Contents

• Summary
• Issues
• Worldview
• Goals
• Effects
• Prioritization
• Resources
• Assessments
• Integration
• Risk

Summary

Over the last few years, the term "partnership" has spread like wildfire through official U.S. national security guidance documents and rhetoric. At the Department of Defense (DOD), which spearheaded the proliferation of the term, "partnership" has been used to refer to a broad array of civilian as well as military activities in support of national security.¹ At other U.S. government agencies, and at the White House, the use of the term "partnership" has been echoed and applied even more broadly—not only in the national security arena, but also to all facets of U.S. relationships with foreign partners.

"Partnership" is not new in either theory or practice. To illustrate, U.S. strategy during the Cold War called for working with formal allies, through combined planning and the development of interoperable capabilities, in order to deter and if necessary defeat a Soviet threat. And it called for working with partners in the developing world to cultivate the allegiance of states and societies to the West, and to bolster their resistance to Soviet influence. Congress provided oversight in the forms of policy direction; resources and authorities for programs ranging from weapons sales to combined military exercises to cultural exchanges; and accountability.

New in recent years is both the profusion of the use of the term partnership and—in the aftermath of both the Cold War and the first post-9/11 decade—a much less singular focus for U.S. global engagement. Recent defense and national strategic guidance clearly conveys the view that partnership is good. But as a rule, it provides much less sense of what partnership is designed to achieve and how that protects U.S. interests; it does not clearly indicate how to prioritize among partnership activities; it does not assign specific roles and responsibilities for partnership across the U.S. government; and it does not indicate how to judge whether partnership is working.²

A lack of sufficient strategic direction could raise a series of potential concerns for Congress:

• Without sufficient national-level strategic guidance, good decisions about the use of partnership tools in support of national security may still be made on a case-by-case basis. But the natural default, practitioners suggest, may be toward embracing available opportunities, building further on evident successes, and falling in on existing patterns of engagement. In effect, that approach means optimizing at the sub-systemic level—focusing on the trees rather than on the forest—which may not optimally address defense and/or national-level strategic priorities.
• Without a clear articulation of the "ends" of partnership in support of national security, and whether and how those ends contribute to protecting U.S. interests, it may be difficult for agencies to judiciously prioritize partnership requirements against those for other national security missions.
• Without a clear articulation of the "ways and means" of partnership in support of national security, it may be difficult for agencies to gauge the extent to which partnership capabilities are distinct from others, or alternatively constitute "lesser included" subsets of other capabilities; and it may be difficult for agencies to consider appropriately the implications of partnership requirements for shaping and sizing the military force and the civilian workforce.
• Without a clear strategy of partnership in support of national security, linking ends with ways and means over time, it may be difficult for U.S. agencies to craft appropriate assessment tools to gauge the impact of partnership efforts on achieving defense and national security objectives, rather than resorting to the common default of focusing on "outputs," such as whether or not a training event took place.
• Without a clear distribution of roles and responsibilities—and corresponding resources and authorities—across the U.S. government for partnership in support of national security, it may be difficult for departments and agencies to plan and execute efficiently, and to integrate their efforts effectively.
• Without a clearly stated premise regarding resourcing—one that links initial investments in partnership efforts to any expected future savings as partners assume greater responsibilities over time—it can be difficult to anticipate the budgetary implications of partnership in support of national security.
• Without sufficient strategy for partnership in support of national strategy, together with appropriate assessment tools, a clear division of labor across the U.S. government, and resourcing expectations, it can be difficult for Congress to effectively allocate resources and authorities among agencies, and to ensure accountability for effective and efficient execution.

Issues

The debates and discussions among U.S. government officials and outside stakeholders about the use of partnership in support of national security are inchoate, but a number of facets of the debates are discernible, including worldview; goals; effects; priorities; resourcing; assessments; roles and responsibilities; and risk. These issues are variously addressed in recent strategic guidance documents. Key unclassified guidance documents include the 2006 Quadrennial Defense Review (QDR) Report, and its follow-on Building Partnership Capacity (BPC) roadmap; the 2010 National Security Strategy (NSS); the 2010 QDR Report; the 2010 Quadrennial Diplomacy and Development Review (QDDR); and the 2012 Defense Strategic Guidance (DSG).³ In addition, a wealth of internal DOD guidance reportedly addresses partnership—in particular the Guidance for the Employment of the Force (GEF) as well as planning and programming guidance documents under their various names. Yet the treatment of "partnership" by these documents is both inconsistent and partial—not all documents address all the major facets of strategy; some, such as resourcing, are barely treated; and in many cases the thrust of the guidance has changed over time. This section describes each facet of partnership strategy, analyzes its treatment in recent guidance, and raises questions that may be germane to congressional oversight.

Worldview

In general, a state's national security strategy is likely to derive from some worldview—a set of assumptions about the nature of the world order and the exercise of power within it, together with a view of that state's role on the world stage. That worldview, in turn, is likely to shape how a state defines its national interests. In any partnership strategy, these starting points are likely to affect what effects are desired, how efforts are prioritized, and how results are assessed. While worldview may not be explicitly stated, identifying its influence on U.S. strategy, including the role of partnership within that strategy, may be helpful to rigorous oversight.⁴

Recent strategic guidance documents vary significantly in both the extent to which worldview is explicitly stated, and the nature of their respective worldviews:

• The 2006 QDR went to great lengths to justify the whole idea of partnership. Partnership was depicted less as a given than as a new necessity, driven by two new realities in the global arena: the urgent threat of terrorism that required actions in new places; and the long-term, large-scale contingency operations in Iraq and Afghanistan that required more hands. In turn, the 2006 QDR ascribed to partnership a relatively linear causal logic: the United States would help build partners' capabilities, and then those partners would employ those capabilities in accordance with U.S. strategy. A basic—and in some ways remarkable—assumption of the 2006 QDR was that partners' decisions and actions would largely follow U.S. intent.⁵
• The 2010 QDR adopted the worldview of the 2006 QDR, that partnership as a rule requires a rationale, as well as a similar view of the global security context. As a result it largely echoed the counter-terrorism (CT)-driven rationale for partnership from the 2006 QDR.
• The 2010 NSS, in contrast, is explicitly based on a worldview in which collective action in the service of common interests is taken as a given—the default way of doing business in general, and thus not an approach that needs to be justified in each case. That view, solidly echoed in the 2010 QDDR, may be contrasted with a more instrumental approach to partnership, in which specific partners are recruited, when circumstances so require, to help accomplish specific ends. Furthermore, the 2010 NSS adopts from the institutionalist school of international relations theory the premise that shared norms help shape outcomes in the international system; so part of the causal logic in the 2010 NSS is that the United States fosters shared norms through partnership efforts, and those norms in turn shape choices by other international actors.
• The 2012 DSG reflects the 2010 NSS worldview—that partnership is the default way of doing business. It also reflects a perception of the global security context that is very different from those described by the 2006 and 2010 QDRs. The DSG underscores that the large-scale contingencies in Iraq and Afghanistan are no longer the top U.S. defense priorities, and the sense of urgency about fostering partners with the kinds of capabilities required for those contingencies has disappeared. The DSG's fundamental "shift toward the future" underscores concern with a broad range of security challenges, in contrast to the almost singular focus on CT as a driver for partnership in 2006. With partnership as the default starting point, the DSG indicates that any or all of these challenges might be addressed in part through partnership.

Key questions concerning worldview might include the following:

• What assumptions about the nature of the world order undergird proposed partnership initiatives?
• How powerful a role does U.S. leadership play in partnership activities—to what extent does strategy assume that partners will participate, and then act, based on U.S. intent?
• Should partnership be the default starting point for engagement on the world stage? Or does the choice to pursue partnership—given its inherent frictions and opportunity costs—require justification in each case?
• What role if any do shared norms play in shaping outcomes? And to what extent if any can the U.S. government shape shared norms?

Goals

In principle, worldview and national interests shape national security strategy, which in turn articulates goals. One fundamental, unresolved tension in the debates about the use of partnership in support of national security concerns the fundamental goal of partnership. One possible logic argues that the global security context today presents a greater or more complex array of challenges than it did in the past, so partnership, including greater participation and contributions by partners, is now essential in order to meet those challenges. Another possible logic argues that partnership generates savings—as U.S. partners assume greater responsibilities, the United States can do less. Those two logics are not mutually exclusive, but different choices about their respective importance could have different implications for prioritizing and resourcing partnership efforts.

Recent strategic guidance has tended to suggest that both logics apply without clarifying their relative importance:

• In the mid-aughts, both logics were powerfully alive in the Pentagon debates that shaped the 2006 QDR and other decision-making. In the wake of the terrorist attacks of 9/11, and amidst attention-grabbing cyber attacks, officials underscored that the 21^st century presented a much broader array of security challenges than ever before. The 2006 QDR called for building international partners' capabilities in order to meet those broader challenges. For example, counter-terrorism (CT) would require new, highly local approaches—and many of them—designed to cut off initial manifestations of terrorism, wherever in the world it might take root.⁶
• The 2006 BPC roadmap argued more pointedly that without partnership at home and abroad, "the nation's strategic objectives are unattainable." In other words, alone—we fail. At the same time, the 2006 BPC roadmap, more explicitly than any other guidance, also invoked the idea of savings: "The Department's efforts to build the planning and operational capabilities of partner agencies and international partners have the potential to reduce the length of U.S. force deployments, minimize the range of circumstances in which U.S. forces are called upon, and preserve the Department's financial resources."⁷ What the roadmap did not do was square the circle by addressing how partnership could achieve savings in the face of a larger overall requirement.
• The 2010 QDR echoed the 2006 QDR's concern with an increased span of challenges as well as its premise that partnership was an important tool for addressing them. In addition, the 2010 QDR noted one way in which partnership could generate savings—by rendering some actions unnecessary or reducing the U.S. share of the burden if action were required. By "strengthening relationships" abroad, it argued, the United States would become better at averting crises altogether or—if needed—at working with others to respond to them.⁸
• The 2012 DSG, in turn, seems to skew in the direction of savings. It states that partnership "remains important for sharing the costs and responsibilities of global leadership." Also, DOD official communications associated with the DSG have frequently stressed that partnership is one pillar of its plan to mitigate risk in the context of constrained resources.⁹

Key questions concerning the fundamental goals of partnership might include the following:

• What is the fundamental goal of partnership in support of national security? Is the logic to save money, as U.S. investments pay off over time in terms of things the U.S. government no longer has to do? Is the logic to meet a greater array of global security challenges by working by, with, and through partners—challenges that the United States would simply not have time or resources to meet on its own?
• To the extent that both goals apply—meeting challenges and generating savings—what is the appropriate balance between these goals in driving decisions about prioritization and resourcing?

Effects

In theory, partnership might be used to help achieve any of a wide array of ends that support national security: enabling partners to do specific things (at home, abroad, or as part of multilateral efforts); giving the United States better situational understanding; ensuring U.S. access; and shaping partners' perceptions and decision-making. Moreover, many specific partnership activities may aim at multiple effects—digging a well might build local good will for further tactical-level cooperation but may also develop capabilities that host nation forces could apply at home or abroad, foster effective host nation civil-military collaboration, deepen U.S. ability to work with host nation partners on a range of issues, and/or demonstrate U.S. commitment as part of a broader, orchestrated bilateral relationship. Clearly establishing the strategic logic that links interests to desired effects, and effects to activities, is widely viewed by strategists as essential for prioritizing efforts, producing effective assessments, and providing accountability.

Recent strategic guidance tends to describe desired effects omnivorously—after all, most potential effects of partnership sound desirable—without clarifying the interests-effects-activities logic trail:

• The 2006 QDR and its BPC roadmap, reportedly driven by a keeping-us-up-at-night view of global terrorism, were relatively specific and distinctly ambitious concerning the desired effects of partnership. The 2006 QDR helped propagate the view that effective counter-terrorism called for "going local"—countering the precursors to terrorism wherever it might take root. That approach, in turn, required working closely with interior as well as defense ministries of partners around the world. It also required a transformative approach toward state and society in partner countries: "improv[ing] states' governance, administration, internal security and the rule of law in order to build partner governments' legitimacy in the eyes of their own people and thereby inoculate societies against terrorism, insurgency, and non-state threats." This 2006 view did clearly link desired effects with U.S. interests, but that list of "effects" was unwieldy, because it failed to separate the essential from the merely desirable. Particularly from a 2012 vantage point—steeped in both emerging lessons from Iraq and Afghanistan, and a deeply austere fiscal context—the 2006 aspiration to "inoculate" may sound strikingly maximalist, and the view that the U.S. government can foster such inoculation, highly optimistic.¹⁰
• The 2010 QDR largely echoed the CT-driven rationale for the use of partnership from the 2006 QDR, as well as its scope and high level of ambition regarding partnership's desired effects. For example, it explained that since terrorists exploit ungoverned and under-governed areas as safe havens, DOD would help strengthen the ability of local forces to provide internal security and would work with other U.S. agencies to strengthen civilian capacity. It also made an adjustment to the strategic logic of partnership by naming "building the security capacity of partner states" as one of its six key missions. While that move may have been intended to emphasize further the importance of partnership, it opened the door to confusion by suggesting that partnership was an "end" rather than a set of instruments for pursuing other ends.¹¹
• The 2010 NSS calls for the use of whole-of-government partnership approaches, including roles for a number of U.S. departments and agencies, to help achieve a wide array of desired effects in support of U.S. national security interests. In the NSS, the effects of "invest[ing] in the capacity of strong and capable partners" include everything from countering violent extremism and stopping proliferation, to helping sustain economic growth and fostering shared norms. Geographically, the NSS calls for pursuing those effects very broadly—with traditional allies, emerging centers of influence, and new partners. Whether or not the objectives are all laudable and the proposed categories of partners appropriate, the expansiveness of both categories raises questions about which effects are most essential for protecting U.S. interests.
• The 2010 QDDR uses the term "partnership" to refer to the full spectrum of U.S. engagement with other states and multilateral organizations, which makes the desired effects of partnership largely coterminous with those of U.S. foreign policy. It affirms that one major component of that partnership is security-focused, and it states broadly that "the United States is investing in the capacity of strong and capable partners and working closely with those partners to advance our common security." Within that security category, it describes a wide range of the desired effects of partnership—from improving justice sectors, to countering violent extremism, to curtailing criminal networks, to strengthening fragile states, to ending conflicts, to supporting the environment—a range that far exceeds the narrow CT focus of the 2006 and 2010 QDRs. The QDDR does not articulate how the application of partnership approaches yields specific effects, or which applications are most important for protecting U.S. interests.¹²
• The 2012 DSG provides the least clarity, among the recent defense guidance documents, about the specific desired ends of partnership. That reflects both the worldview of the 2010 NSS, in which partnership is simply the way to do business, and the DSG's broader-spectrum view of future security challenges compared to previous defense guidance. In stressing the importance of partnership activities including rotational deployments of U.S. forces, and bilateral and multilateral training exercises, the DSG describes a long array of potential pay-offs including ensuring access, reinforcing deterrence, building capacity for internal and external defense, strengthening alliances, and increasing U.S. influence. But such a laundry list of desired effects does not indicate how specific activities generate specific effects, does not provide clear guidelines concerning which of the effects are most important for protecting U.S. interests, and does not convey the strategic logic, if any, by which some effects generate others.

Key questions concerning effects might include the following:

• How exactly does building the capacity and capabilities of U.S. partners lead to outcomes that help protect U.S. national security interests?
• By what logic exactly do partnership activities generate their desired effects?
• How and under what circumstances might some partnership effects help generate others?

Prioritization

Opportunities for partnership in support of national security are theoretically unbounded, so prioritization is essential both to focus effort and to conserve resources. In theory, priorities—always based on advancing and protecting U.S. interests—might be based on geography; or on functional concerns such as CT, countering weapons of mass destruction, and preventing or mitigating conflict; or on qualities of a potential partner such as its willingness to participate, its existing capabilities, and its general importance on the world stage aside from the dynamics of its bilateral relationship with the United States. These three possible rationales are likely to drive decision-making in quite different directions. It makes sense for partnership strategy to provide some mechanism for adjudicating among and sensibly synchronizing these three sets of concerns.¹³

Published strategic guidance documents are generally short on prioritization, while internal guidance reportedly has not settled on a single approach toward prioritization:

• The 2010 NSS and QDDR cast the broadest net, using "partnership" to refer to the full spectrum of U.S. government engagement around the world, providing exhaustive lists of the geographic areas ripe for partnership, the substantive arenas in which partnership should be applied, and the categories of potential partners.
• Not surprisingly, DOD's publicly available strategy documents do not include detailed guidance for prioritizing the use of partnership. The DSG stresses the growing importance of the Asia Pacific region and the continued importance of the Middle East, but it does not cross-walk those broad geographical priorities with functional or partner-characteristic concerns.
• Reportedly, DOD's internal guidance regarding partnership is more forthcoming, but the logic of prioritization that it uses has varied over time and the thinking remains unrefined. Some earlier guidance reportedly emphasized cultivating "willing and capable" partners. Yet some of the most important engagements from a U.S. strategic perspective may be precisely with those states that are not fully willing, or do not yet have all the capabilities required. These might include weak states facing significant internal turmoil that could grow into a threat to U.S. interests; or states that may take a skeptical view of the United States but whose geographic proximity to sources of U.S. concern could offer important access. While having willing and able partners might in theory be welcome, investing in all of them, and only in them, might not yield the biggest pay-offs in terms of protecting U.S. interests.
• Reportedly, more recent internal DOD guidance has recognized multiple potential rationales for partnership beyond the simple "willing and capable" formulation. But the use of multiple rationales has led to long lists of designated partners—each designated perhaps for a different combination of reasons.¹⁴ Without an agreed mechanism for rationalizing the major logics that might drive prioritization, and without some appetite suppressant on the overall scope, such guidance may provide little basis for making tough choices.

Key questions concerning prioritization might include the following:

• By what mechanism should priorities for partnership be determined? How might concerns with specific geographic regions, with specific kinds of threats and challenges, and with key characteristics of potential partner states best be reconciled to produce a coherent approach to prioritization?
• To what extent and in what ways should a sense of the overall requirement drive decision-making about priorities?
• To the extent that partnership efforts in support of national security may include states, multi-lateral organizations, non-governmental organizations, and societies writ large, how can partnership strategy best prioritize among unlike partners?

Resources

The broad partnership debates often seem to assume that partnership yields savings over time. To the extent that savings is part of the desired ends, it may be helpful for partnership strategy to outline the curves of investment and expected pay-off over time, including when and how both curves will be reflected in budget requests.

As a rule, strategic guidance concerning partnership broadly intimates that partnership eventually produces savings without demonstrating how that is expected to occur.

• The 2006 BPC roadmap went further than other strategic guidance by recognizing a range of ways in which partnership might generate savings over time. It also required that DOD officials include "assessments of the fiscal impact" in future internal deliberations about partnership.¹⁵

Key questions concerning resources might include the following:

• To what extent, if any, does partnership, given the initial costs of investment, eventually yield savings?
• In what ways, and according to what broad timeline, are savings generated by partnership efforts expected to be reflected in budget requests?
• To what extent if any does, and should, anticipated savings drive the relative prioritization of proposed partnership activities?

Assessments

One potential fundamental challenge to congressional oversight of Administration partnership efforts in support of national security is the lack of a clear assessment model for gauging the impact of partnership efforts. A common but generally unhelpful approach is to assess easily quantifiable "outputs" rather than "effects"—for example, assessing a bilateral exercise as successful because the exercise did indeed take place, rather than gauging the immediate and cumulative impact of relationship-building and capabilities-fostering on protecting U.S. interests. In theory, rigorous assessment requires as a starting point a clear and specific articulation of desired ends, together with a clear logic for assessing progress toward those ends. The realm of partnership complicates assessment in two ways. First, partnership efforts may be aimed at achieving multiple effects simultaneously—ranging from immediate, concrete results to longer-term, less tangible outcomes such as stronger U.S. influence that shapes a partner's decision-making. Second, some effects may be achieved partially, along a spectrum, rather than in the binary terms of success or failure.

As a rule, strategic guidance regarding partnership has been vague about desired effects, and it has not addressed the balance among qualitatively different kinds of effects. If anything, guidance tends to imply, without stating so, that accomplishing a tactical-level mission will naturally also yield an array of tangible and intangible benefits at the operational and strategic levels. Assessments depend on unambiguous statements of expected results. Among the recent guidance, only the 2006 BPC roadmap explicitly recognized the need to be able to assess return on U.S. investment, but it did not outline how to do so.

Key questions concerning assessments might include the following:

• How can the effects of partnership efforts, and their role in protecting U.S. interests, best be assessed?
• How might an assessments process consider partnership efforts designed to generate multiple, tangible and intangible, discrete effects? How in particular can the growth and impact of U.S. influence best be weighed?
• How can an assessments process best account for the fact that the effects of partnership efforts may depend in significant part on decisions and actions by U.S. partners?
• What qualities must partnership strategy have in order to facilitate effective assessment?

Integration

Observers have suggested that in an ideal world, the U.S. government would closely integrate all of its partnership efforts in support of national security—in diplomacy, development, and defense—not only so that these efforts do not contradict each other, but also so that they actively leverage each other and, as a whole, reflect U.S. priorities. Furthermore, the U.S. government would have a clear internal division of roles and responsibilities for partnership—among departments, and among key components within departments—in order to prevent confusion, mitigate friction, and allow effective and efficient preparation and execution by each entity. That clear division of labor would be reinforced, in turn, by congressional oversight.

In general, strategic guidance tends to be strong in calling for integration of effort, though usually without prescribing mechanisms for achieving that integration; and weak in calling for, let alone clarifying, a clear division of roles and responsibilities:

• At the systemic level, the 2010 NSS calls resoundingly—in a three-page section—for whole-of-government approaches, noting that "we must update, balance, and integrate all the tools of American power." It broadly describes the focus of each major component of U.S. effort—defense, diplomacy, economic, development, homeland security, and intelligence. But it does not assign roles and responsibilities to specific agencies.
• At DOD, the most ambitious guidance documents in this regard were those issued in 2006—the QDR and its follow-on BPC roadmap. At that time, the term "building partnership capacity" was applied ambitiously to all potential DOD partners including other U.S. agencies, non-governmental organizations, and the private sector, as well as international partners. The 2006 guidance documents recognized the need for both integration of effort and clarification of roles and responsibilities across these stakeholders. To that end, the guidance called for the use of national security planning guidance (NSPG)—internal, classified guidance, issued by the White House to all agencies with a national security role, which would confirm specific priorities, and clarify and assign roles and responsibilities. The BPC roadmap argued in support of the NSPG proposal that if the U.S. government is at cross purposes internally, partnership will cost more and be less effective.
• The 2010 QDR echoed its predecessor in portraying close interagency integration as necessary to successful partnership. The 2010 QDR also did something singular in terms of the internal DOD division of labor on partnership matters, by calling to "strengthen and institutionalize general purpose force (GPF) capabilities for security force assistance." Such a boost for the role of GPF might suggest the need for an updated rationalization of the respective contributions of GPF and Special Operations Forces (SOF) to partnership efforts.

Key questions concerning integration of effort and division of labor for partnership efforts in support of national security might include the following:

• How can the U.S. government best establish, and refine as needed, shared overall priorities for partnership efforts in support of national security? How can it best ensure that overall priorities for partnership efforts also support U.S. foreign policy goals writ large?
• What is the proper distribution of roles and responsibilities for partnership in support of national security among U.S. government departments and agencies? What would be the best mechanism for regularly updating systemic-level guidance to departments and agencies about their roles in undertaking partnership efforts in support of national security?
• How can the U.S. government best ensure that the distribution of authorities and resources among agencies corresponds to the most appropriate division of labor?
• How can the partnership roles of all stake-holding departments and agencies, once clearly defined, best be integrated?
• Given that many different departments and agencies are likely to share responsibility for partnership in support of national security, and that many individual programs require various combinations of participation, funding, and consent from multiple agencies, how can Congress best provide effective oversight?

Risk

Many potential benefits of partnership are seemingly obvious—to the extent that they are rarely spelled out. But partnership efforts carry potential risks as well as rewards. For example, partners may, tacitly or otherwise, come to depend on U.S. assistance in lieu of fostering their own fully sustainable systems. Partners may deliberately slow their growth of capabilities, or perpetuate a negative security climate, in order to justify requests for continued assistance. Partners may accept U.S. assistance but then choose not to apply their new capabilities toward U.S. strategic objectives. Or partners may apply the skills, education, and/or weaponry gained through partnership toward ends that contradict U.S. policy, such as carrying out human rights violations and staging a coup against a legitimate government.

Key questions concerning risk might include the following:

• What safeguards are in place to help ensure that partners appropriately assume responsibility over time?
• How and to what extent can the United States best encourage partners to apply new capabilities toward achieving shared objectives?
• What safeguards are in place to help ensure, at the very least, that partners do not misapply the benefits of their partnership with the United States?
• How much U.S. due diligence is enough to mitigate such risks?

Footnotes