to submit questions for our panel should do so within 

2 weeks and we would hope you would answer those questions in 

writing. With that said, we are adjourned. 

[Whereupon, at 12:22 p.m., the Subcommittees were adjourned.]

Æ