Sustainment. The State Department should also appoint or select an official within the Bureau of Management to help oversee State Department contracts with PMSCs. Agencies should assess their contract management needs – particularly as the US now transforms its role in the conflicts of the past two decades – and establish a baseline of personnel needs and indispensable roles to ensure contracts are properly managed and enforced.

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Enhancing training and guidance on corruption risks and countermeasures

While the Defense and State Departments provide materials, guidance, and training that specifically identify and address the role of and opportunities for corruption in government contracting, the State Department policy guidance lacks sufficient information to identify and mitigate corruption. The Defense Department’s policy guidance includes robust examples of the many ways contracting officers may see corruption. Contracting Officer and Contracting Officer Representative handbooks should be updated to provide a wider typology of different forms of contractor corruption as well as guidance on how to identify and address these practices. Contract oversight bodies must train their staff to recognize the detrimental effects of security sector corruption in host nations and the domestic establishment. The State Department should also use this updated guidance in reviewing all types of government-to-government sales of PMSCs services.

Reporting on beneficial ownership and subcontracting

Extensive supply chains allow corrupt contractors to siphon off funds through obscure subcontractors. Subcontractors can serve as fronts for bribes or self-dealing or be connected to actors working against US national security interests. Prime contractors should be required to report on all subcontracting when submitting invoices. At the very least, this should include the names of all subcontractors (including those beyond the first and second tier), their business registration and beneficial ownership status, and the itemized value of subcontracted services. The definition of beneficial ownership as included in the Corporate Transparency Act should be used. The prime contractors should also submit all information on all potential subcontractors when contractors are submitting their bids for new US contracts. The US Government should make this subcontractor information publicly available on the USAspending.gov database, which only includes information on prime contractors and excludes subcontractors. Contract oversight bodies should take full advantage of the 2021 NDAA, which mandates a beneficial ownership database maintained for all registered companies.

Improving coordination and database management of PMSC contracts

The Defense and State Departments have many offices that hire and oversee PMSCs for various needs. Without coordination, this results in different approaches and mechanisms to oversee and manage PMSCs contracts with the US Government. Many of these offices maintain databases with different information and metrics. These differences make it harder for contracting officers from various offices to assess the risks of hiring potential PMSCs because they cannot see potential problems with other US offices. A PMSC that could be disqualified from competing for one contract with one office could qualify for another. The Defense and State Departments also have difficulty pulling together reports on department-wide use of PMSCs. US agencies should jointly assess the utility of developing interagency databases to enhance information sharing on suspect contractors and vendors.