SpyTALK.com; US/1; ATTN: HST/2; TJ/2
17 January 2013
From: POGO (Project On Government Oversight) and FOREIGN POLICY
Read the excellent FP article and POGO follow-up letter to SECSTATE Clinton.
The Honorable Hillary Clinton
Secretary, Department of State
2201 C Street, NW
Washington, DC 20520
Dear Secretary Clinton:
As you know, last month eight rockets were fired into Kabul, two landing near the U.S. Embassy.1
Not long after, at least seven people were killed and 91 wounded,
including children, when a suicide bomber struck close to the Embassy.
Following the second attack, a Taliban spokesman declared that the
target had been the U.S. Embassy itself.2
In response to these and other incidents, Chairman of the Joint Chiefs
of Staff Admiral Michael Mullen conceded that the situation in
Afghanistan is "serious and it is deteriorating."3
In
light of this increasingly violent and uncertain environment, effective
security of the U.S. Embassy in Kabul and the nearly one thousand U.S.
diplomats, staff, and Afghan nationals who work there 4
is paramount. Security for the Embassy is provided under a Department
of State contract with ArmorGroup, North America (AGNA), which is now
owned by Wackenhut Services, Inc. (Wackenhut).5 Some 450 guards and their supervisors protect the Embassy and are quartered at Camp Sullivan, a few miles from the Embassy.
The Project On Government Oversight (POGO) initiated an investigation after nearly one-tenth of the U.S./ex-pat6
guards individually contacted us to express concerns about and provide
evidence of a pattern of blatant, longstanding violations of the
security contract, and of a pervasive breakdown in the chain of command
and guard force discipline and morale. This environment has resulted in
chronic turnover by U.S./ex-pat guards. According to the State
Department, "nearly 90% of the incumbent US/Expats left within the first
six months of contract performance."7
According to POGO sources, the U.S./ex-pat guard turnover may be as
high as 100 percent annually. This untenable turnover prevents the guard
force from developing team cohesion, and requires constant training for
new replacement recruits. The guards have come to POGO because they say
they believe strongly in the mission, but are concerned that many good
guards are quitting out of frustration or being fired for refusing to
participate in the misconduct, and that those responsible for the
misconduct are not being held accountable.
After extensive
interviews with eyewitnesses, and examination of documents, photographs,
videos, and emails, POGO believes that the management of the contract
to protect the U.S. Embassy Kabul is grossly deficient, posing a
significant threat to the security of the Embassy and its personnel—and
thereby to the diplomatic mission in Afghanistan.
Ineffectual Oversight by the Department of State
Failed management of security contractors by the Department of State
is not new, and since the 2007 Iraqi Mansour Square massacre
involving five Blackwater personnel, the State Department has promised
repeatedly to strengthen its oversight.8
Yet, as in Iraq, the Department of State has utterly failed to properly
manage another contractor, this time at the U.S. Embassy Kabul,
Afghanistan. State has repeatedly warned AGNA about its performance on
this security contract, but its threats have been empty. As a result,
violations of the contract continue.
In June 2009, an
investigation by the Senate Subcommittee on Contracting Oversight
revealed a pattern of ineffectual Department of State oversight of the
AGNA contract.9
The Senate found, for instance, that in July 2007, State issued a "cure
notice," a formal advisory that AGNA's deficiencies were endangering
the performance of the contract. In the cure notice, State identified 14
performance deficiencies, including the failure of AGNA to provide an
adequate number of guards, relief personnel, and armored vehicles. The
contracting official stated "I consider the contract deficiencies
addressed below to endanger performance of the contract to such a degree
that the security of the US Embassy in Kabul is in jeopardy…."10
In
April 2008, the Department of State sent another cure notice notifying
AGNA of numerous other serious problems with its performance, including a
lack of English proficiency in a large portion of the guard force.
State also cited AGNA for failing to correct many of the deficiencies
identified in the July 2007 cure notice, including those related to
staffing and training of the guard force. State further informed AGNA
that, due to the contractor's continued weaknesses and deficiencies, the
Department was considering not extending the contract for another year.11
In
July 2008, despite AGNA's continuing problems, State decided to extend
the contract for an additional year, noting that based on satisfactory
meetings with the incoming Wackenhut managers, it was "reasonable" to
expect that all performance problems would be corrected by October of
that year.12
Just a month later, however, the Department of State reiterated to AGNA
that it questioned the contractor's ability to provide security for the
U.S. Embassy in the hostile environment of Afghanistan. Citing ongoing
staffing concerns, State concluded that "AGNA needs to come quickly to
terms with contract requirements especially in light of the current
incidents occurring in and around Kabul and the corresponding threat
environment they pose."13
By September 2008, AGNA's performance problems had grown so severe that Department of State issued a "Show Cause" letter 14
and advised that it was considering terminating the contract because
the failure to provide an adequate number of guards "has negatively
impacted the security posture of the Local Guard Program for the U.S.
Mission to Kabul….[T]he staffing situation has further deteriorated to a
level that…gravely endangers performance of guard services in a
high-threat environment such as Afghanistan."15
In
March 2009, the Department of State again informed AGNA that it had
"grave concerns" relating to AGNA's continuing failure to provide
sufficient numbers of guards. In inspections of the guard force
operations, the Department of State observed that 18 guards were absent
from their posts at the U.S. Embassy Kabul. In response, AGNA stated
that the guards' absences were due to "supervisory personnel
negligence."16
Despite
these and other past problems, senior representatives from the State
Department and Wackenhut Services, Inc. offered sworn testimony at a
June 2009 Senate hearing that security at the Embassy is effective, and
that previously identified problems had been fully remedied.17 The State Department renewed the contract again through July 2010, with the option to extend it until 2012.18
Yet the extensive evidence provided to POGO of continued security
problems at the U.S. Embassy Kabul counters those sworn statements;
calls into question AGNA and Wackenhut's ability to provide effective
security of the Embassy; and makes a clear case that the State
Department has failed in its oversight of its security contractor.
Serious Security Vulnerabilities: Was Congress Misled?
Despite Wackenhut Vice President Sam Brinkley's sworn Senate
testimony that "…the Kabul contract has been fully-staffed since January
2009…" the truth is that chronic understaffing of the guard force
continues to be a major problem.19
And evidence suggests Mr. Brinkley knew that. Around March, according
to numerous participants, he was confronted by some 50 guards at Camp
Sullivan who complained to him directly about a severe, ongoing guard
shortage. Then, in an April 2009 memo to a State Department official,
U.S. Embassy Kabul guard force Commander Werner Ilic reported that guard
shortages had caused chronic sleep deprivation among his men. He
described a situation in which guards habitually face 14-hour-day work
cycles extending for as many as eight weeks in a row, frequently
alternating between day and night shifts. He concluded that "this
ultimately diminishes the LGF's [Local Guard Force's] ability to provide
security." (Attachment 1) The contract with the State Department specifies that guards may not be on duty for longer than 12 consecutive hours.20 Interviewees
and documents reveal that short-staffing frequently results in the
denial of contractually guaranteed leave and vacation, and that those
who do not comply are threatened with termination or actually fired.
In further contradiction of Mr. Brinkley's assurances, the Knoxville News reported on
August 22 that Wackenhut has moved or is planning to deploy up to 18
guards from the nuclear weapons facilities in Tennessee to cover guard
shortages in Kabul, quoting a Wackenhut spokesperson as confirming the
use of the guards "to deal with personnel shortages at the embassy…."21
Communication Breakdown?
There is a significant problem with the guards' ability to communicate with each other: most of the Gurkhas 22—nearly
two-thirds of the guard force—cannot adequately speak English. Although
most of the Gurkha guards are serious about their jobs and perform
their duties in a professional manner, the inability to speak English
adequately has impaired the guard force's ability to secure the Embassy.
According to a Pentagon counter-terrorism expert, tactical
communications are critical to success in either preventing a gunfight
or the successful execution of one should it occur, and are part of the
fabric of a good military or security unit. If different languages are
used, the fog of battle is significantly increased, small tactical
formations do not adjust as required, and close tactical formations are
likely to fail in their mission. Further, any soldier or security
officer who does not know of changes in mission orders as the fight
continues is more likely to respond incorrectly, unnecessarily placing
them in harm's way and increasing the chances of unit fratricide. Poor
tactical communications make mission failure highly probable.
This
is a real risk at U.S. Embassy Kabul. The language barrier between the
non-English-speakers and English-speakers has forced both sides to use
pantomime in order to convey orders or instructions and interpreters to
convey facilitate radio communications. One guard described the
situation as so dire that if he were to say to many of the Gurkhas,
"There is a terrorist standing behind you," those Gurkhas would answer
"Thank you sir, and good morning." Clearly this is an unacceptable
situation, especially given that security emergencies require immediate
response.
The State Department has acknowledged the issue as a
problem, but has not fixed it. In June 2009, State officials briefed the
Senate Homeland Security and Governmental Affairs Subcommittee on
Contracting Oversight, admitting that "inadequate English language
proficiency among the guard force" remains a contract deficiency.23
Supervisors Engaging in Deviant Hazing and Humiliation
Guards have come to POGO with allegations and photographic evidence
that some supervisors and guards are engaging in near-weekly deviant
hazing and humiliation of subordinates. Witnesses report that the
highest levels of AGNA management in Kabul are aware of and have
personally observed—or even engaged in—these activities, but have done
nothing to stop them. Indeed, management has condoned this misconduct,
declining to take disciplinary action against those responsible and
allowing two of the worst offending supervisors to resign and allegedly
move on to work on other U.S. contracts. The lewd and deviant behavior
of approximately 30 supervisors and guards has resulted in complete
distrust of leadership and a breakdown of the chain of command,
compromising security.
Numerous emails, photographs, and videos
portray a Lord of the Flies environment. One email from a current guard
describes scenes in which guards and supervisors are "peeing on people,
eating potato chips out of [buttock] cracks, vodka shots out of
[buttock] cracks (there is video of that one), broken doors after drnken
[sic] brawls, threats and intimidation from those leaders participating
in this activity…." (Attachment 2)
Photograph after photograph shows guards—including supervisors—at
parties in various stages of nudity, sometimes fondling each other.
These parties take place just a few yards from the housing of other
supervisors.
Multiple guards say this deviant hazing has created a
climate of fear and coercion, with those who declined to participate
often ridiculed, humiliated, demoted, or even fired. The result is an
environment that is dangerous and volatile. Some guards have reported
barricading themselves in their rooms for fear that those carrying out
the hazing will harm them physically. Others have reported that AGNA
management has begun to conduct a witch hunt to identify employees who
have provided information about this atmosphere to POGO.
Beyond
basic decency standards, the situation at Camp Sullivan is clearly in
violation of AGNA's contract with the State Department, which specifies,
"Each contractor employee or subcontractor employee is expected to
adhere to standards of conduct that reflect credit on themselves, their
employer, and the United States Government."24
More broadly, the behavior is evidence of a complete breakdown of
discipline and the chain of command among guards and their leadership,
itself a significant security issue.
In fact, an email from a
current guard expressed concern about the impact of the supervisors'
behavior on the chain of command. "I am convinced the greatest threat to
the security of the Embassy is the erosion of the guard forces trust in
its leadership and ultimately the [Department of State]. The failure of
[the supervisors] to protect those they have been tasked to lead is
unacceptable, and if not held accountable will further compromise our
mission. The chain of command's failure to curtail [one supervisor's]
deviant actions and to not hold him accountable for countless
infractions involving alcohol has made them ineffective. This has led to
threats and intimidation as the only means to accomplish the day to day
operations here [at Camp Sullivan] and at the Embassy. This is 'not' a
onetime incident that went unnoticed by [his] direct chain of command.
These are events [that] took place over the past year and a half and
were ignored by the leadership at the cost of the well being of
countless guard force members. If these individuals are not held
accountable for their actions it will only embolden those who remain to
make the same offenses against this guard force." (Attachment 3)
Alleged Victimization of Afghan Nationals
An Afghan national employed as a food service worker at the guard
corps' base at Camp Sullivan submitted a signed statement dated August
16, 2009, attesting that a guard force supervisor and four others
entered a dining facility on August 1, 2009, wearing only short
underwear and brandishing bottles of alcohol. Upon leaving the facility,
the guard force supervisor allegedly grabbed the Afghan national by the
face and began abusing him with foul language, saying, "You are very
good for fXXXing." The Afghan national reported that he "was too afraid
of them I could not tell them any thing." (Attachment 4)
There
is also evidence that members of the guard force and their supervisors
have drawn Afghan nationals into behavior forbidden for Muslims. For
example, photographs show guards posing with Afghan nationals at the
U.S. facility at Camp Sullivan as both the guards and nationals consume
alcoholic beverages in scenes that suggest drunkenness, and one photo
shows a near-naked U.S. guard who appears to have urinated on himself
and splashed an Afghan national. Afghanistan is a conservative Muslim
country where alcohol consumption and public nudity are considered
offensive and, in some instances, prohibited by law.25
Supervisors Compromising Security?
Numerous guards raised concerns to POGO about a Spring 2009 extended
reconnaissance mission outside the Embassy perimeter for which guard
force supervisors took weapons, night vision goggles, and other
equipment from Embassy stores. Photographs posted on the internet show
Embassy guards hiding in abandoned buildings in Kabul, armed, dressed as
Afghans (despite contractual requirements that they be in uniform when
on duty), engaged in a mission for which they had never trained. AGNA
guards train for their mission of static security of the Embassy, not
for reconnaissance exercises away from the Embassy. This incident
created the danger that guards could have been drawn into a military
incident with or taken hostage by Taliban or Afghan locals, and created a
vulnerability at the Embassy by removing military equipment, leaving
the Embassy largely night-blind. AGNA management awarded a commendation
to 18 participants trumpeting their "Intrepidity" in a document
improperly bearing the seal of the Department of State. (Attachment 5)
According
to many guards, another situation in which Embassy security may have
been compromised is when, on at least one occasion, supervisors brought
prostitutes in to Camp Sullivan. This is a breach of security and
discipline made worse because the prostitutes were escorted to the
facility by some guard force supervisors themselves. Some interviewees
recalled that two AGNA guard force supervisors made no secret that, to
celebrate a birthday, they brought prostitutes into Camp Sullivan, which
maintains a sign-in log. Women believed to be prostitutes were observed
attending the birthday party.
Is Protecting a U.S. Embassy in a Combat Zone an Inherently Governmental Function?
Because the diplomatic mission in Afghanistan is so critical, and
because that mission is in a combat zone, the need for effective Embassy
security is particularly acute. Just this year at the U.S. Naval
Academy 2009 McCain Conference, there was a seminar on "Ethics and
Military Contractors: Examining the Public-Private Partnership" which
looked at the question of whether security in a combat zone is an
inherently governmental function. According to the Executive Summary of
the conference, "contractors should not be deployed as security guards,
sentries, or even prison guards within combat areas. [Armed Private
Security Contractors] should be restricted to appropriate support
functions and those geographic areas where the rule of law prevails. In
irregular warfare…environments, where civilian cooperation is crucial,
this restriction is both ethically and strategically necessary."26
Furthermore, Congress itself passed a Sense of Congress that "private
security contractors are not authorized to perform inherently
governmental functions in an area of combat operations."27
This language was watered down from legislation that had passed the
Senate actively prohibiting private security forces from performing
inherently governmental functions. 28
In neither case, however, did the legislative language recognize
protecting a diplomatic mission in a combat zone as an inherently
governmental function. At the very least, this is a question that needs
to be examined regarding the protection of the U.S. Embassy Kabul and
other embassies in combat zones.
The use of private contractors
for security in a combat zone poses several dilemmas. One is the
inherent tension between the effective performance of a mission and the
financial interests of the contractor. Cutting costs is good for the
bottom line, but can put security at risk. A legal case against AGNA
brought by two former U.S. Embassy Kabul guard force supervisors, James
Sauer and Peter Martino, illustrates this problem. According to the
complaint, AGNA officials "acknowledged that AGNA had underbid the
contract in order to secure it," and told Sauer and Martino "to 'make
do' and put a 'good face' on the situation to ensure that a profit would
be made on the contract and that shareholders would be
satisfied....Defendants implemented plans requiring more hours per
individual and fewer shifts of staff in order to cut costs and maximize
Defendants' profit margin." 29 This is a clear example of the contractor endangering the U.S. diplomatic mission in order to advance its bottom line.
Another
dilemma is the threat of work-stoppages—which, according to witnesses,
has happened at least twice with the U.S. Embassy Kabul guard force. On
two separate occasions, the Gurkhas (who make up two-thirds of the guard
force) threatened to walk off the job. In fact, in one instance, buses
had arrived in order to take the Gurkhas to the airport to return to
Nepal. According to POGO sources, the time it took to resolve just one
of those incidents resulted in the on-duty guard shift pulling an
18-hour day.
Yet another dilemma is that the laws in place do not
adequately hold accountable contractors who violate rules and endanger
security in combat zones. Unlike the military, which once had the
responsibility of guarding embassies and which is bound by the Uniform
Code of Military Justice, private employers such as security firms
cannot ensure a binding chain of command that provides adequate
discipline and professionalism in the guard force.
Contractor in Need of Oversight
POGO is concerned that the security of the U.S. Embassy Kabul is in
the hands of a contractor that has knowingly and repeatedly provided
substandard equipment and services. For example, to cut costs, AGNA
"downgrade[d] the quality of the vehicles to be purchased…."30 AGNA
sought to maximize its profit by sacrificing the quality of protective
vehicles it bought to secure the Embassy. In addition, as mentioned
earlier, the State Department has repeatedly chastised AGNA for the
contractor's repeated failures to fulfill staffing, language, and other
contract provisions. AGNA has also failed to properly manage Camp
Sullivan, as has been detailed above.
The problems with AGNA's
U.S. Embassy Kabul security contract do not appear to be unique for this
contractor. Recently, an ArmorGroup security guard in Baghdad's Green
Zone allegedly shot and killed two fellow guards and wounded at least
one Iraqi. Extraordinarily, that guard had a criminal record and was
described by one security guard who worked with him as "a walking
time-bomb," yet was hired by ArmorGroup anyway.31 This
particular incident raises serious concerns about ArmorGroup's vetting
process, and adds to the bigger picture of a contractor in serious need
of strict oversight.
Recommendations
1. After two years of failed attempts by the Department of State to
upgrade the performance of its private security contractors in both
Afghanistan and Iraq, the Department should enter into an arrangement
with Defense Secretary Gates to provide immediate military supervision
of the private security force at the U.S. embassies in Kabul and
Baghdad.
2. The State Department should promptly initiate a
thorough and independent investigation of the U.S. Embassy Kabul
security contract in order to hold corporations as well as individuals
accountable for the above noted misconduct and contract violations.
Simply removing a few people from contract management at AGNA or
Wackenhut, or creating a new corporate ethics compliance officer, is not
going to ensure serious accountability. Allowing those responsible to
quietly resign and seek work with other U.S. contractors, as guard force
whistleblowers report is happening now, will only perpetuate this
problem.
3. State Department representatives either knew or
should have known about this longstanding and dangerous situation
regarding U.S. Embassy Kabul security. The State Department's repeated
warnings to AGNA were of no consequence, and Department officials
responsible for oversight of this contract themselves should be held
accountable.
4. Those whistleblowers who have come forward to
disclose the mismanagement of this State Department contract should be
protected from retaliation for doing so.
5. The State Department
should consider whether the security of an embassy in a combat zone is
an inherently governmental function, and therefore not subject to
contracting out. The language in the 2009 National Defense Authorization
Act could be strengthened to prohibit the reliance on private security
contractors for inherently governmental functions, and to include
protection of the diplomatic mission in a combat zone as being
inherently governmental. If embassy security in combat zones is
determined not to be an inherently governmental function, the State
Department should consider requiring military supervision of its private
security contractors guarding U.S. embassies in combat zones.
6.
The State Department should consider initiating suspension and
debarment proceedings against the companies ArmorGroup North America,
Inc. (AGNA) and Wackenhut Services, Inc., as well as against any
individual employees of these companies who were responsible for
contract-related improprieties or abuses, to prevent these entities from
entering into future contracts with the federal government.
Please
contact me at (202) 347-1122 if you have any questions or need further
information or evidence to aid your efforts. Thank you for your
consideration of this very important matter.
Sincerely,
Danielle Brian
Executive Director
Attachments: 5 documents (complete pdf of attachments 1-5)
12 photographs
cc: Senator Susan Collins
Senator Claire McCaskill
State Department Inspector General Harold W. Geisel
Commission on Wartime Contracting in Iraq and Afghanistan
PDF of POGO letter only
__________________________________________________
1 Sanghar Rahimi and Carlotta Gall, "Rockets Hit Afghan Capital, 2 Near the U.S. Embassy," The New York Times, August 4, 2009. (Downloaded August 27, 2009)
2 Rahim Faiez and Jason Straziuso, "7 die, 91 wounded in blast near NATO HQ in Kabul," Associated Press, August 15, 2009. (Downloaded August 27, 2009)
3 Justin Blum, "Mullen Says Afghan Security Situation 'Serious,' Getting Worse," Bloomberg.com, August 24, 2009.
(Downloaded August 24, 2009)
4 E-mail from Caitlin M. Hayden, Senior Advisor for the Department of State, August 26, 2009.
5 Senate Committee on Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight, New Information about the Guard Force Contract at the U.S. Embassy in Kabul, June 2009. p. 1.
(Downloaded August 20, 2009)
(hereinafter New Information about the Guard Force Contract at the U.S. Embassy in Kabul).
In May 2008, Wackenhut informed the Department of State that it had
assumed responsibility for the AGNA U.S. Embassy Kabul contract.
6 Ex-pat is short for expatriate, a blanket
designation native-English-speaking guards use to describe themselves.
The term, as used by the guards, includes U.S. citizens as well as
citizens from other English-speaking countries such as Australia,
Canada, Ireland, New Zealand, South Africa, and the United Kingdom.
7 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, p. 5.
8 Government Accountability Office, Rebuilding
Iraq: DOD And State Department Have Improved Oversight and
Coordination of Private Security Contractors in Iraq, but Further
Actions Are Needed to Sustain Improvements, p. 32. (Downloaded August 31, 2009) and Testimony of Ambassador David M, Satterfield, Senior Advisor to the Secretary and Coordinator for Iraq, October 2, 2007, p. 2. (Downloaded August 31, 2009)
9 New Information about the Guard Force Contract at the U.S. Embassy in Kabul.
10 Letter from James S. Rogers, Contracting Officer, Department of State, to Karl Semancik, President of ArmorGroup North America Incorporated, June 19, 2007, p. 1. (Downloaded August 20, 2009)
11 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, p. 2.
12 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, p. 2.
13 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, pp. 2-3.
14 A show cause letter is presented to a contractor
before initiating a suspension or debarment action: "The show cause
letter usually provides the general nature of the suspected
misconduct...and provides the contractor with an opportunity to submit
whatever it wishes to demonstrate it is a presently responsible
contractor. A show cause letter does not make a contractor ineligible to
do business...but it is an advance notice that such an action may be
forthcoming." Department of the Air Force General Counsel, "Air Force General Counsel—FAQ Topic,"
(Downloaded August 31, 2009)
15 Letter from Sharon D. James, United States Department of State, to Mark Carruthers, ArmorGroup North America Incorporated, September 28, 2008, p. 1.
(Downloaded August 20, 2009)
16 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, pp. 6-7.
17 Their statements are available at the Senate Committee on Homeland Security and Governmental Affairs website. (Downloaded August 27, 2009)
18 Local Guard Services Kabul, Afghanistan, Contract No. S-AQMPD-07-C0054, Section B.3 and B.4, pp. 5-19 and USASpending.gov, "Federal Contracts for Contract ID Number (PIID) : SAQMPD07C0054, Federal Fiscal Year : 2009." (Downloaded August 27, 2009)
19 Testimony of Samuel Brinkley, Vice President,
Homeland and International Security Services, Wackenhut Services,
Incorporated, June 10, 2009, p. 1.
20 Local Guard Services Kabul, Afghanistan, Contract No. S-AQMPD-07-C0054, Section C, C.3.1.1 (Guard Duty Hour Limits), p. 35.
21 Frank Munger, "OR guards agree to help in Afghanistan: New posts to alleviate shortages in personnel," Knoxnews.com, August 22, 2009.
(Downloaded August 20, 2009)
22 Gurkhas are people from Nepal and Northern India
who are best known for their history of bravery and strength in the
Indian Army's Gurkha regiments and the British Army's Brigade of
Gurkhas. The term "Gurkha" may also be used generically to describe
guards from the region who are employed by private security contractors.
There is a high degree of variability in the skills and training.
23 New Information about the Guard Force Contract at the U.S. Embassy in Kabul, p. 3.
24 Local Guard Services Kabul, Afghanistan, Contract No. S-AQMPD-07-C0054, Section H, H.4.1 (General), p. 52.
25 Rhoda Margesson, "Afghan Refugees: Current Status and Future Prospects," January 26, 2007, p. 7. (Downloaded August 27, 2009) and Islamic.World.Net, "5 Pillars of Islam."
(Downloaded September 1, 2009)
26 United States Naval Academy, Stockdale Center for Ethical Leadership, "Symposiums & Seminars: McCain Conference." (Downloaded August 27, 2009)
27 Public Law 110-417, Sec. 832, "Sense of Congress on Performance by Private Security Contractors of Certain Functions in an Area of Combat Operations."
(Downloaded August 27, 2009)
28 110th Congress, Senate Bill S. 3001, "National Defense Authorization Act for Fiscal Year 2009."
(Downloaded August 31, 2009)
29 Sauer v. ArmorGroup North America, Incorporated,
COMPLAINT FOR DECLARATORY, INJUNCTIVE, AND MONETARY RELIEF AND JURY
DEMAND, CASE # 1:08-cv-00698-RCL, Complaint, Filed April 24, 2008, pp. 3
and 11.
30 Sauer v. ArmorGroup North America, Incorporated,
COMPLAINT FOR DECLARATORY, INJUNCTIVE, AND MONETARY RELIEF AND JURY
DEMAND, CASE # 1:08-cv-00698-RCL, Complaint, Filed April 24, 2008, p.
19.
31 “Briton held in Iraq over shooting,” BBC News, August 10, 2009. (Downloaded August 31, 2009); and Deborah Haynes and Richard Ford, “Briton Facing Iraq Murder Trial on Probation for Gun Offence,” August 13, 2009. (Downloaded August 31, 2009)
