U.S. Embassy Bamako: Family Members on ‘Authorized Departure’ From Mali. Again.

Posted: 4:09 am ET
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In December 2015, the U.S. Embassy in Mail went on “authorized departure” for non-emergency staff and family members.

On March 1, 2016, the “authorized departure” order was lifted.

On July 1, 2016, the State Department updated its Travel Warning for Mali with a notice of an FAA NOTAM for Mali and the authorized departure of embassy family members again:

The Department of State warns U.S. citizens traveling to or residing in Mali of ongoing terrorist attacks and criminal violence in Mali. The security environment in Mali remains fluid, and the potential for attacks throughout the country, including in Bamako, remains high. Additionally, the Federal Aviation Administration (FAA) has revised its advisory NOTAM for Mali advising U.S. civil aviation to avoid flying below 26,000 ft (FL260) over the airspace of Mali. This Travel Warning is being updated to notify U.S. citizens that on July 1, 2016, the Department of State ordered the departure of eligible family members 21 and younger and authorized the departure of their accompanying adult parents from the U.S. Embassy in Bamako.  This notice replaces the Travel Warning issued on April 21, 2016.

Violent extremist groups targeting foreigners, including al-Qa’ida in the Lands of Islamic Maghreb (AQIM) and al-Murabitoun, have claimed responsibility for multiple terrorist attacks in Mali over the past year, as well as kidnappings in Timbuktu and along the border with Burkina Faso.  Furthermore, violent extremist elements continue to target Malian security forces, resulting in attacks on Malian government outposts and base camps for The United Nations Multidimensional Integrated Stabilization Mission in Mali (MINUSMA).

On March 21, 2016, heavily armed assailants attacked the European Union’s Training Mission (EUTM) headquarters and primary residence in the diplomatic enclave in Bamako.  Although no U.S. citizens were affected by the attack and no EUTM staffs were injured, one Malian security officer was shot and required extensive medical care. AQIM claimed responsibility for the attack.

On November 20, 2015, one U.S. citizen and 19 other foreigners were murdered when heavily armed assailants stormed the Radisson Blu Hotel in Bamako using gunfire and grenades.  AQIM and al-Murabitoun claimed responsibility for the attack.

Following the November 20, 2015 attacks on the Radisson Blu Hotel in Bamako, the government of Mali increased its security presence in Bamako.  Roadblocks and random police checkpoints, especially between sundown and sun-up, are possible. U.S. government personnel are restricted from traveling outside the Bamako region, and may be subject to other restrictions, as security situations warrant.  U.S. citizens should consider taking similar precautions, are reminded to stay vigilant and aware of their surroundings, and exercise caution throughout the country, especially at night.

Read in full here.

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@StateDept Issues Policy For Employees With Personal Domestic Workers, Spells Out Penalties

Posted: 3:49 am ET
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In February 2016, the State Department issued a formal policy for employees with  personal domestic workers.

The Department expects its employees to treat personal domestic workers in a manner reflecting basic concepts of dignity.  All employees, their family members, and members of household are advised that the use of physical force, threats of force, coercion (including threatened withdrawal of immigration benefits), or fraud to compel labor or sexual services from a personal domestic worker could constitute the crime of trafficking in persons under U.S. law.  Further, all employees are expected to abide by the provisions of their contracts with personal domestic workers.  

Personal domestic workers are neither Federal employees nor employees of U.S. diplomatic missions.  They are employees of the individual(s) in whose home they work and provide personal services. The policy covers direct-hire Executive Branch employees assigned abroad under Chief of Mission authority who are are expected to ensure that personal domestic workers employed in their homes are treated fairly and provided employment conditions in accordance with local law and custom, to the extent consistent with 3 FAM 4128.”  

The following regulations pertain to all personnel under Chief of Mission authority.  Post management may develop a policy to implement these regulations in conjunction with actions required or permitted under local law.  Any such policy must adhere to the regulations contained in this chapter, be compliant with local labor law and be fully consistent with U.S. human rights and anti-trafficking policies. 

3 FAM 4128.2-1  Employees Bringing  Personal Domestic Workers to Post
(CT:PER-804;   02-01-2016)

(Applies to Executive Branch employees under Chief of Mission Authority)

All Executive Branch employees assigned abroad under Chief of Mission authority who bring personal domestic workers to post with them (i.e., where personal domestic workers obtain immigration benefits in order to accompany an employee to post) are expected to: 

(1)  Enter into a written employment contract with the personal domestic worker before that person requests a visa to travel to post or is otherwise assisted by the mission in coming to or remaining at post; 

(2)  Ensure that the contract complies with local law, 3 FAM 4128, and any applicable post policy, including post policy on the form of payment to personal domestic workers.  Contracts must include the following terms: 

(a)  Description of duties:  The contract must describe the work to be performed, e.g. housekeeping, gardening, child care, etc. 

(b)  Hours of work:  The contract must state the time of the normal working hours and total number of hours worked per week.  A typical work week consists of 35 to 40 hours per week.  The contract must also provide the personal domestic worker with a minimum of at least 1 full day off each week and reflect local law requirements, if any, with regard to paid holidays, sick days, and vacation days.  If local law does not make provision for paid leave in these circumstances, the contract must explicitly state whether such leave will be provided and if so, on what terms.  

(c)  Wages:  The contract must state the hourly/weekly/monthly wage (prevailing or no less than minimum rate) to be paid to the personal domestic worker and the frequency with which the worker will be paid, which must be at least once a month.  It must also state that deductions (e.g., food, lodging, etc.) may not be taken from the wages, except for deductions required by local law (e.g. social security) or requested by the employee (such as repayment of a salary advance) or where such deductions are allowed because the employee who provides lodging pays for the lodging with personal funds.  Employees living in no-cost government-provided housing or in government-subsidized housing may not deduct lodging expenses from wages, nor may they pay a reduced minimum wage for live-in domestic workers, even if such deductions or such a rate is available under local law.  Deductions for lodging or payment of a reduced minimum wage for live-in domestic workers where available under local law are permissible only for employees who provide lodging for domestic workers in housing paid for with personal funds.  The contract must include a provision for severance and/or separation payments on termination of employment, if required by local law. 

(d)  Overtime work:  The contract must state that any hours worked in excess of the normal working hours are considered overtime.  The contract must clearly state the rate for overtime work.  The rate for overtime must be at least as much as the hourly rate paid for normal working hours and must be consistent with local law requirements.  Hours the personal domestic worker is required to stay in the residence because he or she has to be “on stand by” are considered work/overtime hours and must be paid as such.  Where local law and contractual terms permit, the employer may authorize compensatory time in lieu of overtime, provided the employee is given sufficient opportunity to utilize compensatory time off that is earned. 

(e)  Possession of identity and personal documents:  The contract must state that all identity, travel, and personal documents, including the passport and visa must remain in the sole possession of the personal domestic worker. 

(f)   Living conditions:  If the personal domestic worker lives in the residence, the contract must reflect that the employer is obligated to provide adequate and reasonable accommodations.  This will include at a minimum a private bed, access to a bathroom, kitchen facilities, and proper food storage.

(g)  Transportation to and from home country: The contract must state that the employer will pay for the transportation of the personal domestic worker to and from post, unless the worker decides to stay at post and can do so legally.  These costs may not be deducted from the worker’s salary. However, the employer is not responsible for any travel that the domestic worker takes on their own while at post.

(h)  Provide a copy of the signed final contract to the personal domestic worker for his/her records; and 

(i)   Submit to the Management Officer or his/her designee a signed declaration indicating that the sponsoring employee has a written contract with the personal domestic worker that meets the standards of 3 FAM 4128, local labor law, and any applicable post policy (see 3 FAM 4128.5 for a sample declaration).  The declaration must be submitted before the mission provides assistance in obtaining a visa for the personal domestic worker or the mission otherwise assists the personal domestic worker in coming to or remaining at post.  Post management may also require submission of the written contract before requesting a personal domestic worker’s visa.

(j)   Maintain contemporaneous records of payment during the assignment.  Employees are encouraged to keep those records for 5 years after the termination of employment, regardless of whether payment is made via electronic transfer, by check, or in cash.  Payment records must indicate the date of payment and amount paid. If payment is made by cash, these records must make clear to both the employer and the personal domestic worker that payment was made and received on said date.

(k)  Adhere to post policy on payment of personal domestic workers.  When feasible and appropriate, post policy shall require payment of salary by check or electronic fund transfer to a local bank account in the name of the personal domestic worker.    

(l)   Ensure that employment contracts are written in English, and, if the worker does not understand English, the contract must also be written in a language s/he understands. The contract must be signed by both the employer and the worker.

3 FAM 4128.2-2  Employees Employing Locally Hired Personal Domestic Workers Abroad
(CT:PER-804;   02-01-2016)

(Applies to Executive Branch employees under Chief of Mission Authority)

a. All Executive Branch employees assigned abroad under Chief of Mission authority who locally hire personal domestic workers to work for more than 20 hours per week (who are either nationals of the receiving state or otherwise authorized to work in that state) are required to have a written contract with such workers that include all the required elements below.

b. All employees who meet the criteria of 3 FAM 4128.2-2(a) are encouraged to keep contemporaneous records of payment during and for up to 5 years after the termination of employment, regardless of whether payment is made via electronic transfer, by check, or in cash.  Payment records must indicate date of payment and amount paid.  If payment is made by cash, these records must make clear to both the employer and the personal domestic worker that payment was made and received on said date.

c.  Adhere to post policy on payment of personal domestic workers.  When feasible and appropriate, post policy shall require payment of salary by check or electronic fund transfer to a local bank account established in the name of the personal domestic worker.

d. Post management should ensure employees are aware of the contractual requirements for personal domestic workers through check-in procedures, management notices, and/or other appropriate means.  Post management may require submission of a signed declaration attesting to compliance with local law, 3 FAM 4128, and any applicable post policy, including post policy on the form of payment to personal domestic workers when entering into an employment contract with locally-hired personal domestic workers, and/or submission of copies of such contracts. 

e. All contracts with a locally hired personal domestic worker must be in English.  If the worker does not understand English, the contract must also be written in a language s/he understands. The contract must be signed by both the employer and the worker.

f.  All employment contracts with a locally hired personal domestic worker must be in accordance with local law, 3 FAM 4128, and any applicable post policy, including post policy on the form of payment to personal domestic workers. Contracts must include the following terms:

(1)  Description of duties:  The contract must describe the work to be performed, e.g. housekeeping, gardening, child care, etc. 

(2)   Hours of work:  The contract must state the time of the normal working hours and total number of hours worked per week.  A typical work week consists of 35 to 40 hours per week.  The contract must also provide the personal domestic worker with a minimum of at least 1 full day off each week and reflect local law requirements, if any, with regard to paid holidays, sick days, and vacation days. If local law does not make one or more provisions for paid leave in these circumstances, the contract must explicitly state whether such leave will be provided and if so, on what terms.  

(3)  Wages:  The contract must state the hourly/weekly/monthly wage (prevailing or no less than minimum rate) to be paid to the personal domestic worker and the frequency with which the worker will be paid, which must be at least once every month.  It must also state that deductions (e.g., food, lodging, etc.) may not be taken from the wages, except for deductions required by local law (e.g., social security) or requested by the employee (such as repayment of a salary advance) or where such deductions are allowed because the employee who provides lodging pays for the lodging with personal funds. Employees living in no-cost government-provided housing or in government-subsidized housing may not deduct lodging expenses from wages, nor may they pay a reduced minimum wage for live-in domestic workers, even if such deductions or such a rate is available under local law.  Deductions for lodging or payment of a reduced minimum wage for live-in domestic workers where available under local law are permissible only for employees who provide lodging for domestic workers in housing paid for with personal funds.  The contract must include a provision for severance and/or separation payments on termination of employment, if required by local law. 

(4)  Overtime work:  The contract must state that any hours worked in excess of the normal working hours are considered overtime. The contract should clearly state the rate for overtime work. The rate for overtime must be at least as much as the hourly rate paid for normal working hours and must be consistent with local law requirements. Hours the personal domestic worker is required to stay in the residence because he or she has to be “on stand by” are considered work/overtime hours and must be paid as such.  Where local law and contractual terms permit, the employer may authorize compensatory time in lieu of overtime, provided the employee is given sufficient opportunity to utilize compensatory time off that is earned.   

(5)  Living conditions:  If the domestic worker lives in the residence, the contract must reflect that the employer is obligated to provide adequate and reasonable accommodations.  This will include at a minimum a private bed, access to a bathroom, kitchen facilities, and proper food storage.

3 FAM 4128.3  Violations and Penalties
(CT:PER-804;   02-01-2016)

(Applies to Executive Branch employees under Chief of Mission Authority)

a. Any abuse or mistreatment of a personal domestic worker, including but not limited to activities which rise to the level of human trafficking, whether such actions are undertaken by an employee, dependent, or member of household is a matter of grave concern to the Department.  Employees engaging in such misconduct will be subject to discipline up to and including removal from employment.   

b. Allegations of abuse and/or mistreatment of a personal domestic worker by U.S. Government employees assigned abroad under Chief of Mission authority, family members, or members of household shall be brought to the attention of post management, including the Regional Security Officer.  The Regional Security Officer, in coordination with the DS Office of Special Investigations, will determine if there is sufficient basis for a criminal or administrative misconduct investigation.  If claims or allegations are substantiated, employees engaging in such conduct may be subject to an administrative penalty and/or referral to the Department of Justice for criminal prosecution for relevant offenses potentially including trafficking in persons.  Depending on the level of immunities, individuals may be subject to local criminal prosecution and/or civil suit.

c.  Section 3271 of Title 18 of the United States Code specifically extends the reach of federal trafficking statutes (including forced labor) to the activities of U.S. employees and those who accompany them abroad:

“Whoever, while employed by or accompanying the Federal Government outside the United States, engages in conduct outside the United States that would constitute an offense under chapter … 117 of this title [peonage, slavery, trafficking in persons] if the conduct had been engaged in within the United States or within the special maritime and territorial jurisdiction of the United States shall be punished as provided for that offense.”

d. No U.S. government employee or family member accredited to a foreign government is protected from prosecution by U.S. authorities because he or she may enjoy immunity in  the state in which he or she is assigned abroad.

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US Embassy Tashkent: OIG Report Plus What’s This About “Fun Community Policing”?

Posted: 3:13 am ET
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The U.S. Embassy in Tashkent, Uzbekistan is a medium size post with a complement of 408 authorized staff which includes foreign national employees, locally hired Americans and 64 direct-hire Americans.  State/OIG released its inspection report of  US Embassy Tashkent last April. Given that the inspection in 2008 was a limited scope review– with focus on major areas of interest rather than examining all the items covered in a traditional inspection — it is surprising that the 2016 report, a traditional inspection conducted after 7 years  is only 4 pages longer than the 2008 report.  There are no discussion about morale (excerpt that bit about nepotism as being bad for morale), or spouse employment (no spouses looking for jobs?), or schools (no dependents go to school there?). What about the embassy Health Unit? Is it good, bad, non-existent?

Summary of Findings:

  • The Ambassador steers the United States-Uzbekistan engagement in constructive ways, including the signing of agreements on counter-narcotics and the U.S. Foreign Account Tax Compliance Act.
  •   Washington end-users uniformly expressed satisfaction with Political/Economic Section reporting that provides the information needed to understand the United States- Uzbekistan relationship.
  •   American and locally employed staff members in Tashkent described the Ambassador’s collaborative style, interest in a variety of views, and openness to suggestions, in keeping with the Department’s leadership principles.
  •   The Consular Section did not comply with non-immigrant visa adjudication review standards, visa referral management and referral procedures, and consular management control requirements.
  •   The Bureau of Overseas Buildings Operations has not addressed the seismic risk by identifying suitable housing with the lowest possible risk to life safety as required by 15 Foreign Affairs Manual 252.6. The embassy has taken steps to prepare its staff for the aftermath of a major earthquake.
  •   The embassy’s social media outreach is limited by its reliance on English, rather than Russian- and Uzbek- language material.
  •   The reporting and supervisory relationships among the Centers for Disease Control and Prevention regional office, its locally employed staff, the Political/Economic Section, and the Front Office are unresolved and contentious.
  •   Innovative Practice: The embassy produced a no-cost and reliable short message service for employees.

The IG report also includes a section labeled “Tashkent Initiative Worthy of Emulation” which is rather underwhelming. Like  —  we have totally not/not seen this set of activities done elsewhere before! Dear OIG inspection team, c’mon folks — really? Where have you been all this time?

Screen Shot 2016-07-06

 

Excerpts:

American and locally employed staff members in Tashkent described the Ambassador’s collaborative style, interest in a variety of views, and openness to suggestions, in keeping with the Department’s leadership principles.
[…]
The Ambassador is aware of her chief of mission responsibilities in accordance with 2 FAM 022.7. She expressed support for internal controls, reminding the staff that fraud and misconduct cannot be tolerated, and reissuing management notices concerning illegal currency exchange and gift acceptance. The embassy has made it clear that action will be taken in accordance with regulations against those who cannot meet ethical standards. In the 14 months prior to the inspection, seven locally employed staff members were dismissed for misconduct or unethical behavior.

Tone at the Top and Standards of Conduct | American and locally employed embassy staff members told OIG of the Ambassador’s collaborative style, interest in diverse views, and openness to suggestions, in keeping with the Department’s leadership principles in 3 Foreign Affairs Manual (l) 1214. In mission-wide town hall meetings and other fora, the Ambassador has stressed the five values she wants the Mission to exemplify: gratitude, teamwork, partnership, opportunity, and balance.

Lack of a Representation Plan and Uneven Spending | Embassy Tashkent expended approximately $13,000 of its $21,418 in FY 2015 representational funding in the last 2 weeks of the fiscal year.

Interagency Working Groups Not Active | Embassy interagency working groups met infrequently, if at all, reducing their effectiveness in coordinating U.S. Government programs and policies across agencies. Embassy officers told OIG that informal exchanges of information within the mission were sufficient. Chiefs of Mission are charged under 18 FAM 005.1-6b and 18 FAM 005.1-7f with promoting a culture of interagency problem solving and leveraging a wide range of U.S. Government specialized expertise and assets under common objectives. The Law Enforcement Working Group did not meet during FY 2015. Implementation of end-use monitoring for $49.6 million in armored vehicles was not coordinated among embassy offices that could benefit through their participation.

Relationship between Embassy and CDC Office Needs Improvement | The reporting and supervisory relationships among the CDC regional office at U.S. Consulate General Almaty and Embassy Tashkent’s CDC locally employed staff, Political/Economic Section, and Front Office are unresolved and contentious.

Embassy Does Not Use Record Emails | Embassy Tashkent and the Bureau of South and Central Asian Affairs exchange daily official- informal emails but never use record emails,as required in 5 FAM 443.2, even when the exchanges contain information that facilitates decision making and document policy formulation and execution. The embassy Front Office and the Political/Economic Section report that the State Messaging and Archive Retrieval Toolset (SMART), which is meant to record and retain record emails, is too cumbersome to use. Only the Consular Section uses record emails when sending reports on child abductions. Failure to use the SMART system hinders the Department’s ability to retain and retrieve records, as required by the Federal Records Act.

Political/Economic File Management Not in Accordance with Department and Federal Regulations | Embassy Tashkent does not enforce Department and Federal regulations on records management. The Political/Economic Section does not maintain centralized files. Officers have individual files based on their own filing systems that are maintained in personal folders. As a result, these files are not accessible to others and are not archived, retired, or readily retrievable if the action officer is absent or transfers.

Social Media Outreach in English, Not in the Languages of the Host Country | The embassy’s social media outreach is hampered by its lack of Russian- and Uzbek-language material and its reliance on English. Russian media is understandably pervasive in Uzbekistan. A 2010 survey conducted by the Organization for Security and Co-operation in Europe found that 90 percent of the population spoke Uzbek and 57–70 percent spoke Russian. English is the main compulsory foreign language taught in schools, but only 1 percent of respondents to a survey of students, teachers, professors, and bureaucrats use and read English. However, as of October, 92 percent of embassy tweets and 100 percent of ambassadorial tweets sent in 2015 were in English, as were the majority of Facebook entries. Embassy officials said that a strategic decision had been made in the past to offer the embassy’s Facebook and other social media in English.

Non-Compliance with Consular Management Controls | In five areas, the embassy does not comply with management control requirements for overseas posts, as delineated in 7 FAH-1 H-630-660, “Consular Management Controls.” The FAH requires an Accountable Consular Officer (ACO), a Consular Systems Administrator (CSA), and a back-up for each.

Visa Referral Program Not Compliant with Visa Referral Systems Policy | The embassy did not comply with the visa referral management and referral procedures in the Worldwide Non-Immigrant Visa Referral Policy as described in 9 FAM Appendix K “Visa Referral Systems.” OIG found referral form or data entry errors in 39 (45 percent) of the 86 visa referral cases adjudicated in FY 2015. In 58 cases (67 percent), the case notes did not document properly the validity of the referral or the adjudicating officer’s decision. FAST officers adjudicated a total of 41 referral cases, including 33 cases that should have been adjudicated by the Consular Section Chief. The section’s annual validation study on 2014 referrals was 4 months overdue. These errors occurred because the embassy did not comply with the visa referral management and referral procedures. A non-compliant referral program inhibits the ability to identify individual instances or patterns of fraud or abuse.

Visa Adjudication Reviews are Not Compliant with Standards | The embassy does not comply with the non-immigrant visa adjudication review standards in 9 FAM 41.113 PN17 (Review of Visa Issuances) and 9 FAM 41.121 N2.3-7 (Internal Review of Refusals), which require that reviews be performed on the day of issuance or refusal, or as soon as possible thereafter. OIG examined FY 2015 adjudications through September 20, 2015. The adjudication reviews of visa issuances did not meet the review standards for 73 percent of the 219 work days on which visas were issued and for 76 percent of the 184 work days on which visas were refused. The Regional Consular Officer based in Frankfurt reported to the Bureau of Consular Affairs and the embassy that the Consular Section Chief had not conducted any reviews between December 12, 2014, and May 26, 2015. OIG found that the Consular Section Chief had not conducted any reviews between July 2, 2015, and September 20, 2015. Systematic, regular reviews of non-immigrant visa adjudications are an important management and instructional tool to maintain the highest professional standards of adjudications. Such reviews also ensure uniform and correct application of law and regulations and enhance U.S. border security. Absent such reviews, adjudicator training and uniformity of adjudications can be irregular and border security compromised.

Seismic Studies of Embassy Housing | Embassy personnel occupy eight residences that received seismic hazard rating of “Very Poor” and eight residences that received seismic ratings of “Poor” in a 2012 Bureau of Overseas Operations (OBO) study. Embassy personnel occupy 38 (of a total of 54) residences that have not been evaluated for seismic adequacy, as required by 15 FAM 252.6. Tashkent is located in an active seismic zone. An earthquake almost completely destroyed the city in 1966. The OBO Natural Hazard program categorizes Tashkent as has having a “very high” seismic risk. In accordance with 15 FAM 252.6d, embassies in high-risk seismic areas must address the seismic adequacy of residential units and seek housing that is the best suited for high-risk seismic areas. OBO has not addressed the findings of the 2012 study to reduce the seismic risk of the housing pool.

Read the whole report here: Inspection of Embassy Tashkent, Uzbekistan, March 2016 (PDF).

*

A separate but related note, we received the following email in our inbox:

Uzbekistan not only has a politically repressive government but a one with a poor understanding of market economics. Uzbekistan pegs its currency, the soum, to the dollar resulting in a currency black market. While the official exchange rate is 3000 soum to a dollar, in reality it’s closer to 6500 and the gap keeps growing. Local prices of course reflect the black market rate.

The Embassy has decided to not allow American staff to use the exchange rate citing some sort of regulation. Not only that, but after a letter from the host government urging diplomats to use the official exchange rate, the ambassador asked the FMO [financial management officer] to monitor cashier withdrawals of employees to ensure they are not using the black market rate.

Fun community policing! Very Uzbek in style!

Well, there is indeed “some sort of regulation” on this.

According to the FAH, the Chief of Mission has the authority to require all U.S. Government employees to obtain their foreign currency through U.S. Government facilities when the Chief of Mission deems it necessary. Here’s the cite:

4 FAH-3 H-361.3-2  Compliance With Laws and Regulations
(CT:FMP-82;   09-04-2013)

Whenever accommodation exchange services are established, the Chief of Mission or designee takes actions necessary to assure that all accommodation exchange is performed in full compliance with U.S. Government and host government laws and regulations; and that all American Government personnel are familiar with the provisions in 3 FAM 4123 and 22 CFR 1203.735-206, Economic and Financial Activities of Employees Abroad.  The Chief of Mission has the authority to require all U.S. Government employees to obtain their foreign currency through U.S. Government facilities when the Chief of Mission deems it necessary in order to assure full compliance.

See more here.

Note that 3 FAM 4123.1 specifically prohibits a U.S. citizen employee, spouse, or family member from engaging in “transactions at exchange rates differing from local legally available rates, unless such transactions are duly authorized in advance by the Chief of Mission.”

3 FAM 4123.1  Prohibitions in Any Foreign Country
(TL:PER-491;   12-23-2003)
(Uniform State/USAID/Commerce/Foreign Service Corps-USDA)
(Applies to Foreign Service, Foreign Service National, and Civil Service)

A U.S. citizen employee, spouse, or family member is prohibited from engaging in the following activities while present in any foreign country:

(1)  Speculation in currency exchange;

(2)  Transactions at exchange rates differing from local legally available rates, unless such transactions are duly authorized in advance by the Chief of Mission;

(3)  Sales to unauthorized persons (whether at cost or for profit) of currency acquired at preferential rates through diplomatic or other restricted arrangements;

(4)  Transactions which entail the use of the diplomatic pouch or other official mail without official authorization;

(5)  Transfers of blocked funds in violation of U.S. foreign funds and assets control;

(6)  Independent and unsanctioned private transactions which involve an employee as an individual in violation of applicable currency control regulations of the foreign government; and

(7)  Except as part of official duties, acting as an intermediary in the transfer of private funds from persons in one country to persons in another country, including the United States.

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Related items:

OIG Limited Scope Review – US Embassy Uzbekistan 2008 (PDF)

Inspection of Embassy Tashkent, Uzbekistan, March 2016 (PDF)