PEPFAR Botswana CLM KP-specific NOFO - June 2022.pdf

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PEPFAR Botswana Community Led-Monitoring (CLM) Program
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PEPFAR-GABORONE-AF-CLM-GR-22-23
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NOFO - PEPFAR Botswana CLM NOFO 2022

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The CLM Grant Application is FREE of charge and the Embassy DOES NOT request any payment to receive and evaluate a project.

U.S. DEPARTMENT OF STATE

U.S. EMBASSY GABORONE

PEPFAR BOTSWANA COORDINATION OFFICE (PCO)

NOTICE OF FUNDING OPPORTUNITY (NOFO)

▪ Funding Opportunity Title: PEPFAR Botswana - Community-Led Monitoring

(CLM) Program

▪ Funding Opportunity Number: PEPFAR-GABORONE-AF-CLM-GR-22-23

▪ Deadline for Applications: July 8, 2022

▪ Total Amount Available: $ 180,000

▪ Period of Performance: 1 August 2022- 31 August 2023

▪ Maximum Expected Number of Awards: 2

A. PROGRAM DESCRIPTION AND OBJECTIVES

Program Description

U.S. Embassy Gaborone through the PEPFAR Botswana Coordination Office

(PEPFAR/PCO) is pleased to announce an open competition for local key population

(KP)-led civil society organizations (CSOs) and KP-led non-governmental organizations

(NGOs) to submit applications to carry out a Community-Led Monitoring (CLM) program. The CLM program is funded through the U.S. President’s Emergency Plan for

AIDS Relief in Botswana (PEPFAR/Botswana) in support of the Government of

Botswana’s (GoB) effort to achieve HIV epidemic control through the implementation of evidence-based and client-centered interventions to accelerate progress in HIV prevention, care and treatment and ultimately, save lives. This NOFO is specific to

PEPFAR monitoring health services for HIV key populations (KP), which in the

Botswana context include gay and other men who have sex with men (MSM), people who inject drugs (PWID), sex workers and both male and female-identifying transgender persons.

PEPFAR recognizes the importance of engaging with communities in the development and implementation of effective health services. HIV services for KPs in Botswana continue to face the challenge of finding those KPs living with HIV and linking and retaining patients on life-long ART. Collaboration with communities and clients is critical to ensure that health services in the facilities and communities are accessible and of high quality.

The overall goal of the CLM program is to ensure the availability, access to, and delivery of quality health and HIV services. The CLM program’s main objective is to provide a direct feedback mechanism to clients and beneficiaries of these services throughout the health service delivery experience to diagnose persistent issues and barriers to service uptake. The expectation is that this feedback loop will help identify gaps and workable solutions that are driven by the community to overcome them.

Program Background and Objectives

Currently, the PEPFAR CLM program provides grants to three local CSOs who have established, trained, and supported networks of clients and beneficiary groups to monitor and address persistent problems and barriers to effective, client-centered HIV and health services. All three partners have recruited representative beneficiaries from groups including people living with HIV, people living with disabilities, youth groups that include adolescent girls and young women, key populations, DREAMS ambassadors, PrEP ambassadors, and ART champions. Grantees have set up monitoring groups that are diverse, inclusive and gender-and-age balanced.

With the support of the grant recipients, the monitoring groups collect quantitative and qualitative data and observations using standardized tools, developed with the assistance from the International Treatment Preparedness Coalition (ITPC) Global. The data is be synthesized using a variety of methods to provide insights on barriers to service uptake and workable solutions to address them at the appropriate service delivery levels – local (community and facility), district, and national. The CLM program findings are analyzed and discussed collaboratively between community representatives, service providers and facility managers to ensure dialogue and help all participating sides identify, implement and monitor follow up actions. By capturing clients’ and beneficiaries’ perspectives on these barriers and enablers and engaging them in identifying and adopting corrective actions, the CLM program seeks to improve service quality, continuity of care, and retention for all clients and beneficiaries. This includes expanded treatment literacy, improved access to services, and increased service uptake.

The current CLM program covers specific facilities in 10 of the country’s 27 districts, including Francistown, Greater Gaborone, Kgatleng, Kweneng East, Lobatse, Moshupa, Palapye, Selibe Phikwe, and Serowe. The scope and scale of monitoring is determined by the participating client and beneficiary groups, in consultation with the grantees and

PEPFAR/PCO. For example, monitoring activities are somewhat limited to facilities and community sites supported by PEPFAR or expanded to cover all health facilities and sites in a district. However, there is need to expand the geographies covered by CLM in

Botswana, recognizing there are additional districts that are priority for KPs. In addition to the above mentioned districts, applicants may consider assessing services in these additional districts which have more formalized KP programs: Boteti, Kasane, Mahalapye, and Ngamiland, The CLM grant deliverables are:

1. Formation and training of monitoring groups for selected districts; groups must be diverse and inclusive of all constituencies that access health and HIV services.

2. Data collection, consolidation, and analyses.

3. Formulation, implementation, and monitoring of follow up actions to improve service uptake at the local and district levels.

4. Quarterly financial and activity reports.

5. Participation in quarterly meetings with the PEPFAR CLM Community

Consultation Group (CCG), comprised of PEPFAR, government, PLWHA CSO representatives and other stakeholders, to provide in-depth discussion of work and results at the local, district and national levels.

6. Participation in national level advocacy activities when/where relevant.

Currently, CLM partners are assessing HIV services provided at Government of

Botswana facilities. However, there is a need to also assess the role of PEPFAR-supported CSO/NGO and private sector implemented activities that are specifically focused on KPs. These services include the full HIV cascade: prevention (including

PrEP); testing; linkage to ARVs and viral suppression strategies, both those offered in community settings/facilities and virtually.

B. AWARD INFORMATION AND ELIGIBILITY

Award Information

Length of Performance Period: 1August 2022- 31 August 2023 (13 months)

Number of Awards Anticipated: 1 to 2 awards

Award Amounts: Awards may range from $80,000 up to the maximum of $180,000

Total Available Funding: Up to $180,000 for all awards

Type of Funding: FY2022/COP21 and FY2023/COP22 Allocated Funds

Anticipated Program Start Date: 1 August 2022

Funding Instrument Type: Grant

Program Performance Period: Proposed activities should be completed no later than 31 August 2023. The Department of State will entertain applications for continuation grants funded under these awards beyond the initial budget period on a non-competitive basis subject to availability of funds, satisfactory progress of the program, and a determination that continued funding would be in the best interest of the

U.S. Department of State.

Eligibility Information

Not-for-profit organizations led by KP community members themselves or organizations who are KP-competent, including think tanks, civil society or non-governmental organizations, and community-based organizations, that are currently not receiving

PEPFAR funding to deliver health services are eligible to apply. Organizations currently funded by PEPFAR to deliver health services either in the community or at the health facility are excluded from this funding opportunity.

Eligible organizations should also meet the following criteria:

1. Be registered as a not-for-profit organization with the Government of Botswana

(proof is required).

2. Must have experience of successfully implementing programs with funding of a minimum of $40,000.

3. Must apply for only one CLM award, which can cover multiple districts; only one proposal per organization is allowed.

4. Must either have:

a. a majority of board/senior staff who are representatives from KP communities (KP-led)

b. articulated how the organization meets the standards set by PEPFAR to

KP-competent*

In the COP22 Guidance, PEPFAR has defined KP-competence as the following:

1. Organizational Composition

1.1. Affirms human rights of KP through their stated organizational mission/vision

1.2. Demonstrates substantial and increasing leadership involved in policy setting, governance and programmatic decision-making are members, or former members, of the KP community served by the organization. The organization includes and respects the input of KP leaders in organizational and program management.

2. Prioritization of Privacy and Security

2.1. The organization has documented policies that set standards for and emphasize the importance of maintaining confidentiality and privacy of clients

2.2. All staff, including peers, are trained, and required to maintain client confidentiality, safety, and security, as well as risk mitigation*

3. Commitment to Affirming and Promoting the Dignity and Human Rights of KP

3.1. All staff receive relevant KP sensitization training, based on all the key population(s) they serve*

3.2. The organization provides non-judgmental and non-stigmatizing services to all clients, including key population members, and assist clients in knowing their rights

3.3. The organization commits to delivery of services based on harm reduction principles without judgement, coercion, discrimination, or requiring that clients stop related behavior.

3.4. The organization has formal systems to respond and react to stigma, discrimination and violence that may occur in health and other social service settings – both meeting client’s needs and addressing structural barriers

4. Capacity to Meet the Health Needs of KP

4.1. The organization provides a minimum package of evidence-based services that meet the needs of KP.

4.2. The organization ensures cultural, geographic, linguistic, financial, and procedural accessibility to KP services – as determined in consultation with local KP communities.

4.3. The organization has recognized legitimacy as an advocate for key populations and ability to mobilize KP in collaboration with KP CSOs

4.4. The organization has strong financial management procedures and policies that establish the ability to manage grants

4.5. The organization’s KP peer ratio to KP reached is sufficient and in line with global/national recommendations, peer workers receive fair remuneration, there is an explicit plan for peer progression and professional development, peers influence the implementation of interventions *Trainings must be recognized/approved by PEPFAR

Other Eligibility Requirements

Applicants must register with Grants.gov prior to submitting an application. Registering with Grants.gov is a one-time process; however, it may take weeks to have the registration validated and confirmed. Please begin the registration process immediately to ensure that the process is completed well in advance of the deadline for applications.

Until that process is complete, you will not be issued a user password for Grants.gov, which is required for application submission. There are four steps that you must complete before you are able to register: (1) obtain a Data Universal Numbering System

(DUNS) number from Dun & Bradstreet (if your organization does not have one already) by visiting http://fedgov.dnb.com/webform; (2) register with System for Award

Management (SAM) www.SAM.gov; (3) register yourself as an Authorized Organization

Representative (AOR); and (4) be authorized as an AOR by your organization. For more information, go to www.grants.gov. Please note that your SAM registration must be annually renewed. Failure to renew your SAM registration may prohibit submission of a grant application through Grants.gov.

http://fedgov.dnb.com/webform http://www.sam.gov/ http://www.grants.gov/

The U.S. Department of State will not make an award to an applicant until the applicant has complied with all applicable DUNS and SAM requirements by the time the

Department is ready to make an award.

C. APPLICATION AND SUBMISSION INFORMATION

Instructions

Please follow all application instructions carefully. Proposals that do not meet the requirements of this NOFO or fail to comply with the stated requirements will be ineligible. Applicants must ensure:

1. The proposal should clearly address the goals and objectives of this funding opportunity and be aligned with the requirements of the CLM program.

2. All documents must be in English.

3. All budgets must be in U.S. dollars and calculated at USD 1= BWP 11.95 (as of

June 2022).

4. All pages must be numbered, including budgets and attachments.

5. All documents must be formatted to 8 ½ x 11 paper.

6. All Microsoft Word documents must be 1.15 spacing, 12-point Times New

Roman font, with a minimum of 1-inch margins.

7. All materials must be submitted in pdf format.

8. All proposals should be no more 15-page long and all budget narratives should be no more than 3-page long.

The follow documents are required:

1. Mandatory Applications forms

a. SF-424 (Application for Federal Assistance)

b. SF-424A (Budget Information for Non-Construction Programs)

c. SF-424B (Assurance for Non-Construction Programs)

These forms can be found at https://www.grants.gov/forms/sf-424-family.html.

2. Summary Page: Cover sheet stating the organization’s name, districts to be covered, and brief overview of the organization’s implementation strategy for the

CLM program.

3. Proposal: The proposal should contain sufficient information that anyone not familiar with community-led monitoring would understand exactly what the applicant wants to do. Applicant may use their own proposal format, but it must include all the items below:

a. Proposal Summary: Short narrative that outlines your organization’s proposed community-led program, including the program objectives, districts and public facility/NGO service points to be covered, and anticipated results and outcomes.

https://www.grants.gov/forms/sf-424-family.html

b. Introduction to the Applying Organization: A description of past and present operations, documenting status as a KP-led and/or KP-competent organization, efforts working with KP community communities and abilities to carry out the CLM program, including the descriptions of funding programs of more than $40,000, and all previous grants from U.S. government agencies.

c. Program Goals and Objectives: The goals should describe what the organization’s CLM program intends to achieve, with which KP populations, and in which districts. The objectives refer to the intermediate accomplishments on the way to the goals. Both should be measurable and achievable during the grant period. Applications may consider assessing

PEPFAR-supported services for KPs in either public facilities or NGO community partners, however, applications assessing both will be prioritized.

Applications may also choose to assess HIV services for specific KP communities; however, applications that assess services for all KP communities served in Botswana will be prioritized.

d. Program Strategic Approach and Tools: A description of how the organization’s CLM program is expected to achieve the goals, including how monitoring groups will be formed; which monitoring tools will be used; which health services will likely be prioritized; how data will be collected, reported, consolidated and analyzed; how follow up actions will be identified, implemented, monitored and reported; etc.

e. Program Activities: A description of the CLM activities, their expected output and outcomes and how they will help achieve the objectives.

f. Proposed Program Schedule and Timeline: The proposed timeline for the

CLM activities. It should include dates, times, and locations of planned activities and events.

g. Key Personnel: Names, titles, roles, membership in KP communities, and experience/qualifications of key personnel involved in the CLM program. Key personnel include the head of the organization, the program manager, and the finance officer in charge of the CLM program. What proportion of their time will be used in support of the CLM program?

h. Program Partners: List the names of key partner organizations and sub-awardees and describe their specific roles and responsibilities in the implementation of grant activities. If appropriate, partnerships between KP-led organizations serving other KP communities are encouraged.

i. Program Monitoring and Evaluation Plan: The M&E plan should cover the life of the grant; and describe how activities will be monitored to ensure they are happening in a timely manner and how and when the CLM program will be evaluated to make sure it is meeting the goals of the grant.

4. Budget Justification Narrative: After filling out the SF-424A Budget form, use a separate document to describe each of the budget expenses in detail.

5. Attachments:

a. Proof of registration with the government of Botswana.

b. CV or resume of key personnel who are proposed for the program.

c. Letters of support from program partners describing the roles and responsibilities of each partner (if applicable).

d. Three (3) Reference letters; one (1) letter must be from a donor organization of $40,000 or more.

Questions

Please submit your questions on this solicitation to PEPFAR Botswana/PCO at:

PEPFARBotswana@state.gov.

Questions will be received until June 27, 2022 and the answers to all questions received will be provided by July 1, 2022 via the PEPFAR Botswana website at https://bw.usembassy.gov/our-relationship/pepfar/ or during a virtual Bidding

Conference to be organized by that date.

For questions relating to www.grants.gov, please contact them at +1-800-518-4726 or support@grants.gov.

Submission

All application materials must be submitted electronically through www.Grants.gov. If you are unable to submit your proposal on www.grants.gov, you may submit via email at PEPFARBotswana@state.gov before the deadline. The subject line should be as follows: Applicant Organization name: Community Led

Monitoring Grants Program.

All applications must be submitted digitally; paper applications will NOT be accepted.

Application Deadline: July 8, 2022

D. APPLICATION REVIEW AND SELECTION PROCESS

Selection Process

1. Criteria: Each application submitted under this NOFO will be evaluated and rated based on the criteria enumerated in the evaluation section. The criteria are designed to assess the quality of the proposed project, and to determine the likelihood of its success.

2. Acknowledgement of receipt: Applicants will receive acknowledgment of receipt of their proposal.

3. Review: A technical review panel will review the proposal based upon the criteria noted in evaluation section. A determination will be made regarding the CLM proposals and activities, and those applications that are the best fit will be recommended to the U.S. Embassy Grant Officer for consideration for an award.

mailto:PEPFARBotswana@state.gov https://bw.usembassy.gov/our-relationship/pepfar/ http://www.grants.gov/ http://www.grants.gov/ http://www.grants.gov/ mailto:PEPFARBotswana@state.gov

4. Follow up notification: Applicants will be notified within 30 days after the NOFO deadline regarding the results of the review panel.

Criteria

Each application will be evaluated and rated based on the following evaluation criteria.

1. Quality and Feasibility of the CLM Implementation Idea (20 points)

Proposals should address questions such as: a) does the proposal clearly articulate the organization’s understanding of what CLM is and the role of CLM in improving health outcomes for clients and beneficiaries; b) is the organization’s CLM program idea well developed with specific implementation details on how, when

(implementation timeline) and in which districts, facilities and KP communities the organization plans to implement CLM activities; and c) is the organization’s CLM plan inclusive of all constituencies?

2. Program Planning and Ability to Achieve Objectives (15 points)

Applicants should clearly state the goals and objectives of the CLM program and demonstrate that proposed activities are in line with and clearly support these goals and objectives. Applicants should also provide details about their collaboration (if any) with community-based organizations or community groups and the expected impact of that collaboration on the proposed activities and expected results.

3. Monitoring and Evaluation Plan (15 points)

Proposals should demonstrate the organization’s ability to measure implementation success against key indicators and provide milestones to indicate progress toward set goals. Applicants’ monitoring and evaluation plans should identify realistic output and outcome indicators and specify how and when these indicators will be measured. Details should be provided about how applicants plan to collect, consolidate, and analyze qualitative and quantitative data and observations from monitoring clients and beneficiaries and develop periodic reports. Applicants’ M&E plan should also cover activities implemented in collaboration (if any) with community-based organizations or other community groups.

4. Organizational Capacity and Experience (25 points)

Applicants should demonstrate that their key staff have the right expertise for the

KP-specific CLM activities proposed and the organization has a proven track record of implementing CLM-like projects within KP communities, in all their diversity.

Proposals from organizations led by one KP group are encouraged to partner with other KP-led organizations for a more comprehensive approach. Further consideration will be given to the applicant’s experience implementing international funding projects successfully.

5. Budget and Financial Management Capacity (15 points)

Applicants should demonstrate their ability to manage the CLM funds by providing details about their financial management system, particularly the existence or not of necessary internal controls to manage grant funds. Applicants’ budgets should be realistic, accounting for all necessary expenses to achieve proposed activities; costs should be reasonable in relation to proposed activities and anticipated results; and the budget justification should be detailed. Further consideration will be given to applicants with realistic budget proposals and clear plans to effectively manage the resources of the program and audit expenditures.

6. Collaboration and Sustainability of Planned Activities (10 points)

The proposal should detail: a) the organization’s experience working successfully with key stakeholders in the health sector in Botswana such as district and national level government agencies, PEPFAR KP and other implementing partners, and local communities and community-level structures such as the village health committee;

and b) how the program activities will build on already established community health mechanisms at the neighborhood, district, and national levels?

E. AWARD ADMINISTRATION INFORMATION

Award Notices

The grant award will be written, signed, awarded, and administered by the U.S.

Embassy Grants Officer. The assistance award agreement is the authorizing document that will be provided to the grant recipient for review and signature. The recipient may only start incurring program expenses beginning on the start date shown on the grant award document signed by the Grants Officer. The awardee will interact with a designated Grant Officer Representative (GOR).

If a proposal is selected for funding, the Department of State has no obligation to provide any additional future funding. Renewal of an award to increase funding or extend the period of performance is at the discretion of the Department of State.

Issuance of this NOFO does not constitute an award commitment on the part of the U.S.

government, nor does it commit the U.S. government to pay for costs incurred in the preparation and submission of proposals. Further, the U.S. government reserves the right to reject any or all proposals received.

Reporting Requirements

All awards issued under this NOFO require both program and financial reports on a quarterly. The disbursement of funds will be tied to the timely submission of these reports. All details related to award administration will be specified in the award agreement. The point of contact for questions or issues related to the administration of the grant/cooperative agreement will be specified in the award agreement.

Administrative and National Policy Requirements

Terms and Conditions: Before submitting an application, applicants should review all the terms and conditions and required certifications that will apply to this award, to ensure that they will be able to comply. These include:

2 CFR 200, 2 CFR 600, and the Department of State Standard Terms and Conditions that are available at: https://www.state.gov/about-us-office-of-the-procurement-executive/. Note the U.S. Flag branding and marking requirements in the Standard

Terms and Conditions.

F. FEDERAL AWARDING AGENCY CONTACT

If you have any questions about the grant application process, please contact PEPFAR

Botswana/PCO via email at PEPFARBotswana@state.gov.

Agency Contact:

U.S. Embassy Gaborone, P.O. Box 90, Gaborone, Botswana

Attention: PEPFAR Botswana Coordination Office

TEL: +267 367-2400

E-mail: PEPFARBotswana@state.gov

Website: https://bw.usembassy.gov/our-relationship/pepfar/

G. OTHER INFORMATION

Guidelines for Budget Justification

Personnel and Fringe Benefits: Describe the wages, salaries, and benefits of temporary or permanent staff who will be working directly for the applicant on the program, and the percentage of their time that will be spent on the program.

Travel: Estimate the costs of travel and per diem for this program, for program staff, consultants or speakers, and participants/beneficiaries. If the program involves international travel, include a brief statement of justification for that travel.

Equipment: Describe any machinery, furniture, or other personal property that is required for the program, which has a useful life of more than one year (or a life longer than the duration of the program), and costs at least $5,000 per unit.

Supplies: List and describe all the items and materials, including any computer devices, that are needed for the program. If an item costs more than $5,000 per unit, then put it in the budget under Equipment.

Contractual: Describe goods and services that the applicant plans to acquire through a contract with a vendor. Also describe any sub-awards to non-profit partners that will help carry out the program activities.

https://www.state.gov/about-us-office-of-the-procurement-executive/ https://www.state.gov/about-us-office-of-the-procurement-executive/ mailto:PEPFARBotswana@state.gov mailto:PEPFARBotswana@state.gov https://bw.usembassy.gov/our-relationship/pepfar/

Other Direct Costs: Describe other costs directly associated with the program, which do not fit in the other categories. For example, shipping costs for materials and equipment or applicable taxes. All “Other” or “Miscellaneous” expenses must be itemized and explained.

Indirect Costs: These are costs that cannot be linked directly to the program activities, such as overhead costs needed to help keep the organization operating. If your organization has a Negotiated Indirect Cost Rate (NICRA) and includes NICRA charges in the budget, attach a copy of your latest NICRA. Organizations that have never had a

NICRA may request indirect costs of 10% of the modified total direct costs as defined in

2 CFR 200.68.

Alcoholic Beverages: Award funds cannot be used for alcoholic beverages.

Prohibition on Certain Telecommunications and Video Surveillance Services or Equipment

Non-Federal entities are prohibited from obligating or expending grant funds for covered telecommunications equipment or services to:

1) procure or obtain, extend or renew a contract to procure or obtain;

2) enter into a contract (or extend or renew a contract) to procure; or

3) obtain the equipment, services, or systems.

Covered telecommunications equipment and services mean any of the following:

i. Telecommunications equipment produced by Huawei Technologies Company or

ZTE Corporation (or any subsidiary or affiliate of such entities).

ii. For the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).

iii. Telecommunications or video surveillance services provided by such entities or using such equipment.

Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the

National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country.

The Following Is NOT Eligible for Funding

▪ Projects relating to partisan political activity.

▪ Purchase and set up of surveillance equipment.

▪ Duplication of other U.S. Government programs.

▪ Activities that would benefit, either personally or politically, any employee (e.g.

direct hire, contractor, part-time) of the U.S. Government, or the spouse or family member of a U.S. Government employee.

▪ Activities contributing to the violation of internationally recognized rights of workers.

▪ Charitable or donation related activities.

▪ Activities that support specific religious or military activities, as well as those relating to police, prisons, or other law enforcement.

▪ Fund-raising campaigns.

▪ Lobbying for specific legislation or projects.

▪ Scientific research.

▪ Activities intended primarily for the growth or institutional development of the organization.

▪ Activities that duplicate existing efforts.

▪ Purchase of alcohol, medicine, school uniforms, school fees, bursaries, or personal expenses.

▪ Support for educational or other facilities used to a significant degree by U.S.

employees or their dependents.

▪ Support for abortion-related facilities and services.

▪ Purchase of used equipment – to avoid recurring maintenance and support costs. There is a general policy for financing only new equipment unless it is simple in design and spare parts are available locally, thus providing operational and maintenance advantages in less developed countries.

▪ Creating, continuing, or supplement technical assistance programs.

▪ Purchase of luxury goods and gambling equipment.

▪ Assisting any individual or entity involved in illegal drug trafficking as noted in

Section 487 of the Foreign Assistance Act.

▪ Support, benefit, or other services associated with those persons or entities listed under Executive Order 13224 or determined to be subject to this order or other subsequent laws or orders, who commit, threaten to commit, or support terrorism.

▪ Support for any activity barred under the Foreign Assistance Act and legislation appropriating funds for foreign assistance.

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