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The report said that the problems resulted in a possible loss of $12 million through flawed contracts that exposed the agency to drastic currency fluctuations.
While the CPA-IG's October 30, 2004 report to Congress had markedly less detail than previous reports, it noted numerous, troubling irregularities in the CPA's management of Iraqi revenues during the occupation. These deviations from legal obligations and federal contracting norms included:
* A case where approval of funds took place after a contract was signed ($7,050,000).11
* 34 cases where advance payments totaling more than $1.5 billion were made from the DFI to the U.S. Army Corps of Engineers to pay primarily for fuel imports and restoration of oil and electricity infrastructure. This is particularly noteworthy because Kellogg, Brown, and Root (KBR) was securing fuel for the Army Corps of Engineers during the occupation.12 In December 2003, Pentagon auditors uncovered an overcharge of $61 million by KBR on a contract to supply fuel for the military in Iraq, and again, in January 2004, KBR repaid $6.3 million in overcharges and kickbacks for fuel contracts in Kuwait.13
* 37 cases where contracting files could not be located, for contracts totaling more than $185 million.14
* One case where a contract was entered into against the explicit objections of the only Iraqi representative to the spending board (Program Review Board)15
* One case where an advance of almost $3 million was given by a CPA senior advisor without justification (the contract was later canceled and the advisor left the CPA).16
* Several cases where the CPA used DFI funds for purposes explicitly forbidden by statutory laws under occupation.17
* A disbursement of $1.4 billion, in the occupation's final days, to the Iraqi Ministry of Finance under the budget line item "transfer payments." The auditors were "unable to obtain further analysis or information regarding the intended utilization of this budget line item."18
* 111 cases where reports or other supporting documentation describing services received for contracts signed and payments made could not be found, for work totaling more than $19 million.