Export-Import Bank: Monitoring of Dual-Use Exports Should Be Improved
Published: 2014-08-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Since 1994, Ex-Im has had the authority to facilitate the financing of U.S. exports of defense articles and services, provided that it determines these items are nonlethal and primarily meant for civilian use. These “dual-use” exports include aircraft that are used by foreign militaries mainly for humanitarian purposes. After a 9-year hiatus, Ex-Im financed three dual-use exports in fiscal year 2012. These three transactions account for $1.03 billion, or just under 3 percent of Ex-Im's $35.8 billion financing for that year. Federal law requires GAO to report annually on the end uses of dual-use exports financed by Ex-Im during the second preceding fiscal year. This report (1) examines how Ex-Im has complied with its requirements for monitoring the end uses of the dual-use exports it financed in fiscal year 2012 and (2) identifies what dual-use exports, if any, Ex-Im financed in fiscal year 2013.
section_title: What GAO Found
paragraphs: The Export-Import Bank of the United States (Ex-Im) has policies for monitoring the end use of defense articles and services it finances, including documentation requirements that are reflected in its financing agreements with borrowers. However, these policies do not specify what actions Ex-Im officials should take if the bank does not receive the required dual-use-related documents. The requirements for each transaction vary, but may include (1) progress reports on construction and delivery, (2) technical operating reports, and (3) an annual certification and report on end use. As of July 31, 2014, Ex-Im had received most of the information it required in its credit agreements regarding the three dual-use transactions it financed in fiscal year 2012, but some of the information it received was late (see figure). For example, Ex-Im received
some but not all of the progress reports required for the satellite transactions with Eutelsat and the Mexican government, and some information from the government of Mexico was more than a year late;
the required technical operating report from Eutelsat, but only one of the two required reports from the Mexican government; and
the annual certification and reports required from the governments of Mexico and Cameroon late.
Ex-Im officials told GAO they made efforts to obtain missing documentation for all three transactions, and, because of their prior vetting of the transactions and the details they had received, they did not think the missing documentation risked the exports being used in a lethal manner or for primarily military purposes. However, GAO found these efforts were often not timely or documented. Ex-Im therefore did not have complete and timely information about whether the items were actually being used in accordance with the terms of the agreements and Ex-Im policy.
Ex-Im did not finance any exports under its dual-use authority in fiscal year 2013, according to Ex-Im officials and Ex-Im authorizations data.
section_title: What GAO Recommends
paragraphs: To improve oversight for monitoring dual-use items, Ex-Im should strengthen its guidance for monitoring end use in cases where borrowers do not submit required documentation within specified time frames. Ex-Im agreed with GAO's recommendation and said it would revise its guidance.

section_title: Letter
paragraphs: Since October 1994, the Export-Import Bank of the United States (Ex-Im)  has had the authority to facilitate the financing of U.S. exports of defense  articles and services, provided that Ex-Im determines that these items are  nonlethal and primarily meant for civilian use. These “dual-use” exports  include items such as aircraft that are used by foreign militaries mainly for  civilian or humanitarian purposes. As of July 2014, Ex-Im has financed a  total of $1.67 billion in dual-use exports, with several transactions  financed each year through fiscal year 2002. After a 9-year hiatus, it  financed three more exports in fiscal year 2012: a geosynchronous  satellite for a French company, Eutelsat S.A. (Eutelsat), manufactured by  Space Systems/Loral, Inc.; a fleet of three geosynchronous  telecommunications satellites and related equipment and services from  Boeing Satellite Systems and Orbital Sciences Corporation for the  government of Mexico; and 150 pieces of new and used construction  equipment from U.S. manufacturers exported by Hoffman International,  Inc., for the government of Cameroon. These three transactions account  for $1.03 billion in Ex-Im financing, or just under 3 percent of Ex-Im’s  financing for that year of $35.8 billion. The Mexico satellite transaction is  the bank’s single largest dual-use financing transaction to date, with a  loan guarantee of $922 million.
Federal law requires GAO to report annually on the end uses of dual-use   This exports financed by Ex-Im during the second preceding fiscal year. report (1) examines how Ex-Im has complied with its requirements for  monitoring the end uses of the dual-use exports it financed in fiscal year  2012, and (2) identifies what dual-use exports, if any, Ex-Im financed in  fiscal year 2013.
To examine Ex-Im’s compliance with its requirements for monitoring the  end uses of the dual-use exports it financed in fiscal year 2012, and to  identify what dual-use exports, if any, Ex-Im financed in fiscal year 2013,  we reviewed Ex-Im documentation and interviewed Ex-Im officials in  Washington, D.C. We conducted this performance audit from March to  August 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. For more information on  our scope and methodology, see appendix I.
subsections: section_title: Background
paragraphs: Ex-Im is an independent agency operating under the Export-Import Bank  Act of 1945, as amended. Its mission is to support the export of U.S.  goods and services overseas, through the provision of loans, loan  guarantees, and insurance, thereby supporting U.S. jobs. Ex-Im is  generally prohibited by law from financing any credit sale of defense  articles and services for any country. However, in an exception to this  rule, Ex-Im was granted authority to facilitate the financing of U.S. exports  of defense articles and services, provided that it determines that these  items are nonlethal and primarily meant for civilian end use. Such items  are known as dual-use exports.
Ex-Im’s Engineering and Environment Division, with assistance from the  General Counsel, Congressional and External Affairs Division, and the  Policy and Planning Division, is responsible for implementing the dual-use  authority. According to Ex-Im’s Military Policy, its definitions of “defense  articles” and “defense services” are based on who the end user is, and  then by the nature of the item and the use to which it will be put. In  addition, if the item is designed primarily for military use, it is presumed to  be a defense article. For example, according to Ex-Im, furniture sold to a  military organization for military use (e.g., for offices or homes occupied  by military personnel) is deemed a defense article. However, according to  Ex-Im, helicopters sold to a private firm or civilian police force are not  defense articles. According to Ex-Im policy, an export is eligible for  financing as a dual-use item if convincing evidence exists that the export  is nonlethal in nature and will be used mainly for civilian activities. The  determination of eligibility for dual-use financing may require applicants  for Ex-Im financing to provide additional information beyond the contract  and transaction data the bank normally requires for a loan or guarantee.  Ex-Im may also seek to corroborate the information submitted by  applicants by contacting other U.S. government agencies, such as the  Department of State. For example, prior to approving the three fiscal year  2012 dual-use transactions, Ex-Im obtained written certification from each  borrower that the items to be exported were nonlethal and would be  primarily for civilian use. In addition, Ex-Im vetted the Eutelsat and  Cameroon transactions with the Department of State, and vetted the  Mexico transaction with the U.S. embassy military attaché in Mexico.
section_title: Ex-Im End-Use Monitoring Requirements in Credit Agreements Are Not Being Fully Met
paragraphs: Ex-Im has policies and procedures for monitoring end use, including  various documentation requirements, which are reflected in its financing  agreements with each of these borrowers. The documentation  requirements for each transaction vary, but there are three types: (1)  progress reports on construction and delivery of the exported item, (2)  technical operating reports once the item is in use, and (3) an annual  certification and report on end use. Ex-Im may also conduct end-use  inspections, according to the terms of its credit agreements. As of July 31,  2014, Ex-Im had received most of the information required in its credit  agreements regarding the status and end use of the exported items from  the three borrowers approved for financing in fiscal year 2012 under the  bank’s dual-use authority, but some information was received more than  a year late. Figure 1 shows the status of each of these transactions and  the end-use monitoring of the exported items. Ex-Im officials told us they  made efforts to obtain missing documentation for all three transactions.  They also said that because of their prior vetting of the transactions with  the Department of State or Defense and the details they had received  about the transactions, they did not think the missing documentation  risked the exports being used in a lethal manner or for primarily military  purposes. However, we found these efforts were often not timely or  documented. Ex-Im therefore did not have complete and timely  information about whether the items were actually being used in  accordance with the terms of the credit agreements and Ex-Im policy.
subsections: section_title: Ex-Im Has Policies and Procedures for Monitoring End Use
paragraphs: Ex-Im has a detailed 1997 staff memorandum on dual-use policy for  military applications, and Ex-Im officials confirmed that there have been  no changes or updates to this policy. This memorandum tasks the Ex-Im  engineers assigned to monitor dual-use transactions with “determining a  reasonable and effective method to meet this monitoring requirement”  that generally includes submission of periodic reports on end use,  certified as accurate by the buyer, until the loan or guarantee is repaid,  and could include periodic site visits by Ex-Im officials. In addition, the  memorandum states that credit and guarantee agreements for dual-use  transactions should include provisions for “progress reports” and  “technical operating reports” to monitor the status and usage of dual-use  items. Such information helps inform bank officials and provides them  greater assurance about the exports’ end use. The memorandum also  includes provisions for action should Ex-Im find a violation of the dual-use  policy. However, the memorandum does not specify what actions Ex-Im  officials should take if the bank does not receive the documents required  in the agreements.
section_title: Ex-Im’s Policies and Procedures Are Reflected in the Financing Agreements for Each Dual-Use Export Transaction
paragraphs: According to Ex-Im officials, each of the credit agreements was  negotiated on a case-by-case basis to incorporate the specific  circumstances related to the borrower and the item(s) being exported.  These credit agreements are legally binding on Ex-Im and the borrower,  and each includes different provisions to ensure that end use could be  monitored. The credit agreements for the two satellite transactions require  the borrower (Eutelsat or the Mexican Ministry of Finance) to submit to  Ex-Im (1) periodic progress reports covering the satellite(s)’ construction,  launch, and in-orbit testing; and (2) technical operating reports that  include information concerning the operation and maintenance of the  satellite(s) and related telemetry, tracking and command stations, and  transponder capacity and use.
The credit agreements with the governments of Mexico and Cameroon  require an “Annual Certification and Report.” Specifically, the borrower is  to have the end user (the Mexican Secretariat of Communications and  Transportation, and the Cameroon Directorate of Military Engineering)  certify that the exported items have been and are being used primarily for   This certification is to occur within 3 months after the  civilian purposes. end of each calendar year, starting by April after the year in which a first  use is made. For the government of Mexico, this means that since one  satellite was launched and became operational in 2013, the first report  was due by April 2014. The report accompanying this certification is to  include a list and description of tasks for which the satellite was used,  including a summary of the civilian and military uses and the number of  terminals allocated to and in use by any military organization or division of  the government of Mexico.report was also due by April 2014, since the equipment was shipped and  put to use in 2013. This report is to include a list and description of tasks  for which the equipment was used, the duration of each task, and a  summary of their civilian and military uses, including the respective  percentages of civilian and military use.
For the government of Cameroon, the first  All three agreements call for the borrower to permit Ex-Im officials to  make “reasonable inspections” of books and records regarding the use of  the exported items, though no inspections have occurred because Ex-Im  officials determined that due to the timing and nature of the transactions,  conducting a physical monitoring trip prior to significant use would not be  an efficient nor a justified use of taxpayer money. All three agreements  also say that failure to comply with the provisions set forth in the  agreement (if not remedied within a specified grace period) shall be  considered grounds for default. In addition, the agreements with the  governments of Mexico and Cameroon state that any false or misleading  information submitted to Ex-Im shall be grounds for default. The  agreement with Eutelsat states that any information “proven to be  incorrect” shall be grounds for default if not remedied within 60 days.  Officials noted that while the bank does have the option to declare a  default and accelerate payments, this is not usually the best option,  especially with sovereign governments, for issues such as late reporting.
section_title: Ex-Im Has Received Some Required Information More than a Year Late or Not at All
subsections: section_title: Ex-Im Did Not Receive All Progress Reports from Eutelsat within Required Time Frames but Received the Technical Operating Report on Time
paragraphs: Ex-Im provided a direct loan to Eutelsat to finance 45.5 percent of the  purchase and launch of a satellite. The remaining 54.5 percent was  purchased independently by Qatar’s state-owned telecommunications  operator, ictQatar. The credit agreement with Eutelsat required monthly  progress reports on the construction, planned launch, and in-orbit testing  of the satellite, beginning June 30, 2012. These reports help officials  determine when the satellite will go into use. However, Ex-Im received  only two of more than a dozen required progress reports. These reports  were dated July 30, 2012, and January 11, 2013, and were not received  until July 2013. They were titled “Monthly Progress Reports” and included  detailed information on completed and planned activities, such as  anticipated launch and in-orbit testing time frames. Ex-Im officials told us  they determined that despite the requirement in the loan agreement,  monthly reports were not necessary and they did not believe the missing  information posed a risk. An Ex-Im official stated that detailed reports,  such as these, which summarize information over a several-month period,  are more useful than a series of monthly reports. However, Ex-Im officials  could not provide us documentation of this decision or of their efforts to  obtain late (or missing) reports. The official said that when the credit  agreement was being drafted, representatives from the satellite’s  manufacturer told the bank they prepare monthly reports for clients;  according to him, this is why the monthly reporting requirement was  incorporated into the credit agreement. Once the satellite was constructed  and launched and its in-orbit testing was completed, in November 2013,  progress reports were no longer required.
Once the satellite is in use, the credit agreement with Eutelsat requires  the company to submit semiannual technical operating reports. The first  technical operating report is to be submitted 3 months after the satellite’s  “in-orbit acceptance date” (the date on which testing of the satellite in  orbit is completed). According to a January 2014 letter from Eutelsat, the  in-orbit acceptance date was November 4, 2013; Eutelsat submitted its  first technical operating report on time, in February 2014. Thereafter,  these reports are due by the end of January and the end of July each  year, until the loan has been repaid (just over 10 years). Eutelsat also  submitted documentation certifying that (1) the majority of the satellite’s  46 transponders are for civilian use (meaning that Ex-Im can finance  them); (2) the remaining 6 transponders dedicated to military use for the  government of Qatar are nonlethal and, now that the satellite is airborne,  cannot be modified to change their use; and (3) the bandwidth, or  capacity, of these 6 transponders is less than half of the satellite’s total  transponder capacity. Ex-Im officials said that this information, together  with prior vetting of the transaction by the Department of State, gave them  confidence that this satellite is nonlethal and will be used primarily for  civilian purposes. However, there was no formal documentation of this  determination. Ex-Im officials noted that they only needed to look at the  23 transponders financed by the bank and that their support did not  extend to any of the military transponders.
section_title: Ex-Im Did Not Receive All of the Required Reports from the Government of Mexico, and Some Information Was More than a Year Late
paragraphs: Ex-Im received only a few of the reports from the government of Mexico  required in the July 2012 credit agreement, and some of the information  in a report it did receive was more than a year late. Ex-Im officials  received these reports only after contacting Mexican government officials  in April, May, and June 2014—after we began our review—to obtain  missing documentation regarding the status and end use of the  satellites. An Ex-Im official said that the Mexican government  acknowledged that it has been delinquent in submitting the required  documentation and that the government is working with Ex-Im to make  sure that it fulfills the agreement’s documentation requirements.
The credit agreement calls for the borrower to submit both progress  reports and technical operating reports. However, since the launched  satellite’s final in-orbit acceptance date of February 14, 2013, Ex-Im has  received only one combined report, dated June 20, 2014.  According to  the agreement, the borrower should have already provided to Ex-Im at least two progress reports covering all three satellites prior to the  February 14, 2013, in-orbit acceptance date for the launched satellite  (in the third quarter of 2012 and January 2013);  two more progress reports (in mid-2013 and early 2014) covering the  remaining two satellites, which have not yet been launched; and  two technical operating reports for the launched satellite, in April 2013  and April 2014, that were due 60 days after the satellite’s in-orbit  acceptance date, and annually thereafter until the loan guaranteed by  the agreement is paid in full.
The combined report incorporates information contained in a May 21, 2014, draft  progress report received by Ex-Im on or shortly before May 30, 2014.
February 14, 2013; and was handed over to the Mexican government on  February 24, 2013. The ground equipment for this satellite, which is  necessary for satellite use, was handed over to the Mexican government  on December 5, 2013. According to the report, the satellite is currently  operating as expected at about 19 percent of capacity. The report also  states that both mobile service satellites have been built and are in  storage awaiting launch; one has an expected launch period of February  14 to March 15, 2015, and the other a contracted launch period of  October 1, 2015, to March 15, 2016. Since these satellites have not yet  been launched, they are not yet in use, and therefore do not yet need to  be monitored for end use. Nevertheless, prior to receiving the June 2014  combined report, Ex-Im had no documented information regarding the  status of the three satellites since the Ex-Im board approved the Mexico  satellite transaction in May 2012, and none regarding the launch and  operation of one of the satellites.
Finally, with regard to the third type of requirement, Ex-Im received the  first required annual certification and report in May 2014, about a month  after it was due. This document, dated April 28, 2014, consists of a two- paragraph letter and a two-page annex listing the terminals for use by the  satellites. The letter states that the percentage of terminals for military  and civilian use continues to remain the same (40 percent and 60  percent, respectively), as noted in a March 2012 Mexican government  letter to Ex-Im, submitted prior to the Ex-Im board approval of the  transaction.
An Ex-Im official said that despite the late or missing reports, he does not  consider there to be a risk of violating the bank’s military policy under its  dual-use authority because he is confident that the satellites are nonlethal  and will be used primarily for civilian purposes. He said this is because  the Mexican Secretariat of Communications and Transportation—and not  the Mexican military—is operating the satellites, and the military will be  using less than half of the terminals. The official also noted that this  transaction was vetted by the U.S. military attaché in Mexico prior to  board approval.reports posed no risk.
section_title: Ex-Im Received Required End- Use Documentation from the Government of Cameroon Late
paragraphs: According to the credit agreement, the first annual certification and report  on end use of the construction equipment exported to Cameroon was due  by April 2014. Ex-Im received this required documentation several  months late, in July 2014. Ex-Im officials received the certification and  report after reaching out, with reminders regarding the credit agreement  language, to the bank whose loan Ex-Im is guaranteeing; the U.S.  embassy in Cameroon; and the Cameroon Ministry of Finance. An Ex-Im  official said he had also spoken informally with the exporter. In addition,  the report is missing information. The credit agreement requires the  borrower to provide the respective percentages of civilian and military use  of the equipment, but these percentages are lacking. The report simply  notes that some of the equipment (e.g., trucks) “have been used very little  for military purposes” to transport military items to the north of the  country. There are references to additional military uses of the  equipment, but Ex-Im officials reviewed the documents and other  information and determined that the end user had demonstrated that use  has been primarily civilian in nature, despite the lack of a formal  percentage. Nevertheless, Ex-Im officials said they will continue to follow  up on the information in the report as part of their ongoing end-use  monitoring.
An Ex-Im official said that the equipment arrived in Cameroon in several  shipments during 2013 and was put to use on a rolling basis between  March and December of that year. Ex-Im received evidence of delivery in  the form of photos of the equipment on site and in use during operator  training, as well as the transcript of a speech marking the acceptance of  the final shipment. Officials noted that Ex-Im could conduct a site visit to  verify the presence and use of the equipment for this project, but, given  the photos, speech, and prior vetting of the transaction by the Department  of State, there have been no indications of issues that suggest a special  trip is needed. Nevertheless, an official stated that Ex-Im is discussing a  potential visit to Cameroon within the next year to visit other (nonmilitary)  projects involving road and bridge construction, and that if this trip takes  place, Ex-Im officials may take the opportunity to visit the headquarters of  the Cameroon Directorate of Military Engineering to inspect records of the  maintenance and use of the equipment, as well as a list of sites where it  is being used. If some of the sites are close by, officials may visit them.
section_title: Ex-Im Did Not Finance Any Dual- Use Export Transactions in 2013, Based on Application Data and Ex-Im Reviews
paragraphs: Ex-Im did not finance any exports under its dual-use authority in fiscal  year 2013, according to Ex-Im officials and our review of relevant data on  Ex-Im authorizations. According to Ex-Im officials, each application for  financing requires the entry of numerous data elements for the application  record. Several of these elements relate to whether there are any military  implications in the application, and one field relates to whether or not the  application would go forward under the bank’s dual-use authority. The  Engineering and Environment Division, which administers the bank’s  military policy and consequently its dual-use policy, is responsible for  filling in this data field.
According to Ex-Im officials, Ex-Im’s Engineering and Environment  Division finds that roughly 70 percent of all requests for financing of  military items under the dual-use authority have no credible civilian  application; the division therefore deems these requests ineligible for  financing. The remaining requests, those that the division formally  identifies as eligible under the dual-use authority, are considered for  approval by the board, which serves as an additional level of review. After  preliminary board approval, the House Committees on Appropriations and  Financial Services and the Senate Committees on Appropriations and  Banking, Housing, and Urban Development are notified 15 days before  the dual-use transaction is returned to the board for final approval.
section_title: Conclusion
paragraphs: This is the first time in almost a decade that Ex-Im has financed dual-use  defense articles and therefore been required to monitor the end use of  these exports. Ex-Im vetted these dual-use transactions before approving  them and incorporated its policies and procedures for monitoring end use  in its credit agreements. These requirements in the credit agreements  include submitting periodic technical and annual reports documenting the  status and end use of the items being financed in order to help officials  determine whether these items are nonlethal and are being used primarily  for civilian purposes. However, we found that some of these reports were  missing or late. Moreover, we found Ex-Im’s attempts to obtain missing  documents were often not timely, and records of these efforts were  sometimes lacking. Ex-Im officials did not think the missing or late  documentation posed a threat that the exports would be used in a lethal  manner or for primarily military purposes, based on prior vetting and other  information. Nevertheless, this determination was not documented, and  Ex-Im did not promptly and consistently ensure that the terms of its credit  agreements were being followed with respect to end-use monitoring.     Ex-Im’s policies and procedures for monitoring end use do not specify  what steps bank officials should take when borrowers do not comply with  the end-use documentation requirements in their credit agreements and  risk being found in default. Without specifying such steps and following  them consistently, Ex-Im risks not having reasonable assurance that the  items it is financing are actually being used in accordance with the terms  of the agreements and Ex-Im policy.
section_title: Recommendation for Executive Action
paragraphs: To ensure adequate and consistent oversight for monitoring the end use  of dual-use items, the Chairman of the Export-Import Bank of the United  States should strengthen Ex-Im guidance for monitoring end use.  Specifically, Ex-Im should establish steps staff should take in cases  where borrowers do not submit required end-use documentation within  the time frames specified in their financing agreements and ensure that  these efforts are well documented.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided Ex-Im a draft of this report for review and comment.  In  written comments on the draft, which are reprinted in appendix II, Ex-Im  agreed with our recommendation and stated that it would revise its  guidance by adding specific instructions about monitoring end-use  activity, documenting related communications, and actions to be taken if  reports are not received in a timely fashon. GAO also received technical  comments from Ex-Im officials. Ex-Im officials updated information on the  Cameroon transaction and clarified information about the terms of the  loan agreements and their responsibilities. We made changes to our  report in response to these comments where appropriate.
We are sending copies of this report to interested congressional  committees. We will also send copies to the President and Chairman of  Ex-Im, the Secretary of Defense, and the Secretary of State. In addition,  this report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-8612 or GianopoulosK@gao.gov.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: To examine Ex-Im’s compliance with its requirements for monitoring the  end uses of the dual-use exports it financed in fiscal year 2012, and to  identify what dual-use exports, if any, Ex-Im financed in fiscal year 2013,  we reviewed Ex-Im documentation regarding its dual-use policy, including  a 1997 memorandum on implementing that policy; Ex-Im documentation  associated with each of the three dual-use transactions Ex-Im financed in  fiscal year 2012; and data on dual-use determinations. In addition, we  interviewed Ex-Im officials in Washington, D.C., who review applications  for the financing of dual-use exports and monitor end-user compliance  with dual-use requirements, including the Vice-President of the  Engineering and Environment Division. We did not independently verify  the information provided to Ex-Im. Through interviews with cognizant  agency officials about Ex-Im’s procedures for identifying and categorizing  dual-use transactions in its Application Processing System, we  determined that Ex-Im data were sufficiently reliable for the purpose of  identifying the dual-use exports financed under Ex-Im’s dual-use authority  in fiscal years 2012 and 2013.
We conducted this performance audit from March to August 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.
section_title: Appendix II: Comments from the U.S. Export-Import Bank
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Kimberly Gianopoulos, (202) 512-8612, or Gianopoulosk@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Adam Cowles, Assistant Director,  and Kay Halpern made key contributions to this report. In addition, Ashley  Alley, Martin De Alteriis, Karen Deans, Etana Finkler, and Hai Tran  provided technical assistance and other support.
section_title: Related GAO Products
paragraphs: Export-Import Bank: Financing of Dual-Use Exports. GAO-13-628R.  Washington, D.C.: May 29, 2013.
Export Promotion: The Export-Import Bank’s Financing of Dual-Use  Exports. GAO-12-628R. Washington, D.C.: April 12, 2012.
Export Promotion: The Export-Import Bank’s Financing of Dual-Use  Exports. GAO-10-1052R. Washington, D.C.: September 15, 2010.
Export-Import Bank: Financing of Dual-Use Exports. GAO-13-628R.  Washington, D.C.: May 29, 2013.
Export Promotion: The Export-Import Bank’s Financing of Dual-Use  Exports. GAO-12-628R. Washington, D.C.: April 12, 2012.
Export Promotion: The Export-Import Bank’s Financing of Dual-Use  Exports. GAO-10-1052R. Washington, D.C.: September 15, 2010.
Export Promotion: The Export-Import Bank’s Financing of Dual-Use  Exports. GAO-08-1182R. Washington, D.C.: September 30, 2008.
Ex-Im Bank: The U.S. Export-Import Bank’s Financing of Dual-Use  Exports. GAO-07-1234R. Washington, D.C.: September 27, 2007.
Export-Import Bank: The U.S. Export-Import Bank’s Financing of Dual- Use Exports. GAO-01-1110R. Washington, D.C.: August 31, 2001.
Export-Import Bank: The U.S. Export-Import Bank’s Financing of Dual- Use Exports. NSIAD-00-231R. Washington, D.C.: September 1, 2000.
International Affairs: U.S. Export-Import Bank’s Financing of Dual-Use  Exports. NSIAD-99-241R. Washington, D.C.: September 1, 1999.
International Affairs: U.S. Export-Import Bank’s Financing of Dual-Use  Exports. NSIAD-98-244R. Washington, D.C.: September 1, 1998.
U.S. Export-Import Bank: Process in Place to Ensure Compliance With  Dual-Use Export Requirements. NSIAD-97-211. Washington, D.C.:  July17, 1997.