Cablegate: Certification of Consular Management Controls


DE RUEHGB #3542/01 3141301
R 091301Z NOV 08



E.O. 12958: N/A

Reftel: State 114455

1. Post's review of Consular Management Controls was completed on
November 8, 2008. Jeff Lodinsky, FS-02, Consular Chief, conducted
the review and certified its completion. Items in para 2 below are
keyed to para 5(a) of reftel.

2. a. Standard Operating Procedures: All officers have access, via
the CA Intranet site, to 7 and 9 FAM, FAH-1, the Consular Management
Handbook and CA SOPs. All consular section computers have the CA
website as their homepage. All officers also have access to CA's
classified website. While classified computers are housed in the
main Embassy building, all officers have access and utilize them

b. CST Management: All users in CST were reviewed on November 5,
2008. 1) We confirm that only consular employees have consular
roles; only the six American consular officers have adjudicatory
roles, and only the Consular Chief and his Deputy have management
roles. 2) All active users are currently at post and have the need
to utilize the systems to which they have access. No test or
anonymous accounts exist. 3) All system access levels are
appropriate. 4) Passwords automatically expire after six months and
thus must be reset at least that often. There is no sharing of
passwords in the consular section. All guidance in SOP 82 is
currently being followed.

c. Access: The consular section is located in a different building
from the Embassy and is separated from the rest of the building by a
controlled access door. Only the consular section employees have
the door code. FSNs do not remain in the consular section outside
of office hours without a cleared American present. All controlled
items are secured when, during office hours, no American is

d. Access to Personally Identifiable Information (PII): We confirm
that review and collection of PII is confined to official purposes
only when absolutely needed in the course of active and legitimate
consular work. All information is protected and access to consular
systems containing such information is only accessed in connection
with official duties. There have been no breaches or incidents
involving loss, theft, unauthorized access or compromise of PII.
Any such breaches would be reported as described in Department
Notice 2008-06-134 of June 25, 2008.

e. Inventory Count and Reconciliation of Accountable Consular
Items: The Deputy Consular Chief was designated Accountable
Consular Officer (ACO). The Consular Chief and Deputy Consular
Chief conducted a physical inventory of visa foils, blank EPDP
passports, passport barcodes, CRBAs, passport endorsement foils,
emergency passport foils, old blank passports books, wet and dry
seals, legend plates, passport ribbons, and print wheels. The
results were recorded in writing and matched those in the Inventory
Control Ledger. The physical inventory also matches that in the
electronic inventory module in ACS+ and the NIV Accountable Items

f. Control and Reconciliation of Accountable Items: All
accountable items are stored in Mosler combination safes. Only the
American consular officers have the combinations to the safes.
Controlled items are only released from the safe before their
immediate use and are reconciled daily. Daily and Monthly
Reconciliation and Accountability logs record usage and
reconciliation of ACS supplies, while the NIV/IV Accountable Items
module records all NIV/IV foil usage. There have been no instances
of missing controlled items.

g. Destruction Log: Post shreds, using a Department-approved
shredder, all spoiled or unusable controlled items. Their
destruction is witnessed and immediately recorded in AI or the ACS
destruction log. Post follows new guidance on returning all
passport books to the Department for destruction as described in
State 112062.

h. Cash Accountability: The ACO at post is the Deputy Consular
Chief. 1) The ACO, the consular cashier, and his back-up have all
been formally designated in writing. 2) The ACO reviewed
accounting and reconciliation procedures with the cashier and
back-up. 3) The ACO updates the ACRS Daily Accounting Sheet as soon
as the class B cashier returns daily receipts. There have been no
instances of cash discrepancies in the last 12 months. Monthly
reports are forwarded to the FMO for certification and a dually
signed copy of the report is kept by the ACO. The ACO (recently
arrived at post) has registered and will complete PC-417. The
cashier has enrolled in PC 419.

i. Periodic Comparison of MRV fees and NIV applications: Post does
not utilize off-site fee collection. Nonetheless, the ACO routinely
performs periodic comparisons of MRV fees collected with NIV
applications accepted.

j. Referral System: The Mission's most recent visa referral policy
was updated and disseminated under the signature of the Management
Counselor on August 17, 2008. It was approved by the Deputy Chief
of Mission. It was approved by CA/VO/F/P. All referrals are signed
by U.S. military Flag Officers, Agency heads or Section heads. All
of post's referrals are scanned into the NIV system. Referrals from
the past 3 months were reviewed and no anomalies were noted. Part
of post's policy is that only officers who have attended the formal
referral training course are certified to sign referrals. These
courses are held at least once a month. Post has not had any
referrals from inside the consular section. If this were to occur,
they would be handled identically to all other referrals. Post is
also careful to prohibit unofficial referrals and requires a
referral for anyone requesting an expedited appointment.

k. Training: Due to Embassy Baghdad's unusual staffing situation,
three of post's six LES are TDY from other embassies. They are both
senior LES and have all necessary training. The remaining three
were hired by Embassy Amman on one-year, renewable contracts to
serve in Baghdad. Both have received extensive OJT, but their
ongoing training remains a priority. One senior Jordanian hire
attended IV training this past FY. ELOs are given OJT and are
assisted daily by the Deputy Consular Chief when questions of law,
policy or procedure arise. It is very difficult to send ELOs to
conferences due to post's one-year assignments, multiple R&Rs, and
stringent requirements to be in-country for a set amount of days.
Both ACO's have registered to take PC-417 and ACRS training.
Consular chiefs have reviewed the management portion of the CA

l. Standards of Employee Conduct: All consular employees are aware
of the standards of ethical conduct expected of them. The zero
tolerance policy of CA has been replicated in the consular section,
with a discussion on the topic taking place with all consular staff
on November 6, 2008.

m. Namecheck and Clearance Reviews: Namecheck results are
thoroughly reviewed by consular officers at post. The determination
of hits is handled in a consistent manner, always erring on the side
of caution in questionable cases. The Deputy Consular Chief reviews
namecheck and FR results on many of post's cases before issuance.
SAOs are done for the vast majority of applicants at post, and AOs
are also very common. All responses are carefully reviewed to
ensure that the original submission was complete and no new hits
have been added since.

n. Visa Lookout Accountability: Post confirms that VLA procedures
are in place and that all adjudicating officers understand VLA
procedures and the consequences for failure to comply. The Deputy
Consular Chief reviews all visa issuances and refusals.

o. Intake, Interview and Screening: Post is in full compliance
with 9 FAM 41.102, 41.103 procedural notes, and all other guidance
on visa procedures. LES pre-screen the cases for completeness of
application; they are not in any way involved in the actual
adjudication of the case. Applicants are never turned away before
speaking to a consular officer.

p. Oversight of processing: Line-of-sight supervision is practiced
by consular officers at post. Officers spend the majority of their
time in the section with the LES, especially when controlled items
have been released for use.

q. Post is in compliance with fingerprinting regulations. Two NIV
LES are authorized to collect biometrics with an officer verifying
the prints at the time of interview. Post complies with 05 State
191641 regarding waiving of fingerprints. Fingerprints are always
taken, including for diplomats and other government officials
applying for B1/B2 visas. The Deputy Consular Chief verifies
compliance daily using the Waived Fingerprints Report in the CCD.

r. Interview and Adjudication: Consular Chief confirms that all
applicants requiring interviews are required to appear in-person in
the consular section. Personal appearance waivers are only granted
for diplomats, government officials and employees of designated
international organizations applying for A or G visas.

s. Photo Standards: Post maintains strict standards for photos and
rigorously applies standards for NIV, IV, and passport photos.

t. Review of Refusals and Issuances: All cases are reviewed by the
Deputy Consular Chief using the CCD's NIV Adjudication Review Form.
The Consular Chief and Deputy Chief of Mission then review a sample
of these cases. Consular Chief confirms that supervisory overcomes
are not used in cases of reconsideration in which there was no legal
error in the original adjudication.

u. Visa Shopping: Trends in visa applications are monitored by the
Deputy Consular Chief and Fraud Prevention Manager. Post rarely
sees non-Iraqi applicants. Consular Chiefs confirm that Post does
not maintain any sort of NIV written re-application process. Post
does not refuse to accept an application from an individual who is
physically present.

v. Files: Consular chiefs confirm that files are being managed in
accordance with the Record Disposition Schedule and visa files are
maintained per 9 FAM Appendix F. All consular personnel understand
that visa records are to be safeguarded in accordance with INA
Section 222(f). NIV applications are kept in chronological order
according to the date the visa was issued or a final refusal was
made. Post strictly adheres to the Department's record retention

w. Passports and CRBAs: The accuracy and integrity of all
passports and CRBAs are carefully maintained at post. Namechecks
are performed for all citizenship services, and the quality and
correctness of decisions and accuracy of information on applications
are verified and controlled. Baghdad receives more extra page
applications than any other post in the world, and a namecheck is
performed for every one. All emergency passport applications are
reviewed to determine the true urgency of the situation, and the
citizenship documents presented are carefully reviewed. Nationality
determinations and passport cases are thoroughly investigated before
any decisions are made.

x. Fraud Prevention Programs: Post does not yet have a formal
program due to staffing issues, but we work closely with CA/FPP,
RSO, FBI, and other foreign missions in Baghdad to prevent fraud in
all facets of consular work. We maintain a Lexus/Nexus account that
we utilize frequently to check the veracity of applicant claims
and/or documents. The Deputy Consular Chief is designated as Fraud
Prevention Manager and all management controls are in effect for the
fraud prevention program.

y. Classified Access: Although housed in a separate building, all
ConOffs have classified e-mail accounts and check them on a regular
basis. The Consular Chief checks classified e-mail at least daily.

z. Posts Exercising Supervision of Consular Agents: N/A


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