Planning a compliance visit, and reporting a violation

← All Insights

1. A schedule published two years ahead

Compliance visits are not meant to be a surprise. To help planning and coordination with the partner, "a two-year CAV plan has been institutionalized through formal message notifications to the CCMDs and SCOs" (SAMM C8.5.5). "The two-year plan is published at the beginning of each fiscal year and provides an anticipated quarterly CAV or VCA schedule by CCMD and partner" (SAMM C8.5.5).

The published plan is not a limit. "DSCA may, in coordination with the appropriate CCMD, perform additional out-of-cycle CAVs or VCAs as necessary to execute the Golden Sentry mission" (SAMM C8.5.5). The visit types themselves, and the ratings that come out of them, are described in Golden Sentry visits and ratings.

2. How a country reaches the list

Seven considerations are listed, and they read as a description of what draws attention. The first is risk assessment, which will include intelligence analysis and estimates about transfers of the articles the program monitors. Then come the types and quantities of articles designated for routine or enhanced monitoring. The compliance history of the partner under its transfer agreements follows, with any earlier reports of concern about protection of United States supplied articles (SAMM C8.5.5.1.1).

The next two are about the office rather than the country: the compliance history of the security cooperation office itself, and the political or military stability of the region. The last is administrative. "Opportunities to conserve resources by visiting more than one country in a region" (SAMM C8.5.5.1.1) can put a partner on the schedule with no concern behind it. The two monitoring tiers behind the second consideration are explained in routine and enhanced end use monitoring.

3. The annual message, then ninety days out

The sequence begins with a message each fiscal year setting out the criteria and the planned visits by command and country, coordinated with the commands before it is issued. The office in country then confirms receipt, proposes dates, tells the country team and the partner that a visit is coming, and starts preparing against a checklist published in the monitoring database (SAMM C8.5.5).

At ninety days the scope arrives. The monitoring team confirms which specific articles have been selected for enhanced assessment and which categories it wants to observe under routine assessment. At eighty days the office works out where those articles physically are and drafts a tentative itinerary (SAMM C8.5.5).

4. Seventy and sixty days, and the formal notice

At seventy days the office replies with substance. It raises any country team concerns, names its own representative on the team and any command members, and recommends additions to or deletions from the proposed list of articles. It also provides a draft itinerary, the recommended lists for both assessment tiers, and a map of the sites expected to be visited (SAMM C8.5.5).

At sixty days the visit becomes formal. A notification message identifies the dates, the team members and the support requested, and confirms the articles or services that will be assessed under each tier (SAMM C8.5.5). It is the reference point for the rest of the sequence, because later events point back to the list it confirms.

5. Clearances, and the last fifteen days

No later than thirty days before the visit a country and theater clearance message is transmitted under the foreign clearance guide. On receipt the office acknowledges it, confirms a primary and an alternate point of contact, and completes site clearance coordination with the partner (SAMM C8.5.5).

Fifteen days out the practical arrangements are closed. The office confirms access approval and the designated articles to be observed at each site, and must "Ensure that partner unit commanders have received the required authorization from their higher headquarters" (SAMM C8.5.5). The final itinerary then goes to the monitoring team and to the partner. A site cannot be inspected on the strength of a headquarters agreement alone.

6. On site, and what stops a visit

The visit itself has a fixed shape. There is an in brief to the office and country team, then an assessment of current compliance by both the office and the partner. Next comes a review of the records for the articles named in the notification. Site visits evaluate physical security and accountability procedures at those locations. An out brief follows, covering preliminary findings and the timeline for the final report (SAMM C8.5.5).

One preparation item sits with the office. "The SCO provides the CAV team a list by serial number of all EEUM-designated defense articles expected to be inventoried at each facility" (SAMM C8.5.5). Serial number inventories and site certification are covered in storage site certification and inventories.

Where something makes the visit impossible, the escalation is immediate. "The DSCA EUM CAV Team lead notifies the SCO with details about why they are unable to complete the visit successfully" (SAMM C8.5.5), and the assistant director is told as well. A course of action is then decided during the visit rather than afterwards. A suspected violation triggers a separate path, with notice to the office and to the Department of State (SAMM C8.5.5).

7. The report, and ninety days to answer it

Reporting runs on working days. A draft report goes to the monitoring team within five working days. Coordination from the office, the operations directorate and the general counsel is obtained within ten, and the report then goes to the division chief. Within fifteen working days it is submitted for final approval, carrying an overall assessment result for both the partner and the country team. It is then forwarded to the command, the office and other organizations for information or corrective action (SAMM C8.5.5).

Then the obligation reverses. "SCOs will forward a written report of actions taken to correct all findings and recommendations addressed in the CAV report to DSCA CAV team lead (through the CCMD)" (SAMM C8.5.5), no later than ninety days after receiving it.

8. Reporting a problem between visits

Monitoring does not pause between visits. Offices must be alert to and report potential unauthorized end use. The list runs from unauthorized access and transfers through security violations and known equipment losses, to signs of tampering or reverse engineering of articles, services, technical data or training (SAMM C8.9.13). "Potential violations shall be notified via email or through appropriate channels immediately" (SAMM C8.9.13), and the office decides the means by assessing how sensitive the matter is.

The threshold for reporting is low by design. The duty arises "on the basis of information from any source, including a private person unaffiliated with the USG or a foreign citizen" (SAMM C8.9.13.1). A report should carry the dates, the exact location, the articles or services involved, the nature of the suspected violation, any corrective action already taken by the partner, and contact details for whoever raised it (SAMM C8.9.13.1).

The purpose of the detail is stated plainly. "The information gained during the assessment could be useful in correcting the immediate problem and may be used to improve future end use controls" (SAMM C8.9.13). The final listed item asks the hardest question of all, whether sound processes failed in unusual circumstances, or procedures are not being given priority, or interests are diverging (SAMM C8.9.13.1).

Key terms

Two year plan	The quarterly visit schedule published each fiscal year by command and partner country.
Notification message	The formal notice at sixty days fixing dates, team members and the articles to be assessed.
Country clearance message	The travel clearance transmitted no later than thirty days before the visit.
Corrective action report	The written answer to findings, due within ninety days of receiving the visit report.

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.

How Sentfore supports this

Accountability for equipment in country depends on secure storage and controlled movement. Sentfore supports defense programs at the delivery end, providing protective security, secure transport, facilities and life support. Requirements can be sent through the contact page.