Egypt is a key strategic partner of the United States and is among the top recipients of U.S. security-related assistance. According to U.S. officials, the U.S.-Egypt strategic partnership is based on shared interests of promoting a stable and prosperous Egypt, securing regional peace and maintaining peace between Egypt and Israel, and countering violent extremism throughout the region. For example, Egypt has been a member of the U.S. coalition against ISIL since September 2014. In support of this strategic partnership, the U.S. government provides security assistance to Egypt through a number of accounts. Table 1 describes these accounts, the agencies responsible for funding and implementing programs under these accounts, and the goals of these programs. By law, Foreign Military Financing (FMF) funds are obligated upon apportionment from the Office of Management and Budget. DOD therefore refers to the subsequent designation of FMF funds for a particular program or contract as a “commitment.” For programs funded with appropriations from the Nonproliferation, Anti-terrorism, Demining, and Related Programs (NADR); International Narcotics Control and Law Enforcement (INCLE); and International Military Education and Training (IMET) accounts, funds are considered to be obligated once a legal liability of the U.S. government for the payment of goods and services ordered or received has been created. An unobligated balance is the amount of budget authority that has not yet been obligated. Unliquidated obligations, also known as obligated balances, are the amount of obligations already incurred for which payment has not yet been made. Disbursements are the amounts paid by federal agencies to liquidate government obligations. The Arms Export Control Act of 1976 authorizes the President to control the export of defense articles and services. The act authorizes the sale of defense articles and services to foreign countries through Foreign Military Sales and authorizes commercial exports of U.S. defense articles and services to foreign countries through direct commercial sales. State makes policy determinations for Foreign Military Sales, including which countries are eligible to participate, and DOD’s Defense Security Cooperation Agency administers the Foreign Military Sales program. State’s Directorate of Defense Trade Controls administers direct commercial sales by licensing exports of U.S. defense articles and services from U.S. companies to foreign entities. In 1996, Congress amended the Arms Export Control Act to require the President to establish a program for monitoring the end use of defense articles and services sold, leased, or exported under the Arms Export Control Act or the Foreign Assistance Act of 1961, including through Foreign Military Sales and direct commercial sales. The law required that, to the extent practicable, the program should be designed to 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 and that such articles and services are being used for the purposes for which they are provided. DOD’s Defense Security Cooperation Agency administers the Golden Sentry program, which was established to monitor the end use of defense articles and defense services transferred through Foreign Military Sales, and officials at the Office of Military Cooperation–Egypt (OMC-E) implement monitoring in Egypt. Under the Golden Sentry program, DOD implements two levels of end-use monitoring—enhanced and routine—and conducts periodic Compliance Assessment Visits. DOD requires enhanced end-use monitoring for sensitive defense articles, services, or technologies specifically designated by the military departments’ export policy, by the interagency release process, or by DOD policy as a result of consultation with Congress. DOD requires routine end-use monitoring for all defense articles and services provided through government-to- government programs. Routine end-use monitoring is conducted in conjunction with other security cooperation functions and uses any readily available source of information. State’s Directorate of Defense Trade Controls administers the Blue Lantern program, which was established to monitor the end use of defense articles and services exported through direct commercial sales. State officials at the U.S. embassy in Cairo, Egypt—in this report, “Embassy Cairo”—are primarily responsible for conducting Blue Lantern checks in Egypt. Under its Blue Lantern program, State is required to conduct end-use monitoring checks on the basis of a case-by-case review of export license applications against established criteria for determining potential risks. To determine whether to conduct a Blue Lantern check, State considers 20 indicators, such as unfamiliar end users, foreign intermediate consignees with no apparent connection to the end user, and requests for sensitive commodities whose diversion or illicit retransfer could have a negative impact on U.S. national security. See appendix II for an overview of the Blue Lantern and Golden Sentry end-use monitoring programs and for more details on DOD and State accountability efforts. To help ensure that U.S. assistance is not used to support human rights violators, Congress prohibits the provision of certain types of assistance to foreign security forces implicated in human rights abuses. Section 620M of the Foreign Assistance Act of 1961, known colloquially as the State Leahy law, prohibits the United States from providing assistance under the Foreign Assistance Act or the Arms Export Control Act to any unit of the security forces of a foreign country if the Secretary of State has credible information that such unit has committed a gross violation of human rights. Section 1204(a)(1) of the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act for Fiscal Year 2015, known colloquially as the DOD Leahy law, prohibits the use of DOD funds for any training, equipment, or other assistance for a unit of a foreign security force if the Secretary of Defense has credible information that the unit committed a gross violation of human rights. According to State, the Leahy laws and the corresponding policies developed to enforce and supplement these laws (see text box) 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 occur. Key Terms of the Leahy Laws as Defined in State and DOD Policy The State and DOD Leahy laws (22 U.S.C. § 2378d, 10 U.S.C. § 2249e) do not define several key terms used in the laws. State and DOD have sought to define these terms in policy documents. Security forces of a foreign country. State guidance defines a “security force” as any division or entity (including an individual) authorized by a state or political subdivision to use force (including but not limited to the power to search, detain, and arrest) to accomplish its mission. Therefore, the guidance states that “security forces” could be units of law enforcement or the military. According to DOD’s Office of General Counsel, DOD also adheres to this definition. However, DOD may sometimes request vetting for individuals or groups that would not constitute foreign security forces, such as a government bureaucrat. Credible information. State guidance notes that the legislative history indicates that credible information is not intended to mean only evidence that would be admissible in a court of law and that the standard should generally be regarded as low. The guidance provides latitude in evaluating the credibility of information and advises personnel conducting human rights vetting to exercise good judgment and common sense. It notes that major international nongovernmental organizations and most independent newspapers are considered to be relatively credible, whereas credibility among opposition groups and smaller nongovernmental organizations varies. According to DOD’s Office of General Counsel, while DOD retains legal authority for final decisions regarding specific cases funded with DOD appropriations, it relies on State’s judgment in assessing the credibility of available information. Gross violation of human rights. State guidance notes that the Leahy laws do not contain a definition of “gross violations of human rights.” State therefore uses the definition included in Section 502B(d) of the Foreign Assistance Act of 1961 as its working standard: “Gross violations of internationally recognized human rights include torture or cruel, inhuman, or degrading treatment or punishment; prolonged detention without charges and trial; causing the disappearance of persons by the abduction and clandestine detention of those persons; and other flagrant denial of the right to life, liberty, or the security of person.” State guidance further clarifies that this definition includes extrajudicial killing and politically motivated rape. For a comparison of the provisions in the State and DOD Leahy laws, see appendix III. To determine whether there is credible information of a gross violation of human rights in accordance with both the State and DOD Leahy laws, State has established a human rights vetting process. As illustrated in figure 1, State’s process for human rights vetting in Egypt consists of vetting by personnel representing selected agencies and State offices at Embassy Cairo and at State headquarters in Washington, D.C., by State’s Bureau of Democracy, Human Rights, and Labor (DRL) and Bureau of Near Eastern Affairs (NEA). According to State officials, the State offices and other U.S. government agencies at Embassy Cairo that participate in the vetting process for Egypt are State’s Consular Section, Political Section, and Regional Security Office; the Department of Justice’s Office of the Legal Attaché and Drug Enforcement Administration; and the Department of Homeland Security. The embassy and headquarters personnel 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 (INVEST) system, a web-based database. DRL is responsible for overseeing the vetting process and for developing human rights vetting policies, among other duties. U.S. agencies have committed or disbursed almost all of the approximately $6.5 billion allocated for security-related assistance for Egypt in fiscal years 2011 through 2015. The U.S. government allocated security-related assistance for Egypt from a number of accounts during this period; however, almost all of this funding—99.5 percent—was from the FMF account. As of September 30, 2015, State had committed 100 percent of the FMF funds allocated for Egypt in fiscal years 2011 through 2015. Of the total of almost $6.5 billion, State had disbursed about 40 percent of more than $32 million allocated for Egypt from four other security-related assistance accounts during this period, as of the same date. Of the almost $6.5 billion in security-related assistance funds allocated for Egypt in fiscal years 2011 through 2015, U.S. agencies had committed or disbursed more than $6.4 billion, or almost 100 percent, as of September 30, 2015. Table 2 shows the status of U.S. security-related assistance funds allocated for Egypt over the 5 fiscal years from 2011 through 2015, as well as totals for the period, as of September 30, 2015. Some of the unobligated balances shown in table 2 are no longer available to incur new obligations. However, many of these unobligated balances remain available for obligation for an additional 4 years beyond their initial period of availability, by operation of law. For the full disposition of these unobligated balances for each account, see appendix IV. In fiscal years 2011 through 2015, the U.S. government funded bilateral security-related assistance to Egypt from a number of accounts; however, almost all of this allocated funding (99.5 percent) was from the FMF account. As shown in table 3, State committed all of the approximately $6.4 billion in FMF funding allocated for Egypt in fiscal years 2011 through 2015, as of September 30, 2015. State was able to commit all of the FMF funding allocated for Egypt in fiscal years 2011 through 2015 in part due to unique authorities associated with FMF funding for Egypt. Annual appropriations acts for fiscal years 2011 through 2015 contain language stating that FMF funds shall be obligated upon apportionment. In addition, the U.S. government has historically provided Egypt with FMF assistance through a statutory cash flow financing arrangement that provides Egypt the ability to agree to the purchase of defense goods and services in a given year and then pay for them over time, using FMF funds allocated from future appropriations. Cash flow financing gives Egypt the flexibility to commit to major acquisitions in one year that will be paid for over time, similar to installment payments. Because of Egypt’s payment schedules on existing contracts, much of its FMF funding for fiscal years 2011 through 2015 is committed shortly after being obligated, according to State and DOD officials. Egypt generally uses the majority of its allocated FMF funds to purchase defense goods and services through the Foreign Military Sales program. However, it also uses FMF funds to make some direct commercial sales purchases. Egypt is one of only 10 countries that Congress has made eligible to use FMF funds to make direct commercial sales purchases. Egypt has used FMF funding to purchase and sustain a wide array of military systems, including major systems such as F-16 aircraft, Apache helicopters, and M1A1 tanks (see fig. 2). As of September 30, 2015, State had disbursed less than half of the funding allocated for Egypt in fiscal years 2011 through 2015 from the IMET, INCLE, and NADR Antiterrorism Assistance (ATA) accounts and had disbursed about 56 percent of NADR Export Control and Related Border Security (EXBS) account funding (see table 4). In total, State disbursed about 40 percent of the more than $32 million allocated for Egypt from these four accounts during this period. Table 4 provides detailed information on the amount of funds allocated, unobligated, and disbursed for each of these accounts for fiscal years 2011 through 2015. The majority of the funding that State had not disbursed as of September 30, 2015, was appropriated in fiscal years 2014 and 2015. However, each of the accounts also had funding dating back to fiscal years 2011 through 2013 that had not been disbursed. For example, as of September 30, 2015, State had not disbursed 22 percent of IMET funding, 34 percent of INCLE funding, 58 percent of ATA funding, and 27 percent of EXBS funding appropriated for Egypt in fiscal years 2011 through 2013. Of the amounts not disbursed from the four accounts, 95 percent of the funds allocated in fiscal years 2011 through 2015 remained available for obligation as of September 30, 2015. The majority of the remaining 5 percent had expired and was no longer available for disbursement, as of September 30, 2015. State officials noted various challenges since the beginning of fiscal year 2011 that affected State’s ability to obligate and disburse funds from these accounts for Egypt, including Egypt’s political transitions, the security situation in Egypt, and various legal and policy restrictions on assistance for Egypt. For example, Embassy Cairo officials noted that concerns about the ability to clear key Egyptian interlocutors through the Leahy vetting process affected their ability to obligate and disburse funds from some accounts, such as NADR ATA. Appendix V provides more details on the status of funds for these four accounts. The U.S. government has used funding from these accounts for a range of security assistance activities. For example, the U.S. government has used IMET funding to provide training to Egyptian military personnel on U.S. military doctrine and values, INCLE funding to train the Egyptian police on forensic investigative techniques and community policing models, and NADR funding to expand cooperation with the Egyptian government related to efforts to target and disrupt international terrorism and weapons smuggling groups. DOD and State implemented end-use monitoring for equipment transferred to Egyptian security forces; however, challenges associated with obtaining Egyptian government cooperation sometimes hampered these monitoring efforts, and a lack of agency documentation limited accountability for some of them. Under its Golden Sentry program, DOD conducted required serial number inventories and physical security inspections for sensitive equipment in 2015 as well as routine end-use monitoring for less sensitive items, but the department lacked documentation of some prior year monitoring efforts. DOD officials also faced challenges in gaining access to Egyptian government storage facilities to conduct physical security inspections. Under its Blue Lantern program, State conducted 12 end-use monitoring checks in fiscal years 2011 to 2015, but slow and incomplete responses from the Egyptian government and periods of limited staffing at Embassy Cairo limited the effectiveness of some checks. Under the Golden Sentry program in Egypt, DOD implements two levels of end-use monitoring and conducts compliance visits. In fiscal years 2011 through 2015, DOD conducted annual serial number inventories for sensitive equipment provided to Egypt, including Harpoon Block II missiles, night vision devices (NVD), and Stinger missile systems, as required by its enhanced end-use monitoring policy. In fiscal year 2015, DOD also completed physical inspections of storage sites for these items, as required by its enhanced end-use monitoring policy, but lacked evidence of having completed these required inspections in prior years. DOD officials in Cairo also noted challenges in gaining access to an Egyptian government storage facility for NVDs prior to 2015 to verify the physical security for these items. For less sensitive items, DOD documented 49 routine end-use monitoring observations since 2012, including observations of M1A1 tanks and Apache helicopters. Under its Golden Sentry program, DOD has implemented two levels of end-use monitoring—enhanced and routine—and is to conduct periodic Compliance Assessment Visits. Enhanced end-use monitoring. DOD requires enhanced end-use monitoring for sensitive defense articles, services, or technologies specifically designated by the military departments’ export policy, by the interagency release process, or by DOD policy as a result of consultation with Congress. As of November 2015, Egypt had three types of sensitive military equipment that require enhanced end-use monitoring—Harpoon Block II missiles, certain types of NVDs, and Stinger missile systems (see fig. 3). DOD’s policy in the Security Assistance Management Manual and corresponding standard operating procedures for end-use monitoring at the Office of Military Cooperation-Egypt (OMC-E) require DOD officials annually to physically inventory designated equipment by serial number and conduct physical security checks of storage sites where designated equipment is kept. DOD policy requires DOD officials to conduct enhanced end-use monitoring using physical security and accountability checklists. Inventory results must be recorded in DOD’s Security Cooperation Information Portal database—a web-based database that DOD designed to manage various security assistance activities, including Golden Sentry end-use monitoring. Completed checklists must be attached to inventory records and maintained for 5 years. Routine end-use monitoring. DOD requires routine end-use monitoring for all defense articles and services provided through government-to- government programs. OMC-E personnel are required to observe and report any potential misuse, or unapproved transfer, of U.S. defense articles. Routine end-use monitoring is to be conducted in conjunction with other security cooperation functions and uses any readily available source of information. For example, when visiting a military installation on other business, U.S. officials might observe how a host country’s military is using U.S. equipment. DOD policy states that routine end-use monitoring must be documented at least quarterly and records maintained for 5 years. Inventories and physical security checks are not required as part of routine end-use monitoring. Compliance Assessment Visits. In addition to enhanced and routine end-use monitoring, DOD is required to conduct periodic Compliance Assessment Visits to review and evaluate OMC-E’s compliance with Golden Sentry end-use monitoring policy and the Egyptian government’s compliance with specific physical security and accountability requirements and other terms of sale. Compliance Assessment Visits may include facility visits, records inspections, reviews of routine and enhanced end-use monitoring policies and procedures, and inventories of U.S.-origin defense articles. DOD may consider various factors when determining countries to be scheduled for visits, including the types and quantities of defense articles requiring enhanced end-use monitoring, the host nation’s history of compliance with transfer agreements, and the region’s political or military stability. DOD conducted a Compliance Assessment Visit in Egypt in February 2012. DOD’s overall assessment based on this visit was “needs improvement.” According to the manager of the Golden Sentry program, DOD planned to conduct another Compliance Assessment Visit in Egypt in February 2016. Under the Golden Sentry program in Egypt, DOD policy requires that its personnel conduct annual serial number inventories for certain sensitive equipment, including Harpoon Block II missiles, certain types of NVDs, and Stinger missile systems. As of June 1, 2015, DOD data indicate that OMC-E was compliant with required annual inventory requirements for fiscal year 2015 and was able to account for 100 percent of the items subject to enhanced end-use monitoring, including Harpoon missiles, Stinger missiles, and NVDs. Furthermore, DOD data indicate that OMC- E was at least 98 percent compliant with annual inventory requirements at the end of each of fiscal years 2011 through 2014. In an effort to further assess the quality of DOD’s annual inventories, during our June 2015 audit work in Cairo, Egypt, we conducted an inventory check of serial numbers for a random sample of Stinger missiles and were able to account for all of the missiles in our sample. We physically verified serial numbers for 95 percent of the missiles in our sample. For the remaining 5 percent, Egyptian officials provided documentation showing that, since DOD’s previous inventory, the Egyptian Armed Forces had either fired the missiles in testing or deployed them, rendering them unavailable for observation. In advance of our trip, we also requested to inventory a sample of NVDs subject to enhanced end-use monitoring inventory requirements in Egypt. According to the OMC-E official responsible for implementing the Golden Sentry program in Egypt, OMC-E communicated our request to the Egyptian government along with a list of serial numbers for NVDs subject to annual inventory requirements. However, the NVD storage facility that the Egyptian government arranged for us to visit did not house these NVDs, but rather NVDs that did not require annual inventories. As a result, we were unable to complete the planned inventory of NVDs subject to enhanced end-use monitoring requirements. According to the OMC-E official responsible for Golden Sentry in Egypt, Egyptian government officials may have been confused by our request and arranged for us to visit this facility because the NVDs stored there were subject to annual inventory requirements until December 2014. Under Golden Sentry enhanced end-use monitoring, DOD personnel also are required to conduct annual physical security inspections of storage sites where sensitive equipment subject to enhanced end-use monitoring is housed. OMC-E officials said that they generally conduct physical security inspections when they make facility visits to complete required serial number inventories. DOD policy requires that a checklist must be completed and attached to inventory records and maintained for 5 years. OMC-E provided completed checklists to us showing that it had conducted all required physical security checks in fiscal year 2015. Completed checklists showed that DOD personnel verified the physical security of the two facilities housing Harpoon Block II missiles, in March 2015; the two facilities housing NVDs, in February and March 2015; and the facility housing Stinger missiles, in March and June 2015. During our June 2015 fieldwork in Egypt, we visited the storage facility for Stinger missiles and independently verified the physical security of this facility. For example, we verified that the facility had clear zones and fences and had established procedures for accessing the bunkers where the missiles are housed, including three-key entry and sign-in, sign-out procedures. We also noted certain deficiencies. For example, the alarm system and closed circuit TVs for the two bunkers were installed but not operational. According to OMC-E officials, they were aware of these issues, which were due to FMF funding shortfalls. As of October 2015, an OMC-E official stated that the Egyptian Ministry of Defense had allocated funds to resolve these issues and was working on a contract with the U.S. Army Corps of Engineers to complete the necessary work. OMC-E lacked evidence (i.e., completed checklists), required for equipment subject to enhanced end-use monitoring, documenting any physical security inspections conducted during facility visits in fiscal years 2013 and 2014. The OMC-E official responsible for Golden Sentry end- use monitoring in Egypt was unsure why checklists that may have been used to conduct physical security checks during these years had not been maintained along with the serial number inventory records, as required by DOD’s Security Assistance Management Manual. OMC-E updated its operating instruction in June 2015 to note, among other things, the requirement to maintain records of completed physical security checks. According to OMC-E officials and documentation, on at least two occasions before fiscal year 2015, Egyptian officials prevented U.S. personnel from conducting required physical security inspections at a storage site housing many of Egypt’s U.S.-origin NVDs that at the time were subject to Golden Sentry enhanced end-use monitoring. In each instance, Egyptian officials brought the NVDs to a central location, enabling DOD personnel to conduct serial number inventories. While Egypt, as a sovereign nation, is not subject to U.S. government requirements unless it has agreed to them with the U.S. government, the Egyptian government has committed in writing to permit inspections of NVD storage facilities. The Security Assistance Management Manual includes standard terms and conditions that must be included in a Letter of Offer and Acceptance, including a provision in which the purchaser agrees to permit scheduled inspections or physical inventories upon the U.S. government’s request, except when other means of end-use monitoring verification shall have been mutually agreed. Five of the six Letters of Offer and Acceptance covering NVDs subject to enhanced end- use monitoring physical security inspections as of December 1, 2014, included such a provision. According to the manager of the Golden Sentry program at the Defense Security Cooperation Agency, one Letter of Offer and Acceptance did not contain this provision because the NVDs were provided on a grant basis and the Egyptian government agreed to permit observation of the items under a separate exchange of letters. In addition to the terms and conditions in the Letters of Offer and Acceptance, a June 2012 control plan for the physical security and accountability of NVDs signed by the Egyptian Ministry of Defense notes that NVD storage facilities will be subject to compliance assessments, audits, and inventories by U.S. representatives. Nonetheless, during a February 2012 Compliance Assessment Visit, Egyptian officials prohibited DOD inspectors from accessing an NVD storage facility, which prevented the inspectors from assessing whether the proper physical security measures were in place, according to DOD officials. This contributed to DOD’s assessment that Egypt’s procedures to comply with the conditions of the transfer agreements for U.S.-provided defense articles needed improvement. In October 2014, Egyptian officials again prohibited OMC-E personnel from accessing the same NVD storage facility to verify physical security, according to DOD documentation. A senior OMC-E official stated that he asked Egyptian officials to comply with the requirement to permit physical inspections of NVD storage facilities but the officials did not comply. According to another OMC-E official responsible for Golden Sentry end-use monitoring in Egypt, the Egyptian Armed Forces told OMC-E officials that they brought the NVDs to a central location to be inventoried for OMC-E’s convenience and security because the NVDs were deployed with units located around the country, including some unsafe locations. The same official noted that the OMC-E explained to its Egyptian counterparts that DOD’s policy required them to either verify the physical security of the facilities where the NVDs were housed or review the Egyptian Armed Forces’ log books to confirm that the NVDs were deployed with military units in the field and were no longer in storage. However, Egyptian officials were not responsive to either of these requests for reasons that are unclear, according to the OMC-E official. DOD personnel are required to conduct routine end-use monitoring in conjunction with other security cooperation functions. According to DOD policy, routine end-use monitoring must be documented on a quarterly basis and the records must be maintained for 5 years. From July 2012 through June 2015, OMC-E documented 49 routine end-use monitoring observations for a variety of military equipment, including M1A1 tanks, Apache helicopters, and various types of fixed-wing aircraft. As shown in table 5, OMC-E documented these observations during 9 of the 12 quarters of this period, with most occurring in fiscal years 2014 and 2015. According to the manager of the Golden Sentry End-Use Monitoring program at the Defense Security Cooperation Agency, there may be circumstances when DOD personnel are not able to perform routine end- use monitoring, as was the case when Embassy Cairo was under ordered departure status from July to November 2013. During our fieldwork in Egypt in June 2015, we accompanied OMC-E personnel on a routine end-use monitoring visit to observe F-16 aircraft at an airbase outside of Cairo. During this visit, we observed six aircraft parked on the tarmac and an emergency shelter constructed to house a new aircraft upon delivery from the United States. OMC-E officials conducted this visit in accordance with DOD policy, and we did not observe any end-use monitoring violations. Under the Blue Lantern program, in fiscal years 2011 through 2015, State conducted 12 end-use monitoring checks of Egyptian government entities that purchased U.S. equipment through direct commercial sales. However, State was unable to complete all but two of these checks within its self-imposed time frames, in part because of the Egyptian government’s slow responses to Blue Lantern inquiries. In addition, for some Blue Lantern checks, State received no response or partial responses from the Egyptian government to inquiries about the end use of equipment transferred through direct commercial sales. Although State has outreach programs to foster cooperation and compliance with Blue Lantern checks, it did not conduct any such outreach in Egypt in fiscal years 2011 through 2015. Under its Blue Lantern program, State is required to conduct end-use monitoring checks based on a case-by-case review of export license applications against established criteria for determining potential risks. To determine whether to conduct a Blue Lantern check, State considers 20 indicators that may trigger a check, such as unfamiliar end users, foreign intermediate consignees with no apparent connection to the end user, and requests for sensitive commodities whose diversion or illicit retransfer could have a negative impact on U.S. national security. However, State is not required to conduct a particular number of Blue Lantern checks in a given fiscal year. State conducted two types of end-use monitoring checks in Egypt during fiscal years 2011 through 2015—prelicense checks and postshipment verifications (hereafter, postshipment checks). State conducts prelicense checks prior to issuance of a license and conducts postshipment checks after an export has been approved and shipped. According to State’s Blue Lantern Guidebook, prelicense checks are generally used to verify the security of facilities where items may be temporarily or permanently housed and to ensure that the details of a proposed transaction match those on a license application, among other things. Postshipment checks are used to inquire with the end user about the specific use and handling of exported articles or about other follow-up matters related to the transaction and compliance with U.S. regulations and laws, among other things. As shown in figure 4, State’s Directorate of Defense Trade Controls requests a Blue Lantern check in Egypt by sending a cable to U.S. Embassy Cairo. The cable may request that embassy personnel make inquiries to confirm the bona fides of the end user or other party to the transaction and may include specific questions for the embassy to ask the subject of the check. State officials at Embassy Cairo conduct the check by sending letters to the Egyptian government or another entity. When embassy personnel receive a response to their inquiries, they send a return cable with their findings. Directorate of Defense Trade Controls officials then determine whether to close the case favorably or unfavorably. The results of Blue Lantern checks inform decisions on whether to approve licenses for the export of U.S. defense articles. State officials at Embassy Cairo responsible for Blue Lantern checks in Egypt during fiscal years 2013 through 2015 reported never having conducted a site visit to physically verify the security and end use of the items. According to State officials, the Egyptian government has resisted such visits, and Blue Lantern guidance does not require them. From October 2010 to April 2015, 1,280 license applications were submitted for the permanent export of defense articles to Egypt through direct commercial sales. Of those 1,280 license applications, State approved 937 licenses for the export of defense articles to Egypt. In fiscal years 2011 through 2015, State conducted 12 Blue Lantern checks on Egyptian government entities that purchased a variety of security-related equipment through direct commercial sales, including missile equipment, explosives, satellite components, riot control items, and NVDs. Of these 12 checks, 8 were prelicense checks and 4 were postshipment checks, as shown in table 6. State reported favorable results for 8 of the 12 checks and unfavorable results for 4. According to State guidance, if the critical questions have been answered satisfactorily, the transaction appears legitimate, and the bona fides of the end users or other parties are confirmed, the case will likely be closed as “favorable.” If the transaction’s legitimacy cannot be confirmed, the consignees or end user appear untrustworthy, or if there are other troubling discrepancies, the case will likely be closed as “unfavorable.” The reasons for checks in Egypt closed as unfavorable include a lack of response from the Egyptian government and the government’s denial that it had ordered the equipment subject to the check, according to our analysis of State data. While State completed 12 Blue Lantern checks from fiscal years 2011 through 2015, it faced challenges due to slow and incomplete responses from the Egyptian government and other factors such as periods of limited staffing at Embassy Cairo. Slow responses to Blue Lantern checks and limited embassy staffing. Embassy Cairo completed 2 of 12 Blue Lantern checks in Egypt from fiscal years 2011 through 2015 within State’s recommended time frames. According to the Blue Lantern Guidebook, prelicense checks are requested to be completed within 30 days and postshipment checks are requested to be completed within 45 days. In fiscal years 2011 through 2015, Embassy Cairo conducted 1 of its 8 prelicense checks within State’s 30-day goal, and completed 1 of 4 postshipment checks within State’s 45-day goal. On average, during this period, State completed its Blue Lantern checks on Egyptian entities in about 134 days, with prelicense checks averaging about 105 days and postshipment checks averaging 191 days. Seven of 12 Blue Lantern checks on Egyptian entities took 100 or more days to complete, and 1 of these 7 checks took over 300 days to complete during fiscal years 2011 through 2015 (see table 7). According to State guidance, State should defer making a decision on a license application until the results of prelicense checks are received. We found that State generally complied with this guidance for prelicense checks in Egypt. Lengthy delays in completing prelicense checks can be costly to U.S. exporters and foreign end users and ultimately harm U.S. competitiveness, according to State guidance. According to State officials, some of the delays in completing Blue Lantern checks in Egypt were due to the Egyptian government’s slow responses to State’s inquiries. For example, in one postshipment check requested in June 2013, the Egyptian government did not respond to questions related to this Blue Lantern check for over 8 months, according to our analysis of State cables. This check involved thermal imagers, which are considered to be sensitive night vision equipment. As a result, State experienced substantial delays verifying the location, security, and end use of these items. According to our analysis of State data, in another postshipment check requested in October 2013 involving satellite components, State did not receive information it deemed sufficient to close the check from the Egyptian government for more than 6 months and, according to State officials, the satellite was launched before State was able to complete the Blue Lantern check. Another two Blue Lantern checks requested in May and June 2013 took over 100 days to complete. According to State officials, political instability in Egypt and tensions in the U.S.-Egypt relationship at the time affected the timeliness of the Egyptian government’s response to these four checks. In the two most recent Blue Lantern prelicense checks, both of which involved NVDs going to the Egyptian Ministry of Interior, a State official noted that there were delays in obtaining a response because inquiries first had to be routed through the Ministry of Foreign Affairs. For one of these checks, State did not receive a response to two of its initial Blue Lantern inquiries, and as a result, completing the check took 4 months. State officials also noted that Embassy Cairo was under ordered departure status from July to November 2013, which limited staffing at the embassy, and a staffing transition in 2014 also contributed to delays in completing some checks. For instance, limited staffing at Embassy Cairo during the latter half of 2013 affected the timeliness of four Blue Lantern checks active during that period. According to State officials, the lack of available staff at Embassy Cairo during the ordered departure caused embassy officials to request additional time to complete Blue Lantern checks and to request that at least one Blue Lantern check be put on a temporary hold during that period. As a result of the hold and the Egyptian government’s slow response time, this check took 8 months to complete. A State official also noted that a staffing transition in the summer of 2014 affected another check. In this case, Embassy Cairo took 52 days to contact the Egyptian government after receiving the Blue Lantern cable requesting the prelicense check, and as a result, the check took more than 60 days to complete. Incomplete responses to some Blue Lantern checks. During fiscal years 2011 through 2015, the Egyptian government provided complete responses to 4 of 12 Blue Lantern checks. For 6 of the 12 checks, it provided partial responses to the questions asked by State officials from Embassy Cairo. For 1 of the 12 checks, the Egyptian government did not provide any response. For another 1 of the 12 checks, State officials from the Directorate of Defense Trade Controls did not receive a response from Embassy Cairo officials, so we were unable to determine whether Embassy Cairo made inquiries with the Egyptian government and whether the Egyptian government responded to any inquiries that may have been made. Directorate of Defense Trade Controls officials closed the 2 cases for which it received no response, both prelicense checks, as unfavorable and recommended that the license applications not be approved. In the 6 Blue Lantern cases where the Egyptian government partially responded to the questions asked by State officials at Embassy Cairo, State closed the cases as favorable in 5 of the 6 cases. In one prelicense check, the Egyptian government did not respond to questions about the physical security of the storage site where they planned to store NVDs, nor did it specify the branch of the Ministry of Interior—an organization identified by State as having security force units of concern for human rights violations—that would be the end user of the NVDs. In another prelicense check, State asked the Egyptian government to confirm the involvement of intermediaries from two other countries in the transaction as well as the specific type and quantity of the items it had ordered; however, the Egyptian government only confirmed the involvement of one of the intermediaries and did not provide any information about the type and quantity of items ordered. In a postshipment check involving the transfer of riot control items, such as rubber ball cartridges and smoke grenades, to the Egyptian Ministry of Interior, the Egyptian government did not respond to a question about the disposition and use of the items, according to a cable from Embassy Cairo. State closed each of these three checks as favorable. Table 8 shows a breakdown of the response-completeness status for the 12 Blue Lantern checks and the corresponding count of favorable and unfavorable results. State officials offered various reasons to explain why the Egyptian government provided partial responses to Blue Lantern inquiries and why State did not make greater efforts to obtain complete responses. According to State officials, the Egyptian government is sensitive to questions that it views as possibly infringing on its sovereignty, including questions about its purchases of U.S. military equipment. In addition, one State official who has conducted Blue Lantern checks in Egypt noted that the Egyptian government may not entirely understand Blue Lantern inquiries. According to State officials, a response to every question posed in a Blue Lantern check is not necessary for a licensing determination. These officials also noted that if their key concerns have been addressed, they are generally comfortable closing the check. However, as previously noted, because State officials at Embassy Cairo do not conduct optional site visits, written responses from the Egyptian government provide the only available information on the use and security of equipment purchased through direct commercial sales. Without timely and complete information, State may not be able to provide reasonable assurance within its own recommended time frames that some recipients are storing, handling, and using this sensitive U.S. equipment properly. State has two optional programs that are designed to facilitate cooperation and compliance with Blue Lantern end-use monitoring requirements. However, State has not used either program in Egypt since 2008, despite the Egyptian government’s limited cooperation in providing complete and timely responses to Blue Lantern inquiries. One such program consists of outreach visits conducted by State officials from the Directorate of Defense Trade Controls, who travel to meet with U.S. embassy, host government, and local business officials to educate them about the Blue Lantern program and to elicit cooperation with Blue Lantern end-use monitoring. State guidance outlines six criteria that officials use when deciding whether to conduct a Blue Lantern outreach visit. We determined that Egypt meets the following three of these criteria: High percentage of unfavorable results. The average global rate of unfavorable checks for the Blue Lantern program over the last 4 years reported (fiscal years 2011-2014) was 21 percent. Over the same period, 36 percent of Blue Lantern checks in Egypt were closed as unfavorable. State conducted 1 Blue Lantern check in Egypt in fiscal year 2015 and closed it as favorable, which lowered the unfavorable rate for Blue Lantern checks in Egypt to 33 percent during fiscal years 2011 through 2015. Need to provide education on U.S. export law and regulations. According to our analysis of State documents and data, the Egyptian government provided partial responses to 6 Blue Lantern inquiries, gave no response to at least 1 inquiry, and did not respond to at least 5 inquiries within requested time frames in fiscal years 2011 through 2015. As previously mentioned, this resulted partly from a lack of understanding about the program, according to a State official. No prior outreach visit. According to State officials in Washington, D.C., and Cairo, Egypt, as of November 2015, no Blue Lantern outreach visit had been conducted in Egypt since 2008, prior to Egypt’s political transitions in 2011 and 2013. In addition, in July 2015, State introduced the Blue Lantern Post Support Program, which provides funding for outreach and educational activities and events hosted by U.S. embassies or consulates to improve compliance with U.S. export control laws and regulations, among other things. State guidance for this program notes that when considering and prioritizing proposals to fund, State will consider various criteria, including the host government’s cooperation with Blue Lantern checks and the government’s level of understanding of U.S. commercial defense trade controls. According to a State official who conducted Blue Lantern checks in Egypt in 2013, outreach to the Egyptian government on the Blue Lantern program would be worthwhile. However, Embassy Cairo did not submit a proposal for funding under the Blue Lantern Post Support Program in 2015. According to State officials, they did not conduct any outreach in Egypt in fiscal years 2011 through 2015 because the number of Blue Lantern checks conducted in Egypt during this period was small and because they prioritized outreach to other countries. Without the cooperation of the Egyptian government, State may continue to face challenges in obtaining complete and timely responses to Blue Lantern inquiries. The U.S. government completed human rights vetting for 5,581 Egyptian security forces before providing U.S.-funded training in fiscal year 2011 through March 31, 2015; however, our analysis of a sample of names from training rosters of Egyptian security forces who received U.S.-funded training shows that that the U.S. government did not complete all required vetting prior to providing training, in violation of State’s and DOD’s policies. In contrast to State’s vetting requirements for training, State’s policies and procedures encourage, but do not specifically require, vetting for foreign security forces that receive U.S.-funded equipment, including those in Egypt. The primary method State uses in Egypt to comply with Leahy law requirements when providing equipment is to attest in memos that State is in compliance with Leahy law requirements. Various factors have posed challenges to the U.S. government’s efforts to vet recipients of U.S. assistance. Gaps and uncertainties in information have made it challenging for U.S. officials to vet some cases before providing training. Additionally, State has not established procedures for clearing smaller units or individuals within a larger unit that has been deemed ineligible to receive assistance. Finally, Embassy Cairo has recorded little information on human rights abuses by Egyptian officials in INVEST since the beginning of fiscal year 2011, despite State requirements to do so. As shown in table 9, the U.S. government completed human rights vetting for a total of 5,581 Egyptian individuals or units before providing training from fiscal year 2011 through March 31, 2015. Of the individuals and units submitted for vetting, State approved training for approximately 90 percent of the Egyptian security forces it vetted during this period. State suspended about 9 percent of the vetting cases for Egyptian security forces, suspending some cases for administrative reasons and suspending other cases because of potentially derogatory information related to the individuals or units being vetted that could not be resolved before the start of the planned training. In some cases, this potentially derogatory information related to human rights abuses, and in other cases it related to other types of potentially derogatory information, such as involvement in terrorism. For example, State suspended an individual in fiscal year 2015 because it was unable to clear the individual’s unit from involvement in torture at a military prison prior to the start of the planned training. According to State, Embassy Cairo was able to subsequently provide additional information to DRL that cleared this individual’s unit from involvement in the incident at the prison. Embassy Cairo then resubmitted the individual for vetting, and State approved him to participate in a different course, later in fiscal year 2015. State also suspended an individual in fiscal year 2015 because it had identified potential terrorism links that could not be ruled out prior to the start of the planned training. According to State officials, Embassy Cairo found no information credibly linking this person to terrorism activity; however, before further checks could be conducted, he was dropped from the course at the request of OMC-E to avoid holding up other participants. State also rejected training for Egyptian security forces in a limited number of cases due to credible information of gross violations of human rights. State rejected a total of 18 cases in fiscal year 2011 through March 31, 2015—less than 1 percent of the total cases vetted. It has not rejected any cases since fiscal year 2013, including no cases since the removal of President Morsi in July 2013. According to State officials, these rejections were related to both acts committed by specific individuals, as well as credible information about gross violations of human rights involving an individual’s unit. According to State officials, State has rejected a limited number of cases, including no cases since fiscal year 2013, due in part to problematic units and individuals being filtered out by the embassy before they are formally submitted for training. Finally, State cancelled 34 cases (less than 1 percent of the total cases vetted) for administrative reasons from November 2014, when this new disposition option was created in INVEST, through March 2015. According to State officials, these cancellations were due to issues such as training courses being cancelled and data entry errors. We determined that the U.S. government did not conduct required vetting before providing training for some of the Egyptian security forces that were trained with U.S. security-related assistance from seven accounts in fiscal year 2011 through March 31, 2015. To make this determination, we selected a generalizable stratified random sample of 166 names from training rosters of Egyptian security forces who received training funded through these seven accounts during this period. We then cross-checked the 166 names in our sample with human rights vetting data from the INVEST system to verify that the Egyptian security forces were vetted before receiving the training. State deemed our estimate of the percentage of Egyptian security forces that were not vetted and some aspects of the methodology we used to generate this estimate to be sensitive but unclassified information. We therefore omitted that information from this report. By not conducting all required human rights vetting prior to providing U.S. training to Egyptian security forces, State and DOD are not in compliance with their policies regarding human rights vetting. In addition to examining rosters for training funded through the seven accounts, we also requested training rosters from State for Egyptian security forces who had received training funded through the NADR account; however, State was unable to provide this information. We therefore did not include this account in our analysis. While INVEST data show that State vetted a number of Egyptian security forces that received NADR-funded training in fiscal year 2011 through March 31, 2015, without the NADR training roster we were not able to assess the extent to which State completed all required human rights vetting for Egyptian security forces that were trained using funding from the NADR account. State’s Foreign Affairs Manual notes, among other things, the importance of producing and maintaining adequate documentation of the agency’s activities. In addition, federal Standards for Internal Control in the Federal Government states that agencies should clearly document transactions and all significant events, the documentation should be readily available for examination, and all documentation should be properly managed and maintained. Without the training roster for the NADR account, State cannot provide assurance that all Egyptian security forces that received NADR-funded training were vetted as required. The State and DOD Leahy laws’ prohibition against providing assistance to units of foreign security forces for whom there is credible information of a gross violation of human rights also applies to equipment. However, unlike its required process for vetting individuals and units nominated to receive U.S.-provided training (see fig. 1), State does not have policies or procedures specifically requiring vetting of Egyptian security forces slated to receive U.S.-funded equipment. State policy encourages the use of the INVEST system to conduct vetting for equipment recipients but allows posts the flexibility to use other methods to comply with the Leahy laws. For Egypt, State uses memos to attest to its compliance with the Leahy laws for equipment provided to Egyptian security forces. While the memos declare State’s compliance with the Leahy laws, State officials acknowledged that there is no required process used to support the statements in the memos and that INVEST is not used to vet Egyptian recipients of U.S. equipment. We reviewed the eight memos that State drafted for fiscal years 2011 through 2015 that covered all FMF assistance allocated for Egypt during this period. The purpose of these memos is to request the Office of Management and Budget’s approval for the apportionment of FMF funds allocated for Egypt. In each of the memos, State included a statement that it was not aware of any credible information of gross violations of human rights by any unit to which assistance would be provided. More recent memos also included a statement that State would ensure that FMF assistance for Egypt would be provided only to units the department had positively determined not to have been linked to human rights violations. None of the memos we reviewed specified particular Egyptian units that were authorized to receive the FMF assistance covered by the memo. However, two of the eight memos we reviewed identified particular Egyptian security forces that would not be receiving assistance covered by the memo. For example, a September 2013 memo requesting the apportionment of approximately $584 million in fiscal year 2013 FMF funds stated that no funds would be used to support the Cairo military police. State’s three memos requesting the apportionment of fiscal years 2014 and 2015 funds noted that violent incidents in Egypt in July and August 2013 and the Egyptian military’s operations in the Sinai remained under review. State’s Bureau of Political-Military Affairs is responsible for drafting the FMF memos for Egypt, including the statements regarding compliance with the Leahy laws; however, the bureau said that it does not play a role in supporting the statements in the memos and that this was the responsibility of DRL. The DRL official responsible for reviewing these memos told us that he may check the unit names of the prospective equipment recipients if that information is available at the time the memos are drafted, to see if he is aware of human rights concerns with any of the recipient units; however, State officials told us that the specific items to be financed and the specific units or individuals to receive the items are not generally known at the time the memos are circulated and may not be known until many months or even years later. According to State officials, this is due to the Foreign Military Sales process, which can involve lengthy negotiations with Egypt and other partner countries about their requirements and extended contracting processes for complex military systems. Also, according to State officials, the receipt of sale and transfer of equipment is often concluded in the United States, with the Egyptian government then responsible for freighting the equipment to Egypt. This can result in delays in the final Egyptian recipients receiving the equipment, according to State officials. In addition, State does not currently have policies or procedures in place to require vetting after the equipment has been furnished to the Egyptian government and the ultimate end-user unit or individual is known, according to State officials. State officials noted that in some cases, Egyptian security forces receive training in association with equipment that they are provided and are thus vetted through INVEST before receiving the training. Finally, State officials said that in cases where there is no direct recipient for U.S. assistance, such as when bulk equipment and other forms of assistance (e.g., ammunition, uniforms, radios, spare parts) are provided to a country’s military services or the armed forces as a whole for general use, it is a challenge for State to verify the identity of the final recipients of this equipment. Additionally, key officials with information about human rights violations in Egypt are not involved in drafting and reviewing these memos. Embassy Cairo officials who are responsible for managing Leahy vetting at the post stated that they do not play a role in the development of these memos. These Embassy Cairo officials stated that it was not clear what role, if any, the post should be playing in ensuring Leahy law compliance for Egyptian equipment recipients and that more guidance from State headquarters on this issue would be beneficial. NEA and DRL officials in State headquarters who were responsible for conducting human rights vetting for Egyptian training recipients also stated that they do not play a role in ensuring Leahy law compliance for equipment provided to Egyptian security forces. We previously reported on State’s use of memos to comply with Leahy law requirements for equipment in a 2011 report examining human rights vetting in the Persian Gulf countries. In that report, we found that State did not conduct comparable human rights vetting for recipients of equipment as it did for recipients of training. We recommended that State implement individual- and unit-level human rights vetting for recipients of U.S.-funded equipment to reduce the risk that U.S.-funded equipment might be used by violators of human rights in the Persian Gulf countries. State concurred with our recommendation, but as of November 2015, State had not implemented it. DRL officials we interviewed acknowledged that the current approach to complying with the Leahy laws for equipment needs to be strengthened to ensure that equipment will not be provided to security forces that have committed gross violations of human rights. According to DRL officials, State is continuing to work to develop and implement a comprehensive policy on equipment vetting that is different from the current, memo-based procedure, but it has not established a specific time frame for doing so. In addition, a DRL official noted that DRL is working on a revised version of the INVEST system, to be completed in May 2016, that is expected to help facilitate equipment vetting. However, the DRL official stated that DRL has not made specific determinations about what functions related to equipment vetting will be included in the updated system or about time frames for developing agency policies and procedures that would require use of the updated system for equipment vetting. Standard practices in program management include, among other things, developing a plan to execute projects within a specific time frame. Because State has not developed policies or procedures specifically requiring vetting for Egyptian recipients of U.S. equipment, it is more difficult to reasonably ensure that U.S. equipment will not be provided to Egyptian security forces for whom there may be credible information that a unit has committed gross violations of human rights. This increases the risk that State may violate the prohibition in the Leahy laws as well as its own policy that it should ensure that its programs are efficiently and effectively carried out in accordance with applicable laws. Various factors affected State’s implementation of the Leahy laws. For example, gaps and uncertainties in information have challenged U.S. efforts to vet for training. In addition, the Egyptian government has routinely been unwilling to provide information that would facilitate the vetting process, according to State officials. Moreover, State has not established procedures for clearing smaller units or individuals within a larger unit that has been deemed ineligible to receive assistance. Finally, Embassy Cairo has populated little information about human rights abuses in Egypt in the INVEST system, despite State requirements to do so. Embassy Cairo and State officials noted that the Egyptian government has routinely been unwilling to provide information that would facilitate the vetting process. According to U.S. officials, the Egyptian government sometimes does not provide the unit-specific information necessary to complete vetting. Embassy Cairo and State headquarters officials also stated that the Egyptian government was unwilling to provide organizational charts and other information for certain key ministries that would facilitate the vetting process. For example, U.S. officials said that more detailed organizational charts for the Egyptian Ministry of Interior (MOI) would help the U.S. government differentiate between, on one hand, MOI subunits that were of concern for gross violations of human rights and thus were not able to receive U.S. assistance and, on the other hand, those MOI subunits that were not likely involved in the incidents for which State had credible information that human rights violations had occurred. The State Leahy law requires that State develop procedures to ensure that when an individual is designated to receive U.S. training or other assistance, the individual’s unit is vetted as well as the individual. State guidance notes that country security assistance teams should be well informed about the force structure and unit descriptions for the security forces with which they work and thus should be able to provide the appropriate unit-level identification for vetting purposes. State guidance directs embassies to work with host-country counterparts to identify units for the purposes of vetting and notes the importance of host-country cooperation. Embassy Cairo officials noted that issues related to Leahy vetting have been a significant source of tensions with the Egyptian government. In some cases, Egyptian agencies refused to allow any of their members to attend training events if any individuals from their organizational unit failed to clear vetting. In addition, embassy officials acknowledged that they stopped proposing training to the Egyptian government under certain programs, such as NADR ATA, because they did not want to risk causing further strain in the bilateral relationship if Egyptian officials were not approved through the vetting process. U.S. officials noted that this cessation in submitting candidates for training was one of the reasons that, since fiscal year 2013, no Egyptian security forces had been rejected through the Leahy vetting process due to credible information of a gross violation of human rights. We requested to meet with several Egyptian government ministries to obtain their perspective on the Leahy vetting program during our fieldwork in Egypt, but the Egyptian government did not respond to our request, according to State officials. Additionally, although the Egyptian government initially approved our request to meet with officials of the Egyptian Training Authority to discuss Leahy vetting for Egyptian military students, the government subsequently decided not to hold the meeting. When units have been rejected through the vetting process and deemed ineligible to receive assistance under the Leahy laws, the U.S. government cannot provide the unit further assistance unless the requirements for an exception have been met. In February 2015, State and DOD issued a joint remediation policy that outlined standards for exercising these exceptions in the Leahy laws and allowing assistance to resume to units previously deemed ineligible. However, State officials we interviewed said that if a larger unit is rejected in INVEST, it is possible for smaller units within that larger unit to be subsequently approved for training without having to meet the standards in the February 2015 State- DOD guidance, if it can be demonstrated that these smaller units were not implicated in the gross violation of human rights. This is consistent with State’s 2012 Leahy vetting guide, which states that the relevant unit for vetting purposes is the lowest deployable organizational element of a security force capable of exercising command and discipline over its members. State officials said the policy allows State to approve training for smaller units or individuals within a larger unit that is ineligible to receive assistance, if it can be demonstrated that the smaller units or individuals, by the nature of their duties, geographic location, or other circumstances, would not have been involved in the gross violation of human rights. According to U.S. officials, this approach has been used in Egypt on certain occasions. State has also used this approach in cases where units have not been officially rejected in INVEST but have been suspended because State has identified human rights concerns with the unit and there is a lack of sufficient information to complete vetting for the nominated individuals or units. While this approach has been used in Egypt, and although State’s policy allows smaller units to be identified as discrete units for purposes of Leahy vetting, State has not established specific procedures for clearing smaller units within a larger security force organization that has been rejected due to credible information of a gross violation of human rights. For example, State’s Leahy vetting guide, Embassy Cairo’s standard operating procedures, and State and DOD’s joint remediation guidance do not specifically discuss the ability to clear such units and do not establish procedures for doing so. State’s Foreign Affairs Manual highlights the importance of ensuring that key polices are documented. Without established procedures for clearing smaller units within larger organizations that have been deemed ineligible to receive assistance due to a gross violation of human rights, Embassy Cairo and other embassies do not have clear guidance on the extent to which they are able to use this option and in what situations it is or is not appropriate to seek to do so. The State Leahy law requires State to establish procedures to ensure that information on gross violations of human rights by security force units is evaluated and preserved. In addition, State’s 2012 Leahy vetting guide states that embassies in particular are required to populate the INVEST system—in conjunction with vetting or otherwise—with information on human rights abuses as these abuses come to light. However, Embassy Cairo has recorded limited information on human rights abuses by security forces in Egypt in INVEST since the beginning of fiscal year 2011, despite State’s findings of a range of human rights abuses by security forces in Egypt and despite State having vetted thousands of cases since then. As of October 2015, Embassy Cairo had uploaded only three documents to INVEST since fiscal year 2011 and no documents since fiscal year 2013, according to DRL officials. DRL officials stated that it is common for posts to not use the document library function in INVEST despite the requirement in its Leahy guide that they do so and, instead, to maintain this information in other formats, such as spreadsheets Embassy Cairo officials told us that they use to track individuals and units of concern. However, by not uploading relevant information into INVEST, Embassy Cairo is not maintaining a centralized repository of information on human rights abusers in Egypt that can be used by others in the agency. Without a centralized repository of this information, State cannot be assured that all current and future officials vetting cases in INVEST will have the information needed to make accurately informed and timely decisions regarding whether or not to approve Egyptian security officials for U.S.-funded training. The United States provides about $1.3 billion in security-related assistance to Egypt annually. DOD and State established the Golden Sentry and Blue Lantern programs, respectively, to provide reasonable assurance that military equipment transferred or exported to foreign governments is used for its legitimate intended purposes and does not come into the possession of individuals or groups who pose a threat to the United States or its allies. However, gaps in the implementation of these end-use monitoring programs—in part due to limited cooperation from the Egyptian government—hampers DOD’s and State’s ability to provide such assurances. For instance, the Egyptian government’s incomplete and slow responses to U.S. inquiries hindered State’s efforts to ensure that equipment sold through direct commercial sales is used as intended. State has recently made funding available for activities to foster greater host government cooperation with Blue Lantern requirements in some countries. However, such activities have not been used in Egypt to help improve the completeness and timeliness of these end-use monitoring checks targeting U.S. arms and other military items sold through direct commercial sales. The United States has a policy interest in leveraging U.S. assistance to encourage Egypt and other foreign governments to prevent their security forces from committing human rights violations and to hold their forces accountable when violations occur. However, the U.S. government has not consistently vetted all individuals and units in the Egyptian security forces for human rights concerns before providing training, as required by its policies. State also does not have policies or procedures for vetting specific individuals and units before it provides equipment, even though military equipment constitutes the vast majority of U.S. assistance to Egypt. Without such vetting, the U.S. government risks providing U.S. equipment, in violation of the Leahy laws, to Egyptian security forces that have committed human rights abuses. Additionally, gaps in documentation and procedures may limit the effectiveness of State’s process for vetting prospective recipients of training. The absence of certain training rosters for Egyptian security forces that received U.S. training limits the ability of U.S. agencies and third parties to verify whether these forces were properly vetted in accordance with State’s policies. This also limits accountability over U.S. efforts to train and equip Egyptian security forces. State’s lack of procedures for determining when individuals or subunits may be eligible to receive training, despite being part of larger entities prohibited from receiving assistance under the Leahy laws, increases the likelihood that these determinations may be applied inconsistently. Finally, Embassy Cairo’s minimal use of the INVEST system as a centralized repository for information on human rights abuses in Egypt limits the availability of relevant information to other U.S. officials conducting human rights vetting of candidates for U.S.-funded training in Egypt. To strengthen assurances that military equipment sold through direct commercial sales is used as intended, we recommend that the Secretary of State take the following action: Utilize available Blue Lantern outreach programs to help improve the completeness and timeliness of responses from the Egyptian government. To strengthen compliance with the Leahy laws and implementation of State’s human rights vetting process and to help ensure that U.S. funded assistance is not provided to Egyptian security forces that have committed gross violations of human rights, we recommend that the Secretary of State take the following two actions: Determine, in consultation with the Secretary of Defense, the factors that resulted in some Egyptian security forces not being vetted before receiving U.S. training, and take steps to address these factors, to ensure full compliance with human rights vetting requirements for future training. As State works to implement a revised version of the INVEST system that is expected to help facilitate equipment vetting, develop time frames for establishing corresponding policies and procedures to implement a vetting process to help enable the U.S. government to provide a more reasonable level of assurance that equipment is not transferred to foreign security forces, including those in Egypt, when there is credible information that a unit has committed a gross violation of human rights. To strengthen State’s documentation and procedures related to its human rights vetting process, we recommend that the Secretary of State take the following three actions: Take steps to ensure that State maintains training rosters or similar records of Egyptian security forces that have received U.S.-funded training to allow verification that required human rights vetting was completed before the individual or units received the training. Issue guidance establishing procedures for determining when subunits—and individuals within those subunits—are eligible to receive U.S. assistance when they are part of a larger unit that has been deemed ineligible to receive assistance under the Leahy laws. Direct Embassy Cairo to comply with the State requirement to record relevant information it obtains regarding gross violations of human rights in INVEST. We provided a draft of the sensitive but unclassified version of this report to the Departments of State, Defense, Homeland Security, and Justice for review and comment. State and the Departments of Homeland Security and Justice provided technical comments, which we incorporated as appropriate. State also provided written comments, which are reproduced in appendix VI. State generally concurred with our recommendations. DOD did not provide comments. State agreed with our recommendation to utilize available Blue Lantern outreach programs to help improve the completeness and timeliness of responses from the Egyptian government and noted that it would do so, subject to restrictions on travel to Egypt and any limitations inherent in the United States’ current political relations with the Egyptian government. State also agreed with our recommendation to determine and address the factors that led to some Egyptian security forces not being vetted before receiving training and asserted that the department remains committed to ensuring that perpetrators of gross violations of human rights do not receive U.S. training or assistance. Additionally, State agreed with our recommendation to develop time frames for establishing policies and procedures to provide a more reasonable level of assurance that the department is complying with the Leahy laws for recipients of equipment. Although State acknowledged challenges identifying recipients of equipment across the range of assistance activities, it noted that it would continue to update its systems—including a new version of the INVEST system—and procedures to facilitate human rights vetting for recipients of equipment. State partially agreed with our recommendation to maintain training rosters or other records of Egyptian security forces that have received U.S.-funded training. State indicated that it would attempt to implement this recommendation but noted resource constraints at Embassy Cairo may hinder its ability to do so. State also partially agreed with our recommendation to develop policies and procedures for determining when individuals and subunits may receive U.S. assistance while part of larger units that have been deemed ineligible to receive assistance. While State acknowledged that criteria for making these determinations are not covered in its guidance, it noted that it already takes such considerations into account on a case-by-case basis during internal policy deliberations to restrict or deny assistance and is currently discussing revisions to its guidance regarding this issue. State agreed with our recommendation that Embassy Cairo comply with the State requirement to record relevant information it obtains regarding gross violations of human rights in INVEST. Accordingly, State noted that it would maintain in INVEST, and periodically update, a version of the spreadsheet it uses to track Egyptian security force units of concern and other allegations of human rights abuses. As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution of this report until 30 days from the report date. At that time, we will send copies of this report to the appropriate congressional committees; the Secretaries of State, Defense, and Homeland Security; and the Attorney General of the United States. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov. If you or your staff members have any questions about this report, please contact me at (202) 512-7331 or johnsoncm@gao.gov. GAO staff who made contributions to this report are listed in appendix VII. The objectives of this review were to examine, for fiscal years 2011 through 2015, the extent to which the U.S. government (1) committed or disbursed funds allocated for security-related assistance for Egypt, (2) implemented end-use monitoring for equipment transferred to Egyptian security forces, and (3) vetted Egyptian recipients of U.S. security-related assistance for human rights concerns. To determine the extent to which the U.S. government committed or disbursed funds allocated for security-related assistance to Egypt in fiscal years 2011 through 2015, we collected and analyzed data from the Department of State’s (State) Office of U.S. Foreign Assistance Resources, by appropriation account, on allocations, unobligated balances, unliquidated obligations, and commitments or disbursements. Recognizing that different agencies and bureaus may use slightly different accounting terms, we provided State with definitions from GAO’s A Glossary of Terms Used in the Federal Budget Process and requested that it provide the relevant data according to those definitions. The data State provided were as of the end of fiscal year 2015. State provided data on bilateral security assistance from the Foreign Military Financing (FMF); International Military Education and Training (IMET); International Narcotics Control and Law Enforcement (INCLE); and Nonproliferation, Anti-terrorism, Demining, and Related Programs (NADR) accounts. Because FMF funds are budgeted and tracked differently than for other foreign assistance accounts, State provided data on FMF funding that was uncommitted or committed rather than data on unliquidated obligations and disbursements. To assess the reliability of the data provided, we requested and reviewed information from State 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 State provided were sufficiently reliable for the purposes of this report. To gather additional information on the status of assistance to Egypt, we interviewed State and Department of Defense (DOD) officials and reviewed agency documents to identify factors that contributed to any unobligated balances and unliquidated obligations. Finally, we identified any relevant legal authorities related to these accounts, including the periods of availability for funds to be obligated from each of these accounts. To determine the extent to which the U.S. government implemented end- use monitoring for equipment transferred to Egyptian security forces, we reviewed agency guidance, analyzed end-use monitoring data and documentation, interviewed U.S. and Egyptian officials, and conducted on-site inspections of military equipment during fieldwork to Egypt in June 2015. To determine the extent to which DOD implemented Golden Sentry end-use monitoring for equipment transferred to Egyptian security forces through government-to-government programs, we reviewed relevant program guidance in the Security Assistance Management Manual and standard operating procedures used by the Office of Military Cooperation–Egypt (OMC-E). We also reviewed the terms and conditions of the Letters of Offer and Acceptance for transfers of U.S.-origin night vision devices (NVD) to Egyptian security forces, the Egyptian Ministry of Defense’s June 2012 control plan for the physical security and accountability of NVDs, and DOD’s April 2013 criteria for end-use monitoring of man-portable NVDs. We reviewed a report summarizing the findings from DOD’s February 2012 Compliance Assessment Visit in Egypt, two U.S. Central Command Inspector General reports for OMC-E, and correspondence from OMC-E to the Egyptian Ministry of Defense communicating end-use monitoring findings. We interviewed or obtained written information from DOD officials in the Defense Security Cooperation Agency, Defense Technology Security Administration, and U.S. Central Command. During fieldwork in Cairo, Egypt, from June 7 through June 11, 2015, we interviewed DOD officials from OMC-E and Egyptian officials from the Egyptian Armament Authority, a unit within the Egyptian Armed Forces responsible for overseeing the procurement of U.S. military equipment and communicating end-use monitoring requirements to units that use this equipment, according to Egyptian officials. We reviewed and analyzed data and management reports from DOD’s Security Cooperation Information Portal database to identify defense articles provided to Egypt and determine compliance with enhanced end-use monitoring inventory requirements. We compared the data with management reports and other documents and determined that the data were sufficiently reliable for the purposes of our analysis. Using data provided by DOD, we drew a random sample of Stinger missiles out of the total number that the U.S. government had transferred to Egypt through government-to-government programs as of April 2015, and we inventoried the missiles in our sample by serial number during fieldwork in Egypt. Our sample was generalizable to the population of Stinger missiles available for observation. We also requested to inventory a sample of NVDs subject to enhanced end-use monitoring during our fieldwork in Egypt, but we were unable to complete this inventory because the NVD storage facility we visited housed NVDs that were not subject to enhanced end-use monitoring. During our fieldwork in Egypt, we also observed DOD officials conducting routine end-use monitoring for F-16 aircraft. To assess evidence of enhanced and routine end-use monitoring in Egypt, we reviewed enhanced end-use monitoring physical security and accountability checklists and routine end-use monitoring reports. To determine the extent to which State implemented Blue Lantern end- use monitoring for equipment transferred to Egyptian security forces through direct commercial sales, we reviewed State guidance on the Blue Lantern program, including the Blue Lantern Guidebook and the Standard Operating Procedures for the Blue Lantern program. We also reviewed relevant cables on the Blue Lantern program. To determine the timeliness and completeness of responses to Blue Lantern checks, we reviewed the cables associated with each Blue Lantern check conducted in Egypt in fiscal years 2011 through 2015. We also reviewed correspondence between the U.S. embassy in Cairo—in this report, “Embassy Cairo”— and the Egyptian government on Blue Lantern checks conducted from July 2014 to September 2015. To determine the number, type, and results of Blue Lantern checks conducted on Egyptian entities in fiscal years 2011 through 2015, we obtained and analyzed Blue Lantern data for Egypt. We also used these data in our analysis of the length of time it took to complete Blue Lantern checks, the commodities subject to the checks, and the reasons for unfavorable Blue Lantern checks in Egypt in fiscal years 2011 through 2015. We reviewed the information in the Blue Lantern cables for consistency with corresponding data in the Blue Lantern database and determined that the Blue Lantern data were sufficiently reliable for the purposes of our analysis. In addition, we analyzed State’s direct commercial sales licensing data on defense articles exported to Egypt to identify the number of licenses going to Egyptian end users and intermediaries from fiscal year 2011 to April 2015, as well as State’s determinations on such licenses subject to Blue Lantern checks during that period. We interviewed State officials in the Directorate of Defense Trade Controls in Washington, D.C., who are responsible for managing the Blue Lantern program as well as the State official at Embassy Cairo who is responsible for conducting Blue Lantern checks in Egypt. In addition, we interviewed a State official who conducted Blue Lantern checks in Egypt from December 2012 to April 2014 to obtain information on the extent to which Egypt’s 2013 political transition affected Blue Lantern checks conducted during that time. To assess the extent to which the U.S. government vetted Egyptian security forces for human rights concerns, we reviewed both the State and DOD Leahy laws. In addition, we analyzed State documents establishing its policies and procedures for complying with the Leahy laws and conducting human rights vetting. For example, we analyzed State’s 2012 Leahy vetting guide, State’s 2010 International Vetting and Security Tracking (INVEST) user guide, and a number of other relevant State cables and policy documents issued since the beginning of fiscal year 2011 that establish further requirements or provide additional guidance on various aspects of the human rights vetting process. We also analyzed DOD’s 2014 implementation guidance for the DOD Leahy law. In addition, we assessed Embassy Cairo’s 2014 Guide for Leahy Law Human Rights Vetting, which establishes the embassy’s standard operating procedures for complying with the Leahy laws. To gather additional information on human rights vetting in Egypt, we conducted interviews with State officials from the Bureau of Democracy, Human Rights, and Labor (DRL) and the Bureau of Near Eastern Affairs (NEA) who are responsible for conducting or overseeing human rights vetting in Washington, D.C. DRL officials also provided us a demonstration of the INVEST system. At Embassy Cairo, we interviewed State officials from the Political Section who oversee human rights vetting at the post. To gather further information on the human rights vetting process at Embassy Cairo, we interviewed State officials from the International Narcotics and Law Enforcement Section and the Regional Security Office, DOD officials from OMC-E, Department of Homeland Security officials from Immigration and Customs Enforcement and U.S. Customs and Border Protection, and Department of Justice officials from the Federal Bureau of Investigation and the Drug Enforcement Administration. These officials were responsible for vetting Egyptian security officials for training, for sponsoring training that required Egyptian participants to be vetted, or for both. During our fieldwork in Egypt, we also requested to meet with officials of several Egyptian government ministries to obtain their perspective on the Leahy laws and U.S. government human rights vetting efforts; however, according to an Embassy Cairo official, the Egyptian government did not respond to our request. The Egyptian government initially approved our request to meet with officials of the Egyptian Training Authority to discuss human rights vetting for Egyptian military students; however, the Egyptian Training Authority later declined to participate in the meeting. We also analyzed State data on human rights vetting results in Egypt from the INVEST system for fiscal year 2011 through March 31, 2015, to determine the extent to which State approved, rejected, suspended, or cancelled vetting cases for Egyptian officials nominated for U.S.-funded training. To assess the reliability of the INVEST data, we reviewed documentation on the INVEST system and conducted interviews with State officials knowledgeable of the system. We determined that the INVEST data State provided were sufficiently reliable for the purposes of this report. To assess the extent to which the U.S. government conducted required vetting of Egyptian security officials before they received U.S.-funded training, we collected rosters of Egyptian security forces that received U.S.-funded training from State and DOD in fiscal year 2011 through March 31, 2015. In total, we received rosters for training funded through seven appropriations accounts. These seven accounts included four State accounts—FMF, IMET, INCLE, and Peacekeeping Operations— and three DOD accounts—the Countering Terrorism Fellowship Program, the DOD Regional Centers, and Joint Combined Exchange Training. Using these training rosters, we developed a generalizable random sample of 166 names from a population of 3,743 Egyptian security forces that received training funded through these seven accounts during this period. The sample included names from the roster for each of the seven accounts. We then cross-checked the names in our sample with human rights vetting data from the INVEST system to verify that the Egyptian security forces were vetted before receiving the training. In addition to receiving rosters for training funded through the seven accounts, we also requested training rosters from State on Egyptian security forces that had received training funded through the NADR account. However, State told us that it was unable to provide this information. As a result, we were not able to include the NADR account in our sample and we were not able to assess the extent to which State had completed required human rights vetting for Egyptian security forces that received training funded through this account. To gather additional information on how State ensures compliance with the Leahy laws for equipment that it provided to Egyptian security forces, we also reviewed eight State apportionment memos covering all FMF assistance for Egypt in fiscal years 2011 through 2015. We assessed the extent to which each of these memos addressed Leahy vetting compliance in Egypt. Finally, we assessed State’s actions to ensure compliance with the Leahy laws against standards in its Foreign Affairs Manual related to creating records and management controls. We also assessed State’s actions against established internal control standards in the federal government and against standards established by the Project Management Institute. We conducted this performance audit from February 2015 to April 2016 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. DOD’s Defense Security Cooperation Agency administers the Golden Sentry program to monitor the end use of defense articles and defense services transferred through Foreign Military Sales. Under this program, DOD implements two levels of end-use monitoring—enhanced and routine—and conducts periodic Compliance Assessment Visits. DOD requires enhanced end-use monitoring for sensitive defense articles, services, or technologies specifically designated by the military departments’ export policy, the interagency release process, or by DOD policy as a result of consultation with Congress. DOD requires routine end-use monitoring for all defense articles and services provided through government-to-government programs. Routine end-use monitoring is conducted in conjunction with other security cooperation functions and uses any readily available source of information. State’s Directorate of Defense Trade Controls administers the Blue Lantern program to monitor the end use of defense articles and services exported through direct commercial sales. Under its Blue Lantern program, State is required to conduct end-use monitoring checks based on a case-by-case review of export license applications against established criteria for determining potential risks. To determine whether to conduct a Blue Lantern check, State considers 20 indicators that may trigger a check, such as unfamiliar end users, foreign intermediate consignees with no apparent connection to the end user, and requests for sensitive commodities whose diversion or illicit retransfer could have a negative impact on U.S. national security. Table 10 provides an overview of the Golden Sentry and Blue Lantern end-use monitoring programs. Department of State Leahy law No assistance shall be furnished under the Foreign Assistance Act of 1961 or the Arms Export Control Act to any unit of the security forces of a foreign country if the Secretary of State has credible information that such unit has committed a gross violation of human rights. Department of Defense Leahy law Of the amounts made available to the Department of Defense, none may be used for any training, equipment, or other assistance for a unit of a foreign security force if the Secretary of Defense has credible information that the unit has committed a gross violation of human rights. The Secretary of Defense shall, in consultation with the Secretary of State, ensure that prior to a decision to provide any training, equipment, or other assistance to a unit of a foreign security force full consideration is given to any credible information available to the Department of State relating to human rights violations by such unit. Prohibition does not apply if the Secretary of State determines and reports to specified congressional committees that “the government of such country is taking effective steps to bring the responsible members of the security forces unit to justice.” Prohibition does not apply if the Secretary of Defense, after consultation with the Secretary of State, determines that the government of such country has taken all necessary corrective steps, or if the equipment or other assistance is necessary to assist in disaster relief operations or other humanitarian or national security emergencies. Not later than 15 days after the use of the exception, the Secretary of Defense shall submit to the appropriate congressional committees a report providing notice of the use of the exception and stating the grounds for the exception. The Secretary of Defense, after consultation with the Secretary of State, may waive the prohibition if he determines that such a waiver is required by extraordinary circumstances. Not later than 15 days after the exercise of any waiver, the Secretary of Defense shall submit a report to the appropriate congressional committees describing the information related to the gross violation of human rights; the extraordinary circumstances that necessitate the waiver; the purpose and duration of the training, equipment, or other assistance; and the U.S. forces and the foreign security force unit involved. In the event that funds are withheld from any unit pursuant to the law, the Secretary of State shall promptly inform the foreign government of the basis for such action and shall, to the maximum extent practicable, assist the foreign government in taking effective measures to bring the responsible members of the security forces to justice. Department of Defense Leahy law The Secretary of Defense shall establish, and periodically update, procedures to ensure that any information in the possession of the Department of Defense about gross violations of human rights by units of foreign security forces is shared on a timely basis with the Department of State. ensure that for each country the Department of State has a current list of all security force units receiving U.S. training, equipment, or other types of assistance; facilitate receipt by the Department of State and U.S. embassies of information from individuals and organizations outside the U.S. government on gross violations of human rights by security force units; routinely request and obtain such information from the Department of Defense, the Central Intelligence Agency, and other U.S. government sources; ensure that such information is evaluated and preserved; ensure that when an individual is designated to receive United States training, equipment, or other types of assistance the individual’s unit is vetted as well as the individual; seek to identify the unit involved when credible information of a gross violation exists but the identity of the unit is lacking; and make publicly available, to the maximum extent practicable, the identity of those units for which no assistance shall be furnished pursuant to the law. The Secretary of Defense shall submit a report to congressional appropriations committees not later than March 31, 2015, and annually thereafter through 2024, providing information on the total number of cases submitted for vetting, and the total number of such cases approved, suspended, or rejected for human rights reasons, non-human rights reasons, or administrative reasons; in the case of units rejected for non-human rights reasons, a detailed description of the reasons relating to the rejection; a description of the interagency processes used to evaluate compliance with vetting requirements; and any comments from commanders of the combatant commands about how the Department of Defense Leahy law affects their theater security cooperation plans, among other things. Table 11 provides a summary of the status of all bilateral security-related assistance allocated for Egypt in fiscal years 2011 through 2015, as of September 30, 2015. The U.S. government provides bilateral security-related assistance to Egypt through a number of accounts, including the Foreign Military Financing; International Narcotics Control and Law Enforcement; International Military Education and Training; and Nonproliferation, Anti- terrorism, Demining, and Related Programs accounts. Tables 12 through 15 provide information on the status of funds allocated for assistance for Egypt from these accounts for fiscal years 2011 through 2015, as of the end of fiscal year 2015. In addition to the contact named above, Jeff Phillips (Assistant Director), Drew Lindsey (Analyst-in-Charge), Ryan Vaughan, Rachel Dunsmoor, Ashley Alley, Tina Cheng, David Dayton, Justin Fisher, Jeff Isaacs, and Oziel Trevino made key contributions to this report.

Summary: The U.S. government has allocated an average of about $1.3 billion annually in security assistance for Egypt in fiscal years 2011 through 2015. DOD and State have established end-use monitoring programs to ensure that military equipment transferred to foreign countries is safeguarded and used for its intended purposes. In addition, legal requirements, known as the Leahy laws, prohibit DOD- and State-funded assistance to units of foreign security forces if there is credible information that these forces have committed a gross violation of human rights. This report examines, for fiscal years 2011 through 2015, the extent to which the U.S. government (1) committed or disbursed funds allocated for security-related assistance for Egypt, (2) implemented end-use monitoring for equipment transferred to Egyptian security forces, and (3) vetted Egyptian recipients of security-related assistance for human rights concerns. GAO analyzed U.S. agency data and documentation; conducted fieldwork in Egypt; and interviewed U.S. officials in Washington, D.C., and Cairo, Egypt. This is the public version of a sensitive but unclassified report issued in February 2016. U.S. agencies allocated approximately $6.5 billion for security-related assistance to Egypt in fiscal years 2011 through 2015. As of September 30, 2015, over $6.4 billion of the $6.5 billion total had been committed or disbursed. The majority of the funding (99.5 percent) was provided to Egypt through the Department of State's (State) Foreign Military Financing (FMF) account. The funds from this account were used to purchase and sustain a wide variety of military systems, including F-16 aircraft, Apache helicopters, and M1A1 tanks. The Departments of Defense (DOD) and State implemented end-use monitoring for equipment transferred to Egyptian security forces, but challenges including obtaining Egyptian government cooperation hindered some efforts. DOD completed all required end-use monitoring inventories and physical security inspections of storage sites for missiles and night vision devices (NVD) in fiscal year 2015, but DOD lacked documentation showing that it completed physical security inspections for these sensitive items in prior years. Despite agreeing to give access, the Egyptian government prevented DOD officials from accessing a storage site to verify the physical security of some NVDs prior to 2015, according to DOD officials and documents. State conducted 12 end-use checks of U.S. equipment exported to Egypt in fiscal years 2011 to 2015, but State data indicate that the Egyptian government's incomplete and slow responses to some inquiries limited U.S. efforts to verify the use and security of certain equipment, including NVDs and riot-control items. Despite this lack of cooperation, since 2008, State has not used outreach programs in Egypt that are intended to facilitate host country cooperation and compliance with State's monitoring program. According to State officials, this was due to the small number of end-use checks conducted in Egypt and the lower priority assigned to Egypt than to other countries. The U.S. government completed some, but not all, human rights vetting required by State policy before providing training or equipment to Egyptian security forces. State deemed GAO's estimate of the percentage of Egyptian security forces that were not vetted to be sensitive but unclassified information, which is excluded from this public report. Moreover, State has not established specific policies and procedures for vetting Egyptian security forces receiving equipment. Although State concurred with a 2011 GAO recommendation to implement equipment vetting, it has not established a time frame for such action. State currently attests in memos that it is in compliance with the Leahy law. However, without vetting policies and procedures, the U.S. government risks providing U.S. equipment to recipients in Egypt in violation of the Leahy laws. GAO is making six recommendations to strengthen State's implementation of end-use monitoring and human rights vetting, including utilizing its end-use monitoring outreach programs and developing time frames for establishing policies and procedures for equipment vetting. State generally agreed with these recommendations.