COUNTERING 

OVERSEAS 

THREATS

DOD and State Need 

to Address Gaps in 

Monitoring of Security 

Equipment 

Transferred to 

Lebanon

Report to the Chairman, Subcommittee 

on the Middle East and North Africa, 

Committee on Foreign Affairs, House 

of Representatives

February 2014

GAO-14-161

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-161, a report to the 

Chairman, Subcommittee on the Middle East 

and North Africa, Committee on Foreign

Affairs, House of Representatives

February 2014

COUNTERING OVERSEAS THREATS

DOD and State Need to Address Gaps in Monitoring

of Security Equipment Transferred to Lebanon

Why GAO Did This Study

Since 2009, the United States has 

allocated $671 million in securityrelated assistance for Lebanon to train, 

modernize, and equip the Lebanese 

Armed Forces and Internal Security 

Forces. The U.S. government

established end-use monitoring 

programs to ensure that defense 

equipment is safeguarded. The 

Foreign Assistance Act prohibits 

certain assistance to any unit of foreign 

security forces if the Secretary of State 

has credible information that such a 

unit has committed a gross violation of 

human rights. GAO was asked to 

examine U.S. security-related 

assistance for Lebanon.

This report assesses the extent to 

which the U.S. government (1) 

disbursed or committed funds allocated 

for Lebanese security forces in fiscal 

years 2009 through 2013, (2) 

implemented end-use monitoring for 

equipment transferred to Lebanese 

security forces, and (3) vetted 

Lebanese recipients of U.S. securityrelated training for human rights 

violations. To address these 

objectives, GAO reviewed laws and 

regulations, analyzed agency data, and 

interviewed officials in Washington,

D.C., and Beirut, Lebanon.

What GAO Recommends

GAO recommends that DOD ensure 

U.S. officials use required checklists to 

confirm Lebanese facilities’ compliance 

with required safeguards, and that

State maintain proper documentation 

of end-use checks and establish formal 

procedures to ensure that bureaus

identify defense articles and any

recommended physical security 

safeguards for storing them. DOD and 

State concurred.

What GAO Found

The United States allocated $671 million for Lebanese security forces from fiscal 

year 2009 through fiscal year 2013. Of these total allocated funds, $477 million, 

or 71 percent, had been disbursed or committed by the end of fiscal year 2013. 

Nearly all of the allocations made in fiscal years 2009 through 2011 had been 

disbursed or committed. For the largest program, Foreign Military Financing, the 

Department of Defense (DOD) had committed about $352 million of the $481 

million allocated in fiscal years 2009 through 2013.

Consistent with end-use monitoring requirements, DOD and the Department of 

State (State) conduct annual inventories for equipment transferred to Lebanese 

security forces. However, GAO found gaps in efforts to document and monitor

physical security of some U.S. equipment transferred to Lebanese security forces 

that may weaken efforts to safeguard physical security of some equipment. First, 

while DOD annually inventories sensitive equipment by serial number, as 

required by its policy, U.S embassy officials in Beirut have not always used 

DOD’s required checklists to document compliance with physical security 

safeguards. Second, State did not fully document 4 of the 10 end-use monitoring 

checks it conducted in fiscal years 2011 and 2012 for defense equipment the 

Lebanese government purchased commercially. State end-use monitoring 

guidance requires that specific information be documented and maintained for all 

such checks. Third, while State conducts an annual inventory of the equipment it 

transfers to the Lebanese security forces, State may not be ensuring that the 

recipients of defense articles implement recommended physical security 

safeguards because State lacks procedures to identify defense articles and any 

recommended safeguards for storing them.

Examples of Items Subject to End-Use Monitoring in Lebanon

GAO estimates that State vetted 100 percent of the Lebanese students that 

attended U.S.-funded security-related training from October 10, 2010, through 

April 30, 2013, for human rights violations. On the basis of a cross-check

analysis of vetting data and a sample of names from six training rosters, GAO 

estimates that State vetted all of the 7,104 Lebanese students that attended 

training during that period. View GAO-14-161. For more information, 

contact Charles Michael Johnson, Jr., at 

(202) 512-7331 or johnsoncm@gao.gov.
Page i GAO-14-161 Security-Related Assistance to Lebanon

Letter 1

Background 3

U.S. Agencies Have Disbursed or Committed Most of the $671 

Million Allocated for Security-Related Assistance Programs for 

Lebanon in Fiscal Years 2009 through 2013 8

DOD and State Monitor End Use of Equipment Transferred to 

Lebanese Security Forces, but Gaps in Documentation and 

Security Checks May Limit Efforts to Safeguard Some 

Equipment 11

U.S. Government Has Vetted Lebanese Recipients for Human 

Rights Violations Prior to Providing Assistance 24

Conclusions 28

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 29

Appendix I Scope and Methodology 31

Appendix II U.S. Human Rights Vetting Process 36

Appendix III Status of Funds for U.S. Security-Related Assistance Programs for 

Lebanon 38

Appendix IV Comments from the Department of Defense 47

Appendix V Comments from the U.S. Department of State 49

Appendix VI GAO Contact and Staff Acknowledgments 51

Contents
Page ii GAO-14-161 Security-Related Assistance to Lebanon

Tables

Table 1: Funds Allocated and Funds Committed or Disbursed by

U.S. Security-Related Assistance Programs for Lebanese 

Security Forces, Fiscal Years (FY) 2009-2013 9

Table 2: U.S. Security-Related Assistance Programs for Lebanon 10

Table 3: Population of Lebanese Student Names on Training 

Rosters and Final Sample of Names Selected for CrossCheck with International Vetting and Security Tracking 

Database Records 27

Figures

Figure 1: Map of Lebanon 4

Figure 2: Timeline of Selected Political Events in Lebanon, from 

October 1990 to September 2013 5

Figure 3: Photographs of Lebanese Armed Forces Equipment

Prepared for End-Use Monitoring 14

Figure 4: U.S. Officials Conducting an Inventory of U.S.-Provided 

Equipment at a Lebanese Armed Forces Facility 15

Figure 5: Photographs of U.S. Equipment Provided to Lebanon’s 

Internal Security Forces 21

Figure 6: Percentage of Lebanese Candidates That Applied for 

U.S. Security-Related Training, by Funding Source 25

Figure 7: U.S. Human Rights Vetting Process 37

Figure 8: Foreign Military Financing Program, Fiscal Years 2009-

2013 39

Figure 9: International Narcotics Control and Law Enforcement 

Program, Fiscal Years 2009-2013 40

Figure 10: Section 1206 Authority Program, Fiscal Years 2009-

2013 41

Figure 11: International Military Education and Training Program, 

Fiscal Years 2009-2013 42

Figure 12: NADR: Antiterrorism Assistance Program, Fiscal Years 

2009-2013 43

Figure 13: NADR: Counterterrorism Financing Program, Fiscal 

Years 2009-2013 44

Figure 14: NADR: Export Control and Related Border Security 

Program, Fiscal Years 2009-2013 45

Figure 15: Section 1207 Authority Program, Fiscal Years 2009-

2013 46
Page iii GAO-14-161 Security-Related Assistance to Lebanon

Abbreviations 

DOD Department of Defense

DSCA Defense Security Cooperation Agency 

FMS Foreign Military Sales 

INCLE International Narcotics Control and Law Enforcement 

INL Bureau of International Narcotics Control and Law

Enforcement Affairs

INVEST International Vetting and Security Tracking database

ISF Internal Security Forces

LAF Lebanese Armed Forces

NADR Nonproliferation, Antiterrorism, Demining, and Related 

programs

State Department of State

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Page 1 GAO-14-161 Security-Related Assistance to Lebanon

441 G St. N.W.

Washington, DC 20548

February 26, 2014

The Honorable Ileana Ros-Lehtinen

Chairman

Subcommittee on the Middle East and North Africa

Committee on Foreign Affairs

House of Representatives

Dear Madam Chairman:

Lebanon is a religiously diverse country transitioning toward 

independence and democratic consolidation after a 15-year civil war and 

subsequent occupation by Syrian and Israeli forces. Following Syrian 

withdrawal from Lebanon in 2005 and the war between Israel and the 

Lebanese militant group Hezbollah in the summer of 2006, the United 

States significantly increased security-related assistance for Lebanon to 

support its efforts to build a stable, secure, and independent democracy. 

U.S. agencies have allocated over $925 million in security-related 

assistance for Lebanon from fiscal years 2007 through 2012,1 to train, 

modernize, and equip the Lebanese Armed Forces (LAF) and Internal 

Security Forces (ISF). Those efforts and the U.S. investment are now 

challenged by new tensions resulting from spillover of the civil war in 

Syria. Members of Congress have raised concerns about U.S. assistance 

to Lebanon and possible weapons smuggling to Hezbollah and other 

armed groups, given Hezbollah’s involvement in the Lebanese 

government and a clash between the LAF and Israeli Defense Forces 

along Lebanon’s and Israel’s shared border.

 1

According to officials from the Departments of Defense and State, there is no consensus 

about whether some funding accounts that support security cooperation or security sector 

reform should be labeled “assistance.” For the purposes of this report, we consider 

accounts that funded overt security-related activities in Lebanon to be security-related 

assistance. 
Page 2 GAO-14-161 Security-Related Assistance to Lebanon

This is the second of two reports responding to your request that we 

review U.S. security equipment and training for Lebanon.2 In this report, 

we assess the extent to which the U.S. government (1) disbursed or 

committed funds allocated for Lebanese security forces in fiscal years 

2009 through 2013, (2) implemented end-use monitoring for equipment 

transferred to Lebanese security forces, and (3) vetted Lebanese 

recipients of U.S. security-related training for human rights violations.

To address these objectives, we obtained funding data from the 

Department of Defense (DOD) and the Department of State (State) on 

programs that provide security-related assistance to Lebanon. We also 

examined documents from DOD and State, such as cables, handbooks, 

and compliance and inventory reports, and analyzed data on U.S.-

provided equipment, training, end-use checks, and human rights vetting 

of applicants for security-related equipment and training. To assess the 

extent to which DOD and State complied with their regulations and 

guidance on end-use monitoring and human rights vetting, we selected 

and analyzed the following: a nongeneralizable random sample of 30 

items out of 184 provided to the LAF at two locations in Beirut that 

required enhanced end-use monitoring for physical inspection; a 

judgmental sample of all 10 end-use checks performed by State for 

equipment exported to Lebanon in fiscal years 2010 through 2012; and a 

generalizable random sample of 118 of 7,104 Lebanese students who 

were vetted for human rights violations from October 10, 2010, through 

April 30, 2013. We interviewed DOD and State officials in Washington, 

D.C.; at the U.S. Central Command in Tampa, Florida; and at the U.S. 

Embassy in Beirut, Lebanon. We also interviewed officials of the LAF and 

ISF in Lebanon. To assess the reliability of the data provided, we 

requested and reviewed information from officials from each agency 

regarding the agency’s underlying financial data systems and the checks, 

controls, and reviews used to ensure the accuracy and reliability of the 

data provided. We determined that the data provided were sufficiently 

reliable for the purposes of this report. Appendix I provides a detailed 

description of our scope and methodology.

 2

In the first report, we assessed the extent to which the U.S. government adjusted its 

strategic goals and security assistance programs in Lebanon, funded assistance programs 

for Lebanese security forces, and evaluated the effectiveness of security assistance 

programs in Lebanon from fiscal years 2007 through 2012. See GAO, Security Assistance 

to Lebanon: Evaluations Needed to Determine Effectiveness of U.S. Aid to Lebanon’s 

Security Forces, GAO-13-289 (Washington, D.C.: Mar. 19, 2013).
Page 3 GAO-14-161 Security-Related Assistance to Lebanon

We conducted this performance audit from April 2013 to February 2014 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.

Lebanon is a small, religiously diverse country on the Mediterranean Sea 

that borders Israel and Syria (see fig. 1). Background
Page 4 GAO-14-161 Security-Related Assistance to Lebanon

Figure 1: Map of Lebanon

Religious tensions among Lebanon’s Maronite Christians, Sunni Muslims, 

and Shiite Muslims, and others, along with an influx of Palestinian 

refugees, for decades have underpinned Lebanon’s internal conflicts as 

well as its conflicts with neighboring countries. Hezbollah emerged in 

Lebanon as a powerful Islamic militant group and since 2005, a member 

of Hezbollah has held a cabinet position in the Lebanese government. 

Hezbollah is funded by Iran and has been designated by the United 

States and Israel as a terrorist organization. In the summer of 2006, 

Hezbollah and Israel entered into a month-long conflict that ended with 

the adoption of United Nations Resolution 1701 by both the Israeli and 
Page 5 GAO-14-161 Security-Related Assistance to Lebanon

Lebanese governments.3 The resolution called for, among other things, 

Israeli withdrawal from southern Lebanon in parallel with the deployment 

of Lebanese and United Nations forces and the disarmament of all armed 

groups in Lebanon. Instability arising from the civil war in neighboring 

Syria that began in 2011 has exacerbated sectarian conflict within 

Lebanon. In May 2013, Hezbollah leaders confirmed their intervention in 

the Syrian conflict. Figure 2 presents a timeline of selected political 

events in Lebanon.

Figure 2: Timeline of Selected Political Events in Lebanon, from October 1990 to September 2013

Since the end of the 2006 Israeli-Hezbollah war, the United States has 

kept strategic goals for Lebanon constant. These goals are to support 

Lebanon as a stable, secure, and independent democracy. The 

overarching priorities of U.S. assistance programs for Lebanon focus on 

supporting Lebanese sovereignty and stability and countering the 

influence of Syria and Iran. Security-related goals for Lebanon focus on

counterterrorism and regional stability or internal security, and 

corresponding activities seek to support development of the LAF and the 

ISF as the only legitimate providers of Lebanon’s security. The United 

States has provided security equipment and training to the LAF, which is 

generally responsible for providing border security, counterterrorism, and 

 3

S.C. Res. 1701, U.N. Doc. S/Res/1701 (2006). 
Page 6 GAO-14-161 Security-Related Assistance to Lebanon

national defense, and to the ISF, or national police force, which is 

generally responsible for maintaining law and order in Lebanon.

In 1996, Congress amended the Arms Export Control Act of 1976, which 

authorizes the President to control the sale or export of defense articles 

and services,4 to require the President to establish a program for 

monitoring the end-use of defense articles5 and defense services sold, 

leased, or exported under the act, including through Foreign Military 

Sales (FMS) and direct commercial sales,6 or the Foreign Assistance Act 

of 1961.7 The amendment specified that the program should provide 

reasonable assurances that recipients comply with restrictions imposed 

by the U.S. government on the use, transfer, and security of defense 

articles and defense services.8 The President delegated responsibilities 

for the program to the Secretary of Defense, insofar as they relate to 

defense articles and defense services sold, leased, or transferred under 

FMS, and to the Secretary of State, insofar as they relate to commercial 

exports licensed under the Arms Export Control Act.9 For FMS, DOD’s 

Defense Security Cooperation Agency (DSCA) is responsible for end-use 

monitoring; for direct commercial sales, State’s Directorate of Defense 

Trade Controls is responsible for end-use monitoring. In addition to the 

end-use monitoring requirements under the Arms Export Control Act, the 

Foreign Assistance Act, as amended, directs the President to take all 

reasonable steps to ensure that aircraft and other equipment made 

available to foreign countries for international narcotics control under the 

Foreign Assistance Act are used only in ways that are consistent with the 

 4

Arms Export Control Act, as amended, 22 U.S.C. §§ 2751 et seq. 

5

Throughout this report, we use the terms “equipment” and “security equipment”

synonymously with “defense articles.”

6

The FMS program allows recipient countries to obtain defense articles from U.S. military 

departments. Direct commercial sales involve purchases directly from U.S. companies.

7

22 U.S.C. § 2785.

8

22 U.S.C. § 2785(a).

9

See Executive Order 13637, § 1(p), 78 Fed. Reg. 16130, Mar. 8, 2013, set out as a note 

under 22 U.S.C. § 2751. Functions were previously delegated by Executive Order 11958, 

which was formerly set out as a note under 22 U.S.C. § 2751 and was revoked, subject to 

a savings provision, by section 4 of Executive Order 13637.

End-Use Monitoring
Page 7 GAO-14-161 Security-Related Assistance to Lebanon

purposes for which such equipment was made available.10 State’s Bureau 

of International Narcotics Control and Law Enforcement Affairs (INL) has 

implemented this requirement by means of its End-Use Monitoring 

Program.

To help ensure that U.S. assistance is not used to support human rights 

violators, Congress prohibits certain types of assistance from being 

provided to foreign security forces implicated in human rights abuses. 

Section 620M of the Foreign Assistance Act prohibits the United States 

from providing assistance under the Foreign Assistance Act or the Arms 

Export Control Act to any unit of a foreign country’s security forces if the 

Secretary of State has credible information that such unit has committed 

a gross violation of human rights.11 This provision is known colloquially as 

the State Leahy law. DOD’s annual appropriation contains a similar 

provision, known colloquially as the DOD Leahy law. The current version 

prohibits funds from being used to support training, equipment, or other 

assistance for security forces of a foreign country if the Secretary of 

Defense has received credible information that the unit has committed a 

gross violation of human rights.12 DOD, in consultation with State, must 

give full consideration to any credible information available to State 

relating to human rights violations by a unit of the foreign security forces 

before it conducts training for the unit. According to State, Leahy laws and 

the corresponding policies developed to enforce and supplement these 

laws are intended to leverage U.S. assistance to encourage foreign 

governments to prevent their security forces from committing human 

rights violations and to hold their forces accountable when violations 

 10Section 484 of the Foreign Assistance Act, Pub. L. No. 87-195, codified as amended at 

22 U.S.C. § 2291c(b).

1122 U.S.C. § 2378d. 

12For the purposes of this report, we use the term “Leahy laws” to refer collectively to the 

prohibition on assistance to security forces in section 620M of the Foreign Assistance Act 

of 1961 and the similar recurring provision in the DOD appropriations act prohibiting 

funding for training, equipment, or other assistance involving units of security forces, 

which was most recently enacted in section 8057 of the Consolidated Appropriations Act, 

2014. Pub. L. No. 113-76, § 8057, 128 Stat. 5, 118-119. We refer to the Foreign 

Assistance Act provision as the “State Leahy law” and the DOD appropriations provision 

as the “DOD Leahy law.” DOD and State use the term “Leahy laws” for these 

requirements, introduced in legislation by Senator Leahy, in order to distinguish them from 

other human rights requirements.

DOD and State Leahy 

Laws
Page 8 GAO-14-161 Security-Related Assistance to Lebanon

occur.13 According to State, U.S. programs subject to the Leahy laws in 

Lebanon include Foreign Military Financing; International Narcotics 

Control and Law Enforcement (INCLE); Nonproliferation, Antiterrorism, 

Demining, and Related programs; and Sections 1206 and 1207 

authorities. See appendix II for additional information on the U.S. human 

rights vetting process.

The United States allocated $671 million for security-related assistance 

for Lebanon from fiscal year 2009 through fiscal year 2013. Of these total 

allocated funds, $477 million, or 71 percent, had been disbursed or 

committed by the end of fiscal year 2013. Nearly all of the allocations 

made in fiscal years 2009 through 2011 had been disbursed or 

committed.

Since 2007, the United States has provided security-related assistance 

for Lebanon through the Foreign Military Financing program; the 

International Military Education and Training program; the INCLE 

program; the Nonproliferation, Antiterrorism, Demining, and Related 

programs;14 and Section 1206 and 1207 authorities for training and 

equipping foreign militaries and security forces and for reconstruction, 

stabilization, and security activities in foreign countries, respectively. For 

the largest program, Foreign Military Financing, DOD had committed 

about $352 million of the $481 million allocated from fiscal years 2009 

through 2013. Table 1 presents the amounts of funds allocated, 

committed, or disbursed to these programs for Lebanon in fiscal years 

2009 through 2013. Appendix III provides additional information on the 

status of these funds.

 13See GAO, Human Rights: Additional Guidance, Monitoring, and Training Could Improve 

Implementation of the Leahy Laws, GAO-13-866 (Washington, D.C.: Sept. 25, 2013). 

14The Department of State’s Nonproliferation, Antiterrorism, Demining, and Related 

programs provide security-related assistance for Lebanon through three subaccounts: 

Antiterrorism Assistance, Counterterrorism Financing, and Export Control and Related 

Border Security.

U.S. Agencies Have 

Disbursed or 

Committed Most of 

the $671 Million 

Allocated for SecurityRelated Assistance 

Programs for 

Lebanon in Fiscal 

Years 2009 through 

2013
Page 9 GAO-14-161 Security-Related Assistance to Lebanon

Table 1: Funds Allocated and Funds Committed or Disbursed by U.S. Security-Related Assistance Programs for Lebanese 

Security Forces, Fiscal Years (FY) 2009-2013

Dollars in thousands

Program or account FY2009 FY2010 FY2011 FY2012 FY2013 Total

Foreign Military Financing

Allocated 159,700 100,000 74,850 75,000 71,207 480,757

Committed 159,700 100,000 74,850 17,629 0 352,179

International Military Education

and Training

Allocated 2,278 2,500 2,467 2,372 2,850 12,467

Disbursed 1,992 2,216 2,130 1,868 943 9,149

International Narcotics Control

and Law Enforcement

Allocated 6,000 20,000 19,500 24,000 15,406 84,906

Disbursed 5,938 15,781 6,551 486 453 29,209

NADRa - Antiterrorism Assistance

Allocated 3,714 4,600 2,000 2,000 1,994 14,312

Disbursed 2,940 3,953 1,464 1,464 0 9,821

NADR - Counterterrorism Financing

Allocated 0 0 174 0 0 618

Disbursed 0 0 2 0 0 603

NADR - Export Control and Related Border Security

Allocated 400 800 800 1,050 800 3,850

Disbursed 400 798 553 467 0 2,218

Section 1206

Allocated 49,240 16,582 0 0 8,700 74,522

Disbursed 49,240 16,582 0 0 8,700 74,522

Section 1207b

Allocated 508 0 0 0 0 508

Disbursed 0 0 0 0 0 0

Total allocated 221,840 144,486 99,791 104,422 100,957 671,496

Total disbursed or committed 220,210 139,330 85,550 21,914 10,096 477,100

Source: GAO analysis of State and DOD data.

Notes: Data are as of September 30, 2013. Agencies may have several years in which to obligate 

and disburse or commit allocated funds. App. III provides additional detailed information on the 

amount of unobligated balances and unliquidated obligations for each funding account.

a

Nonproliferation, Antiterrorism, Demining, and Related (NADR) programs. The Department of State’s 

NADR security-related assistance for Lebanon has been provided through three subaccounts: 

Antiterrorism Assistance, Counterterrorism Financing, and Export Control and Related Border 

Security.

b

Section 1207 authority expired on September 30, 2010.
Page 10 GAO-14-161 Security-Related Assistance to Lebanon

Table 2 describes the U.S. security-related assistance programs for 

Lebanon and their goals, and identifies the agencies that implement 

them.

Table 2: U.S. Security-Related Assistance Programs for Lebanon

Program and implementing agency Description 

Program goals as stated by agency 

officials

Foreign Military Financinga

Department of Defense (DOD)

Provides grants and loans to foreign 

governments for the acquisition of U.S. 

defense equipment, services, and training. 

To bolster the capability of the Lebanese 

Armed Forces (LAF), nurture the bilateral 

military relationship between the United 

States and the LAF, and continue 

encouraging establishment of a stable, 

legal, and pro-U.S. civil government.

International Military Education and 

Training

DOD

Provides training, such as technical and 

professional military education, on a grant 

basis to students from allied and friendly 

nations. 

To bolster the capability of the LAF, nurture 

the bilateral military relationship between 

the United States and the LAF, and 

continue encouraging establishment of a 

stable, legal, and pro-U.S. civil government.

International Narcotics Control and Law 

Enforcement

Department of State (State)

Supports country and global programs 

critical to combating transnational crime 

and illicit threats, including efforts against 

terrorist networks in the illegal drug trade 

and illicit enterprises. 

To (1) build Lebanon’s operational capacity 

to combat crime and prevent and respond 

to terror attacks, and (2) assist Lebanon in 

developing the Internal Security Forces 

(ISF) into a competent, professional, and 

democratic police force with the necessary 

training, equipment, and institutional 

capacity to enforce the rule of law in 

Lebanon, cement sovereign Lebanese 

government control over its territory, and 

protect the Lebanese people.

NADRb - Antiterrorism Assistance

State

Trains civilian security and law enforcement 

personnel from friendly governments in 

police procedures that deal with terrorism. 

To develop and build the Lebanese 

government’s capacities in border security, 

mid- and senior-level leadership 

development, and counterterrorism 

investigations.

NADR - Counterterrorism Financing

State

Provides training for law enforcement 

officials, prosecutors, and judges, among 

others, in specific elements of money 

laundering and terrorist financing crimes. 

To deny terrorists access to money, 

resources, and support.

NADR - Export Control and Related Border 

Security

State

Assesses countries’ export control systems 

and provides a variety of assistance to help 

countries develop and improve their 

strategic trade and related border control 

systems. 

To strengthen the capability of Lebanese 

enforcement agencies to effectively control 

cross-border trade in strategic goods.

Section 1206 authority

DOD and State

Trains and equips foreign military and 

nonmilitary maritime forces to conduct 

counterterrorist operations or support 

military and stability operations in which the 

U.S. armed services are a participant. 

To bolster the capability of the LAF, nurture 

the bilateral military relationship between 

the United States and the LAF, and 

continue encouraging establishment of a 

stable, legal, and pro-U.S. civil government.
Page 11 GAO-14-161 Security-Related Assistance to Lebanon

Program and implementing agency Description 

Program goals as stated by agency 

officials

Section 1207 authorityc

State

Provides for reconstruction, stabilization, 

and security activities in foreign countries. 

To strengthen Lebanon’s internal security 

forces after armed conflicts in 2006 and 

2007.

Source: GAO analysis of State and DOD information.

Notes: Some of the information on goals is derived from discussions with DOD and State officials.

a

Foreign Military Financing can fund the transfer of services or equipment through either Direct 

Commercial Sales or Foreign Military Sales.

b

Nonproliferation, Antiterrorism, Demining, and Related (NADR) programs. The Department of State’s 

NADR security-related assistance for Lebanon has been provided through three programs: 

Antiterrorism Assistance, Counterterrorism Financing, and Export Control and Related Border 

Security.

c

Section 1207 authority expired on September 30, 2010.

We provide examples of the types of equipment some of these programs 

provide to the Lebanese security forces in the next section.

DOD and State conduct end-use monitoring for equipment each has 

provided or authorized for sale to Lebanese security forces, but gaps in 

implementation of procedures may limit efforts to safeguard some 

equipment. DOD annually inventories sensitive equipment by serial 

number, as required by its policy; however, U.S. embassy officials in 

Beirut have not always used DOD’s required checklists to document 

compliance with security safeguards and accountability procedures. In 

addition, State officials in headquarters and at the U.S. Embassy in Beirut 

did not always document the results of end-use monitoring checks as 

specified in State guidance. Finally, State INL officials annually inventory 

all equipment INL has provided to the ISF, but INL may not be ensuring 

that the ISF is implementing recommended physical security safeguards 

for defense articles because INL lacks procedures to identify defense 

articles and the recommended safeguards for storing them.

DOD and State 

Monitor End Use of 

Equipment 

Transferred to 

Lebanese Security 

Forces, but Gaps in 

Documentation and 

Security Checks May 

Limit Efforts to 

Safeguard Some 

Equipment
Page 12 GAO-14-161 Security-Related Assistance to Lebanon

DOD officials conduct annual inventories as part of end-use monitoring 

through the Golden Sentry program, which is DOD’s program to comply 

with requirements of the Arms Export Control Act, as amended, related to 

the end use of defense articles and services. DOD personnel at U.S. 

missions worldwide conduct the monitoring activities established and 

overseen by DSCA.15 Under this program, DOD conducts two levels of 

monitoring: routine end-use monitoring and enhanced end-use 

monitoring.

• Routine end-use monitoring: DOD conducts routine end-use 

monitoring for defense articles and services sold through FMS that do 

not have any unique conditions associated with their transfer. Routine 

end-use monitoring is conducted in conjunction with other required 

security-related duties. For example, U.S. officials might observe how 

a host country’s military is using U.S. equipment when visiting a 

military installation on other business.

• Enhanced end-use monitoring: DOD conducts enhanced end-use 

monitoring for defense services, technologies, or articles specifically 

identified as sensitive—such as night vision devices. DOD policy 

requires serial number inventories for defense articles requiring 

enhanced end-use monitoring following delivery of the articles and at 

regular intervals thereafter. In addition, Letters of Offer and 

Acceptance, the FMS purchase agreements authorizing the sale of an 

item, may contain specialized notes or provisos requiring the 

purchaser to adhere to certain physical security and accountability 

requirements.16

With respect to enhanced end-use monitoring, DSCA’s policy manual for 

end-use monitoring, the Security Assistance Management Manual,17 and 

 15DSCA is the central agency that coordinates global security cooperation programs, 

funding, and efforts across the Office of the Secretary of Defense, Joint Staff, State 

Department, combatant commands, the military services, and U.S. industry. DSCA 

administers the Golden Sentry program. Activities include conducting regional forums to 

provide updated policy guidance, visiting DOD overseas officials to assess their 

compliance with Golden Sentry policy, and publishing and disseminating end-use 

monitoring best practices and lessons learned. 

16Letters of Offer and Acceptance are FMS purchase agreements between the United 

States and a foreign purchaser. The specialized notes that may be in these agreements 

are outlined in Chapter 5 of the Security Assistance Management Manual.

17Department of Defense, Defense Security Cooperation Agency, Security Assistance 

Management Manual, (Washington, D.C.: Apr. 30, 2012), accessed January 9, 2014, 

http://www.samm.dsca.mil/.

DOD Officials Conduct 

Annual Inventories in EndUse Monitoring for 

Sensitive Equipment
Page 13 GAO-14-161 Security-Related Assistance to Lebanon

the associated standard operating procedures for Beirut require DOD 

officials annually to

• conduct a physical inventory of 100 percent of designated defense 

articles,18

• conduct physical security checks of facilities where the equipment is 

kept, and

• use and maintain records of equipment-specific checklists that outline 

the physical security requirements for Lebanese facilities that store 

the equipment.

Officials of DOD’s Office of Defense Cooperation in Beirut19 told us that 

they annually conduct an inventory involving the inspection of serial 

numbers for 100 percent of defense articles requiring enhanced end-use 

monitoring. Such equipment includes certain types of missiles, night 

vision devices, sniper rifles, aircraft, and unmanned aerial vehicles. 

Figure 3 shows examples of defense articles provided to the LAF.20

 18According to the DSCA Security Assistance Management Manual, enhanced end-use 

monitoring is conducted through planned and coordinated visits to the host nation’s 

installations and verification of in-country receipt of defense articles by serial number 

within 90 days of delivery. Subsequent inventories require serial number verification, 

physical security checks of storage sites or other facilities where defense articles 

designated for enhanced end-use monitoring are located, and verification that recipients 

are complying with the terms and conditions stated in the transfer agreements.

19The Office of Defense Cooperation executes security assistance and cooperation 

programs in partnership with U.S. Embassy country teams and under the direction of the 

U.S. ambassador.

20According to a DOD official in Beirut, DOD officials also conduct 100 percent annual 

inventories for other items provided to Lebanon that are not subject to enhanced end-use 

monitoring, although this is not a requirement of DSCA’s Security Assistance 

Management Manual.
Page 14 GAO-14-161 Security-Related Assistance to Lebanon

Figure 3: Photographs of Lebanese Armed Forces Equipment Prepared for End-Use 

Monitoring

During our visit to Beirut in July 2013, we determined that DOD and the 

LAF accounted for almost 100 percent of the defense items in our sample 

in two locations. To assess the extent to which DOD accounts for 

equipment provided to the LAF, we drew a random sample by serial 

number from DOD’s equipment inventory database for two locations we 
Page 15 GAO-14-161 Security-Related Assistance to Lebanon

planned to visit during our fieldwork in Lebanon.21 The items in the 

sample included various types of night vision devices at one location and 

various types of night vision devices and a sniper rifle at the other 

location. Although the results cannot be generalized to these or other 

locations, they showed that DOD and the LAF accounted for almost 100 

percent of the items in our sample in both locations. In addition, during 

our visit, DOD performed its 2013 inventory of 100 percent of the 

equipment provided to one of the LAF regiments, including some new 

equipment not previously inventoried. The DOD officials were able to 

confirm that all equipment was either physically present or accounted for 

through documentation. Figure 4 shows U.S. officials conducting the 

inventory of U.S.-provided equipment at an LAF facility.

Figure 4: U.S. Officials Conducting an Inventory of U.S.-Provided Equipment at a 

Lebanese Armed Forces Facility

 21The sample consisted of 15 items from each location, from a total of 68 items at one 

location and 116 items at the other. We directly observed 13 of the 15 items at one 

location and 9 of the 15 at the other location. DOD and LAF officials showed us 

documentation that accounted for the whereabouts of the items we were not able to 

inspect. For example, the LAF presented documents showing that some items were 

signed out to another LAF location. In such cases, DOD officials in Beirut require the LAF 

to present equipment for inspection at a later date.
Page 16 GAO-14-161 Security-Related Assistance to Lebanon

When U.S. travel restrictions due to security concerns prohibit U.S. 

embassy personnel from traveling to specific areas of Lebanon in which 

some LAF storage facilities are located, DOD officials in Beirut require the 

LAF to bring the equipment to a central location in Beirut to allow the 

DOD officials to conduct the annual inventory. DOD quarterly reports from 

2011 through 2013 show 100 percent accountability for equipment 

provided to the LAF.

As part of end-use monitoring, DSCA’s Security Assistance Management 

Manual and the standard operating procedures for Beirut require DOD 

officials to conduct physical security checks of LAF facilities, using a 

required checklist to document accountability and physical security of 

U.S.-provided equipment.22 While DOD’s quarterly reports from 2011 

through 2013 show 100 percent accountability for equipment provided to 

the LAF, during our site visit in July 2013, we determined that DOD 

officials in Beirut were not using the required checklist to document 

compliance with physical security safeguards. The DOD manual 

specifically directs that enhanced end-use monitoring must be performed 

using checklists developed by the military departments. Furthermore, 

according to the manual, all such checks must be recorded, with the 

physical security and accountability checklists attached to the inventory 

records that must be maintained for 5 years.

According to a DOD official in Beirut, at least 75 percent of the U.S.-

provided equipment subject to end-use monitoring is held in locations 

where DOD can and has conducted inspections to verify compliance with 

physical security requirements. For the remaining facilities, DOD 

mitigates security challenges by other means. DOD officials stated that a 

U.S. embassy employee who is a Lebanese national had visited some 

locations that U.S. officials were not able to visit because of security 

concerns and had conducted physical security compliance checks at 

those locations. For each of the remaining facilities that neither a U.S. 

official nor this Lebanese employee could personally inspect, DOD also 

requires the LAF to submit a letter attesting that the appropriate physical 

security measures had been implemented.

 22Such physical security conditions might include fencing, a locked or guarded building 

structure, and specific types of doors and locks.

DOD Officials Have Not 

Always Used Required 

Checklists to Document 

Compliance with Security 

Safeguards
Page 17 GAO-14-161 Security-Related Assistance to Lebanon

During our site visit in July 2013, we determined that when DOD officials 

in Beirut were able to conduct physical security checks, they were not 

using checklists for enhanced end-use monitoring required by DSCA’s 

Security Assistance Management Manual to ensure that security 

safeguards and accountability procedures are in place. The manual 

directs that enhanced end-use monitoring must be performed using 

checklists developed by the military departments. Furthermore, according 

to the manual, all such checks must be recorded, with the physical 

security and accountability checklists attached to the inventory records 

that must be maintained for 5 years.

Our finding was consistent with the results of a 2011 DSCA compliance 

assessment visit, when DSCA officials also found that the DOD Office of 

Defense Cooperation in Beirut was not using the required checklists to 

verify Lebanese compliance with facility security requirements.23 In April 

2012, U.S. officials in Beirut responded to the DSCA finding, stating that 

they planned to use the checklists during their 2012 annual inventory. In 

their response, they also stated that the requirement to use DSCAprovided checklists during inventories was captured in the post’s updated 

standard operating procedures for end-use monitoring.24 We followed up 

on this matter in September 2013 and found that, when presented 

examples of the checklists, DOD officials in Beirut said that they were not 

aware of the checklists. The officials, however, noted that the information 

requested in the checklists is the same type of information they enter into 

the Security Cooperation Information Portal, which is the system used to 

record end-use monitoring activities.25 However, the documentation of the 

 23In 2011, DSCA conducted a compliance assessment visit to Lebanon that included a 

review of selected LAF facilities for compliance with requirements to safeguard U.S.-

provided equipment. DSCA officials found that some LAF facilities did not meet certain 

safeguard requirements and recommended corrective actions. U.S. officials from the 

embassy inspected the facilities during the 2012 annual equipment inventory. According to 

the 2012 report on the results of that inventory, the LAF had upgraded doors and storage 

containers at facilities storing night vision devices, installed double barriers, moved some 

equipment to more secure facilities, and equipped some facilities with external lighting.

24Office of Defense Cooperation, U.S. Embassy, Beirut, End-Use Monitoring Program: 

Golden Sentry Program End-Use Monitoring and Enhanced End-Use Monitoring (Beirut, 

Lebanon: April 25, 2012).

25The Security Cooperation Information Portal is a web-based database DOD designed to 

manage various security assistance activities, including the Golden Sentry program. It 

includes information on the defense articles purchased by each country, the date that 

these items were last inventoried, and the status of their inventories.
Page 18 GAO-14-161 Security-Related Assistance to Lebanon

end-use monitoring we observed did not include sufficient information on 

the physical security of the equipment. Use of the checklists would help 

ensure that DOD officials document compliance with physical security 

requirements for defense items transferred to the LAF. Without such 

documentation, it is not clear whether DOD officials verify physical 

security safeguards as required by DSCA’s manual. In December 2013, 

DOD officials acknowledged that there had been a gap in the Office of 

Defense Cooperation’s use of the checklists.

State’s Directorate of Defense Trade Controls administers a program 

called Blue Lantern to conduct end-use monitoring for defense articles 

and defense services exported through direct commercial sales. Under 

the Blue Lantern program, U.S. embassy officials conduct end-use 

checks by means of a case-by-case review of export license applications 

against established criteria or “warning flags” for determining potential 

risks. Embassy officials primarily conduct two types of end-use monitoring 

checks: prelicense checks prior to issuance of a license and 

postshipment checks after an export has been approved and shipped.26

• Prelicense checks: A prelicense check may be requested to (1) 

confirm the bona fides of an unfamiliar consignee or end-user; (2) 

ensure that details of a proposed transaction match those identified 

on a license application; (3) confirm that the end-user listed on the 

license application has ordered the items in question; (4) verify the 

security of facilities where items may be permanently or temporarily 

housed; and (5) help to ensure that the foreign party understands its 

responsibilities under U.S. regulations and law.

• Postshipment checks: The Directorate of Defense Trade Controls may 

request a postshipment check in order to (1) confirm that the party or 

parties named on the license received the licensed items exported 

from the United States; (2) determine whether the items have been or 

are being used in accordance with the provisions of that license; (3) 

identify any parties involved in the transaction that are not listed on 

the license application; and (4) determine the specific use and 

handling of the exported articles, or other issues related to the 

transaction.

 26State also occasionally conducts checks after a license has been issued but before the 

items have been shipped if new information comes to light indicating possible concerns 

about a transaction that were not known at the time the license was approved.

State Did Not Consistently 

Document End-Use 

Checks for Defense 

Equipment That Lebanon 

Purchased Commercially
Page 19 GAO-14-161 Security-Related Assistance to Lebanon

State’s Blue Lantern guidebook provides instructions to U.S. diplomatic 

posts on how to conduct Blue Lantern end-use monitoring, including 

reporting and documentation requirements.27 For example, the guide 

specifies the type of information that should be included in cables from 

the overseas posts in response to an inquiry from State.

In fiscal years 2007 through 2012, State conducted 15 Blue Lantern enduse monitoring checks for equipment—mostly firearms for the ISF—

authorized for export to Lebanon through direct commercial sales.28 State 

reported favorable results for 14 of the Blue Lantern checks and 

unfavorable results for one.29

On the basis of our review of State documents and interviews with U.S. 

officials in Washington, D.C., and Beirut, we determined that State 

officials in headquarters and at the U.S. Embassy in Beirut did not always 

document the results of the Blue Lantern checks consistent with guidance 

specified in State’s Blue Lantern guidebook. According to the guidebook, 

all Blue Lantern requests are sent by cable to the U.S. embassy or 

consulate in the country or countries involved in the transaction. The 

guidebook specifies that Blue Lantern cables prepared by the U.S. 

mission in response to the request should describe specific actions taken 

and results of the inquiry, including identification of persons interviewed; 

description of documents or equipment reviewed; difficulties incurred; 

degree of cooperation by the end-users, consignees, or both; and 

recommendations for State action, if appropriate. According to the 

guidebook, the U.S. mission should maintain detailed records regarding 

the Blue Lantern cases as a resource to facilitate future checks and to 

brief new staff on how to conduct the checks.

To assess State’s compliance with its Blue Lantern guidance, we selected 

a judgmental sample of all 10 Blue Lantern checks for equipment 

exported or intended for export to Lebanon in fiscal years 2010 through 

2012 and requested copies of the cables associated with those checks. 

 27Department of Defense, Directorate of Defense Trade Controls, Blue Lantern: A Guide 

to End-Use Monitoring of Defense Articles and Services Exported via Commercial 

Channels (Washington, D.C.: July 2010).

28Two cases were not completed. No defense articles were involved.

29During this same period, State approved a total of about 200 licenses for direct 

commercial sales of defense articles to Lebanon.
Page 20 GAO-14-161 Security-Related Assistance to Lebanon

State documented the details of 5 of the 10 checks in diplomatic cables 

and 1 in e-mail messages. For the 4 remaining Blue Lantern checks, 

State officials informed us that the requests from headquarters and the 

responses from the embassy were made by e-mail. We asked for copies 

of the e-mails, but State officials told us that the e-mails were no longer in 

State’s information system. A State official noted that the Blue Lantern 

database had case summaries based on the e-mails. However, the 

summary information in the database consisted of notes that did not 

always contain all the required information specified in State’s guidance. 

For example, the summary information for the cases in which the e-mails 

were no longer available showed that the embassy officials met with the 

ISF but did not identify the officials interviewed. Without the information 

specified in the guidebook, State may not have information it needs to 

fully inform future checks and train new staff. State said in February 2014 

that the U. S. Embassy in Beirut has established a policy requiring all 

Blue Lantern responses to be sent via cable to Washington, D.C., in order 

to ensure that there is a permanent record of the Embassy's response to 

a Blue Lantern check. However, State did not provide support this 

statement.

As required by INL’s End-Use Monitoring Program, INL officials conduct 

an annual inventory by serial number of equipment that INL has provided 

to the ISF. This equipment typically includes office furniture, vehicles, and 

computer equipment but may also include boats, training firearms, and 

police vehicles. (See fig. 5 for photographs of equipment INL provided to 

the ISF.) INL personnel said they had attached barcodes to the 

equipment and we observed them use a scanner to inventory the 

equipment. The 2012 INL inventory report for Lebanon shows that INL 

personnel inspected about 78 percent of 1,243 items provided to the 

Lebanese security forces. INL personnel may also inspect items by 

secondary means including comparing inventory records and consulting 

with host government officials.

State’s INL Inventories 

Equipment Provided to the 

ISF but May Not Be 

Ensuring That Recipients 

Implement Recommended 

Physical Security 

Safeguards for Defense 

Articles
Page 21 GAO-14-161 Security-Related Assistance to Lebanon

Figure 5: Photographs of U.S. Equipment Provided to Lebanon’s Internal Security 

Forces
Page 22 GAO-14-161 Security-Related Assistance to Lebanon

While INL officials annually inventory all equipment INL has provided to 

the ISF, INL may not be ensuring that the ISF is implementing 

recommended physical security safeguards for defense articles because 

INL lacks procedures to identify defense articles and the recommended 

safeguards for storing them. In May 2013, we asked INL officials if any of 

the equipment INL had provided to Lebanon were defense articles. 

Though INL officials first told us that they had provided no defense 

articles or any other controlled items to Lebanon, in August 2013 INL 

provided us with its formal response confirming that it had provided two 

defense articles to the ISF—night vision devices and ceramic plates for 

bullet proof vests. With regard to these two articles, we found the 

following:

• INL consulted with the directorate only one of the two times it sought 

to transfer defense articles to Lebanon during the period covered by 

our review. While INL did not have formal procedures for identifying 

defense articles, INL officials stated that their practice is to contact 

State’s Directorate of Defense Trade Controls, which licenses direct 

commercial sales of defense articles, when providing equipment 

pursuant to a certain license exception. In 2012, INL consulted with 

the directorate to confirm that no export license would be required for 

the provision of night vision devices to the Government of Lebanon.30

In the directorate’s memo back to INL confirming that no license was 

required, INL was informed of physical security safeguards that the 

directorate recommended that the INL should direct the ISF to 

implement as conditions for a transfer of night vision devices to the 

ISF. However, INL did not consult the directorate about ceramic 

plates, which INL provided for bullet proof vests that it transferred to 

the ISF in February 2013 under the license exception. This was the 

only other case that INL identified in which it provided a defense 

article to the ISF. Although INL did not consult with the directorate 

about the ceramic plates, INL officials said that INL would contact the 

directorate in the future about any defense articles it planned to 

transfer to the ISF.

 30According to a July 2012 memorandum prepared in response, the Directorate of 

Defense Trade Controls indicated that INL could transfer the equipment without a license 

under Section 38 (b)(2) of the Arms Export Control Act, which states that no export license 

shall be required for exports by or for any agency of the U.S. government for carrying out 

a foreign assistance or sales program authorized by law and subject to control by the 

President by other means. The “control by the President by other means” in this case was 

the ability to monitor and control procurements to the ISF through end-use monitoring by 

the U.S. Embassy in Beirut. 
Page 23 GAO-14-161 Security-Related Assistance to Lebanon

• INL lacked written procedures to determine what physical security 

safeguards are recommended for defense articles. INL officials said 

that the ISF secures INL-provided equipment and guards the facilities 

where it is stored. According to embassy officials in Beirut, there are 

no INL requirements for inspecting the ISF facilities where U.S.-

provided equipment is stored. However, when INL consulted the 

Directorate of Defense Trade Controls about the transfer of night 

vision devices to the ISF, the directorate recommended that INL place 

10 conditions on the transfer. These conditions included 5 technical 

parameters setting limitations on the performance of key components 

of the night vision devices, such as the brightness and resolution of 

their image intensifier tubes, and 5 physical security safeguards that 

the ISF should implement, such as storing the devices in a secured, 

locked facility. State officials in Washington, D.C., said that, although

the conditions communicated by the directorate to the INL were not 

requirements, embassy officials would, in the future, inspect ISF 

facilities to see that the recommended physical security safeguards 

were being implemented. Nonetheless, in the absence of written 

procedures, it is unclear what procedures INL would follow for future 

transfers of defense articles. Moreover, INL communicated the 

conditions of the transfer of night vision devices to the ISF only in 

September 2013, after transferring the equipment in August 2013. 

Communicating conditions for physical security safeguards to the ISF 

after delivery of the equipment could lessen INL’s ability to determine 

whether the ISF implements those safeguards.

In response to our inquiries on its plans to address potential gaps in 

physical security safeguards for defense articles, INL stated in January 

2014 that it would update its Acquisition Handbook to document new 

policies. State anticipates that changes to the handbook would require 

INL to inform the Directorate of Defense Trade Controls of INL’s decision 

to procure and provide equipment without an export license, as allowed 

under Section 38(b)(2) of the Arms Export Control Act. However, it is 

unclear whether these revisions would establish procedures to (1) identify 

when items are defense articles and (2) determine if physical security 

safeguards are recommended.
Page 24 GAO-14-161 Security-Related Assistance to Lebanon

State’s 2012 Guide to Vetting Policy and Process—a primary source of 

guidance for U.S. personnel responsible for implementing the Leahy 

laws—requires State officials in Washington, D.C., and overseas to vet 

for potential human rights violations all individuals or units nominated to 

receive training or equipment by checking their names against files, 

databases, and other sources of information.31 In detailing the steps for 

vetting, the guidance specifies that relevant data are to be entered into 

the International Vetting and Security Tracking (INVEST) database.32

INVEST is State’s official system of record for conducting Leahy vetting 

and recording compliance with the Leahy laws. State requires human 

rights vetting through INVEST unless the individual or unit has already 

been vetted within the prior year, according to a State official. State 

approves, suspends, or denies the requests for training as a result of its 

vetting efforts. 33 Our review of State’s INVEST database showed that 

State vetted almost 10,000 individuals and units in Lebanon that applied 

for U.S. training from October 10, 2010, through April 30, 2013. The 

majority (77 percent), applied for INCLE training (see figure 6). By crosschecking a random sample of names from six rosters for U.S. training 

delivered to Lebanese security force individuals or units against State’s 

designated vetting database, we found that all the names in the sample 

had been vetted for human rights violations before the individuals 

received the training, as required.

 31See Department of State, Compliance with the State and DOD Leahy Laws: A Guide to 

Vetting Policy and Process (Washington, D.C.: September 2012). 

32INVEST was launched in Lebanon on October 10, 2010. Prior to the implementation of 

INVEST, State used cables to communicate vetting requests and results between State 

headquarters in Washington, D.C., and U.S. embassies around the world. 

33To suspend is to withdraw a candidate from consideration. In some instances, the post 

withdraws a name due to non-Leahy-specific grounds, such as suspicion of involvement in 

narcotics or corruption.

U.S. Government Has 

Vetted Lebanese 

Recipients for Human 

Rights Violations Prior 

to Providing 

Assistance
Page 25 GAO-14-161 Security-Related Assistance to Lebanon

Figure 6: Percentage of Lebanese Candidates That Applied for U.S. SecurityRelated Training, by Funding Source

Notes: Percentages do not sum to 100 because of rounding. Included in data were all individuals and 

units in Lebanon that applied for U.S. security-related training from October 10, 2010, through April 

30, 2013—a total of almost 10,000 candidates.

State approved training for approximately 93 percent of the candidates 

and disallowed training for the remaining 7 percent for whom the vetting 

process produced a suspension. While administrative reasons accounted 

for most of the suspensions, such as a name submitted with insufficient 

time for vetting clearance prior to the class start date, potential human 

rights violations accounted for a few suspensions.34 U.S. officials in Beirut 

communicated suspensions based on human rights violations to 

Lebanese government officials. Administrative reasons for some 

suspensions were not communicated to the Lebanese government 

because the U.S. officials did not think they were required to do so. In 

 34Other administrative reasons recorded for suspensions in Lebanon included the 

following: vetting was not required, incorrect names, or the course was cancelled, 

according to INVEST case notes as of May 21, 2013. 
Page 26 GAO-14-161 Security-Related Assistance to Lebanon

September 2013, we reported that State guidance to embassies on the 

human rights vetting process did not specify whether the requirement to 

inform foreign governments applies when a unit or individual is 

suspended from receiving assistance.35 Hence, we recommended that

State provide clarifying guidance for implementing the duty-to-inform 

requirement of the State Leahy law, such as guidance on whether U.S. 

embassies should or should not notify a foreign government in cases of 

suspensions.36 On the basis of evidence presented in a June 2013 

Human Rights Watch report on Lebanon, in August 2013, State issued its 

first denial for training to individuals from the Drugs Repression Bureau of 

the ISF and informed ISF about this denial.37 As a result of the denial, 

three Lebanese counternarcotics officials were not approved for a 

September 2013 training course. Officials of the U.S. Embassy in Beirut 

communicated the reasons for the denial to the ISF during the course of 

our review.38

On the basis of our cross-check analysis of a sample of names from six 

training rosters against INVEST data, we estimated that State vetted for 

potential human rights violations all Lebanese students who attended 

security forces training from October 10, 2010, through April 30, 2013. 

We selected a random sample of 118 names from training rosters from 

the Lebanese Armed Forces; INCLE; Antiterrorism Assistance and other 

Nonproliferation, Antiterrorism, Demining, and Related programs; and 

International Military Education and Training. We cross-checked those 

names with the names of all Lebanese candidates vetted for human rights 

violations through INVEST from October 10, 2010, through April 30, 2013. 

Results of our analysis show that all 118 names on the training rosters 

were also found in INVEST. Therefore, we estimate that 100 percent of 

the 7,104 Lebanese students that attended U.S. training during that 

 35State’s guidance notes that a unit or individual should be suspended if the embassy 

cannot confirm or rule out the derogatory information found on a unit or individual in time 

to accommodate a training event.

36See GAO-13-866.

37Human Rights Watch, “It’s Part of the Job”: Ill-treatment and Torture of Vulnerable 

Groups in Lebanese Police Stations (June 2013). 

38In response to an official letter from U.S. Embassy in Beirut, the ISF launched a number 

of conferences and training courses on human rights and opened an investigation into the 

content of the Human Rights Watch report. 
Page 27 GAO-14-161 Security-Related Assistance to Lebanon

period were vetted for human rights violations through INVEST before 

they received training (see table 3).39

Table 3: Population of Lebanese Student Names on Training Rosters and Final Sample of Names Selected for Cross-Check 

with International Vetting and Security Tracking Database Records

Training rosters Population Final Sample

1 Foreign Military Financing 423 10

2 International Narcotics Control and Law Enforcement (I) 3,093 39

3 International Narcotics Control and Law Enforcement (II) 3,133 39

4 Antiterrorism Assistance (Nonproliferation, Antiterrorism, Demining, and Related programs) 247 10

5 Other Nonproliferation, Antiterrorism, Demining, and Related programs 10 10

6 International Military Education and Training 198 10

Total 7,104 118 a

Source: GAO analysis of State data.

a

We deleted two names from our original sample of 120 names because the individuals were 

scheduled to attend a course that occurred prior to October 10, 2010, the date that INVEST was 

launched in Lebanon.

The U.S. Embassy in Beirut also conducts human rights vetting for units 

that are to receive equipment. In November 2011, State agreed with our 

recommendation that it implement individual- and unit-level human rights 

vetting for all recipients of equipment.40 As of July 2013, Bureau of 

Democracy, Human Rights, and Labor officials said that vetting of units 

that receive equipment is increasing worldwide and that the bureau hopes 

to achieve State-wide concurrence implementing the recommendation.

State guidance also requires embassies to develop standard operating

procedures for human rights vetting. The U.S. Embassy in Beirut 

developed standard operating procedures to implement State guidance 

during the course of our review. In September 2013, we found that State 

does not monitor whether all U.S. embassies have developed standard 

operating procedures that address the Leahy laws’ requirements. 

Therefore, we recommended, and State agreed, to ensure that all U.S. 

 39We are 95 percent confident that the actual proportion of INVEST names that were 

properly vetted was at least 97 percent.

40See GAO, Persian Gulf: Implementation Gaps Limit the Effectiveness of End-Use 

Monitoring and Human Rights Vetting for U.S. Military Equipment, GAO-12-89

(Washington, D.C.: Nov. 17, 2011).
Page 28 GAO-14-161 Security-Related Assistance to Lebanon

embassies have standard operating procedures that address human 

rights vetting requirements in the Leahy laws.41

U.S. agencies have allocated hundreds of millions of dollars for 

equipment and training to the government of Lebanon as part of U.S. 

efforts to build partner capacity and address threats to U.S. interests. 

Such efforts remain a U.S. priority. Just as important to the interests of 

the United States and its partners are efforts to ensure that any provided 

security-related equipment or training assistance does not help those who 

wish to do harm to the United States or its partners. Hence, end-use 

monitoring and human rights vetting are two critical activities that the U.S. 

government employs in Lebanon and worldwide to prevent misuse of its 

security-related equipment and training assistance. However, existing 

implementation gaps may weaken efforts to safeguard some equipment 

from misuse. These gaps involve embassy officials not utilizing required 

checklists to verify Lebanese facilities’ safeguards for sensitive defense 

equipment and not documenting details of State’s end-use checks. 

Closing these gaps could help mitigate the impact of security-related 

travel restrictions on U.S. officials’ access to some locations and could 

also help raise the level of confidence that Lebanese security forces are 

complying with security requirements. Because end-use monitoring in 

Lebanon is intended to provide U.S. officials with visibility over the 

implementation of required safeguards, the above-mentioned gaps 

reduce the U.S. government’s confidence that safeguards are being 

properly implemented to prevent equipment from falling into the wrong 

hands. Furthermore, the absence of INL procedures for identifying 

defense articles erodes confidence that State officials are applying 

recommended end-use monitoring and security safeguards on defense 

equipment. On a more positive note, our analysis did confirm that 100 

percent of the Lebanese recipients of U.S. training were vetted for human 

rights violations and that this system appears to be working as intended in 

Lebanon.

To help ensure that U.S. agencies are in a better position to ensure 

adequate safeguards for and monitoring of sensitive equipment, we 

recommend that the Secretary of Defense take additional steps to ensure 

 41See GAO-13-866.

Conclusions

Recommendations for 

Executive Action
Page 29 GAO-14-161 Security-Related Assistance to Lebanon

that Office of Defense Cooperation officials in Beirut use the checklists 

required during the physical security checks.

In addition, we recommend that the Secretary of State take the following 

three actions:

• Direct the Directorate of Defense Trade Controls and U.S. officials 

overseas to maintain cables or e-mails as required by State guidance 

to document each Blue Lantern end-use check.

• Direct State bureaus transferring equipment to foreign security forces 

under security-related assistance programs to establish formal written 

procedures to identify whether items are defense articles.

• Direct State bureaus transferring equipment to foreign security forces 

under security-related assistance programs to establish formal written 

procedures to consult with the Directorate of Defense Trade Controls 

to determine if there are additional safeguards recommended for the 

transfer of the defense articles.

We provided a draft of this report to DOD and State for comment. DOD 

and State provided written comments which are reprinted in appendixes 

IV and V, respectively. State also provided technical comments, which we 

have incorporated into the report, as appropriate. In their comments, DOD 

and State generally concurred with the report’s findings and 

recommendations.

In its written comments, DOD noted that the Office of Defense 

Cooperation in Beirut has started taking steps to address the 

recommendation.

In its written comments, State noted that while it agreed with our 

recommendation that it maintain records of cables and e-mails that 

document each Blue Lantern end-use check, it disagreed with our finding 

that it did not adequately do so with regard to Lebanon. State noted that it 

did document key findings of the four inquiries in the Blue Lantern 

database, as these cases were adjudicated together as a group involving 

the same foreign consignee and Lebanese Security Forces. However, as 

we pointed out in the draft report, the summary information in State’s

database consisted of notes that did not always contain all the required 

information specified in State’s guidance. For example, the summary 

information on the four cases showed that the embassy officials met with 

the ISF but did not identify the officials interviewed. State also noted that 

the draft referred to defense articles that were "exported" to Lebanon

Agency Comments

and Our Evaluation
Page 30 GAO-14-161 Security-Related Assistance to Lebanon

rather than “authorized” for export. We have revised the report

accordingly.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until five days from the 

report date. At that time, we will send copies of this report to appropriate 

congressional committees; the Secretary of Defense; the Secretary of 

State; and other interested parties. In addition, the report will be 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) 512-7331 or johnsoncm@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 VI.

Sincerely yours,

Charles Michael Johnson, Jr.

Director, International Affairs and Trade
Appendix I: Scope and Methodology

Page 31 GAO-14-161 Security-Related Assistance to Lebanon

The objectives of this review were to assess the extent to which the U.S. 

government (1) disbursed or committed funds allocated for Lebanese 

security forces in fiscal years 2009 through 2013, (2) implemented enduse monitoring for equipment transferred to Lebanese security forces, 

and (3) vetted Lebanese recipients of U.S. security-related training for 

human rights violations. To address these objectives, we obtained 

funding data from the Department of Defense (DOD) and the Department 

of State (State) on programs that provide security-related assistance to 

Lebanon. We also analyzed documents from DOD and State, such as 

cables, manuals, handbooks, compliance and inventory reports, and data 

on U.S.-provided equipment, training, and end-use checks, among 

others. We interviewed U.S. officials in Washington, D.C.; at the U.S. 

Central Command in Tampa, Florida; and at the U.S. Embassy in Beirut, 

Lebanon, as well as officials of the Lebanese Armed Forces (LAF) and 

Internal Security Forces (ISF) in Beirut, Lebanon.

To assess the extent to which the U.S. government has disbursed or 

committed security-related assistance funding for Lebanon’s security 

forces since fiscal year 2009, we requested data from State and DOD. 

The funding data we report represent the balances as of September 30, 

2013. State provided data on the status of allocations, obligations, 

unobligated balances, and disbursements for all of the funding accounts 

that support security-related assistance in Lebanon: Foreign Military 

Financing; International Narcotics Control and Law Enforcement; 

International Military Education and Training; and Nonproliferation, 

Antiterrorism, Demining and Related Programs; and Section 1206 and 

1207 authorities. State collected the data directly from each bureau for 

State-implemented accounts and from DOD for Foreign Military Financing 

and International Military Education and Training. However, because 

Foreign Military Financing funds are budgeted and tracked in a different 

way than other foreign assistance accounts, DOD provided us with data 

on commitments. Recognizing that different agencies and bureaus may 

use slightly different accounting terms, we provided each agency with the 

definitions from GAO’s A Glossary of Terms Used in the Federal Budget 

Process1 and requested that each agency provide the relevant data 

according to those definitions. We also discussed the types of assistance 

provided with various officials of the LAF and the ISF. To assess the 

 1

GAO, A Glossary of Terms Used in the Federal Budget Process, GAO-05-734SP

(Washington, D.C.: September 2005).

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 32 GAO-14-161 Security-Related Assistance to Lebanon

reliability of the data provided, we requested and reviewed information 

from officials from each agency regarding the agency’s underlying 

financial data system(s) and the checks, controls, and reviews used to 

ensure the accuracy and reliability of the data provided. We determined 

that the data provided were sufficiently reliable for the purposes of this 

report.

To assess the extent to which the U.S. government has implemented 

end-use monitoring for equipment provided to Lebanese security forces, 

we reviewed relevant laws and regulations, DOD and State policy 

guidance, and reports and other documents; analyzed equipment and 

end-use monitoring data and reports; and interviewed officials from DOD, 

State, the LAF, and the ISF.

For DOD’s Golden Sentry program, we reviewed policy and guidance 

documents, including the Defense Security Cooperation Agency’s 

Security Assistance Management Manual, the Office of Defense 

Cooperation-Beirut’s Standard Operating Procedures, the Security 

Cooperation Information Portal End-Use Monitoring Customer Assistance 

Handbook, and U.S. Central Command regulations. We also obtained 

and analyzed the 2012 Compliance Assessment Visit to Lebanon report, 

U.S. Central Command Inspector General Report for the Office of 

Defense Cooperation-Beirut, annual end-use monitoring reports for 

Lebanon, reports of lost or destroyed U.S. equipment provided to 

Lebanon, Lebanese compliance plans for safeguarding U.S. equipment, 

and security checklists required for enhanced end-use equipment in 

Lebanon. In addition, we reviewed and analyzed data and management 

reports on the equipment provided to Lebanon and end-use checks. 

Specifically, we reviewed management reports from DOD’s Security 

Cooperation Information Portal database, including delinquent, 

reconciliation, ad-hoc, and trend reports. We used the portal database to 

identify defense articles provided to Lebanon that require routine and 

enhanced end-use monitoring and the compliance actions taken for the 

items. We compared the data on defense articles and end-use monitoring 

to the various management reports and found the data to be sufficiently 

reliable for our purposes. Using the data provided by DOD, we drew a 

nongeneralizable random sample of 30 items for physical inspection out 

of 184 items that required enhanced end-use monitoring at two locations 

in Beirut, Lebanon. During our fieldwork at one of the locations, we 

observed DOD officials conducting enhanced end-use monitoring checks. 

In addition, we interviewed DOD officials with the Defense Security 

Cooperation Agency, U.S. Central Command, U.S. Special Operations 
Appendix I: Scope and Methodology

Page 33 GAO-14-161 Security-Related Assistance to Lebanon

Command, and the U.S. Embassy in Beirut. In Lebanon, we also met with 

officials from the LAF and the ISF.

For State’s Blue Lantern program, we reviewed the Blue Lantern 

guidebook.2 We reviewed and analyzed Direct Commercial Sales license 

data, and Blue Lantern checks for Lebanon from fiscal years 2007 

through 2012. Although State conducted 15 checks between fiscal years 

2007 and 2012, we analyzed only the 10 Blue Lantern checks conducted 

in fiscal years 2011 and 2012. We limited our analysis to checks during 

these years to increase the likelihood that the embassy officials who 

conducted these checks would still be in their current positions, thereby 

enabling further discussion about the specific details of the checks. We 

requested both outgoing and responding cables for each of the 10 

checks; State was unable to provide cables or email communication for 4 

of the 10 Blue Lantern checks. Based on summary information provided 

for each check and cables and e-mail correspondence on 7 of the 10 

checks, we analyzed and recorded information about each case, 

including the subject of the check, the commodity checked, license 

conditions, evidence that site visits were or were not requested and 

conducted, inventories requested and conducted, and any follow-up that 

post indicated was necessary. We determined the Blue Lantern data to 

be sufficiently reliable for our purposes. In addition, we interviewed State 

officials in the Bureau of Political and Military Affairs, the Bureau of Near 

Eastern Affairs, the Office of Foreign Assistance, and the Directorate of 

Defense Trade Controls in Washington, D.C., as well as officials at the 

U.S. Embassy in Beirut.

For State’s Bureau of International Narcotics and Law Enforcement 

Affairs (INL), we reviewed policy and procedure guidelines for end-use 

monitoring. We obtained and analyzed inventory lists of equipment that 

INL provided to Lebanon’s security forces during fiscal years 2007 

through 2012, data extracted from the Integrated Logistics Management 

System database. We received a demonstration on the use of this 

database to record annual inspection and inventory of equipment. In 

addition, we reviewed annual inspection reports submitted by embassy 

officials, Letters of Offer and Acceptance, and a sample transfer letter that 

contained inspection requirements. In addition, we toured two ISF 

 2

Department of State, Directorate of Defense Trade Controls, Blue Lantern: A Guide to 

End-Use Monitoring of Defense Articles and Services Exported via Commercial Channels

(Washington, D.C.: July 2010).
Appendix I: Scope and Methodology

Page 34 GAO-14-161 Security-Related Assistance to Lebanon

facilities in Beirut, Lebanon, and observed INL-provided equipment. 

Lastly, we interviewed State officials of the Bureaus Political and Military 

Affairs, International Narcotics and Law Enforcement Affairs, and Near 

Eastern Affairs; the Office of Foreign Assistance; the Directorate of 

Defense Trade Controls; and the U.S. Embassy in Beirut.

To assess the extent to which the U.S. government vetted Lebanese 

recipients of U.S. security-related training for potential human rights 

violations, we interviewed DOD and State officials, reviewed both 

agencies’ vetting guidance, and analyzed State documents from Lebanon 

on individuals and units vetted. We interviewed officials from State’s 

Bureau of Democracy, Human Rights, and Labor and Bureau of Near 

Eastern Affairs who are responsible for overseeing the human rights 

vetting process and answering questions from vetting personnel at the 

U.S. Embassy in Beirut. In Lebanon, we also met with U.S. embassy 

officials from DOD and State, and also relevant officials from the 

Department of Justice and the U.S. Agency for International Development 

to understand these other agencies’ roles in the human rights vetting 

process. We also met with representatives of the LAF and ISF to 

understand their familiarity with the Leahy laws and the U.S. human rights 

vetting process, as well as how the U.S. Embassy in Beirut 

communicates vetting results to them. In addition, we reviewed State’s 

human rights vetting guidance, including the Leahy human rights vetting 

guide; the International Vetting and Security Tracking (INVEST) user 

guide; multiple cables from State communicating directives to embassies 

regarding the implementation of the State and DOD Leahy laws; and a 

Joint Staff message issued by DOD in June 2004 that provided guidance 

on human rights verification for DOD-funded training of foreign security 

forces.

Furthermore, we reviewed the State and DOD Leahy laws, as well as the 

U.S. Embassy in Beirut’s standard operating procedures. Lastly, to 

assess whether or not Lebanese students who attended training were 

previously vetted for potential human rights violations, we analyzed data 

from State’s INVEST database on almost 10,000 Lebanese individuals or 

units vetted from October 10, 2010, through April 30, 2013. We 

requested, obtained, and reviewed six training rosters with about 7,100 

names of Lebanese students that attended training from October 1, 2010, 

to April 30, 2013, provided by these security-related assistance programs: 

International Military Education and Training; International Narcotics 

Control and Law Enforcement; and Nonproliferation, Antiterrorism, 

Demining, and Related programs. We selected a random sample of 118 

Lebanese names that included representation from all rosters, with a 
Appendix I: Scope and Methodology

Page 35 GAO-14-161 Security-Related Assistance to Lebanon

minimum of 10 sampled names per roster. We provided this list of names 

to the Bureau of Democracy, Human Rights, and Labor and observed as

a bureau official entered the first and last name into the search feature of 

INVEST. If the name was found, we then confirmed other fields, such as 

the date and description of the training, or the rank of the trainee. Despite 

some spelling variations, all 118 names of students were found in 

INVEST. Therefore, we estimate that 100 percent of the Lebanese 

recipients of training were vetted. The 95 percent margin of error on this 

estimate is 3 percentage points.

We conducted this performance audit from April 2013 to February 2014 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: U.S. Human Rights Vetting 

Process

Page 36 GAO-14-161 Security-Related Assistance to Lebanon

To address both the State and DOD Leahy laws and determine whether 

there is credible information of a gross violation of human rights, State 

has established a U.S. human rights vetting process. The State-led 

process, as illustrated in figure 7, consists of vetting by personnel 

representing selected agencies and State offices at (1) the U.S. Embassy 

in Beirut and State headquarters in Washington, D.C.; (2) State’s Bureau 

of Democracy, Human Rights, and Labor; and (3) State’s Bureau of Near 

Eastern Affairs. The personnel involved in the vetting process screen 

prospective recipients of assistance by searching relevant files, 

databases, and other sources of information for credible information 

about gross violations of human rights. State processes, documents, and 

tracks human rights vetting requests and results through its International 

Vetting and Security Tracking system (INVEST), a web-based database.1

The Bureau of Democracy, Human Rights, and Labor is responsible for 

overseeing the vetting process and for developing human rights vetting

polices, among other duties.

 1

State began implementing INVEST in Beirut on October 10, 2010. Before implementing 

INVEST, State used cables to communicate vetting requests and results between State 

headquarters in Washington, D.C., and the U.S. Embassy in Beirut. 

Appendix II: U.S. Human Rights Vetting 

Process
Appendix II: U.S. Human Rights Vetting 

Process

Page 37 GAO-14-161 Security-Related Assistance to Lebanon

Figure 7: U.S. Human Rights Vetting Process
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 38 GAO-14-161 Security-Related Assistance to Lebanon

The Department of Defense (DOD) and Department of State (State) 

allocated $671 million in security-related assistance for Lebanon in fiscal 

years 2009 through 2013, with funds varying by year and program. The 

agencies utilized eight programs to provide this security-related 

assistance: Foreign Military Financing, International Narcotics Control and 

Law Enforcement, Section 1206, International Military Education and 

Training, Antiterrorism Assistance, Counterterrorism Financing, Export 

Control and Related Border Security, and Section 1207. See figures 8 

through 15 for details on allocation, obligation, and disbursement, or 

commitment of funds for each program’s security-related assistance 

provided to Lebanon in fiscal years 2009 through 2013. Data are as of 

September 30, 2013.

Appendix III: Status of Funds for U.S. 

Security-Related Assistance Programs for 

Lebanon
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 39 GAO-14-161 Security-Related Assistance to Lebanon

Figure 8: Foreign Military Financing Program, Fiscal Years 2009-2013

Notes: We were not able to present data on Foreign Military Financing (FMF) for Lebanon in the 

same way as for the other programs because FMF funds are budgeted and tracked differently and 

the system used does not track FMF information consistent with the way we are presenting the data 

for the other programs. For the purposes of this report, “uncommitted” amounts represent FMF 

obligations not yet committed for expenditure and “committed” amounts include FMF funding that has 

been committed but not yet disbursed, as well as FMF funding that has been disbursed to a case. 

This funding is available for obligation for 1 year, and annual appropriations for FMF generally have 

contained language stating that FMF funds shall be obligated upon apportionment. For the most 

recent appropriations containing this language, see the Consolidated Appropriations Act, 2014, Pub. 

L. No. 113-76, January 17, 2014. Once the period of availability for new obligations expires, the funds 

are available for an additional 5 years to liquidate obligations. 
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 40 GAO-14-161 Security-Related Assistance to Lebanon

Figure 9: International Narcotics Control and Law Enforcement Program, Fiscal 

Years 2009-2013

Notes: International Narcotics Control and Law Enforcement (INCLE) funds are generally available for 

obligation for 2 years. Once the period of availability for new obligations expires, the funds are 

available for an additional 5 years to liquidate the obligations. The period of availability for obligations 

of INCLE funds may be extended for an additional 4 years in certain cases. Pursuant to authority 

generally provided in the annual Department of State, Foreign Operations, and Related Programs 

Appropriations Act, certain funds that have been deobligated remain available for obligation for an 

additional 4 years from the date on which the availability of such funds would otherwise expire if the 

funds were initially obligated before they would have expired.

a

According to State, unobligated balances in fiscal years 2009 and 2011 are no longer available for 

obligation.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 41 GAO-14-161 Security-Related Assistance to Lebanon

Figure 10: Section 1206 Authority Program, Fiscal Years 2009-2013

Notes: State and DOD jointly administer Section 1206 assistance. Funded from the DOD operations 

and maintenance accounts, Section 1206 funds remain available for 1 year for obligation. Once the 

period of availability for new obligations expires, the funds are available for an additional 5 years to 

liquidate the obligations.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 42 GAO-14-161 Security-Related Assistance to Lebanon

Figure 11: International Military Education and Training Program, Fiscal Years 2009-

2013

Notes: The Department of State’s (State) Bureau for Political-Military Affairs manages the 

International Military Education and Training (IMET) budget with input from the Department of 

Defense’s Defense Security Cooperation Agency, which implements the program. According to State 

officials, the differences between the data we are reporting here for IMET and the data we reported in 

GAO-13-289 are due to a different methodology that State used for identifying the data. See GAO, 

Security Assistance: Evaluations Needed to Determine Effectiveness of U.S. Aid to Lebanon’s 

Security Forces, GAO-13-289 (Washington, D.C.: Mar.19, 2013).

a

According to State officials, the unobligated balances for fiscal years 2009, 2010, and 2011 are still 

available for obligation because these funds are available until expended pursuant to congressionally 

provided authority that allows up to $4 million annually from IMET funding to remain available until 

expended subject to regular notification procedures of the Committees on Appropriations.

b

According to State officials, the unobligated balances for fiscal year 2012 are no longer available for 

obligation.

c

The unobligated balance for fiscal year 2013 is still available for obligation until the end of 2014 

because, according to State, these funds are part of a portion of the congressional appropriation for 

IMET that Congress authorized to remain available for 2 years.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 43 GAO-14-161 Security-Related Assistance to Lebanon

Figure 12: NADR: Antiterrorism Assistance Program, Fiscal Years 2009-2013

Notes:

NADR funding supports the Antiterrorism Assistance program, which is managed and implemented 

by State with some implementation by a broader set of agencies.

NADR Antiterrorism Assistance funds are generally available for obligation for 2 years. The 

availability of NADR funds may be extended for an additional 4 years in some cases. Pursuant to 

authority generally provided in the annual Department of State, Foreign Operations, and Related 

Programs Appropriations Act, certain funds that have been deobligated remain available for obligation 

for an additional 4 years from the date on which the availability of such funds would otherwise expire 

if the funds were initially obligated before they would have expired. All NADR obligations continue to 

be available for expenditure for an additional 5 years after the end of their period of availability for 

obligation.

a

According to State, unobligated balances in fiscal years 2009, 2010, 2011, and 2012 are no longer 

available for obligation.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 44 GAO-14-161 Security-Related Assistance to Lebanon

Figure 13: NADR: Counterterrorism Financing Program, Fiscal Years 2009-2013

Notes:

NADR funding supports the Counterterrorism Financing program, which is managed and 

implemented by State with some implementation by a broader set of agencies.

NADR Counterterrorism Financing funds are generally available for obligation for 2 years. All NADR 

obligations continue to be available for expenditure for an additional 5 years after the end of their 

period of availability for obligation.

In our prior report, State reported that it had allocated $166,000 for the Counterterrorism Financing 

program in fiscal year 2011. See GAO-13-289.The $174,000 State is currently reporting for fiscal year 

2011 includes Lebanon-specific costs incurred as part of a regional training program that was not 

included in the first report.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 45 GAO-14-161 Security-Related Assistance to Lebanon

Figure 14: NADR: Export Control and Related Border Security Program, Fiscal 

Years 2009-2013

Notes:

NADR funding supports the Export Control and Related Border Security program, which is managed 

and implemented by State with some implementation by a broader set of agencies.

NADR Export Control and Related Border Security funds are generally available for obligation for 2 

years. All NADR obligations continue to be available for expenditure for an additional 5 years after the 

end of their period of availability for obligation.

a

According to State, unobligated balance in fiscal year 2011 is no longer available for obligation.
Appendix III: Status of Funds for U.S. SecurityRelated Assistance Programs for Lebanon

Page 46 GAO-14-161 Security-Related Assistance to Lebanon

Figure 15: Section 1207 Authority Program, Fiscal Years 2009-2013

Notes: The authority for Section 1207 expired at the end of fiscal year 2010. Although funded through 

DOD, Section 1207 funds were transferred to the Department of State for management. When 

Section 1207 funds were transferred to State, they became “no year” money and remain available 

until expended.
Appendix IV: Comments from the Department 

of Defense

Page 47 GAO-14-161 Security-Related Assistance to Lebanon

Appendix IV: Comments from the 

Department of Defense
Appendix IV: Comments from the Department 

of Defense

Page 48 GAO-14-161 Security-Related Assistance to Lebanon
Appendix V: Comments from the U.S. 

Department of State

Page 49 GAO-14-161 Security-Related Assistance to Lebanon

Appendix V: Comments from the U.S. 

Department of State
Appendix V: Comments from the U.S. 

Department of State

Page 50 GAO-14-161 Security-Related Assistance to Lebanon
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 51 GAO-14-161 Security-Related Assistance to Lebanon

Charles Michael Johnson, Jr., 202-512-7331, or johnsoncm@gao.gov

In addition to the contact named above, Jeff Phillips (Assistant Director), 

Claude Adrien, Jenna Beveridge, David Dayton, Justin Fisher, Julia Ann 

Roberts, and La Verne Tharpes made key contributions to this report. 

Martin de Alteriis, Jeff Isaacs, Grace Lui, and Etana Finkler provided 

additional technical assistance.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(320975)
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