Legislative Discussion Draft · LD-2026-01

Taliban Financial Accountability and Aid Integrity Act

Discussion Draft with Drafter’s Note

Published
Status Discussion draft
Supersedes 16 September 2026 draft
Version 2
Author Collin B. George, CISSP
License CC BY-NC-ND 4.0
Unclassified // Open Source
Paper record
Type
Legislative discussion draft with drafter’s note, a one-page summary, the bill text, a crosswalk, and annexes listing every citation with its source (Annex A) and the changes from the prior draft (Annex B). Not official U.S. government analysis and not the product of the Office of the Legislative Counsel.
The problem
SIGAR documented at least $10.9 million in taxes and fees paid by U.S.-funded partners to Taliban-controlled entities and called it a fraction of the total. The payments are legal under OFAC General License 20. The United Nations shipped at least $3.8 billion in U.S. currency into Afghanistan through January 2024, and the Taliban-run central bank buys those dollars. H.R. 260 asks for reports; it does not reach the UN, the development banks, or the license that makes the payments lawful.
The limit
The Taliban budget is financed entirely from domestic revenue — about $4.0 billion in the fiscal year that ended in March 2026. Foreign aid is off-budget, and no U.S. statute reaches that money. The draft does four things a statute can do, and claims no more.
The ask
H.R. 260 is on the Senate calendar (No. 330) with a committee substitute. Offer this text as a substitute amendment when the bill is taken up, or introduce it as a standalone bill and refer it to Foreign Relations. The Afghan-ally relocation language (section 505) is severable.
Cost
CBO scored the House-passed H.R. 260 at less than $500,000 over 2025–2030. This draft adds a bracketed authorization for the State OIG and a rescission expected to exceed it once OMB certifies the balances: net deficit reduction, amount to be fixed with CBO.
Revision history
Revision of 2 October 2026; supersedes the 16 September 2026 draft. Every citation checked against the source listed in Annex A.
What the bill does

Title I. No U.S. assistance for Afghanistan, directly or through any international organization, unless the Secretary of State certifies six safeguards, including reporting of every payment to the Taliban at every award tier and currency conversion that keeps dollars away from the central bank.

Title II. Treasury must amend General License 20 within 90 days: report payments over $10,000; no payment of levies aimed at aid groups; humanitarian activity still authorized. Mandatory blocking and visa sanctions on officials who divert aid or detain aid workers.

Title III. The U.S. trustee of the Afghan Fund may not consent to any transfer to the central bank, and the $3.5 billion blocked at the Federal Reserve Bank of New York stays blocked, until Treasury certifies the bank is independent of the Taliban. Pending litigation is unaffected.

Titles IV and V. Suspension of assistance to governments and NGOs that knowingly fund the Taliban, with a standard, a waiver, and notice to Congress. The State Department Inspector General becomes the auditor SIGAR’s closure left missing. OMB certifies unobligated Afghanistan balances by account before a rescission amount is fixed.

How this differs from H.R. 260

It acts where H.R. 260 reports. The draft covers the United Nations and the multilateral banks, acts on OFAC General License 20, replaces the Senate substitute’s one-sentence suspension clause with a knowing-and-material standard, a waiver, and notice to Congress, codifies the Afghan Fund release conditions, names an auditor, fixes the rescission, and preserves a humanitarian exception consistent with UN Security Council Resolutions 2615 and 2664.


Full text

Read the draft

Taliban Financial Accountability and Aid Integrity Act: Discussion Draft with Drafter’s Note

The one-page summary, the drafter’s note on where things stand as of 2 October 2026, the bill text by title, the crosswalk to H.R. 260, the tradeoffs the sponsor must decide, and Annexes A and B. View · Download
LD-2026-01 · 24 pp

Limitations

What this draft does not establish

This is a discussion draft prepared for staff deliberation. It is not a bill introduced in Congress, it is not the product of the Office of the Legislative Counsel, and it is not official U.S. government analysis. Bracketed values are open policy choices.

The statement of where things stand reflects the record as of 2 October 2026, including pending litigation over the blocked reserves; later developments are not reflected.

Nothing in this draft is legal advice or a substitute for counsel.


Citation

Suggested citation

Suggested citation

George, Collin B. Taliban Financial Accountability and Aid Integrity Act: Discussion Draft with Drafter’s Note. Legislative discussion draft LD-2026-01, version 2. Sanctir LLC, 2 October 2026.


Author

About the author

Collin B. George, CISSP, is the principal of Sanctir LLC, an independent research and advisory practice working on national security, export controls, sanctions, and defense industrial base risk.

Sanctir is a solo practice. This paper was prepared in the author’s personal capacity, is not official U.S. government analysis, and is not affiliated with any government agency, academic institution, or defense contractor.

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