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Testimony:

Before the Permanent Subcommittee on Investigations, Committee on 
Homeland Security and Governmental Affairs, U.S. Senate:

United States Government Accountability Office:

GAO:

For Release on Delivery Expected at 9:30 a.m. EST:

Tuesday, February 15, 2005:

UNITED NATIONS:

Oil for Food Program Audits:

Statement of Joseph A. Christoff, Director, International Affairs and 
Trade:

GAO-05-346T:

GAO Highlights:

Highlights of GAO-05-346T, a testimony before the Permanent 
Subcommittee on Investigations, Committee on Homeland Security and 
Governmental Affairs, U.S. Senate.

Why GAO Did This Study:

The Oil for Food program was established by the United Nations and Iraq 
in 1996 to address concerns about the humanitarian situation after 
international sanctions were imposed in 1990. The program allowed the 
Iraqi government to use the proceeds of its oil sales to pay for food, 
medicine, and infrastructure maintenance.

Allegations of fraud and corruption have plagued the Oil for Food 
program. As we have testified and others have reported, the former 
regime gained illicit revenues through smuggling and through illegal 
surcharges and commissions on Oil for Food contracts. The United 
Nations’ Independent Inquiry Committee was established in April 2004 to 
investigate allegations of corruption and misconduct within the Oil for 
Food program and its overall management of the humanitarian program. In 
January 2005, the Committee publicly released 58 internal audit reports 
conducted by the United Nations’ Office of Internal Oversight Services 
(OIOS). 

GAO (1) provides information on OIOS’ background, structure, and 
resources; (2) highlights the findings of the internal audit reports; 
and (3) discusses limitations on the audits’ coverage. 

What GAO Found:

Before the United Nations established OIOS, the United States and other 
member states had criticized its lack of internal oversight mechanisms. 
In 1993, the United States proposed the establishment of an inspector 
general position within the United Nations and withheld U.S. funds 
until such an office was established. In 1994, the General Assembly 
created OIOS and tasked it with conducting audits, investigations, 
inspections, and evaluations of U.N. programs and funds. OIOS has 
generally provided audit reports to the head of the U.N. agency or 
program subject to the audit but also provided certain reports of 
interest to the General Assembly. However, this limited distribution 
hampered member states’ efforts to oversee important U.N. programs. In 
December 2004, the General Assembly directed OIOS to publish the titles 
and summaries of all audit reports and provide member states with 
access to these reports on request.	

The audit reports released in January 2005 found deficiencies in the 
management of the Oil for Food program and made numerous 
recommendations. We identified 702 findings in these reports. Most 
reports focused on U.N. activities in northern Iraq, the operations of 
the U.N. Compensation Commission, and the implementation of U.N. 
inspection contracts. In the north, OIOS audits found problems with 
coordination, planning, procurement, asset management, and cash 
management. For example, U.N. agencies had purchased diesel generators 
in an area where diesel fuel was not readily available and constructed 
a health facility subject to frequent flooding. An audit of U.N.-
Habitat found $1.6 million in excess construction material on hand 
after most projects were complete. OIOS audits of the U.N. Compensation 
Commission found poor internal controls and recommended downward 
adjustments totaling more than $500 million. The United Nations 
asserted that OIOS had limited audit authority over the Commission. 
Finally, OIOS audits of the contractors inspecting Iraq’s oil exports 
and commodity imports found procurement irregularities and limited U.N. 
oversight.

OIOS’ audits and summary reports revealed deficiencies in the 
management and internal controls of the Oil for Food program. However, 
OIOS did not examine certain headquarters functions—particularly OIP’s 
oversight of the contracts for central and southern Iraq that accounted 
for 59 percent or almost $40 billion in Oil for Food proceeds. The 
Independent Inquiry Committee noted several factors that limited OIOS’ 
scope and authority. First, OIOS did not believe it had purview over 
the humanitarian contracts because the sanctions committee approved the 
contracts. Second, the U.N. Office of the Iraq Program steered OIOS 
toward programs in the field rather than at headquarters. Third, the 
Office of the Iraq Program refused to fund an OIOS risk assessment of 
its program management division. Finally, U.N. management and the 
Office of the Iraq Program prevented OIOS from reporting its audit 
results directly to the Security Council.

www.gao.gov/cgi-bin/getrpt?GAO-05-346T.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Joseph Christoff at (202) 
512-8979 or christoffj@gao.gov.

[End of section]

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss our review of the internal 
audit reports of the United Nations (U.N.) Oil for Food program.

Allegations of fraud and corruption have plagued the Oil for Food 
program. As we have testified and others have reported, the former 
regime gained illicit revenues through smuggling oil and obtaining 
illegal surcharges and commissions on Oil for Food contracts. The 
United Nations' Independent Inquiry Committee was established in April 
2004 to investigate allegations of mismanagement and misconduct within 
the Oil for Food program. In January 2005, the Committee released 58 
internal audit reports on the Oil for Food program conducted by the 
United Nations' Office of Internal Oversight Services (OIOS). On 
February 3, 2005, the Committee issued an interim report on the 
procurement of U.N. contractors, recipients of oil allocations, OIOS 
structure and activities, and U.N. management of Oil for Food 
administrative expenses.[Footnote 1]

Today, I will (1) provide information on OIOS' background, structure, 
and resources; (2) highlight the findings of the internal audit 
reports; and (3) discuss limitations on the audits' coverage.

To address these objectives, we analyzed the internal audit reports to 
determine the reports' audit coverage, findings, recommendations, 
disposition of recommendations, and potential cost savings. We 
catalogued the findings to determine common themes related to the 
management of the Oil for Food program. We also reviewed the February 
2005 Independent Inquiry Committee report. Appendix I contains an 
explanation of our scope and methodology.

We conducted this review in January and February 2005 in accordance 
with generally accepted government auditing standards.

Summary:

Before the United Nations established OIOS, the United States and other 
member states had criticized its lack of internal oversight mechanisms. 
In 1993, the United States proposed the establishment of an inspector 
general position within the United Nations and withheld U.S. funds 
until such an office was established. In 1994, the General Assembly 
created OIOS and tasked it with conducting audits, investigations, 
inspections, and evaluations of U.N. programs and funds. OIOS has 
generally provided audit reports to the head of the U.N. agency or 
program subject to the audit. OIOS also provided certain reports of 
interest to the General Assembly. However, this limited distribution 
hampered member states' efforts to oversee important U.N. programs. In 
December 2004, the General Assembly directed OIOS to publish the titles 
and summaries of all audit reports and provide member states with 
access to these reports on request.

The audit reports released in January 2005 found deficiencies in the 
management of the Oil for Food program and made numerous 
recommendations to correct these deficiencies. We identified 702 
findings contained in the reports. Most reports focused on U.N. 
activities in northern Iraq, the operations of the U.N. Compensation 
Commission, and the implementation of U.N. inspection contracts. In the 
north, OIOS audits found problems with coordination, planning, 
procurement, asset management, and cash management. For example, U.N. 
agencies had purchased diesel generators in an area where diesel fuel 
was not readily available and constructed a health facility subject to 
frequent flooding. An audit of U.N.-Habitat found $1.6 million in 
excess construction material on hand after most projects were complete. 
OIOS audits of the U.N. Compensation Commission found poor internal 
controls to prevent employee fraud, collusion, and illegal activities. 
In its 2004 assessment of claims for war damages, OIOS recommended 
downward adjustments totaling more than $500 million. The U.N.'s Office 
of Legal Affairs stated that OIOS' audit authority did not extend to 
reviewing the Commission's decisions. Finally, OIOS audits of the 
contractors inspecting Iraq's oil exports and commodity imports found 
procurement irregularities and limited U.N. oversight.

OIOS' audits and summary reports revealed deficiencies in the 
management and internal controls of the Oil for Food program. However, 
OIOS did not examine certain headquarters functions--particularly the 
Office of the Iraq Program's oversight of the contracts for central and 
southern Iraq that accounted for 59 percent or almost $40 billion in 
Oil for Food proceeds. The Independent Inquiry Committee noted several 
factors that limited OIOS' scope and authority. First, OIOS did not 
believe it had purview over the humanitarian contracts because the 
sanctions committee approved the contracts. Second, the U.N. Office of 
the Iraq Program steered OIOS toward programs in the field rather than 
at headquarters. Third, the Office of the Iraq Program refused to fund 
an OIOS risk assessment of its program management division. Finally, 
U.N. management and the Office of the Iraq Program prevented the 
internal auditors from reporting their audit results directly to the 
Security Council.

Background:

In 1996, the United Nations and Iraq established the Oil for Food 
program to address growing concerns about the humanitarian situation in 
Iraq after international sanctions were imposed in 1990. The program's 
intent was to allow the Iraqi government to use the proceeds of its oil 
sales to pay for food, medicine, and infrastructure maintenance, and at 
the same time prevent the regime from obtaining goods for military 
purposes. From 1997 through 2002, Iraq sold more than $67 billion in 
oil through the program and issued $38 billion in letters of credit to 
purchase commodities.

The Oil for Food program initially permitted Iraq to sell up to $1 
billion worth of oil every 90 days to pay for humanitarian goods. 
Subsequent U.N. resolutions increased the amount of oil that could be 
sold and expanded the humanitarian goods that could be imported. In 
1999, the Security Council removed all restrictions on the amount of 
oil Iraq could sell to purchase civilian goods. The United Nations and 
the Security Council monitored and screened contracts that the Iraqi 
government signed with commodity suppliers and oil purchasers, and 
Iraq's oil revenue was placed in a U.N.-controlled escrow account. In 
May 2003, U.N. resolution 1483 requested the U.N. Secretary General to 
transfer the Oil for Food program to the Coalition Provisional 
Authority by November 2003. The United Nations allocated 59 percent of 
the oil revenue for the 15 central and southern governorates, which 
were controlled by the central government; 13 percent for the 3 
northern Kurdish governorates; 25 percent for a war reparations fund 
for victims of the Iraq invasion of Kuwait in 1990; and 3 percent for 
U.N. administrative costs, including the costs of weapons inspectors.

In central and southern Iraq, the Iraqi government used the proceeds 
from its oil sales to purchase food, medicines, and infrastructure 
supplies and equipment. The Iraqi government negotiated directly with 
suppliers and distributed food in accordance with its Public 
Distribution System, a food ration basket for all Iraqis. In northern 
Iraq, nine U.N. agencies implemented the program, primarily through 
constructing or rehabilitating schools, health clinics, power 
generation facilities, and houses.[Footnote 2] Local authorities 
submitted project proposals to the United Nations to consider and 
implement. The Iraqi government in Baghdad procured bulk food and 
medicines for the northern region, but the World Food Program and the 
World Health Organization were responsible for ensuring the delivery of 
these items.

From 1997 to 2002, the Oil for Food program was responsible for more 
than $67 billion of Iraq's oil revenue. Through a large portion of this 
revenue, the United Nations provided food, medicine, and services to 24 
million people and helped the Iraqi government supply goods to 24 
economic sectors. In February 2002, the United Nations reported that 
the Oil for Food program had considerable success in sectors such as 
agriculture, food, health, and nutrition by arresting the decline in 
living conditions and improving the nutritional status of the average 
Iraqi citizen.

OIOS History, Organization, and Resources:

Prior to the creation of OIOS, the United States and other member 
states had expressed concern about the ability of the United Nations to 
conduct internal oversight. In 1994, the General Assembly established 
OIOS to conduct audits, evaluations, inspections, and investigations of 
U.N. programs and funds. Its mandate reflects many characteristics of 
U.S. inspector general offices in purpose, authority, and budget. Since 
its inception, OIOS has submitted its audit reports to the head of the 
unit being audited for action and only forwarded to the Secretary 
General those reports in which program officials disagreed with audit 
recommendations. It also provided certain reports to the General 
Assembly. However, in December 2004, the General Assembly passed a 
resolution requiring OIOS to publish the titles and summaries of all 
audit reports and provide member states with access to these reports on 
request.

Events Leading to the Creation of OIOS:

Before the OIOS was created in July 1994, the United States and other 
U.N. member states, the U.S. Congress, and the Government 
Accountability Office (GAO) had expressed concern about the United 
Nations' management of its resources and had criticized the 
inadequacies of its internal oversight mechanisms. In response, the 
Secretary General established the Office for Inspections and 
Investigations in August 1993 under the leadership of an Assistant 
Secretary General. However, member states--primarily the United States-
-wanted a more autonomous oversight body with greater authority.

In November 1993, the U.S. Permanent Representative to the United 
Nations proposed the establishment of an "office of inspector general" 
to the General Assembly. The office would be headed by an "inspector 
general" who, although an integral part of the Secretariat, would carry 
out his/her responsibilities independently of the Secretariat and all 
U.N. governing bodies. According to the proposal, the office would 
support member states and the Secretary General by providing 
independent advice based on an examination of all activities carried 
out at all U.N. headquarters and field locations financed by the 
regular budget, peacekeeping budgets, and voluntary contributions. At 
the same time, the new office would have external reporting 
responsibilities.

In April 1994, Congress enacted Public Law 103-236, which required 
certain funds to be withheld from the United Nations until the 
President certified that it had established an independent office of 
inspector general to conduct and supervise objective audits, 
investigations, and inspections. The legislation stated, among other 
things, that the inspector general should have access to all records, 
documents, and offices related to U.N. programs and operations. The 
legislation also called for the United Nations to have procedures to 
(1) ensure compliance with the inspector general office's 
recommendations and (2) protect the identity of, and prevent reprisals 
against, any staff members making a complaint, disclosing information, 
or cooperating in any investigation or inspection by the inspector 
general's office.

After a series of negotiations among member states, including the 
United States, a compromise was reached. The General Assembly, in July 
1994, approved a resolution creating OIOS within the U.N. Secretariat. 
OIOS' mandate reflects many of the characteristics of U.S. inspector 
general offices in purpose, authority, and budget. For example, OIOS 
staff have access to all records, documents, or other material assets 
necessary to fulfill their responsibilities.

OIOS' reporting mandate calls for it to submit reports to the Secretary 
General and the General Assembly. Since its inception, OIOS has 
generally submitted its reports to the head of the unit audited. If 
program officials disagreed with the report's recommendations, the 
report was submitted to the Secretary General. However, beginning in 
1997, OIOS began listing all its reports in its annual reports to the 
General Assembly and briefing representatives of member states 
interested in a particular report. It also provided certain reports of 
interest to the General Assembly. Further transparency over OIOS audit 
reports occurred in December 2004 when the General Assembly approved a 
resolution calling for OIOS to include in its annual and semi-annual 
reports the titles and brief summaries of all OIOS reports issued 
during the reporting period. OIOS was also directed to provide member 
states with access to original versions of OIOS reports upon 
request.[Footnote 3]

OIOS Organization and Staffing:

As of June 2004, OIOS had 180 posts, including 124 professional staff 
and 56 general service staff. Staff work in four operational divisions: 
Internal Audit Divisions I and II; the Monitoring, Evaluation, and 
Consulting Division; and the Investigations Division. The 58 audit 
reports released on January 9, 2005, reflect the work of Internal Audit 
Division I, which contained a separate unit for Iraq-related work. For 
2004, OIOS' resources totaled $23.5 million.

OIOS generally conducts four types of activities: audits, evaluations, 
inspections, and investigations. Audits determine if internal controls 
provide reasonable assurance of the integrity of financial and 
operational information and whether rules are followed and resources 
are safeguarded. Audits also identify ways to improve the efficient use 
of resources and the effectiveness of program management. OIOS' 
internal audit divisions adhere to the Standards for the Professional 
Practice of Internal Auditing in the United Nations.[Footnote 4] These 
standards regulate issues related to independence, objectivity, 
proficiency, management, and the code of ethics and rules of conduct 
for auditors.

Inspections address mandates, management issues, or areas of high risk, 
make recommendations, and are generally submitted through the Secretary 
General to the General Assembly. Evaluations assess the relevance, 
efficiency, effectiveness, and impact of a program's outputs and 
activities against its objectives. These reports are addressed to the 
intergovernmental body--normally the Committee for Program and 
Coordination or the General Assembly--that requested the evaluation.

Investigations staff follow up on reports of possible violations of 
rules or regulations, mismanagement, misconduct, waste of resources, or 
abuses of authority. OIOS also monitors program performance and 
prepares the Program Performance Report of the Secretary General, which 
is submitted to the General Assembly every 2 years.

The complexity and diversity of the U.N. Oil for Food program and 
associated risks called for adequate oversight coverage. In 2000, OIOS 
established the Iraq Program Audit Section within the Internal Audit 
Division. The Independent Inquiry Committee report stated that the 
number of auditors assigned to Oil for Food audits increased from 2 in 
1996 to 6 in 2002 and 2003. OIOS' audit responsibilities extended to 
the following entities involved in Iraq operations:

* Office of the Iraq Program (OIP) in New York;

* U.N. Office of the Humanitarian Coordinator in Iraq;

* U.N. Compensation Commission (UNCC);

* U.N. Monitoring, Verification, and Inspection Commission;

* U.N. Human Settlement Program (U.N.-Habitat) Settlement 
Rehabilitation Program in northern Iraq;[Footnote 5]

* U.N. Guards Contingent in Iraq; and:

* U.N. Department of Management.

Audits Show Recurring Management Weaknesses:

The OIOS audits revealed a number of deficiencies in the management of 
the Oil for Food program and its assets and made numerous 
recommendations to correct these deficiencies. The audits focused 
primarily on Oil for Food activities in northern Iraq and at the U.N. 
Compensation Commission. OIOS also conducted audits of the three U.N. 
contracts for inspecting commodities coming into Iraq and for 
independent experts to monitor Iraq's oil exports.[Footnote 6]

We identified a total of 702 findings contained in the reports across 
numerous programs and sectors. Weaknesses and irregularities were 
common in planning and coordination, procurement, and asset and cash 
management. Appendix I contains the summary data of our analysis and a 
description of our scope and methodology. Our summary below focuses on 
key findings for the areas that received the most audit coverage--
activities in northern Iraq and the U.N. Compensation Commission. We 
also highlight findings from the audits of the inspections contracts.

U.N. Oil for Food Program in Northern Iraq:

The OIOS audits that reviewed U.N. activities in northern Iraq found 
problems with planning and coordination, procurement, and asset and 
cash management.

In 2004, OIOS reported that U.N.-Habitat had not adequately coordinated 
with other U.N. agencies in providing essential services for its 
housing projects. For example, U.N.-Habitat provided high-capacity 
generators but had not contacted the U.N. Development Program--the 
entity responsible for the power sector--to provide electric power 
connections. OIOS also found that about 3,200 houses were unoccupied 
for extended periods due to a lack of coordination with agencies 
providing complementary services.

An August 2000 report noted a lack of planning that resulted in the 
questionable viability of some Oil for Food projects in northern Iraq. 
For example, six diesel generators were procured in an area where 
diesel fuel was not readily available. In addition, local authorities 
would not accept a newly constructed health facility subject to 
flooding. A December 2000 report also noted that highways and a sports 
stadium were built in violation of criteria established by the Security 
Council and the Iraqi government.

In November 2002, OIOS reported that almost $38 million in procurement 
of equipment for the U.N.-Habitat program was not based on a needs 
assessment. As a result, 51 generators went unused from September 2000 
to March 2002, and 12 generators meant for project-related activities 
were converted to office use. In addition, OIOS reported that 11 
purchase orders totaling almost $14 million showed no documentary 
evidence supporting the requisitions.

In 2002, OIOS found that the U.N-Habitat program lacked a proper asset 
inventory system and that no policies and procedures governing asset 
management were evident. As a result, the value of assets was not 
readily available. In one case, $1.6 million in excess construction 
material remained after most projects were complete.

OIOS also reported that a lack of effective cash management policies 
meant that project funds were misused or put at risk. In a March 2000 
audit, OIOS reported that the U.N. Development Program's country office 
used $500,000 in project funds for office expenses without 
authorization or proper documentation. A February 2002 audit found that 
the office in Erbil put at risk $600,000 to $800,000 in cash due to a 
lack of cash management policies.

U.N. Compensation Commission:

The U.N. Compensation Commission (UNCC), a subsidiary unit of the 
Security Council, was established in 1991 to process claims and provide 
compensation for losses resulting from Iraq's invasion and occupation 
of Kuwait. Compensation is payable from a special fund that initially 
received 30 percent of the proceeds from Iraqi oil sales. The claims 
are resolved by panels, each of which is made up of three commissioners 
who are experts in law, accounting, loss adjustment, assessment of 
environmental damage, and engineering, according to UNCC.

The UNCC received more than 2.6 million claims for death, injury, loss 
of or damage to property, commercial claims, and claims for 
environmental damage resulting from Iraq's invasion of Kuwait in 1991. 
As of December 2004, all but about 25,000 of these claims had been 
resolved, and almost $19 billion had been paid in compensation, 
according to UNCC.

In a July 2002 risk assessment of UNCC, OIOS found that controls to 
prevent employee fraud were marginal, operations required close 
monitoring to prevent possible collusion, possibilities existed for 
illegal activities, and payment processing controls were inadequate. 
The report concluded that the overcompensation of claims and irregular 
or fraudulent activities could lead to significant financial risks.

OIOS audits identified weaknesses in UNCC's management of claims 
processing and payments resulting in recommended downward adjustments 
of more than $500 million. For example, in a September 2002 audit, OIOS 
found potential overpayments of $419 million in compensation awarded to 
Kuwait. OIOS identified duplicate payments, calculation errors, 
insufficient evidence to support losses, and inconsistent application 
of claims methodology.

In a December 2004 audit, OIOS found that using the exchange rate 
against the U.S. dollar on the date of the claimed loss, rather than 
the date of payment as consistent with U.N. financial rules and 
regulations, had resulted in substantial overpayments. OIOS estimated 
that the likely overpayments were about $510 million.

Previously in 2002, UNCC had challenged OIOS' audit authority. In a 
legal opinion on OIOS' authority requested by UNCC, the U.N. Office of 
Legal Affairs noted that the audit authority extended to computing the 
amounts of compensation but did not extend to reviewing those aspects 
of the panels' work that constitute a legal process. However, OIOS 
disputed the legal opinion, noting that its mandate was to review and 
appraise the use of financial resources of the United Nations. OIOS 
believed that the opinion would effectively restrict any meaningful 
audit of the claims process.

As a result of the legal opinion, UNCC did not respond to many OIOS 
observations and recommendations, considering them beyond the scope of 
an audit. According to OIOS, UNCC accepted about $3.3 million of the 
more than $500 million in recommended claims reductions. On the audit 
of $419 million in potential overpayments to Kuwait, OIOS noted that it 
received the workpapers to conduct the audit 8 days after the award was 
made.

Contracts to Inspect Oil Exports and Commodity Deliveries:

To help ensure that the proceeds of Iraq's oil sales were used for 
humanitarian and administrative purposes, the United Nations contracted 
with companies to monitor Iraq's oil exports and commodity imports. 
OIOS audits of these contracts revealed procurement problems and poor 
contract management and oversight by OIP.

The United Nations contracted with Saybolt Eastern Hemisphere B.V. to 
oversee the export of oil and oil products from Iraq through approved 
export points. At the time of the audit report in July 2002, the 
estimated total value of the contract was $21.3 million, with an annual 
contract value of $5.3 million. OIOS found that OIP had made no 
inspection visits to Iraq and posted no contract management staff in 
Iraq. However, OIP had certified that Saybolt's compliance with the 
contract was satisfactory and approved extensions to the contract. In 
addition, OIOS estimated that the United Nations paid $1 million more 
than was necessary because equipment costs were already built into the 
inspectors' daily fee structure. OIOS asserted that these costs should 
have been charged as a one-time expenditure. OIOS recommended that OIP 
recover the $1 million paid for equipment and that future contracts 
provide for equipment purchases as one-time expenditures. OIP did not 
respond to the auditors' first recommendation and did not agree with 
the second recommendation.

The first contract for inspecting imported commodities was with Lloyds' 
Register Inspection Ltd; the initial 6-month contract was for $4.5 
million, and the total value of the contract increased to more than $25 
million by July 1999. Lloyds' agents were to monitor, verify, inspect, 
test, and authenticate humanitarian supplies imported into Iraq at 
three entry points.

In July 1999, OIOS found deficiencies in OIP's oversight of Lloyds' 
contract. OIP had certified Lloyd's invoices for payment without any 
on-site verification or inspection reports. OIOS reported that Lloyds' 
used suppliers' manifests to authenticate the weight of bulk cargo and 
did not independently test the quality of medicines and vaccines 
supplied. In responding to the audit's findings, OIP rejected the call 
for on-site inspections and stated that any dissatisfaction with 
Lloyds' services should come from the suppliers or their home 
countries.

OIP awarded a new contract to Cotecna Inspection S.A. Similar to 
Lloyd's, Cotecna was to verify that the description, value, quantity, 
and quality of supplies arriving in Iraq were in accordance with the 
criteria established by the sanctions committee. In April 2003, OIOS 
cited concerns about procurement issues and amendments and extensions 
to Cotecna's original $4.9 million contract. Specifically, OIOS found 
that, 4 days after the contract was signed, OIP increased Cotecna's 
contract by $356,000. The amendment included additional costs for 
communication equipment and operations that OIOS asserted were included 
in the original contract. OIP agreed to amend future contracts to 
ensure that procurement documents include all requirements, thus 
eliminating the need to amend contracts.

Various Factors Affected Audit Coverage and Effectiveness:

OIOS' audits and summary reports revealed a number of deficiencies in 
the management and internal controls of the Oil for Food program, 
particularly in northern Iraq. The reports also identified problems in 
UNCC's claims processing resulting in significant overpayments. 
However, OIOS did not examine certain headquarters functions 
responsible for overseeing the humanitarian commodity contracts for 
central and southern Iraq. Limitations on OIOS' resources and reporting 
hampered its coverage of the Oil for Food program and its effectiveness 
as an oversight tool.

OIOS did not examine certain headquarters functions--particularly OIP's 
oversight of the contracts for central and southern Iraq that accounted 
for 59 percent or almost $40 billion in Oil for Food proceeds. The 
Iraqi government used these funds to purchase goods and equipment for 
central and southern Iraq and food and medical supplies for the entire 
country. As we reported in 2004, the Iraqi government's ability to 
negotiate contracts directly with the suppliers of commodities was an 
important factor in enabling Iraq to levy illegal commissions.[Footnote 
7]

OIP was responsible for examining contracts for price and value at its 
New York headquarters. In addition, the U.N. sanctions committee 
reviewed contracts primarily to remove dual-use items that Iraq could 
use in its weapons programs. However, it remains unclear which U.N. 
entity reviewed Iraq contracts for price reasonableness.

OIOS did not assess the humanitarian contracts or OIP's roles and 
responsibilities and its relationship with the sanctions committee. 
OIOS believed that these contracts were outside its purview because the 
sanctions committee was responsible for their approval. OIP management 
also steered OIOS toward program activities in Iraq rather than 
headquarters functions where OIP reviewed the humanitarian contracts.

Even when OIOS requested funds to conduct an assessment of OIP 
operations, the funds were denied. For example, in May 2002, OIP's 
executive director did not approve a request to conduct a risk 
assessment of OIP's Program Management Division, citing financial 
reasons. The Committee also noted that the practice of allowing the 
heads of programs the right to fund internal audit activities leads to 
excluding high-risk areas from internal audit examination. The 
Committee therefore recommended that the Internal Audit Division's 
budgets and staffing levels for all activities be submitted directly to 
the General Assembly.

In addition, OIOS assigned only 2 to 6 auditors to cover the Oil for 
Food program. The Committee found that this level of staffing was low 
compared to OIOS' oversight of peacekeeping operations. In addition, 
the U.N. Board of Auditors indicated that 12 auditors were needed for 
every $1 billion in U.N. expenditures. The Committee concluded that the 
Oil for Food program should therefore have had more than 160 auditors 
at its height in 2000. However, the Committee found no instances in 
which OIOS communicated broad concerns about insufficient staff levels 
to U.N. management.

OIOS also encountered problems in its efforts to widen the distribution 
of its reporting beyond the head of the agency audited. In August 2000, 
OIOS proposed to send its reports to the Security Council. However, the 
Committee reported that the OIP director opposed this proposal, stating 
that it would compromise the division of responsibility between 
internal and external audit. In addition, the U.N. Deputy Secretary 
General denied the request and OIOS subsequently abandoned any efforts 
to report directly to the Security Council.

Conclusion:

The internal audits provide important information on the management of 
the Oil for Food program, particularly in the north, and on the 
management of the commission that compensates claims for war damages 
with proceeds from Iraq's oil sales--two areas that have received 
little public attention. The reports also broaden the findings of the 
Independent Inquiry Committee's report, particularly with respect to 
the inadequacies in the award of the oil and customs inspections 
contracts. However, many unanswered questions remain about the 
management and failings of the Oil for Food program, particularly the 
oversight roles of OIP and the Security Council's sanctions committee.

Mr. Chairman, this concludes my prepared statement. I will be happy to 
answer any questions you or the other Subcommittee members may have.

[End of section]

Appendix I: Summary of OIOS Audit Findings and Recommendations:

We reviewed the 58 reports released by the Independent Inquiry 
Committee to determine the scope of the audits and the issues addressed 
in the reports' findings and recommendations. We created a data base of 
information from 50 reports to identify the program elements that the 
audits reviewed, the findings of each audit, and the recommendations 
for improvement.[Footnote 8] To identify audit scope, we identified the 
extent to which the audits addressed Oil for Food headquarters 
operations, U.N. Secretariat Treasury operations in New York, U.N. 
operations in the northern Iraq, and the U.N. Compensation Commission 
for disbursing claims for damage caused by the 1991 Persian Gulf War. 
To determine the range of issues addressed by the audits, we identified 
the kinds of issues raised by the findings and determined that the 
audits addressed the following issues: (1) procurement and contract 
management and oversight; (2) financial management, including financial 
controls, management of funds, and procedures for payments; (3) asset 
management, including inventory, and the management of fixed assets 
such as vehicles, buildings, and supplies; (4) personnel and staffing; 
(5) project planning, coordination, and oversight; (6) security; and 
(7) information technology. We established a protocol to identify 
findings for data input, and we identified specific recommendations in 
the audit reports. To ensure consistency of data input, a data base 
manager reviewed all input, and all data input was independently 
validated. Table 1 presents the summary of overall findings and 
recommendations in OIOS reports. Table 2 presents these findings by 
area of U.N. operation.

Table 1: Number of Findings and Recommendations in 50 U.N. OIOS Reports 
by Finding Subject:

Finding subject: Asset management; 
Findings: 34; 
Recommendations: 32.

Finding subject: Financial management; 
Findings: 226; 
Recommendations: 212.

Finding subject: Information technology; 
Findings: 26; 
Recommendations: 22.

Finding subject: Planning, coordination, and oversight; 
Findings: 66; 
Recommendations: 63.

Finding subject: Procurement/contract management and oversight; 
Findings: 219; 
Recommendations: 212.

Finding subject: Personnel and staffing; 
Findings: 79; 
Recommendations: 74.

Finding subject: Security; 
Findings: 52; 
Recommendations: 52.

Finding subject: Total; 
Findings: 702; 
Recommendations: 667.

[End of table]

Source: GAO analysis of 50 OIOS reports on various Oil for Food program 
and UNCC activities.

Table 2: Number of Findings and Recommendations in 50 U.N. OIOS Reports 
for Selected Oil for Food Program and Related Activities:

Activities: UN headquarters; 
Finding subject: Asset management; 
Findings: 2; 
Recommendations: 2.

Activities: UN headquarters; 
Finding subject: Financial management; 
Findings: 4; 
Recommendations: 4.

Activities: UN headquarters; 
Finding subject: Information technology; 
Findings: 0; 
Recommendations: 0.

Activities: UN headquarters; 
Finding subject: Planning, coordination, and oversight; 
Findings: 9; 
Recommendations: 9.

Activities: UN headquarters; 
Finding subject: Procurement/contract management and oversight; 
Findings: 54; 
Recommendations: 52.

Activities: UN headquarters; 
Finding subject: Personnel and staffing; 
Findings: 2; 
Recommendations: 2.

Activities: UN headquarters; 
Finding subject: Security; 
Findings: 0; 
Recommendations: 0.

Activities: UN headquarters; 
Finding subject: Subtotal; 
Findings: 71; 
Recommendations: 69.

Activities: Northern Iraq; 
Finding subject: Asset management; 
Findings: 29; 
Recommendations: 27.

Activities: Northern Iraq; 
Finding subject: Financial management; 
Findings: 93; 
Recommendations: 93.

Activities: Northern Iraq; 
Finding subject: Information technology; 
Findings: 9; 
Recommendations: 9. 

Activities: Northern Iraq; 
Finding subject: Planning, coordination, and oversight; 
Findings: 53; 
Recommendations: 51. 

Activities: Northern Iraq; 
Finding subject: Procurement/contract management and oversight; 
Findings: 153; 
Recommendations: 150. 

Activities: Northern Iraq; 
Finding subject: Personnel and staffing; 
Findings: 41; 
Recommendations: 39. 

Activities: Northern Iraq; 
Finding subject: Security; 
Findings: 52; 
Recommendations: 52. 

Activities: Northern Iraq; 
Finding subject: Subtotal; 
Findings: 430; 
Recommendations: 421.

Activities: Treasury; 
Finding subject: Asset management; 
Findings: 1; 
Recommendations: 1. 

Activities: Treasury; 
Finding subject: Financial management; 
Findings: 27; 
Recommendations: 27. 

Activities: Treasury; 
Finding subject: Information technology; 
Findings: 2; 
Recommendations: 2. 

Activities: Treasury; 
Finding subject: Planning, coordination, and oversight; 
Findings: 1; 
Recommendations: 0. 

Activities: Treasury; 
Finding subject: Procurement/contract management and oversight; 
Findings: 0; 
Recommendations: 0. 

Activities: Treasury; 
Finding subject: Personnel and staffing; 
Findings: 1; 
Recommendations: 1. 

Activities: Treasury; 
Finding subject: Security; 
Findings: 0; 
Recommendations: 0. 

Activities: Treasury; 
Finding subject: Subtotal; 
Findings: 32; 
Recommendations: 31.

Activities: UNCC; 
Finding subject: Asset management; 
Findings: 2; 
Recommendations: 2. 

Activities: UNCC; 
Finding subject: Financial management; 
Findings: 102; 
Recommendations: 88. 

Activities: UNCC; 
Finding subject: Information technology; 
Findings: 15; 
Recommendations: 11. 

Activities: UNCC; 
Finding subject: Planning, coordination, and oversight; 
Findings: 3; 
Recommendations: 3. 

Activities: UNCC; 
Finding subject: Procurement/contract management and oversight; 
Findings: 12; 
Recommendations: 10. 

Activities: UNCC; 
Finding subject: Personnel and staffing; 
Findings: 35; 
Recommendations: 32. 

Activities: UNCC; 
Finding subject: Security; 
Findings: 0; 
Recommendations: 0. 

Activities: UNCC; 
Finding subject: Subtotal; 
Findings: 169; 
Recommendations: 146. 

Source: GAO analysis of 50 OIOS reports on various Oil for Food program 
and UNCC activities.

[End of table]

FOOTNOTES

[1] Independent Inquiry Committee into the United Nations Oil-for-Food 
Programme, Interim Report (New York: Feb. 3, 2005).

[2] The Food and Agricultural Organization; International 
Telecommunications Union; U.N. Development Program; U.N. Children's 
Fund; U.N. Educational, Scientific, and Cultural Organization; U.N.-
Habitat; U.N. Office for Project Services; World Health Organization; 
and World Food Program. 

[3] "Review of the Implementation of General Assembly resolutions 48/
218B and 54/244," A/59/649, para.1(c) (Dec. 22, 2004).

[4] As promulgated by the Institute of Internal Auditors and adopted by 
the Representatives of Internal Audit Services of the United Nations 
Organizations and Multilateral Financial Institution.

[5] OIOS provided audit coverage for U.N.-Habitat; the other 8 U.N. 
agencies implementing programs in northern Iraq were audited internally 
by their respective departments.

[6] Of the 58 reports, 26 reported on activities related to the program 
northern Iraq, 19 audited the UNCC, 6 addressed liquidation issues, 3 
audited the contracts for inspecting oil exports and goods coming into 
Iraq, and 2 reviewed the U.N. Treasury's management of funds. The 
Independent Inquiry Committee also released 2 summary reports, one of 
which had been drafted by OIOS but not issued. 

[7] U.S. General Accounting Office, United Nations: Observations on the 
Oil for Food Program and Areas for Further Investigation, GAO-04-953T 
(Washington, D.C.: July 8, 2004).

[8] We did not include in the data base information from the six audits 
that addressed the liquidation and shutdown of the Oil for Food program 
in 2003. These reports focused on the termination rather than the 
operations of the Oil for Food program. We also did not include 
information from the two summary reports because they included 
discussions of findings documented in previous audits. However, we 
reviewed these reports to help identify overall areas of concern and 
lessons learned, and we incorporated information and observations from 
the summary reports into our statement.