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QUARTERLY HIGHLIGHT<br />

Afghan fuel trucks like these were used in multi-million-dollar fuel thefts that <strong>SIGAR</strong> investigated.<br />

(<strong>SIGAR</strong> photo by Special Agent Kyushik “Danny” Min)<br />

<strong>SIGAR</strong>’s Suspension and Debarment Program is<br />

unique because it embeds two attorneys, experienced<br />

with suspensions and debarments, within the<br />

Investigations Directorate to provide oversight over<br />

case development and guidance on the use of the suspensions<br />

and debarments. This integration enables<br />

them to track individuals, organizations, and companies<br />

accused of criminal activity or poor performance at an<br />

early stage of an investigation, resulting in the development<br />

of detailed referral packages.<br />

Integration within the Investigations Directorate also<br />

allows attorneys to assess whether follow-up actions,<br />

using suspension and debarment remedies, are needed<br />

when other targets are identified during an investigation<br />

or audit. It also allows for regular travel by <strong>SIGAR</strong> suspension<br />

and debarment attorneys to Afghanistan to conduct<br />

training, provide guidance for investigations, and to meet<br />

with counterparts in the Afghan government. <strong>SIGAR</strong>’s program<br />

has another unique element: unlike other criminal<br />

investigative organizations, all of <strong>SIGAR</strong>’s investigations<br />

are required to be reviewed for potential suspension<br />

and debarment action immediately prior to closing. This<br />

maximizes the number of cases referred for suspension<br />

and debarment.<br />

In addition, because <strong>SIGAR</strong> is not attached to an<br />

agency involved in contracting, <strong>SIGAR</strong> does not need its<br />

own suspension and debarment official. Instead, <strong>SIGAR</strong><br />

refers all suspensions and debarments to other agencies<br />

for adjudication, resulting in a high degree of interagency<br />

coordination. This operational necessity to work with<br />

other agencies fosters information-shaing and coordination,<br />

enhancing <strong>SIGAR</strong>’s program.<br />

Agencies typically maintain their suspension and debarment<br />

function at the headquarters/management level, so<br />

there is the potential for agency interests to influence the<br />

development of a suspension or debarment case. <strong>SIGAR</strong>’s<br />

independent standing makes for referrals not affected by<br />

considerations of impacts on the agency or a particular<br />

program. The need to go outside of <strong>SIGAR</strong> for a suspension<br />

or debarment also requires that <strong>SIGAR</strong>’s referrals be<br />

of high quality with well-supported allegations.<br />

Once it refers a case, <strong>SIGAR</strong> has no influence over the<br />

adjudication process, yet it has been remarkably successful.<br />

Not a single individual or organization has successfully<br />

56<br />

SPECIAL INSPECTOR GENERAL I AFGHANISTAN RECONSTRUCTION

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