1 Interaction Letter To Secretary Clinton - March 15, 2009

President and CEO Samuel A. Worthington Chair Charles MacCormack,

Save the Children Vice Chair Ritu Sharma Fox,

Women Thrive Worldwide

Treasurer Amy Coen,

Population Action International

Board of Directors Kenneth Bacon, Refugees International David Beckmann, Bread for the World Carol Bellamy, World Learning Sekyu Chang,

Korean American Sharing Movement Julius Coles, Africare Helene D. Gayle, CARE USA Anne Lynam oddard,

Christian Children’s Fund

Lee H. Hamilton, Woodrow Wilson International Center for Scholars Neal Keny-Guyer, Mercy Corps Elizabeth Lathem, US Committee for UNDP Jo Luck, Heifer International John McCullough, Church World Service Mary Ellen McNish, American Friends service

Committee

Hugh Parmer, American Refugee Committee Daniel E. Pellegrom, Pathfinder International Linda Pfeiffer, INMED Robert Radtke,

Episcopal Relief and Development Yolonda C. Richardson, Centre for Development and Population Activities Carter Roberts, World Wildlife Fund George Rupp,

International Rescue Committee Zainab Salbi,

Women for Women International Ron Sconyers, Physicians for Peace Kathy Spahn, Helen Keller International Richard Stearns, World Vision Tsehaye Teferra,

Ethiopian Community Development Council Emily Untermeyer, Amigos de las Americas Sam Worthington (Ex-Officio)

1400 16th St., NW Suite 210 Washington, DC 20036 PHONE: (202) 667-8227 FAX: (202) 667-8236 E-MAIL: [email protected] http://www.interaction.org

March 15, 2009 Secretary Hillary Rodham Clinton U.S. Department of State 2201 C Street NW Washington, DC 20520 Subject: USAID’s proposed Partner Vetting System 74 Federal Register 9 (January 2, 2009) 74 Federal Register 5808 (February 2, 2009) RIN 0412-AA61 Title of Action: Final Rule (22 CFR Part 215) (the “Rule”) Dear Secretary Clinton: I write to you today about a subject of paramount concern to the U.S. NGO community: USAID’s proposed Partner Vetting System (PVS). The PVS would require U.S. NGOs and their subgrantees to turn over the private information of their officers and employees to the U.S. Government to be vetted against the classified list of terror suspects maintained by the Terrorist Screening Center. The expansive list of individuals that USAID envisions screening with the PVS includes prominent civic and religious leaders, sitting members of Congress, and at least one former Secretary of State. While one must question the utility of screening such individuals as a method of preventing the diversion of taxpayer dollars to suspected terrorists, our chief concern is that implementation of the PVS will undermine the effectiveness of U.S. humanitarian and development programs. The PVS will almost certainly create the perception that U.S. NGOs are collecting sensitive information on behalf of U.S. law enforcement and intelligence agencies. This will detract from the ability of U.S. NGOs to partner with local communities overseas and will undoubtedly increase the risk of violence that the employees of U.S. NGOs already face around the globe. Furthermore, the PVS, as currently proposed, would be unevenly applied to non-profit NGOs and not for-profit contractors, thereby competitively disadvantaging a major segment of USAID’s implementing partners. Please understand that the U.S. NGO community shares USAID’s commitment to ensuring that no funds are diverted to terrorist organizations, and we already have systems in place to prevent such diversions. We recognize that USAID faces external pressures from Congress and others on this issue, but we do not feel like the PVS is the right system to address those pressures, and we certainly do not believe that the PVS will effectively prevent the diversion of funds to suspected terrorists or terrorist organizations. In fact, senior USAID officials have publicly admitted that the system is unlikely to prevent such diversions. Because the Partner Vetting System is unlikely to be effective, and will severely undermine the ability of American NGOs to safely and effectively partner with the communities that benefit from U.S. foreign assistance, I respectfully request that the administration

InterAction is a membership association of US private voluntary organizations engaged in international humanitarian efforts including relief, development, refugee assistance, environmental protection, population programming, policy advocacy, and education.

withdraw the Rule cited above as well as its proposed Partner Vetting System. In the absence of a nominee for the position of USAID Administrator, and because of the improbability that an Administrator will be nominated and confirmed before the Rule becomes effective on April 3, 2009, it is imperative that you act quickly in your capacity as Secretary of State to withdraw the Rule before its effective date. In his inaugural address, President Obama stated that, “As for our common defense, we reject as false the choice between our safety and our ideals,” and U.S. humanitarian and development programs represent the best of those ideals: the willingness to lend a helping hand to those most in need. In a world that is rife with violence and instability, the U.S. NGO community is the positive face of America around the globe. Implementing the Partner Vetting System will undoubtedly limit the effectiveness of those programs, an outcome that is certainly not in line with U.S. foreign policy goals. I ask you to consider whether implementing a misguided and ineffective Partner Vetting System will actually make the world safer and more stable, and whether the United States can afford to cede the schools, hospitals, and villages of places like Gaza, Pakistan, and Afghanistan to our nation’s enemies. The U.S. NGO community argues that it will not improve global stability or U.S. security, and that lowering the profile of U.S. relief and development programs in the FATA region of Pakistan, for example, is not in the United States’ strategic interest. As I stated above, the U.S. NGO community shares USAID’s commitment to ensuring that no foreign assistance funds are diverted to terrorist or terrorist organizations, and we look forward to working constructively with the new USAID Administrator. That said, any new or strengthened screening system would need to be designed so as not to undermine humanitarian and development programs or put NGO staff at an increased risk of violence, and allowing an onerous rule promulgated by the Bush administration to become effective is a step in the wrong direction if we hope to achieve an amicable solution in this matter. We have raised this matter with USAID, Congress, and senior Obama administration officials and, again, respectfully request that the administration withdraw the Rule cited above before it becomes effective on April 3, 2009. Thank you for your prompt handling of this matter. I look forward to your response. Sincerely,

Samuel A. Worthington President & CEO cc: Jack Lew, Deputy Secretary of State Alonzo Fulgham, Acting USAID Administrator Richard Greene, Deputy Director of U.S. Foreign Assistance Gayle Smith, Senior Director for Relief, Stabilization and Development and Senior Advisor to the President, National Security Council

InterAction is a membership association of US private voluntary organizations engaged in international humanitarian efforts including relief, development, refugee assistance, environmental protection, population programming, policy advocacy, and education.