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Review of the Bureau of International Narcotics and Law Enforcement Affairs’ Property Donations to Ukraine

ISP-I-26-10
    Report Contents
    Unclassified

    SUMMARY OF REVIEW  

    Since Russia’s full-scale invasion of Ukraine in February 2022, the U.S. government has provided approximately $67 billion in security assistance to Ukraine, as of March 2025. Of this amount, the Department of State (Department), Bureau of International Narcotics and Law Enforcement Affairs (INL) committed almost $1 billion in training and assistance, representing the largest inventory of INL property worldwide and including more than 146,000 donated items that were subject to end-use monitoring (EUM) requirements and more than one million donated items that were not subject to EUM, as of July 2024. 

    Kearney & Company, P.C. (Kearney), acting on the Office of Inspector General’s (OIG) behalf, conducted a review of the Department’s INL property donations to Ukraine to: (1) describe the number and acquisition value of property acquired and donated to Ukrainian government entities, and (2) determine the extent to which INL complied with applicable Department and INL property management standards throughout the property lifecycle for commodities and equipment provided to Ukraine. 

    Kearney found that INL lacked processes to maintain complete and accurate data for assets that it acquired and donated to the Ukrainian government. Specifically, the Department system INL used to manage its property donations lacked acquisition costs for items INL identified as either retired or disposed. Additionally, data available for INL-donated items not subject to EUM requirements was incomplete and inaccurate. Without accurate data regarding the items INL donated to Ukraine, staff charged with overseeing the property may lack visibility into key metrics associated with the bureau’s assistance to Ukraine, potentially resulting in misinformed decisions or inaccurate information provided to responsible parties. 

    Despite the inaccurate data, Kearney found that INL generally complied with property management standards for the items donated to Ukraine. Kearney reviewed a statistically significant sample of 145 donated items subject to EUM requirements and identified 6 discrepancies between the data contained in INL’s official system of record and the transfer documentation supporting the donation. Similarly, Kearney reviewed a non-statistically significant sample of 78 donated items not subject to EUM and identified 7 errors in the official system of record. 

    Kearney made four recommendations to improve the Department’s ability to oversee and track INL’s donated property, including items subject to EUM requirements. In its comments on the draft report, the Department concurred with all four recommendations. OIG considers all four recommendations resolved. The Department’s response to each recommendation, and OIG’s reply, can be found in the Recommendations section of this report. The Department’s formal written responses are reprinted in their entirety in Appendix B. 

    Recommendation Number
    1
    Open Resolved

    The Bureau of Diplomatic Technology, in coordination with the Bureau of International Narcotics and Law Enforcement Affairs (INL), should update the Integrated Logistics Management System’s INL –End-Use Monitoring Module to ensure that acquisition costs and inspection data for assets that are retired or disposed are readily available to end-users for purposes of analyses and informed decision making.

    Recommendation Number
    2
    Open Resolved

    The Bureau of International Narcotics and Law Enforcement Affairs should define policies and procedures related to non-end-use monitoring acquisitions and donations, and then consistently follow those policies and procedures to ensure consistent and accurate updates of non-end-use monitoring data within transfer letter trackers.

    Recommendation Number
    3
    Open Resolved

    The Bureau of International Narcotics and Law Enforcement Affairs should revise its end-use monitoring standard operating policies and procedures to ensure timely and accurate recording of in-service end-use monitoring assets, retired assets, and disposals within the Integrated Logistics Management System.

    Recommendation Number
    4
    Open Resolved

    The Bureau of International Narcotics and Law Enforcement Affairs should revise the end-use monitoring standard operating policies and procedures to ensure that data within the transfer letter trackers accurately reflect data for non-end-use monitoring assets.