VZCZCXYZ0003
RR RUEHWEB

DE RUEHGB #3542/01 3141301
ZNR UUUUU ZZH
R 091301Z NOV 08
FM AMEMBASSY BAGHDAD
TO SECSTATE WASHDC 0281

UNCLAS BAGHDAD 003542 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: CMGT CVIS CASC KFRD
SUBJECT:  CERTIFICATION OF CONSULAR MANAGEMENT CONTROLS 
 
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 
frequently. 
 
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 
present. 
 
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 
module. 
 
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 
wegsite. 
 
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 
schedule. 
 
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 
 
CROCKER