VZCZCXYZ0002
RR RUEHWEB

DE RUEHMO #0438/01 0581919
ZNR UUUUU ZZH
R 271919Z FEB 10
FM AMEMBASSY MOSCOW
TO SECSTATE WASHDC 6619

UNCLAS MOSCOW 000438 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: CMGT CVIS CASC KFRD RU
SUBJECT:  CERTIFICATION OF CONSULAR MANAGEMENT CONTROLS 
 
Ref:   State 12136 
 
¶1.  In accordance with reftel, the Consular Section at U.S. Embassy 
Moscow completed its review of consular management controls on 25 
February 2010.  Richard Beer, FE-OC, Consul General, certifies that 
the management review was successfully completed and that we are in 
compliance with the Department guidelines with the exception of two 
items:  line-of-sight for IV printing and physical access to the 
Section by non-consular employees.  Both of these issues will be 
corrected in the coming months. 
 
¶2.  Below is a narrative of our review of consular management 
controls: 
 
¶A. Inventory Count and Reconciliation of Accountable Items: Post has 
conducted inventories of accountable consular supplies in the NIV, 
IV and ACS sections.  Post always uses the AI module to manage visa 
foils, CRBAs, passport books and foils; all other accountable items 
are tracked through a spreadsheet system maintained by the ACO.  The 
physical inventory reconciles with the AI and ACO-file inventory 
records.  The following officers participated in the inventories: 
Richard Beer, Consul General; Julie Stufft, overall section ACO and 
ACS ACO; Doug Johnston, NIV ACO, and Jessica Wolf-Hudson, IV ACO. 
 
¶B. Guidance: 
-  All consular officers have access to 7 and 9 FAM, 7 FAH and CA 
web on their desktops as Qfavorites.Q  Moscow officers have access 
to classified references (including CAWeb) and are encouraged to 
read classified traffic at least bi-monthly (classified access is 
located in another building).  Consular supervisors routinely stress 
that only official Department guidance should be consulted. No one 
should be using training materials or outdated SOPs as references. 
-  All consular officers in Moscow have access to classified systems 
located in another building.  Consular officers from the St. 
Petersburg and Yekaterinburg consulates travel to Moscow quarterly 
in order to read classified material.  MoscowQs Consular Section 
facilitates their travel, lodging and classified access. For reasons 
of cost and travel convenience, the lone consular officer at 
Consulate Vladivostok travels to Embassy Seoul for quarterly access 
to the classified system.  The Consular Chief checks the classified 
system daily and, in his absence, the acting Consular Chief does the 
same.  Other supervisory officers check the classified system on at 
least a weekly basis. 
 
¶C.  Consular Shared Tables (CST) Management:  Post has reviewed its 
CST tables and verifies it is in full compliance; CST roles are 
checked by the FPM on a monthly basis to ensure that they are 
accurate in the system.   RSO staff has non-consular roles in INK, 
NIV and CCD.  All parser roles have been disabled in CST.  All 
adjudicatory and management roles are limited to American consular 
officers.  ACOs for fees have separate user IDs for ACRS and ACOs 
were advised to set different passwords for ACRS.  LES consular 
cashiers have been set up with different user IDs and passwords in 
ACRS as well.  Systems passwords are periodically reset (when the 
system prompts a change) and are self selected by the individuals. 
Only the individual user has access to their individual passwords 
and passwords are never shared. 
 
¶D. Physical Access: 
-  Regular access is limited to consular section employees and those 
whose responsibilities require access.  Currently two employees of 
our courier service, Pony Express, also have a door combination 
which allows access during business hours for passport pick-up and 
delivery.  We recognize this is a vulnerability and have requested 
construction of an entrance with access remotely controlled by an 
MSG or local guard.  Pending construction of that access, we are 
installing a buzzer and changing the door combination.  When 
complete, Pony Express employees will have to press the buzzer for 
access.  These contract employees, due to the nature of their work, 
require frequent access. 
- LES personnel are not present outside of office hours unless a 
cleared American is present.  During working hours, controlled items 
are secured if an American consular officer is not present. 
 
¶E. Access to PII: Post confirms that collection of PII is kept to a 
minimum.  Access to consular systems containing PII is controlled 
and limited to consular section employees or those with a legitimate 
need to see this information; PII is properly secured after business 
hours.  Post has not had any incidents of disclosure of PII. 
 
¶F. Control/Reconciliation/Destruction of Accountable Items: Post 
confirms that accountable consular items are controlled, handled, 
destroyed and accounted for in accordance with 7 FAH-1 H-600.  The 
AI module is being used for reconciling daily usage of accountable 
consular supplies.  Post has not had any instance of a missing 
controlled item in the last twelve months, but reported the loss of 
two missing passport-application barcodes in January 2010, after the 
barcodes lost adhesion and fell from the roll.  Post is properly 
destroying spoiled consular accountable items and recording their 
witnessed destruction in AI when applicable.  Post recently sent two 
cables (09 Moscow 2612 and Moscow 3156) including serial numbers of 
presumed-destroyed items, dating back to 2002, which were still 
listed in AI as not destroyed; ACO destroyed these in the AI system 
per Department guidance. 
 
 
¶G. Cash Accountability:  Post confirms that the Accountable Consular 
Officer, alternates, and consular sub-cashiers, have been designated 
using the model letters found on the CA web.  The ACO and alternates 
have completed PC-417, and all consular cashiers and alternates have 
successfully completed PC-419.  The ACO has on file the Daily 
Accounting sheets for the last twelve months signed by both the FMO 
and ACO, noting no discrepancies between cash count and ACRS 
records. 
 
¶H. Periodic Comparison of MRV fees and NIV applications:  Post 
confirms the regular and robust periodic comparison of MRV fees and 
applications on a weekly basis.  When postQs ACO receives deposit 
reports from the off-site fee collection agency, she verifies these 
against OF-158 receipts issued by postQs Class B cashier, and 
creates a weekly report comparing the number of NIV applications and 
the fees registered for that month. Post is using the DS-160. Under 
current arrangements with our offsite collection agency, it produces 
one copy of the MRV receipt, which is attached to the passport and 
initialed by the officer at the time of visa adjudication, to 
prevent its re-use. At present the offisite collection agency is 
unable to generate a second copy of the MRV receipt for retention by 
us. Given these new reconciliation procedures, we will request that 
the agency do this. 
 
¶I. Referral System: Post certifies it is in full compliance with the 
Worldwide Referral Policy. All Mission officers are required to 
attend a referral briefing and submit a signed compliance agreement 
before they can submit referrals. Only officers under COM authority 
are permitted to submit referrals and all referral data is captured 
in the NIV system. The section chief personally reviews every 
referral (A and B) upon submission and before data entry, to confirm 
that it meets referral criteria, and returns to the referring 
officer with an explanation those that do not meet criteria. 
Referrals are reviewed for fraud trends. Only tenured officers 
adjudicate Class B referrals. The section chief adjudicates all 
Class A referrals. Referrals from within the Consular section and 
from all other sections and agencies are handled in an identical 
manner. 
 
¶J. Training: 
-  All American and locally employed staff are adequately trained 
for their responsibilities, including awareness of fraud in visa 
applications and other benefits. 
-  All cashiers have completed PC-419.  All officers and some 
locally employed staff have completed PC 441;  those who have not 
yet taken the course are currently registered and in the process of 
completing the on-line class. 
-  All ACOs have completed PC-400 and PC-417, as appropriate. 
 
¶K.  Standards of Employee Conduct:  We reviewed the DepartmentQs 
Standards of Ethical Conduct for Employees of the Executive Branch 
during one of our regularly scheduled training days and provided 
each officer with a copy of those standards.  The Consul General 
made particular application of these standards to our local context. 
 There are no influences brought to bear on either the visa or 
passport process that would lead to any perception of impropriety. 
Officers are instructed to recuse themselves from cases where there 
may be a real or perceived conflict of interest.  The Consular 
Section is in compliance with the Department standards on gift 
giving and receiving.  The Consul General makes a practice of 
reminding/reinforcing these standards regularly during weekly staff 
meetings and our monthly Consular training days.  We have reminded 
all members of the Consular Section of the reporting requirements 
and options for reporting possible unethical or malfeasant 
behavior. 
 
 ¶L.  Namecheck and Clearance Reviews:  All consular officers are 
aware of and comply with VLA requirements.  Officers understand that 
if a there is insufficient biographical data to exclude a hit or if 
the hit is a close match, that it should be treated as if it were a 
match. 
 
¶M.  Visa Lookout Accountability (VLA):  Consular supervisors review 
a random sampling of issuances to verify that adjudicating officers 
comply with VLA procedures.  In addition, bimonthly the FPM pulls 
the CCD generated report that deals with QIssuances over CAT 1 hits 
to ensure that officers are compliant with the guidelines. Over the 
past year, we have held two training sessions on VLA procedures and 
guidelines.  When new officers arrive at Post, VLA responsibilities 
are explained in detail. 
 
¶N.  Intake, Interview, and Screening :  The NIV and IV Units are in 
full compliance with Department instructions regarding intake, 
interview and screening.  LESs data enter, screen for completeness 
of documentation and take fingerprints.  They do not ask further 
questions or make notes.  LESs do not turn away anyone who has paid 
the MRV fee.  If an application is incomplete, an officer refuses 
221(g).  IV applicants are interviewed by an officer and refused 
221(g) if they are missing any required documents. 
 
¶O.  Oversight of processing: 
- Adequate supervision of processing is exercised by American 
officers. 
-  The layout of the antiquated annex building which houses the 
Consular section makes it difficult to co-locate cleared Americans 
with local staff in every case.  However, we have improved 
co-location during the past year.  A new Immigrant Visa furniture 
configuration, when completed, will improve line of site in that 
unit. 
- The NIV Unit moved its visa printing operation to improve line of 
site supervision.  Due to the physical layout of the IV Unit, there 
is currently not line of sight of visa printing stations in IV, 
although a planned reconfiguration of the IV Unit in the coming 
months will provide direct officer line-of-sight over all printers 
in the IV Unit. 
- The IV Unit Chief exercises oversight of the panel physicians 
located in Moscow, including occasional unannounced visits.  The 
most recent unannounced visit occurred in January and February 2010. 
 The Consul in Vladivostok exercises direct oversight of the panel 
physicians located in Vladivostok and visited the clinic last year. 
At that time, he found all procedures to be in accordance with FAM 
guidance.  The Vladivostok-based panel physician divides her time 
between a local hospital and the clinic where IV medical 
examinations are conducted, making it difficult to conduct an 
unannounced visit, but the Consul in Vladivostok plans to complete 
an unannounced visit in mid-March. 
 
¶P.  Biometric collection:  The Consular Section is in compliance 
with Bio/Visa Enrollment policy and procedures found in 9 FAM 
Appendix L.  LES collect fingerprints and American Officers verify 
them.  Where fingerprint quality is too low for verification, an EFM 
collects fingerprints. 
 
¶Q.  Photo Standards:  Post rigorously applies the photo standards of 
the Department.  Fortunately, most of our applicants visit a Pony 
Express contractor site prior to submission of application.  Pony 
Express advises applicants to replace unacceptable photos with 
proper photos before applicants visit us or before they send their 
applications to us, in the case of interview waiver candidates.  If 
a photo is dated, we refuse the case 221(g) and request a new 
photo. 
 
¶R.  Visa Adjudication Oversight: 
-  NIV refusals and issuances are reviewed electronically daily by 
the appropriate supervisors in the chain of command.  If a 
supervisory officer determines that an error was made during initial 
adjudication, the supervisory officer re-interviews the applicant 
and speaks with the adjudicating officer prior to adjudicating the 
case under his/her own login. In these rare cases, the supervisory 
officer enters a thorough explanation in the system.  Per 
DepartmentQs guidance, all of visa applicants for whom a personal 
appearance is required are being interviewed. 
-  The Fraud Prevention Unit (FPU) regularly reviews issuance 
patterns to third country nationals and reports trends to the Consul 
General and to all adjudicating officers.  Russian posts are 
authorized to adjudicate Belarusian visa applicants (they are not 
considered to be applying out-of-district) due to understaffing in 
Minsk.  FPU regularly conducts validation studies of these 
applicants and reports its findings. 
-  We do not have a written re-application process.  Applicants may 
apply at a time of their choosing through  normal visa application 
procedures. 
 
¶S.  Files:  Post confirms that it is compliant with the records 
disposition schedule in 9 FAM Appendix F.  In December 2009, we 
began using the on-line CEAC application for all NIV applicants and 
therefore, we no longer keep paper records after the NIV case is 
closed.  Additionally, all consular employees, officers, LES and 
EFMs, understand and abide by INA 222(F). 
 
¶T. Passports and CRBAs: Post confirms that procedures are in place 
to ensure the accuracy and integrity of the U.S. passport and CRBA 
functions.  Post conducts namechecks for all 
passport services, including extra visa pages.  The ACS Unit Chief 
audits passport cases adjudicated at post for accuracy, 
completeness, and fraud detection purposes. 
 
 
¶U.  Fraud Prevention Programs: Post confirms that there is active 
oversight of the Fraud Prevention Unit by a tenured, mid-level 
consular officer.  All consular officers use the electronic system 
to refer cases to the FPU for investigation.  These cases are first 
reviewed by the Fraud Prevention Manager (FPM) and then the notes 
are inserted into the case instructing what action is required by 
the LES.  To ensure that the reports are unbiased and accurate and 
that no further action is required all investigation reports are 
reviewed by the FPM prior to processing the results in the system. 
The FPM randomly selects one to two cases a month to verify the 
results.  We have not conducted a field investigation over the past 
year, but in the event that a field investigation was required, a 
consular officer would accompany the LES. 
 
¶V.  Wilberforce Act:  The Consular Section conducted Wilberforce 
training on one of its regularly scheduled training days.  The same 
information was conveyed to constituent posts during one of our 
monthly digital video conferences.  Moscow designated an officer to 
ensure compliance with the Wilberforce Act.  Moscow has sufficient 
copies of the brochures on hand and officers ensure that every 
affected applicant reads and understands the brochure. 
 
¶W.  Oversight of Applicant Service Centers (ASCs):  Not applicable. 
 
¶X.  Consular Agents:  A new Consular Agent was recently designated 
for Yuzhno-Sakhalinsk, in the Russian Far East. He is under the 
supervision of Consulate Vladivostok, although Embassy Moscow is 
handling matters relating to his accreditation by the Russian 
government. 
 
BEYRLE