Why We Did This Audit
On October 7, 2023, Hamas—a U.S.-designated foreign terrorist organization—launched a massive terrorist attack on Israel that triggered the latest armed conflict in Gaza and resulted in widespread destruction and a humanitarian crisis. Between January 2023 and October 2024, the period under review, USAID had 18 active humanitarian assistance awards, valued at $650 million, in West Bank and Gaza to address urgent needs like food security, healthcare, and lack of shelter.
To mitigate the risk of the diversion of humanitarian assistance to U.S.-designated terrorists in addressing the crisis in West Bank and Gaza, USAID used partner vetting, which involved checking the names and other identifying information of its implementers and beneficiaries against public and nonpublic databases for any associations with terrorism. We have previously reported concerns about USAID’s ability to deliver humanitarian assistance in conflicts involving designated terrorist organizations. For example, in July 2024, we issued an advisory notice highlighting challenges in USAID’s oversight mechanism to prevent humanitarian assistance from being diverted by Hamas and other U.S.-designated terrorist organizations.
We conducted this audit to determine the extent to which USAID’s partner vetting for selected humanitarian assistance awards in West Bank and Gaza provided assurance that related funding did not support entities associated with terrorism.
What We Found
USAID selectively vetted organizations and individuals in West Bank and Gaza for humanitarian assistance awards, deeming the majority of them eligible. The individuals included principal officers, deputy officers, program managers, chiefs of party, and other people with significant responsibilities for the administration of USAID-funded activities or resources. We reviewed USAID’s vetting records from January 2023 to October 2024 for four selected awards and found that the Agency deemed 622 of 627 entities eligible for assistance. Five were ineligible, but the Agency did not disclose the reasons for ineligibility.
USAID’s policy exempted United Nations (UN) staff and other groups receiving assistance from the vetting process. Although USAID/West Bank and Gaza’s Mission Order 21 provided specific partner-vetting requirements and detailed guidance, it also exempted certain entities. For example, UN staff and ultimate beneficiaries receiving less than a $1,000 worth of humanitarian assistance were not subject to vetting, according to the order. The order also exempted any non-U.S. contractor or subcontractor that received less than $25,000 in total USAID funding in a 12-month period. The last update of the vetting exemptions was in 2007, nearly 20 years ago. Not assessing whether its vetting policies and procedures meet needs and legal requirements weakens the U.S. government’s ability to detect potential terrorist affiliations among UN staff, prospective implementers, and beneficiaries.
USAID’s partner vetting relied on implementer self-reporting and had information shortfalls. Such weak internal controls limited oversight and data quality in USAID’s partner vetting program. For example, USAID did not independently verify the vetting information it received from implementers’ self-reporting, and Agency vetting records included duplicate entries and multiple variations of the same name across entries. Assessing whether vetting policies are appropriate and addressing information shortfalls would enhance the U.S. government’s ability to ensure humanitarian assistance is not diverted to designated terrorists.
What We Recommend
We suggest that the administration consider reviewing exemptions to partner vetting policies and enhancing procedures and other internal controls for vetting partners that receive humanitarian assistance in West Bank and Gaza.