Testimony 

Before the Committee on Foreign 

Relations, U.S. Senate

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 9:30 a.m. EDT 

Wednesday, April 7, 2004 UNITED NATIONS 

Observations on the Oil for 

Food Program 

Statement of Joseph A. Christoff, Director 

International Affairs and Trade 

GAO-04-651T 
www.gao.gov/cgi-bin/getrpt?GAO-04-651T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Joseph 

Christoff at (202) 512-8979 or 

christoffj@gao.gov. 

Highlights of GAO-04-651T, a testimony 

before the Committee on Foreign 

Relations 

Wednesday, April 7, 2004

UNITED NATIONS

Observations on the Oil for Food 

Program 

GAO estimates that from 1997- 2002, the former Iraqi regime attained $10.1 

billion in illegal revenues from the Oil for Food program, including $5.7 

billion in oil smuggled out of Iraq and $4.4 billion through surcharges on oil 

sales and illicit commissions from suppliers exporting goods to Iraq. This 

estimate includes oil revenue and contract amounts for 2002, updated letters 

of credit from prior years, and newer estimates of illicit commissions from 

commodity suppliers. 

Both the U.N. Secretary General, through the Office of the Iraq Program 

(OIP) and the Security Council, through its sanctions committee for Iraq, 

were responsible for overseeing the Oil for Food Program. However, the 

Iraq government negotiated contracts directly with purchasers of Iraqi oil 

and suppliers of commodities, which may have been one important factor 

that allowed Iraq to levy illegal surcharges and commissions. While OIP was 

responsible for examining Iraqi contracts for price and value, it is unclear 

how it performed this function. The sanctions committee was responsible 

for monitoring oil smuggling, screening contracts for items that could have 

military uses, and approving oil and commodity contracts. While the 

sanctions committee responded to illegal surcharges on oil, it is unclear 

what actions it took to respond to illicit commissions on commodity 

contracts. 

OIP transferred 3,059 Oil for Food contracts—with pending shipments 

valued at $6.2 billion—to the CPA on November 22, 2003. However, the CPA 

stated that it has not received all the original contracts, amendments, and 

letters of credit it needs to manage the program. These problems, along with 

inadequate CPA staffing during the transfer, hampered the efforts of CPA’s 

Oil for Food coordination center in Baghdad to ensure continued delivery of 

commodities. Poor planning, coordination, and the security environment in 

Iraq continue to affect the execution of these contracts. 

Inadequate oversight and corruption in the Oil for Food program raise 

concerns about the Iraqi government’s ability to import and distribute Oil for 

Food commodities and manage at least $32 billion in expected donor 

reconstruction funds. The CPA has taken steps, such as appointing 

inspectors general, to build internal control and accountability measures at 

Iraq’s ministries. The CPA and the World Food Program (WFP) are also 

training ministry staff to help them assume responsibility for Oil for Food 

contracts in July 2004. The new government will have to balance the reform 

of its costly food subsidy program with the need to maintain food stability 

and protect the poorest populations. 

The Oil for Food program was 

established by the United Nations 

and Iraq in 1996 to address 

concerns about the humanitarian 

situation after international 

sanctions were imposed in 1990. 

The program allowed the Iraqi 

government to use the proceeds of 

its oil sales to pay for food, 

medicine, and infrastructure 

maintenance. The program appears 

to have helped the Iraqi people. 

From 1996 through 2001, the 

average daily food intake increased 

from 1,300 to 2,300 calories. From 

1997-2002, Iraq sold more than $67 

billion of oil through the program 

and issued $38 billion in letters of 

credit to purchase commodities. 

GAO (1) reports on its estimates of 

the revenue diverted from the 

program, (2) provides preliminary 

observations on the program’s 

administration, (3) describes some 

challenges in its transfer to the 

CPA, and (4) discusses the 

challenges Iraq faces as it assumes 

program responsibility. 
Page 1 GAO-04-651T 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss GAO’s review of the United 

Nations (U.N.) Oil for Food program. 

In 1996, the United Nations and Iraq established the Oil for Food program 

to address growing concerns about the humanitarian situation after 

international sanctions were imposed in 1990. The program allowed the 

Iraqi government to use the proceeds of its oil sales to pay for food, 

medicine, and infrastructure maintenance. 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.1

Today, we will present our findings and observations on the operation of 

the Oil for Food program and its transfer to the Coalition Provisional 

Authority (CPA). Specifically, we will (1) report on our estimates of the 

revenue diverted from the program by the former Iraqi regime; (2) provide 

some preliminary observations on the administration of the program; (3) 

describe the challenges the CPA faced when it assumed responsibility for 

the program; and (4) discuss the challenges Iraq faces as it assumes 

responsibility for the program. 

To address these objectives, we reviewed documents and statements from 

(1) the United Nations on its management and oversight responsibilities 

for the Oil for Food program; (2) the CPA, the Departments of Defense and 

State, and the United Nations and its World Food Program (WFP) on the 

transfer of the program to the CPA and its implementation; and (3) from 

the World Bank and Iraq’s 2004 budget regarding the effect of food 

subsidies on the Iraqi economy. We met with U.N. officials immediately 

following the transfer of the program to the CPA in November 2003 and 

with numerous U.S. officials representing the CPA, the Departments of 

Defense and State, and the U.S. Agency for International Development to 

discuss the program’s transfer and ongoing management by the CPA. Our 

review is ongoing because we have not yet received all the CPA and Iraqi 

ministry documentation that we have requested from the CPA and the 

Department of State. We have also requested certain U.N. documents, 

including internal audits, to determine the use of Oil for Food funds prior 

to the transfer to the CPA and the current disposition of funds. We 

assessed the reliability of the data on the number of contracts reviewed for 

 1

All references to Oil for Food estimates are in 2003 constant U.S. dollars. 
Page 2 GAO-04-651T 

priority by the United Nations, the CPA, and Iraqi ministries and those 

transferred to the CPA November 2003 by corroborating OIP information 

with CPA data. We were unable to assess the reliability of the dollar 

amounts of contracts reviewed and pending shipment because we did not 

have access to the information that would have allowed us to confirm the 

dollar amounts reviewed and transferred. 

We conducted our review from November 2003 through April 2004 in 

accordance with generally accepted government auditing standards. 

• From 1997 through 2002, we estimate that the former Iraqi regime 

acquired $10.1 billion in illegal revenues related to the Oil for Food 

program—$5.7 billion in oil smuggled out of Iraq and $4.4 billion in 

surcharges on oil sales and illicit charges from suppliers exporting 

goods to Iraq. This estimate is higher than our May 2002 estimate of 

$6.6 billion because it includes (1) oil revenue and contract amounts 

for 2002, (2) updated letters of credit from prior years, and (3) newer 

estimates of illicit commissions from commodity suppliers. 

• Both the U.N. Secretary General, through the Office of the Iraq 

Program (OIP) and the Security Council, through its sanctions 

committee for Iraq, were responsible for overseeing the Oil for Food 

Program. However, the Iraq government negotiated contracts directly 

with purchasers of Iraqi oil and suppliers of commodities, which may 

have been one important factor in allowing Iraq to levy illegal 

surcharges and commissions. While OIP was responsible for examining 

Iraqi contracts for price and value, it is unclear how it performed this 

function. The sanctions committee was responsible for monitoring oil 

smuggling, screening contracts for items that could have military uses, 

and approving oil and commodity contracts. While the sanctions 

committee responded to illegal surcharges on oil, it is unclear what 

actions it took to respond to illicit commissions on commodity 

contracts. 

• OIP turned over responsibility for 3,059 Oil for Food contracts—with 

pending shipments valued at $6.2 billion—to the CPA on November 22, 

2003. However, the information the United Nations supplied to the CPA 

on the renegotiated contracts contained database errors and did not 

include all contracts, amendments, and letters of credit associated with 

the 3,000 contracts. These problems, along with inadequate CPA 

staffing at the time of the transfer, hampered efforts by the CPA’s Oil 

for Food coordination center in Baghdad to ensure that commodities 

continued to be delivered. Also, the execution of these contracts 

Summary 
Page 3 GAO-04-651T 

continues to be affected by poor planning, coordination, and security. 

• The history of inadequate oversight and corruption in the Oil for Food 

program raises concerns about the Iraqi government’s ability to 

manage the remaining Oil for Food commodities and about $32 billion 

in expected donor reconstruction funds. The CPA has taken steps, such 

as appointing inspectors general, to build internal controls and 

accountability measures in Iraq’s ministries. The CPA and the World 

Food Program (WFP) are also training ministry staff on procurement 

and distribution functions to help them fully assume responsibility for 

remaining contracts and a continued food distribution system in July 

2004. In addition, the new government will have to balance the need to 

reform a costly food subsidy program with the need to maintain food 

stability and protect the poorest populations. 

In August 1990, Iraq invaded Kuwait, and the United Nations imposed 

sanctions against Iraq. Security Council Resolution 661 of 1990 prohibited 

all nations from buying and selling Iraqi commodities, except for food and 

medicine. Security Council Resolution 661 also prohibited all nations from 

exporting weapons or military equipment to Iraq and established a 

sanctions committee to monitor compliance and progress in implementing 

the sanctions. The members of the sanctions committee were members of 

the Security Council. Subsequent Security Council resolutions specifically 

prohibited nations from exporting to Iraq items that could be used to build 

chemical, biological, or nuclear weapons. In 1991, the Security Council 

offered to let Iraq sell oil under a U.N. program to meet its peoples’ basic 

needs. The Iraqi government rejected the offer, and over the next 5 years, 

the United Nations reported food shortages and a general deterioration in 

social services. 

In December 1996, the United Nations and Iraq agreed on the Oil for Food 

program, which permitted Iraq to sell up to $1 billion worth of oil every 90 

days to pay for food, medicine, and humanitarian goods. Subsequent U.N. 

resolutions increased the amount of oil that could be sold and expanded 

the humanitarian goods that could be imported. In 1999, the Security 

Council removed all restrictions on the amount of oil Iraq could sell to 

purchase civilian goods. 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. In May 2003, U.N. resolution 1483 

requested the U.N. Secretary General to transfer the Oil for Food program 

to the CPA by November 2003. 

Background 
Page 4 GAO-04-651T 

Despite concerns that sanctions may have worsened the humanitarian 

situation, the Oil for Food program appears to have helped the Iraqi 

people. According to the United Nations, the average daily food intake 

increased from around 1,275 calories per person per day in 1996 to about 

2,229 calories at the end of 2001. In February 2002, the United Nations 

reported that the Oil for Food program had considerable success in 

several sectors such as agriculture, food, health, and nutrition by arresting 

the decline in living conditions and improving the nutritional status of the 

average Iraqi citizen. 

The Public Distribution System run by Iraq’s Ministry of Trade is the food 

portion of the Oil for Food program. The system distributes a monthly 

“food basket” that normally consists of a dozen items2

 to all Iraqis. About 

60 percent of Iraqis rely on this basket as their main source of food. 

We estimate that, from 1997 through 2002, the former Iraqi regime 

acquired $10.1 billion in illegal revenues related to the Oil for Food 

program—$5.7 billion through oil smuggling and $4.4 billion through 

surcharges against oil sales and illicit commissions from commodity 

suppliers. This estimate is higher than the $6.6 billion in illegal revenues 

we reported in May 2002.3

 We updated our estimate to include (1) oil 

revenue and contract amounts for 2002, (2) updated letters of credit from 

prior years, and (3) newer estimates of illicit commissions from 

commodity suppliers. 

Oil was smuggled out through several routes, according to U.S. 

government officials and oil industry experts. Oil entered Syria by 

pipeline, crossed the borders of Jordan and Turkey by truck, and was 

smuggled through the Persian Gulf by ship. In addition to revenues from 

oil smuggling, the Iraqi government levied surcharges against oil 

purchasers and commissions against commodity suppliers participating in 

the Oil for Food program. According to some Security Council members, 

 2

Wheat flour, rice, vegetable ghee (semifluid clarified butter used for cooking), pulses 

(edible seeds of various leguminous crops, such as peas, beans, or lentils), sugar, tea, salt, 

milk, infant formula, weaning cereal, soap, and detergent. 

3

U.S. General Accounting Office, Weapons of Mass Destruction: U.N. Confronts 

Significant Challenges in implementing Sanctions Against Iraq, GAO-02-625

(Washington, D.C.: May 23, 2002). 

Former Iraqi Regime 

Diverted an Estimated 

$10.1 Billion from the 

Oil for Food Program 
Page 5 GAO-04-651T 

the surcharge was up to 50 cents per barrel of oil and the commission was 

5 to 15 percent of the commodity contract. 

In our 2002 report, we estimated that the Iraqi regime received a 5-percent 

illicit commission on commodity contracts. However, a September 2003 

Department of Defense review found that at least 48 percent of 759 Oil for 

Food contracts that it reviewed were overpriced by an average of 21 

percent.4

 Defense officials found 5 contracts that included “after-sales 

service charges” of between 10 and 20 percent. In addition, interviews by 

U.S. investigators with high-ranking Iraq regime officials, including the 

former oil and finance ministers, confirmed that the former regime 

received a 10-percent commission from commodity suppliers. 

Both OIP and the sanctions committee were responsible for overseeing the 

Oil for Food Program. However, the Iraqi government negotiated contracts 

directly with purchasers of Iraqi oil and suppliers of commodities. While 

OIP was to examine each contract for price and value, it is unclear how it 

performed this function. The sanctions committee was responsible for 

monitoring oil smuggling, screening contracts for items that could have 

military uses, and approving oil and commodity contracts. The sanctions 

committee responded to illegal surcharges on oil, but it is unclear what 

actions it took to respond to commissions on commodity contracts. 

U.N. Security Council resolutions and procedures recognized the 

sovereignty of Iraq and gave the Iraqi government authority to negotiate 

contracts and decide on contractors. Security Council resolution 986 of 

1995 authorized states to import petroleum products from Iraq, subject to 

the Iraqi government’s endorsement of transactions. Resolution 986 also 

stated that each export of goods would be at the request of the 

government of Iraq. Security Council procedures for implementing 

resolution 986 further stated that the Iraqi government or the United 

Nations Inter-Agency Humanitarian Program would contract directly with 

suppliers and conclude the appropriate contractual arrangements. Iraqi 

 4

The Defense Contract Audit Agency and the Defense Contract Management Agency, 

Report on the Pricing Evaluation of Contracts Awarded under the Iraq Oil for Food 

Program (Washington, D.C.: Sept. 12, 2003). 

United Nations and 

Security Council Had 

Responsibility for 

Oversight of Program, 

but Iraq Contracted 

Directly with 

Purchasers and 

Suppliers 

Iraq Negotiated Directly 

with Oil Purchasers and 

Suppliers 
Page 6 GAO-04-651T 

control over contract negotiations may have been one important factor in 

allowing Iraq to levy illegal surcharges and commissions. Appendix I 

contains a chronology of major events related to sanctions against Iraq 

and the administration of the Oil for Food program. 

OIP administered the Oil for Food program from December 1996 to 

November 2003. As provided in Security Council resolution 986 of 1995 

and a memorandum of understanding between the United Nations and the 

Iraqi government, OIP was responsible for monitoring the sale of Iraq’s oil, 

monitoring Iraq’s purchase of commodities and the delivery of goods, and 

accounting for the program’s finances. The United Nations received 3 

percent of Iraq’s oil export proceeds for its administrative and operational 

costs, which included the cost of U.N. weapons inspections. 

The sanctions committee’s procedures for implementing resolution 986 

stated that U.N. independent inspection agents were responsible for 

monitoring the quality and quantity of oil being shipped and were 

authorized to stop shipments if they found irregularities. To do this, OIP 

employed 14 contract workers to monitor Iraqi oil sales at 3 exit points in 

Iraq. However, the Iraqi government bypassed the official exit points by 

smuggling oil through an illegal Syrian pipeline and by trucks through 

Jordan and Turkey. According to OIP, member states were responsible for 

ensuring that their nationals and corporations complied with the 

sanctions. 

OIP was also responsible for monitoring Iraq’s purchase of commodities 

and the delivery of goods. Security Council Resolution 986, paragraph 

8a(ii) required Iraq to submit a plan, approved by the Secretary General, to 

ensure equitable distribution of Iraq’s commodity purchases. The initial 

distribution plans focused on food and medicines while subsequent plans 

were expansive and covered 24 economic sectors, including electricity, oil, 

and telecommunications. 

The sanction committee’s procedures for implementing Security Council 

resolution 986 stated that experts in the Secretariat were to examine each 

proposed Iraqi commodity contract, in particular the details of price and 

value, and to determine whether the contract items were on the 

distribution plan. It is unclear whether the office performed this function. 

OIP officials told the Defense Contract Audit Agency they performed very 

limited, if any, pricing review. They stated that no U.N. resolution tasked 

them with assessing the price reasonableness of the contracts and no 

OIP Was Responsible for 

Key Oversight Aspects of 

the Program 
Page 7 GAO-04-651T 

contracts were rejected solely on the basis of price. 

The sanction committee’s procedures for implementing resolution 986 

state that independent inspection agents will confirm the arrival of 

supplies in Iraq. OIP deployed about 78 U.N. contract monitors to verify 

shipments and authenticate the supplies for payment. OIP employees were 

able to visually inspect 7 to 10 percent of the approved deliveries. 

Security Council resolution 986 also requested the Secretary General to 

establish an escrow account for the Oil for Food Program, and to appoint 

independent and certified public accountants to audit the account. In this 

regard, the Secretary General established an escrow account at BNP 

Paribas into which Iraqi oil revenues were deposited and letters of credit 

were issued to suppliers having approved contracts. The U.N. Board of 

Audit, a body of external public auditors, audited the account. According 

to OIP, there were also numerous internal audits of the program. We are 

trying to obtain these audits. 

The sanctions committee was responsible for three key elements of the Oil 

for Food Program: (1) monitoring implementation of the sanctions, (2) 

screening contracts to prevent the purchase of items that could have 

military uses, and (3) approving Iraq’s oil and commodity contracts. 

U.N. Security Council resolution 661 of 1990 directs all states to prevent 

Iraq from exporting petroleum products into their territories. Paragraph 6 

of Resolution 661 establishes a sanctions committee to report to the 

Security Council on states’ compliance with the sanctions and recommend 

actions regarding effective implementation. As early as June 1996, the 

Maritime Interception Force, a naval force of coalition partners including 

the United States and Great Britain, informed the sanctions committee 

that oil was being smuggled out of Iraq through Iranian territorial waters. 

In December 1996, Iran acknowledged the smuggling and reported that it 

had taken action. In October 1997, the sanctions committee was again 

informed about smuggling through Iranian waters. According to multiple 

sources, oil smuggling also occurred through Jordan, Turkey, Syria, and 

the Gulf. Smuggling was a major source of illicit revenue for the former 

Iraqi regime through 2002. It is unclear what recommended actions the 

sanctions committee made to the Security Council to address the 

continued smuggling. 

A primary function of the members of the sanctions committee was to 

review and approve contracts for items that could be used for military 

The Sanctions Committee 

Had a Key Role in 

Enforcing Sanctions and 

Approving Contracts 
Page 8 GAO-04-651T 

purposes. For example, the United States conducted the most thorough 

review; about 60 U.S. government technical experts assessed each item in 

a contract to determine its potential military application. According to 

U.N. Secretariat data in 2002, the United States was responsible for about 

90 percent of the holds placed on goods to be exported to Iraq. As of April 

2002, about $5.1 billion of worth of goods were being held for shipment to 

Iraq. 

Under Security Council resolution 986 of 1995, paragraphs 1 and 8, the 

sanctions committee was responsible for approving Iraq’s oil contracts, 

particularly to ensure that the contract price is fair, and for approving 

most of Iraq’s commodity contracts.5

 In March 2001, the United States 

informed the Security Council about allegations that Iraqi government 

officials were receiving illegal surcharges on oil contracts and illicit 

commissions on commodity contracts.6

 According to OIP officials, the 

Security Council took action on the allegations of surcharges in 2001 by 

implementing retroactive pricing for oil contracts.7

 However, it is unclear 

what actions the sanctions committee took to respond to illicit 

commissions on commodity contracts. At that time, there was increasing 

concern about the humanitarian situation in Iraq and pressure on the 

United States to expedite its review process. 

In November 2003, the United Nations transferred to the CPA 

responsibility for 3,059 Oil for Food contracts totaling about $6.2 billion 

and decided not to transfer a remaining 2,199 contracts for a variety of 

reasons. U.N. agencies had renegotiated most of the contracts turned over 

to the CPA with the suppliers to remove illicit charges and amend delivery 

and location terms. However, the information the United Nations supplied 

to the CPA on the renegotiated contracts contained database errors and 

did not include all contracts, amendments, and letters of credit associated 

with the 3,000 contracts. These data problems, coupled with inadequate 

 5

Under fast-track procedures established by Security Council resolution 1383 of 1999, OIP 

could approve contracts that contained only humanitarian goods. 

6

The sanctions committee received reports from the independent oil experts appointed by 

the Secretary General to determine whether there was fraud or deception in the oil 

contracting process. 

7

Under retroactive pricing, the Security Council did not approve a price per barrel until the 

oil was delivered to the refinery. The Iraq government signed contracts with suppliers 

without knowing the price it would have to pay until delivery. This allowed a fair market 

price to be set. 

CPA’s Administration 

of the Oil for Food 

Program 
Page 9 GAO-04-651T 

staffing at the CPA, hampered the ability of the CPA’s Oil for Food 

coordination center to ensure that suppliers complied with commodity 

deliveries. In addition, poor planning and coordination are affecting the 

execution of food contracts. 

On November 22, 2003, OIP transferred 3,059 contracts worth about $6.2 

billion in pending commodity shipments to the CPA, according to OIP. 

Prior to the transfer, U.N. agencies had renegotiated the contracts with the 

suppliers to remove “after-sales service fees”—based on information 

provided by the CPA and Iraqi ministries—and to change delivery dates 

and locations. These fees were either calculated separately or were part of 

the unit price of the goods. At the time of the transfer, all but 251 contracts 

had been renegotiated with the suppliers. The Defense Contract 

Management Agency is renegotiating the remaining contracts for the CPA 

to remove additional fees averaging 10 percent. The criteria for 

renegotiating contracts and the amount of the reductions were based on 

information from the CPA in Baghdad and the ministries that originally 

negotiated the contracts. 

An additional 2,199 contracts worth almost $2 billion were not transferred 

as a result of a review by U.N. agencies, the CPA, and the Iraqi ministries 

that negotiated the contracts. For example: 

• The review did not recommend continuing 762 contracts, worth almost 

$1.2 billion, because it determined that the commodities associated 

with the contracts were no longer needed. 

• Another 728 contracts, worth about $750 million, had been classified as 

priority contracts, but were not transferred to the CPA for several 

reasons. About half—351 contracts—were not transferred because 

suppliers were concerned about the adequacy of security within Iraq or 

could not reach agreement on price reductions or specification 

changes. Another 180 contracts were considered fully delivered. 

Another 136 suppliers had either declared bankruptcy, did not exist, or 

did not respond to U.N. requests. It is unclear why the remaining 61 

contracts were removed from the priority list; the OIP document lists 

them as “other.” 

• Suppliers did not want to ship the outstanding small balances for an 

additional 709 contracts totaling about $28 million. 

Program Transferred to the 

CPA in November 2003 
Page 10 GAO-04-651T 

The largest portion of the $6.2 billion in Oil for Food contracts pending 

shipment in November 2003—about 23 percent—was designated for food 

procurement. An additional 9 percent was for food handling and transport. 

The oil infrastructure, power, and agriculture sectors also benefited from 

the remaining contracts. Nearly one half of the renegotiated contracts 

were with suppliers in Russia, Jordan, Turkey, the United Arab Emirates, 

and France. 

According to CPA officials and documents, the incomplete and unreliable 

contract information the CPA received from the United Nations has 

hindered CPA’s ability to execute and accurately report on the remaining 

contracts. U.N. resolution 1483 requested the Secretary General, through 

OIP, to transfer to the CPA all relevant documentation on Oil for Food 

contracts.8

 When we met with OIP officials on November 24, 2003, they 

stated that they had transferred all contract information to the CPA. 

CPA officials and documents report that the CPA has not received 

complete information, including copies of all contracts. The CPA received 

several compact disks in November and January that were to contain 

detailed contract and delivery data, but the information was incomplete. 

The CPA received few source documents such as the original contracts, 

amendments, and letters of credit needed to identify the status of 

commodities, prepare shipment schedules, and contact suppliers. In 

addition, the CPA received little information on letters of credit that had 

expired or were cancelled. Funds for the Oil for Food program are 

obligated by letters of credit to the bank holding the U.N. escrow account. 

When these commitments are cancelled, the remaining funds are available 

for transfer to the Development Fund for Iraq. Without this information, 

the CPA cannot determine the disposition of Oil for Food funds and 

whether the proper amounts were deposited into the Development Fund 

for Iraq.9

In addition, the CPA received an OIP contract database but found it 

unreliable. For example, CPA staff found mathematical and currency 

errors in the calculation of contract cost. The inadequate data and 

documentation have made it difficult for CPA to prepare accurate reports 

on the status of inbound goods and closeouts of completed contracts. 

 8

U.N. Resolution 1483, ¶16(f) (May 2003). 

9

As of March 31, 2004, the United Nations had transferred $7.6 billion in Oil for Food funds 

to the Development Fund for Iraq. 

Inadequate Information 

and Staffing Affected 

Transfer and 

Implementation of 

Contracts 
Page 11 GAO-04-651T 

According to a Department of Defense contracting official, some 

contractors have not received payment for goods delivered in Iraq because 

the CPA had no record of their contracts. 

In November 2003, the CPA established a coordination center in Baghdad 

to oversee the receipt and delivery of Oil for Food commodities. The CPA 

authorized 48 coalition positions, to be assisted by Iraqis from various 

ministries. However, according to several U.S. and U.N. officials, the CPA 

had insufficient staff to manage the program and high staff turnover. As of 

mid-December 2003, the center had 19 coalition staff, including 18 staff 

whose tours ended in January 2004. U.S. and WFP officials stated that the 

staff assigned at the time of the transfer lacked experience in managing 

and monitoring the import and distribution of goods. A former CPA official 

stated that the Oil for Food program had been thrust upon an already 

overburdened and understaffed CPA. As a result, 251 contracts had not 

been renegotiated prior to the time of the transfer and the CPA asked the 

Defense Contract Management Agency to continue the renegotiation 

process. A November 2003 WFP report placed part of the blame in food 

shortfalls during the fall of 2003 on OIP delays in releasing guidelines for 

the contract prioritization and renegotiation process. A September 2003 

U.N. report also noted that the transfer process in the northern governates 

was slowing due to an insufficient number of CPA counterparts to work 

with U.N. staff on transition issues. 

The center’s capacity improved in March 2004 when its coalition staff 

totaled 37. By April 2004, the coordination center had 16 coalition staff. Up 

to 40 Iraqi ministry staff are currently working on Oil for Food contracts. 

As of April 1, the coordination center’s seven ministry advisors have begun 

working with staff at their respective ministries as the first step in moving 

control of the program to the Iraqi government. 

According to U.S. officials and documents, CPA’s failed plans to privatize 

the food distribution system and delayed negotiations with WFP to 

administer the system resulted in diminished stocks of food commodities 

and localized shortages. Before the transfer of the Oil for Food program, 

the CPA administrator proposed to eliminate Iraq’s food distribution 

system and to provide former recipients with cash payments. He asserted 

that the system was expensive and depressed the agricultural sector, and 

the Ministry of Trade began drawing down existing inventories of food. In 

December 2003, as the security environment worsened, the CPA 

administrator reversed his decision to reform the food ration system and 

left the decision to the provisional Iraqi government. 

Inadequate Planning, 

Coordination, and Security 

Affect the Management of 

Food Contracts 
Page 12 GAO-04-651T 

In January 2004, CPA negotiated a memorandum of understanding (MOU) 

with WFP and the Ministry of Trade that committed WFP to procuring a 3-

month emergency food stock by March 31, 2004 and providing technical 

support to the CPA and Ministry of Trade. Delays in signing the MOU were 

due to disagreements about the procurement of emergency food stocks, 

contract delivery terms, and the terms of WFP’s involvement. No 

additional food was procured during the negotiations, and food stocks 

diminished and localized shortages occurred in February and March 2004. 

The CPA and WFP addressed these problems with emergency 

procurements from nearby countries. 

An April WFP report projected a continued supply of food items through 

May 2004 except for a 12-percent shortage in milk. Only 55 percent of 

required domestic wheat has been procured for July 2004 and no domestic 

wheat has been procured for August. Under the terms of MOU, WFP’s 

commitment to procuring food stock ended March 31, 2004. The Ministry 

of Trade assumed responsibility for food procurement on April 1, 2004. 

According to a U.S. official, coordination between WFP and the Ministry of 

Trade has been deteriorating. The Ministry has not provided WFP with 

complete and timely information on monthly food allocation plans, weekly 

stock reports, or information on cargo arrivals, as the MOU required. WFP 

staff reported that the Ministry’s data are subject to sudden, large, and 

unexplained stock adjustments, thereby making it difficult to plan 

deliveries. 

The security environment in Iraq has also affected planning for the 

transfer and movement of Oil for Food goods in fall 2003. The transfer 

occurred during a period of deteriorating security conditions and growing 

violence in Iraq. A September 2003 U.N. report found that the evacuation 

of U.N. personnel from Baghdad affected the timetable and procedures for 

the transfer of the Oil for Food program to the CPA and contributed to 

delays in the contract prioritization and renegotiation processes. Most 

WFP staff remained in Amman and other regional offices and continued to 

manage the Oil for Food program from those locations. The August 

bombing of the U.N. Baghdad headquarters also resulted in the temporary 

suspension of the border inspection process and shipments of 

humanitarian supplies and equipment. A March 2004 CPA report also 

noted that stability of the food supply would be affected if security 

conditions worsened. 
Page 13 GAO-04-651T 

The history of inadequate oversight and corruption in the Oil for Food 

program raises questions about the Iraqi government’s ability to manage 

the import and distribution of Oil for Food commodities and the billions in 

international assistance expected to flow into the country. In addition, the 

food distribution system created a dependency on food subsidies that 

disrupted private food markets. The government will have to decide 

whether to continue, reform, or eliminate the current system. 

The CPA and Iraqi ministries must address corruption in the Oil for Food 

program to help ensure that the remaining contracts are managed with 

transparent and accountable controls. Building these internal control and 

accountability measures into the operations of Iraqi ministries will also 

help safeguard the $18.4 billion in fiscal year 2004 U.S. reconstruction 

funds and at least $13.8 billion pledged by other countries. 

To address these concerns and oversee government operations, the CPA 

administrator announced the appointment of inspectors general for 21 of 

Iraq’s 25 national ministries on March 30, 2004. At the same time, the CPA 

announced the establishment of two independent agencies to work with 

the inspectors general—the Commission on Public Integrity and a Board 

of Supreme Audit. Finally, the United States will spend about $1.63 billion 

on governance-related activities in Iraq, which will include building a 

transparent financial management system in Iraq’s ministries. 

CPA’s coordination center continues to provide on-the-job training for 

ministry staff who will assume responsibility for Oil for Food contracts 

after July 2004. Coalition personnel have provided Iraqi staff with guidance 

on working with suppliers in a fair and open manner and determining 

when changes to letters of credit are appropriate. In addition, according to 

center staff, coalition and Iraqi staff signed a code of conduct, which 

outlined proper job behavior. Among other provisions, the code of 

conduct prohibited kickbacks and secret commissions from suppliers. The 

center also developed a code of conduct for suppliers. In addition, the 

center has begun identifying the steps needed for the transition of full 

authority to the Iraqi ministries. These steps include transferring contractrelated documents, contacting suppliers, and providing authority to amend 

contracts. In addition, the January 2004 MOU agreement commits WFP to 

training ministry staff in the procurement and transport functions 

CPA and Transitional 

Government Face 

Challenges in 

Preventing Corruption 

and Reforming the 

Food Distribution 

System 

Addressing Corruption 
Page 14 GAO-04-651T 

currently conducted by WFP. Training is taking place at WFP headquarters 

in Rome, Italy. 

After the CPA transfers responsibility for the food distribution system to 

the Iraqi provisional government in July 2004, the government will have to 

decide whether to continue, reform, or eliminate the current system. 

Documents from the Ministries of Trade and Finance indicate that the 

annual cost of maintaining the system is as high as $5 billion, or about 25 

percent of total government expenditures. In 2005 and 2006, expenditures 

for food will be almost as much as all expenditures for capital projects. 

According to a September 2003 joint U.N. and World Bank needs 

assessment of Iraq,10 the food subsidy, given out as a monthly ration to the 

entire population, staved off mass starvation during the time of the 

sanctions, but at the same time it disrupted the market for food grains 

produced locally. The agricultural sector had little incentive to produce 

crops in the absence of a promising market. However, the Iraqi 

government may find it politically difficult to scale back the food 

distribution system with 60 percent of the population relying on monthly 

rations as their primary source of nutrition. WFP is completing a 

vulnerability assessment that Iraq could use to make future decisions on 

food security programs and better target food items to those most in need. 

Mr. Chairman and Members of the Committee, this concludes my prepared 

statement. I will be happy to answer any questions you may have. 

For questions regarding this testimony, please call Joseph Christoff at 

(202) 512-8979. Other key contributors to this statement were Pamela 

Briggs, Lyric Clark, Lynn Cothern, Jeanette Espinola, Zina Merritt, Tetsuo 

Miyabara, José M. Peña, III, Stephanie Robinson, Jonathan Rose, Richard 

Seldin, Audrey Solis, and Phillip Thomas. 

 10United Nations/World Bank, Joint Iraq Needs Assessment: Agriculture, Water Resources, 

and Food Security (New York: October 2003). 

Reforming the Food 

Distribution System 

Contacts and 

Acknowledgments 
Page 15 GAO-04-651T 

Date Event/Action Summary 

Aug. 2, 1990 U.N. Security Council 

Resolution 660 

Iraqi forces invaded Kuwait. Resolution 660 condemned the invasion and 

demanded immediate withdrawal from Kuwait. 

Aug. 6, 1990 U.N. Security Council 

Resolution 661 

Imposed economic sanctions against the Republic of Iraq. The resolution called 

for member states to prevent all commodity imports from Iraq and exports to 

Iraq, with the exception of supplies intended strictly for medical purposes and, in 

humanitarian circumstances, foodstuffs. 

Aug. 6, 1990 Operation Desert Shield President Bush ordered the deployment of thousands of U.S. forces to Saudi 

Arabia. 

Nov. 5, 1990 U.S. legislation Public Law 101-513 prohibited the import of products from Iraq into the United 

States and export of U.S. products to Iraq. 

Jan. 12, 1991 U.S. legislation Iraq War Powers Resolution authorized the president to use “all necessary 

means” to compel Iraq to withdraw military forces from Kuwait. 

Jan. 16, 1991 Operation Desert Storm Operation Desert Storm was launched: Coalition operation was targeted to 

force Iraq to withdraw from Kuwait. 

Feb. 28, 1991 Gulf War cease-fire Iraq announced acceptance of all relevant U.N. Security Council resolutions. 

Apr. 3, 1991 U.N. Security Council 

Resolution 687 

(Cease-Fire Resolution) 

Mandated that Iraq must respect the sovereignty of Kuwait and declare and 

destroy all ballistic missiles with a range of more than 150 kilometers as well as 

all weapons of mass destruction and production facilities. 

Jun. 17, 1991 Creation of U.N. Special 

Commission 

The U.N. Special Commission (UNSCOM) was charged with monitoring Iraqi 

disarmament as mandated by U.N. resolutions and to assist the International 

Atomic Energy Agency in nuclear monitoring efforts. 

Aug. 15, 1991 U.N. Security Council 

Resolution 706 

Proposed the creation of an Oil for Food program and authorized an escrow 

account to be established by the Secretary General. Iraq rejected the terms of 

this resolution. 

Sep. 19, 1991 U.N. Security Council 

Resolution 712 

Second attempt to create an Oil for Food program. Iraq rejected the terms of 

this resolution. 

Oct. 2, 1992 U.N. Security Council 

Resolution 778 

Authorized transferring money produced by any Iraqi oil transaction on or after 

August 6, 1990, which had been deposited into the escrow account, to the 

states or accounts concerned as long as the oil exports took place or until 

sanctions were lifted. 

Apr. 14, 1995 U.N. Security Council 

Resolution 986 

Allowed Iraq to sell $1 billion worth of oil every 90 days. Proceeds were to be 

used to procure foodstuffs, medicine, and material and supplies for essential 

civilian needs. Resolution 986 was supplemented by several U.N. resolutions 

over the next 7 years that extended the Oil for Food program for different 

periods of time and increased the amount of exported oil and imported 

humanitarian goods. 

Mar. 27, 1996 U.N. Security Council 

Resolution 1051 

Established the export and import monitoring system for Iraq. 

May 20, 1996 Government of Iraq and the United 

Nations 

Signed a memorandum of understanding allowing Iraq’s export of oil to pay for 

food, medicine, and essential civilian supplies. 

Jun. 17, 1996 United States Based on information provided by the Multinational Interception Force (MIF), 

communicated concerns about alleged smuggling of Iraqi petroleum products 

through Iranian territorial waters in violation of resolution 661 to the Security 

Council sanctions committee. 

Appendix I: Timeline of Major Events Related 

to Sanctions Against Iraq and the 

Administration of the Oil for Food Program 
Page 16 GAO-04-651T 

Date Event/Action Summary 

Jul. 9, 1996 U.N. Security Council Sanctions 

Committee 

Committee members asked the United States for more factual information about 

smuggling allegations, including the final destination and the nationality of the 

vessels involved. 

Aug. 28, 1996 U.S. delegation to the U.N. Security 

Council Sanctions Committee 

Provided briefing on the Iraqi oil smuggling allegations to the sanctions 

committee. 

Dec. 3, 1996 Islamic Republic of Iran Permanent 

Representative to the United 

Nations 

Acknowledged that some vessels carrying illegal goods and oil to and from Iraq 

had been using the Iranian flag and territorial waters without authorization and 

that Iranian authorities had confiscated forged documents and manifests. 

Representative agreed to provide the results of the investigations to the 

sanctions committee once they were available. 

Dec. 10, 1996 Iraq and the United Nations Phase I of the Oil for Food program began. 

Jun. 4, 1997 U.N. Security Council 

Resolution 1111 

Extended the term of resolution 986 another 180 days (phase II). 

Sep. 12, 1997 U.N. Security Council 

Resolution 1129 

Authorized special provision to allow Iraq to sell petroleum in a more favorable 

time frame. 

Oct. 8, 1997 Representatives of the United 

Kingdom of Great Britain and 

Northern Ireland to the United 

Nations 

Brought the issue of Iraqi smuggling petroleum products through Iranian 

territorial waters to the attention of the U.N. Security Council sanctions 

committee. 

Nov. 18, 1997 Coordinator of the Multinational 

Interception Force (MIF) 

Reported to the U.N. Security Council sanctions committee that since February 

1997 there had been a dramatic increase in the number of ships smuggling 

petroleum from Iraq inside Iranian territorial waters. 

Dec. 4, 1997 U.N. Security Council 

Resolution 1143 

Extended the Oil for Food program another 180 days (phase III). 

Feb. 20, 1998 U.N. Security Council 

Resolution 1153 

Raised Iraq’s export ceiling of oil to about $5.3 billion per 6-month phase (phase 

IV). 

Mar. 25, 1998 U.N. Security Council 

Resolution 1158 

Permitted Iraq to export additional oil in the 90 days from March 5, 1998, to 

compensate for delayed resumption of oil production and reduced oil price. 

Jun. 19, 1998 U.N. Security Council 

Resolution 1175 

Authorized Iraq to buy $300 million worth of oil spare parts to reach the export 

ceiling of about $5.3 billion. 

Aug. 14, 1998 U.S. legislation Public Law 105-235, a joint resolution finding Iraq in unacceptable and material 

breach of its international obligations. 

Oct. 31, 1998 U.S. legislation: Iraq Liberation Act Public Law 105-338 §4 authorized the president to provide assistance to Iraqi 

democratic opposition organizations. 

Oct. 31, 1998 Iraqi termination of U.N. Special 

Commission (UNSCOM) Activity 

Iraq announced it would terminate all forms of interaction with UNSCOM and 

that it would halt all UNSCOM activity inside Iraq. 

Nov. 24, 1998 U.N. Security Council 

Resolution 1210 

Renewed the Oil for Food program for 6 months beyond November 26 at the 

higher levels established by resolution 1153. The resolution included additional 

oil spare parts (phase V). 

Dec. 16, 1998 Operation Desert Fox Following Iraq’s recurrent blocking of U.N. weapons inspectors, President 

Clinton ordered 4 days of air strikes against military and security targets in Iraq 

that contribute to Iraq’s ability to produce, store, and maintain weapons of mass 

destruction and potential delivery systems. 
Page 17 GAO-04-651T 

Date Event/Action Summary 

Mar. 3, 1999 President Clinton Report to 

Congress 

President Clinton provided the status of efforts to obtain Iraq’s compliance with 

U.N. Security Council resolutions. He discussed the MIF report of oil smuggling 

out of Iraq and smuggling of other prohibited items into Iraq. 

May 21, 1999 U.N. Security Council 

Resolution 1242 

Renewed the Oil for Food program another 6 months (phase VI). 

Oct. 4, 1999 U.N. Security Council 

Resolution 1266 

Permitted Iraq to export an additional amount of $3.04 billion of oil to make up 

for revenue deficits in phases IV and V. 

Nov. 19, 1999 U.N. Security Council 

Resolution 1275 

Extended phase VI of the Oil for Food program for 2 weeks until December 4, 

1999. 

Dec. 3, 1999 U.N. Security Council 

Resolution 1280 

Extended phase VI of the Oil for Food program for 1 week until December 11, 

1999. 

Dec. 10, 1999 U.N. Security Council 

Resolution 1281 

Renewed the Oil for Food program another 6 months (phase VII). 

Dec. 17, 1999 U.N. Security Council 

Resolution 1284 

Abolished Iraq’s export ceiling to purchase civilian goods. Eased restrictions on 

the flow of civilian goods to Iraq and streamlined the approval process for some 

oil industry spare parts. Also established the United Nations Monitoring, 

Verification and Inspection Commission (UNMOVIC). 

Mar. 31, 2000 U.N. Security Council 

Resolution 1293 

Increased oil spare parts allocation from $300 million to $600 million under 

phases VI and VII. 

Jun. 8, 2000 U.N. Security Council 

Resolution 1302 

Renewed the Oil for Food program another 180 days until December 5, 2000 

(phase VIII). 

Dec. 5, 2000 U.N. Security Council 

Resolution 1330 

Extended the Oil for Food program another 180 days (phase IX). 

Mar. 8, 2001 Deputy U.S. Representative to the 

United Nations Remarks to the 

Security Council 

Ambassador Cunningham acknowledged Iraq’s illegal re-export of humanitarian 

supplies, oil smuggling, establishment of front companies, and payment of 

kickbacks to manipulate and gain from Oil for Food contracts. Also 

acknowledged that the United States had put holds on hundreds of Oil for Food 

contracts that posed dual-use concerns. 

Mar. 8, 2001 Acting U.S. Representative to the 

United Nations Remarks to the 

Security Council 

Ambassador Cunningham addressed questions regarding allegations of 

surcharges on oil and smuggling. Acknowledged that oil industry 

representatives and other Security Council members provided the United States 

anecdotal information about Iraqi surcharges on oil sales. Also acknowledged 

companies claiming they were asked to pay commissions on contracts. 

Jun. 1, 2001 U.N. Security Council 

Resolution 1352 

Extended the terms of resolution 1330 (phase IX) another 30 days. 

Jul. 3, 2001 U.N. Security Council 

Resolution 1360 

Renewed the Oil for Food program an additional 150 days until November 30, 

2001 (phase X). 

Nov. 29, 2001 U.N. Security Council 

Resolution 1382 

The resolution stipulated that a new Goods Review List would be adopted and 

that relevant procedures would be subject to refinement. Renewed the Oil for 

Food program another 180 days (phase XI). 

May 14, 2002 U.N. Security Council 

Resolution 1409 

UNMOVIC reviewed export contracts to ensure that they contain no items on a 

designated list of dual-use items known as the Goods Review List. The 

resolution also extended the program another 180 days (phase XII). 

Nov. 6, 2002 U.N. Security Council Sanctions 

Committee 

MIF reported that there had been a significant reduction in illegal oil exports 

from Iraq by sea over the past year but noted oil smuggling was continuing. 
Page 18 GAO-04-651T 

Date Event/Action Summary 

Nov. 25, 2002 U.N. Security Council 

Resolution 1443 

Extended phase XII of the Oil for Food program another 9 days. 

Dec. 4, 2002 U.N. Security Council 

Resolution 1447 

Renewed the Oil for Food program another 180 days until June 3, 2003 (phase 

XIII). 

Dec. 30, 2002 U.N. Security Council 

Resolution 1454 

Approved changes to the list of goods subject to review and the sanctions 

committee. 

Mar. 12, 2003 U.N. Security Council Sanctions 

Committee 

Chairman reported on a number of alleged sanctions violations noted by letters 

from several countries and the media from February to November 2002. 

Alleged incidents involved Syria, India, Liberia, Jordan, Belarus, Switzerland, 

Lebanon, Ukraine, and the United Arab Emirates. 

Mar. 19, 2003 Operation Iraqi Freedom Operation Iraqi Freedom is launched. Coalition operation led by the United 

States initiated hostilities in Iraq. 

Mar. 28, 2003 U.N. Security Council 

Resolution 1472 

Adjusted the Oil for Food program and gave the Secretary General authority for 

45 days to facilitate the delivery and receipt of goods contracted by the 

Government of Iraq for the humanitarian needs of its people. 

Apr. 16, 2003 U.S. legislation Public Law 108-11 §1503 authorized the President to suspend the application of 

any provision of the Iraq Sanctions Act of 1990. 

Apr. 24, 2003 U.N. Security Council 

Resolution 1476 

Extended provision of resolution 1472 until June 3, 2003. 

May 1, 2003 Operation Iraqi Freedom End of major combat operations and beginning of post-war rebuilding efforts. 

May 22, 2003 U.N. Security Council 

Resolution 1483 

Lifted civilian sanctions on Iraq and provided for the end of the Oil for Food 

program within 6 months, transferring responsibility for the administration of any 

remaining program activities to the Coalition Provisional Authority (CPA). 

Nov. 21, 2003 U.N. Secretary General Transferred administration of the Oil for Food program to the CPA. 

Mar.19, 2004 U.N. Secretary General Responded to allegations of fraud by U.N. officials that were involved in the 

administration of the Oil for Food program. 

Mar. 25, 2004 U.N. Secretary General Proposed that a special investigation be conducted by an independent panel. 

(320232) 
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