Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement Page: 33 of 46
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Appendix I: Scope and Methodology
Under the authority of the Comptroller General of the United States, we
initiated a review to identify what efforts, if any, are under way to ensure
that U.S. contracting funds or resources are not diverted to support
corruption or insurgent organizations. Specifically, we examined (1) the
extent to which the Department of Defense (DOD) has established a
process to vet non-U.S. vendors in Afghanistan, both to ensure that
resources are not used to support insurgent or criminal groups and to
safeguard U.S. personnel and assets against security risks; (2) the extent to
which the Department of State (State) and the United States Agency for
International Development (USAID) have established processes to vet
non-U.S. vendors and other assistance recipients in Afghanistan; and
(3) the extent to which vetting information is shared among DOD, State,
As the use of host nation and regional contractors is expected to increase
through the use of various agreements, such as Afghan First, in which the
United States and NATO have demonstrated a commitment to obtain
products and services locally, we focused our review on non-U.S.
contractors and nongovernmental organizations, as well as based on
congressional interest. Further, legal protections, policy considerations,
and business practices in the United States could constrain the U.S.
Government from investigating U.S. citizens, so vetting of U.S. contractors
would be more constrained.
To identify and examine the efforts DOD has taken to vet non-U.S vendors
in Afghanistan and the extent to which State and USAID have established
processes to vet non-U.S. vendors in Afghanistan and to share this vetting
information, we reviewed recent DOD, State, and USAID policies and
procedures, including fragmentary orders; the recently updated November
2010 U.S. Central Command (CENTCOM) Contracting Command's
Acquisition Instruction as well as a previous version USAID's Mission
Order for Afghanistan 201.03; and an April 2010 memorandum of
understanding between DOD, State, and USAID relating to contracting in
Iraq and Afghanistan. Additionally, we reviewed the DOD contract that
establishes a vendor vetting cell in support of U.S. forces in Afghanistan
1 While the term vetting can be used to describe any sort of background screening or fact
checking of companies, individuals, or information, for purposes of this review, vetting is
used to describe the examination of available background and intelligence information to
determine whether prospective vendors or assistance recipients are affiliated with
insurgent or criminal groups, or appear to pose a significant risk of diverting funds or
security information to terrorist, criminal, or other corrupt organizations.
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United States. Government Accountability Office. Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement, report, June 8, 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc295959/m1/33/: accessed June 5, 2020), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.