C8.5.5. Conducting EUM in a Hostile Environment. The following policy sets procedures for the conduct of EUM when force protection limitations exist that could endanger USG personnel performing Routine EUM observations, EEUM inventories, and physical security inspections of Partner Nations’ (PN) storage facilities. This process applies to reporting potential violations and the accountability of Enhanced EUM (EEUM) defense articles identified in SAMM
Table C8.T4. or other defense articles that require EEUM and / or additional U.S. required control measures as determined in the transfer approval process. To mitigate proliferation and to comply with the requirement in Section 40A of the Arms Export Control Act
(22 U.S.C. 2785) that the EUM program provide ‘reasonable assurance’ that the PN is complying with U.S. End Use requirements, the following procedures are to be implemented.
C8.5.5.1. Accountability of U.S. defense articles deployed to restricted areas that cannot be inventoried due to heightened security risk. When conditions allow, the SCO shall conduct an initial 100% inventory, by serial number, of all EEUM designated articles prior to shipment/delivery into hostile areas. The SCO shall also assist locally employed staff and the PN to improve inventory management and accountability procedures of EEUM designated articles currently in restricted areas.
C8.5.5.2. Partner Nation Self-Reporting. Under certain circumstances, when USG led assessments are not possible, PN ‘Self-Reporting’ can be accomplished by providing the SCO with records of inventories, other accountability records, or the use of barcode scanning. PN self-reporting is authorized only when the following criteria are met:
- The CCMD issues a memorandum to the SCO and DSCA, endorsed at the SES/07 General Officer/Flag Officer level, outlining the increased security risk situation, restricted areas, and the necessity to modify standard peacetime accountability and physical security inspection processes outlined in SAMM Table C8.T2.
- The PN shall provide the SCO with a signed Control Plan for each EEUM designated defense article that the USG has transferred to the PN under grant authorities (e.g., title 10 BPC, Presidential Drawdowns, Third Party Transfers). Signed Control Plans of EEUM designated articles are required to establish EUM requirements for item transfers outside of Letter of Offer and Agreements (LOA) EUM assurances. A template is located in the SCIP-EUM database under Support-Policy/Procedures Memos.
- The PN agrees to produce and to sign an EEUM self-reporting Concept of Operations (CONOPS) describing self-reporting procedures with conducting end use monitoring in the absence of USG led observation and assessment.
