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* Atleast Project Title is Required.
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Project No. |
CTWG 01 2017
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Project Title |
Halting Terrorist Financing: APEC Workshop on Targeted Financial Sanctions Regime
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Project Status |
Completed Project
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Publication (if any) |
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Fund Account |
General Project Account
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Sub-fund |
None
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Project Year |
2017
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Project Session |
Session 1
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APEC Funding |
139,216
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Co-funding Amount |
25,000
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Total Project Value |
164,216
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Sponsoring Forum |
Counter Terrorism Working Group (CTWG)
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Topics |
Counter Terrorism
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Committee |
SOM Steering Committee on Economic and Technical Cooperation (SCE)
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Other Fora Involved |
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Other Non-APEC Stakeholders Involved |
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Proposing Economy(ies) |
Chile
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Co-Sponsoring Economies |
Australia; Japan; Papua New Guinea; Russia; United States
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Expected Start Date |
01/06/2017
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Expected Completion Date |
31/12/2017
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Project Proponent Name 1 |
Carolina Rudnick
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Job Title 1 |
International Relations Officer
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Organization 1 |
Financial Analysis Unit
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Postal Address 1 |
Moneda 975, 17th Floor, Santiago, Chile
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Telephone 1 |
56-2 24393014
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Fax 1 |
Not Applicable
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Email 1 |
crudnick@uaf.gov.cl
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Project Proponent Name 2 |
Julio Torres
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Job Title 2 |
Counterterrorism Officer
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Organization 2 |
Ministry of Foreign Affairs
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Postal Address 2 |
Teatinos 180, 14th Floor, Santiago, Chile
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Telephone 2 |
56-2 28274648
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Fax 2 |
Not Applicable
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Email 2 |
jtorres@minrel.gob.cl
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Declaration |
Carolina Rudnick and Julio Torres
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Project Summary |
This project aims to increase APEC members’ understanding of the targeted financial sanctions regime as stated in the resolutions adopted by the United Nations Security Council and the FATF’s 40 Recommendations relating to the prevention and suppression of terrorism and terrorist financing, and assist economies in strengthening the development and implementation of the terrorist financing preventive regime.
This would be achieved through a three-day workshop to be held in November 2017 in Santiago, Chile. Relevant international organizations such as the UN, FATF (or a regional body like APG), GSSC and ICCT, could present on current challenges and priorities regarding terrorist financing and money laundering, as well as implementation of the financial sanctions regime.
Additionally, an e-booklet with the presentations and concrete recommendations from the workshop would be circulated digitally to the participants and made available through the APEC website.
The workshop would provide the opportunity to exchange best practices and generate regional peer learning on issues of interest to APEC and its strategic partners, the UN and the FATF, on terrorist financing, centering on both the formal and informal financial sectors.
This project is designed in accordance with the APEC Consolidated Counter-Terrorism and Secure Trade Strategy 2011. |
Relevance |
We perceive that certain APEC economies (particularly developing economies) lack sufficient implementation and understanding of the multilateral financial sanctions regime, as required by the United Nations Security Council resolutions and the FATF Recommendations that target terrorist groups and their financiers. These regimes are becoming more complex, primarily in response to the fact that, terrorist groups themselves – the Islamic State being a chief example – are becoming more dynamic, covering greater geographical space, and in constant need of diversifying their sources of funding to adapt to the international community’s responses and fulfill their illicit objectives. Terrorist groups are increasingly delving into other aspects of transnational crime (human and drug trafficking, money laundering, etc.) to acquire funds, further hindering member economies’ ability to detect and deny their access to the international financial market.
As a result of the Workshop, member economies should have a clearer understanding of Security Council sanctions and FATF recommendations, which will in turn, benefit their implementation efforts and the capacity of economies to adapt to the changing and emerging trends in terrorist financing. The experience from international organization and member economies’ experts will contribute to this goal, while allowing participants to gauge their own situation regarding sanctions implementation and terrorist financing. Furthermore, the distribution of the e-booklet as a concrete product of the Workshop, should contribute to disseminate and share best practices for experts in capitals as well.
The project fulfills the criteria on “Secure Growth: counter terrorism”, and also relates with Anti‐corruption, good governance and transparency, including anti‐money laundering activities under Rank 2 of the APEC funding criteria, and maximizes the cross cutting issue of engagement of other multilateral organizations, mainly FATF and the UN, but also INTERPOL, etc.
The terrorist threat in the APEC region (and around the world) is growing. As a result, economies must equip themselves with the tools and expertise to derail terrorist financing, as part of a multidimensional preventive approach to tackling this problem at the national level, but also strengthening the region’s counter-terrorism capacity as a whole. |
Objectives |
1) Enhance member economies’ understanding of the nature, scope and components of the targeted financial sanctions regime, as required by the UN Security Council resolutions and FATF Recommendations, by leading a workshop.
2) Strengthen member economies’ capacity to implement the targeted financial sanctions and the terrorist financing preventive regime. Topics that may be addressed include legislative constraints, issues with ensuring due process, and inter-agency coordination, among others.
3) Share experiences and best practices in dealing with the freezing of assets within the APEC economies, in order to contribute to each member economy’s evaluation of their own capacity to implement financial sanctions.
4) To strengthen cooperation and collaboration between APEC economies by exchanging information about the contact points for foreign requests.
5) In December 2017, after finalization of the workshop, an e-booklet containing the presentations and relevant material related to the development and implementation of the targeted financial sanctions, shall be distributed to member economies and posted on the APEC website. It is intended to serve as educational and training material for officials in capitals entrusted with the implementation of financial sanctions.
6) Contribute to fulfilling the goals set out under Secure Finance, one of the four cross-cutting activity areas of the APEC Counter-Terrorism and Secure Trade Strategy, namely:
a) implementing a capacity building workshop on counterterrorism financing;
b) engaging relevant non-APEC entities to ensure that secure finance efforts are fully and effectively coordinated; and
c) implement and comply with the Financial Action Task Force Recommendations. |
Alignment |
The Workshop proposal is consistent with the 2016 APEC Leaders’ Statement which encouraged economies to continue to take actions and share best practices in the four cross-cutting areas of APEC´s Consolidated Counter-Terrorism and Secure Trade Strategy, a pledge both shared in the 2016 APEC Ministerial Meeting Joint Statement and the 2016 APEC Ministers Responsible for Trade Statement. Likewise, the focus on measures that address UN Security Council resolutions 1373 (2001) and 1390 (2002) and the effective enforcement of denying terrorist assets is a long lasting pledge of APEC´s Leaders, as stated in 2002 APEC Leaders’ Statement on Fighting Terrorism and Promoting Growth and 2001 APEC Leaders’ Statement on Counter-Terrorism.
Furthermore, the workshop is intended to achieve one of the steps defined by the Counter-Terrorism Working Group’s Proposed Workplan for 2017, which is to increase cooperation among APEC member economies to address the dramatic evolution in the nature of terrorist threats, including by ISIL, deny terrorists the access to tools of terrorism and safe havens, to promote the security and resilience of business and communities and advance programs that will strengthen APEC member Economies’ collaboration in countering the financing of terrorism.
Lastly, the proposal is in line with the efforts of APEC´s partners, such as the FATF and the United Nations, and fosters compatibility and sharing of best practices on security standards and programs in accordance with international norms, promoting the collaboration between member economies and other relevant international partners and stakeholders. |
TILF/ASF Justification |
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Beneficiaries and Outputs |
Outputs: The main product of the project is a three-day Workshop on terrorist financing. The Workshop seeks to generate the exchange of knowledge, experience and best practices between international organizations and member economies, and amongst member economies themselves, with the fundamental aim of enhancing the capacity of APEC member economies’ to effectively apply the UN Security Council financial sanctions regime targeting terrorists and their financiers.
The exchange of information and expertise should benefit developing economies with less experience in implementing financial sanctions as well as provide a holistic view of the APEC region’s weaknesses and strengths in its efforts to deter terrorist financing. Furthermore, the participating international organizations may also profit from the feedback received from member economies, which can ultimately serve to strengthen and/or correct certain aspects of the international sanctions regime that member Economies are required to implement.
At the end of the Workshop, the organizers will work with co-sponsors and the APEC Secretariat to draft a summary report of the principal conclusions and recommendations. Moreover, the organizers propose to provide an e-booklet with valuable information, recommendations, and the presentations of the Workshop. The e-booklet, with assistance from the APEC Secretariat, would be disseminated throughout the APEC region as a training tool for all officials and personnel involved in the freezing of terrorism-related assets.
Outcomes: The United Nations Secretary General has acknowledged, in his reports, that there is unevenness among member Economies in the implementation of the international sanctions regime imposed by the UN Security Council. Reasons for this may include lack of resources and political will, legislative constrictions, inadequate technical capacity, poor inter-agency coordination, insufficient inter-State cooperation, among others. As a consequence, the capacity of the international community to deter terrorist financing as a whole is undermined, since cross-border coordination and cooperation, among other aspects, are essential elements to its effectiveness.
This Workshop, therefore, seeks to increase knowledge and awareness of the Security Council financial sanctions regime, as well as its technical, security, and political impact on the fight against terrorism. Furthermore, the sharing of experience and best practices should serve to contribute in identifying gaps and challenges associated to the implementation of sanctions, with the ultimate aim of enhancing member economies’ policy to this end. Additional projects, initiatives or cooperation schemes could arise from this exercise, within the framework of APEC or at the bilateral level, given the proven capacity and expertise of certain member economies in the financial counter-terrorism context and the presence of experts from international organizations.
With respect to the APEC CTWG specifically, the knowledge shared and lessons learned will contribute in the design and implementation of its goals and objectives on the financing of terrorism and the Secure Finance activity area, taking into account the need to renew the Counter Terrorism Working Group’s mandate and design and agree on the priorities of the CTWG Strategic Plan 2018-2022. In this connection, this activity will provide an opportunity to focus and address emerging issues and trends related to terrorism and terrorist financing, in preparation for the priorities and objectives that will be outlined in the Working Group’s four-year plan.
Beneficiaries: The Workshop is intended for government officers and employees of APEC member economies in charge of developing, reviewing, and implementing financial sanctions and asset freezing requests; these could be counter-terrorism or financial experts from economies’ financial intelligence units, police and security agencies, or the different ministries that may be involved in this work, such as finance, foreign affairs, justice, interior, etc. Delegates from member economies to the CTWG could especially benefit from this event, given their background and knowledge, its linkages to past and future workshops on these issues, and eventual outcomes and follow-up in preparation for the CTWG Strategic Plan 2018-2022.
In general terms, the participants should have a background in international affairs and the capacity to disseminate the outputs to colleagues and agencies at home that can also benefit from this knowledge. The presenters will most likely be experts in the field of multilateral financial sanctions, whether they are employed in their economies’ respective financial intelligence units or ministry of foreign affairs. Relevant international organizations such as FATF, UN, INTERPOL, and others, could also benefit from the exchange of information on the application of UN sanctions and asset freezing practices and experiences. The feedback received from member economies could help shape future mandates from their organizations. The e-booklet, which will be issued as a result of the workshop, could contribute to policy-making and enhancement of measures by member economies regarding the implementation of the financial sanctions regime. It can also help to raise awareness of the political and security importance of implementing financial sanctions among colleagues back in capital that were unable to attend the Workshop. In addition, the recommendations and expertise shared in this e-booklet could prove useful for future exchanges and coordination with FATF or the United Nations, in terms of identifying needs for technical cooperation and assistance on implementation. This also applies to cooperation among APEC member economies. |
Dissemination |
The e-booklet that will be produced with presentations and recommendations from the Workshop will be disseminated electronically throughout the APEC region and its member economies, with the assistance of the APEC Secretariat. The results of the Workshop will also be distributed to Chilean embassies and multilateral missions that deal with counter-terrorism and financial sanctions issues, as well as to Chilean government agencies and ministries in Santiago connected to these topics.
A press release from the Chilean Ministry of Foreign Affairs or the Financial Analysis Unit, summarizing the highlights of the Workshop, may be issued at the end of the event. It would appear on the website of the issuing entity.
Furthermore, a summary of the project’s outcomes would be presented by the organizing economy at the succeeding CTWG meeting, most likely in 2018.
The target audience is government officers and employees of APEC member economies in charge of developing, reviewing, and implementing financial sanctions and asset freezing requests. There is no intention to sell the outputs arising from this project. |
Gender |
The organization of the workshop will comply with APEC’s gender balance principles. As the organizing economy, we propose to encourage the equal participation of women and men from the member economies attending the Workshop. This principle will also be communicated to local Chilean agencies that will be invited to attend. We endeavor to engage women, moreover, in the planning and organizational aspects of the Workshop. It is important to note that one of the overseers, is indeed, a woman. The objectives of the Workshop – namely, enhance member economies’ understanding of the nature, scope and components of the targeted financial sanctions regime and increase their capacity to effectively implement these measures – are designed to have a positive influence in member economies’ behavior and policy decision making regarding counter terrorism, which can equally impact the lives of women, as well as men. This in line with the principles of Security Council resolution 1325 (2000) and subsequent resolutions, which promote the active participation of women in the maintenance of international peace and security and decision making in the political arena. |
Work Plan |
The following is the proposed Workplan for the Workshop, as envisioned in the pre-approved Concept Note:
1) June-July 2017: Draft of the Workshop Agenda will be elaborated and circulated to economies
An important aspect of the organizational process, as it engages the membership and provides valuable feedback from economies that will be useful in the subsequent stages of planning. The draft Agenda will identify the number of speakers and participants and will contribute to refining organizational aspects like programming, material, timing, budget, etc. Moreover, observations from economies will help make final decisions on what international organizations to invite, as well as what topics to cover and/or omit.
2) 20-31 July 2017: Incorporate the comments and finalize the agenda to reflect all interests by stakeholders
3) August 2017: Invite and confirm speakers for the workshop from APEC economies and international organizations
Based on original planning decisions and feedback from member economies, presenters and speakers from APEC member economies and international organizations will be formally invited to participate in the Workshop. For the moment, United Nations and FATF experts are being considered, but others may be incorporated. Also, at present time, we envision three experts from member economies, taking into consideration those that have co-sponsored the Concept Note.
In this process, presenters will be explained the primary objectives of their role, approximate time allotted for presenting, and specific topics on which to focus their presentations, among other logistical and organizational information regarding their participation. Regarding experts from member economies, local Embassies will also be asked to assist. During the subsequent weeks and months, the organizing staff will maintain regular contact with the invited international and member economy experts, in order to attend to any questions and concerns that may arise regarding their role and ensure confirmation of their participation.
4) August-September 2017: Promotion, dissemination and invitation to the workshop
With a consolidated Agenda now in hand, the Workshop will be disseminated, with the help of the APEC Secretariat, so that the nomination process for member economy participation can begin. To aide and complement this task, Embassies with representation in Chile will be contacted as well.
Furthermore, the Workshop will be disseminated in Chile among agencies and ministries involved in counter-terrorism and terrorist financing, as well as member economies with representation in Chile. The participation of non-APEC economies with diplomatic representation in Chile will be considered.
Prior to the start of the Workshop, the organizing team will request its promotion on the websites of the Financial Analysis Unit and the Ministry of Foreign Affairs, as well as prepare a press release for dissemination, covering the main objectives and details of the event.
6) September-October 2017 Ground arrangements by the organizing committee (logistic and documentation)
The organizing committee will advance and look to finalize the logistical and organizational aspects of the Workshop, including planning and timing of lunches and coffee breaks, technological aspects of the venue, printed material, transport of participants and experts, hotel accommodations, etc.
7) November 2017: Implementation of the workshop
Though exact dates have not been set, we propose to hold the three-day workshop, entitled Halting Terrorist Financing: APEC Workshop on Targeted Financial Sanctions regime related to terrorism and terrorist financing, during the first half of November.
8) November-December 2017 Drafting of report and creation of e-booklet
Upon conclusion of the Workshop, the project overseers will work with co-sponsors, speakers and other participants to draft a report of the Workshop to present to the CTWG. The report will contain the main conclusions and summarize the presentations and discussions of the Workshop. The overseers will also work on the design and creation of the e-booklet that will be disseminated in the ensuing weeks, containing the primary conclusions and recommendations. The e-booklet is intended to serve as a tool to assist member economies and officials in capital on the implementation of the financial sanctions regime.
9) December 2017: E-booklet finalization and launch in APEC website
With the help of the APEC Secretariat, the e-booklet will be uploaded to the APEC-CTWG website to facilitate access for officials in capital and other interested parties. |
Risks |
The implementation of sanctions and terrorist financing as a whole involve the collaboration of many government agencies, as well as non-governmental entities such as the private and bank sector. Therefore, one concern is the possibility of not reaching this diverse audience, since only two experts per economy would be attending. To maximize the benefits associated to the outputs of the Workshop, the organizers will do their utmost to encourage member economies to carry out a thorough job of disseminating the recommendations and will communicate them to all relevant parties. Certainly the e-booklet will help mitigate this risk. Furthermore, the language contained in the summary and recommendations of the e-booklet must be simplified as much as possible in order for it to be clear and useful to a maximum number of interested stakeholders.
Another risk is not having ample representation from APEC member economies, considering the travel distance to Santiago, specially from Asian member economies. On this issue, we plan to engage with economies with diplomatic representation in Chile and others that may be represented in other South American capitals, as well as our embassies and trade representative abroad. We endeavor to be as efficient as possible in order to grant economies sufficient time to carry out the nomination process.
A vital objective of the Workshop is to positively influence the implementation of financial sanctions within member economies and at the regional level, by sending a clear message of the importance of carrying out these measures to deter terrorist financing. Here, the quality of the presenters and their presentations is key. They must take into account the region’s particularities and specific problems associated to terrorist financing and the sanctions regime. The expertise and work background of participants is also important; they should preferably be associated with financial sanctions/terrorist financing in order to generate useful exchange and discussion with the experts that is advantageous to all those present. |
Monitoring and Evaluation |
The impact of this project is long-term, as it aims to improve the implementation of sanctions and increase its visibility as a policy tool for member economies. In that sense, and as a way to gauge progress, member economies should be consulted in the future regarding measures they have taken to enhance implementation and address institutional, legislative, technical, or other weaknesses. The FATF’s national evaluations could provide further insight on the capacity of member economies to comply with their obligations in this area.
Moreover, we endeavor that the results and recommendations of the Workshop, particularly regarding emerging issues and trends related to terrorist financing, have a direct impact on the design and implementation of the goals and objectives set out in the 2018-2022 CTWG Strategic Plan. This would facilitate the monitoring of the Workshop’s main recommendations and conclusions as set out in the Strategic Plan, which could be measured within a reasonable time frame, for example, at its half-way point (2020).
The project outcomes, in terms of long-term impact, will be mainly reflected through the number of its recommendations that are incorporated into the 2018-2021 CTWG Strategic Plan. Taking into consideration gender and stakeholder feedback, participants from different APEC economies will be tracked through a participant sign-in sheet that notes their organization and economy.
In terms of its mid-term impact, this can be measured by the number of downloads from the APEC web page of the workshops final report that will reflect the discussions undertaken during the workshop. A target of 200 downloads in the first two months after the holding of the Workshop could be established.
Furthermore, information on the following indicators will be collected to measure/assess progress and impact:
The first indicator to be used is to assess whether the Workshop meets its set objectives. This can be assessed comparing what participants gain from the Workshop (using an evaluation form) and whether the Workshop is able to produce practical recommendations to be submitted to relevant APEC committees/WGs/fora.
The second indicator can be the quality of speakers; this can also be assessed by compiling comments of participants in the evaluation forms.
The third indicator relates to the issue of gender: How many female participants can attend and learn from the knowledge/experience shared at the Workshop and how many female speakers can come and share their expertise. It is expected that 30% to 40% of the participants attending the Workshop be women.
The forth is a communications indicator that will tell us how widely the Workshop’s materials will be disseminated to interested groups in APEC: it is planned that presentations and documents of the Workshop be made available via the APEC Meeting Document Database. The Project’s Report will be presented to CTWG for consideration. The PO will check with APEC Secretariat to make sure that the materials of the Workshop will be uploaded to the APEC AIMP; the PO will also be responsible for sending the report to APEC’s relevant working groups. The fifth indicator is how many participants from the developing economies can benefit from this Workshop. |
Linkages |
The United Nations and FATF are indispensable players in this proposal, given their key role as institutions that impose financial sanctions to counter terrorism and monitor their implementation. The participation of other regional or international organizations with expertise in this area will also be considered.
The draft Agenda for the Workshop will take into account the Secure Finance Workshop on Countering the Financing of Terrorism with New Payment Systems, organized by the United States in the context of SOM I 2015 in the Philippines. l. The information shared and discussions held in the current proposal could shed light on progress and challenges regarding the countering of new payment systems, as well as other new and emerging sources of illicit funding.
This project will also build on other past initiatives, in particular Australia’s two Counter Terrorist Financing (CTF) Workshops held in 2007, which focused on the roles and responsibilities of Financial Intelligence Units (FIUs) in safeguarding Charities, Non-Profit Organizations (NPOs) and Alternative Remittance Systems (ARS) against misuse by terrorist groups.
APEC’s comparative advantage lies in the diversity of its membership, its large geographical scope, and the growing terrorist threat in the region. As its economic and financial connectivity increases, so does the possibility of using these links to create new avenues to access international funding to support the planning and commission of terrorist acts. Thus regional collaboration and experience-sharing with international organizations is essential.
This project will have a closely collaborate with members of economies and non-APEC stakeholders from the private sector involved in the sharing of best practices. It seeks to engage experts from international organizations that focus on finance and counter-terrorism. The Finance Ministers Process and the APEC Business Advisory Council will be consulted regarding this project.
Moreover, the project will provide working-level financial crimes policy and operational representatives from APEC economies' legal, regulatory, investigative, enforcement, and prosecution units the opportunity to develop or reinforce capacities in the prevention and suppression of terrorism and terrorist financing, including an update of the knowledge on on-going and planned APEC activities contributing to counter-terrorism, promoting inter-agency coordination to enhance the security while preventing unnecessary additional burden to the trade. |
Sustainability |
The participants and the experts can share experiences and best practices on how to apply the whole government approach as well as private and public partnership to deal with the situation. Sharing experiences and best practices on how to optimize the use of media and social media will also be beneficial to the participants.
After the workshop, this knowledge based on best practices and lessons learned could be used in their respective economies.
The workshop materials will be available for use by participants, economies, stakeholders and beneficiaries long after the project has been completed, through its availability as a printed and online document at no cost on the AIMP. In the short term, future actions on this area may lead to increasing APEC members’ understanding of the targeted financial sanctions regime relating to the prevention and suppression of terrorism and terrorist financing. References, presentations, and recommendations from this workshop may form a good baseline for such understanding. Workshop speakers and participants are also valuable resources to get inputs or experts for future survey, questionnaires, or other activities. The outcomes and recommendations of this workshop may be used as input for future projects/ studies in CTWG.
The organizing economy proposes to share the final recommendations guide with APEC economies for comments and suggestions in order to include all the observations. This will enable to present the recommendations guide for approval of the CTWG and, ultimately, to circulate this guide as an APEC publication.
As mentioned before, there will be follow up activities in the short-term, such as the survey post workshop; in the long term, the number of downloads of the final publication of the project, per year.
Furthermore, depending on the results of this project, specifically on the contents gathered in the final recommendations guide, we are considering organizing a second phase to enhance implementation of its goals through a 2 day-workshop with a final publication that will gather the contents of the entire process. |
Project Overseers |
The project has two overseers, as it is a joint undertaking between Chile’s Financial Analysis Unit and the Ministry of Foreign Affairs.
Carolina Rudnick, International Relations Office, Financial Analysis Unit
Address: Moneda 975, 17th Floor, Santiago, Chile
Tel: +56-2-24393014; e-mail: crudnick@uaf.gov.cl
A Chilean national, Carolina Rudnick was most recently the executive coordinator of the Intergovernmental Committee Against Trafficking in Persons of the Chilean Ministry of the Interior. Under her leadership, Chile designed and implemented the first national plan of action against human trafficking and advanced Chile’s qualification from Tier 2 to Tier 1 in the TIP Report 2014. She holds a B.A. in Law, postgraduate studies in Ethics from the Universidad de Concepción of Chile and an MSc in criminal justice from the London School of Economics. She is a Fulbright fellow and has worked in the World Bank and the Inter-American Bank.
Julio Torres, Counterterrorism Office, Ministry of Foreign Affairs
Address: Teatinos 180 14th Floor, Santiago, Chile
Tel: +56-2-28274648; e-mail: jtorres@minrel.gob.cl
Julio Torres is a Chilean national with a B.A. in Political Science from Montclair State University and M.A. in International Relations from the Seton Hall University School of Diplomacy and International Relations, both in New Jersey, USA. He has worked in the Ministry of Foreign Affairs in Santiago since 2012, including in the UN Security Council Unit and the Division of International and Human Security, overseeing UN sanctions implementation and counterterrorism. Prior to that, from 2005 to 2011, he worked at the Permanent Mission of Chile to the United Nations in New York, covering budgetary/administrative and international security issues, among others. |
Cost Efficiency |
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Drawdown Timetable |
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Direct Labour |
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Waivers |
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Are there any supporting document attached? |
No
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