Testimony 

Before the Subcommittee on Oversight 

and Investigations, Committee on 

Financial Services, House of 

Representatives

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EST 

Thursday, March 18, 2004 RECOVERING IRAQ’S 

ASSETS 

Preliminary Observations 

on U.S. Efforts and 

Challenges 

Statement of Joseph A. Christoff, Director 

International Affairs and Trade 

and Davi M. D’Agostino, Director 

Financial Markets and Community Investment 

GAO-04-579T 
www.gao.gov/cgi-bin/getrpt?GAO-04-579T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Joseph 

Christoff at (202) 512-8789 or 

christoffj@gao.gov or Davi M. D'Agostino at 

(202) 512-5431 or dagostinod@gao.gov. 

Highlights of GAO-04-579T, a testimony to 

Subcommittee on Oversight and 

Investigations, House Committee on 

Financial Services 

March 18, 2004

RECOVERING IRAQ’S ASSETS 

Preliminary Observations on U.S. Efforts 

and Challenges 

GAO estimates 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 in oil smuggled out of Iraq and $4.4 billion in illicit 

surcharges on oil sales and after-sales charges on suppliers. This estimate is 

higher than our May 2002 estimate of $6.6 billion because it includes 2002 

data from oil revenues and contracts under the Oil for Food Program and 

newer estimates of illicit commissions from commodity suppliers. 

The United States has tapped the services of a variety of U.S. agencies and 

recently developed domestic and international tools in its efforts to recover 

Iraqi assets worldwide. Led by the Department of the Treasury, about 20 

government entities have combined efforts to identify, freeze, and transfer 

the former regime’s assets to Iraq. The United States also used the 

International Emergency Economic Powers Act, as amended by provisions 

in the USA PATRIOT Act of 2001, to confiscate the property of the former 

Iraqi regime under U.S. jurisdiction and vest the assets in the U.S. Treasury. 

Finally, U.N. Security Council Resolution 1483 required all U.N. members to 

freeze without delay and immediately transfer assets of the former Iraqi 

regime to the new Development Fund for Iraq (DFI). 

U.S. efforts to recover Iraqi assets have had varying results. In March 2003, 

the U.S. government quickly took control of Iraq’s assets in the United 

States. From May to September 2003, the United States transferred $1.7 

billion to Iraq to help pay for the salaries of Iraqi civil servants, ministry 

operations, and pensions. Within Iraq, U.S. military and coalition forces 

seized about $926 million of the regime’s assets. Other countries froze about 

$3.7 billion of Iraqi regime assets in compliance with U.N. Security Council 

resolutions. As of March 2004, Treasury reported that more than 10 countries 

and the Bank for International Settlements had transferred approximately 

$751 million to the DFI. Little progress has been made in identifying and 

freezing additional Iraqi assets that remain hidden. While the amount of 

hidden assets accumulated by the former Iraqi regime is unknown, estimates 

range from $10 to $40 billion in illicit earnings. 

The United States faces key challenges in recovering Iraq’s assets. First, 

recovering the former regime’s assets was not initially a high priority in the 

overall U.S. effort in Iraq. Second, U.S. officials stated that many countries 

needed to adopt additional legislation to implement the U.N. requirements 

and transfer the funds to the DFI. U.S. expectations for the quick transfer of 

funds may have been overly optimistic given the legal capabilities of some 

countries. Third, the impending transfer of sovereignty to an interim Iraqi 

government on June 30, 2004, may further complicate U.S. efforts to locate 

and recover assets of the former regime. It is uncertain whether the new 

government will allow the United States to continue its hunt for the former 

regime’s assets. 

Rebuilding Iraq is a U.S. national 

security priority. Billions of dollars 

are needed for Iraq’s 

reconstruction. The U.S. 

government and the international 

community have undertaken 

important efforts to recover the 

assets of the former regime and 

return them to the Iraqi people. In 

this testimony, GAO will present its 

preliminary observations on the 

recovery effort. Specifically, GAO 

(1) updates its estimate of the 

revenues diverted from the Oil for 

Food Program, (2) describes the 

U.S. government agencies working 

on the asset recovery effort, (3) 

discusses the results of U.S. efforts, 

and (4) highlights challenges that 

the United States faces in 

recovering Iraqi assets. 

As this testimony reflects GAO’s 

preliminary observations, GAO is 

making no recommendations. 
Page 1 GAO-04-579T Recovering Iraq's Assets 

Madam Chairwoman and Members of the Subcommittee: 

We are pleased to be here today to discuss our preliminary observations 

on U.S. and international efforts to recover assets of the former Iraqi 

regime and transfer them to Iraq for reconstruction. 

Rebuilding Iraq is a U.S. national security and foreign policy priority. 

Billions of dollars are needed for meeting humanitarian needs, stabilizing 

Iraq, and repairing the country’s infrastructure. The U.S. government and 

the international community have undertaken important efforts to recover 

the assets of the former regime and return them to the Iraqi people. 

In May 2003, this committee asked GAO to examine how the U.S. 

government works with the international community to recover the assets 

of targeted foreign regimes. We will complete this broader report on U.S. 

recovery efforts for the committee in May 2004. 

Today, we will present our preliminary observations on Iraqi asset 

recovery efforts. Specifically, we will (1) update our estimate of the 

revenues diverted from the Oil for Food Program by the former Iraqi 

regime, (2) describe the U.S. agencies working to recover Iraqi assets, (3) 

discuss the results of U.S. efforts, and (4) highlight challenges in asset 

recovery. 

To address these issues, we reviewed documents and statements from the 

Departments of the Treasury, State, Defense, and Justice on the asset 

recovery effort, the Coalition Provisional Authority (CPA)1

 in Iraq on the 

funds transferred to Iraq, and the United Nations on the Oil for Food 

Program. We met with U.S. officials working on the recovery effort, 

including officials from the Treasury’s Office of Foreign Assets Control 

(OFAC), analysts from U.S. law enforcement and intelligence agencies, 

financial regulators, and representatives from U.S. financial institutions 

responsible for implementing U.S. orders to freeze and transfer blocked 

Iraqi assets. We have yet to review the reliability of the data provided by 

the Department of the Treasury and the CPA. 

 1

The CPA is the U.N.-recognized coalition authority, led by the United States and the United 

Kingdom, responsible for the temporary governance of Iraq. 
Page 2 GAO-04-579T Recovering Iraq's Assets 

• 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 in oil smuggled out of Iraq and $4.4 billion in 

illicit surcharges on oil sales and commissions from suppliers. This 

estimate is higher than our reported May 2002 estimate of $6.6 billion 

because it includes 2002 data from oil revenues and contracts under 

the Oil for Food Program, newer estimates of illicit commissions from 

commodity suppliers. 2

• The United States has tapped the services of several U.S. agencies and 

used recently developed domestic and international tools in its efforts 

to recover Iraqi assets worldwide. Led by the Department of the 

Treasury, about 20 government entities have combined efforts to 

identify, freeze, and transfer the former regime’s assets to Iraq. The 

United States also used the International Emergency Economic Powers 

Act (IEEPA), as amended by provisions in the USA PATRIOT Act of 

2001, to confiscate the property of the former Iraqi regime under U.S. 

jurisdiction and vest the assets in the U.S. Treasury. Finally, U.N. 

Security Council Resolution 1483 required all U.N. members to freeze 

without delay and immediately transfer assets of the former Iraqi 

regime to the new Development Fund for Iraq (DFI). 

• U.S. efforts to recover Iraqi assets have had varying results. 

• In March 2003, the U.S. government quickly took control of Iraq’s 

assets in the United States. From May to September 2003, the 

United States transferred $1.7 billion to Iraq to help pay for the 

salaries of Iraqi civil servants, ministry operations, and pensions. 

The United States also transferred $192 million to the DFI in July 

2003. Most of the vested funds have been spent on reconstruction. 

• Within Iraq, U.S. military and coalition forces seized about $926 

million of the regime’s assets. The CPA used these funds for Iraqi 

projects, ministry operations, and liquefied petroleum gas 

purchases. 

• Other countries froze about $3.7 billion of Iraqi regime assets in 

compliance with U.N. Security Council resolutions. As of March 

2004, Treasury reported that more than 10 countries and the Bank 

 2

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

Challenges in implementing Sanctions Against Iraq, GAO-02-625 (Washington, DC.: May 23, 

2002). 

Summary 
Page 3 GAO-04-579T Recovering Iraq's Assets 

for International Settlements had transferred approximately $751 

million to the DFI. State Department and Treasury officials continue 

to work diplomatically with other countries to expedite the transfer 

of remaining Iraqi assets. 

• Little progress has been made in identifying and freezing additional 

Iraqi assets that remain hidden. While the amount of hidden assets 

accumulated by the former Iraqi regime is unknown, estimates 

range from $10 billion to $40 billion in illicit earnings. 

• The United States faces key challenges in recovering Iraq’s assets. 

First, recovering the former regime’s assets was not initially a high 

priority in the overall U.S. effort in Iraq. Second, U.S. expectations for 

the quick transfer of funds may have been overly optimistic given the 

legal capabilities of some countries. Third, the impending transfer of 

sovereignty to an interim Iraqi government may further complicate U.S. 

efforts to locate and recover assets of the former regime. 

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

sanctions against the regime. Security Council Resolution 661 of 1990, 

prohibited all nations from buying Iraqi oil and selling Iraq any 

commodities except food or medicines. The resolution also required 

member states to block the transfer of Iraqi assets from their countries. 

Consistent with this resolution, the President froze all Iraq’s assets held in 

the United States. Other nations similarly froze Iraqi government assets in 

their countries. 

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, food shortages and a general 

deterioration in social services were reported. 

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

Program, which allowed Iraq to sell a set amount of oil to pay for food, 

medicine, and infrastructure repairs. The United Nations monitored and 

screened contracts that the Iraqi government signed with commodity 

suppliers. Iraq’s oil revenue was placed in a U.N.-controlled escrow 

account. From 1997 through 2002, Iraq sold more than $67 billion of oil 

through the U.N. program and issued $38 billion in letters of credit for 

humanitarian goods. In May 2003, the Security Council passed Resolution 

1483, which recognized the United States, Great Britain, and coalition 

partners as the authority for providing security and provisional 

Background 
Page 4 GAO-04-579T Recovering Iraq's Assets 

administration in Iraq. The resolution also ended the sanctions, except for 

the prohibition on exporting arms to Iraq. 

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.3

 This estimate is higher than the $6.6 billion we reported in May 

2002.4

 We updated this 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, 

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

5 to 10 percent of the commodity contract. The funds were paid directly to 

officials connected with the Iraqi government. In addition, according to a 

Department of Defense (DOD) official, a DOD report in September 2003 

evaluated 759 contracts funded and approved under the Oil for Food 

Program. The study found that at least 48 percent of the contracts were 

overpriced and that on average the contracts were overpriced by 21 

percent. 

 3

This estimate is in 2003 U.S. constant dollars. 

4

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

Challenges in implementing Sanctions Against Iraq, GAO-02-625 (Washington, DC.: May 23, 

2002). 

Estimated Revenue 

Obtained Illegally by 

the Former Iraqi 

Regime from the Oil 

for Food Program 

Exceeds $10 Billion 
Page 5 GAO-04-579T Recovering Iraq's Assets 

The United States has tapped the services of several U.S. agencies and 

used recently developed U.S. and international authorities in its efforts to 

recover Iraqi assets worldwide. About 20 entities, including those of the 

Departments of the Treasury, Homeland Security, Defense, Justice, State, 

intelligence agencies, law enforcement agencies, and the White House 

National Security Council, are involved in recovering Iraqi assets. 

To lead the asset recovery efforts, the United States created an 

interagency coordinating body headed by the Department of the Treasury. 

The Iraqi Assets Working Group has developed a strategy to identify, 

freeze, seize, and transfer former regime assets to Iraq. The working 

group’s goals are to: 

• Exploit documents and key financial figures in Iraq to better 

understand fund flows; 

• Secure the cooperation of jurisdictions through which illicit funds have 

flowed so that working group members may exploit financial records 

and uncover the money trail; 

• Secure the cooperation of jurisdictions in which illicit assets may 

reside to locate, freeze, and repatriate the assets; 

• Engage the financial community in the hunt for illicit assets generally, 

and specifically secure the cooperation of the financial institutions 

through which illicit funds have flowed or may still reside; 

• Develop a system to facilitate the fluid repatriation of funds; and 

• Prepare for potential sanctions against uncooperative jurisdictions and 

financial institutions. 

The working group is leveraging the expertise of U.S. officials involved in 

efforts to recover assets of terrorists and money launderers. 

The U.S. Congress recently passed legislation containing provisions that 

allowed the President to confiscate foreign funds frozen in U.S. financial 

institutions. Specifically, provisions in the USA PATRIOT Act of 2001 

amended IEEPA to allow the President to confiscate foreign property 

subject to U.S. jurisdiction in times of “on-going hostilities” or if the United 

States is attacked. These provisions gave the President the necessary 

authority, through an Executive Order, to confiscate the property of the 

former Iraqi regime and to vest these assets in the U.S. Treasury. 

U.S. Efforts to 

Recover Iraqi Assets 

Involve Many 

Agencies and Use 

Recently Developed 

Domestic and 

International 

Authorities 
Page 6 GAO-04-579T Recovering Iraq's Assets 

In addition, the State Department cited U.N. Security Council Resolution 

1483 as an important vehicle for requiring other countries to transfer 

assets to Iraq. On May 22, 2003, the U.N. Security Council adopted 

Resolution 1483, which (1) noted the establishment of the DFI, a special 

account in the name of the Central Bank of Iraq; and (2) required member 

states to freeze and immediately transfer to the DFI all assets of the 

former Iraqi government and of Saddam Hussein, senior officials of his 

regime and their family members. The resolution also included a unique 

immunity provision to protect the assets from new claims. 

In 2003, the U.S. government quickly vested Iraq’s assets held in the United 

States and transferred them to Iraq. Similarly, the U.S. military, in 

coordination with U.S. law enforcement agencies, seized assets of the 

former regime in Iraq. The CPA has used most of the vested and seized 

assets for reconstruction projects and ministry operations. U.S. officials 

noted that some other countries’ efforts to transfer Iraqi funds have been 

slowed by their lack of implementing legislation. There has been little 

progress in recovering the regime’s hidden assets. 

In 2003, the United States vested about $1.9 billion of the former regime’s 

assets in the U.S. Treasury. Between May and December, the United States 

transferred more than $1.7 billion to Iraq and $192 million to the DFI. The 

United States had the necessary legal authorities to make the transfers 

quickly. 

On August 2, 1990, in compliance with a Presidential Executive Order, the 

Treasury Office of Foreign Assets Control (OFAC) issued regulations to 

financial institutions requiring them to freeze Iraqi assets in the United 

States. More than 30 banks in the United States identified and froze 

accounts with $1.4 billion in Iraqi assets.5

 These institutions held assets in 

accounts that accumulated interest. 

In March 2003, the President used authorities, including the enhanced 

authority in IEEPA, as amended by provisions in the USA PATRIOT Act, to 

issue a new executive order to confiscate or take ownership of Iraqi assets 

held by U.S. financial institutions and vest them in the U.S. Treasury. 

 5

In addition, according to OFAC, more than $480 million was frozen in U.S. financial 

institutions abroad. 

U.S. Efforts to 

Recover the Former 

Iraqi Regime’s Assets 

Have Had Varying 

Results 

The United States 

Transferred Nearly $1.9 

Billion in Vested Assets to 

Iraq 
Page 7 GAO-04-579T Recovering Iraq's Assets 

According to Treasury and Federal Reserve officials, Treasury instructed 

the Federal Reserve Bank to release portions of the funds to DOD upon 

the Office of Management and Budget’s approval of DOD’s spending plans. 

As of March 2004, the CPA had spent about $1.67 billion of the $1.9 billion 

for emergency needs, including salaries for civil servants and pensions, 

and for ministry operations. 

CPA informed us in March 2004 that the U.S. military, in coordination with 

U.S. law enforcement agencies had seized about $926 million of the 

regime’s assets in Iraq. The U.S. military seized about $894 million in Iraqi 

bonds, U.S. dollars, euros, and Iraqi dinars, as well as quantities of gold 

and jewelry. This amount included $750,000 found with Saddam Hussein 

when he was captured. Department of Homeland Security agents seized an 

additional $32 million. 

The CPA is authorized to use these seized funds for humanitarian and 

reconstruction efforts. As of March 2004, the CPA had used $752 million 

for reconstruction activities, including projects, ministry operations, and 

liquefied petroleum gas purchases. 

According to Treasury, other countries have frozen about $3.7 billion in 

Iraqi assets. Treasury officials reported that, as of March 2004, more than 

10 countries and the Bank for International Settlements have transferred 

$751 million to the DFI. Treasury officials noted that the remaining assets 

have not been transferred to the DFI because some countries do not have 

the necessary legislation to affect the transfer or are holding about $1 

billion to adjudicate claims. U.N. Security Council Resolution 1483 

requires the immediate transfer of Iraqi funds identified and frozen in 

these accounts to the DFI. 

To encourage other countries to transfer the funds to Iraq, the Secretary of 

the Treasury requested that the international community identify and 

freeze all assets of the former regime. Additionally, Treasury and State 

officials said that they have engaged in diplomatic efforts to encourage 

countries to report and transfer the amounts of Iraqi assets that they had 

frozen. For example, since March 2003, State officials told us that they 

have sent more than 400 cables to other countries requesting that they 

transfer funds to the DFI. 

According to U.S. officials, Treasury and State continue to leverage the 

U.S. government’s diplomatic relations with finance ministries and central 

The United States Seized 

More Than $900 Million in 

Iraq 

Other Countries Have 

Transferred $751 Million to 

the DFI 
Page 8 GAO-04-579T Recovering Iraq's Assets 

banks to encourage the transfer of Iraqi assets to the DFI, according to 

Treasury officials. Some of the remaining frozen funds are located in 

financial institutions in Iraq’s neighboring countries or Europe. 

Little progress has been made in recovering the former Iraqi regime’s 

hidden assets. Because the former Iraqi regime used a network of front 

companies, trusts, and cash accounts in the names of the regime family 

members and associates, it has been difficult to identify how much 

remains hidden in the international financial system. U.S. government 

officials have cited estimates ranging from $10 billion to $40 billion in 

illicit earnings. 

According to U.S. government officials, U.S. government asset recovery 

efforts have focused on exploiting documents in Iraq, interviewing key 

financial figures, and convincing other countries to cooperate in 

identifying and freezing illicit funds that have flowed through or still reside 

in their countries. For example, Department of Homeland Security agents 

have exploited Central Bank of Iraq records for leads regarding Saddam 

Hussein’s procurement network. Internal Revenue Service criminal 

investigators have conducted interviews of former finance ministry 

individuals and exploited financial documents of the regime to obtain 

leads on the location of targeted assets. The Defense Intelligence Agency 

provides some of the research and analysis used to identify assets of the 

former Iraqi regime. 

In addition, according to Treasury and State officials, they are 

coordinating efforts to gain the cooperation of other countries. For 

example, State officials said that U.S. investigators have identified 500 

accounts that potentially belonged to the former regime in other countries. 

State is working through their overseas embassies to get the cooperation 

of these countries to return the funds to the DFI. 

The U.S. government has faced key challenges to recovering the assets of 

the former Iraqi regime. 

First, recovering the former regime’s assets was not initially a high priority 

in the overall U.S. effort in Iraq. As the need for additional resources to 

rebuild Iraq became apparent, the United States placed a higher priority on 

recovering the former regime’s assets. According to U.S. government 

officials, recovering the former Iraqi regime’s assets became the U.S. 

government’s third priority behind the hunt for weapons of mass 

destruction and security in September 2003. In addition, Internal Revenue 

Little Progress Has Been 

Made in Recovering 

Hidden Assets of the 

Former Iraqi Regime 

Challenges to 

Transferring Frozen 

Assets and Locating 

the Hidden Assets 
Page 9 GAO-04-579T Recovering Iraq's Assets 

Service agents stated that DOD’s post-war plans and priorities did not 

include protection of financial documents or other information that could 

have provided leads on the location of the former regime’s assets. 

Second, U.S. expectations for the quick transfer of funds under U.N. 

Security Council Resolution 1483 may have been overly optimistic given 

the lack of legal capabilities of some countries to do so. In June 2003, State 

and Treasury officials said that the U.N. resolution included unique 

provisions that afforded the United States and the international 

community with an opportunity to quickly recover Iraqi assets worldwide. 

The resolution required all U.N. members to freeze without delay assets of 

the former Iraqi regime and immediately transfer them to the DFI. Many of 

the member states that had frozen Iraqi government assets in 1991 did not 

immediately transfer the assets to the DFI. 

U.S. officials stated that many countries needed to adopt additional 

legislation to implement the U.N. requirements and transfer the funds to 

the DFI. According to U.S. government officials, some U.N. member 

countries have developed the authorities, institutions, and mechanisms to 

freeze assets of targeted terrorists, but others had not developed similar 

mechanisms for targeted regimes. U.S. government officials also stated 

that some countries did not have the administrative capabilities and 

financial mechanisms to transfer the frozen assets. U.S. officials did not 

have a central repository of other countries’ laws and regulations related 

to transferring Iraqi assets. Furthermore, according to U.S. officials, 

despite the immunity provision included in the U.N. resolution, some 

countries are delaying transfer of funds until all claims have been settled. 

Third, the impending transfer of sovereignty to an interim Iraqi 

government on June 30, 2004, may further complicate U.S. efforts to locate 

and recover assets of the former regime. It is uncertain whether the new 

government will allow the United States to continue its hunt for the former 

regime’s assets. The future transitional government has yet to conclude 

agreements regarding the activities of the multi-national force, which may 

include the right to interview Iraqi officials and exploit documents. In 

addition, it is also uncertain whether other countries will transfer their 

remaining funds to the DFI when the interim government assumes 

authority over it. 

Madam Chairwoman and Members of the Subcommittee, this concludes 

our prepared statement. We will be happy to answer any questions you 

may have. 
Page 10 GAO-04-579T Recovering Iraq's Assets 

For questions regarding this testimony, please call Joseph Christoff at 

(202) 512-8979 or Davi M. D’Agostino at (202) 512-5431. Other key 

contributors to this statement were Thomas Conahan, Lynn Cothern, 

Philip Farah, Rachel DeMarcus, Ronald Ito, Barbara Keller, Sarah Lynch, 

Zina Merritt, Tetsuo Miyabara, Marc Molino, and Mark Speight. 

Contacts and 

Acknowledgments 
Page 11 GAO-04-579T Recovering Iraq's Assets 

Appendix I: Roles of U.S. Entities In 

Recovering Iraqi Assets 

Asset location

United States

Assets

$1.92 billion

Frozen and transferred

$1.67 billion

Funds disbursed in Iraq

Current status

Department of the Treasury

Executive Office of the President

Coalition Provisional Authority

Entity Agency/Office/Subdivision Role

Office of Foreign Assets Control

Executive Office for Terrorist

Financing and Financial Crime

Froze assets in 1990, directed financial institutions to transfer these

assets to Treasury account in 2003.

Leads interagency Iraq Task Force Working Group for Tracking and

Recovery of Iraqi Assets (Iraqi Assets Working Group, IAWG). 

Office of Management and Budget Approves CPA spending requests of vested funds.

Federal Reserve Bank of New York Maintains Treasury's vested account. As directed by Treasury, released the vested

funds to the Department of Defense and the Coalition Provisional Authority (CPA).

Approves and manages the obligation and expenditure of vested funds.

Coalition Provisional Authority Approves and, with DOD, manages the obligation and expenditure of seized funds.

Asset location

Iraq

Assets

$926 million

Seized

$752 million

Funds disbursed in Iraq

Current status

Department of Defense

Entity Agency/Office/Subdivision Role

Military identified and seized assets in U.S. dollar, euro, and dinar currency notes;

gold, jewelry, and Iraqi bonds.

Department of Homeland Security Bureau of Immigration

and Customs Enforcement

Secret Service

Assisted the military in the identification and seizure of assets. 

Seized an additional $32 million.

Determined the authenticity of seized assets.

Source: GAO.
Page 12 GAO-04-579T Recovering Iraq's Assets (320262) 

Asset location

Other countires

Assets

$3.7 billion

Identified and frozen

$751 million

Transferred to the

Development Fund for Iraqa

Current status

Department of the Treasury

Entity Agency/Office/Subdivision Role

Office of Foreign Assets Control Coordinates with State and Justice on potential asset designations.

International Affairs Tracks the status of assets frozen in and transferred from other countries.

Bureau of Economic and Business Affairs and

International Organizations

Undertake diplomatic efforts to encourage other governments to

implement UN Resolution 1483. 

Bureau of Intelligence and Research and

Regional Bureaus

Collect and analyze economic and other information on Iraq and its

neighboring countries

Department of State

U.S. Mission to the United Nations Negotiated consensus on UN Resolution 1483.

Submits potential freezing designations to the United Nations. 

Financial Institutions Identify, freeze, and transfer assets to the Development Fund for Iraq.

Coordinates with State on outreach to foreign government officials, including

finance ministries. 

Executive Office for Terrorist

Financing and Financial Crime

Bureau of Economic and Business Affairs

and overseas embassies

Undertake diplomatic efforts to encourage other governments to

follow up on leads and freeze assets.

U.S. Mission to the United Nations Encourages UN members to identify, freeze, and transfer assets.

Asset location

Global

Assets

$Unknownb

Hidden Iraqi assets

?

Current status

Department of the Treasury

Department of State

Internal Revenue Service

 Criminal Investigation Division

Department of Defense Defense Intelligence Agency

Department of Homeland Security

Entity Agency/Office/Subdivision Role

Executive Office for Terrorist Financing

and Financial Crime

Reviews documents and interviews individuals connected to Saddam

Hussein's finances, front companies, and account transactions; provides

leads to embassies and to other governments and financial institutions.

Provides research and analysis used to identify assets of the former Iraqi

regime.

Office of the Secretary of Defense and the

Special Operations and Low-intensity Conflict

Work with the IAWG to facilitate activities in Iraq, including providing logistical

support to Treasury investigators.

Source: GAO.

Coordinates U.S. efforts to locate additional hidden assets.

Bureau of Immigration and Customs Enforcement Identify and track financial assets related to the Central Bank of Iraq.
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
The General Accounting Office, the audit, evaluation and investigative arm of 

Congress, exists to support Congress in meeting its constitutional responsibilities 

and to help improve the performance and accountability of the federal 

government for the American people. GAO examines the use of public funds; 

evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and fulltext files of current reports and testimony and an expanding archive of older 

products. The Web site features a search engine to help you locate documents 

using key words and phrases. You can print these documents in their entirety, 

including charts and other graphics. 

Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its Web site 

daily. The list contains links to the full-text document files. To have GAO e-mail 

this list to you every afternoon, go to www.gao.gov and select “Subscribe to e-mail 

alerts” under the “Order GAO Products” heading. 

The first copy of each printed report is free. Additional copies are $2 each. A 

check or money order should be made out to the Superintendent of Documents. 

GAO also accepts VISA and Mastercard. Orders for 100 or more copies mailed to a 

single address are discounted 25 percent. Orders should be sent to: 

U.S. General Accounting Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Public Affairs