End Use Monitoring · 4 of 5
Monitoring is not conducted only from an embassy. The Golden Sentry program includes in country visits, and the manual names three types: familiarization and assistance visits, compliance assessment visits with a remote variant, and focused verification assessments (SAMM C8.5.1).
They differ in purpose rather than in intensity alone. One is help, one is audit, and one is investigation. A partner or a supplier working alongside one of them is in a different situation in each case.
The purpose of a familiarization visit is to help the partner, the embassy office and the combatant command build a working compliance program. It also lets the visiting team judge what future visits will require (SAMM C8.5.2).
A visit can be prompted by a request from the partner, the embassy office, the combatant command or another United States stakeholder. It can equally be prompted by the introduction of a specific article into the country (SAMM C8.5.2).
The timetable is published. A country clearance message goes out not later than 30 calendar days before the visit, identifying the major topics. The itinerary is finalized 15 calendar days before, including entry arrangements for any storage sites to be visited. An after action report is prepared not later than 15 calendar days after the team returns (SAMM C8.5.2).
The manual is careful about what this visit is not. It is not intended to perform physical inventories or compliance assessments, although a team may observe issues during the visit that must be addressed immediately (SAMM C8.5.2).
A compliance assessment visit reviews two things at once. It evaluates the embassy office against Golden Sentry policy and procedures, using a published checklist, and it evaluates the partner against the physical security and accountability requirements and other terms in the transfer agreement (SAMM C8.5.3).
Activities may include storage site visits, review of records and documentation, review of routine and enhanced monitoring procedures, and inventories of United States provided articles. Visits are coordinated in advance with the combatant command, the embassy office and the partner, and are arranged to coincide with the partner's own scheduled inventory dates where possible (SAMM C8.5.3).
One line in that section is worth reading twice by anyone arranging access. "Inability to obtain proper entry credentials for the CAV or VCA Team from the partner will result in unfavorable reports" (SAMM C8.5.3). A visit that cannot happen is recorded as a failure, not as a neutral event.
A virtual assessment covers the same ground remotely, and is used where travel is impeded or other limitations apply. The manual states its limit plainly: "a VCA does not provide the same degree of assessment as a CAV" (SAMM C8.5.4).
The outcome is a grade. "The CAV or VCA ratings are Outstanding, Satisfactory, Needs Improvement, and Unsatisfactory" (SAMM C8.5.6).
On the American side the checklist covers (SAMM C8.5.6.1):
On the partner side, responsibilities come from the terms of the transfer agreements themselves. They include cooperation with the assessments and resolution of potential violations found or previously reported. They also include implementation of physical security and accountability measures at storage sites holding designated articles. And they include reporting of losses, of the action taken to prevent further ones, and of any demilitarization, disposal, destruction, expenditure or other change of end use (SAMM C8.5.7).
The third kind of visit is not routine at all. Its purpose is to examine possible violations of section 3 of the Arms Export Control Act, section 505 of the Foreign Assistance Act, and any applicable diplomatic notes or agreements (SAMM C8.5.8).
It may be prompted by intelligence reports or other sources indicating that a partner may be using United States provided articles in a way that does not comply with American law and policy. Each one is handled case by case, conducted as quickly as foreign travel coordination allows, and directed at the discretion of the Director of the Defense Security Cooperation Agency (SAMM C8.5.8).
A declaration that an area is hostile identifies it as unsafe for personnel because of instability, conflict or other dangers. What that declaration does to monitoring depends entirely on who issued it (SAMM C8.5.9).
A combatant commander, an ambassador or another authorized official may declare a hostile environment for force protection reasons. That declaration restricts the movement of people. It does not change the monitoring obligation: "such a declaration does not modify EUM related policies, processes, or procedures" enacted to comply with the statute (SAMM C8.5.10). Where an article cannot be assessed for that reason, a specific disposition status is recorded in the portal with the declaration uploaded as supporting evidence.
Only one authority can change the procedures themselves. The Director of the Defense Security Cooperation Agency holds the delegated authority to declare a hostile environment that formally modifies monitoring policies, processes and procedures, case by case, with detailed guidance issued for each instance (SAMM C8.5.11).
Even then, accountability is established before anything moves. An initial 100 percent inventory, by serial number, of all designated articles is conducted before shipment or delivery into a declared hostile environment area (SAMM C8.5.12).
"When USG-led EEUM assessments are not feasible for DSCA declared hostile environment areas, partner self-reporting may be allowed with DSCA authorization and at the discretion of DSCA" (SAMM C8.5.13). Three documents are required before that is considered. The first is a combatant command memorandum, endorsed at senior level, setting out the security situation. The second is a partner signed control plan for each designated article. The third is a partner signed concept of operations describing how it will self report (SAMM C8.5.13).
Self reported records are not accepted loosely. All documentation must carry the article description, the serial number of each article, the date it was observed, and its current disposition status (SAMM C8.5.14). The status recorded in that situation states that the article was observed by the partner rather than by American personnel, so the record shows how the accountability was obtained.
| FAV | Familiarization and assistance visit, to help build a compliance program. SAMM C8.5.2. |
|---|---|
| CAV | Compliance assessment visit, the audit of embassy and partner compliance. SAMM C8.5.3. |
| VCA | Virtual compliance assessment, the remote form of a CAV. SAMM C8.5.4. |
| FEVA | Focused end use monitoring verification assessment, used to examine possible violations. SAMM C8.5.8. |
| Hostile environment | A geographic area formally identified as unsafe for personnel. SAMM C8.5.9. |
Every statement above links to the document behind it. The full source list for this piece is on the sources page.
This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.
Assessment visits happen in places where moving people in and out safely is the first problem. Sentfore provides secure movement, protective security, accommodation and life support in difficult environments, and its principals have worked on overseas defense and security programs there. Requirements can be sent through the contact page.