HomeResourcesAudit Database Project Compliance RecommendationsEnsure 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

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

Mandatory Standard Provisions for Non-U.S., Nongovernmental Recipients, a mandatory reference for ADS 303, Grants and Cooperative Agreements to Nongovernmental Organizations, and Acquisition and Assistance Policy Directive 04-14, Certification Regarding Terrorist Financing Implementing E.O. 13224, issued on September 24, 2004, implemented Executive Order 13224 on Terrorist Financing.

The directives establish the legal responsibility for recipients of USAID funds to comply with the order and other laws.. Some USAID missions implement Executive Order 13224 using three specific requirements:

  • Mandatory Clauses – require mandatory provisions to be included in all solicitations and awards for contracts, grants, cooperative agreements, subcontracts, and subawards indicating that a recipient will comply with antiterrorism guidance.
  • Certification – requires all U.S. and non-U.S. entities to certify that they do not provide material support or resources for terrorism.
  • Vetting – requires inquiries from individuals and searches of special databases for background information on contractors and subcontractors who receive in excess of $25,000, as well as recipients of assistance instruments regardless of the dollar amount.

Additionally, ADS 303.2, Primary Responsibilities, requires agreement officers’ technical representatives to be responsible for prudently managing assistance awards by monitoring to ensure recipients’ compliance with legally binding award terms and conditions.

General Recommendations

  • Review programs to determine whether antiterrorism measures would help to mitigate the risk of inadvertently providing financing to terrorist organizations or individuals associated with terrorism.

  • Provide training on USAID’s antiterrorism measures.

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

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.

Tags: Anti-Terrorism

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