The Government Accountability Office (GAO) report, Cuba Democracy Assistance: USAID Should Improve Collection of Security Risk Information to Help Awardee Mitigation Efforts, delves into the intricacies of democracy assistance programs led by USAID, the Department of State, and the National Endowment for Democracy (NED). These programs are designed to foster democratic values and human rights in Cuba, a one-party authoritarian state that suppresses free expression, organization, and political participation. Although these initiatives align with U.S. Congressional directives under acts like the Cuban Democracy Act of 1992 and the Cuban Liberty and Democratic Solidarity Act of 1996, they face substantial opposition from the Cuban government. This opposition results in significant security risks for implementing partners, including physical and digital threats.

USAID, State, and NED provide general guidance to awardees about security risks and require them to analyze and propose mitigation measures. However, USAID does not conduct security risk assessments specific to each award, nor does it have a formalized process for gathering security risk information prior to program implementation. This lack of structured risk analysis limits the agency's ability to assist awardees in preparing effective risk responses. For instance, applicants are expected to propose risk mitigation strategies based on their own experiences and insights, but they lack access to the broader perspective that USAID could offer by leveraging its oversight of multiple awards.

The report highlights the necessity for USAID to adopt a more proactive stance. By developing a process to gather and document security risks based on its and its partners’ collective experiences, USAID could better inform awardees’ mitigation strategies. Such a centralized repository of risk knowledge would provide a comprehensive view of recurring challenges and potential solutions, which could then be tailored to specific awards. This approach is grounded in the principles outlined in GAO’s Standards for Internal Control in the Federal Government, which emphasize the importance of risk identification and response in achieving organizational objectives.

In addition to risk analysis, USAID, State, and NED support awardees through orientation sessions and ongoing communication, offering information about travel risks and available protection resources. They also direct awardees to U.S. and international programs designed to enhance security, such as those managed by the State Department’s Bureau of Democracy, Human Rights, and Labor. Despite these efforts, the report underscores that awardees often find the security guidance provided to be minimally useful, further emphasizing the need for a more robust framework.

The report also compares risk management practices in Cuba to those in other restricted environments, revealing inconsistencies in travel provisions, liability protections, and procurement approaches. These differences reflect the unique historical and political contexts of each environment but also underscore the challenges in standardizing risk management practices across regions.

One stark example of the risks faced by awardees is the case of Alan Gross, a subcontractor for one of USAID’s partners, who was arrested in Cuba in 2009 while delivering equipment to facilitate internet access. Such incidents highlight the high stakes involved in democracy assistance programs and the urgent need for comprehensive risk mitigation measures.

Ultimately, the GAO recommends that USAID’s Office of Cuban Affairs collaborate with its Office of Security to develop a systematic approach for gathering and disseminating security risk information. By doing so, the agency can better equip its awardees to navigate the complex and often hostile environment in which they operate. USAID has concurred with this recommendation and is expected to refine its processes to enhance the safety and effectiveness of its democracy assistance programs.

This blog post is intended for informational purposes only and does not guarantee accuracy or constitute legal advice. Readers are encouraged to consult official sources or legal professionals for specific guidance.