{"schemaVersion":"case-card-export-v1","frozenRecordSchemaVersion":"frozen-decision-record-v1","product":"Trace-li","slug":"irc-syria-procurement-settlement","title":"International Rescue Committee: were the bids independent?","lede":"In March 2021, the International Rescue Committee agreed to pay US$6,934,500 to settle False Claims Act allegations concerning USAID-funded Syria procurement. This is a civil settlement, not a criminal verdict. The card is a research fixture, not a frozen desk record.","caseId":"case:irc-syria-procurement-settlement","recordKind":"fixture","publicationState":"awaiting_founder_freeze","statusLabel":"Fixture · awaiting founder freeze","packScope":"finding-slice","packsStamped":false,"packsInForce":[{"packId":"irc-public-source-review","version":"research-2026-10-08","name":"Trace-li IRC case review questions (proposed)"}],"readiness":null,"readinessNote":"Not issued. This fixture has not been through a desk freeze, so readiness is left blank rather than shown as unknown, red, amber, or green.","dispositionSummary":"No disposition. A founder-confirmed desk freeze has not been recorded.","frozenRecordId":null,"snapshotHash":null,"packsHash":null,"hashMethod":null,"hashNote":"Snapshot and packs hashes are omitted. They are produced only by freezeAtJudgment (sha256:sorted-json-v1). The sha256 on the primary source file identifies the retained public source file, not a freeze hash.","fixtureSnapshot":{"schemaVersion":"award-registry-snapshot-v1","registryVersion":1,"classification":"public-source","organizationId":"org:public-case-cards","projectId":"project:irc-syria-procurement-settlement","awardId":"research:irc-syria-procurement-settlement","procurementReference":"irc-syria-procurement-settlement","donor":{"donorId":"donor:usaid","name":"USAID"},"framework":{"frameworkId":"irc-public-source-review","name":"Trace-li IRC case review questions (proposed)","version":"research-2026-10-08"},"fields":[{"fieldId":"field:irc-syria-procurement-settlement:research.source_status","entityKind":"evidence","entityId":"evidence:irc-syria-procurement-settlement:research.source_status","key":"research.source_status","value":{"state":"present","value":"Civil settlement of False Claims Act allegations, described by the Justice Department on 19 March 2021."},"provenance":{"sourceFileHash":"af3dd802c764c18d6094e0c1ddf91a2ee45ca35e6bdb820a25a70cc3d415c1fa","sourceRef":{"kind":"page","id":"source:irc-syria-procurement-settlement:research.source_status","label":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"},"extractedAt":"2026-10-08T12:31:34.953Z","confidence":1,"verificationMethod":"unverified"}},{"fieldId":"field:irc-syria-procurement-settlement:research.settlement_amount","entityKind":"evidence","entityId":"evidence:irc-syria-procurement-settlement:research.settlement_amount","key":"research.settlement_amount","value":{"state":"present","value":"US$6,934,500 agreed settlement; not a measure of total aid lost or a criminal fine."},"provenance":{"sourceFileHash":"af3dd802c764c18d6094e0c1ddf91a2ee45ca35e6bdb820a25a70cc3d415c1fa","sourceRef":{"kind":"page","id":"source:irc-syria-procurement-settlement:research.settlement_amount","label":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"},"extractedAt":"2026-10-08T12:31:34.953Z","confidence":1,"verificationMethod":"unverified"}},{"fieldId":"field:irc-syria-procurement-settlement:integrity.bid_independence_review","entityKind":"evidence","entityId":"evidence:irc-syria-procurement-settlement:integrity.bid_independence_review","key":"integrity.bid_independence_review","value":{"state":"missing","reason":"The notice describes procurement allegations but does not publish transaction-level bid-independence checks or declarations. Those records are not reconstructed here."},"provenance":{"sourceFileHash":"af3dd802c764c18d6094e0c1ddf91a2ee45ca35e6bdb820a25a70cc3d415c1fa","sourceRef":{"kind":"page","id":"source:irc-syria-procurement-settlement:integrity.bid_independence_review","label":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"},"extractedAt":"2026-10-08T12:31:34.953Z","confidence":1,"verificationMethod":"unverified"}},{"fieldId":"field:irc-syria-procurement-settlement:procurement.independent_price_basis","entityKind":"evidence","entityId":"evidence:irc-syria-procurement-settlement:procurement.independent_price_basis","key":"procurement.independent_price_basis","value":{"state":"missing","reason":"The notice does not supply the price comparisons and authorizations needed to judge a particular purchase. Missing from the public packet is not proof that no original document existed."},"provenance":{"sourceFileHash":"af3dd802c764c18d6094e0c1ddf91a2ee45ca35e6bdb820a25a70cc3d415c1fa","sourceRef":{"kind":"page","id":"source:irc-syria-procurement-settlement:procurement.independent_price_basis","label":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"},"extractedAt":"2026-10-08T12:31:34.953Z","confidence":1,"verificationMethod":"unverified"}}],"asOf":"2026-10-08T12:31:34.953Z"},"frozenRecord":null,"findings":[{"findingId":"finding:irc-syria-procurement-settlement:1","title":"Competition and relationships under examination","summary":"DOJ described investigations into alleged collusion, kickbacks, bid steering, and staff–vendor conflicts in Turkey-based cross-border procurement. It reported inflated prices invoiced to USAID between October 2012 and December 2015. This card preserves the civil-settlement status.","sourceLabel":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"}],"narrative":{"officialRecord":"IRC was buying goods and services for people displaced inside Syria when the procurement relationships behind those purchases later became the subject of a civil investigation. The settlement notice supplies the institutional account; it does not supply a complete tender file.","whatWasMissing":"The Justice Department described alleged interference with competition and staff–vendor conflicts, making the independence of the procurement a material review question. This card does not invent a missing declaration or claim that a completed form would have exposed the scheme.","whatFollowed":"IRC agreed to the civil settlement. Separately, USAID OIG report 8-000-21-001-P called for assessment of IRC’s pledged corrective actions; its public tracker records that recommendation closed on 10 June 2021. All four audit recommendations show closure dates, the last on 5 December 2024. Closure alone does not establish the amount recovered or prove that every control remained effective.","assuranceQuestion":"Before signing, what evidence supports the independence of the bids, the handling of staff–vendor relationships, and the reasonableness of the price?","whereTraceLiFits":"This fixture asks a reviewer to connect those checks to their supporting evidence and a named decision. It is a proposed Trace-li review structure, not an IRC or USAID policy pack. Substantive verification and monitoring remain necessary; a well-organized file cannot guarantee detection of collusion."},"patternTicketIds":["pt:irc-syria-procurement-settlement:bid-independence","pt:irc-syria-procurement-settlement:price-basis"],"patternTickets":[{"schemaVersion":"pattern-ticket-v1","ticketId":"pt:irc-syria-procurement-settlement:bid-independence","title":"Bid independence and staff–vendor conflicts review","statement":"Proposed review question: what independent checks support the competing bids and staff–vendor relationships? A declaration alone cannot establish the absence of collusion.","status":"stub","packId":"irc-public-source-review","ruleId":null,"fieldKey":"integrity.bid_independence_review","sourceCaseSlugs":["irc-syria-procurement-settlement"]},{"schemaVersion":"pattern-ticket-v1","ticketId":"pt:irc-syria-procurement-settlement:price-basis","title":"Independent price comparison and approval","statement":"Proposed review question: can the reviewer inspect the independent price basis, the exceptions, and the decision authorizing the purchase? Documentary checks alone cannot guarantee prevention of bid rigging.","status":"stub","packId":"irc-public-source-review","ruleId":null,"fieldKey":"procurement.independent_price_basis","sourceCaseSlugs":["irc-syria-procurement-settlement"]}],"primarySources":[{"sourceId":"src:irc-syria-procurement-settlement:1","title":"IRC agrees to settle allegations concerning USAID-funded procurement","publisher":"US Department of Justice; retained by USAID Office of Inspector General","url":"https://oig.usaid.gov/sites/default/files/2022-02/Department-of-Justice-PressRelease-031921.pdf","publishedOn":"2021-03-19","locator":"PDF p. 1, paragraphs 1–4; DOJ press release 21-040"},{"sourceId":"src:irc-syria-procurement-settlement:2","title":"Weaknesses in Oversight of USAID’s Syria Response, 8-000-21-001-P","publisher":"USAID Office of Inspector General","url":"https://oig.usaid.gov/node/4625","publishedOn":"2021-03-04","locator":"Recommendation 2 and closure dates for recommendations 1–4; checked 8 October 2026"}],"primarySourceFile":{"url":"https://oig.usaid.gov/sites/default/files/2022-02/Department-of-Justice-PressRelease-031921.pdf","sha256":"af3dd802c764c18d6094e0c1ddf91a2ee45ca35e6bdb820a25a70cc3d415c1fa","retrievedOn":"2026-10-08","label":"SHA-256 of the retained PDF, retrieved 8 October 2026. Source-file hash only; not a desk freeze."},"redaction":{"policyId":"case-card-redaction-v1","public":["Historical institutional source, its scope and procedural status, and proposed review questions"],"withheld":["Personal and supplier identities","Underlying transaction records, customer data, and any invented award chronology","Freeze hashes and readiness: no founder-confirmed freeze exists"]},"claimBoundary":"The settlement resolves civil allegations; it is not a criminal verdict or a quantified total loss. Audit recommendation closure is distinct from recovery and from the settlement. IRC and USAID are not presented as Trace-li customers or endorsers. This card does not say Trace-li prevents fraud. Evidence absent from this public packet is not automatically absent from the original file."}