Cablegate: Harare Annual Certification of Management Controls

DE RUEHSB #0102/01 0391429
R 081428Z FEB 10



E.O. 12958: N/A

REF: STATE 012136

1. Per reftel, post completed its review of consular operations on
February 9, 2010, which was certified by Deputy Chief of Mission
Kathy Dhanani, FE-OC. Post is in full compliance with consular
management control requirements.

2. (a) Inventory and Reconciliation of Accountable Items. The NIV
and ACS Unit Chief serves as the ACO and completed a comprehensive
physical inventory of all accountable consular supplies with the
Consular Section Chief on February 8, 2010. This inventory was
without incident, and was documented in writing and electronically
through the AI module in IVO, NIV, and ACS. All AI tracked items
and non-expendable items such as seals and stamps were included.
Post no longer uses manual ledgers or inventory control sheets to
track AI.

(b) Guidance. All consular officers are familiar with and have
access to all consular references and instructions. Officers rely
on 7 and 9 FAM , 7 FAH-1
, consular ALDACs,
and CAWeb (both the unclassified
and classified) for reference. Training materials are not used for
reference. All consular officers have access to classified
systems. However, the Consular Section Chief does not check
classified e-mail daily because the consular section is not rated
for classified equipment. Classified email is checked at least

(c) Consular Shared Tables Management. Only consular section
employees have consular roles in NIV, IVO, ACS, and ACRS. RSO
ARSOs are assigned CCD roles and the DCM is assigned an NIV review
role. Adjudicatory and management roles are limited to American
consular officers. All parser roles have been disabled. All
active users are at post and authorized system access only at the
appropriate level. Users who no longer have any need for access
have been verified as disabled. User passwords are periodically
reset and individually chosen by the individual IAW SOP82.

(d) Physical Access. Physical access to the Consular Section and
all consular workstations is controlled and limited to Consular
Section employees. Locally employed staff (LES) are not present
outside office hours unless a cleared American consular officer is

(e) Access to Personally Identifiable Information (PII). Post
protects and restricts access of PII to only those with a
legitimate need for such information. Data base systems that
contain such information (including PIERs, IVO, NIV and ACS) are
restricted through CST user roles and local controls, and only
accessed in connection with official duties. All consular assigned
personnel have been briefed on inappropriate use of such systems,
the penalties for improper use, and the critical need to safeguard
such information. Post is unaware of any breaches or incidents
involving loss, theft, unauthorized access or compromise of PII.
If such a breach occurs in the future, it will be reported and
handled per 7 FAM 1300, Appendix Y

(f) Control/Reconciliation/Destruction of Controlled Items.
Consular Section procedures ensure accountable consular items are
controlled, handled, destroyed, and accounted for in accordance
with 7 FAH-1 H-600. The Accountable Items (AI) function is being
used for daily reconciliation of all accountable consular supplies
including passports, passport foils, supplemental pages, CRBAs, NIV
foils, and IV foils. Post destroys spoiled, unusable, and obsolete
controlled times, and records via a witness their destruction in
AI. Per State 112062, all unusable, spoiled, or obsolete passport
books, passport cards and border crossing cards are returned to the
Department for destruction.

(g) Cash Accountability. The ACO, backup ACO, Consular Cashier,
and backup Consular Cashier are all designated in writing per
guidance, and all are fully familiar with the instructions in 7

HARARE 00000102 002 OF 004

FAH-1 H-700. The ACO completed FSI on-line course PC 417,
Accounting for Consular Fees, in August 2008. The backup ACO
completed the course in March 2008. Both the Consular Cashier and
backup have completed PC 419, Collection of Consular Fees for
Consular Cashiers. Local SOPs are in place that implement 7 FAH
and CAWeb Consular Fee Page guidance, ensuring that accounting and
reconciliation procedures for consular fees are properly carried
out. Daily Accounting Sheets reconciled against ACRS and OF-158
receipts are on file for the last 12 months, with monthly
reconciliation signed by both the ACO and FMO. There have been no
discrepancies within the past 12 months.

(h) Periodic comparison of MRV fees and NIV applications. Post
does not use an off-site collection for MRV fees. All consular
service fees, including MRV, are paid to the consular cashier in
USD cash at the time of service. Adjudicating officers confirm a
valid ACRS (MRV) receipt for each service, and cancel the receipt
by initialing it. State Dept copies of MRV receipts are stapled to
the application. Daily, weekly, and monthly comparison of MRV fees
collected against NIV applications is carried out as prescribed in
7 FAH-1 H-740. However, post finds the guidance for reconciliation
of non off-site MRV fees provided on the consular fees page of
CAWeb to be lacking. Instead of NIV Report 44, post recommends
Report FEE, MRV Fees for Non-Immigrant Visas by Visa Class. An
additional option better suited than NIV Report 44 is the Visa Fee
Collection Estimate Report from CCD. The ACO uses all three
reports to compare the cumulative total of fees collected against
the number of MRV applications (excluding no-fee).

(i) Referral System. Post's NIV referral policy is published as
Management Policy 56, and reflects 09 State 068314 and 9 FAM
Appendix K. Only American officers under COM Authority are
permitted to make referrals, all referrals are signed by both the
referring officer and agency or section head as appropriate,
referral information is captured in the NIV system, all referral
forms (A and B referrals, whether issued or refused) are scanned
into the NIV system with the application form and all supporting
documents, and consular managers periodically review referral
reports to identify trends and possible areas of concern. All
officers are required to be briefed on the policy and sign a
compliance agreement before being entered into NIV as an approved
referrer. All class A and B referrals are adjudicated by the
Section Chief or the Acting Section Chief in his absence.
Referrals from within the consular section are handled and
documented identically to those from outside the section and no
unofficial referrals are allowed outside of the formal process.

(j) Training. American and locally employed staff are expertly
trained for their responsibilities in accordance with SOP 73,
including fraud detection. The ACO and backup ACO have completed
PC-417 and the on-line user training for ACRS. Post has instituted
weekly training sessions that take advantage of FSI OJT training
modules and other material posted on the CA website. All locally
employed staff have completed PC102, PC103, and PC104.

(k) Standards of Employee Conduct. The Consular Section has a
written zero gift policy, and a policy for all consular officers to
recuse themselves from any case in which there may be a real or
perceived conflict of interest. All consular employees are
familiar with the standards of ethical conduct expected of them.
Consular officers have reviewed the Department's Standards of
Ethical Conduct for Employees of the Executive Branch, and these
standards have been reviewed and discussed. There are no
influences being brought to bear on the visa or passport process
that would lead to any perception of impropriety. All members of
the section know and understand the reporting requirements and
options for reporting possible unethical or malfeasant activity.

(l) Namecheck and Clearance Reviews. Namecheck returns are given
rigorous review and consistent standards are applied in determining
when a hit is close enough to warrant further action. When
insufficient information is present to rule out a potential match
to a namecheck hit, that hit is treated as if it were a match.

(m) Visa Lookout Accountability (VLA). Post's Visa Lookout
Accountability (VLA), Automated Biometric Identification (IDENT),

HARARE 00000102 003 OF 004

Facial Recognition (FR), and Integrated Automated Fingerprint
Identification System (IAFIS) procedures are in compliance with
Dept guidelines. The Section Chief regularly reviews issuances to
verify compliance and reviews VLA responsibilities with arriving
officers. All adjudicating officers understand VLA provisions and
requirements, as well as the consequences for failing to comply
with VLA procedures.

(n) Intake, Interview, and Screening. Intake, interview, and
document screening procedures comply with the Department's
instructions (including 9 FAM 41.102 and 41.103). Screening of
applications by locally employed staff (LES) does not encroach on
adjudication. LES only review applications for completeness and do
not ask questions or make notes on the application that could be
interpreted as influencing adjudication. LES do not turn away NIV
or IV applicants who have paid the appropriate fees and have a
completed application, even if they believe additional documents
are required.

(o) Oversight of processing. Adequate supervision of processing is
exercised by American officers. However, the layout of the
Consular Section does not allow constant line-of-sight supervision
of print stations. Posts DNA policy and collection of samples
complies with 09 State 097431 and 9 FAM 42.44. Post exercises
proper oversight of panel physicians and possesses recently updated

(p) Biometric collection. Fingerprinting for biometric purposes is
only performed by consular officers or cleared American EFMs. Post
is in compliance with Bio/Visa Enrollment policy and procedures
found in 9 FAM Appendix L.

(q) Photo Standards. Per the photo guide on,
post is only entering recent photos of the applicant and is
rigorously applying the photo guide standards for NIV, IV, and
passport photos.

(r) Visa Adjudication Oversight. The Section Chief and DCM
regularly review NIV refusals and issuances via the NIV review
system in CCD, at a rate well above the minimum. Comments are
entered into the system from initial adjudication through CCD
review. If upon review, a supervisory consular officer determines
that an error in the application of law was made during the initial
adjudication, s/he personally re-interviews the applicant and makes
an adjudication decision under his/her own login. In such cases,
the supervisor marks the case as overcome in the system, explains
the legal error in the original officer's adjudication, and the
action taken. Supervisory overcomes are extremely rare and are not
used in cases of reconsideration in which there was no legal error
in the original adjudication. All cases for reconsideration
require a new application and fee. All applicants for whom a
personal appearance is required are interviewed per 05 State
092176, 08 State 04990, and 9 FAM 41.102. Post regularly (at least
monthly) reviews issuance patterns to third country nationals, and
knows to report any unexplained trends or anomalies to CA/VO/F/P
and CA/FPP/CID. Per 9 FAM 41.121 N2.5, previously refused visa
applicants are allowed to reapply any time, using the same
procedures as first-time applicants. Posts does not have a written
re-application procedure.

(s) Files. Consular files are managed in accordance with the
Record Disposition Schedule and visa files are maintained per 9 FAM
Appendix F instructions. All consular personnel safeguard visa
records in accordance with INA Section 222(f), in order to prevent
unauthorized disclosure of any form. NIV records are filed
chronologically per instructions in 9 FAM Appendix F, 200.

(t) Passports and CRBAs. Procedures and controls are in place to
ensure the accuracy and integrity of U.S. passport, CRBA, and other
nationality determinations. Post conducts passport namechecks per
7 FAM 1330 for all passport services, including the addition of
visa pages. The ACS Unit chief and Consular Section Chief audit
passport cases and procedures to ensure the accuracy of: annotation
of citizenship and identity documentation; annotation related to

HARARE 00000102 004 OF 004

name clearances, endorsements and limitations; clarification of
illegible entries; correction of inaccuracies; and, fraud
detection. Per 09 State 112062 and 7 FAM 1366, all unusable,
spoiled, or obsolete passport books, passport cards and border
crossing cards are returned to the Department for destruction.

(u) Fraud Prevention Programs. The Section Chief serves as post's
Fraud Prevention Manager and post has a written Fraud Prevention
SOP that includes criteria for referring cases for investigation.
The FPU feature (button) in NIV and IVO are used to refer cases to
the FPU and to track FPU case status. Written procedures are in
place to safeguard the role of the LES fraud investigator by
prohibiting her (or any other LES) from influencing eligibility
decisions. Reports on investigations are confined to factual
information, not opinion or recommendations for adjudication. All
investigative reports are carefully reviewed by an American officer
and are randomly validated. Anti-fraud field trips are undertaken
rarely, but often with a consular officer. The Section Chief
reviews and approves all fraud investigator vouchers.

(v) Wilberforce Act. Per 09 State 05632, 09 State 05634, and 09
State 067921, post provides the Wilberforce pamphlets to the
relevant visa applicants, and confirms that the applicants have
received, read, and understood the contents of the pamphlet. Links
to the Wilberforce pamphlet and information about worker and
student rights are provided on Post's NIV website.

(w) Oversight of Applicant Service Centers (ASCs). N/A.

(x) Consular Agents. N/A.

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