Two U.N. investigations into Israel’s allegations against the agency are underway, but the European Commission -– the third biggest donor to UNRWA after the United States and Germany -– has demanded a separate audit and wants to appoint experts to carry it out. The audit would focus “on the control systems needed to prevent the possible involvement of (UNRWA) staff in terrorist activities,” the EU’s executive branch said. It also is insisting on “a review of all UNRWA staff” to confirm they had no role in the attacks.


Was UNRWA subject to examination or investigation regarding the adequacy of its audits before the terrorist attacks? The U.S. and Germany have demanded an audit to focus on the control systems needed to prevent UNRWA staff to engage in terrorist activities, but looking at the UNRWA website, it does mention some internal audit, and I saw no red flags until I read this news. So I am wondering if people raised some red flags before the terrorist attacks happened.

  • One thing to keep in mind is that aid agencies having to "hold their nose" in which armed groups they deal with to deliver aid to civilians under those groups' areas of controls is not unheard of. Which is not to say either that some UNRWA expat staff may not have crossed the line to sympathizing with Hamas either. Mar 6 at 16:48

2 Answers 2


Depending exactly how you define "scrutiny", yes. For example in 2009 the (pro-Israel, according to Wikipedia) Washington Institute for Near East Policy had a lengthy piece on UNRWA which says among other things (pp. 28-29):

Despite the awkward construction of section 301(c), when the United States does urge action regarding terrorism, the UNRWA treats the request seriously, sometimes with concrete results. For instance, in a November 1, 2002, letter to the agency, the State Department suggested several steps it might take toward compliance with 301 (c) matters, such as providing reports, establishing a training program for staff, providing information on refugees removed from UNRWA rolls as a result of 301(c) requirements, discontinuing support for allegedly militant-linked youth activity centers in the West Bank and Gaza, maintaining contacts with Israeli authorities, reporting on disciplinary actions taken against staff who had failed to maintain the impartiality and neutrality required of UN staff, and instituting a written plan for reference checks on individuals hired for emergency programs. UNRWA responded with assurances that it no longer supported the youth activity centers (other than by easily monitored aid, such as the provision of athletic equipment, computer training, etc.), that reference checks were being made on individuals hired for emergency programs (except for the thousands of short-term job creation program laborers), and that it would report on its efforts in the other areas twice a year.

One less successful U.S. approach was attempted in 2003, when Congress asked the Government Accountability Office (GAO) for a report concerning “the extent to which the Department of State is complying with section 301(c)” and “the implementation of procedures that have been established to meet the standards of the Department of State regarding compliance with…301(c).” The resultant GAO report, submitted to the Congressional Appropriations Committees on November 17, 2003, was only mildly critical of the State Department, faulting it for not providing definitions of the terms used in 301(c), but praising it for requiring reports and certifications from UNRWA (as if those were the same as taking actual steps to implement 301(c)’s requirements), for appointing an officer to monitor UNRWA, and for funding UNRWA international staff tasked with inspecting the agency’s facilities (i.e., the operations support officers discussed in the previous chapter). The report did not criticize UNRWA for failing to implement 301(c), but rather presented the agency sympathetically, as being “constrained” by several factors:

  • lack of official Israeli and/or PA governmental review for staff applications in Gaza and the West Bank (in fact, UNRWA had never sought such review);
  • lack of information on arrests of current or potential staff members (although UNRWA had sought arrest information on the former, it had not done so with regard to potential hires);
  • an inability to halt armed incursions into its facilities (certainly a valid point);
  • an inability to query beneficiaries as to their compliance with 301(c) (because asking such questions would endanger the staff member doing the questioning ) or to verify responses if questions were asked.

Because the GAO portrayed UNRWA as being constrained from implementing 301(c) rather than being reluctant or opposed to such action, congressional reaction to the report was muted. The report did not, on its face, provide a clear basis for Congress to pressure UNRWA into changing its procedures in any fundamental way, and nothing seems to have come of the GAO’s assessment.

Another example of American pressure having little practical effect occurred in 2005, when the United States asked UNRWA (along with other U.S.-funded UN agencies) to make sure it was not inadvertently financing terrorism. Via a June 26 letter, the U.S. embassy in Amman asked UNRWA to (1) report on its procedures for avoiding contractual or financial relationships with terrorists, and (2) vet its “prospective and existing partners” against both the UN 1267 Sanctions Committee list and the U.S. Treasury Department’s list of entities and individuals tied to terrorism (i.e., the “OFAC list” maintained by the department’s Office of Foreign Assets Control). Although UNRWA agreed to begin comparing its payee lists against the 1267 Committee list, it noted that the OFAC request was under consideration by the UN legal counsel in New York; the agency promised to address the issue once it received the legal counsel’s advice. The legal counsel’s opinion, issued via a letter to the U.S. permanent representative to the UN in early 2006, concluded that it would not be appropriate for a UN organ to establish a verification regime that included a list of possible terrorist entities developed by one member state. Accordingly, UNRWA declined to make the requested OFAC checks, and the United States did not pursue the matter.

A later (2016) CRS report talks about later rounds of US efforts to scrutinize UNRWA in those terrorism regards:

A May 2009 GAO report said that, since a previous GAO report in 2003, UNRWA and the State Department (aka State) had strengthened their policies and procedures to conform with Section 301(c) legal requirements, but that "weaknesses remain." Neither report found UNRWA to be in noncompliance with Section 301(c), and to date, no arm of the U.S. government has made such a finding. In November 2009, State and UNRWA signed a nonbinding "Framework for Cooperation" for 2010. The document agreed that, along with the compliance reports UNRWA submits to State biannually, State would use 15 enumerated criteria "as a way to evaluate" UNRWA's compliance with Section 301(c). [The Department of?] State has signed a similar document with UNRWA in each subsequent year.

According to the State Department, "Every six months, UNRWA checks the names of the approximately 5.2 million registered Palestinian refugees, other persons registered to receive UNRWA services, UNRWA staff members, and persons and non-state entities to/from which UNRWA has made/received payments, including suppliers, microfinance loan recipients, and other third parties, against the Consolidated United Nations Security Council Sanctions List. To date, there have been no matches."

It took me a while to find the 2018 State Department announcement (under the Trump administration) that cut funding to UNRWA (because it's seemingly no longer on their site) but it doesn't mention terrorism, just that "the United States was no longer willing to shoulder the very disproportionate share of the burden of UNRWA’s costs [...]".

FWTW, the June 2023 renewed "Framework for Cooperation" between UNRWA and the US also mentions that

UNRWA intends to continue to provide semi-annual section 301(c) reporting to PRM, as discussed in Section II of this Framework.

It also talks of an Annex with reporting specifics that is not part of the same PDF though, and probably doesn't detail how the US intended to review the reports anyway.


Was UNRWA subject to examination or investigation regarding the adequacy of its audits before the terrorist attacks?


During one of the previous rounds of fighting in Gaza in 2014, UNRWA had to repeatedly admit that it's facilities were being used by Hamas (one, two, three).

As the result a UN investigation has been launched (excerpt of the relevant parts here, the full report here). As you can see from the report, UNRWA took zero responsibility, and claimed that it conducts inspections and reports violations while also admitting that it explicitly instructed employees and guards to stay away on these specific dates and sets of keys were conveniently misplaced.


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