Much federal guidance exists regarding the implementation of Executive Order 13224 of September 23, 2001—Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism, which prohibits support to individuals and organizations associated with terrorism.
To implement Executive Order 13224, USAID uses (1) certifications, (2) vetting, and (3) special contract provisions, such as a mandatory clause.
USAID’s Acquisition and Assistance Policy Directive 04-14, “Certification Regarding Terrorist Financing Implementing E.O. 13224” (Revision 2), requires agreement officers to obtain certifications from recipients that they did not and will not knowingly provide material support or resources, such as currency, lodging, or training, to any individual or entity that has engaged or engages in terrorist activity before an award is made.
As stated in the USAID policy directive, the implementer should verify that an individual or entity to which it provides material support or resources does not appear on lists maintained by the U.S. Government or the United Nations. Moreover, .... the implementer [is] required to include mandatory clauses regarding terrorist financing in all contracts and subawards issued under the agreement.
In addition, at the mission level, the agreement officer’s technical representative (AOTR) is responsible for verifying that the recipient’s activities conform to the terms and conditions of the award as outlined in the designation letter for agreement officer’s technical representatives, a management control.
- Obtain the antiterrorism certifications required and include the information in official award files.
- Verify that secondary implementers and individuals provided with material support are not associated with terrorism.
- Include requirements for certifications and mandatory clauses for the prohibition of terrorist financing.
- Develop a schedule to verify periodically that implementers have taken actions to ensure that antiterrorism measures are followed in a timely manner.
Source: 6-263-11-007-p Year: 2011
The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations. Please see the disclaimer of this site before using recommendations.
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- Review and Obtain Antiterrorism Certifications - ADS 596.3 - Executive Order 13224
- Required Antiterrorism Provisions Were Not Included in Some Subawards – Executive Order 13224 on Terrorism Financing
- Ensure That Antiterrorism Measures Are Conducted - ADS 303 - Assistance Policy Directive 04-14, Certification Regarding Terrorist Financing Implementing E.O. 13224, issued on September 24, 2004 - Executive Order 13224
- Project Documentation to Ensure Adequate Monitoring Not Reviewed - ADS 303.2.f - ADS 596.3.1