INTERNATIONAL 

RELIGIOUS 

FREEDOM ACT

State Department and 

Commission Are 

Implementing 

Responsibilities but 

Need to Improve 

Interaction

Report to Congressional Committees

March 2013

GAO-13-196

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-196, a report to 

congressional committees

March 2013

INTERNATIONAL RELIGIOUS FREEDOM ACT

State Department and Commission Are 

Implementing Responsibilities but Need to Improve 

Interaction 

Why GAO Did This Study

Congress passed the Act in 1998 to 

promote international religious 

freedom, among other purposes. The 

Act established within State the Office 

of International Religious Freedom, 

headed by an Ambassador-at-Large. 

The Act also established USCIRF, with 

the Ambassador-at-Large as an exofficio member. In addition, the Act 

outlined primary responsibilities for 

both State and USCIRF. 

The U.S. Commission on International 

Religious Freedom Reform and 

Reauthorization Act of 2011required 

GAO to report on matters related to the 

U.S. promotion of international 

religious freedom. This report 

assesses (1) State’s implementation of 

its primary responsibilities established 

in the Act, (2) USCIRF’s 

implementation of its primary 

responsibilities established in the Act, 

(3) State’s and USCIRF’s interaction to 

promote religious freedom, and (4) 

NGOs’ views on U.S. efforts to 

promote religious freedom. 

GAO analyzed documents and 

interviewed officials from State, 

USCIRF, NGOs, and foreign 

governments. GAO conducted 

fieldwork in five countries, including 

CPCs, and surveyed 131 NGOs. The 

survey results reflect the views of 

survey respondents and cannot be

generalized. 

What GAO Recommends

GAO recommends that the Secretary 

of State and the Chair of USCIRF 

jointly define how State and USCIRF 

should interact in their efforts to 

promote international religious 

freedom. State and USCIRF concurred 

with GAO’s recommendation.

What GAO Found

The Department of State (State) is implementing the primary responsibilities 

outlined in the International Religious Freedom Act of 1998 (the Act) by 

undertaking numerous actions to promote religious freedom, engaging with 

foreign officials, and annually publishing its International Religious Freedom 

Report. The Ambassador-at-Large and the Office of International Religious 

Freedom assist the Secretary of State with certain responsibilities outlined in the 

Act, including the designation of Countries of Particular Concern (CPC) and the 

development of training. 

The U.S. Commission on International Religious Freedom (USCIRF) is 

implementing its primary responsibilities outlined in the Act by conducting ongoing 

reviews of violations of religious freedom and issuing policy recommendations to 

the U.S. government. According to USCIRF officials, its primary responsibilities 

culminate in the release of its annual report. The report discusses the 20 to 30 

countries that USCIRF considers the worst offenders against religious freedom, 

and it presents policy recommendations to the U.S. government. USCIRF has at 

times also provided technical assistance or recommendations to foreign officials.

Although the Act, as amended, directs State and USCIRF to cooperate, they 

have not defined how they should interact, which has at times created tensions 

with foreign-government officials. For example, in its 2012 report, USCIRF 

recommended that the Secretary of State designate Turkey as a CPC. Because 

the Ambassador-at-Large was not regularly attending USCIRF meetings at the 

time, State officials learned of the commissioners’ intent shortly before USCIRF 

published its report. State officials explained that Turkey did not warrant CPC 

designation, as it had taken steps to improve religious freedom, but USCIRF 

proceeded with its recommendation. According to Turkish officials, USCIRF’s 

report contradicted State’s report and was therefore “null and void.” State officials

told GAO that they had to resolve the resulting tensions with the Turkish 

government. 

Representatives of nongovernmental organizations (NGOs) whom GAO 

surveyed and interviewed generally viewed overall U.S. government efforts to 

promote international religious freedom positively, while raising some concerns 

and suggesting several improvements. To better promote international religious 

freedom, some NGOs suggested greater inclusion of civil society and other 

nonstate actors and further empowerment of U.S. government entities. Likewise, 

NGOs familiar with State’s and USCIRF’s annual reports generally viewed them 

positively, although several raised concerns that both reports lacked objectivity. 

Finally, NGOs generally viewed State’s CPC designations positively, although 

some doubted how useful the designations or recommended designations were 

to their work. NGOs from GAO’s five fieldwork countries provided similar 

opinions.

View GAO-13-196. For more information, 

contact Thomas Melito at (202) 512-9601 or 

melitot@gao.gov.
Page i GAO-13-196 International Religious Freedom Act

Letter 1 

Background 3

State Is Implementing the Primary Responsibilities Established in 

the Act but Has Provided Inconsistent Reporting Policy and 

Guidance for the Ambassador 8

USCIRF Is Implementing Its Primary Responsibilities as Outlined 

in the Act and Has Undertaken Other Activities 23

State and USCIRF Have Not Defined How They Should Interact, 

Which Has at Times Created Foreign Policy Tensions 28

NGOs Generally Rated Overall U.S. Government Efforts Positively 

While Raising Some Concerns and Suggesting Several 

Improvements 33

Conclusions 40

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 41

Appendix I Objectives, Scope, and Methodology 42

Appendix II Comparison of the U.S. Commission on International Religious 

Freedom with Other Select Congressional Commissions 47

Appendix III Analysis of Department of State Cables Concerning 

International Religious Freedom 50

Appendix IV Selected Results from Survey of Nongovernmental 

Organizations 52

Appendix V Comments from the Department of State 61

Appendix VI Comments from the U.S. Commission on International Religious 

Freedom 63

Contents 
Page ii GAO-13-196 International Religious Freedom Act

Appendix VII GAO Contact and Staff Acknowledgments 65

Tables

Table 1: Policy Commissions, Boards and Advisory Bodies That 

Report to U.S. Congress 48

Table 2: Analysis of 178 Cables Sent by U.S. Embassies and 

Consulates, January 2009–October 2012 50

Figures

Figure 1: Timeline Highlighting the Tenure of Each Ambassador-atLarge for International Religious Freedom 5

Figure 2: Timeline Depicting State’s Designation and Removal of 

Countries and Regimes from the Countries of Particular 

Concern (CPC) List 17

Figure 3: Organizational Status of State’s Six Current Ambassadorsat-Large 21

Figure 4: NGOs’ Ratings of the Overall Progress the U.S. 

Government Has Made With Respect to the Specified 

Activities 53

Figure 5: NGOs’ Ratings of the Usefulness of State’s Annual 

International Religious Freedom Report with Respect to 

the Specified Factors 54

Figure 6: NGOs’ Ratings of State’s Annual International Religious 

Freedom Report with Respect to the Specified Factors 55

Figure 7: NGOs’ Ratings of the Usefulness of USCIRF’s Annual 

Report on International Religious Freedom with Respect 

to the Specified Factors 56

Figure 8: NGOs’ Ratings of USCIRF’s Annual Report on 

International Religious Freedom with Respect to the 

Specified Factors 57

Figure 9: NGOs’ Ratings of the Extent to Which State’s CPC 

Designations Have Helped or Hindered the NGOs’ 

International Religious Freedom–Related Work 58

Figure 10: NGOs’ Ratings of the Extent to Which USCIRF’s 

Recommendations for CPC Designations Have Helped or 

Hindered the NGOs’ International Religious Freedom–

Related Work 59
Page iii GAO-13-196 International Religious Freedom Act

Figure 11: NGOs’ Ratings of the Extent to Which They Agree or 

Disagree That the Countries Included in USCIRF’s Annual 

Report Fully Represent the Worst Offenders of Religious 

Freedom 60

Abbreviations

CRS Congressional Research Service

CPC Countries of Particular Concern

DRL Bureau of Democracy, Human Rights, and Labor

NGO nongovernmental organization

UN United Nations

USCIRF U.S. Commission on International Religious 

Freedom

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Page 1 GAO-13-196 International Religious Freedom Act

United States Government Accountability Office

Washington, DC 20548

March 26, 2013

The Honorable Robert Menendez

Chairman

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations

United States Senate

The Honorable Edward R. Royce

Chairman

The Honorable Eliot L. Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

Because of concerns about increasing restrictions on religious rights 

around the world, Congress passed the International Religious Freedom 

Act of 1998 (the Act) to strengthen U.S. advocacy of individuals 

persecuted in foreign countries on account of religion.1 According to the 

Act, more than half of the world’s population was living under 

governments that severely restricted or prohibited freedom of religion. In 

2012, the Pew Research Center reported that approximately 75 percent 

of the world’s population was living in countries with high or very high 

government restrictions on religion or with religious hostilities in society.2

 

1

See International Religious Freedom Act of 1998, Pub. L. No. 105-292, Oct. 27, 1998, as 

amended by later acts such as A Bill to Amend the International Religious Freedom Act of 

1998 to Provide Additional Administrative Authorities to the United States Commission on 

International Religious Freedom, and to Make Technical Corrections to the Act, and for 

other purposes, Pub. L. No. 106-55, Aug. 17, 1999; and the United States Commission on 

International Religious Freedom Reform and Reauthorization Act of 2011, Pub. L. No. 

112-75, Dec. 23, 2011.

The Act established an Office of International Religious Freedom (Office) 

within the Department of State (State), headed by an Ambassador-atLarge, to promote international religious freedom. The Act also 

established the U.S. Commission on International Religious Freedom 

(USCIRF) to review the facts and circumstances of violations of religious 

2

Pew Research Center’s Forum on Religion & Public Life, Rising Tide of Restrictions on 

Religion (Washington, D.C.: 2012).

 
 

Page 2 GAO-13-196 International Religious Freedom Act

freedom and recommend policy actions to the President, Secretary of 

State, and Congress.

The United States Commission on International Religious Freedom 

Reform and Reauthorization Act of 2011 (the Reauthorization Act) 

required us to report to the committees regarding several matters related 

to U.S. promotion of international religious freedom.3

To address our objectives, we analyzed documents from State and 

USCIRF, including grant documents, cables, and annual reports. We also 

met with officials from State and USCIRF, including all three 

Ambassadors-at-Large—two former and one present—as well as all of 

the current and more than half of the former USCIRF commissioners. We 

also conducted fieldwork in Afghanistan, Indonesia, Turkey, Uzbekistan, 

and Vietnam, meeting with U.S. officials and representatives from 

relevant host-government agencies, NGOs, civil society, and religious 

communities. The five countries we selected for fieldwork met at least two 

of the following criteria: (1) State had funded an international religious 

freedom program in the country; (2) the country was on USCIRF’s watch 

list; (3) USCIRF had recommended designating the country, or State has 

designated it, as a Country of Particular Concern (CPC); and (4) the 

Ambassador-at-Large or USCIRF had visited the country in the past 3 

years. We also conducted a survey of 131 NGOs that we identified from a 

variety of sources as working on religious freedom issues. The results of 

the survey, which had a 64 percent response rate, reflect only the views 

of the respondents to our survey and cannot be generalized. See 

appendix I for a more detailed discussion of our scope and methodology.

The Reauthorization 

Act also included a specific requirement that we consult with 

nongovernmental organizations (NGO) in preparing the report. In 

addition, the Reauthorization Act required us to compare USCIRF with 

other commissions. To respond to the mandate, we have assessed (1) 

State’s implementation of its primary responsibilities established in the 

Act; (2) USCIRF’s implementation of its primary responsibilities 

established in the Act; (3) State’s and USCIRF’s interaction in their efforts 

to promote religious freedom; and (4) NGOs’ views on U.S. efforts to 

promote international religious freedom. Appendix II presents our 

comparative analysis of USCIRF and other commissions.

 

3

Pub. L. No. 112-75, Sec. 7, Dec. 23, 2011. 
 

Page 3 GAO-13-196 International Religious Freedom Act

We conducted this performance audit from March 2012 to March 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

In passing the Act, Congress noted that, at that time, more than half of 

the world’s population lived under regimes that severely restricted or 

prohibited citizens from freely observing their religious beliefs. In addition, 

the Act describes government-sponsored and government-tolerated 

violations to religious freedom that people faced, including slander 

campaigns; confiscation of property; denial of the right to assemble; and 

prohibitions against publishing, distributing, or possessing religious 

literature. According to the Act, religious believers in many countries also 

faced severe and violent forms of religious persecution, such as 

imprisonment, torture, beatings, mass resettlement, and death for their 

peaceful belief in, change of, or practice of their faith.

In its findings on religious freedom, the Act refers to the U.S. Constitution 

and various principles of international law. The first amendment of the 

U.S. Constitution established the right to freely exercise religious beliefs, 

and according to the Act, “the right to freedom of religion undergirds the 

very origin and existence of the United States.” In addition, the Act 

highlights principles of international law, such as those outlined in the 

United Nations (UN) Universal Declaration of Human Rights and the 

International Covenant on Civil and Political Rights, which identify 

religious freedom as a universal human right.4

 

4

The UN General Assembly adopted the Universal Declaration of Human Rights on 

December 10, 1948. According to the UN, the Universal Declaration of Human Rights 

complemented the UN charter by providing a road map to guarantee the rights of 

individuals. On December 16, 1966, the UN General Assembly adopted the International 

Covenant on Civil and Political Rights, which provides for the protection of the rights to 

freedom of thought, conscience, and religion. Together, the Universal Declaration of 

Human Rights, the International Covenant on Civil and Political Rights, and the 

International Covenant on Economic, Social, and Cultural Rights make up the 

International Bill of Human Rights.

For example, according to 

Background 

The Act Established 

International Religious 

Freedom as a U.S. Foreign 

Policy Objective
 

Page 4 GAO-13-196 International Religious Freedom Act

the Universal Declaration of Human Rights, “Everyone has the right to 

freedom of thought, conscience, and religion. This right includes freedom 

to change his religion or belief, and freedom, either alone or in community 

with others and in public or private, to manifest his religion or belief in 

teaching, practice, worship, and observance.” 

The Act states that it shall be the policy of the United States to condemn 

violations of religious freedom and to promote and assist other 

governments in the promotion of religious freedom. The Act describes 

several actions that the United States shall take in accordance with this 

policy objective, including the implementation of appropriate diplomatic, 

political, commercial, and other tools to promote respect for religious 

freedom by all governments and peoples. In July 2012, the Secretary of 

State reiterated the U.S. government’s commitment to promote religious 

freedom and said that the administration had elevated religious freedom 

as a diplomatic priority.5 She also discussed her personal diplomatic 

outreach around the world concerning religious freedom and the 

appointment of the first envoy to the Organization of Islamic Cooperation.

In accordance with the Act, State created the Office of International 

Religious Freedom (the Office) in 1999, headed by the Ambassador-atLarge for International Religious Freedom (the Ambassador). State 

placed the Office within the Bureau of Democracy, Human Rights, and 

Labor (DRL). Three individuals have served in this position (see fig. 1).6

 

5

Hillary Clinton, “Remarks at the Release of the 2011 International Religious Freedom 

Report” (address by the Secretary of State given at the Carnegie Endowment for 

International Peace, Washington, D.C., July 30, 2012).

The position has been vacant for approximately 4.5 of the 14 years since 

6

The Secretary of State created the position of Special Adviser for Religious Freedom in 

DRL in August 1998. Robert Seiple served in that position until he was sworn in as the 

Ambassador in May 1999, at which point the Special Adviser position ceased to exist. 

The Act Established Two 

Separate Entities and 

Outlined Their 

Responsibilities 

The Act Established State’s 

Office and Ambassador-atLarge for International 

Religious Freedom and 

Outlined State’s 

Responsibilities
 

Page 5 GAO-13-196 International Religious Freedom Act

the Act’s passage, primarily because of delays in the presidential 

nomination process.7

Figure 1: Timeline Highlighting the Tenure of Each Ambassador-at-Large for International Religious Freedom

The Act outlines four primary responsibilities for the Ambassador: (1) 

promote religious freedom, (2) serve as a principal adviser to the 

President and Secretary of State on religious freedom issues abroad, (3) 

represent the U.S. government diplomatically in matters relevant to 

religious freedom abroad, and (4) report on the status of international 

religious freedom annually. Although the Act directs that the Ambassador 

is the head of the Office, it does not explicitly outline responsibilities for 

the Office. State officials said that the primary responsibilities of the Office 

mirror those established for the Ambassador.

The Act directs the President and the Secretary of State to take certain 

actions in response to violations of religious freedom. Specifically, the Act 

requires the President to designate and take action against CPCs. First, 

the Act requires the President to review the religious freedom situation in 

each country and designate countries as CPCs for “systematic, ongoing, 

egregious” violations of religious freedom. Secondly, the Act requires the 

President, with certain exceptions, to take a range of actions against 

designated countries, unless he waives this provision. The Act includes a 

list of actions the President may take against CPCs, including 

 

7

President Clinton nominated Robert Seiple as the Ambassador in early 1999, a few 

months after the Act’s passage. President Bush nominated John Hanford in November 

2001, 10 months after taking office. President Obama initially nominated Suzan Johnson 

Cook in June 2010, 17 months after taking office. Congress did not act on this nomination. 

President Obama renominated Johnson Cook in February 2011 and she was sworn in on 

May 16, 2011.
 

Page 6 GAO-13-196 International Religious Freedom Act

demarches,8

The Act also established USCIRF, comprising nine volunteer members 

(commissioners); the President, the President pro tempore of the Senate, 

and the Speaker of the House of Representatives each appoints three 

members.

public condemnation, cancellation of a state visit, or 

withdrawal or limitation of development or security assistance. However, 

the President may submit a waiver of any CPC designation for certain 

reasons, including furtherance of the Act’s goals or to support important 

U.S. national interests. The President has delegated these responsibilities 

and authorities to the Secretary of State. Finally, the Act outlines 

additional responsibilities for the Secretary of State, including the 

development of training for Foreign Service officers on religious freedom 

issues and the establishment of an international religious freedom 

website.

9

The Act outlines two primary responsibilities for USCIRF: (1) review the 

facts and circumstances of violations of religious freedom and (2) make 

policy recommendations to the President, Secretary of State, and 

Congress with respect to these matters. In addition, the Act requires the 

commission to issue an annual report setting forth its recommendations 

for U.S. policy options based on its evaluation of the facts and 

Moreover, the Act established that the Ambassador would 

serve ex officio as a nonvoting member of the commission. USCIRF has 

a professional staff and an executive director, in addition to the 

commissioners. 

 

8

A demarche is a formal diplomatic representation of one government’s official position, 

views, or wishes on a given subject to an appropriate official in another government or 

international organization. Demarches generally seek to persuade, inform, or gather 

information from a foreign government. Governments may also use a demarche to protest 

or object to actions by a foreign government. 

9

Specifically, the Act states that of the three members of the commission that are 

appointed by the President pro tempore of the Senate, two shall be appointed upon the 

recommendation of the leader in the Senate of the political party that is not the political 

party of the President, and one shall be appointed upon the recommendation of the leader 

in the Senate of the other political party. Similarly, the Act states that of the three 

members of the commission that are appointed by the Speaker of the House of 

Representatives, two shall be appointed upon the recommendation of the leader in the 

House of the political party that is not the political party of the President, and of which one 

of the members shall be appointed upon the recommendation of the leader in the House 

of the other political party. See Pub. L. No. 105-292, Sec. 201(b) and 22 U.S.C. § 

6431(b)(1)(B). 

The Act Established USCIRF 

and Outlined Its 

Responsibilities
 

Page 7 GAO-13-196 International Religious Freedom Act

circumstances presented in State’s annual report and of information from 

other sources where appropriate. The Act authorized USCIRF to hold 

hearings, and a 1999 amendment to the Act authorized USCIRF to 

conduct travel and to secure information from any federal agency as 

necessary to carry out its duties. Since fiscal year 2000, Congress has 

appropriated more than $42 million for USCIRF’s activities.

The Act established USCIRF as a 4-year commission, and the 1999 

amendment to the Act established that USCIRF would terminate on May 

14, 2003.10 The Act established a 2-year term of office for each 

commissioner and also allowed for the reappointment of each 

commissioner to a second term. In 2002, Congress amended the Act 

again to extend USCIRF’s authority to September 30, 2011, but did not 

establish term limits for commissioners.11 In 2011, Congress extended the 

termination date to September 30, 2014, and implemented some 

additional changes, including placing a limit of two 2-year terms on 

commissioners.12

 

10See Pub. L. No. 106-55, Aug. 17, 1999.

As a result of the term limits, 7 of the 9 commissioners 

at that time were required to leave the commission. Since 1999, 33 

commissioners have served on USCIRF; 9 have served for 5 or more 

years, and 3 have served for 10 or more years.

11Foreign Relations Authorization Act, Fiscal Year 2003, Pub. L. No. 107-228. Section 

681(g), Sept. 30, 2002.

12United States Commission on International Religious Freedom Reform and 

Reauthorization Act of 2011, Pub. L. No. 112-75, Section 6, Dec. 23, 2011. 
 

Page 8 GAO-13-196 International Religious Freedom Act

State, including the Ambassador and the Office, is implementing the 

primary responsibilities outlined in the Act. The Ambassador, with the 

support of the Office, promotes religious freedom, advises the President 

and Secretary of State, represents the United States diplomatically on 

international religious freedom issues, and annually publishes the 

International Religious Freedom Report. Other entities in State, such as 

other offices and embassies, also take actions to implement some of the 

responsibilities outlined in the Act. In addition, the Ambassador and the 

Office support the Secretary of State in implementing some of the 

responsibilities that the Act establishes for the Secretary. However, the 

Ambassadors-at-Large for International Religious Freedom have a lower 

organizational status than State’s other Ambassadors-at-Large, and State 

has provided inconsistent reporting policy and guidance to the 

Ambassadors-at-Large for International Religious Freedom.

The Ambassador and the Office are implementing the primary 

responsibilities that the Act established—namely, promoting international 

religious freedom, advising the President and Secretary of State, 

diplomatically representing the United States with regard to religious 

freedom issues, and publishing an annual report on the status of religious 

freedom worldwide. The Ambassador carries out these responsibilities 

both independently and with the assistance of other State entities, 

including U.S. embassies abroad.

The Ambassador, the Office, and other State entities have undertaken 

actions, in accordance with both the Act and U.S. foreign policy 

objectives, to promote religious freedom. Examples of these activities 

include the following:

• Hosting and participating in events. The Ambassador and the Office 

host, and participate in, events that promote religious freedom and 

tolerance through dialogue. For example, in October 2012, the Office 

and the U.S. Institute of Peace sponsored a public panel discussion 

titled “Religion, Violence, and Coexistence,” at which the Ambassador 

spoke. The event’s discussion focused on (1) civil society’s role in 

preventing and addressing statements of religious bias and (2) ways 

in which civil society and the U.S. government can collaborate to 

advance peaceful religious coexistence, freedom, and security.

State Is Implementing 

the Primary 

Responsibilities 

Established in the Act 

but Has Provided 

Inconsistent 

Reporting Policy and 

Guidance for the 

Ambassador 

State Is Implementing the 

Primary Responsibilities 

Established in the Act

Ambassador and Office Are 

Implementing Primary 

Responsibilities Independently 

and Through Efforts of Other 

State Entities

Ambassador, Office, and Other 

State Entities Promote 

Religious Freedom 
 

Page 9 GAO-13-196 International Religious Freedom Act

• Working directly with foreign governments. State officials said that the 

Ambassador and the Office work directly with foreign government 

officials to promote religious freedom by discussing concerns and 

assisting with the development of concrete steps a government might 

take to improve religious freedom or with legislative changes. For 

example, one Ambassador said that negotiations led to a formal 

public statement in which the government of Saudi Arabia clarified 

policies it had adopted and would pursue in order to improve religious 

freedom for minority faiths and eliminate religiously intolerant material 

from textbooks and other literature used in Saudi Arabia or exported 

abroad.

• Elevating religious freedom issues within State. According to Office 

staff, the Office and the Ambassador continually work to elevate 

religious freedom issues within State. A State official explained that 

Office staff conduct numerous briefings for mid-level and executive 

department officials concerning religious freedom in various countries, 

as the situations warrant. In addition, another State official said that 

Office staff prepare talking points and briefing memorandums for 

senior State officials to use during meetings with foreign-government 

officials, although they told us they do not always know whether the 

officials use the talking points. According to a State official, the 

Ambassador also disseminates religious freedom-related information 

throughout DRL and across State.

• Developing religious freedom–related grants. According to Office staff, 

since 2007, the Office has developed 27 religious freedom–related 

programs with $16.6 million in grants from DRL’s Human Rights and 

Democracy Fund.13 These programs include global initiatives and 

support the promotion of religious freedom across the six regions of 

the world,14

 

13According to the first and second Ambassadors, the Office was responsible for issuing 

some block grants for religious freedom–related efforts during their tenures. However, 

State provided us with documentation for religious freedom–related grants only from 2007 

to the present.

with a focus on changing societal perceptions, attitudes, 

and behaviors. For example, one program supported in-country 

capacity building to establish teams to track, catalogue, and respond 

14State organizes countries into six regions: Africa (sub-Sahara), East Asia and the 

Pacific, Europe and Eurasia, Near East (North Africa and the Middle East), South and 

Central Asia, and the Western Hemisphere.
 

Page 10 GAO-13-196 International Religious Freedom Act

to religious tensions within the country. Our review of 7 of the 27 

program grants found that, in general, the grantees reported that they 

are meeting their grant objectives, such as capacity building and 

public awareness. See appendix I for detailed information concerning 

our grant analysis.

• Undertaking a variety of activities at U.S. embassies. U.S. embassies 

have undertaken a variety of activities to promote religious freedom, 

as indicated in our review of 178 cables that U.S. embassies sent 

from January 2009 to October 2012 addressing religious freedom in 

approximately 60 countries (see app. III for more detailed results of 

our analysis).15 In addition, embassy officials in the five countries 

where we conducted fieldwork described various embassy activities to 

promote religious freedom. For example, some officials told us that 

their embassies organized events to promote religious tolerance and 

dialogue, such as speaker panels; hosted religious holiday dinners 

and roundtable discussions; and met with foreign-government, NGO, 

and religious officials to discuss religious freedom. Embassy officials 

in two countries we visited stated that they do not receive funding 

specifically for religious freedom activities; rather, the embassy uses 

funds from its operational budget account when hosting events to 

promote religious freedom.

• Developing other religious freedom–related programs. Other State 

offices have also undertaken activities to promote religious freedom. 

For example, the Bureau of Educational and Cultural Affairs funds and 

administers the International Visitor Leadership Program, which 

connects current and emerging foreign leaders with their U.S. 

counterparts through short-term professional-exchange programs. 

According to State officials, the program has supported the exchange 

of religious and civil society leaders. In addition, State’s Special 

Representative to Muslim Communities and former Special Envoy to 

Monitor and Combat Anti-Semitism launched a campaign, “2012 

Hours Against Hate,” to promote respect across lines of culture, 

 

15We asked State to provide us with cables concerning international religious freedom 

sent from January 2009 through October 2012. State provided 183 cables, 5 of which 

were duplicates. We analyzed the cables we received to obtain information about the 

activities that U.S. embassies and other U.S. government entities perform to promote 

religious freedom. However, because not all activities are reported in cables, and because 

State may not have located all relevant cables sent during this time period, this analysis 

may not provide a full list of all religious freedom-related activities that State performed 

globally during this time period. 
 

Page 11 GAO-13-196 International Religious Freedom Act

religion, tradition, class, and gender.16

According to the Act, the Ambassador “shall be a principal adviser to the 

President and the Secretary of State regarding matters affecting religious 

freedom abroad.” The former Ambassadors and State officials told us that 

the three Ambassadors-at-Large for International Religious Freedom 

have served as a principal adviser to the President primarily by 

communicating with National Security Staff. For example, the 

Ambassadors and Office staff said that the Ambassadors communicated 

with National Security Staff to discuss religious freedom, including 

potential CPC designations. According to State officials, the current 

Ambassador also participates in the National Security Council’s 

Interagency Policy Committee meetings when religion is a topic of focus.

The initiative involves sending 

requests, via social media, to young people asking them to pledge 1 

hour or more of their time to stop hate by helping someone who does 

not look, live, or pray like them.

The three Ambassadors reported having advised the Secretary of State in 

a number of ways. For example, the first Ambassador said that, in 

addition to meeting with the Secretary of State in person, he provided her 

with notes from his trips to update her on religious freedom in the 

countries he visited. In addition, the Secretary of State occasionally asked 

him for specific advice on interacting with various religious communities. 

Similarly, the second Ambassador said he met occasionally with the 

Secretary of State to discuss religious freedom issues and at times 

participated in the Secretary’s meetings with foreign officials or religious 

leaders. The second and third Ambassadors told us that they also 

provided the Secretary of State with talking points and trip summaries. In 

addition, the current Ambassador said that she has served as an adviser 

to the Secretary of State through her role as a co-chair of the Religion 

 

16The Special Representative and former Special Envoy officially launched “2011 Hours 

Against Hate” at the Organization of Security and Cooperation in Europe in Vienna, 

Austria, on February 17, 2011. In 2012, the program continued as “2012 Hours Against 

Hate.”

Ambassador Advises the 

President and Secretary of 

State
 

Page 12 GAO-13-196 International Religious Freedom Act

and Foreign Policy Working Group, which was part of the former 

Secretary’s Strategic Dialogue with Civil Society.17

The Act authorizes the Ambassador to represent the United States in 

matters relevant to religious freedom abroad, and the Ambassador—as 

well as other State officials—engages with foreign officials with regard to 

international religious freedom. The three Ambassadors have represented 

the U.S. government in multilateral forums and met with foreigngovernment officials and others to promote religious freedom. For 

example, the first Ambassador said that he attended the annual UN 

Human Rights Council meetings in Geneva, and all three Ambassadors 

said they attended UN General Assembly meetings that discussed 

religious freedom. According to the second Ambassador, the purpose of 

the Ambassador at these meetings was to influence the content of 

resolutions and to seek to coordinate policy goals with other U.S. officials 

at the UN. In September 2011, the Secretary of State named the current 

Ambassador as the lead coordinator for the United States on the 

implementation of UN Human Rights Council Resolution 16/18, which the 

UN Human Rights Council passed in March 2011.18 In December 2011, 

the Ambassador hosted the first meeting of experts to promote 

implementation of Resolution 16/18, which 26 governments and 4 

international organizations attended.19

 

17In February 2011, the Secretary of State launched the Strategic Dialogue with Civil 

Society to provide a forum for cooperation and discussion with civil society. The Religion 

and Foreign Policy Working Group was one of six working groups that made up the 

Strategic Dialogue. The other working groups that State created were Governance and 

Accountability, Democracy and Human Rights, Empowering Women, Global Philanthropy, 

and Labor. The current Ambassador co-chaired the Religion and Foreign Policy Working 

Group with the Under Secretary for Civilian Security, Democracy and Human Rights and 

the Executive Director of the White House Office of Faith-based and Neighborhood 

Partnerships. The working groups that made up the Strategic Dialogue with Civil Society 

are no longer meeting, because the Strategic Dialogue was an initiative of Secretary 

Clinton’s. 

In addition, according to State 

officials, all three Ambassadors have traveled abroad to meet with 

18See “Resolution adopted by the UN Human Rights Council, 16/18, Combating 

intolerance, negative stereotyping and stigmatization of, and discrimination, incitement to 

violence and violence against, persons based on religion or belief,” A/HRC/RES/16/18.

19The 3-day meeting focused on the identification of best practices for prohibiting 

discrimination against individuals on the basis of religion or belief, training government 

officials to avoid discrimination, establishing enforcement mechanisms, and engaging with 

members of religious communities.

Ambassador and Other State 

Officials Represent the United 

States Diplomatically 

Regarding Religious Freedom
 

Page 13 GAO-13-196 International Religious Freedom Act

officials of foreign governments, religious organizations, and NGOs to 

discuss religious freedom on behalf of State.

Furthermore, other State officials discuss religious freedom with foreigngovernment and NGO officials and with civil-society and religious leaders. 

For example, when visiting Turkey in 2011, the Secretary of State urged 

the Turkish government to reopen the Halki Seminary in Istanbul as a 

symbol of Turkey’s commitment to religious freedom.20

State has published the International Religious Freedom Report annually 

since 1999, in accordance with the Act.

In addition, many 

of the 178 cables State provided to us described activities that the 

Ambassador or other embassy officials undertook to engage with foreigngovernment and NGO officials and with civil-society and religious leaders 

regarding religious freedom.

21 The report, which involves the 

engagement of embassies worldwide, describes the status of religious 

freedom in every country; identifies government policies that violate 

religious freedom and the persecution of groups, religious denominations, 

and individuals; and discusses U.S. actions and policies to promote 

religious freedom in each country. According to a 2010 report by State’s 

Office of Inspector General,22

 

20In 1971, the Turkish government closed Halki Seminary, a Greek Orthodox theological 

seminary, enforcing a law that placed religious and military training under state control. 

State officials and religious representatives described the seminary as the only school 

where Turkey’s Greek minority educated its clergy. In August 2011, the Turkish 

government adopted a decree to return all confiscated property belonging to minority 

foundations in Turkey. On January 11, 2013, Turkey’s Council of Foundations announced 

that it had agreed to return approximately 470 acres of forest land to the Halki Seminary.

the International Religious Freedom Report

is among the most resource intensive of the 310 congressionally 

mandated reports for which State is responsible, because it requires 

21Although State has published the International Religious Freedom Report every year 

since 1999, the time period covered by the reports has changed over time. The 1999 

report covered an 18-month period from January 1, 1998, to June 30, 1999. The 

subsequent 11 annual reports covered 12-month periods from July 1 of the year before 

the report was issued to June 30 of the year in which the report was issued. In 2010, to 

shift to a calendar-year reporting period, State published a second report covering the 6 

months from July 1, 2010, through December 31, 2010. The 2011 report thus represented 

the first report to correspond to the full calendar year. State expects reports for 2012 and 

subsequent years to continue on the full-year schedule.

22U.S. Department of State and the Broadcasting Board of Governors Office of Inspector 

General, Inspection of Department-Required and Congressionally Mandated Reports: 

Assessment of Resource Implications, ISP-I-11-11 (Washington, D.C.: 2010). 

State Annually Publishes the 

International Religious 

Freedom Report 
 

Page 14 GAO-13-196 International Religious Freedom Act

significant additional resources in Washington, D.C., and in the field. For 

example, while other mandated reports are based largely on regular 

embassy reporting, embassies must obtain additional information to write 

the International Religious Freedom Report.

23 State officials told us that 

the Office works with Foreign Service officers worldwide to write the 

report24

The Act establishes several responsibilities that the Secretary of State 

conducts with the assistance of the Ambassador and the Office. These 

include designating CPCs,

and that drafting and publication of the report involves a number 

of review phases. According to Foreign Service officers in our five 

fieldwork countries, they undertake a number of activities—such as 

monitoring court cases related to religious freedom and maintaining 

relationships with religious communities, religious leaders, civil society, 

NGOs, and foreign-government officials throughout the year—to gather 

information for the report. After they complete the initial drafts, numerous 

offices and bureaus in Washington review and revise the draft country 

reports through an iterative process. Before finalizing the report, 

embassies and various State offices approve each country report and 

relevant sections.

25

 

23In 2010, the Inspector General concluded that State’s Human Rights Report, Trafficking 

in Persons Report, and International Narcotics Control Strategy Report are also among 

the most resource intensive of the 310 congressionally mandated reports for which State 

is responsible. We have previously reviewed State’s process for preparing the Human 

Rights Report and the Trafficking in Persons Report; see GAO, Human Rights: State 

Department Followed an Extensive Process to Prepare Annual Country Reports, 

developing religious freedom–related training 

for Foreign Service officers, including chiefs of mission, and establishing 

an international religious freedom website.

GAO-12-561R (Washington, D.C.: May 31, 2012) and Human Trafficking: Better Data, 

Strategy, and Reporting Needed to Enhance U.S. Antitrafficking Efforts Abroad, 

GAO-06-825 (Washington, D.C.: July 18, 2006).

24According to a State official, since 2010, the Office has issued detailed annual guidance 

to U.S. embassies that covers each section of the report, suggests sources, and identifies 

types of data to include or exclude when assessing the status of religious freedom in a 

country.

25The Act assigned the responsibility for making CPC designations to the President, and 

the President delegated this responsibility to the Secretary of State in 1999.

Ambassador and Office 

Support the Secretary of State 

in Implementing Other 

Responsibilities Established in 

the Act 
 

Page 15 GAO-13-196 International Religious Freedom Act

State Has Designated Countries of Particular Concern, and the U.S. 

Government Has Taken Some Corresponding Actions

In response to the Act, the Secretary of State has reviewed the status of 

religious freedom in each foreign country and designated those countries 

whose government has engaged in, or tolerated, particularly severe 

violations of religious freedom as CPCs. State officials said that the 

Secretary of State tasks the Office with the development of CPC 

recommendations. State does not designate CPCs every year, and 

according to State officials, the Act does not require the agency to do so. 

A State official said that the Office develops the recommendations based 

on its assessment of many factors, including (1) whether the government 

is restricting rights or is complicit in allowing certain groups to be targeted 

and (2) whether issues are systematic, egregious, and ongoing. 

According to State officials, the Office reviews the International Religious 

Freedom Report and consults with the Ambassador, DRL management, 

and others within and outside State when developing recommendations 

for the CPC list. For example, the Office meets with USCIRF officials and 

considers their recommendations. The Office also discusses the CPC 

recommendations with National Security Staff. On the basis of the 

Office’s recommendations, the Ambassador and DRL management 

determine the final list of countries they will recommend for CPC 

designation to the Secretary of State.

The Secretary of State periodically designates CPCs after reviewing the 

recommendations that the Ambassador and DRL management provide. 

Since 1999, Secretaries of State have designated CPCs at least nine 

times, designating 10 countries as CPCs: Burma, China, Eritrea, Iran, 

Iraq, North Korea, Saudi Arabia, Sudan, Vietnam, and Uzbekistan (see 

fig. 2).26

 

26The Act generally requires designation of CPCs to be published in the Federal Register, 

but State has not always taken this action, making it difficult to determine every instance in 

which a Secretary of State designated countries.

In addition, the Secretary of State designated two regimes as 

particularly severe violators of religious freedom—the Milošević regime in 

Serbia and the Taliban regime in Afghanistan. To date, Iraq, Vietnam, the 

Milošević regime, and the Taliban regime are the only entities that State 
 

Page 16 GAO-13-196 International Religious Freedom Act

has removed from the CPC list.27

 

27State designated the Milošević regime in Serbia as a CPC in 1999 and 2000 but 

withdrew the designation after the Milošević regime was removed from power in 2001. 

State designated the Taliban regime as a CPC in 1999, 2000, and 2001. In March 2003, 

State designated CPCs but did not designate the Taliban regime. According to the 2003 

International Religious Freedom Report, in December 2001, the U.S. government 

discussed religious freedom with Afghan officials, after the fall of the Taliban regime. State 

designated Iraq as a CPC in 1999, 2000, 2001, and 2003. State removed Iraq from the list 

in 2004 after the fall of Saddam Hussein and the development of a transitional 

government.

After State designated Vietnam as a 

CPC in 2004, the Ambassador negotiated an action plan with the 

Vietnamese government whereby the government, among other things, 

would pass a law to reduce religious persecution. On the basis of 

subsequent actions by the Vietnamese government, State removed 

Vietnam from the list in 2006. Similarly, the current Ambassador and her 

staff recently developed an action plan to help the government of another 

designated country identify actions that, if taken, could support the 

removal of the country from the CPC list.
 

Page 17 GAO-13-196 International Religious Freedom Act

Figure 2: Timeline Depicting State’s Designation and Removal of Countries and Regimes from the Countries of Particular 

Concern (CPC) List

Note: The Secretary of State designated the Milošević regime in Serbia and the Taliban regime in 

Afghanistan as particularly severe violators of religious freedom with Country of Particular Concern 

status.

The Act requires the President to take action against CPCs following their 

designation, although certain exceptions exist and the President may 

waive application of these actions.28

 

28For example, the President is not required to take action if, among other factors, the 

President took action against the CPC pursuant to the Act in the preceding year. See 

Section 402(c)(4) of Pub. L. No. 105-292, codified at 22 U.S.C. § 6442(c)(4).

The President delegated these 
 

Page 18 GAO-13-196 International Religious Freedom Act

responsibilities to the Secretary of State. Although the Secretary imposed 

sanctions specific to religious freedom in 2005 on Eritrea, in other cases 

the Secretary of State has adopted existing sanctions in response to the 

CPC designation. The Secretary has waived sanctions for both Saudi 

Arabia and Uzbekistan, consistent with the authorities of the Act. 

State Developed Religious Freedom Training

The Ambassador, the Office, and DRL have supported State’s Foreign 

Service Institute in the development of training related to religious 

freedom. The Act required the Secretary of State, with the assistance of 

the Ambassador, to establish instruction on the internationally recognized 

right to freedom of religion and the various manifestations of violations of 

religious freedom, as part of the standard training for Foreign Service 

officers, including chiefs of mission, provided after January 1, 1999. State 

has taken steps to implement this requirement. For example, in June 

1999, the Foreign Service Institute added religious freedom to the 

Political/Economic Tradecraft course—a 3-week course that is mandatory 

for political and economic officers—in a 90-minute session covering 

human rights. This session may include topics such as religious freedom, 

trafficking in persons, gender issues, and labor issues. In addition, during 

a required 6-week mandatory orientation course, new Foreign Service 

officers attend a 1-hour session on human rights that includes information 

about international religious freedom. Finally, State requires chiefs of 

mission to take a 2-week ambassadorial seminar, which includes a 45-

minute session on global issues, including human rights.

In addition, the Foreign Service Institute, the Office, and DRL developed 

an optional, 3-day, religious freedom–specific course titled “Religion and 

Foreign Policy,” which they piloted in June 2011. The Foreign Service 

Institute expanded the course to 4 days in January 2012. State has now 

offered the “Religion and Foreign Policy” course three times. Thirty-four of 

the 60 students who have taken the course are Foreign Service officers. 

In addition, the Foreign Service Institute is working with DRL and the 

Office to develop an optional distance-learning course on drafting State’s 

annual Human Rights Report and, possibly, the International Religious 

Freedom Report. 

Furthermore, before and after the Act was passed, the Foreign Service 

Institute provided relevant training in other courses in which religious 

freedom is one of many components. For example, starting in August 

1993, the Foreign Service Institute added a short segment on religious 

freedom to the human rights module of its 2-day Global Issues course. In 
 

Page 19 GAO-13-196 International Religious Freedom Act

2003, the Foreign Service Institute combined the 1-day Human Rights 

Workshop with the Global Issues course. The revised course, titled 

“Global Issues and Human Rights Workshop,” contained a 1-hour and 45-

minute case-study segment related to religious freedom.29

State Established an International Religious Freedom Website

The Act directs the Secretary of State, with the assistance of the 

Ambassador, to establish and maintain a website containing relevant 

religious freedom documents to facilitate NGOs’ and the public’s access 

to international documents on the protection of religious freedom. State 

has established a website for the Office that includes documents that may 

be useful for NGOs and the public seeking information about religious 

freedom. For example, the website provides a link to the annual 

International Religious Freedom Reports and links to relevant legislation, 

UN websites, some international agreements and declarations, NGOs’ 

websites, and international organizations’ websites. The website also 

includes a section for press releases and remarks made by some State 

officials regarding religious freedom, including press releases and 

remarks from the first and current Ambassadors’ tenures.

The Ambassador’s organizational status in State is lower than that of 

other Ambassadors-at-Large. The Act established the position but does 

not designate the Ambassador’s organizational status. However, the 

other five current Ambassadors-at-Large within State report to higherlevel officials than does the Ambassador. Two Ambassadors-at-Large 

report directly to the Secretary of State, and three report to an Under 

Secretary. In contrast, in 1999 State placed the Ambassador in a bureau 

and under the direction of a lower-level official, the Assistant Secretary for 

DRL. At that time, State had two other Ambassadors-at-Large, both of 

whom reported directly to the Secretary of State. According to the State 

Inspector General’s 2005 report, the Executive Secretariat had a longstanding goal of avoiding growth in the number of officials reporting to the 

 

29In October 2010, the Foreign Service Institute replaced the Global Issues and Human 

Rights Workshop course with a new, 5-day course, “Promoting Human Rights and 

Democracy,” which contains a 60- or 90-minute segment dedicated to promoting religious 

freedom. 

Ambassador’s 

Organizational Status Is 

Lower Than Other 

Ambassadors’-at-Large, 

and State Has Provided 

Inconsistent Reporting 

Policy and Guidance
 

Page 20 GAO-13-196 International Religious Freedom Act

Secretary.30 A senior State official also told us that the location of an 

office is at the discretion of the Secretary of State. However, according to 

State’s organizational structure guidelines,31

 

30The Executive Secretariat, which consists of the Executive Secretary and four Deputy 

Executive Secretaries, is responsible for coordinating State’s internal work and serving as 

the liaison between State’s bureaus and the offices of the Secretary, Deputy Secretary, 

and Under Secretaries. The secretariat also handles State’s relations with the White 

House, the National Security Council, and other cabinet agencies.

an Ambassador-at-Large is 

ranked higher than an Assistant Secretary. Moreover, as figure 3 shows, 

the current Ambassador is the only Ambassador-at-Large who reports to 

an Assistant Secretary.

31State’s organizational guidelines categorize the Secretary of State at organizational level 

1, Deputy Secretaries at level 1a, Under Secretaries at level 1b, Ambassadors-at-Large at 

level 1c, and Assistant Secretaries at level 2. The guidelines also note that there are some 

exceptions to the basic nomenclature but that the exceptions are, for the most part, 

reflected in specific legislative requirements. See U.S. Department of State, Foreign 

Affairs Manual, Volume 1: Organization and Functions, 1 FAM 014.3 Organizational 

Nomenclature. 
 

Page 21 GAO-13-196 International Religious Freedom Act

Figure 3: Organizational Status of State’s Six Current Ambassadors-at-Large

State has also applied and provided inconsistent reporting policy and 

guidance to the Ambassadors. For example, State officials told us that 

each of the three Ambassadors received different reporting guidance that 

did not necessarily reflect the organizational chart. The first Ambassador 

said that State placed him in DRL but that no one at State explained 

whom he was to report to or provided related documentation. He said that 

he reported directly to the Secretary of State. The second Ambassador 

said that he also did not receive documents or briefings concerning his 

reporting structure and that he reported to the Assistant Secretary. 
 

Page 22 GAO-13-196 International Religious Freedom Act

Furthermore, according to State officials, DRL management told the 

current Ambassador that, although she officially reports to the Assistant 

Secretary, she would have to report primarily to the Principal Deputy 

Assistant Secretary or another Deputy Assistant Secretary.

In addition, State’s Office of Inspector General found in 2003 that the 

then-Ambassador’s organizational status—which mirrors the current 

Ambassador’s organizational status—confused reporting relationships.32

At that time, the Inspector General concluded that the arrangement in 

which the Ambassador reports to and through the Assistant Secretary for 

DRL appeared at odds with State’s own organizational guidelines. The 

Inspector General recommended that DRL, the Office of the Under 

Secretary for Global Affairs,33 and the Office of the Under Secretary for 

Management reexamine the role and organizational status of the 

Ambassador. In a 2005 follow-up review, the Inspector General reported 

that, although the three groups had reviewed the role and organizational 

status of the Ambassador following the 2003 report, they had decided that 

the Ambassador and the Office would continue to reside in DRL.34

 

32U.S. Department of State Office of Inspector General, Report of Inspection: Bureau of 

Democracy, Human Rights and Labor, ISP-I-03-48 (Washington, D.C.: 2003).

The 

Inspector General also reported that DRL had said that a number of 

coordination and communications issues had been successfully 

addressed, citing the 2004 decision of the Deputy Secretary of State to 

allow the second Ambassador to communicate directly with the Secretary 

on policy issues through memoranda. In its 2005 follow-up review, the 

Inspector General closed its 2003 recommendation. However, the Deputy 

Secretary’s decision was reversed sometime before the current 

Ambassador took office. It is not clear when or who within State reversed 

the decision; however, according to State officials, the current 

Ambassador has been required to send memorandums jointly with the 

Assistant Secretary of DRL since the beginning of her tenure. In addition, 

33In 2010, the Secretary of State’s Quadrennial Diplomacy and Development Review 

called for State to respond to the political, social, and economic challenges of the 

21st century. In early 2012, Secretary Clinton realigned State’s bureaus and offices to 

implement the results of the review. During this reorganization, the existing Bureau for 

Democracy and Global Affairs was renamed as the Bureau for Civilian Security, 

Democracy, and Human Rights.

34U.S. Department of State and Broadcasting Board of Governors Office of Inspector 

General, Compliance Follow-up Review of Bureau of Democracy, Human Rights, and 

Labor, ISP-C-05-41 (Washington, D.C.: 2005).
 

Page 23 GAO-13-196 International Religious Freedom Act

although the Inspector General closed the recommendation from its 2003 

review, it noted that DRL and the Office agreed that difficulties continued 

to arise from the Ambassador’s organizational status and that at some 

point in the future, the structure should be fundamentally addressed and 

resolved.35 However, State has not fully addressed the concerns that the 

Inspector General raised in 2003 and 2005 and continues to require the 

current Ambassador to report to and through the Assistant Secretary of 

DRL.

USCIRF is implementing its primary responsibilities as outlined in the Act 

by conducting an ongoing review of violations of religious freedom 

throughout the world and issuing policy recommendations to the 

President, the Secretary of State, and Congress. According to USCIRF 

officials, the culmination of these activities is the release of its own annual 

report on international religious freedom, which the Act also requires.36

Based on USCIRF’s ongoing reviews, the report discusses the 20 to 30 

countries that USCIRF considers the worst offenders of religious freedom 

and presents policy recommendations to the U.S. government. In addition 

to performing these activities, USCIRF has at times provided technical 

assistance or recommendations to foreign officials through meetings, 

letters, press releases, or editorials.

In accordance with the Act, USCIRF conducts an ongoing review of 

violations of religious freedom throughout the world by undertaking 

independent research and reviewing State’s annual International 

Religious Freedom Report. USCIRF staff members are responsible for 

specific regions of the world or thematic areas and information collection 

from a range of sources, including religious communities, NGOs, and 

U.S. and foreign-government officials as well as from documentation and 

media reports on those countries. USCIRF officials stated that they 

 

35In 2005, State’s Inspector General urged DRL to revisit the concern at a future date. In 

addition, the Inspector General noted that the Office of Inspector General would look 

closely at this matter again during the bureau’s next inspection. However, the Inspector 

General has not conducted an inspection of DRL since that time.

36In our report, “USCIRF officials” refers to the commissioners and USCIRF staff, unless 

otherwise noted. It does not refer to the Ambassador, who serves as an ex-officio member 

of the commission. 

USCIRF Is 

Implementing Its 

Primary 

Responsibilities as 

Outlined in the Act 

and Has Undertaken 

Other Activities

USCIRF Conducts Ongoing 

Review of the 

Circumstances of 

Religious Freedom 

Violations 
 

Page 24 GAO-13-196 International Religious Freedom Act

interact with a network of NGOs through various international religious 

freedom working groups, roundtables, seminars, and conferences as well 

as through State contacts. USCIRF officials also travel abroad to observe 

conditions and meet with U.S. embassy and foreign-government officials

and NGO officials and members of religious communities. For example, 

according to USCIRF staff, at their request State officials in Turkey 

organized a roundtable of NGOs to brief USCIRF commissioners on 

religious freedom issues during their 2011 visit to the country. Similarly, in 

the United States, USCIRF officials meet with members of religious 

communities, including diaspora communities, NGOs, human rights 

activists, dissidents, victims of religious freedom violations, academics, 

experts, and U.S. and foreign-government officials. USCIRF staff engage 

with their counterparts in State’s Office of International Religious Freedom 

and the relevant officers in State’s regional bureaus to understand the 

conditions of religious freedom in various countries and U.S. government 

efforts to promote religious freedom in those countries. According to 

USCIRF staff, they also review and independently verify the 

characterization of facts and the status of religious freedom in State’s 

annual report.

In accordance with the Act, USCIRF provides policy recommendations to 

the President, the Secretary of State, and Congress through various 

means. According to USCIRF officials, the primary mechanism for 

providing recommendations is its annual report. Specifically, the chapter 

for each country in the USCIRF report contains a list of recommendations 

for U.S. government action with regard to religious freedom in that 

country. For example, in the 2010 report’s chapter on Eritrea, USCIRF 

made 20 recommendations, including that the U.S. government should 

continue to designate Eritrea as a CPC, should impose targeted 

sanctions against individuals and institutions identified as responsible for, 

or complicit in, serious human rights abuses, and should prohibit any 

foreign company’s raising capital or listing its securities in the United 

States while engaged in developing Eritrea’s mineral resources.37

 

37See USCIRF, Annual Report 2010 (Washington, D.C.: May 2010), 52.

USCIRF also provides recommendations to the U.S. government through 

correspondence, congressional testimony, press releases, editorials, and 

policy briefs. In addition, USCIRF officials stated that they provide 

recommendations during meetings with State and other executive branch 

USCIRF Provides Policy 

Recommendations 
 

Page 25 GAO-13-196 International Religious Freedom Act

officials and their staff and members of Congress and their staff. For 

example, in a July 2012 letter to the Secretary of State, USCIRF 

recommended that the U.S. government work with the new Egyptian 

government to (1) ensure that a portion of U.S. military assistance is used 

to help Egyptian police assess security needs for protecting religious 

minority communities and (2) undertake reforms to promote religious 

freedom. USCIRF staff first draft these documents and recommendations, 

which the commissioners then review and approve with a majority vote.

According to USCIRF officials, the culmination of USCIRF’s primary 

responsibilities is the release of its annual report. The report, based on 

USCIRF’s ongoing reviews, discusses the 20 to 30 countries that 

USCIRF considers the worst offenders of religious freedom. The report 

also presents policy recommendations to the U.S. government with 

regard to religious freedom in each of those countries. USCIRF officials

stated that the annual report covers a smaller number of countries than 

the State report because the USCIRF report focuses only on countries in 

which religious freedom violations occur and because USCIRF does not 

have the resources needed to report on the status of religious freedom in 

every country. According to USCIRF officials, staff first provide 

recommendations to the commissioners regarding the countries that 

should be included in the report, on the basis of (1) the staff’s ongoing 

monitoring of religious freedom and (2) trends or changes in countries 

that USCIRF observed in its prior-year report. Commissioners then 

discuss and vote on which countries to include, on the basis of the staff 

recommendations and the commissioners’ interests, knowledge, and 

deliberations. The report contains three sections that, respectively,

• highlight the countries that USCIRF recommends that the Secretary of 

State designate as CPCs for particularly severe violations of religious 

freedom;

• focus on the countries USCIRF has placed on a watch list for serious 

violations of religious freedom that do not meet the CPC threshold but 

require very close attention; and

• discuss other countries and issues of concern.

The CPC and watch list sections of the report are divided by country and 

includes a summary of religious freedom conditions in that country, U.S. 

government policies and actions taken in the country, and policy 

recommendations for the U.S. government.

USCIRF’s Annual Report 

Focuses on Countries That 

USCIRF Considers the 

Worst Offenders
 

Page 26 GAO-13-196 International Religious Freedom Act

USCIRF officials stated that the policy directors, the executive director, 

and commissioners review the report for accuracy and tone. USCIRF staff 

said that they verify information in the report with State officials, NGOs, 

and religious communities. Commissioners deliberate and vote on which 

countries they want to categorize as CPCs, place on the watch list, or 

identify as additional countries of concern. After commissioners make a 

determination for each country, staff members prepare the country 

chapters and circulate them to the commissioners for review. 

Commissioners’ dissenting opinions are included in the report when

voting is not unanimous. For example, in USCIRF’s 2012 annual report, a 

commissioner dissented from the CPC recommendation for Iraq, stating 

that USCIRF’s report, among other things, did “not establish either that 

the government [of Iraq] engaged itself in severe violations or that it 

tolerated them.” Further, the commissioner stated that USCIRF’s report 

“only establishes the existence of such violations and the inability of the 

government to prevent them always (or prevent them often).”38

In addition to carrying out the primary responsibilities laid out in the Act, 

USCIRF at times has provided technical assistance and 

recommendations to foreign officials through meetings, letters, press 

releases, and editorials. Examples of these activities include the 

following.

• Meetings with foreign officials. During meetings abroad, USCIRF has 

provided assistance to foreign governments and at times has called 

directly for policy changes. For instance, according to USCIRF’s 2011 

annual report, USCIRF worked with members of the Indonesian 

House of Representatives and civil society groups to introduce 

measures to strengthen criminal code provisions regarding attacks on 

religious gatherings and to amend laws governing the building of 

religious venues. Further, during its 2011 visit to Saudi Arabia, 

USCIRF said that it called on high-level Saudi officials to release longterm religious prisoner Hadi Al-Mutif from prison and raised concerns 

about six young Shi’a Muslim prisoners.39

 

38USCIRF, Annual Report 2012 (Washington, D.C.: March 2012), 106.

39According to USCIRF, Hadi Al-Mutif has been jailed for apostasy since 1994 and is one 

of the longest-serving religious prisoners in the world.

USCIRF Has Provided 

Technical Assistance and 

Recommendations to 

Foreign Officials
 

Page 27 GAO-13-196 International Religious Freedom Act

• Writing letters to foreign officials. USCIRF provided policy 

recommendations to foreign officials through letters. In June 2010, 

USCIRF wrote a letter to the Ambassador of the Republic of Turkey 

about reports of Turkish government interference in the election of the 

Armenian Orthodox Patriarch, requesting additional information and 

urging the removal of governmental constraints on such internal 

church matters. In June 2011, USCIRF wrote to the Head of Mission 

of the Government of South Sudan, providing a review of the draft of 

the Government of South Sudan’s interim constitution and offering 

suggestions to strengthen the freedom of religion or belief provisions.

• Writing press releases. According to USCIRF officials, it issues press 

releases in response to current events and at times has used press 

releases to urge foreign officials to take actions. For example, in a 

May 2011 press release, USCIRF provided recommendations to the 

government of Egypt. USCIRF recommended, among other things, 

that the government establish a special unit in the Office of the Public 

Prosecutor that would be dedicated to investigating acts of violence 

against Egyptian citizens on the basis of religion or belief, particularly 

Coptic Orthodox Christians; vigorously prosecuting, and bringing to 

justice, perpetrators of these acts; and ensuring compensation for 

victims. In addition, in a July 2012 press release, USCIRF urged 

China’s government to lift its restrictions on all peaceful religious 

activities in the Xinjiang Uighur Autonomous Region, especially during 

the Muslim holy month of Ramadan.

• Writing editorials. USCIRF commissioners have written editorials that 

also urge foreign officials to take actions related to religious freedom. 

For example in a November 2011 editorial, USCIRF commissioners 

stated that Pakistan’s government should replace current public 

school textbooks with ones that exclude messages of intolerance, 

hatred, or violence based on religious or other differences. Also, in a 

January 2012 editorial, USCIRF commissioners wrote that “Nigeria’s 

political establishment, including President Goodluck Jonathan and 

other leaders, should muster the will and courage not only to curb the 

strife but to bring all perpetrators to justice.”40

 

40Leonard A. Leo and Rev. William Shaw, “In Nigeria, Getting Away with Murder: The 

Government in Africa's Most Populous Country Turns a Blind Eye to Violence between 

Muslims and Christians,” Baltimore Sun, January 23, 2012, accessed February 19, 2013,

http://www.baltimoresun.com/news/opinion/oped/bs-ed-nigeria20120123,0,6743343.story. 
 

Page 28 GAO-13-196 International Religious Freedom Act

Although the Act, as amended, directs State and USCIRF to cooperate, 

they have not defined how they should interact. As a result, their level of 

interaction has fluctuated over the years, although it has recently 

increased after a period of little interaction. In addition, State and USCIRF 

have at times conveyed inconsistent information to foreign-government 

officials on U.S. foreign policy, creating tensions that State has had to 

mitigate.

The Act created two separate entities that are to cooperate and work on 

behalf of international religious freedom, yet the Act does not prescribe 

how State and USCIRF should interact and coordinate their efforts. The 

Act establishes the Ambassador as an ex-officio member of USCIRF and 

states that the Ambassador is to consider USCIRF’s advice in making 

policy recommendations. In addition, the Act states that the Secretary of 

State is to consider USCIRF’s recommendations in preparing the annual 

report on international religious freedom. A 1999 amendment to the Act 

directs USCIRF to cooperate with State, stating that “[t]he commission 

shall seek to effectively and freely cooperate with all entities engaged in 

the promotion of religious freedom abroad, governmental and 

nongovernmental, in the performance of the commission’s duties,” 

specifically listing State among those entities.41

Although both USCIRF and State are to promote international religious 

freedom, USCIRF is a commission focused on a single issue, while State 

is a U.S. department that must consider other foreign policy issues.

At the same time, the Act 

originally directed that the commission would terminate four years after 

the initial appointment of all of the commissioners. 

42

 

41Pub. L. No. 106-55, Sec. 1, 113 Stat. 403, Aug. 17, 1999.

Both State and USCIRF officials said that this arrangement sometimes 

sets up a “good cop/bad cop” relationship. For example, USCIRF may 

raise a particular country’s religious freedom issues that State wants to 

address but that may be too sensitive for State to broach, given other 

bilateral considerations. State officials also said that USCIRF’s criticisms 

42According to USCIRF, the commission is independent, bipartisan, and dedicated to 

defending the universal right to freedom of religion or belief abroad.

State and USCIRF

Have Not Defined 

How They Should 

Interact, Which Has at 

Times Created 

Foreign Policy 

Tensions 

Act Directs State Office 

and USCIRF to Cooperate, 

but Agencies Have Not 

Defined How They Should 

Interact
 

Page 29 GAO-13-196 International Religious Freedom Act

of a country’s religious freedom situation can create a line of 

communication for State if, for instance, that country’s officials then 

decide they want to work with State to determine how they can stay off of 

the official CPC list. The Act also requires USCIRF to conduct an “annual 

and ongoing review of the facts and circumstances of violations of 

religious freedom presented [in State’s reports]” as well as make policy 

recommendations to the Secretary of State, among others. At the same 

time, the Ambassador, as an ex-officio member of USCIRF, sits on a 

commission that gives recommendations to the Ambassador’s agency.

All of the Ambassadors and many of the commissioners we spoke with 

said that they have never jointly defined how they should interact. Former 

and current commissioners expressed various ideas about the ex-officio 

role of the Ambassador; for example, commissioners stated that the 

Ambassador should participate in every USCIRF meeting and share 

information, that the Ambassador’s role was irrelevant to USCIRF’s work, 

and that the Ambassador should not participate in USCIRF discussions. 

Some former commissioners said that without the Ambassador’s regular 

participation, USCIRF had difficulty getting access to State policymakers 

to discuss religious freedom. One former commissioner said that such 

access would have enriched USCIRF’s recommendations. At the same 

time, two of the current commissioners said that USCIRF could improve 

its efforts to understand State’s diplomatic efforts with regard to religious 

freedom.

The Ambassadors also provided varying interpretations of the ex-officio 

role. They said, for example, that the Ambassador should be an active 

participant at USCIRF meetings during every discussion, short of voting; 

that the Ambassador’s role was to explain State activities and actions to 

USCIRF and that USCIRF, conversely, should include the Ambassador 

on e-mails and other forms of internal communication; and that the 

Ambassador has no clear role on USCIRF but should try to attend as 

many USCIRF commissioner meetings as possible. One of the 

Ambassadors said that commissioners did not always include him in email conversations and exchanges, resulting in a loss of communication. 

For example, he said that at times commissioners withheld documents 

and e-mail communications from the Ambassador’s office or only shared 

drafts of press releases at the last minute, thereby inhibiting the 

Ambassador’s ability to convey State’s perspective or correct factual 

errors.
 

Page 30 GAO-13-196 International Religious Freedom Act

The level of interaction between the Ambassador and USCIRF has varied 

greatly over the years. According to the first Ambassador and USCIRF 

officials, the first Ambassador attended USCIRF’s monthly meetings, 

participated in their monthly teleconferences, and traveled overseas with 

the USCIRF chair on one occasion. However, that Ambassador said he 

had discussed his ex-officio role with USCIRF only once, during a debate, 

when a commissioner told him he should not be participating. State and 

USCIRF officials told us that the second Ambassador began his tenure by 

regularly attending the monthly USCIRF meetings, but he attended less 

frequently over time. Former State officials and USCIRF officials said that 

both entities considerably decreased their official communication, in part 

because of disagreement over how they should work together.

As the level of interaction between the Ambassador and commissioners 

has varied over the years, so has the level of interaction between their 

staffs. According to State and USCIRF officials, when the Ambassador 

and commissioners had little official interaction, their staffs had little 

interaction as well, although they did try to maintain some informal 

collaboration. For example, according to one former Office staff member, 

during a period of little official interaction and even discouragement of 

staff interaction, he and the USCIRF executive director began meeting for 

lunch to maintain a line of communication. In addition, a former 

commissioner noted that when the Ambassador’s position was vacant for 

2 1⁄2 years, USCIRF’s contact with State was primarily at the staff level.

More recently, according to the current Ambassador and USCIRF 

officials, they have increased their interaction from its previously low level, 

with both a new Ambassador and a largely new commission in place. For 

example, from 2009 to 2011, USCIRF and State officials, including 

officials from the Office of International Religious Freedom, collaborated 

on efforts that led to the passage of UN Resolution 16/18 to combat 

religious intolerance. The Ambassador now participates in the lunchtime 

portions of discussions during some of the monthly meetings, although 

she generally does not participate in USCIRF’s monthly teleconferences. 

The Ambassador and the current USCIRF chair also have been joint 

presenters at various forums, both in the United States and abroad. In 

October 2012, for example, they gave a joint speech on religious freedom 

at Europe’s largest annual human rights and democracy conference, 

sponsored by the Organization for Security and Co-operation in Europe. 

In addition, staff from the Office and USCIRF staff stated that they share 

information with each other more now than in the past. State and USCIRF 

officials told us that this information sharing recently helped USCIRF 

determine whether to elevate a country from its watch list to its CPC 

State and USCIRF’s 

Interaction Has Fluctuated
 

Page 31 GAO-13-196 International Religious Freedom Act

recommendation list. State and USCIRF officials discussed the issues as 

well as actions that State would take with the country’s officials. Their 

interaction resulted in USCIRF’s keeping the country on its watch list 

rather moving it to the CPC list.

All three Ambassadors and a few commissioners told us that the limited 

interaction between State and USCIRF, arising from a lack of a definition 

of how they should interact, had sometimes created tensions with foreigngovernment officials. For example, USCIRF recommended in its 2012 

annual report that the Secretary of State designate Turkey as a CPC. The 

Ambassador was not regularly attending USCIRF meetings at the time, 

and State officials learned of USCIRF’s intent to recommend Turkey only 

shortly before USCIRF published its report in March 2012. State officials 

tried to engage the commissioners and explain State’s position against 

such a recommendation, but USCIRF proceeded to recommend Turkey 

for CPC designation. Turkish officials from the Ministry of Foreign Affairs 

said in a press release that USCIRF’s report directly contradicted State’s 

annual report on religious freedom, and called the USCIRF report “null 

and void.” State officials told us that they had to resolve the resulting 

tensions with the Turkish government. In June 2012, a senior State 

official briefed USCIRF regarding State’s position on Turkey, namely, that 

because the Turkish government had taken actions to improve religious 

freedom in the country, Turkey did not deserve CPC designation.

In addition, according to State officials, because the Ambassador and 

commissioners have not defined how they should interact, they have at 

times communicated conflicting information to foreign governments on 

behalf of the United States. For example, 5 days after USCIRF 

recommended Turkey for CPC designation in March 2012, the President 

publicly congratulated the Turkish prime minister on efforts he had made 

to protect religious minorities in Turkey. In addition, one Ambassador said 

that in meetings with foreign-government officials, he sometimes not only 

had to explain the function of USCIRF, but—because some statements 

by commissioners were not in line with U.S. foreign policy—he also had 

to clarify that USCIRF did not speak for him, even as an ex-officio 

member of the commission, or for the U.S. government.

All three Ambassadors cited instances when USCIRF’s approach with 

foreign-government officials created bilateral tensions. For example, the 

first Ambassador recounted helping to bring a delegation of high-level 

Laotian officials to the United States to tour, meet with government 

officials and religious communities, and view examples of religious 

State and USCIRF’s 

Limited Interaction 

Created Foreign Policy 

Tensions That State Had to 

Mitigate
 

Page 32 GAO-13-196 International Religious Freedom Act

freedom.43

Some State, USCIRF, and NGO officials we spoke with raised other 

concerns about the role USCIRF has played with respect to U.S. foreign 

policy. According to a former commissioner, during her tenure on 

USCIRF, commissioners became bolder in speaking out in letters or 

during meetings with foreign officials, and it was unclear to her whether 

these activities were within the bounds of the Act. Also, USCIRF officials 

told us that the commission has at times applied an expansive 

interpretation of the Act, questioning whether the responsibilities in the 

Act were a “floor or a ceiling.” They also said that, under USCIRF’s 

mandate to provide recommendations to the U.S. government on 

religious freedom, USCIRF has the obligation to help foreign 

governments take actions to address U.S. critiques. Some former 

commissioners said that foreign governments have at times requested 

advice or assistance from USCIRF and that, in general, USCIRF urged or 

made recommendations to foreign officials when it thought the 

recommendations were consistent with U.S. foreign policy. At the same 

time, some USCIRF officials noted that without active participation from 

According to the Ambassador, when the delegation returned, 

they freed 34 of 37 people imprisoned for their religious beliefs. The 

Ambassador told us that as a result, he had judged that Laos was making 

progress in instituting some real changes in the area of religious freedom; 

however, USCIRF recommended Laos for CPC designation shortly 

thereafter. The Ambassador said that USCIRF’s recommendation almost 

ruined State’s diplomatic efforts to address religious freedom in Laos. In 

another example, in 2005, the second Ambassador negotiated an action 

plan with the Vietnamese government including actions that, if taken by 

the government, could support its case for removal from the CPC list. 

According to State officials, Vietnam took the necessary steps and the 

Secretary of State removed the country’s CPC designation in 2006. 

However, when USCIRF commissioners visited Vietnam later that year, 

according to State and Vietnamese officials, they offended the 

Vietnamese officials by their conduct in high-level meetings. State officials 

told us that this was damaging to some of the progress made with 

Vietnamese officials and necessitated efforts to repair the U.S. 

relationship with Vietnam.

 

43At the time of the Laotian delegation, the first Ambassador had left State and was 

president of the Institute for Global Engagement.
 

Page 33 GAO-13-196 International Religious Freedom Act

the Ambassador, they risk not fully understanding U.S. foreign policy in a 

particular situation or country.

The NGOs—religious organizations and other civil society groups—that 

we surveyed, as well as NGO representatives whom we interviewed, 

generally rated overall U.S. government, State, and USCIRF efforts to 

promote international religious freedom positively. At the same time, they 

raised some concerns and suggested several improvements, such as 

including more civil society and other nonstate actors and making the 

promotion of international religious freedom a higher foreign-policy 

priority. Likewise, NGOs that were familiar with State’s and USCIRF’s 

annual reports generally viewed both reports positively, although several 

raised concerns about a lack of objectivity in each report. Finally, NGOs 

generally viewed CPC designations positively, although some doubted 

the helpfulness of the designations to their own religious freedom work.

The NGOs that we surveyed and NGO representatives whom we 

interviewed indicated that they generally rated overall U.S. progress in 

promoting international religious freedom positively, although most 

provided specific suggestions to improve U.S. government efforts.44

Among the 84 NGOs that responded to our survey, 63 NGOs (75 percent) 

said that the U.S. government had made at least some progress in 

promoting religious freedom overall.45

 

44To develop our survey universe, we selected organizations from a variety of sources, 

including those that had engaged with State or USCIRF or were on lists of groups active in 

religious freedom issues. See appendix I for additional information on our survey

methodology. 

The responding NGOs also 

45We sent the survey to 131 NGOs that promote international religious freedom, and 84 of 

these NGOs sent responses to the survey. However, because not all NGOs responded to 

each question, the total number of responses varied for each question. The results reflect 

NGO responses rating the U.S. government as having made great, good, moderate, or 

some progress. See appendixes I and IV for additional information on our survey.

NGOs Generally 

Rated Overall U.S. 

Government Efforts 

Positively While 

Raising Some 

Concerns and 

Suggesting Several 

Improvements 

NGOs Generally Rated 

Overall U.S. Government 

Progress Positively While 

Suggesting Improvements

Overall Progress 
 

Page 34 GAO-13-196 International Religious Freedom Act

generally said that the U.S. government had made progress in promoting 

specific international religious freedom activities, such as engaging in 

dialogue with foreign governments to effect changes in policy (59 of 83 

NGOs, or 71 percent) and engaging in dialogue with NGOs and civil 

society groups regarding international religious freedom (65 of 84 NGOs, 

or 77 percent). For additional survey results, see appendix IV.46

One of the NGO survey responses stated, “I believe that it is very helpful 

that the U.S. government emphasizes religious freedom as a key foreign

policy issue. This keeps the issue on the international agenda.” NGO 

representatives whom we spoke with on our field visits echoed these 

views, and a few told us that, in their opinion, the United States is the only 

country actively encouraging other governments to improve religious 

freedom. For example, some NGO representatives in four of our five 

fieldwork countries told us that they communicated with the U.S. embassy 

regularly, both on their own initiative and in response to information 

requests from the embassy’s human rights officer. Representatives of 

other NGOs, in Turkey and Vietnam, said that the U.S. embassies have 

invited them to interfaith discussions hosted by the embassies and that 

they were free to contact the embassies to raise specific issues regarding 

religious freedom situations. However, a representative from a religious 

group in Afghanistan told us that although he had met with U.S. officials 

on multiple occasions over the past few years and had described to them 

the various challenges facing his religious community, he had not seen 

any action taken.

While the NGO responses to our survey generally expressed positive 

views of U.S. government efforts to promote international religious 

freedom, they also raised some concerns and identified several areas 

where they believed the U.S. government could improve its efforts.

In response to our survey’s request for elaboration on ratings of progress 

made, the NGOs’ most common concern was that international religious 

freedom was not as high a priority for the U.S. government as it should be 

and that this hindered overall efforts to promote international religious 

freedom (9 of the 27 NGOs that elaborated on their responses expressed 

this view). For example, one NGO stated, “Too often, religious freedom 

 

46The results reflect NGO responses rating the U.S. government as having made great, 

good, moderate, or some progress.

Concerns and Suggested 

Improvements
 

Page 35 GAO-13-196 International Religious Freedom Act

appears to be an afterthought.” Other NGOs commented that State has 

not made international religious freedom a priority and that the Office is 

not valued within State’s structure. Other NGOs expressed in the survey 

the perception that the U.S. government has had limited success in 

promoting international religious freedom in general, including through the 

use of the CPC designation, or in obtaining the release of prisoners of 

conscience. When asked to list their organization’s top suggestions to 

improve U.S. government efforts to promote international religious 

freedom, 27 of the 69 NGOs (39 percent) that responded to the question 

suggested greater inclusion of, and consultation with, civil society and 

nonstate actors, both in the United States and abroad. One NGO 

responding to the survey pointed to State’s Religious Freedom and 

Foreign Policy Working Group as a positive development toward 

addressing this concern.47

Other frequently suggested improvements included making international 

religious freedom a higher priority in U.S. foreign policy and empowering 

State—and to a lesser extent, USCIRF—with greater resources and 

authority to promote international religious freedom. For example, an 

NGO responding to our survey suggested that the U.S. government 

“include the promotion of international religious freedom as a greater 

aspect of formulating foreign policy toward a particular country or region.” 

Another NGO responded that “funding should be substantially increased 

for both the Office and USCIRF. They have a tiny amount of resources 

with which to investigate an issue affecting billions of individuals.” 

Most of the NGOs that responded to our survey questions about State’s 

annual report on international religious freedom rated the report 

 

47In February 2011, the Secretary of State launched the Strategic Dialogue with Civil 

Society to provide a forum for cooperation and discussion with civil society. The Religion

and Foreign Policy Working Group was one of six working groups that made up the 

Strategic Dialogue. 

NGOs Generally Rated 

Both State’s and USCIRF’s 

Annual Reports Positively 

but Raised Some Concerns 

about Lack of Objectivity 

State’s Annual Report
 

Page 36 GAO-13-196 International Religious Freedom Act

positively. The NGOs responding to the survey and the NGO 

representatives we interviewed in Indonesia, Turkey, Vietnam, and 

Uzbekistan were largely familiar with the State report.48

Of the 70 NGOs that were familiar with State’s annual report, 54 NGOs 

(77 percent) said that State’s annual report was at least somewhat useful 

in affecting religious freedom in a country, and 58 NGOs (83 percent) said 

that State’s annual report was at least somewhat useful in impacting U.S. 

policy on religious freedom.

Of the 84 NGOs 

that responded to our survey, 70 (83 percent) stated that they were 

familiar with the report. Representatives from several NGOs and religious 

organizations whom we met with in Indonesia, Turkey, Vietnam, and 

Uzbekistan told us that State’s annual report raises awareness of 

religious freedom issues in their countries and around the world. For 

example, one NGO representative told us that the report is a useful tool 

for disseminating information about the situation in her country and helps 

raise awareness of the issues to the government of her country and to the 

world. A leader of a religious organization in another country explained 

that the publication of the State report proves to his country’s government 

that the U.S. government is aware of the restrictions placed on his 

religious community. He said that this knowledge has influenced his 

government’s decision making in some cases, such as in the early 

release of a prisoner, jailed for conscientious objection to military service, 

whom State listed in its report.

49

 

48Of the two NGOs we spoke with in Afghanistan, one was not familiar with State’s annual 

report, and the other provided information to State but assumed that State’s report was for 

internal U.S. government discussion only.

In addition, 66 of the 70 NGOs (94 percent) 

said that the report was useful for their overall efforts. One NGO that 

deals with a specific religious group said, “It was very helpful to have a 

clear, official document from the State Department that named and 

condemned...atrocities.” Another NGO said that the report was “accurate, 

timely, objective, and extremely useful.” This perception may be related to 

the level of familiarity that various groups had with State and USCIRF. 

While the NGOs we surveyed had a high degree of familiarity with both 

State and USCIRF (70 of 84 NGOs, or 83 percent, were familiar with 

State, and 64 of 84 NGOs, or 76 percent, were familiar with USCIRF), 

49These results reflect NGO responses rating State’s annual report as extremely or very 

useful and as useful or somewhat useful.
 

Page 37 GAO-13-196 International Religious Freedom Act

groups we met with during our field visits tended to identify State as the 

U.S. actor most responsible for promoting international religious freedom.

Additionally, of the 70 NGOs that were familiar with State’s annual report, 

61 NGOs (87 percent) said that the report was credible overall and 58 

NGOs (83 percent) said that it was accurate.50

However, 16 of the 70 NGOs familiar with the State report (23 percent) 

rated its objectivity as only fair or poor. In addition, 11 of 28 NGOs that 

elaborated on their responses to questions about State’s report raised 

concerns about a perceived lack of objectivity in State’s report. One NGO 

noted, “There is a perception of the report, by the international civil 

society, American NGOs, and State Department personnel that the 

conclusions of the report are politically predetermined.” NGOs had a 

similar concern when responding about the usefulness of State’s report. 

Five of the 11 survey respondents who elaborated on their response said 

that they perceive State’s report to be influenced by U.S. policy. One 

NGO wrote, “The State Department tends to undervalue religious 

freedom issues in countries where there are significant U.S. economic or 

security interests.” 

Several NGO 

representatives whom we spoke with overseas said that they could vouch 

only for information they provided to the embassy and were hesitant to 

judge the reports’ degree of accuracy and comprehensiveness.

Most of the NGOs that responded to our survey expressed positive views 

of USCIRF’s annual report on international religious freedom. Of the 84 

respondents, 64 NGOs (76 percent) were familiar with the USCIRF 

report. Fifty-one of the 64 NGOs familiar with the report (80 percent) said 

that it was at least somewhat useful in affecting religious freedom in a 

country and 49 of the 64 NGOs (77 percent) said that it was at least 

somewhat useful in affecting U.S. policy.51

 

50These results reflect NGO responses rating the overall credibility and accuracy of 

State’s annual report as excellent, very good, or good.

Many of the NGO 

representatives whom we interviewed in Afghanistan, Indonesia, 

Uzbekistan, and Vietnam were not aware of USCIRF’s report—for 

example, none of the 9 representatives of NGOs, religious or in civil 

society, whom we interviewed in Uzbekistan were familiar with the report.

51These results reflect NGO responses rating USCIRF’s annual report as extremely or 

very useful and as useful or somewhat useful.

USCIRF’s Annual Report
 

Page 38 GAO-13-196 International Religious Freedom Act

Of the 64 respondents that were familiar with USCIRF’s annual report, 59 

NGOs (92 percent) said the report was credible and 57 NGOs (89 

percent) said it was accurate.52

Nine of the 64 respondents that were familiar with the USCIRF report 

rated its objectivity as “fair” or “poor,” and 5 of 14 NGOs that elaborated 

on their responses about USCIRF’s annual report reported a perceived 

lack of objectivity of the report. For example, one NGO commented, “The 

USCIRF report can feel more overtly steered by U.S. diplomatic and 

political interests.” Another stated that the report has, “in some cases, 

been more representative of individual concerns of the appointed 

commissioners, rather than a comprehensive and evenhanded analysis of 

IRF [international religious freedom] concerns and abuses worldwide.” An 

additional 4 of the 14 NGOs commented that USCIRF’s report was not 

always comprehensive, omitting some countries and focusing on CPC 

countries, and said that it reflected individual commissioners’ concerns. 

This observation was further echoed when NGOs were asked to provide 

suggestions for improving the USCIRF report. Other groups echoed one 

NGO’s suggestion of “more global coverage and better documentation of 

incidents reported.” 

One NGO commented further that “the 

IRF report is a credible source of information which accurately highlights 

challenges in countries.” Another NGO commented, “USCIRF made an 

effort to talk directly to victims of religious persecution and to verify the 

facts they presented.” 

NGOs expressed somewhat mixed opinions about whether the Secretary 

of State’s CPC designations helped or hindered their work. Of the 84 

respondents to our survey, 38 NGOs (45 percent) said that the CPC 

 

52These results reflect NGO responses rating USCIRF’s annual report as excellent, very 

good, or good.

NGOs Had Generally 

Positive Views about CPC 

Designations, but Some 

Questioned the 

Designations’ Usefulness 

to Their Work

State’s CPC Designations 
 

Page 39 GAO-13-196 International Religious Freedom Act

designation helped their work, 26 NGOs (31 percent) said that it neither 

helped nor hindered, and 6 NGOs (7 percent) said that it hindered their 

work. The remaining 14 NGOs (17 percent) had no opinion. For example, 

one NGO explained, “Other nations take notice of U.S. government 

religious freedom concerns raised in the report but since there are few 

negative consequences even if given a CPC designation, those nations 

may be inclined to ignore U.S. human rights criticisms.” Other 

government-sanctioned groups, such as those we spoke with in 

Uzbekistan, said the CPC designation of their country was not justified 

and did not affect them or their communities. In contrast, several NGO 

representatives whom we interviewed in Vietnam said that the CPC 

designation of the country from 2004 through 2006 put pressure on the 

Vietnamese government to institute religious freedom reforms.53

Similarly, NGOs expressed somewhat mixed opinions about whether 

USCIRF’s CPC or watch list recommendations helped or hindered their 

work. Of the 84 respondents to our survey, 40 NGOs (48 percent) said 

that USCIRF’s CPC recommendations had helped their work, 21 NGOs 

(25 percent) said that the designations neither helped nor hindered, and 5 

NGOs (6 percent) said the designations hindered their work. The 

remaining 16 NGOs (19 percent) expressed no opinion.

Further, 

some said that the removal of Vietnam from the CPC list had slowed 

progress and had lessened pressure on the Vietnamese government to 

protect religious freedom. However, some also said that redesignating 

Vietnam as a CPC was unwarranted, given the progress that the country 

has made.

54

 

53However, State officials and NGO representatives told us that, in addition to Vietnam’s 

CPC designation, the Vietnam government’s desire to achieve most favored nation trading 

status with the United States was also a strong incentive for instituting religious freedom 

reforms. 

The NGOs’ 

perceptions of the watch list that USCIRF compiles, in addition to 

providing its CPC recommendations, were similar to respondents’ 

perceptions of both the State and USCIRF CPC lists. Of the 84 survey 

respondents, 37 NGOs (44 percent) said that USCIRF’s watch list 

recommendations helped their work, 26 NGOs (31 percent) said that the 

designations neither helped nor hindered, and 5 NGOs (6 percent) said 

54Two of the 84 respondents (2 percent) did not respond to the question.

USCIRF’s Commentary on CPC 

Designations and Watch List
 

Page 40 GAO-13-196 International Religious Freedom Act

that the designations hindered their work. The remaining 15 NGOs (18 

percent) expressed no opinion.55

Fifty-two of the 84 NGOs that responded to our survey (62 percent) said 

that they agreed with USCIRF’s recommendations to designate 25 to 30 

countries as CPCs or for its watch list.56 Ten of the 84 NGOs (12 percent) 

neither agreed nor disagreed, 5 of the NGOs (6 percent) disagreed, and 

17 of the NGOs (20 percent) had no opinion. An additional 26 NGOs 

responded with specific suggestions for improving the USCIRF annual 

report—for example, taking a more comprehensive approach to reporting 

globally, soliciting additional input from other sources, and providing 

constructive examples of how countries can improve religious freedom.

Both State and USCIRF have implemented their primary responsibilities 

outlined in the Act, and each has undertaken a variety of activities in 

response to increased restrictions on religious freedom around the world. 

In general, NGOs that we surveyed and NGO representatives whom we 

interviewed expressed positive perceptions of these activities, including 

State’s and USCIRF’s annual reports on international religious freedom. 

However, the lack of a definition regarding how the two entities are to 

interact has created foreign policy tensions that State has had to mitigate. 

These tensions have resulted in part from the fact that the Ambassadors 

and USCIRF have not defined the Ambassador’s role as an ex-officio 

member of the commission. Guidance that would clarify how State and 

USCIRF are to cooperate would strengthen each entity’s unique 

contribution to promoting international religious freedom. It would also 

institutionalize their information sharing and help ensure that the U.S. 

government presents a more consistent foreign policy message with 

respect to religious freedom.

To enhance U.S. efforts to promote international religious freedom, we 

recommend that the Secretary of State and the Chair of USCIRF jointly 

define how State and USCIRF should interact in their efforts to promote 

international religious freedom, paying particular attention to defining the 

 

55One of the 84 NGOs (1 percent) did not respond to the question.

56These results reflect NGO responses of “strongly agree” and “somewhat agree” to 

USCIRF’s annual CPC recommendations. 

Conclusions 

Recommendation for 

Executive Action
 

Page 41 GAO-13-196 International Religious Freedom Act

ex-officio role of the Ambassador-at-Large for International Religious 

Freedom as a nonvoting USCIRF member.

We provided a draft of this report to the State and USCIRF for comment. 

We received written comments from both entities, which are reproduced 

in full in appendices V and VI, respectively. State and USCIRF agreed 

with our recommendation and both expressed willingness to take action. 

We also received technical comments from each, which we incorporated 

throughout our report as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of State, and the Chair of USCIRF. In addition, 

the report is available at no charge on the GAO website at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-9601 or MelitoT@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix VII.

Thomas Melito

Director, International Affairs and Trade

Agency Comments 

and Our Evaluation
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-13-196 International Religious Freedom Act

The United States Commission on International Religious Freedom 

Reform and Reauthorization Act of 2011 mandated that we report to the 

Senate Committee on Foreign Relations and the House Committee on 

Foreign Affairs on several matters related to U.S. promotion of 

international religious freedom. In addition, the mandate included a 

specific requirement that we consult with nongovernmental organizations 

(NGO) in preparing the report. In response to the mandate, this report 

assesses (1) the Department of State’s (State) implementation of its 

primary responsibilities established in the International Religious Freedom 

Act of 1998 (the Act); (2) the U.S. Commission on International Religious 

Freedom’s (USCIRF) implementation of its primary responsibilities 

established in the Act; (3) State’s and USCIRF’s interaction in their efforts 

to promote religious freedom; and (4) NGOs’ views on U.S. efforts to 

promote international religious freedom. The mandate also directed us to 

compare USCIRF with other advisory commissions; for this analysis, we 

summarized a previous Congressional Research Service report (see app. 

II).

To address our four objectives, we conducted fieldwork in five countries—

Afghanistan, Indonesia, Turkey, Uzbekistan, and Vietnam. We selected 

these countries on the basis of their meeting at least two of the following 

criteria: (1) State had funded international religious freedom programs in 

the country; (2) the country was on USCIRF’s watch list; (3) USCIRF had 

recommended the country for designation as a Country of Particular 

Concern (CPC) or State had designated it as a CPC; and (4) the 

Ambassador-at-Large for International Religious Freedom (the 

Ambassador) or USCIRF had visited the country in the previous 3 years. 

Specifically:

• Afghanistan. State had funded international religious freedom 

programs in the country. In addition, USCIRF had included 

Afghanistan on its watch list for several years and visited the country 

in 2010. 

 

• Indonesia. State had funded international religious freedom programs 

in the country, and USCIRF had included Indonesia on its watch list 

for several years.

1

 

1

USCIRF established a watch list to identify countries that require close monitoring 

because of the nature and extent of violations of freedom of thought, conscience, religion, 

or belief engaged in, or tolerated by, the governments.

 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-13-196 International Religious Freedom Act

• Turkey. USCIRF recommended Turkey for CPC designation for the 

first time in 2012, but according to State officials, State did not agree 

with the recommendation. The Ambassador and USCIRF had both 

traveled to Turkey in the previous 3 years.

• Uzbekistan. State had designated Uzbekistan as a CPC for several 

years and had waived sanctions against it. The Ambassador had 

traveled to Uzbekistan in the last year.

• Vietnam. State had funded an international religious freedom program 

in the country. State removed Vietnam from the CPC list in 2006, 

making it one of only two countries that State had ever removed from 

the CPC list. The Ambassador had traveled there in the last year. 

While in each country, we interviewed State embassy officials, including 

the U.S. Ambassador to the country and the International Religious 

Freedom officer. We also interviewed representatives from host 

governments, NGOs, and religious communities. In two countries we 

visited, we also met with officials from third-country embassies.

To address our first objective, we reviewed the provisions of the Act and 

identified the primary responsibilities that the Act established for State. 

We also analyzed State documents, including cables, grant materials, 

State’s annual International Religious Freedom Report, the 2003 State 

Inspector General’s Report of Inspection: Bureau for Democracy, Human 

Rights and Labor, and the Inspector General’s 2005 Compliance Followup Review on the Bureau for Democracy, Human Rights and Labor. We 

also met with State officials, including staff from the Office of International 

Religious Freedom, all three Ambassadors-at-Large for International 

Religious Freedom—two former and one present—and senior level 

officials such as an Assistant Secretary and two Under Secretaries in 

Washington, D.C. We requested that State provide us with cables to 

demonstrate the type of activities it undertook from January 2009 through 

October 2012 to (1) promote or improve international religious freedom 

and (2) document international religious freedom issues. State provided 

us with 183 unclassified cables, five of which were duplicates. State also 

identified more than 100 additional classified cables that pertained to 

CPCs, but State did not provide those cables to us in time for us to 

analyze them for this report. This analysis does not provide a full list of all 

religious freedom–related activities that State conducted worldwide during 

this time period, because (1) not all activities are reported in cables; (2) 

State may not have located all the relevant cables sent during this time 

period; and (3) we did not receive the classified cables in time for us to 
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-13-196 International Religious Freedom Act

analyze them for this report. See appendix III for a summary of our 

analysis of the cables.

In response to our request that State identify all of its grants related to 

international religious freedom, State provided us with a list of 27 grants 

that it had grouped either globally or by region of the world. For our 

analysis, we selected seven grants that generally represented the largest 

award amount in each region of the world and that included both ongoing 

and completed grants as well as a grant in one of our fieldwork countries. 

We also selected a seventh grant that was not country specific from the 

global programs category. For each of these seven grants, we reviewed 

the grant’s goals and objectives, how the grant implementer measured 

progress toward those goals, and whether the implementer reported

meeting the goals.

To address our second objective, we reviewed the provisions of the Act, 

identified the primary responsibilities that the Act established for USCIRF, 

and analyzed USCIRF documents such as its annual report on 

international religious freedom, letters to U.S. government officials, 

editorials, and press releases. To determine how USCIRF implemented 

its primary responsibilities, we also interviewed USCIRF staff and 20 of 

the 33 commissioners appointed to USCIRF, including all of the current 

commissioners. In addition, we also interviewed all three Ambassadorsat-Large—two former and one present—who serve as ex-officio members 

of USCIRF. We conducted these interviews in or near Washington, D.C.

To address our third objective, we met with officials from State and 

USCIRF, including all three Ambassadors-at-Large—two former and one 

present—and all of the current and approximately half of the former 

USCIRF commissioners. We also interviewed State and foreigngovernment officials in our fieldwork countries, as well as NGO officials 

both in the United States and abroad who have worked closely with both 

entities. In addition, we analyzed State cables as well as documents from 

USCIRF, including press releases, editorials, and their annual reports.

To address our fourth objective, we conducted a survey of NGOs that we 

identified from five sources: (1) State’s Office of International Religious 

Freedom’s list of 30 most-consulted NGOs; (2) USCIRF’s list of NGOs 

that the commission has worked, or been in contact, with; (3) members of 

the Secretary of State’s Religion and Foreign Policy Working Group; (4) a 

list of NGOs participating in the International Religious Freedom 

Roundtable in Washington, D.C.; and (5) the Pew Online Directory of 

Religious Advocacy Groups, which the Pew Research Center’s Pew 
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-13-196 International Religious Freedom Act

Forum on Religion and Public Life developed. These sources produced a 

list of 317 unique NGOs. To determine the universe of NGOs from our 

five sources, we contacted each NGO and identified 137 that had 

conducted work related to international religious freedom. We developed 

a web-based survey instrument in August 2012 and pretested it with 6 

NGOs. The survey contained closed- and open-ended questions in four 

general areas: (1) demographics, (2) State’s international religious 

freedom activities, (3) USCIRF’s international religious freedom activities, 

and (4) general U.S. policy on international religious freedom. We sent 

the web-based survey to all 137 NGOs via e-mail in September 2012. 

However, we removed six NGOs from our universe of 137, resulting in a 

universe of 131 NGOs, after 5 NGOs responded that they did not conduct 

work related to religious freedom and we determined that one NGO was a 

duplicate. We received 84 responses to our survey, or a 64 percent 

response rate. The results of the survey reflect the views of only the 

respondents to our survey and cannot be generalized either to the 

universe of 131 organizations or to any other organizations that are 

involved in these types of issues. See appendix IV for selected survey 

results.

We administered the web-based survey from September 5 to October 18, 

2012. We sent each NGO an e-mail invitation to complete the survey on a 

GAO web server using a unique username and password. During the 

data collection period, we sent reminder e-mails and made phone calls to 

nonresponding NGOs. Because this was not a sample survey, it had no 

sampling errors; however, the practical difficulties of conducting any 

survey may introduce nonsampling errors, such as difficulties in 

interpreting a particular question, which can introduce unwanted 

variability in the survey results. We took steps to minimize nonsampling 

errors by pretesting the questionnaire with six NGOs representing 

different religious traditions or no religious affiliation. We conducted 

pretests to ensure that the questions were clear and unbiased, that the 

data and information were readily obtainable, and that the questionnaire 

did not place an undue burden on respondents. Additionally, a senior 

GAO methodologist independently reviewed a draft of the questionnaire 

prior to its administration. We made appropriate revisions to the content 

and format of the questionnaire after the pretests. All data analysis of 

survey results were independently verified for accuracy.

In addition, we conducted a limited content analysis of open-ended 

responses to five survey questions. We developed initial categories for 

selected questions with open-ended responses, to characterize the 

general theme of the response. For responses to questions asking about 
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-13-196 International Religious Freedom Act

the credibility of each report, we developed the following categories: 

Timeliness (described as the frequency and/or timing of the reports); 

Effectiveness; Specific; CPC; Lack of Objectivity (initially coded as 

“Bias”); Lack of Input; Composition/Format; Contrast; and Lack of 

Resources. For questions elaborating on the perception of the usefulness 

of each report, we developed the following categories: Specific; Policy 

(regarding the formulation/motivation of U.S. international religious 

freedom policy); CPC; Contrast; Limited (meaning the State or USCIRF 

report has a circumscribed impact); and Not Applicable. For the question 

asking NGOs to provide their suggestions on ways to improve U.S. 

promotion of international religious freedom, we developed the following 

categories: Inclusion; Measurement; Enforcement; Empowerment; 

Awareness; Prioritize; Specific; and Not Applicable. One analyst coded 

the responses with at least one category, with an optional second 

category. After the initial coding, a second analyst independently 

assigned categories to the same responses. The analysts then reconciled 

the two sets of coding, assigning a final determination to each response. 

A methodologist then reviewed the categories, making language changes 

as needed. These results were then tabulated.

We conducted this performance audit from March 2012 to March 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comparison of the U.S. 

Commission on International Religious 

Freedom with Other Select Congressional 

Commissions

Page 47 GAO-13-196 International Religious Freedom Act

The United States Commission on International Religious Freedom 

Reform and Reauthorization Act of 2011 directed us to, among other 

things, conduct a comparative analysis of the structure of the U.S. 

Commission on International Religious Freedom (USCIRF) in relation to 

other U.S. advisory commissions.1 To conduct this analysis, we relied on 

the Congressional Research Service’s (CRS) compilation of 

Congressional Advisory Boards and Commissions to which Congress has 

a direct appointing role.2

In 2013, CRS reported on the 85 permanent and temporary congressional 

commissions whose members Congress participates in appointing.3

Our analysis shows that USCIRF does not appear to be unique among 

policy advisory bodies in duration limit, membership numbers, or 

appointment terms. USCIRF comprises 10 members known as 

commissioners, with 2-year appointments and a limit of two terms.

CRS 

defines a congressional commission as a multi-member independent 

entity that (1) is established by Congress, (2) exists temporarily, (3) 

serves in an advisory capacity, (4) is appointed in part or whole by 

members of Congress, and (5) reports to Congress. CRS grouped the 

current 85 congressional commissions in four categories: (1) policy 

advisory bodies, (2) commemorative advisory bodies, (3) operational 

advisory bodies, and (4) diplomatic advisory bodies. Given that CRS 

categorized USCIRF as a policy advisory body, we focused our 

comparative analysis on the 26 advisory bodies that CRS classified as 

policy advisory bodies.

4

• Seven of the advisory bodies had a statutory duration limit, while 19 

did not.

Following are characteristics of the 26 policy advisory bodies:

 

1

Pub. L. No. 112-75, Sec. 7, Dec. 23, 2011. 

2

Congressional Research Service, Congressional Membership and Appointment Authority 

to Advisory Commissions, Boards, and Groups, RL33313 (Washington, D.C.: February. 

2013). 

3

The CRS report includes only temporary congressional commissions active as of 

February 2013.

4

Nine of the 10 commission members are limited to a 2-year appointment and 2 terms. 

The Ambassador-at-Large, who is an ex-officio, nonvoting commission member, is not 

subject to the appointment or term limitations.

Appendix II: Comparison of the U.S. Commission 

on International Religious Freedom with Other 

Select Congressional Commissions 
Appendix II: Comparison of the U.S. 

Commission on International Religious 

Freedom with Other Select Congressional 

Commissions

Page 48 GAO-13-196 International Religious Freedom Act

• Membership ranged from 4 to 37 members.

• Appointments ranged from 1 to 6 years for advisory bodies that had 

delineated term limits; five of the advisory bodies had term limits for 

the life of the body; two of the advisory bodies had term limits for the 

duration of the Congress from which they were appointed; and one 

advisory body had a statutorily unclear term of appointment.

Table 1: Policy Commissions, Boards and Advisory Bodies That Report to U.S. Congress 

Entity name Duration

Number of 

members Term of appointment

Advisory Committee on Student 

Financial Assistance

No statutory end date 11 4 years

Citizen’s Coinage Advisory Committee No statutory end date 11 4 years

Commission on Long-Term Care The commission terminates 

30 days after submission of 

its final recommendations, 

which are due no later than 6 

months after appointments 

are made.

15 Duration of commission

Commission on Security and 

Cooperation in Europe (Helsinki 

Commission)

No statutory end date 21 Not specified

Commission to Reduce Child Abuse 

and Neglect Fatalities

The commission terminates 

30 days after submission of 

its final recommendations, 

which are due no later than 2 

years after the appointment 

of a majority of the 

commission members, or 3 

years after the initial meeting, 

whichever is earlier.

12 Duration of commission

Congressional-Executive Commission 

on the People’s Republic of China

No statutory 

end date

23 Not specified

Congressional Advisers for Trade Policy 

and Negotiations

No statutory 

end date

10 For the session of Congress from 

which the appointees are chosen. 

Coordinating Council on Juvenile 

Justice and Delinquency Prevention

No statutory end date Varies; minimum of 

18 members

1, 2, or 3 years

Denali Commission No statutory end date 7 Duration of commission, except 

federal co-chairperson who is 

appointed for 4 years

Election Assistance Commission No statutory end date 4 4 years

Election Assistance Commission, Board 

of Advisors

No statutory end date 37 2 years
Appendix II: Comparison of the U.S. 

Commission on International Religious 

Freedom with Other Select Congressional 

Commissions

Page 49 GAO-13-196 International Religious Freedom Act

Entity name Duration

Number of 

members Term of appointment

Foreign Intelligence and Information 

Commission

The commission terminates 

60 days after submission of 

its final report. 

10 Duration of commission

Health Information Technology Policy 

Committee

No statutory end date Varies; minimum of 

20 members

3 years

Independent Payment Advisory Board No statutory end date 18 6 years

Indian Law and Order Commission The commission terminates 

90 days after submission of 

its final report. 

9 Duration of commission

Migratory Bird Conservation 

Commission

No statutory end date 7 Not specified

National Advisory Committee on 

Institutional Quality and Integrity

No statutory end date 18 6 years

National Capital Planning Commission No statutory end date 12 Presidential appointments for 6 years 

and mayoral appointments for 4 

years

National Commission on the Structure 

of the Air force

The commission terminates 

90 days after issuing its final 

report, which is due no later 

than February 1, 2014.

8 Presidential appointments for 6 years 

and mayoral appointments for 4 

years

National Committee on Vital and Health 

Statistics

No statutory end date 18 4 years

National Rural Investment Board No statutory end date 14 4 years

Social Security Advisory Board No statutory end date 7 6 years

United States-China Economic and 

Security Review Commission

No statutory end date 12 2 years

United States Commission On Civil 

Rights

No statutory end date 8 6 years

United States Commission on 

International Religious Freedom

September 30, 2014 10 2 years

Utah Reclamation Mitigation and 

Conservation Commission

a

The commission terminates 

20 years from the end of the 

fiscal year during which the 

Secretary declares the 

Central Utah Project to be 

substantially complete.

5 4 years

Source: GAO analysis of Congressional Research Service information.

a

Nine of the 10 commission members are limited to a 2-year appointment and 2 terms. The 

Ambassador-at-Large, who is an ex-officio, nonvoting commission member, is not subject to the 

appointment or term limitations.
Appendix III: Analysis of Department of State 

Cables Concerning International Religious 

Freedom

Page 50 GAO-13-196 International Religious Freedom Act

We asked the Department of State (State) to provide us with cables 

concerning international religious freedom sent from January 2009 

through October 2012. State provided 183 cables, 5 of which were 

duplicates. We analyzed the cables to obtain information on the activities 

U.S. embassies and other U.S. government entities conduct to promote 

religious freedom. However, because not all activities are reported in 

cables, and because State might not have located all the relevant cables 

sent during this time period, this analysis does not provide a full list of all 

religious freedom–related activities that State performed globally during 

this time period. We developed 10 categories to analyze, or code, the 

activities described in the cables. We included a category for duplicate 

cables within the list of 10 categories and a category titled “other” for 

cables that did not fit into any one of the 9 categories.1

Table 2: Analysis of 178 Cables Sent by U.S. Embassies and Consulates, January 2009–October 2012

Because many of 

the cables covered a variety of topics, our coding rules allowed multiple 

codes to be applied to each cable. Two analysts independently coded 

each cable and then reconciled any differences in their coding.

Cable category Description of category

Number of 

cables

Status of religious 

freedom

Cable provides an update concerning the status of religious freedom in a particular 

country (positive or negative) and may discuss actions being taken by the foreign 

government (positive or negative). The update may be provided in conjunction with a 

discussion of activities described in the following categories.

108

U.S. embassy interaction 

with nongovernmental 

organizations (NGOs), 

religious leaders/ 

organizations, or relevant 

individuals

Cable describes either an attempt by U.S. embassy officials to interact with NGOs, 

religious leaders/organizations, or relevant individuals on religious freedom issues (or 

vice versa) or an actual instance in which the two sides interacted on the subject. 

These bilateral interactions include only representatives from the U.S. embassy, such 

as the Ambassador, Consulate General, and political officers, and representatives 

from one NGO, religious organization, or a relevant individual.

63

Activities conducted to 

promote religious 

tolerance and dialogue

Cable provides a summary of an activity organized and/or funded by the U.S. 

embassy to promote religious tolerance or dialogue in country by bringing people of 

different faiths and/or representatives of different organizations together. Others from 

State or within the U.S. government may have participated in or led the activity. Such 

activities may include, for example, roundtable discussions, dinners, working groups 

and may include representatives from NGOs, religious organizations, and/or foreign 

governments.

40

 

1

Cables coded as “other” included (1) cables from the Secretary of State to all U.S. 

embassies and consulates sharing information and talking points concerning events such 

as UN Human Rights Council Resolution 16/18 expert-level meetings and the publication 

of the annual International Religious Freedom Report and (2) cables from U.S. embassies 

or consulates in which religious freedom was not discussed.

Appendix III: Analysis of Department of State 

Cables Concerning International Religious 

Freedom
Appendix III: Analysis of Department of State 

Cables Concerning International Religious 

Freedom

Page 51 GAO-13-196 International Religious Freedom Act

Cable category Description of category

Number of 

cables

U.S. embassy interaction 

with foreign government 

officials

Cable describes either an attempt by U.S. embassy officials to interact with foreign 

government officials on religious freedom issues (or vice versa) or an actual instance 

in which the two sides interacted on the subject. These bilateral interactions include 

only representatives from the U.S. embassy, such as the Ambassador, Consulate 

General, and political officers, and foreign government officials.

31

Visit by high-level U.S. 

government official/s

Cable describes a visit by a high-level U.S. official—such as the President, Secretary 

of State, Ambassador-at-Large for International Religious Freedom, Under Secretary, 

Assistant Secretary, Deputy Assistant Secretary, Special Envoy, or other high-level 

U.S. government official—in which religious freedom was a primary focus of the visit 

or factored heavily into discussions with foreign government officials and/or NGO and 

religious organizations’ representatives.

30

U.S. government 

assistance to NGOs, 

religious organizations, or 

individuals

Cable provides a description of assistance and/or the status of the assistance 

provided by a U.S. government agency, including State, the U.S. Agency for 

International Development (USAID), and the Department of Defense, to NGOs, 

religious organizations, or individuals in a specified country. The assistance is 

intended to support the organization’s or individual’s efforts to improve religious 

freedom in country and may include financial and/or nonfinancial assistance, such as 

training.

14

U.S. embassy 

representatives’ 

participation in events 

promoting religious 

freedom

Cable describes participation by one or more U.S. embassy representatives, such as 

the Ambassador, Consulate General, and political officers, in an event focused 

primarily on promoting religious freedom. The event was not organized by the U.S. 

embassy but may have been organized by foreign government officials, NGOs, or 

religious organizations in a specified country.

11

U.S. government 

assistance to foreign 

governments

Cable provides a description of assistance and/or the status of the assistance 

provided by a U.S. government agency, including State, USAID, and Department of 

Defense, to a foreign government. The assistance is intended to support the foreign 

government’s efforts to improve religious freedom in country and may include financial 

and/or nonfinancial assistance, such as training.

5 

Other Cable does not fit into one of the first eight categories. 16

Source: GAO analysis of Department of State cables.
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 52 GAO-13-196 International Religious Freedom Act

We conducted a survey of 131 nongovernmental organizations (NGO) 

that we identified as having conducted work related to international 

religious freedom. Of the 131 NGOs, 84 responded to the survey. The 

survey addressed the Department of State’s (State) and the U.S. 

Commission on International Religious Freedom’s (USCIRF) international 

religious freedom activities, including their respective annual reports; 

State’s designations, and USCIRF’s recommendations for designations, 

of Countries of Particular Concern (CPC); overall U.S. government 

progress on international religious freedom; and U.S. international 

religious freedom policy.1

 

1

The results of our survey reflect the views of only the 84 respondents and cannot be 

generalized to the 131 international religious freedom organizations that received the 

survey or to any other organizations involved in religious freedom–related work. 

For a full description of the survey’s 

methodology, see appendix I. Figures 4 through 11 summarize selected 

results of the NGO responses to our survey. We selected these survey 

results because they add additional detail to the information summarized 

in the report.

Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 53 GAO-13-196 International Religious Freedom Act

Figure 4: NGOs’ Ratings of the Overall Progress the U.S. Government Has Made With Respect to the Specified Activities

Note: Numbers in graphic represent responses to the survey question: “How much progress has the 

U.S. government made in promoting each of the following international religious freedom activities?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 54 GAO-13-196 International Religious Freedom Act

Figure 5: NGOs’ Ratings of the Usefulness of State’s Annual International Religious Freedom Report with Respect to the 

Specified Factors

Note: Numbers in graphic represent responses to the survey question: “How useful does your 

organization believe State’s annual international religious freedom report to be with respect to each of 

the following?” This represents a subset of respondents that replied “yes” to the following question: “Is 

your organization familiar with the annual international religious freedom report produced by the 

Department of State?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 55 GAO-13-196 International Religious Freedom Act

Figure 6: NGOs’ Ratings of State’s Annual International Religious Freedom Report with Respect to the Specified Factors

Note: Numbers in graphic represent responses to the survey question: “How would your organization 

rate State’s annual international religious freedom report with respect to each of the following 

factors?” This represents a subset of respondents that replied “yes” to the following question: “Is your 

organization familiar with the annual international religious freedom report produced by the 

Department of State?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 56 GAO-13-196 International Religious Freedom Act

Figure 7: NGOs’ Ratings of the Usefulness of USCIRF’s Annual Report on International Religious Freedom with Respect to 

the Specified Factors

Note: Numbers in graphic represent responses to the survey question: “How useful does your 

organization believe USCIRF’s annual international religious freedom report to be with respect to 

each of the following?” This represents a subset of respondents that replied “yes” to the following 

question: “Is your organization familiar with the annual international religious freedom report produced 

by the U.S. Commission on International Religious Freedom (USCIRF)?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 57 GAO-13-196 International Religious Freedom Act

Figure 8: NGOs’ Ratings of USCIRF’s Annual Report on International Religious Freedom with Respect to the Specified 

Factors

Note: Numbers in graphic represent responses to the survey question: “How would your organization

rate USCIRF’s annual international religious freedom report with respect to each of the following 

factors?” This represents a subset of respondents that replied “yes” to the following question: “Is your 

organization familiar with the annual international religious freedom report produced by the U.S. 

Commission on International Religious Freedom (USCIRF)?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 58 GAO-13-196 International Religious Freedom Act

Figure 9: NGOs’ Ratings of the Extent to Which State’s CPC Designations Have 

Helped or Hindered the NGOs’ International Religious Freedom–Related Work

Note: Numbers in graphic represent responses to the survey question: “The Secretary of State 

periodically designates certain countries as Countries of Particular Concern (CPC). Overall, have the 

CPC designations helped or hindered your organization’s international religious freedom-related 

work?” 
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 59 GAO-13-196 International Religious Freedom Act

Figure 10: NGOs’ Ratings of the Extent to Which USCIRF’s Recommendations for 

CPC Designations Have Helped or Hindered the NGOs’ International Religious 

Freedom–Related Work

Note: Numbers in graphic represent responses to the survey question: “In its annual report, USCIRF 

recommends certain countries for CPC designation. Overall, have USCIRF’s CPC recommendations 

helped or hindered your organization’s international religious freedom-related work?” Responses do 

not total 84, as 2 NGOs did not respond to this question.
Appendix IV: Selected Results from Survey of 

Nongovernmental Organizations

Page 60 GAO-13-196 International Religious Freedom Act

Figure 11: NGOs’ Ratings of the Extent to Which They Agree or Disagree That the 

Countries Included in USCIRF’s Annual Report Fully Represent the Worst Offenders 

of Religious Freedom

Note: Numbers in graphic represent responses to the survey question: “The USCIRF annual 

international religious freedom report covers the approximately 25 to 30 countries that it either 

recommends as CPCs or places on its watch list. Does your organization agree or disagree that the 

25 to 30 countries USCIRF chooses to include in its annual international religious freedom report fully 

represent the worst offenders of religious freedom?” 
Appendix V: Comments from the Department 

of State

Page 61 GAO-13-196 International Religious Freedom Act

Appendix V: Comments from the Department 

of State
Appendix V: Comments from the Department 

of State

Page 62 GAO-13-196 International Religious Freedom Act
Appendix VI: Comments from the U.S. 

Commission on International Religious 

Freedom

Page 63 GAO-13-196 International Religious Freedom Act

Appendix VI: Comments from the U.S. 

Commission on International Religious 

Freedom
Appendix VI: Comments from the U.S. 

Commission on International Religious 

Freedom

Page 64 GAO-13-196 International Religious Freedom Act
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 65 GAO-13-196 International Religious Freedom Act

Thomas Melito, (202) 512-9601 or MelitoT@gao.gov

In addition to the contact named above, Cheryl Goodman and Michael 

Rohrback (Assistant Directors), Judith Williams, Sushmita Srikanth, Juan 

P. Avila, Amanda Bartine, and Kathryn Crosby made key contributions to 

this report. Jessica Bull, Lynn Cothern, Martin De Alteriis, Etana Finkler, 

Rachel Girshick, Heather Hampton, David Hancock, Brandon Hunt, Jill 

Lacey, Reid Lowe, Mary Moutsos, Elizabeth Repko, and Jeremy Sebest 

also provided substantial assistance.

Appendix VII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(320901)
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