One of the single points of confliction you may have as an AFRICA OSC will be End-Use Monitoring (EUM). You were given a quick class on this during the DISCS course, but you should take time to reflect on the DISCS Green Book and chapter two of the Security Assistance Management Manual (SAMM) once you arrive at the Embassy. Your situation with EUM will be different in each country you serve in, but in Africa, there will be numerous similar situations you will have to navigate.
When you talk to AFRICA OSCs, almost all of them have a EUM story. Someone in the crowd once had to convince their partner nation that they had to inventory rockets, which only the partner nation President could authorize. Can you imagine the partner nation conversations and the required paperwork the AFRICA OSC had to do to accomplish that task? Another AFRICA OSC will curse his/her arse off about Night Vision Goggle inspections and then yell out loud about how NVG-7Bs stickers fall off, so how do you know which serial number is which? How do you think she solved that issue? NVG’s are the single biggest EUM item in Africa. Then another AFRICA OSC will try to up the others about his EUM nightmare and talk about having to inspect all of the “changes” the partner nation did to a recent Foreign Military Sale (FMS), without informing the United States before doing so. Every one of them will more than likely curse this EUM burden; however, they should/will all understand the necessity of its purpose and their role in conducting EUM.
Quick review: why do we do EUM? Mainly, we do EUM because we have to by law, and for good reasons.
Security Assistance Management Manual (SAMM) Chapter 2.1.5 FMS Program Management and Oversight.
End-Use Monitoring (EUM). The AECA requires a comprehensive EUM program for arms sales and transfers to verify a recipient’s compliance with USG export controls. The DoS Political-Military Bureau Office of Regional Security and Arms Transfers (DoS (PM/RSAT)) monitors, reports, and addresses unauthorized arms transfers and diversions in accordance with the AECA, section 3 (22 USC 2753). See Chapter 8 for EUM information.
C220.127.116.11.1. Golden Sentry. The SCO is normally assigned responsibility for in-country activities in support of the DoD EUM program, called Golden Sentry. The DoS manages a similar program, called Blue Lantern, for items transferred through the DCS process. SCOs work with partner nation counterparts to ensure compliance with EUM requirements and coordinates activities with the in-country Blue Lantern program manager within the Embassy. SCOs should be prepared for a DSCA led in-country Compliance Assessment Visit (CAV) every 18 to 24 months. See Table C8.T2. for a comprehensive list of SCO EUM responsibilities and Figure C8.F2. for EUM related forms.
C18.104.22.168.2. SCIP EUM Community. SCOs use the SCIP EUM Community to track defense articles transferred to the partner nation, to conduct periodic reporting, and to capture SCO costs associated with the execution of the EUM program.
C22.214.171.124.3. EUM Compliance Plan. SCOs work with the partner nation to develop a combined EUM control plan that spells out procedures to ensure requirements specified in the appropriate transfer documents are met. EUM Control Plans should include: partner nation internal accountability procedures, procedures for reporting required inventories and inspections; procedures for record-keeping on the part of the host nation and the SCO, procedures for reporting possible violations, and procedures to be followed for EUM visits. When necessary, DSCA (Integrated Regional Teams (IRT)) can assist with Control Plan development, contact DSCA.NCR.BPC.MBX.EUM-HELPDESK@mail.mil.
C126.96.36.199.4. Change of end-use. Examples of possible changes of end-use include demilitarization and scrapping, disposal, use of U.S.-provided equipment as displays or targets, and transfer to civil government, police, or educational institutions. These change of end-use actions all require prior approval from the USG, specifically, DoS (PM/RSAT). If the partner nation has been granted approval to dispose of materiel by the DoS, its disposal procedures must follow in form and content those used by DLA Disposition Services, as described in DoD 4160.21-M-1, the DoD Defense Demilitarization Manual. SCOs are responsible for ensuring DoD disposal procedures are followed by the partner nation. In some cases, this may mean personally witnessing demilitarization/disposal actions or coordinating with the appropriate MILDEP to have a subject matter expert witness demilitarization/disposal. A disposal process that fails to meet US demilitarization standards should be reported through the appropriate DoS and DoD chains of command to DoS (PM/RSAT). If environmental agreements exist with the partner nation, the SCO must ensure “before” and “after” conditions are recorded. Disposal procedures are discussed further in Section C8.7. and Section C8.8.
C188.8.131.52.5. Third Party Transfers. Foreign Governments may not transfer title or possession of US origin defense articles or services to anyone not an officer, employee, or agent of that country without prior written consent from the USG. Requests for re-transfer are submitted to DoS (PM/RSAT). SCOs are often called upon to explain US third party transfer policies to partner nations and assist in submitting partner nation third party transfer requests. See Section C8.8. and Table C8.T7. for information requirement on third party transfers request to DoS. Templates, samples, and points of contact can be found at the PM/RSAT web page.
C184.108.40.206.6. Violations. When an indication of unauthorized end-use is found and the discrepancy is not resolved locally, the Country Team forwards the information to DoS (PM/RSAT) to determine whether an investigation and report to Congress is required. Section C8.6. discusses violations and reporting procedures.
Did you read all that? If not, it was critical stuff, so I suggest you take the time to re-read it. No, really – re-read it and understand it.
War creates the need for modifications
I have a war story from Iraq that now looking back makes me think of EUM. When I was a Lieutenant in 2004, we rolled into Northern Iraq in unarmored HUMWVs with the soft top off, and a modified M6 weapons mount with a .50 cal or M240B on the back of our M998 HMMWVs. We constructed wooden U-shaped boxes in the back of the vehicle around the gunner and filled them with sandbags as there were recent intelligence reports about roadside bombs happening. We all had our weapons pointed out, not wearing our seatbelts, and were prepared to stop and hit the ground and return fire if necessary. Imagine applying a Vietnam era React to Ambush doctrine to a “modern” war in mobile vehicles. We were moving in just as the insurgency in Iraq was sprouting its roots, and our military was not prepared for the roadside bomb – a new deadly acronym: IED. Over the next five months, I was selected to be the Battalion S4 (Logistics Officer), I spent the next eight months in that position, and our battalion staff modified more US Army vehicles than I can imagine adjusting to the local threat environment. We bought local steel plates so much that the price went up weekly. Our welders turned 5-ton troop carriers into MadMax troop carriers that sustained five (or more) crew-served weapons, with spring-loaded ramps off the back. I remember one week when the single significant event was when the laser cutter broke. The Battalion Maintenance Officer drove to Kuwait (3 days one way) to buy a part to fix it ($35.00) – the cost of the trip (at least $3,000).
When the Military Police M1115 Armored Vehicles eventually arrived from across the entire Army about halfway through our tour, we almost didn’t know what to do with this new technology. We had spent seven months exposed to the environment, and now our military had given us this completely protective (somewhat) vehicle. Our soldier’s kit and vehicle fleet looked like a ragtag African military soldier and fleet. The fleet had different colors because we had bought local paint to paint over the steel we had welded to the side of our vehicles, different vehicles sets (one patrol could have a MadMax 5-ton, a Bradley Fighting Vehicle, and two armored HMMWS), different stuff welded onto the side of different vehicles. We had moved to survival mode as soon as we crossed the line of departure in Kuwait.
We didn’t care about who authorized the “modification” of a vehicle; what we cared about was surviving. By 2005 the Department of Defense realized this and slowly modified the force at a great expense to our taxpayers, but the catastrophic deaths somewhat ended for a while. The enemy adapted, as it always does. More lethal IEDs were produced, and more Americans died. During my time in Iraq, we also put a lot of Americans and Iraqis in body bags. I never knew that a dead soldier became a supply item and thus the S4’s responsibility.
After that deployment, every time I look at an African military, I wonder if they are as unprepared for whatever challenge they have as compared to as the United States was unprepared for the Iraqi insurgency. I am humbled to know that no matter what military you are in, you adapt to the environment your government sends you into.
When your AFRICA OSC partner adjusts an item, what do you say?
So I violated EUM policies every time I ordered the upgrading of a US military vehicle to meet the current threat environment in Iraq. Now, as an AFRICA OSC, I have to report on these same types of violations. Mmmmm. Well, the law is the law – report it. Luckily, my violations in Iraq were being ordered to be done at the General Officer level. You actually will rarely encompass this issue, and if you do, I suggest putting a bit of common sense into the situation. If the partner nation changed a weapons mount to allow for a PKM to be mounted, does that matter? No, it doesn’t. What the regulation is talking about mainly is the transfer of equipment, perhaps from the Ministry of Defense to the Ministry of Interior. The change of use(age) of the item is what we are concerned with. We want to know when an article has reached its life cycle and moved onto the rust bucket graveyard of the world. We also don’t want our military items being used for civilian law enforcement, or what some would say as – militarization of the civilian security (police) forces. You will more than likely have many issues enforcing this part of the regulation. When you enter into a base and see a few dozen HMMWVs on blocks in the boneyard, your EUM sensors should go off.
One night over some horrible African pizzas and a few beers, I debated with some other AFRICA OSCs what “disposal procedures” meant in Africa. As an AFRICA OSC, it is your job to culturally translate the difference between what your host nation and the US regulations mean concerning disposal procedures. Most African countries will move a vehicle to their junkyard, and continue to take parts from that vehicle over the next five to 30 years. The vehicle will never actually meet our standards of needing to be disposed of because African’s never view something as disposable. Trying to talk them through this to review some rusted non-mission capable HMMWV is probably not worth your time, the rub with a partner nation, or the paperwork required to do it. More than likely, it will just sit there and rot, rust, and deteriorate: be it a truck, a boat, or a plane.
EUM: An excellent reason to get out of the office and engage the partner nation
So far, this blog has been somewhat cynical about EUM, which has been on purpose. Now it is time to look at the positives of the program. The program promotes the enforcement of security of military items, especially the Enhanced EUM (EEUM) items. The United States, more than likely, does not want weapons, ammunition, armed drones, rockets, F-16s, etc. coming into the hands of bad actors. Through the EUM process, we assist our partner nations with ensuring their systems adhere to our standards of security for these sensitive items.
How do you explain these “rules” to your partner nation? Perhaps some countries have purchased equipment from the United States and just signed the paperwork without actually reading it, and translating it for their senior leaders to understand. Most often, in Africa, meeting the standards of our EEUM requirements will be difficult. Primarily the criteria for tracking singing in and out and any electrical lighting requirements will be questionable at best. Consistent electricity is rare on military bases in Africa. Another issue will be hinges and doors. Imagine convincing an African partner that the doors to their arms room is on wrong and are not made of the right material. Perhaps the door swings out, and the hinges are on the outside and not the inside. Maybe the door is not steel or is steel but only ¼ inch thick. These things sound petty, but they are part of the requirements. Most partners might sign the agreement and have no clue as to the exact specifications they agreed to secure items.
What are the culture problems with EUM?
Can you imagine allowing a foreign partner to inspect a US arms room and take serial numbers, perhaps pictures, and count the numbers of each weapon? I’ve heard of partner nations moving equipment into another place, covering weapons with sheets, and even building a stand-alone arms room for US equipment only. EUM also can come across to a partner nation as overbearing or upety. Another nation is coming in to tell them how to secure and use items that they have rightfully purchased.
Arriving at station
Concerning EUM – the first thing I would ask my OSC NCO is: When was the last time you submitted a quarterly EUM report into the Security Cooperation Information Portal (SCIP)? This will give you a good idea of the status of your EUM program. You may have EEUM items or not. If not, your EUM will be as easy as observing a few things every three to four months and submitting a report. If you have EEUM, then I suggest you make an engagement plan to execute the requirement.
In some countries, it might take the President to allow EEUM; in others, it may simply be a written request. Either way, to conduct EEUM, it is wise to get everything you need in writing and approved by at least someone at the general officer level. It is also possibly necessary to memorize a few phrases that answer the question, “Why does the United States require this?”.
Overall, End-Use Monitoring will not get you an accolades from anyone, but it is required, and it is part of your job.