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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

November 2006: 

Afghanistan Drug Control: 

Despite Improved Efforts, Deteriorating Security Threatens Success of 
U.S. Goals: 

Afghanistan Drug Control: 

GAO-07-78: 

GAO Highlights: 

Highlights of GAO-07-78, a report to congressional committees 

Why GAO Did This Study: 

The prevalence of opium poppy cultivation and drug trafficking in 
Afghanistan imperils the stability of its government and threatens to 
turn the conflict-ridden nation once again into a safe haven for 
traffickers and terrorists. To combat the drug trade, the U.S. 
government developed a counternarcotics strategy consisting of five 
pillars—alternative livelihoods, elimination and eradication, 
interdiction, law enforcement and justice, and public information. 

The Emergency Supplemental Appropriations Act of 2005 directed GAO to 
examine the use of all fiscal year 2005 funds administered by the U.S. 
Agency for International Development (USAID) and Department of State 
(State) for Afghan counternarcotics programs. To comply with this 
mandate, we examined progress under each counternarcotics pillar, 
challenges faced, and efforts to ensure that funds were used for 
intended purposes. To address these objectives, GAO reviewed pertinent 
USAID and State documents and met with cognizant U.S. and international 
officials in Washington, D.C., and Afghanistan. 

GAO makes no recommendations in this report. USAID, State, Department 
of Defense, and Department of Justice were provided a draft of this 
report, but did not provide formal comments. 

What GAO Found: 

USAID and State received about $532 million in fiscal year 2005 funds 
and initiated a number of projects under each counternarcotics pillar, 
but delays in implementation limited progress. For example, State’s 
provision of aircraft enhanced the mobility of eradicators, but 
coordination difficulties between Afghan officials and security forces 
delayed the eradicators’ fielding. Despite increased eradication and 
other U.S. efforts, the poppy crop grew by 50 percent in 2006 to a 
record level. However, many projects have not been in place long enough 
to assess progress toward the overall goal of significantly reducing 
drug cultivation, production, and trafficking. For example, projects to 
provide rural credit and to field teams to discourage poppy cultivation 
were not in place prior to the 2005-2006 growing season. 

The worsening security situation and the lack of Afghan capacity are 
tremendous challenges to the success of U.S. counternarcotics programs 
in Afghanistan. The security situation continues to decline; during the 
2005-2006 growing season, eradicators were attacked several times and 
alternative livelihoods project personnel were killed. Moreover, due to 
Afghanistan’s lack of infrastructure, educated populace, and 
functioning governmental institutions, significantly reducing poppy 
cultivation and drug trafficking is expected to take at least a decade. 

USAID and State have made efforts to oversee the use of funds, 
including the use of self certifications, contract clauses, and 
vetting, when applicable. However, a lack of official records and 
reliable information limited efforts to vet Afghan nationals. In 
addition, although USAID and State have made efforts to monitor ongoing 
projects, security concerns and poor infrastructure limited site 
visits. 

Figure: Five Pillar Counternarcotics Strategy in Afghanistan: 

[See PDF for Image] 

Source: GAO and State Department (data and photos). 

[End of Figure] 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-78]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact David Gootnick, (202) 512-
3149 or GootnickD@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

USAID and State Projects Made Progress, but Implementation Delays 
Limited Accomplishments: 

U.S. Counternarcotics Programs Face Several Challenges: 

USAID and State Made Efforts to Oversee the Use of Funds, but Lack of 
Information and Security Limited Some Efforts: 

Concluding Observations: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Opium Production in Afghanistan, 2002 through 2006: 

Table 2: Fiscal Year 2005 Counternarcotics Assistance to Afghanistan 
Administered by USAID and State by Pillar as of June 2006 (in 
millions): 

Table 3: Fiscal Year 2005 Alternative Livelihoods Assistance as of June 
2006 (in millions): 

Table 4: Alternative Livelihoods Performance Data Reported as of 
September 30, 2006: 

Table 5: Fiscal Year 2005 Eradication Assistance as of June 2006 (in 
millions): 

Table 6: Fiscal Year 2005 Interdiction Assistance as of June 2006 (in 
millions): 

Table 7: Fiscal Year 2005 Law Enforcement/Justice Reform Assistance as 
of June 2006 (in millions): 

Table 8: Fiscal Year 2005 Public Information Assistance as of June 2006 
(in millions): 

Figures: 

Figure 1: Opium Poppy Seed Capsule: 

Figure 2: Five Pillar Counternarcotics Strategy in Afghanistan: 

Figure 3: Map of Afghanistan Counternarcotics Projects: 

Figure 4: Cash-for-Work Road-Construction Project: 

Figure 5: Huey-II Helicopters in Kandahar: 

Figure 6: AEF Conducting Manual and Mechanized Eradication in Helmand: 

Figure 7: Khirmanjo, Tajikistan, Border Post Scheduled to Be 
Refurbished: 

Figure 8: Afghan Corrections Officer Training: 

Figure 9: Ministry of Justice Building under Construction in Wardak 
Province: 

Figure 10: Public Information Campaign Stickers, Billboard, and 
Posters: 

Figure 11: Aftermath of April 7, 2006, Improvised Explosive Device 
Attack on Government Vehicle in Helmand: 

Abbreviations: 

AEF: Afghan Eradication Force: 

CJTF: Criminal Justice Task Force: 

CNPA: Counter Narcotics Police of Afghanistan: 

CPEF: Central Poppy Eradication Force: 

CSSP: Corrections System Support Program: 

DEA: Drug Enforcement Administration: 

NIU: National Interdiction Unit: 

PEP: Poppy Elimination Program: 

UN: United Nations: 

UNODC: United Nations Office on Drugs and Crime: 

USAID: U.S. Agency for International Development: 

United States Government Accountability Office: 
Washington, DC 20548: 

November 15, 2006: 

The Honorable Mitch McConnell: 
Chairman: 
The Honorable Patrick J. Leahy: 
Ranking Minority Member: 
Subcommittee on State, Foreign Operations, and Related Programs: 
Committee on Appropriations: 
United States Senate: 

The Honorable Jim Kolbe: 
Chairman: 
The Honorable Nita M. Lowey: 
Ranking Minority Member: 
Subcommittee on Foreign Operations, Export Financing, and Related 
Programs: 
Committee on Appropriations: 
House of Representatives: 

The continued prevalence of opium poppy[Footnote 1] cultivation and 
drug trafficking in Afghanistan imperils the stability of the Afghan 
government and threatens to turn the conflict-ridden nation into a safe 
haven for traffickers and terrorists. In 2005, opium poppy was 
cultivated in more than three-quarters of Afghanistan's provinces. The 
estimated export value of opium, morphine, and heroin equaled about 
half of the country's licit economy, with drug profits reportedly 
funding terrorists and other antigovernment entities.[Footnote 2] As a 
result, counternarcotics--for which the United Kingdom took the 
international lead in Afghanistan in 2002[Footnote 3]--has become one 
of the top priorities of the United States. To combat opium poppy 
cultivation, drug trafficking, and their negative effects on Afghan 
stability and pursuit of democracy, in 2005, the U.S. government, 
working with allied governments, developed a five-pillared 
counternarcotics strategy addressing (1) alternative livelihoods, (2) 
elimination and eradication, (3) interdiction, (4) law enforcement and 
justice reform, and (5) public information. The overall goal of the 
strategy is to significantly reduce Afghanistan's poppy cultivation, 
drug production, and drug trafficking. In fiscal year 2005, the United 
States provided about $782 million dollars for programs administered by 
the Departments of Defense (Defense) and State (State), the U.S. Agency 
for International Development (USAID), and the Drug Enforcement 
Administration (DEA) for counternarcotics programs in 
Afghanistan.[Footnote 4] 

The Emergency Supplemental Appropriations Act for Defense, the Global 
War on Terror, and Tsunami Relief of 2005[Footnote 5] required the 
Comptroller General to examine the use of all fiscal year 2005 funds 
administered by USAID and State--about $532 million--for bilateral 
Afghanistan counternarcotics and alternative livelihoods 
programs.[Footnote 6] To comply with this mandate, we examined (1) 
USAID's and State's progress in implementing counternarcotics programs, 
projects, and activities under each pillar, and the factors, if any, 
limiting implementation; (2) challenges faced by counternarcotics 
efforts; and (3) the agencies' efforts to ensure that the funds were 
used for intended purposes. 

To address these objectives, we reviewed pertinent USAID and State 
planning, funding, and reporting documents for counternarcotics 
programs. We discussed these programs with cognizant officials from the 
Departments of Defense, Justice (Justice), and State; USAID; DEA in 
Washington, D.C., and Afghanistan; and with private contractors 
implementing U.S. projects in Afghanistan. In Kabul, Afghanistan, we 
met with officials from the United Nations (UN) and the governments of 
Afghanistan and the United Kingdom to discuss counternarcotics efforts. 
We traveled to the provinces of Balkh, Helmand, Kandahar, and Nangarhar 
to meet with U.S. and Afghan officials to discuss various U.S.-funded 
projects. We determined the data provided to us were sufficiently 
reliable for the purposes of this report. 

We conducted our review from September 2005 through October 2006 in 
accordance with generally accepted government auditing standards. (See 
app. I for a more complete description of our scope and methodology.) 

Results in Brief: 

USAID and State initiated a number of projects under each of the U.S. 
counternarcotics strategy's five pillars, but delays in implementation-
-due to the security situation, poor infrastructure, and other factors-
-limited progress. Many projects have not been in place long enough to 
fully assess progress toward the overall goal of significantly reducing 
poppy cultivation, drug production, and drug trafficking. 

Alternative livelihoods. With $180 million, USAID implemented projects 
to provide economic alternatives to poppy production and thus reduce 
the amount of Afghanistan's economic activity attributable to the drug 
industry. USAID supported regional alternative livelihoods projects, 
distributed seed and fertilizer, and initiated a rural credit project. 
USAID continued cash-for-work projects and supported business 
development in targeted poppy areas. Results varied in the three 
principal alternative livelihoods regions, in part because of the 
differing security risks and access to infrastructure. 

Elimination and eradication. With $258 million, State supported the 
Afghan government's efforts to prevent poppy planting and eradicate 
poppy crops if prevention failed. State provided support for central 
and provincial eradication efforts. Central government eradication 
efforts improved with the reorganization of the Afghan Eradication 
Force (AEF) into smaller, more mobile units and the addition of 
purchased and leased transport and logistical-support aircraft. 
However, the AEF's fielding was delayed from early February 2006 until 
late March 2006 because of the need to address coordination challenges, 
reducing the amount of eradication possible. Provincial eradication 
efforts also improved when State began reimbursing governors for 
provincial eradication expenses. However, teams designed to help 
governors discourage farmers from growing poppy, the Poppy Elimination 
Program (PEP) teams, were not fully fielded as of June 2006. 

Interdiction. With $65 million, State assisted DEA-led efforts to help 
build Afghan capacity to destroy drug labs, seize precursor chemicals 
and opiates, and arrest major traffickers. State provided support for 
border security enhancements in neighboring countries and the 
counternarcotics police. In the neighboring countries of Pakistan, 
Tajikistan, and Turkmenistan, State began border security projects; 
however, other projects had not started as of June 2006. For example, 
State had not begun planned support for the National Interdiction Unit 
(NIU) and the Counter Narcotics Police of Afghanistan (CNPA) because an 
NIU support facility and ongoing police reform efforts were not 
completed. 

Law enforcement and justice reform. With almost $24 million, State 
supported the Afghan government's efforts to increase its capacity to 
arrest, prosecute, and punish traffickers and corrupt officials. State 
provided support for Department of Justice prosecutors, corrections 
reform, and a planned justice center. The Justice prosecutors helped 
develop and implement a new counternarcotics law. State support for 
corrections reform, including the training of guards and refurbishment 
of courthouses, is under way. State has delayed its support for the 
operations and maintenance of a new counternarcotics justice facility 
while its construction is completed. 

Public information. With $5 million, State led a public information 
campaign intended to convince the Afghan populace to reject poppy 
cultivation and trade. State initially transferred funds to USAID to 
initiate a campaign that used radio spots and print media over three 
targeted phases, and which State continued and expanded. However, 
because of delays with the PEP team implementation, the campaign was 
not able to rely on planned support from the PEP teams. 

The worsening security situation and the lack of Afghan capacity are 
tremendous challenges for the success of U.S. counternarcotics programs 
in Afghanistan. The security situation in Afghanistan continues to 
decline. The central government faces threats from the Taliban, 
terrorist attacks, and criminal activity. During the 2005-2006 growing 
season, eradication forces were attacked several times and alternative 
livelihoods project personnel were killed. Moreover, because of 
Afghanistan's lack of infrastructure, educated populace, and 
functioning governmental institutions, addressing opium poppy 
cultivation and drug trafficking is expected to take at least a decade. 
The nation has few roads and poor access to power. The population is 
mostly illiterate and untrained. According to U.S., International 
Monetary Fund, and other officials, the government is plagued by 
corruption, has a weak judicial sector, and will be unable to pay its 
recurring costs without foreign assistance for at least 10 years. 

USAID and State took steps to help ensure that U.S. assistance funds 
were used as intended, but (1) documentation to help prevent terrorists 
and criminals from benefiting from U.S. assistance was limited at best 
and (2) monitoring the status of ongoing projects through site visits 
and other efforts were constrained by the lack of security in many 
project areas and poor or nonexistent infrastructure, such as roads. 
USAID and State are required to adhere to an executive order and laws 
that ban, among other things, assistance to terrorists, drug 
traffickers, and human rights violators. To comply, USAID and State 
used certifications and contract clauses to help ensure that the 
contractors, grantees, and other aid recipients were aware of the legal 
requirements. However, USAID's and State's vetting of Afghan nationals 
was limited because of incomplete or nonexistent birth records and 
other identifying documentation, and the difficulty of investigating 
widespread allegations of misconduct. USAID and State also used 
contractor reporting and site visits to monitor the performance of 
projects. Although USAID and State contractors submitted required 
progress reports, external factors beyond the agencies' or contractors' 
control, such as Afghanistan's poor security environment and 
infrastructure, limited project monitoring by restricting access to 
project sites. 

We provided a draft of this report for review and comment to State, 
USAID, Defense, and Justice. Each agency informed us that they were not 
providing formal comments. However, USAID and Justice provided 
technical comments, which we have incorporated into the report where 
appropriate. 

Background: 

Afghanistan is a mountainous, arid, land-locked country with limited 
natural resources, bordered by Pakistan to the east and south; 
Tajikistan, Turkmenistan, Uzbekistan, and China to the north; and Iran 
to the west. At 647,500 square kilometers, Afghanistan is slightly 
smaller than the state of Texas. The country is divided into 34 
provinces, more than 300 districts, and approximately 30,000 villages. 

Afghanistan is one of the world's poorest countries; its population, 
estimated at more than 31 million, is ethnically diverse, largely 
rural, and mostly uneducated. Development indicators published by the 
World Bank and the UN rank Afghanistan at the bottom of virtually every 
category, including nutrition; infant, child, and maternal mortality; 
life expectancy; and literacy. 

Over the last two decades, conflict ravaged Afghanistan. The Soviet 
Union invaded Afghanistan in 1979 and withdrew only after waging a 
prolonged and destructive war against Afghan resistance groups. 
Following a protracted civil war, by 1998, most of Afghanistan was 
under the control of the fundamentalist Taliban group. Under the 
Taliban, Afghanistan became a haven for terrorists. After the terrorist 
attacks of September 11, 2001, the United States and a coalition of its 
allies invaded Afghanistan and removed the Taliban from power. 

Following the Taliban's removal, the coalition began the process of 
establishing a new Afghan government.[Footnote 7] To help rebuild the 
country and create a stable Afghan society that would not be a threat 
to itself or others, in fiscal years 2002 through 2004 the United 
States spent $1.6 billion on humanitarian and reconstruction projects. 
In June 2004 and again in July 2005, we reported that U.S. humanitarian 
and short-term assistance over the two-year period had helped 
Afghanistan's vulnerable population, but that longer-term 
reconstruction efforts achieved limited results in creating a stable 
Afghan society.[Footnote 8] 

The United States and several other donor nations met in Geneva, 
Switzerland, in April 2002, to help Afghanistan address threats to its 
security. At the Geneva conference, the donors established a five- 
pillared security reform agenda and designated a donor country to take 
the lead in reforming each pillar. In a June 2005 report on efforts to 
establish the army and police, we reported that there needed to be 
concurrent progress in all security pillars, otherwise Afghanistan 
could again become a haven for terrorists. Furthermore, we reported 
that limited progress had been made in reforming Afghanistan's 
judiciary and combating illicit narcotics.[Footnote 9] 

Afghanistan's Opium Industry: 

Afghanistan is the world's largest supplier of opium and has been a 
source of illegal opium for decades. Opium poppy is a hardy, drought- 
resistant crop that is easily grown throughout Afghanistan's rugged 
territory. Opium poppy, as seen in figure 1, is an annual crop with a 
six to seven month planting cycle that starts earlier in the south and 
later in the north of Afghanistan. It is planted between September and 
December and flowers approximately three months after planting. After 
the flower's petals fall away, the opium, an opaque, milky sap found in 
the plant's seed capsule, is harvested between April and July. The sap 
can then be refined into morphine and heroin. United Nations Office on 
Drugs and Crime (UNODC) surveys indicate that the primary deterrent to 
farmers growing poppy is the threat of eradication. The majority of 
eradication takes place after the poppy plant has sprouted and before 
it is harvested, approximately a two-month long period. 

Figure 1: Opium Poppy Seed Capsule: 

[See PDF for image] 

Source: Department of State. 

[End of figure] 

According to UNODC, in the three-year period, 2002 through 2004, 
Afghanistan's opium harvest increased substantially. In 2005, the 
number of hectares of opium poppy cultivation declined by over 20 
percent, yet the crop yield per hectare rose because of favorable 
weather conditions. Thus, the estimated amount of potential opium 
produced declined only slightly. In 2006, poppy cultivation increased 
to 165,000 hectares, yielding a record poppy crop estimated at a 
potential 6,100 metric tons of opium, or more than 90 percent of the 
world's illicit opium (see table 1). 

Table 1: Opium Production in Afghanistan, 2002 through 2006: 

Net opium poppy cultivation (hectares); 
2002: 74,000; 
2003: 80,000; 
2004: 131,000; 
2005: 104,000; 
2006: 165,000. 

Potential opium production (metric tons); 
2002: 3,400; 
2003: 3,600; 
2004: 4,200; 
2005: 4,100; 
2006: 6,100. 

Provinces where opium poppy is grown[A]; 
2002: 24; 
2003: 28; 
2004: 32 (all); 
2005: 25; 
2006: 28. 

Source: UN Office on Drugs and Crime. 

Notes: 

1 hectare equals 2.47 acres. 

1 metric ton equals 2,204.6 pounds. 

[A] In 2005, the Afghan Government reorganized the country's 
administrative divisions into 34 provinces. However, the 2005 UNODC 
opium survey was designed, and its results are presented, according to 
the previous 32 provinces. The 2006 survey was based on 34 provinces. 

[End of table] 

State attributed the reduction in cultivation in 2005 to surplus opium 
from previous years, public information efforts by President Karzai and 
others, promised alternative livelihoods assistance, and farmers' fears 
of eradication. However, eradication fears were not realized; only an 
estimated 5,100 hectares of poppy were eradicated. Further, drug- 
related corruption is a problem at all levels of government and remains 
pervasive at the provincial and district levels. Conversely, the 
reasons for the growth in 2006 cultivation are not fully known, but 
U.S. officials described a combination of factors, including the 
relatively small amount of eradication in 2005 and pressure from 
traffickers and the Taliban on farmers to grow. For example, U.S. 
officials said that in southern Afghanistan, farmers reported finding 
"night letters" from the Taliban left on their doors threatening them 
if they did not cultivate poppy. Moreover, UNODC reported that many 
farmers paid eradicators not to eradicate their fields and that 
eradication was often a consensual decision between eradicators and 
farmers. 

The U.S. Counternarcotics Strategy: 

From 2002 through 2004, the United States saw increasing opium poppy 
cultivation and drug trafficking as a growing threat to stability and 
security of Afghanistan and provided approximately $380 million for 
Afghan-and United Kingdom-led counternarcotics efforts. The United 
States used these funds to train Afghan narcotics interdiction units, 
construct border and highway checkpoint facilities, and supply 
operational support and nonlethal equipment to Afghan eradication 
teams. These efforts failed to have any significant effect on the 
illicit narcotics industry because of limited security and stability 
across Afghanistan. As a result, the U.S. government made 
counternarcotics a top priority and developed a strategy in 2004 to 
reduce poppy cultivation, drug production, and trafficking. This new 
strategy is comprised of five pillars, as illustrated in figure 2. The 
five-pillar counternarcotics plan is intended to offer incentives to 
stop the growing of opium poppy through alternative livelihoods 
projects, combined with strong disincentives in the form of forced 
eradication, interdiction, and law enforcement, while spreading the 
Afghan government's antinarcotics message. These U.S. efforts are also 
expected to build the Afghan government's capacity to conduct 
counternarcotics efforts on its own. 

Figure 2: Five Pillar Counternarcotics Strategy in Afghanistan: 

[See PDF for image] 

Source: GAO and State Department (data and photos); Nova Development 
(clip art). 

[End of figure] 

The United States originally planned to use crop-dusting airplanes to 
spray herbicide on the opium poppy before it could be harvested. 
However, the Afghan government would not allow the use of herbicides. 
Consequently, the United States and Afghanistan rely on manual 
eradication, such as police on foot using sticks, sickles, and scythes 
to knock or cut down poppy, and mechanized eradication, which involves 
police using tractors, all-terrain vehicles, and other vehicles to 
drive over or plow up the poppy. USAID also modified some of its 
projects to specifically focus on counternarcotics in those provinces 
where opium poppy cultivation was greatest. These alternative 
livelihoods projects are coordinated with USAID's on-going 
reconstruction efforts, and several of the short term cash-for-work 
projects stem from prior humanitarian assistance projects designed to 
help vulnerable populations. 

U.S. Funding for Counternarcotics: 

To accomplish U.S. counternarcotics goals in Afghanistan, the United 
States provided about $782 million in fiscal year 2005, of which $532 
million was administered by USAID and State,[Footnote 10] as shown in 
table 2, and over $250 million by Defense and DEA. The majority of 
USAID and State funding was provided by the Emergency Supplemental 
Appropriations Act for Defense, the Global War on Terror, and Tsunami 
Relief, 2005, which was enacted into law in May 2005.[Footnote 11] 
Several federal and agency regulations govern USAID's and State's use 
of these funds for counternarcotics programs, prohibiting use of the 
funds to assist terrorists, drug traffickers, or human rights 
violators. Though not explicitly addressed in this report, funds 
administered by Defense and DEA are being expended on projects, such as 
constructing the counternarcotics justice center and supporting Afghan 
interdiction efforts. 

Table 2: Fiscal Year 2005 Counternarcotics Assistance to Afghanistan 
Administered by USAID and State by Pillar as of June 2006 (in 
millions): 

Pillar: Alternative Livelihoods (USAID); 
Provided: $180; 
Obligated: $162; 
Expended[A]: $117. 

Pillar: Elimination/Eradication (State); 
Provided: 258; 
Obligated: 204; 
Expended[A]: 69. 

Pillar: Interdiction (State); 
Provided: 65; 
Obligated: 44; 
Expended[A]: 2. 

Pillar: Law Enforcement/Justice Reform (State); 
Provided: 24; 
Obligated: 17; 
Expended[A]: 2. 

Pillar: Public Information (State); 
Provided: 5; 
Obligated: 5; 
Expended[A]: 1. 

Pillar: Total; 
Provided: $532; 
Obligated: $432; 
Expended[A]: $191. 

Source: USAID and State. 

[A] According to a Department of State official, actual expenditures 
may be higher than reported figures due, in part, to delays in 
receiving bills from other agencies, international organizations, and 
contractors. 

[End of table] 

USAID and State Projects Made Progress, but Implementation Delays 
Limited Accomplishments: 

USAID and State established goals for each of the U.S. counternarcotics 
strategy's five pillars, funded projects under each pillar, and made 
progress toward some project objectives. However, the implementation of 
several projects was hindered by the security situation, poor 
infrastructure, and other factors. Moreover, USAID's and State's 
projects (see fig. 3) had not been in place long enough to determine 
whether they had contributed toward the overall goal of significantly 
reducing poppy cultivation, drug production, and drug trafficking. 

Figure 3: Map of Afghanistan Counternarcotics Projects: 

[See PDF for image] 

Sources: GAO presentation of USAID, State, and UN data; Afghanistan 
information management Services (map); and Map Resources (clip art). 

[End of figure] 

Alternative Livelihoods: Despite Efforts, Increased Security Risks and 
Infrastructure Limited Achievements: 

As shown in table 3, USAID provided $180 million to fund licit economic 
alternatives to poppy cultivation and thus reduce the amount of 
Afghanistan's economic activity attributable to the drug industry. 
According to UNODC, as of 2006, 2.9 million Afghans were involved in a 
narcotics industry that is equivalent to about half of Afghanistan's 
legal economic activity. 

Table 3: Fiscal Year 2005 Alternative Livelihoods Assistance as of June 
2006 (in millions): 

Project: Regional Alternative Livelihoods Projects: East;  
Provided: $53; 
Obligated: $53; 
Expended: $37. 

Project: Regional Alternative Livelihoods Project: North; 
Provided: 22; 
Obligated: 22; 
Expended: 9. 

Project: Regional Alternative Livelihoods Project: South; 
Provided: 50; 
Obligated: 50; 
Expended: 35. 

Project: Other Alternative Livelihoods Projects: Seed and Fertilizer: 
Provided: 30; 
Obligated: 30; 
Expended: 29. 

Project: Other Alternative Livelihoods Projects: Agricultural Credit; 
Provided: 16; 
Obligated: 0; 
Expended: 0. 

Project: Other[A]; 
Provided: 8; 
Obligated: 7; 
Expended: 6. 

Project: Total[B]; 
Provided: $180; 
Obligated: $162; 
Expended: $117. 

Source: USAID. 

[A] Other covers funds that were not allocated to the five project 
lines, including program management and contributions to the World Bank 
for alternative livelihoods projects. 

[B] Totals may not add due to rounding. 

[End of table] 

Regional Projects Under Way, but Results Varied: 

USAID provided about $125 million for regional alternative livelihoods 
projects. The projects were split into three regions--Nangarhar, 
Laghman, and Konar in the east; Badakshan and Takhar in the north; and 
Helmand, Kandahar, Oruzgan in the south--and were implemented by 
different contractors in an effort to ensure the projects were tailored 
to the appropriate needs and potential of each region. In all the 
regions, similar types of labor intensive, cash-for-work projects were 
implemented, such as road repair, as illustrated in figure 4, and 
irrigation and drainage canal rehabilitation. The contractors in each 
region were supposed to develop longer-term projects more suited to 
their provinces. A key element of these efforts was to develop industry 
"clusters." For example, dairy, poultry, and livestock industries were 
associated with feed development and production; veterinary services; 
and milk, meat, and egg products being packaged, processed, and stored. 
Although rehabilitating the agriculture sector is a priority in all of 
these provinces, in the east, USAID is also exploring ways to expand 
and add value to the marble industry and, in the north, USAID is 
focusing on cattle and other livestock industries. 

Figure 4: Cash-for-Work Road-Construction Project: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

As shown in table 4, USAID reported the following results for its cash- 
for-work projects in the east, north, and south. USAID had not 
established targets for all these activities in fiscal year 2006, but 
had established targets in September 2006 for fiscal year 2007. 

Table 4: Alternative Livelihoods Performance Data Reported as of 
September 30, 2006: 

Performance Indicator: Roads repaired(in kilometers); 
East: 306; 
North: 38; 
South: 73; 
Total: 417. 

Performance Indicator: Irrigation and drainage canals rehabilitated (in 
kilometers); 
East: 2,432; 
North: 543; 
South: 1,494; 
Total: 4,469. 

Performance Indicator: People employed; 
East: 153,698; 
North: 25,339; 
South: 39,783; 
Total: 218,820. 

Performance Indicator: Cash-for-work wages (in millions); 
East: $14.0; 
North: $1.0; 
South: $5.2; 
Total: $20.3. 

Source: Contractor reports provided to USAID. 

Note: Data includes cash-for-work projects begun in 2005 and later 
incorporated into the alternative livelihoods program. 

[End of table] 

As part of the longer-term objectives of developing business clusters, 
USAID conducted numerous studies in all three regions to assess various 
business sectors that could be sustainable in the respective regions, 
such as dairy, fruits and nuts, flour mills, carpets, and other 
industries. In Nangarhar, a business center was opened in April 2006 
and is expected to boost development in the region. The business center 
will provide computer training and other services to local businessmen. 
Also, in Nangarhar and Laghman, fruit and nut trees were planted on 
some 1,500 hectares of former poppy-producing land. 

The deteriorating security situation, the lack of infrastructure, and, 
in northern Afghanistan, bad weather all contributed to delays in 
implementing the alternative livelihoods projects. Contractors often 
reported the security situation in a particular district or area forced 
them to suspend projects for weeks or months at a time. For example, in 
May 2005, four Afghan subcontractors working on cash-for-work projects 
in the south were killed, which led the USAID contractor to leave the 
area until September 2005. Contractors and potential investors cited 
the lack of adequate roads and electricity as deterrents to investors. 
For example, the poor condition of the road leading into Badakshan made 
it difficult to obtain the use of heavy machinery for construction and 
other projects, as many contractors were unable or unwilling to 
transport such equipment there. In addition, the weather in Badakshan 
led to the delay of projects because the area was snowed in for much of 
the winter, while flooding in the summer limited activities. 

Seed and Fertilizer Distributed, but Agricultural Credit Project 
Delayed: 

USAID provided almost $30 million to purchase seed and fertilizer for 
Afghan farmers to use as an alternative to growing poppy. The initial 
quantity of wheat seed and fertilizer in the fall of 2005 was equally 
distributed among all of Afghanistan's provinces and was intended to 
demonstrate the central government's reach throughout Afghanistan. The 
spring 2006 distribution of vegetable seeds was limited to the three 
alternative livelihoods regions. According to USAID, this distribution 
of seed and fertilizer targets farmers with access to both water to 
grow the vegetables and markets to sell the produce. USAID reported 
that the fall seed and fertilizer distribution reached all 34 provinces 
and 550,000 farmers. The spring seed and fertilizer project distributed 
vegetable seeds and fertilizer to approximately 112,000 farmers in the 
east, north, and south. 

USAID provided almost $16 million for an agricultural-credit project. 
Afghan farmers do not have access to credit for planting licit crops, 
although drug traffickers provide credit to farmers for planting opium 
poppies. USAID's project seeks to remedy this situation by providing 
loans to farmers to grow licit crops. USAID planned to initiate this 
project by mid-summer 2006, but the funding was not obligated until the 
fall. According to USAID officials, the project was delayed while they 
searched for a contractor who was able to initiate the project in all 
the targeted regions. 

Elimination and Eradication: Despite More Eradication, Cultivation 
Increased: 

As shown in table 5, State provided $258 million to support the Afghan 
government's efforts to prevent poppy planting and eradicate poppy 
crops if prevention failed. In 2005, after central and provincial 
government eradication efforts, an estimated 104,000 hectares of opium 
poppy were cultivated. In 2006, this number increased to an estimated 
165,000 hectares despite a threefold increase in eradication. 

Table 5: Fiscal Year 2005 Eradication Assistance as of June 2006 (in 
millions): 

Dollars in millions. 

Project: Central Government Support: Afghan Eradication Force (AEF) 
support; 
Provided: $104; 
Obligated: $68; 
Expended[A]: $15. 

Project: Central Government Support: Air mobility assets; 
Provided: 124; 
Obligated: 114; 
Expended[A]: 51. 

Project: Provincial Government Support: Governor-led eradication; 
Provided: 6; 
Obligated: 6; 
Expended[A]: 0. 

Project: Provincial Government Support: Poppy Elimination Program (PEP) 
teams; 
Provided: 24; 
Obligated: 16; 
Expended[A]: 3. 

Project: Total; 
Provided: $258; 
Obligated: $204; 
Expended[A]: $69. 

Source: Department of State. 

[A] According to a Department of State official, actual expenditures 
may be higher than reported figures due, in part, to delays in 
receiving bills from other agencies, international organizations, and 
contractors. 

[End of table] 

Central Eradication Efforts Improved, but Fielding Was Delayed: 

State provided $104 million to support the AEF's operating costs and 
purchase of additional equipment,[Footnote 12] and $124 million to 
purchase and lease aircraft to move the force around the country. These 
efforts were intended to address the challenges faced by the AEF's 
predecessor, the Central Poppy Eradication Force (CPEF). According to 
State officials, the CPEF's operational procedures and lack of mobility 
made getting the force into the field and supplying it difficult. For 
example, a senior State official stated that because the CPEF operated 
as one large unit and traveled in convoys on the roads, impassable 
roads slowed or stopped their getting out to planned locations. 
Moreover, because the CPEF lacked logistical support, they had to 
return to Kabul to re-supply. In 2005, UNODC reported, but did not 
verify, that the CPEF eradicated about 210 hectares of opium poppy and 
the Afghan National Police eradicated about 890 hectares. 

After the 2005 season, the CPEF was renamed the AEF and reorganized 
into four smaller and more mobile units of 150 counternarcotics police 
each. One half of this police force provided security while the rest 
served as eradicators and support. The teams could be deployed in 
multiple areas of the country simultaneously. In order to carry out its 
eradication efforts, the force was expected to have the mobility to get 
into the field and the logistics to remain there. State paid for a "wet 
lease"[Footnote 13] of four Russian-made aircraft and the purchase and 
operating costs of ten U.S. Huey-II helicopters (see fig. 5). The 
leased aircraft were used primarily for troop and cargo transport to 
support reconnaissance, establish camps, and deploy the AEF, while the 
Huey-II helicopters provided enhanced security, reconnaissance, and 
medical evacuation capacity, as well as limited personnel and cargo 
transport for the AEF. The aircraft were also used to provide 
additional lift and transport support to the PEP teams and embassy 
personnel. The addition of airlift at airfields from Kabul, Parvan, and 
Kandahar, and other vehicles allowed the AEF to travel more easily and 
remain in the field for longer periods. 

Figure 5: Huey-II Helicopters in Kandahar: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

In 2006, UNODC reported the AEF eradicated an estimated 2,250 hectares 
of opium poppy in Helmand and Badakshan provinces (see fig. 
6).[Footnote 14] Although the AEF eradicated over ten times the amount 
eradicated by the CPEF in 2005, its initial deployment was delayed. 
According to USAID and State officials, the governor of Helmand wanted 
additional alternative livelihoods projects in place before allowing 
the AEF to begin working. Moreover, State officials stated that because 
of the security risks in Helmand, the AEF needed the Afghan National 
Police and Afghan National Army to provide security. However, 
coordinating their efforts to assist the AEF proved time-consuming. The 
combination of these challenges pushed the AEF's fielding date back 
from early February 2006 until late March 2006. Because most poppy 
growth occurs over a two-month period, the AEF's fielding delay 
prevented them from eradicating as much as it might have had it been 
fielded in February, as intended. 

Figure 6: AEF Conducting Manual and Mechanized Eradication in Helmand: 

[See PDF for image] 

Source: Department of State. 

[End of figure] 

Governor-Led Eradication Improved, but PEP Teams Were Not Fully 
Fielded: 

State provided $6 million for equipment and training to provincial 
authorities to conduct eradication activities and $24 million to create 
seven provincial PEP teams to discourage poppy cultivation in the 
provinces where it is most prevalent--Badakshan, Balkh, Farah, Helmand, 
Kandahar, Nangarhar, and Oruzgan. Beginning in 2003, at the initiative 
of President Karzai, provincial governors were given the responsibility 
for carrying out their own eradication efforts with the financial 
support of the central government and donors. In 2005, governor-led 
eradication was responsible for more eradication than the central 
government's efforts. UNODC reported and verified about 4,000 hectares 
of governor-led eradication.[Footnote 15] 

In response to the larger amount of eradication conducted by governors 
than the central government in 2005, State decided to increase support 
for provincial authorities by reimbursing governor-led eradication 
efforts and creating the PEP teams. In 2006, State began to reimburse 
provincial authorities for their eradication expenses at a rate of $60 
per hectare of UNODC-verified eradication. However, when UNODC was not 
able to verify provincial efforts, the governor was reimbursed based on 
his submitted expenses.[Footnote 16] According to State officials, they 
also wanted to enhance governor efforts to eliminate poppy cultivation 
by creating the PEP teams attached to the offices of the seven 
provincial governors where poppy cultivation was greatest. The teams 
were planned to consist of seven Afghan advisors hired by the Afghan 
Ministry of Counter Narcotics and two international advisors hired by 
the United States. PEP teams were to assist the provincial governors in 
discouraging farmers from growing poppy and encouraging farmers to 
eradicate their own poppy fields by coordinating antinarcotics public 
information messages, ensuring delivery of assistance projects from all 
donors, and assisting with verification of reported eradication. These 
teams were also designed to be closely integrated with the public 
information campaign by helping to identify local messages and local 
leaders to assist with the campaign, as well as to assist central 
government counternarcotics efforts by reporting on any obstacles that 
inhibit achieving provincial poppy reduction goals. 

Even though the PEP teams were not fully fielded, governor-led 
eradication, according to UNODC, more than tripled in 2006, to an 
estimated 13,050 hectares. Governor-led eradication took place in 19 
provinces and was again responsible for more eradication than central 
eradication forces. Each PEP team was intended to be fully staffed and 
provided security and housing by the end of 2005, however State did not 
fully field the PEP teams because its contractor was unable to hire all 
of the international advisors and supply each team with the required 
security, housing, and equipment in time for the 2005 growing season. 
As of June 2006, 11 of 14 international PEP advisors had been hired. 
Moreover, the Afghan government did not hire all the required Afghan 
nationals to staff each team. Because the teams were not fully fielded, 
they were unable to work as intended with provincial officials to 
coordinate alternative livelihoods projects, assist with eradication 
verification as planned, or coordinate public information projects to 
discourage poppy growing. 

Interdiction: Border Security Projects Begun, but State's Support of 
Counternarcotics Police Delayed: 

As seen in table 6, State provided $65 million to support DEA-led 
interdiction efforts[Footnote 17] to help build Afghan capacity to 
destroy drug labs, seize precursor chemicals and opiates, and arrest 
major traffickers. State's efforts to enhance border security in 
neighboring countries that serve as transit points for narcotics are 
under way. State also planned to provide support for the CNPA and NIU, 
but these projects were delayed while State awaited the results of 
recently completed police-reform efforts and construction of a new 
facility. 

Table 6: Fiscal Year 2005 Interdiction Assistance as of June 2006 (in 
millions): 

Project: Border Security Enhancements; 
Provided: $41; 
Obligated: $41; 
Expended[A]: $2. 

Project: Counternarcotics Police Support; 
Provided: 24; 
Obligated: 3; 
Expended[A]: 0. 

Project: Total; 
Provided: $65; 
Obligated: $44; 
Expended[A]: $2. 

Source: Department of State. 

[A] According to a Department of State official, actual expenditures 
may be higher than reported figures due, in part, to delays in 
receiving bills from other agencies, international organizations, and 
contractors. 

[End of table] 

Border Security Enhancements Ongoing: 

State provided $41 million to enhance border security in the 
neighboring countries that often serve as transit points for drug 
traffickers, including $30 million in Pakistan, $9 million in 
Tajikistan, and $2 million in Turkmenistan. The planned assistance to 
Pakistan included the purchase of vehicles and equipment for Pakistan's 
Frontier Corp to conduct counternarcotics and border security and 
Pakistan's Anti Narcotics Force to support poppy eradication and 
interdiction operations, as well as the purchase of pre-fabricated 
steel bridges to increase mobility in the Federally Administered Tribal 
Areas. The planned assistance for Tajikistan and Turkmenistan included 
the purchase of vehicles and other equipment, upgrading of border 
posts, and the training of border police. 

State moved forward with border security enhancements. In Pakistan, 
State began purchasing vehicles, body armor, and surveillance gear for 
border security forces. State also issued a request for proposals for 
the purchase of the pre-fabricated bridges. In Tajikistan, State, 
working with UNODC and International Organization for Migration, 
started to equip forensics labs and a police-dog training center; 
ordered a variety of equipment for border police, including a 
communications system, ambulances, surveillance gear, and vehicles; and 
started refurbishing border posts such as the one seen in figure 7. In 
Turkmenistan, State transferred the funds to UNODC, with whom State was 
already working, to properly equip a major border checkpoint and 
provide relevant training to border control personnel. UNODC contracted 
with a company for construction and equipment. 

Figure 7: Khirmanjo, Tajikistan, Border Post Scheduled to Be 
Refurbished: 

[See PDF for image] 

Source: Department of State. 

[End of figure] 

State Support for Counternarcotics Police Delayed: 

State planned to provide $24 million to support the NIU and leadership 
of the CNPA, but the spending of these funds was delayed. Of these 
funds, State planned to spend $12.5 million to provide mentors, 
housing, equipment, and vehicles for the CNPA leadership, with the 
remaining funds going to operate and maintain the NIU Center for two 
years after its completion; provide equipment for the center; and for 
NIU vetting, training, and administrative costs. 

As of August 2006, State's support for the NIU was delayed while 
ongoing police reform plans were finalized and Defense completed 
construction of the NIU facility. Department of Defense-supported 
police reforms, according to State officials, notably pay and rank 
reform, were only recently completed, and State had been waiting until 
the CNPA's leadership was determined to begin using its support funds. 
The NIU facility is expected to be completed November 30, 2006, almost 
eight months later than the original completion date due, in part, to 
building modifications. 

Law Enforcement and Justice Reform: Efforts Led to New Counternarcotics 
Law and Supported Strengthening Corrections System: 

As seen in table 7, State provided nearly $24 million to support the 
Afghan government's efforts to increase its capacity to arrest, 
prosecute, and punish traffickers and corrupt officials. State brought 
in senior federal prosecutors from the Department of Justice to assist 
with legislative reform efforts, such as the crafting of the new 
counternarcotics law, and training investigators and prosecutors. State 
also began the Corrections System Support Program (CSSP) to develop a 
professional, accountable, and centralized Afghan corrections system. 
Under this program, State started training corrections personnel and 
constructing new facilities. State also planned support for the Counter 
Narcotics Justice Center, a counternarcotics court and detention 
facility. However, construction of the facility was still under way. 

Table 7: Fiscal Year 2005 Law Enforcement/Justice Reform Assistance as 
of June 2006 (in millions): 

Project: Justice prosecutors; 
Provided: $2; 
Obligated: $2; 
Expended[A]: $0. 

Project: Corrections Reform and Counternarcotics Center; 
Provided: 22; 
Obligated: 15; 
Expended[A]: 2. 

Project: Total; 
Provided: $24; 
Obligated: $17; 
Expended[A]: $2. 

Source: Department of State. 

[A] According to a Department of State official, actual expenditures 
may be higher than reported figures due, in part, to delays in 
receiving bills from other agencies, international organizations, and 
contractors. 

[End of table] 

Justice Prosecutors Reformed Counternarcotics Law, but Coordination 
Remained a Challenge: 

State transferred $2 million to the Department of Justice to continue 
to pay for U.S. prosecutors from the Criminal Division's Senior Federal 
Prosecutors' Program to provide legal and legislative assistance. The 
prosecutors worked in several areas, including: 

* reform of key laws and implementation of regulations and authorities; 

* design, planning, and coordination of training in fundamentals and 
advanced areas of the criminal law with emphasis on counternarcotics 
and antimoney laundering enforcement; and: 

* assessment of, mentoring of, and assistance to the Criminal Justice 
Task Force (CJTF), a specialized unit of investigators and prosecutors 
dedicated to working mid-and high-level narcotics and narcotics-related 
investigations and prosecutions. 

The Justice prosecutors, working with the government of Afghanistan, 
helped develop and implement a new comprehensive counternarcotics law 
that grants legal and investigative authority for mid-and high-level 
investigations and prosecutions to a new counternarcotics legal 
infrastructure apart from Afghanistan's national judicial system. The 
new law nationalized most drug crimes for investigation and prosecution 
by the CJTF and trial by the Central Narcotics Tribunal,[Footnote 18] 
diminishing local influences and chances of intimidation. The new law 
and the legal authorities it provides are the centerpiece of CJTF 
training developed by the United States. The Justice prosecutors, along 
with their international partners, have mentored and guided the CJTF in 
the successful prosecution of three mid-and high-level traffickers. The 
Justice prosecutors are providing advice on the drafting of a more 
modern and flexible criminal procedure code. The Justice prosecutors 
were also instrumental in having the government of Afghanistan effect 
its first-ever extradition to the United States of an Afghan narcotics 
trafficker. 

Corrections Reform Program Ongoing: 

State provided almost $16 million for the CSSP, which is designed to 
develop a professional, accountable, and centralized Afghan corrections 
system. The CSSP is expected to devise and conduct training for Afghan 
correctional officers and build and rehabilitate correctional 
facilities. 

The CSSP began training prison guards and constructing new buildings, 
with the award of the CSSP contract in March 2006. The contractor 
finished a survey of Afghan prisons, developed corrections training 
classes, trained its first 36 corrections officers at the Central 
Training Facility in Kabul, and continued training in three other 
provinces (see fig. 8). In addition, the CSSP contractor began 
construction of an attorney general's office and a courthouse in Wardak 
province (see fig. 9). 

Figure 8: Afghan Corrections Officer Training: 

[See PDF for image] 

Source: Department of State. 

[End of figure] 

Figure 9: Ministry of Justice Building under Construction in Wardak 
Province: 

[See PDF for image] 

Source: Department of State. 

[End of figure] 

Counternarcotics Center Delayed: 

State provided $6 million to pay the operations and maintenance costs 
of the Counter Narcotics Justice Center--a counternarcotics court and 
administrative offices for the CJTF and Central Narcotics Tribunal, as 
well as a detention facility, which is still under construction. 
According to Defense, State, and Justice, original plans called for 
Defense to erect a temporary building for the Counter Narcotics Justice 
Center. However, interagency discussions led to the decision to build a 
permanent set of structures, which delayed expected completion while 
new plans were drafted and a new contractor was chosen. Ongoing 
discussions may further modify the construction. 

The Counter Narcotics Justice Center is expected to be completed in 
November 2006, over three months later than the original completion 
date for the permanent structures. Additional modifications to the 
construction design, should they be funded, will further delay the 
completion of the facility. 

Public Information: Campaign Launched, but Not Fully Coordinated with 
PEP Teams: 

As shown in table 8, State provided $5 million to support a public 
information campaign intended to convince the Afghan populace to reject 
poppy cultivation and trafficking. State transferred almost $1 million 
to USAID for a grantee to begin a public information campaign. The 
campaign was designed to (1) develop and produce media materials to 
raise awareness and promote behavior change regarding poppy planting in 
Afghanistan, (2) establish a regional network to disseminate the 
materials and monitor and assess the efficacy of the campaign, and (3) 
support the government of Afghanistan in its efforts to eliminate poppy 
cultivation. State also provided almost $4 million for a new 
contractor, hired in May 2006, to continue and build on public 
information efforts. 

Table 8: Fiscal Year 2005 Public Information Assistance as of June 2006 
(in millions): 

Project: 2005-2006 Public Information Campaign; 
Provided: $5; 
Obligated: $5; 
Expended[A]: $1. 

Source: Department of State. 

[A] According to a Department of State official, actual expenditures 
may be higher than reported figures due, in part, to delays in 
receiving bills from other agencies, international organizations, and 
contractors. 

[End of table] 

The 2005 campaign, which used radio spots and printed media, was 
developed to target key poppy-growing provinces over three phases 
concerning (1) pre-planting, (2) pre-eradication and the health impact 
of drugs, and (3) eradication and the rule of law. The grantee 
established regional offices in the seven provinces with PEP teams to 
disseminate materials and monitor the campaign. The grantee completed 
the campaign on time between July 15, 2005 and May 15, 2006. According 
to information provided by State, over the three phases, the campaign 
paid for 41 radio spots that often featured prominent Afghans and were 
broadcast almost 9,000 times and prepared millions of stickers, 
matchboxes, booklets, posters, banners, and billboards, as illustrated 
in figure 10, to publicize the counternarcotics message. The grantee 
used focus groups and surveys to assess its efforts. A survey conducted 
in November 2005 of more than 2,200 Afghans reported that about 75 
percent of respondents had heard counternarcotics radio messages. 
During the last two phases of the campaign, the grantee worked with and 
paid the salaries of the Ministry of Interior's media office personnel. 

Figure 10: Public Information Campaign Stickers, Billboard, and 
Posters: 

[See PDF for image] 

Source: Department of state. 

Note: Actual stickers, billboards, and posters printed are in Pashto 
and Dari. 

[End of figure] 

Because of delays in getting PEP teams formed, the public-information 
grantee was unable to rely on expected PEP support during the 2005-2006 
poppy growing season. In several provinces, the grantee stated the PEP 
teams did not coordinate their public information activities or were 
not active in public information activities. In particular, the grantee 
had expected the PEP teams to assist in compiling a map of the schools, 
clinics, mosques, civil society organizations, and public gathering 
places in the provinces to use in identifying community stakeholders 
for delivery of public information materials. However, the grantee 
found most of the PEP teams provided no support in building the maps, 
and the grantee had to create them without the help of the provincial 
PEP teams. The new public information contract requires the contractor 
to implement the campaign in concert with the PEP teams. 

U.S. Counternarcotics Programs Face Several Challenges: 

The deteriorating security situation and the lack of Afghan capacity, 
including governmental institutions, are tremendous challenges to 
reducing illicit drug production and trafficking. The worsening 
security situation in Afghanistan threatens the achievement of the U.S. 
counternarcotics strategy. Additionally, the narcotics trade continues 
to undermine Afghanistan's fragile institutions by fostering persistent 
corruption and criminal activities. Consequently, U.S. officials and 
others have commented that combating narcotics in Afghanistan will take 
at least a decade. 

U.S. Counternarcotics Efforts Jeopardized by Worsening Security: 

Progress toward the achievement of the U.S. counternarcotics strategy 
in Afghanistan is threatened by the worsening security situation. USAID 
predicates the success of its reconstruction plans on an improving 
security situation, however, continued attacks prevent some projects 
from being implemented. Moreover, as we reported previously, State 
officials expect that drug processing and trafficking will continue 
until security is established.[Footnote 19] In early 2006,[Footnote 20] 
Afghanistan and the international community agreed to the Afghanistan 
Compact, which stated that "genuine security remains a fundamental 
prerequisite for achieving stability and development in Afghanistan." 

The central government faces various threats, including Taliban and 
terrorist attacks, tribal violence, and criminal activity. In 2006, 
U.S. officials acknowledged that violence was increasing, including the 
use of improvised explosive devices, such as the one used against the 
vehicle in figure 11, and suicide bombers.[Footnote 21] U.S. military 
officials also stated the presence and strength of the Taliban 
increased, particularly in the south; that they demonstrated better 
command and control and fighting with increased intensity; and that 
Afghanistan has seen the highest rates of violence since the Taliban 
regime was removed from power in 2001. Moreover, UN accessibility maps 
that denote the risk level of different areas of Afghanistan also show 
that the security environment in many areas of Afghanistan has worsened 
noticeably. 

Figure 11: Aftermath of April 7, 2006, Improvised Explosive Device 
Attack on Government Vehicle in Helmand: 

[See PDF for image] 

Source: Department of Defense. 

[End of figure] 

During the 2005-2006 growing season, eradication forces and alternative 
livelihoods personnel were attacked several times and in some cases 
killed, slowing or preventing their efforts. 

* In a two-week period in March 2006, Helmand had 20 confirmed security 
incidents, including 4 rocket attacks, 8 improvised explosive devices, 
5 assassinations, and 3 incidents of intimidation against public 
officials. U.S. officials said that many of the incidents were related 
to the eradication campaign. 

* In April 2006, AEF came under direct attack and encountered 
improvised explosive devices and mines while eradicating in Helmand 
province, including a mine that exploded on April 10, killing two AEF 
security personnel and wounding two others. 

* In May 2006, the alternative livelihoods contractor in the north 
reported that two staff members were killed when their vehicle was 
struck by an improvised explosive device. USAID and contractor 
officials stated the attack may have occurred in retribution for the 
contractor's discovery of fraud on one of its cash-for-work projects, 
or may have been because of eradication occurring in the area. 

* That same month, AEF had a standoff with farmers in Badakshan 
province, and in June, came under small arms fire that injured two AEF 
police. 

* Also in May, in Nangarhar, where the security situation had been more 
permissive, the alternative livelihoods contractor reported that 
antigovernment groups were offering rewards for conducting attacks in 
the region. 

* In June 2006, State decided not to allow the PEP international 
advisors to move into their housing in Oruzgan province until the 
threat level diminished and construction of an office complex could 
begin. 

* During the first half of June 2006, the USAID contractor reported 
that Afghan nationals were threatened with retribution if they 
participated in alternative-livelihoods projects. This circumstance, 
combined with the travel restrictions resulting from the volatile 
security situation, restricted the progress of road construction and 
irrigation system repairs. 

Afghan Infrastructure, Human Capital, and Government Institutional 
Capacities Are Limited: 

Reducing opium cultivation and drug trafficking in Afghanistan will 
take at least a decade, in part because of the need to address 
Afghanistan's lack of infrastructure, human capital, and government 
capacity. According to U.S., International Monetary Fund, and other 
officials, the impoverished country lacks adequate roads and access to 
power; its labor force is mostly illiterate and untrained; and the 
government, saddled with prevalent corruption, has a weak judicial 
sector and is not expected to be able to cover its own expenses in the 
near future. These limitations discourage investment in Afghanistan and 
make Afghanistan dependent on foreign assistance. 

The nation has few roads and poor access to power. Furthermore, the 
lack of roads makes it difficult for farmers to get goods to markets 
and the lack of electricity makes it difficult for farmers to store 
perishable goods. Afghanistan has one major highway, the "ring-road," 
but access to certain areas can still take weeks or more and, during 
winter months, some areas are completely inaccessible, according to 
U.S. and UN officials. In Badakshan, the alternative livelihoods 
contractor reported that significant upgrades to the primary road 
networks were needed in order to allow farmers to deliver fresh 
vegetables to market centers without the produce being bruised, 
smashed, or otherwise damaged. Further, project staff reported that 
they were unable to visit some field sites in the province at the end 
of April 2006 because of heavy rains that made the roads impassable. 
The lack of reliable power was cited as a major concern by potential 
investors. In the short term, USAID intends to provide generators for 
the industrial parks it is planning to build to assure investors of 
reliable power. 

Afghanistan's human capital provides another capacity problem as most 
of the population is illiterate and many are untrained. U.S. and UN 
officials stated that illiteracy is a tremendous problem, making it 
difficult to recruit police, prosecutors, and investigators, adding 
that even some provincial governors are illiterate. Furthermore, the 
high illiteracy further complicated efforts to train Afghans, and the 
lack of trained personnel meant that even government ministries had few 
adequately trained staff. For example, the UN provided the Afghans a 
small lab for drug testing, but it had to be staffed and funded by the 
UN. 

Capacity is also a challenge for Afghanistan's government; corruption 
is endemic, the judicial sector is weak, and the government is not 
expected to be able to support itself for at least 10 years, according 
to U.S. and other officials. 

* According to U.S. embassy officials, most Afghan public salaries are 
very low, which makes corruption more likely. Moreover, corrupt 
officials are rarely removed from their government jobs, but are 
instead reassigned. For example, as mentioned earlier, corrupt 
eradicators accepted bribes to skip certain poppy fields, which 
eliminated the biggest deterrent to poppy cultivation. In addition, 
corrupt judicial officials reduce the fear of legal repercussions for 
drug traffickers. 

* U.S. officials stated that rebuilding the judicial sector of 
Afghanistan lagged behind the other four security pillars--army, 
police, combating drugs, and disarmament. In 2005, we reported that 
overall justice sector reform was underfunded and 
understaffed.[Footnote 22] To date, four years after the Geneva 
conference established the five-pillared security agenda, work to 
establish a permanent criminal code has not been completed. 

* According to State officials, the government will be unable to 
support its recurring costs without foreign assistance for at least 10 
years. In 2004-2005, Afghan government revenues equaled less than one- 
third of its recurring expenditures. Consequently, Afghanistan remains 
dependent on other nations for over half of its budget. 

USAID and State Made Efforts to Oversee the Use of Funds, but Lack of 
Information and Security Limited Some Efforts: 

In an effort to prevent counternarcotics funds from assisting 
terrorists, drug traffickers, or human rights violators in Afghanistan, 
USAID and State required that grantees sign antiterrorism and 
antitrafficking certifications, financial agreements contain 
antiterrorism and antitrafficking clauses, and Afghan security 
personnel receiving training be vetted for associations with prohibited 
activities when applicable. However, a lack of official records and 
reliable information limited efforts to vet Afghan nationals. In 
addition, although USAID and State made efforts to monitor ongoing 
projects to ascertain their status, security concerns and poor 
infrastructure limited the agencies' monitoring of sites outside Kabul. 

Agencies Required Certifications, Clauses, and Vetting to Help Prevent 
Funds from Being Used for Prohibited Purposes, but Lack of Information 
Hampered Vetting: 

To comply with federal bans on assisting terrorists, drug traffickers, 
and human rights violators,[Footnote 23] USAID and State required that 
grantees certify their nonsupport of prohibited individuals or groups; 
that financial agreements contain clauses outlining U.S. prohibitions; 
and that candidates for security training or assistance are vetted. 

* Certifications. USAID issued guidance requiring that recipients of 
all grants and cooperative agreements sign certifications attesting 
that they are not supporting, and have not supported, terrorists. In 
signing the certifications, recipients also acknowledged the steps they 
are to take to help prevent assistance from being provided to 
terrorists, including reviewing U.S. and UN lists of known terrorists. 
In addition, USAID and State require recipients of assistance to 
certify that they have not been convicted of, or involved in, a 
narcotics offense.[Footnote 24] We reviewed USAID grants and contracts 
and found that the required certifications were included where required 
by USAID's regulations. According to State, its letter of agreement 
with the government of Afghanistan requires that each recipient of 
foreign assistance sign a certification disclosing any past 
narcotrafficking. State also included this requirement in fund 
transfers to USAID, Justice, and Defense. 

* Clauses. USAID requires that financial agreements, including 
contracts and grants, contain a clause intended to familiarize award 
recipients with their legal responsibilities to comply with the 
executive order and law prohibiting assistance to terrorists.[Footnote 
25] In addition, both USAID and State require that any financial 
agreement representing more than $100,000 contain a clause to 
familiarize award recipients with their legal responsibilities to 
comply with the law prohibiting assistance to drug traffickers. In our 
review of the 10 alternative livelihoods program grants and contracts, 
we found that each agreement included the clauses that were required. 

* Vetting. USAID and State require the vetting of individuals and 
organizations for involvement with drug trafficking, through the review 
of arrest records and assessment of the credibility of any trafficking 
allegations. State also requires the vetting of individuals and 
organizations against criminal and terrorist databases for any 
involvement in terrorism or human rights violations. According to 
State, the U.S. embassy runs initial screening of security force 
personnel against local databases and with nongovernmental 
organizations. State then forwards biographical data on security forces 
to the Bureau of Democracy, Human Rights and Labor and Bureau of South 
and Central Asian Affairs for vetting against classified and 
unclassified databases to identify criminal conduct, including that 
related to terrorism, narcotrafficking, and human rights violations. 
However, USAID's and State's vetting of Afghan nationals was 
constrained by limited or incomplete records and the difficulty of 
investigating widespread allegations of misconduct. According to State, 
USAID, and contract officials, after years of conflict, Afghanistan 
lacks many official records, such as birth, identification, and 
criminal records. According to U.S. officials, this lack of records 
forced them to rely on word of mouth to vet Afghan nationals. Moreover, 
rivals often accuse one another of criminality and affiliation with 
terrorists or drug traffickers, and it is difficult to investigate the 
truth of these allegations. To assist with future vetting, State plans 
to administer lie-detector tests to certain project participants. 
However, as of July 2006, State had not been able to initiate the 
testing. 

Efforts Made to Monitor Projects, but Access to Project Sites Is 
Limited: 

USAID and State monitor project performance through contractor reports, 
site visits, and information from third parties, such as the U.S. 
military or Afghan officials, as access to project sites outside Kabul 
is difficult because of security conditions and poor infrastructure. 
Contractors developed performance management plans, which include 
performance indicators, a monitoring and evaluation plan, and reporting 
requirements. Furthermore, according to U.S. officials, USAID and State 
used experienced U.S. firms and international organizations as the 
primary grantees and contractors. For example, State hired DynCorp 
International, a company that State uses to carry out counternarcotics 
efforts in Colombia and elsewhere, to implement its eradication efforts 
and used the UN to carry out some of the border security station 
rehabilitation in Tajikistan. USAID hired three U.S. firms already 
experienced with working in Afghanistan--Chemonics International; 
Development Alternatives, Inc; and Planning and Development 
Collaboration International--to run its alternative livelihoods 
projects. 

USAID attempted to assess progress through various means. First, 
USAID's contractors submitted required biweekly reports detailing 
challenges and progress in their respective provinces. For example, in 
May 2006, the contractor in the south reported that "security concerns 
have dramatically decreased project activities… as such, no monitoring 
visits were conducted." During the same period, the contractor in the 
east reported they were able "to monitor active and completed cash-for- 
work projects." In addition to these reports, USAID assigned a project 
officer to each region's provincial reconstruction teams' compound to 
be responsible for monitoring the contract. They attempted to get to 
the field as often as possible to view the progress of projects and 
assist in developing new ones. USAID also relied on the local U.S. 
military commanders and Afghan officials to report on the status of any 
projects they saw. For example, the U.S. commander in Nangarhar told us 
during our visit that when he goes on routine patrols, he tries to 
visit any USAID projects in the vicinity of his patrol and provides any 
information from those patrols to the resident USAID representative. 

State contractors and other implementers of State-funded projects 
submitted the required reports on the progress and obstacles facing 
their projects. For example, DynCorp submits biweekly reports detailing 
the activities of the leased aircraft, AEF, and PEP teams, and 
reporting on problems, such as the challenges of hiring qualified 
international advisors for the PEP teams. In addition, State personnel 
stated that they regularly travel to program sites. For example, State 
staff made visits to the AEF while it was out in the field. Similarly, 
the Justice prosecutors stated that they work several times a week with 
the CJTF. 

Despite these efforts, external factors, such as security and 
Afghanistan's poor infrastructure, limited project monitoring by 
reducing USAID's, contractors', and, to a lesser extent, State's access 
to project sites. For example, in Helmand, the monitoring and 
evaluation plan developed by USAID's alternative livelihoods contractor 
could not be implemented because of the danger to both Afghans and 
foreign nationals traveling in the area. Additionally, USAID field 
staff were constrained by security rules and restrictions established 
by the military commanders in their areas. For example, in Nangarhar, 
monitoring staff must provide U.S. commanders 96-hours notice for trips 
outside the military camp, and these trips can be cancelled at any time 
if sufficient military personnel are not available to provide security. 
Poor infrastructure limits the ability to monitor projects. In northern 
Afghanistan, many roads are impassable during the winter months. 
Furthermore, many areas can only be reached via helicopter or on foot, 
as no roads exist. State projects in and around Kabul are more 
accessible, and, therefore, are easier to monitor. Additionally, the 
eradication efforts funded by State are being monitored by UNODC in 
cooperation with Afghanistan's government and are also confirmed 
through satellite and other imagery. However, UNODC was unable to send 
ground monitors to Helmand to verify governor-led eradication efforts 
there. 

Concluding Observations: 

Despite significant efforts by USAID and State, the deteriorating 
security situation in Afghanistan threatens the success of the U.S. 
counternarcotics goal of significantly reducing illicit drug 
cultivation, production, and trafficking. Unlike in our prior reports 
concerning other programs in Afghanistan, we found USAID and State had 
developed a strategy for counternarcotics tailored to Afghanistan's 
difficult environment. They reported some accomplishments in each of 
the strategy's five pillars; nevertheless, the opium poppy crop in 2006 
grew by over 50 percent, reaching a record amount. The worsening 
security situation, particularly because of the Taliban's resurgence, 
threatens to derail U.S. efforts by slowing or stopping projects. 
Moreover, the pace of U.S. efforts was further slowed by the country's 
persistent developmental challenges, including inadequate access to 
roads and limited government institutions. Given the difficulties of 
working in Afghanistan, sustainable progress toward the U.S. 
counternarcotics goal will likely take a decade or more of committed 
U.S. resources and efforts. Because many of the counternarcotics 
projects are still in the early stages of implementation, we have no 
recommendations at this time. 

Agency Comments: 

We provided a draft of this report for review and comment to State, 
USAID, Defense, and Justice. Each agency informed us that they were not 
providing formal comments. However, USAID and Justice provided 
technical comments, which we have incorporated into the report where 
appropriate. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3149 or GootnickD@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made contributions to 
this report are listed in appendix II. 

Signed by: 

David Gootnick, Director: 
International Affairs and Trade: 

[End of section] 

Appendix I: Scope and Methodology: 

To examine the U.S. Agency for International Development's (USAID) and 
Department of State's (State) progress in implementing counternarcotics 
programs, projects, and activities under each pillar, and the factors, 
if any, limiting implementation, we reviewed pertinent USAID and State 
planning, funding, and reporting documents for their counternarcotics 
programs in Afghanistan. Our review of these documents provided us with 
information regarding the program's structure, goals, objectives, 
progress, and limitations. In addition, we met with cognizant officials 
from Departments of Defense (Defense), Justice (Justice), and State; 
USAID; and Drug Enforcement Administration (DEA) in Washington, D.C. 
and Kabul, Afghanistan. In Kabul, we also met with officials from the 
United Nations (UN) and the governments of Afghanistan and the United 
Kingdom to discuss counternarcotics efforts. We traveled to the 
provinces of Balkh, Helmand, Kandahar, and Nangarhar to meet with U.S. 
and Afghan officials and discussed various U.S.-funded projects. For 
example, in Helmand and Nangarhar, we met with the governors to discuss 
the progress of USAID's alternative livelihoods projects, visited 
several projects, and met with U.S. contractors implementing the 
projects. In Balkh, we met with the governor to discuss the governor- 
led eradication efforts and how U.S. assistance was being used. While 
in Kandahar, we met with State contractors and observed the aircraft 
being used to enhance the AEF's eradication efforts. 

To examine the challenges faced by counternarcotics efforts in 
Afghanistan, we reviewed USAID, State, and Defense documents addressing 
the status of U.S. efforts in Afghanistan. Additionally, we reviewed 
UN, International Monetary Fund, and academic reports regarding the 
current security and economic situation in Afghanistan, as well as 
discussing its past problems and outlook for the future. Specifically, 
we reviewed several months of UN reporting on the security situation in 
Afghanistan in regards to what precautions their personnel needed to 
take. In addition, we met with experts and attended academic symposia 
in Washington, D.C., regarding Afghanistan's current situation and the 
challenges it faces in the future. 

To examine USAID's and State's efforts to ensure that the fiscal year 
2005 counternarcotics funds were used for intended purposes, we 
reviewed the contracts, grants, and other financial agreements by which 
these funds were obligated and expended. We reviewed USAID contracts 
and State financial instruments that received fiscal year 2005 
counternarcotics funding. We met with USAID and State budget and 
financial officers in Washington, D.C., and Kabul to discuss the 
safeguards placed on the funds. Additionally, we talked to several 
contractors in Afghanistan about their monitoring plans and ability to 
implement them. 

To determine the reliability of the funding data, we compared data from 
multiple sources. For example, we compared the funding data we received 
from USAID and State with the appropriations language and congressional 
notifications. Although we did not audit the funding data and are not 
expressing an opinion on them, based on our examination of the 
documents received and our discussions with cognizant agency officials, 
we concluded that the funding data we obtained were sufficiently 
reliable for the purposes of this report. To determine the reliability 
of United Nations Office on Drugs and Crime (UNODC) eradication and 
opium poppy cultivation data, we reviewed the methodology used to 
estimate the areas where opium poppy was cultivated in Afghanistan in 
2005. In particular, we reviewed the sampling and estimation procedures 
used, the ways in which satellite imagery was incorporated into the 
estimate, and the procedures followed by the ground surveyors. We noted 
that the sampling methods were appropriate for generating estimates for 
Afghanistan as a whole, but that there were limitations to the 
estimates for particular provinces. Overall, we determined that the 
methodologies used by the UNODC were reasonable, and that the results 
were sufficiently reliable for the purposes of this report. To 
determine the reliability of Afghan public opinion survey data, we 
reviewed the survey methodology used by the Afghan Center for Socio- 
economic and Opinion Research, and determined it to be sufficiently 
reliable for our purposes. The information on foreign law in this 
report does not reflect our independent legal analysis, but is based on 
interviews and secondary sources. 

However, because of the security situation in Afghanistan, we could not 
independently verify or randomly test USAID or State project 
information at field locations. Nevertheless, based on our assessments 
of the data provided, our discussions with the cognizant officials, and 
limited field visits, we concluded that the counternarcotics program 
data provided to us were sufficiently reliable for the purposes of this 
report. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David Gootnick, (202) 512-3149: 

Staff Acknowledgments: 

Key contributors to this report were Al Huntington, Hynek Kalkus, 
Thomas Costa, Elizabeth Repko, Reid Lowe, and David Bruno. 

FOOTNOTES 

[1] Opium, which can be used to produce morphine and heroin, is derived 
from the opium poppy. 

[2] United Nations Office of Drugs and Crime, Afghanistan Opium Survey 
2005 (Nov. 2005). This report provides comprehensive survey results and 
statistics on Afghanistan's 2004-2005 opium cultivation season. 

[3] In 2002, the international community established a security reform 
agenda for Afghanistan with five pillars--establishing a national army, 
reforming the police, countering illicit narcotics, reforming the 
judicial system, and disarming militia groups--and designated a donor 
country to take the lead in reforming each pillar. For more information 
see, GAO, Afghanistan Security: Efforts to Establish Army and Police 
Have Made Progress, but Future Plans Need to Be Better Defined, GAO-05-
575, (Washington, D.C.: June 30, 2005). 

[4] Most of these funds were provided by the Emergency Supplemental 
Appropriations Act for Defense, the Global War on Terror, and Tsunami 
Relief of 2005, P.L. 109-13, enacted on May 11, 2005. 

[5] P.L. 109-13, Sec. 2105. 

[6] We were not mandated to examine funds administered by Defense and 
DEA. 

[7] Presidential elections were held in October 2004. National Assembly 
and provincial elections were held in September 2005. 

[8] GAO, Afghanistan Reconstruction: Deteriorating Security and Limited 
Resources Have Impeded Progress; Improvements in U.S. Strategy Need, 
GAO-04-403, (Washington, D.C.: June 2, 2004), and GAO, Afghanistan 
Reconstruction: Despite Some Progress, Deteriorating Security and Other 
Obstacles Continue to Threaten Achievement of U.S. Goals, GAO-05-742 
(Washington, D.C.: July 28, 2005). 

[9] GAO-05-575. 

[10] USAID and State plan to use $350 million of the funds made 
available by the Foreign Operations and Related Programs Appropriations 
Act, 2006 (P.L. 109-102), to continue their counternarcotics programs 
in Afghanistan. 

[11] State did not receive all of the supplemental appropriations until 
August 2005 because it had to provide congressional notifications of 
its spending plans. This process took about three months. 

[12] State purchased land vehicles, body armor, small arms, ammunition, 
communications equipment, and other goods. 

[13] A lease for aircraft is termed a "wet lease" when the lease 
includes the cost of the fuel, as well as operation, maintenance, and 
other costs associated with usage of the aircraft. 

[14] State also reported about 35 hectares of eradication in Baghlan 
province. 

[15] UNODC verifies eradication results with on-the-ground, trained 
observers and aerial and satellite photography. 

[16] For example, expenses in Helmand included the rental fees for 
vehicles and salaries of provincial eradicators. 

[17] DEA focused most of its enforcement program and funding on (1) 
expanding the Afghanistan aspects of Operation Containment, a multi- 
national, law enforcement initiative that targets high-level drug 
trafficking organizations; (2) deploying Foreign-deployed Advisory and 
Support Teams (FAST) that work with the Afghans to carry out 
interdiction operations; and (3) advising and training the NIU, the 
primary narcotics investigators under the CNPA. 

[18] The Central Narcotics Tribunal is a specialized court that has 
exclusive nationwide jurisdiction for the trial and appellate review of 
mid-and high-level narcotics offenses. 

[19] GAO-05-575. 

[20] The Afghanistan Compact was agreed to at the London Conference, 
which took place from January 31 through February 1, 2006. 

[21] In June 2004 and July 2005, we reported security was 
deteriorating. See GAO-04-403 and GAO-05-742. 

[22] GAO-05-575. 

[23] Executive Order 13224 blocks property and prohibits transactions 
with persons who commit, threaten to commit, or support terrorism, and 
18 USC 2339A and 2339B criminalizes the knowing provision of material 
support or resources, including financial support, lodging, equipment, 
transportation, training, and expert advice, to terrorists or foreign 
terrorist organizations. Section 487 of the Foreign Assistance Act of 
1961, as amended (codified at 22 USC 2291f), and Code of Federal 
Regulations, Title 22, Part 140, implementing the act, prohibit 
assistance to drug traffickers and require the President to take all 
reasonable steps to ensure that U.S. assistance is not provided to drug 
traffickers. The "Leahy Amendment," which has been regularly 
incorporated into foreign operations appropriations bills, prohibits 
security assistance to foreign security force units implicated in human 
rights violations. 

[24] The regulations implementing section 487 of the Foreign Assistance 
Act (22 CFR 140), allow for certain exceptions, including assistance to 
small farmers when part of a community-based alternative development 
project. 

[25] USAID issued the guidelines requiring the antiterrorism clause and 
certification although it was not legally required to do so. State has 
not issued, and is not required to issue, such guidance or procedures. 

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