Security Assistance; and Logistics - Federation of American Scientists

End-Use Monitoring Compliance PlanThe Arms Export Control Act, section 40A, states that a EUM Compliance Plan provides“reasonable assurances that the recipient is complying with the requirements imposed bythe U.S. Government with respect to the use, transfer, and security of defense articles andmonitoring of U.S. arms transfers, and security of defense articles and services.”The Iraqi Minister of Foreign Affairs has signed a Section 505 assurance letter that Iraqwill accept the legal and policy standards required by the Security AssistanceManagement Manual, a commitment that is also stated in FMS Letters of Offer andAcceptance. Iraq has previously received weapons technology from the U.S. and hasagreed to a variety of controls stated in U.S. law and policy. Among those is the EUMcompliance plan, which represents the foundation of the EUM program. Theserequirements were included in Chapters 5 and 8 of the Security Assistance ManagementManual and in the documents authorizing transfer.MNSTC-I End-Use Monitoring InitiativesIn August 2008, the MNSTC-I SAO reported that, with the assistance of DSCApersonnel and Defense Institute of Security Assistance Management (DISAM) trainers, ithad developed and planned to implement a EUM Compliance Plan and StandardOperating Procedures (SOP) and had incorporated those documents into the MNSTC-I J4accountability SOP. The MNSTC-I SAO also reported that it was endeavoring to “assistthe Iraqis to understand EUM accountability requirements including a suitable inventorysystem for monitoring sensitive items.”Recommendations, Client Comments, and OurResponseRevised Recommendations. As a result of our assessment of client comments,we revised Recommendations 3.a. and 3.b. to clarify that MNSTC-I is the organizationassigned primary responsibility for accomplishing the actions associated with theserecommendations.3.a. We recommend that the Commander, Multi-National Security Transition Command-Iraq, in coordination with the Director, Defense Security Cooperation Agency, developan End-Use Monitoring compliance plan in coordination with the Government of Iraq.Client CommentsCommander, MNSTC-I concurred. The Commander, MNSTC-I stated that the “IraqGolden Sentry End-Use-Monitoring (EUM) Standard Operating Procedure” was signedSeptember 12, 2008, and describes the responsibilities, points of contacts, requiredprocedures, inspection requirements, documentation, and visit procedures for the EUMprogram. He also stated that MNSTC-I had developed and updated Memorandums ofAgreement for Night Vision Devices (NVDs) with the Iraqi Counter Terrorism Bureau,MoD, and MoI detailing the requirements and procedures for the Enhanced End-UseMonitoring of NVDs purchased, delivered, or controlled by the ISF.50