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COVID-19 Economic Injury Disaster Loan Applications Submitted From Foreign IP Addresses — Report Number 22-17

Summary

SBA Inspector General Evaluation Report 22-17, dated September 12, 2022, on COVID-19 Economic Injury Disaster Loan (EIDL) applications submitted from foreign IP addresses, addressed to Administrator Isabella Casillas Guzman. The executive summary says SBA and a contractor designed four layers of internal controls and that, in a judgmental sample of 50 applications, 16 were not flagged by the system and another 15 were flagged but not properly reviewed by loan officers. It reports that SBA approved and disbursed 41,638 COVID-19 EIDLs, advances, and grants for $1.3 billion. Management partially agreed with recommendation 1 and agreed with recommendation 2.

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“COVID-19 Economic Injury Disaster Loan Applications Submitted From Foreign IP Addresses — Report Number 22-17.” Original at www.sba.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/covid-19-eidl-applications-from-foreign-ip-addresses-22-17-cbedf95ab4/, SHA-256 55e835b1ef32e2ea6ef379879c91140088859a87e60aacda6b08255b2762f6c3.

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SBA INSPECTOR GENERAL EVALUATION REPORT



COVID-19 ECONOMIC INJURY DISASTER LOAN
     APPLICATIONS SUBMITTED FROM
        FOREIGN IP ADDRESSES
     REPORT NUMBER 22-17 | SEPTEMBER 12, 2022
                     EXECUTIVE SUMMARY                                                       Report 22-17
                                                                                             September
                                                                                             12, 2022
                        COVID-19 ECONOMIC INJURY DISASTER LOAN
                        APPLICATIONS SUBMITTED FROM FOREIGN IP ADDRESSES


What OIG Reviewed                                          If a loan application from a foreign IP address made it
Our objective was to assess the U.S. Small Business        past the first two controls, control layer 3 was for the
Administration’s (SBA) controls to flag or prevent         system to flag the application. Control layer 4 was to
potentially fraudulent Coronavirus Disease 2019            have a loan officer thoroughly review the flagged
(COVID-19) Economic Injury Disaster Loan (EIDL)            application to determine if the applicant was eligible.
applications submitted from foreign Internet Protocol      We used a judgmental sample of 50 COVID-19 EIDL
(IP) addresses.                                            applications submitted from foreign IP addresses to
We reviewed SBA policies and procedures, interviewed       test control layers 3 and 4. We found 16 applications
agency and contractor officials, and analyzed SBA’s        were not flagged by the system and another 15
COVID-19 EIDL data.                                        applications were flagged by the system but were not
                                                           properly reviewed by loan officers before loans were
What OIG Found                                             approved and disbursed.
Although the agency implemented several layers of          SBA acknowledged that the controls did not perform as
controls to prevent or reduce fraud from foreign           intended and will not be used in future or current
countries, individuals at foreign IP addresses were able   application systems.
to access the COVID-19 EIDL application system.
                                                           OIG Recommendations
SBA received millions of attempts to submit COVID-19
EIDL applications from foreign IP addresses and            We recommended the agency thoroughly review the
stopped most of them; however, the agency processed        loans in our test sample and the $1.3 billion disbursed
more than 233,000 of these applications from March         to applicants from foreign IP addresses. The agency
20, 2020 to November 12, 2021, our review period. Of       should stop any further or future disbursements to any
this amount, SBA approved and disbursed 41,638             applicants deemed to be ineligible or fraudulent. We
COVID-19 EIDLs, advances, and grants for $1.3 billion.     also recommended SBA recover any disbursed loans
                                                           and advances determined to be ineligible or fraudulent.
Although applicants that reside overseas may qualify       Additionally, we recommended that the agency
for this assistance, transnational crime entities in       examine controls related to foreign IP addresses and
foreign countries have fraudulently obtained funding       ensure these controls are more effective in future
from this and other U.S. programs in the past.             disaster processing systems.
The numerous applications submitted from foreign IP        Agency Response
addresses are an indication of potential fraud that may
involve international criminal organizations. OIG has      Management partially agreed with recommendation 1,
ongoing investigations into international organized        stating they would conduct a proactive review of
crime operations that applied for and stole pandemic       COVID-19 EIDL applications that received funds for
relief funds.                                              potentially ineligible or fraudulent businesses. They
                                                           will attempt recovery and continue to refer suspected
SBA officials were aware of and concerned about the        fraud to the OIG. Management also emphasized that the
potential fraud from overseas. SBA hired a contractor      applications approved from foreign IP addresses were
to process 27.8 million COVID-19 EIDL applications as      a small proportion of all applications. SBA agreed with
of December 31, 2021. SBA and contractor officials         recommendation 2, stating the agency will examine
designed a system of four layers of internal controls to   controls related to foreign IP addresses and ensure
prevent loan applications from foreign IP addresses.       these controls are more effective in future disaster
Control layers 1 and 2 were supposed to block (1) the      processing systems.
submission of applications from foreign IP addresses in
six countries deemed high risk and (2) the completion
of applications from foreign IP addresses in all foreign
countries. We found both controls did not always block
these applications.
                        U.S. Small Business Administration
                      Office of Inspector General
DATE:         September 12, 2022
TO:           Isabella Casillas Guzman
              Administrator
FROM:         Hannibal “Mike” Ware
              Inspector General
SUBJECT:      COVID-19 Economic Injury Disaster Loan Applications Submitted from
              Foreign IP Addresses
This report presents the results of our evaluation COVID-19 Economic Injury Disaster Loan
Applications Submitted from Foreign IP Addresses. We considered management’s comments
on the draft of this report when preparing the final report. Management partially agreed to
one recommendation and agreed with the other recommendation.
We appreciate the cooperation and courtesies provided by your staff. If you have any
questions, contact me or Andrea Deadwyler, Assistant Inspector General for Audits, at
(202) 205-6586.
cc:     Arthur Plews, Chief of Staff
        Patrick Kelley, Associate Administrator, Office of Capital Access
        Peggy Delinois Hamilton, Special Counsel for Enterprise Risk
        Therese Meers, Acting General Counsel
        Michael Simmons, Attorney Advisor, Office of General Counsel
        Katherine Aaby, Associate Administrator, Office of Performance, Planning, and the
               Chief Financial Officer
        Erica Gaddy, Deputy Chief Financial Officer
        John Miller, Deputy Associate Administrator, Office of Capital Access
        Tonia Butler, Director, Office of Internal Controls
Table of Contents
Introduction ................................................................................................................................................................ 1
    Background............................................................................................................................................................. 1
        Record-setting Funding Amounts ............................................................................................................ 1
        Historic Application Volumes for COVID-19 EIDLs .......................................................................... 1
        Overview of the COVID-19 Application Process ................................................................................ 2
        Figure 1. SBA’s COVID-19 EIDL Application Process ....................................................................... 3
        SBA Can No Longer Accept New Applications .................................................................................... 3
    Objective .................................................................................................................................................................. 4
    Results....................................................................................................................................................................... 4
Finding: SBA’s Controls Did Not Prevent All COVID-19 EIDL Applications from Foreign IP
Addresses ..................................................................................................................................................................... 5
    Structure and Function of SBA Foreign IP Controls.............................................................................. 5
        Figure 2. Four Layers of Control in SBA’s System ............................................................................. 5
        Control Layer 1 = Firewall 1 – The Intake Point Control ............................................................... 6
        Table 1. Attempts to Access COVID-19 EIDL Application System from IP Addresses
        Located in Six Countries Deemed High Risk ........................................................................................ 7
        Table 2. COVID-19 EIDL Funds to Applicants with IP Addresses Located in Six
        Countries Deemed High Risk ...................................................................................................................... 8
        Control Layer 2 = Firewall 2 - The Client Portal Control................................................................ 8
        Table 3. Applications Processed by Country ....................................................................................... 9
        Control Layer 3 = Contractor System Flags....................................................................................... 10
        Table 4. Results of OIG Audit Test of System Flagging for Foreign IP Addresses............. 11
        Control Layer 4 = Loan Officer Review ............................................................................................... 11
        Table 5. OIG Test Results of Loan Officer Review of Flagged Loan Applications from
        Foreign IP Addresses .................................................................................................................................. 13
    Conclusion ............................................................................................................................................................ 13
    Recommendations ............................................................................................................................................ 14
Analysis of Agency Response ........................................................................................................................... 15
    Summary of Actions Necessary to Close the Recommendations ................................................. 15
Appendix I: Objective, Scope, and Methodology ...................................................................................... 17
Appendix II: Prior Work ..................................................................................................................................... 19
    Table 6. OIG Prior Oversight Work on SBA’s COVID-19 EIDL Program .................................... 19
Appendix III: Foreign IP Loan Data by Country ....................................................................................... 20
Appendix IV: Management Comments ......................................................................................................... 30
Introduction
The U.S. Small Business Administration’s (SBA) disaster assistance is the federal
government’s primary program for assisting small businesses, small agricultural
cooperatives, and most private, nonprofit organizations after declared disasters. The
program provides up to $2 million in disaster assistance loans to help eligible entities meet
financial obligations and operating expenses after a disaster.

Background
A series of national relief packages aimed at easing the economic effects of the Coronavirus
Disease 2019 (COVID-19) pandemic directed SBA, in accordance with the Small Business
Act, to provide COVID-19 Economic Injury Disaster Loans (EIDL) and additional funds in
three grant and advance programs, emergency EIDL grants, Targeted EIDL Advances, and
Supplemental Targeted Advances to affected eligible entities. 1 We refer to the three
programs as EIDL grants and advances in this report.
The laws also expanded the types of organizations that qualified for the funding to small
businesses to include small agricultural cooperatives, most private, nonprofit
organizations, cooperatives, Employee Stock Ownership Plans, and tribal concerns, all with
no more than 500 employees, then to sole proprietorships, independent contractors, and
agricultural enterprises. Agricultural enterprises are small businesses in food and fiber
production, ranching and raising livestock, aquaculture, or other farming or agricultural-
related industries. 2
To be eligible, an entity must have been in business on or before January 31, 2020,
adversely affected by the COVID-19 pandemic, and located in the United States or U.S.
territories.

Record-setting Funding Amounts
The national relief packages tasked SBA with quickly lending an enormous amount of
taxpayer funds: $500 billion in COVID-19 EIDLs; $20 billion in COVID-19 emergency EIDL
grants, up to $10,000 each; $30 billion in Targeted EIDL Advances, up to $10,000 each; and
$5 billion in Supplemental Targeted Advances, up to $5,000 each. Since the agency’s
inception in 1953, SBA has provided more disaster assistance funding through these
programs than in its entire history.

Historic Application Volumes for COVID-19 EIDLs
SBA suddenly had to process an unprecedented number of applications. On March 31,
2020, more than 680,000 applications were submitted to SBA, the highest number of loan

1 Public Law 116-123 - Coronavirus Preparedness and Response Supplemental Appropriations Act (March 6, 2020);

Public Law 116-136 - Coronavirus Aid, Relief, and Economic Security Act (March 27, 2020); Public Law 116-139 -
Paycheck Protection Program and Health Care Enhancement Act (April 24, 2020); and Economic Aid to Hard-Hit Small
Businesses, Nonprofits, and Venues Act (December 27, 2020); American Rescue Plan Act of 2021 (March 11, 2021).
2 Small Business Act 15 U.S.C. 647(b), section 18(b).




                                                        1
applications the agency had ever received in a day. By April 10, 2020, SBA had received
more than 4.5 million loan applications, well above the average of 65,000 per year before
the pandemic. By December 31, 2021, SBA had received 27.8 million COVID-19 EIDL
applications.
SBA hired a contractor to process COVID-19 EIDL applications and make recommendations
to approve or deny loan applications. SBA loan officers or team leads would give final
approval of each application.

Overview of the COVID-19 Application Process
EIDL relief eligibility, in accordance with U.S.C. Title 8, Chapter 14, Section 1611, is limited
to U.S. citizens, noncitizen nationals, and qualified aliens. 3 Therefore, those applicants
located at foreign Internet Protocol (IP) addresses could be legitimate if they controlled at
least a 20 percent share of an eligible entity, were adversely affected by the COVID-19
pandemic, located in the United States or U.S. territories, and in business on or before
January 31, 2020.
Although individuals who reside overseas may qualify for the assistance if they meet the
eligibility requirements, the fraud risk was high because of the history of fraud originating
from transnational crime organizations that have stolen funds from U.S programs in the
past. SBA was concerned with potential fraud from overseas and elected to block or flag all
applications from foreign IP addresses. To reduce fraud and cyber threats, SBA and the
contractor designed four layers of technical computing controls, known as firewalls (two
digital entry blocks), electronic flags (alerts), and human intervention (loan officer review)
to prevent fraud (See Figure 1). SBA did not have a plan to address how qualifying
individuals overseas could apply for this relief.




3 Part of the Immigration and Nationality Act.




                                                 2
Figure 1. SBA’s COVID-19 EIDL Application Process




Source: SBA and its contractor

SBA Can No Longer Accept New Applications
As of January 1, 2022, SBA stopped accepting new COVID-19 EIDL applications. Because of
lack of funds as of May 6, 2022, SBA was no longer accepting requests for increases to
COVID-19 EIDLs or reconsiderations of previously declined loan applications. Finally, on
May 16, 2022, the COVID-19 EIDL portal closed.




                                            3
Objective
Our objective was to assess SBA’s internal controls in place to flag or prevent potentially
fraudulent COVID-19 EIDL applications submitted from foreign IP addresses.

Results
Despite the four layers of controls SBA
and its contractor established, we found
that SBA disbursed 15,873 COVID-19
EIDLs totaling $1.2 billion and 25,765
EIDL grants and advances totaling $111.5
million, as of November 12, 2021, the end
of our review period, to individuals who
submitted applications from foreign IP
addresses. These were applications
missed by the first two layers of controls.
The third and fourth layers of controls
were designed to flag any applications
missed by the first two layers and ensure
SBA loan officers reviewed them. From a
judgmental sample of 50 COVID EIDL applications, we found the system did not flag 16
applications. The controls did flag the remaining 34 applications in our sample. However,
we found loan officers did not properly review 15 of the flagged applications in accordance
with written procedures to address and mitigate potential fraud indicators.




                                              4
Finding: SBA’s Controls Did Not Prevent All COVID-19
EIDL Applications from Foreign IP Addresses
We found that as of November 12, 2021, SBA had disbursed approximately $1.2 billion in
COVID-19 EIDLs and $111.5 million in EIDL grants and advances to applicants whose initial
application came from a foreign IP address.
Although SBA’s contractor provided evidence that the controls prevented individuals
located at a foreign IP address from accessing the system millions of times, we determined
the controls did not prevent such access more than 233,000 times. In addition, we found
problems with the flagging of applications from foreign IP addresses and the vetting of
those applications. From a judgmental sample of 50 COVID-19 EIDL applications, we found
the system did not flag 16 applications. The controls did flag 34 applications in our sample.
However, we found loan officers did not properly review 15 of the 34 flagged applications
in accordance with policies and procedures in place to prevent potentially fraudulent
applications.

Structure and Function of SBA Foreign IP Controls
The contractor’s system to process COVID-19 EIDL applications comprised at least two
access portals (intake point and client portal). When a potential applicant went to SBA’s
website to apply for a COVID-19 EIDL, the system would redirect to one of the contractor’s
access portals, referred to here as the “intake point” for initial applications and the “client
portal” for the completion of applications (see Figure 2). In general, the intake point should
have blocked all applicants from six foreign countries deemed high risk (Layer 1 = Firewall
1) from accessing the contractor’s system and the client portal (Layer 2 = Firewall 2)
should have blocked all foreign applicants not deemed high risk from completing
applications submitted to the intake point from all foreign countries.

Figure 2. Four Layers of Control in SBA’s System




Source: OIG analysis of SBA’s COVID-19 EIDL control structure

SBA speculated that applicants could have used technology to subvert the controls. During
our review, SBA acknowledged that the controls did not perform as intended and will not
be in use in future or current application systems.



                                                     5
As we describe in detail below, applicants were able to submit COVID-19 applications from
foreign IP addresses although there were layers of controls intended to prevent this and to
address the potential fraud risk. In addition, we asked SBA why Layer 1 and 2 controls had
separate application blocking criteria designed to prevent applications from foreign
countries. SBA officials stated there were points in time in 2020 where the decision by SBA
was to not block all foreign IP addresses. SBA did not maintain any information as to why
they made the different blocking criteria decisions in 2020. Thus, it is unknown why Layer
1 control was designed to prevent applications from six high-risk countries and Layer 2
control was designed to prevent the completion of applications from all foreign countries.

Control Layer 1 = Firewall 1 – The Intake Point Control
The first control between the applicant and contractor’s access portal, called the “intake
point,” of the system was designed to prevent submission of COVID-19 EIDL applications
from IP addresses in six countries categorized as high risk by a third-party software vendor
used by SBA’s contractor.
If Firewall 1 did not find the IP address was geolocated in one of the specified countries
deemed high risk, the applicant was allowed to fill out a COVID-19 EIDL application and
submit it. Once an application was submitted, the system executed various controls, such as
checking the applicant’s credit score and other identifying information. If the application
passed these controls and checks, the applicant would then be invited back to finish
additional application requirements in a second access portal, called the “client portal,” on
return to the system.
Firewall 1 should have prevented anyone at IP addresses in countries deemed high risk
from accessing the intake point. The contractor stated the firewall blocked 110,549
attempts from the six countries in May 2021 alone (see Table 1). We were unable to get
information on the number of attempts for other time periods because SBA’s contractor did
not maintain more than 1 month of information on blocked attempts.




                                             6
Table 1. Attempts to Access COVID-19 EIDL Application System from IP
Addresses Located in Six Countries Deemed High Risk
                            Number of
       Country              Attempts
 High-Risk Country 1               71,174
 High-Risk Country 2                 9,681
 High-Risk Country 3                 3,901
 High-Risk Country 4                   389
 High-Risk Country 5                       0
 High-Risk Country 6               25,404
                 Total            110,549
Source: SBA contractor data for May 2021

Our analysis of SBA’s COVID-19 loan, grant, and advance data revealed that between March
20, 2020 and November 12, 2021, 3,097 applications from the six countries deemed high
risk were not blocked.
Those applications were processed, approved, and disbursed a total of $14.3 million in
COVID-19 EIDLs and emergency EIDL grants (see Table 2).




                                               7
Table 2. COVID-19 EIDL Funds to Applicants with IP Addresses Located
in Six Countries Deemed High Risk
                                                          Total
                                          Total
                                                       Approved                       Total           Total
                                        Approved                       Total
                       Applications                     Amount,                     Amount,         Disbursed
      Country                            Grants                      Approved
                        Submitted                      Grants and                     EIDLs          Amount
                                           and                         EIDLs
                                                        Advances                    (dollars)       (dollars)
                                        Advances
                                                        (dollars)
 High-Risk Country               488             64      $316,000             26    $1,268,100       $1,584,100
 1
 High-Risk Country             1,338           187      1,040,000            108     7,475,600        8,515,600
 2
 High-Risk Country               112              8        26,000              4      139,900          165,900
 3
 High-Risk Country               104              6        36,000              0                0       36,000
 4
 High-Risk Country                  0             0              0             0                0               0
 5
 High-Risk Country             1,055           100        448,000             47     3,568,800        4,016,800
 6
 Total                         3,097           365     $1,866,000            185   $12,452,400      $14,318,400
Source: SBA COVID-19 EIDL, grant, and advance data as of November 12, 2021

We asked the contractor why the control did not block access from all six countries
completely and how applicants were able to subvert Firewall 1. Their response was that
they could not guarantee 100 percent effectiveness. The contractor speculated that the IP
addresses could be masked. Neither SBA nor its contractor knew why so many applications
were able to subvert Firewall 1.
During our evaluation, SBA transitioned the responsibility of the COVID-19 EIDL program
from the Office of Disaster Assistance to the Office of Capital Access on June 29, 2021. After
the transition, we asked the Office of Capital Access why the control was designed to block
applications from only six countries deemed high risk when the Layer 2 control was
designed to block the completion of all applications from all foreign countries. Again, SBA
officials did not know why this decision was made at the onset of the program. After our
questions, SBA and the contractor confirmed that SBA had directed the contractor on July
19, 2021 to block IP addresses of all foreign countries from accessing the intake point.

Control Layer 2 = Firewall 2 - The Client Portal Control
The control at the client portal was supposed to prevent applicants from all foreign IP
addresses from accessing the system and completing COVID-19 EIDL applications. The
contractor’s data showed Firewall 2 blocked more than 1.6 million attempts by applicants
located at foreign IP addresses from accessing the client portal in May 2021. Again, we



                                                   8
were unable to get information on the number of attempts for other time periods because
SBA’s contractor does not maintain more than 1 month of information on blocked attempts.
In addition to blocking foreign IP addresses, the contractor banned some IP addresses for
repeated attempts to access the system and various other reasons. In total, the contractor
banned more than 32,000 IP addresses located in foreign countries.
The blocking and banning of foreign IP addresses showed the system had some effect on
preventing applications from foreign countries. However, we found Firewalls 1 and 2 did
not prevent the completion of 233,872 applications submitted from foreign IP addresses at
the intake point and the disbursement of $1.3 billion in COVID-19 EIDLs and grants (see
Table 3).

Table 3. Applications Processed by Country
                              Total              Total
                                                                                                    Total
                            Approved           Approved          Total       Total Amount,
               Applications                                                                       Disbursed
  Country                    Grants            Amount,         Approved          EIDLs
                Submitted                                                                          Amount
                               and             Advances          EIDLs         (dollars)
                                                                                                  (dollars)
                            Advances           (dollars)
 Nigeria              33,477           241      $1,109,000            496       $18,452,300        $19,561,300
 Pakistan             29,290           632        3,353,000           483        43,862,300         47,215,300
 Canada               20,500         3,755      19,236,000          2,062       164,071,090        183,307,090
 Mexico               14,656         3,100      12,740,000          2,081       145,128,775        157,868,775
 United               12,007         1,358        6,418,000           834        59,884,398         66,302,398
 Kingdom
 Philippines            9,762          658        3,399,000           335        25,902,800         29,301,800
 Dominican              9,524          781        3,750,000           564        30,397,700         34,147,700
 Republic
 India                  9,273        1,561        6,763,000         1,061       137,027,317        143,790,317
 Germany                6,061          719        3,056,000           355        18,106,768         21,162,768
 All other            89,322        12,960      51,666,000          7,602       560,044,698        611,710,698
 countries
 Total               233,872        25,765 $111,490,000            15,873 $1,202,878,146 $1,314,368,146
Source: OIG analysis of SBA’s COVID-19 EIDL, grant, and advance data from March 20, 2020 to November 12,
2021

We believe there is a significant risk of potential fraud in applications submitted from
foreign IP addresses. SBA was also concerned with this risk because agency officials
recommended blocking all applications from foreign IP addresses at program outset.
However, the control did not prevent all applications from foreign countries. Neither SBA
nor its contractor knew how so many applications were able to subvert Firewall 2.




                                                    9
Control Layer 3 = Contractor System Flags
If the software did not detect a foreign IP address, the applicant would be admitted to the
client portal to finish their application. To complete COVID-19 EIDL applications, the
applicant would verify their identity, submit any needed additional documents and
information, and eventually sign the loan agreement to receive the funds.
SBA and the contractor officials told us they had been concerned about the risk that
Firewall 1 and 2 controls might be bypassed. Technologically savvy ineligible applicants
might use computer technology, such as virtual private networks (VPNs), proxy servers, or
The Onion Router, commonly known as TOR, to mask their actual locations, enter the
system, and apply for American relief funds.
In case some applicants were able to bypass system controls, the contractor installed a
third-party software program to identify and flag attempts to mask the actual location of
applicants.
If the software identified a foreign IP address, it electronically flagged the COVID-19 EIDL
application with an alert warning of “Client location is international” or “high-risk IP
address.”
       Client Location Is International. This flag alerted loan officers that the applicant
       accessed the loan system from a location outside the United States and its
       territories, indicating a high risk of fraud.
       High-risk IP. This flag alerted the loan officer that a device used to electronically
       submit the loan application may have been used in fraudulent activity. For example,
       if the application came from a domestic IP address as a proxy or if a connection to
       the “dark web” was detected. The dark web is the area of the internet that allows
       users to be anonymous.
If the software did not detect an IP address, or the IP address was in some way suspect, the
software flagged the application with an alert of “suspicious online behavior.”
       Suspicious Online Behavior. This flag alerted loan officers if different devices had
       accessed the system, the data had been associated with possible online fraud, or if
       there was an attempt to bypass fraud checks.
To test the third control layer, we judgmentally selected a sample of 50 approved and
disbursed COVID-19 EIDLs from the loan data from locations in 12 foreign countries
geographically dispersed across the world. We reviewed the selected loan files to
determine if the software had flagged them.
We found 34 applications, totaling $5.3 million, were properly flagged by the software.
However, 16 applications out of the 50 in our sample were not identified or flagged by the
contractor’s third-party software intended to alert loan officers to properly mitigate these
flags. These 16 applications were processed, approved, and disbursed for a total amount of
more than $3.1 million. Without the software alert flags, loan officers were unaware that
additional vetting was needed for approval (see Table 4).




                                             10
Table 4. Results of OIG Audit Test of System Flagging for Foreign IP
Addresses
                                                                           Grant
                                                             EIDL           and            Total
                                              System
                                 Flagged                   Amount        Advance         Disbursed
                   Loans                        Did
   Country                          by                        Not        Amount         Amount Not
                   Tested                       Not
                                 System*                    Flagged         Not           Flagged
                                               Flag
                                                           (dollars)      Flagged        (dollars)
                                                                         (dollars)
 Afghanistan                4             2           2     $162,300        $6,000            $168,300
 China                      4             1           3      406,000        13,000             419,000
 Dominican                  5             4           1      174,400          5,000            179,400
 Republic
 India                      5             2           3      897,400          5,000            902,400
 Iraq                       4             4           0              0            0                    0
 Israel                     5             5           0              0            0                    0
 Nigeria                    5             4           1      150,000              0            150,000
 Russia                     4             2           2      300,000          4,000            304,000
 Syria                      1             1           0              0            0                    0
 United                     5             3           2      719,000        11,000             730,000
 Kingdom
 Venezuela                  4             3           1      150,000          2,000            152,000
 Yemen                      4             3           1      150,000          1,000            151,000
 Total                     50            34         16     $3,109,100      $47,000          $3,156,100
Source: OIG analysis

*COVID-19 EIDL applications flagged by the system for any of these three fraud alerts: “Client location is
international,” “High-risk IP address,” and “Suspicious online behavior.”

Control Layer 4 = Loan Officer Review
The fourth layer of control established by SBA and the contractor required a review by the
loan officers to address or clear alert flags on the applications. SBA and the contractor
released written procedures on April 13, 2020 and revised them five times over the next
year, outlining specific loan officer actions on how to properly mitigate these alert flags. In
this layer, COVID-19 EIDL applications flagged by the system for any of these three fraud
alerts: “Client location is international,” “High-risk IP address,” and “Suspicious online
behavior” required review and approval by a loan officer.
SBA policy required the following:




                                                      11
       Client Location Is International. The procedures required loan officers to confirm
       the business was physically located within the United States or a U.S. territory
       before approving the application. If not, the officer was supposed to deny the
       application.
       High-risk IP. This alert flag was not added until the written procedures were
       revised on April 20, 2021. The written procedures required the loan officer to call
       the applicant to verify the applicant’s identity, but there was no requirement for a
       loan officer to obtain a copy of valid identification.
       Suspicious Online Behavior. Prior to April 20, 2021, the written procedures
       required the loan officer to automatically deny the loan.
SBA revised the written procedures on April 20, 2021, reversing the automatic denial. The
revision required loan officers to call the applicant to verify identity and request a copy of
valid identification within 7 days. If the applicant’s identity could not be verified, then the
loan would be denied.
To test these alert flags, we reviewed the 34 loan files in our testing sample flagged by the
system. These files were tagged in the system with the fraud alert flags, “Client location is
international,” “Suspicious online behavior,” or “High-risk IP address.”
We found 19 of the files, totaling about $2.9 million, had been properly reviewed before
loan approval. However, 15 loan files, totaling about $2.4 million, were not vetted by the
loan officers before loan approval and disbursement (see Table 5).
We asked SBA officials why applications with fraud flags were approved without a loan
officer addressing these alerts. SBA officials informed us that there were several factors:
   •   For five of the loan applications, “the file was sent to the approved queue by the
       system” bypassing loan officer review;
   •   For seven of the applications, the reference guide did not provide direction for fraud
       alerts. However, we found the reference guide did provide loan officer actions to
       mitigate or deny the loan based on fraud alerts; and
   •   For six of the applications, the fraud alert did not exist at time of approval. However,
       there is no data field for the date the alert flags were created, and it is uncertain
       when the alert flags were created by the system. Therefore, the fraud flag may or
       may not have existed at the time of loan office review.
The total number of exceptions exceeds the number of files because the response provided
for each file consisted of more than one of the factors or reasons listed above.




                                              12
Table 5. OIG Test Results of Loan Officer Review of Flagged Loan
Applications from Foreign IP Addresses
                                                Loan                     Grant and          Total
                                  Loan                        EIDL
                                             Officer Did                  Advance         Disbursed
   Country          Flags        Officer                     Amount
                                                 Not                      Amount           Amount
                                Mitigated                   (dollars)*
                                              Mitigate                   (dollars)*       (dollars)*
 Afghanistan                2            2              0            0                0                0
 China                      1            1              0            0                0                0
 Dominican                  4            3              1     150,000          1,000         151,000
 Republic
 India                      2            2              0            0                0                0
 Iraq                       4            2              2     103,500          2,000         105,500
 Israel                     5            3              2     300,000         17,000         317,000
 Nigeria                    4            1              3     450,000         14,000         464,000
 Russia                     2            1              1     150,000         10,000         160,000
 Syria                      1            0              1      21,500          1,000          22,500
 United                     3            2              1     300,700                 0      300,700
 Kingdom
 Venezuela                  3            1              2     650,000          8,000         658,000
 Yemen                      3            1              2     213,800          3,000         216,800
 Total                   34             19             15 $2,339,500         $56,000       $2,395,500
Source: OIG analysis of SBA COVID-19 data

*For applications not mitigated by the loan officer.

Conclusion
The agency implemented several layers of controls to prevent or reduce fraud with
firewalls or alerts designed to prevent applications originating from foreign countries. We
believe the system blocked a majority of the applications from foreign IP addresses.
However, we found that applicants with foreign IP addresses were able to access the
system more than 233,000 times, resulting in $1.3 billion in COVID-19 EIDL funding to
applicants in foreign countries who may not have been eligible.




                                                       13
Recommendations
We recommend the Administrator direct the Associate Administrator for the Office of
Capital Access in conjunction with the Associate Administrator for Disaster Assistance and
Chief Information Officer to:
   1. Thoroughly review each COVID-19 EIDL, grant, and advance application submitted
      from foreign IP addresses that were approved and funded and verify eligibility. If
      ineligibility or evidence of potential fraud is found, SBA should stop any further or
      future disbursements, recover any disbursed funds, and refer fraudulent loans to
      OIG for investigation.
   2. Examine controls related to foreign IP addresses and ensure these controls are more
      effective in future disaster processing systems.




                                            14
Analysis of Agency Response
SBA management provided formal comments to the draft report, which are included in
Appendix IV. Management partially agreed with recommendation 1 and agreed with
recommendation 2. The proposed actions will resolve both recommendations and
management will provide implementation dates by separate correspondence. We
considered management’s comments when preparing this final report.
Regarding recommendation 1, management partially agreed and proposed actions that
were responsive to the recommendation. Specifically, management agreed that controls
initially in place to flag and prevent the applications from high-risk countries did not do so
consistently. However, they stated that “The $1.3 billion identified by the OIG that
originated from applications submitted from a foreign IP address represents less than .04
percent of the more than $342 billion approved by SBA for COVID EIDL advances and
loans.” OIG acknowledges that the percentage of disbursements identified may seem small,
however, we believe that $1.3 billion in taxpayer funds to individuals or businesses that
should not have received it is significant. We reported that the numerous applications
submitted from foreign IP addresses are an indication of potential fraud that may involve
international criminal organizations. Also, OIG has ongoing investigations into
international organized crime operations that applied for and stole pandemic relief funds.
Consequently, it is concerning that $1.3 billion intended to assist small businesses during
the pandemic potentially funded illegal activities worldwide, making it critical that proper
controls are in place and working as intended.

Summary of Actions Necessary to Close the Recommendations
Recommendation 1
Thoroughly review each COVID-19 EIDL, grant, and advance application submitted from
foreign IP addresses that were approved and funded and verify eligibility. If ineligibility or
evidence of potential fraud is found, SBA should stop any further or future disbursements,
recover any disbursed funds, and refer fraudulent loans to OIG for investigation.
Status: Resolved
Management partially agreed with our recommendation and stated SBA will conduct a
proactive review using additional data analytics of COVID EIDL applications that received
funds for potentially ineligible or fraudulent businesses. Management further stated SBA
will attempt recovery and continue to refer all suspected cases of fraud to OIG to be
investigated. Management’s proposed actions were responsive to the recommendation, and
we consider this recommendation to be resolved.
This recommendation can be closed when management provides evidence that the agency
has completed the review of the over 233,000 applications from foreign IP addresses and
then recovered, or at a minimum, attempted to recover funds and referred potentially
fraudulent loans to OIG.




                                              15
Recommendation 2
Examine controls related to foreign IP addresses and ensure these controls are more
effective in future disaster processing systems.
Status: Resolved
Management agreed with this recommendation to examine controls related to foreign IP
addresses and ensure these controls are more effective in future disaster processing
systems. Management’s proposed actions were responsive to the recommendation, and we
consider this recommendation to be resolved.
This recommendation can be closed when management provides evidence that they have
examined controls related to foreign IP addresses and they have implemented a system
with adequate controls to prevent access from foreign IP addresses or to adequately vet
access from foreign IP addresses.




                                           16
Appendix I: Objective, Scope, and Methodology
Our objective was to assess SBA’s controls in place to flag or prevent potentially fraudulent
applications for the COVID-19 EIDL program submitted from foreign IP addresses not in a
U.S. territory.
To meet our objective, we reviewed the following:
   •   Coronavirus Aid, Relief, and Economic Security Act
   •   Coronavirus Preparedness and Response Supplemental Appropriations Act
   •   SOP 50 30 9, Disaster Assistance Program
   •   SBA Rapid Decision Reference Guides (dated April 13, 2020 through April 20, 2021)
   •   SBA contractor data for COVID-19 EIDLs, grants, and advances
   •   U.S.C. Title 8, Chapter 14, Section 1611
We interviewed SBA officials at the Office of Disaster Assistance, Office of Capital Access,
and the Office of the Chief Information Officer. We also interviewed officials of the
contractor used by SBA to process COVID-19 EIDLs.
We obtained data for COVID-19 EIDLs from March 20, 2020 through November 12, 2021
from the contractor’s system and loan approval and disbursement data from SBA’s system,
known as ETRAN. Within this data, we used a private vendor geolocation tool to identify IP
addresses located outside the United States and its territories.
We attempted to assess the reliability of the data by performing limited testing. However,
neither SBA nor the contractor provided source information to us to perform data
reliability testing. As a result, the reliability of the ETRAN and subcontractor’s system data
is undetermined. But it produces the best available data, which SBA uses to manage the
program and derive program statistics.
Additionally, SBA and contractor officials told us the login records of the client portal were
not reliable to use in this review. SBA’s contractor told us the computer software at the
client portal was not updated to capture the increased number of characters of the newer
Internet Protocol version 6 addresses, but that it did not affect the login records of the
application intake point. Consequently, we were unable to reliably analyze the foreign IP
addresses that accessed the client portal. Based on the contractor’s statement, our analyses
about devices with foreign IP addresses accessing the initial application submitted at the
intake point remain reliable.
We ran the IP addresses in the loan data through a geolocation software tool from a private
vendor to identify the internet provider used by the applicant and the location of the device
used to submit the application. The geolocator tool that we used to identify the applications
received from outside the U. S. and its territories is used by OIG Investigations Division and
other government agencies. This geolocator tool asserts a 99.8 percent accuracy rate for
identifying the internet service providers and specific locations of the submitted IP
addresses.
We judgmentally selected 50 COVID-19 EIDL applications submitted from 12 randomly
selected countries. These specific loans were selected in order to provide a wide or
reasonable representation of countries. To confirm that the IP addresses used to submit


                                              17
these 50 EIDLs were from outside the United States and its territories, we used a second
and distinct geolocator tool to retest them. This tool confirmed that all 50 EIDL applications
in our test sample had come from the foreign location identified by the first geolocator tool.
We selected a sample of 50 loans approved between April 20, 2020 and April 23, 2021,
totaling more than $8.4 million. These were judgmentally selected because they originated
from the 12 randomly selected countries. We tested the 50 EIDL files to determine whether
SBA had identified the foreign source of the loan application, and if so, whether a loan
officer reviewed the system flag to determine whether the application was legitimately
from an eligible applicant.
We conducted this evaluation in accordance with the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards
require that we plan and perform the inspection to obtain sufficient, appropriate evidence
to provide a reasonable basis for our conclusions and observations based on our objectives.




                                             18
Appendix II: Prior Work
Table 6. OIG Prior Oversight Work on SBA’s COVID-19 EIDL
Program
          Report Title               Report Number    Final Report Date
        COVID-19 EIDL Program         SBA OIG 22-06       November 30,
 Recipients on the Department of                                2021
       Treasury’s Do Not Pay List
   SBA’s Emergency EIDL Grants        SBA OIG 22-01     October 7, 2021
          to Sole Proprietors and
       Independent Contractors
 SBA’s Handling of Identity Theft     SBA OIG 21-15         May 6, 2021
  in the COVID-19 EIDL Program
    Serious Concerns About SBA’s      SBA OIG 21-13        April 7, 2021
    Control Environment and the
         Tracking of Performance
   Results in the Shuttered Venue
        Operators Grant Program
    Inspection of Small Business      SBA OIG 21-02    October 28, 2020
 Administration’s Initial Disaster
      Assistance Response to the
          Coronavirus Pandemic
    Serious Concerns of Potential     SBA-OIG 20-16        July 28, 2020
         Fraud in EIDL Program
    Pertaining to the Response to
                        COVID-19
    White Paper: Risk Awareness       SBA OIG 20-12        April 3, 2020
       and Lessons Learned from
  Audits and Inspections of EIDLs
     and Other Disaster Lending
Source: SBA OIG




                                               19
Appendix III: Foreign IP Loan Data by Country
The following table is a comprehensive list of COVID-19 EIDLs disbursed for approved loan applications submitted to SBA
from foreign IP addresses in descending order of total number of applications. The countries are listed from higher to lower
based on the number of applications submitted.
   Country      Applications      Total           Total        Total       Total Amount,        Total
                 Submitted     Approved        Approved      Approved      EIDLs (dollars)    Disbursed
                               Grants and       Amount,        EIDLs                           Amount
                                Advances       Grants and                                     (dollars)
                                                Advances
                                                (dollars)
 Nigeria             33,477            241      $1,109,000           496     $18,452,300      $19,561,300
 Pakistan            29,290            632       3,353,000           483      43,862,300       47,215,300
 Canada              20,500          3,755      19,236,000         2,062     164,071,090      183,307,090
 Mexico              14,656          3,100      12,740,000         2,081     145,128,775      157,868,775
 United              12,007          1,358       6,418,000           834      59,884,398       66,302,398
 Kingdom
 Philippines           9,762           658       3,399,000          335       25,902,800       29,301,800
 Dominican             9,524           781       3,750,000          564       30,397,700       34,147,700
 Republic
 India                 9,273          1561       6,763,000         1061      137,027,317      143,790,317
 Germany               6,061           719       3,056,000          355       18,106,768       21,162,768
 Netherlands           4,583           337       1,812,000          218       15,422,400       17,234,400
 Ghana                 4,313            68         351,000           59        3,273,100        3,624,100
 Colombia              3,956           811       2,776,000          588       38,187,300       40,963,300
 France                3,632           438       1,885,000          248       16,639,600       18,524,600
 Israel                3,198           917       3,460,000          656       72,275,200       75,735,200
 Turkey                3,030           298         883,000          158       12,808,900       13,691,900
 Spain                 2,967           540       1,363,000          284       20,934,800       22,297,800


                                                              20
South Africa   2,723   127    591,000         126    9,275,300    9,866,300
Jamaica        2,525   191    812,000         168    8,596,500    9,408,500
United Arab    2,459   183    748,000          92    9,900,800   10,648,800
Emirates
Australia      2,315   330   1,284,000        184   12,920,800   14,204,800
Brazil         2,285   373   1,557,000        225   15,016,000   16,573,000
Japan          2,052   396   1,695,000        172    7,183,700    8,878,700
South Korea    1,830   397   1,295,000        159   11,609,000   12,904,000
Kenya          1,508    90     453,000         54    5,176,300    5,629,300
Italy          1,483   295     945,000        142   10,899,100   11,844,100
Switzerland    1,471   202     787,000         98    7,557,700    8,344,700
Costa Rica     1,458   389   1,356,000        280   23,914,000   25,270,000
Egypt          1,338   187   1,040,000        108    7,475,600    8,515,600
Thailand       1,231   311   1,174,000        167    9,080,900   10,254,900
Argentina      1,146   317   1,403,000        135    7,625,900    9,028,900
Hong Kong      1,124   224   1,021,000         97    6,698,300    7,719,300
Vietnam        1,099   312   1,050,000        127    9,011,300   10,061,300
Romania        1076     90     331,000         45    4,018,500    4,349,500
Russia         1055    100     448,000         47    3,568,800    4,016,800
Singapore        933   156     707,000         70    4,767,200    5,474,200
Ecuador          923   159     501,000         96    6,217,800    6,718,800
Venezuela        874   187     526,000         70    5,014,400    5,540,400
Taiwan           827   230     656,000         89    6,328,400    6,984,400
Morocco          822    83     511,000         39    1,898,400    2,409,400
Burkina          816     7      64,000         10      610,300      674,300
Faso
Ukraine         812    106    419,000          74    6,834,500    7,253,500
Portugal        781    116    360,000          78    3,736,800    4,096,800



                                         21
Bulgaria      768    89   338,000         64    4,837,400    5,175,400
Ethiopia      740    50   422,000         47    3,149,100    3,571,100
Peru          692   204   652,000        140    7,186,400    7,838,400
Jordan        680    96   410,000         57    4,578,500    4,988,500
Greece        607   101   355,000         76    4,954,900    5,309,900
Austria       603    71   299,000         43    2,958,700    3,257,700
Haiti         597    41   201,000         33    1,281,100    1,482,100
Malaysia      589    43   179,000         30    1,840,900    2,019,900
Nicaragua     557   122   497,000        108   12,241,800   12,738,800
Belgium       550    87   389,000         38    2,114,900    2,503,900
Bangladesh    538    81   688,000         58    5,621,200    6,309,200
Indonesia     532    98   329,000         62    4,207,399    4,536,399
Ireland       520   109   557,000         62    6,241,100    6,798,100
Senegal       507    45   300,000         30    1,243,200    1,543,200
Sweden        497    83   285,000         51    3,094,800    3,379,800
China         488    64   316,000         26    1,268,100    1,584,100
Bahamas       479    75   332,000         49    2,768,100    3,100,100
Poland        472    90   273,000         55    2,549,000    2,822,000
Panama        444   105   426,000         82    7,678,400    8,104,400
Cyprus        437    14    51,000         12      378,100      429,100
New           428   139   489,000         78    6,085,200    6,574,200
Zealand
Chile         384    82   323,000         38    3,475,200    3,798,200
Serbia        378    78   273,000         62    7,088,500    7,361,500
Georgia       369    43   142,000         23    1,023,700    1,165,700
Guatemala     366    87   302,000         47    2,238,400    2,540,400
Afghanistan   358    70   299,000         31    1,289,700    1,588,700
Honduras      350    67   317,000         44    3,491,100    3,808,100


                                    22
Saudi Arabia   342   86   340,000        32   1,742,500   2,082,500
Armenia        313   45   197,000        27   2,084,900   2,281,900
Belize         301   35   173,000        29     966,900   1,139,900
Denmark        294   64   397,000        35   1,438,500   1,835,500
Albania        290   19    96,000        11   1,073,600   1,169,600
Benin          289    2    16,000         2      67,300      83,300
Kuwait         285   72   371,000        25   1,160,100   1,531,100
Lebanon        268   57   235,000        46   4,608,600   4,843,600
Czechia        263   49   148,000        23   1,100,600   1,248,600
El Salvador    256   32   149,000        22   2,603,100   2,752,100
Iraq           256   26   148,000        16     538,800     686,800
Norway         252   38    83,000        28     845,500     928,500
Antigua and    240   17    75,000        12   2,177,000   2,252,000
Barbuda
Palestine      225   27    78,000        16   1,401,500   1,479,500
Finland        223   18    63,000        15   1,542,300   1,605,300
Cambodia       216   29   105,000        18     944,900   1,049,900
Bahrain        211   30   195,000        18     648,400     843,400
Somalia        210   15   144,000         4     208,000     352,000
Luxembourg     207   25   147,000         6     287,300     434,300
Hungary        201   39   116,000        29   2,814,000   2,930,000
Uganda         199   21   130,000        11     720,100     850,100
Barbados       198   26   131,000        21   1,514,499   1,645,499
Tanzania       195    9    30,000         8     276,800     306,800
Trinidad       194   47   185,000        31   2,043,500   2,228,500
and Tobago
Uzbekistan     192   26   108,000        12   1,470,500   1,578,500
Algeria        181   20   117,000         4      57,100     174,100



                                    23
Cameroon       179   13    88,000        10     553,700     641,700
Sudan          178   10    69,000         5     530,300     599,300
Croatia        177   41   255,000        21   1,161,000   1,416,000
Cuba           175   28    82,000         8     194,200     276,200
Ivory Coast    172    8    38,000         8     403,900     441,900
Liberia        169   11    69,000        11     517,000     586,000
Nepal          167   26    91,000        13     588,100     679,100
Moldova        154   27    84,000        12     802,600     886,600
Tunisia        154   12    60,000         8     648,100     708,100
Yemen          154   10    77,000         5     629,600     706,600
Togo           153    2     2,000         6     215,800     217,800
Guinea         151    9   107,000         3     208,500     315,500
Qatar          142   34   126,000        17     679,600     805,600
Mali           139    8    79,000         5     858,700     937,700
Iceland        137   18    76,000        15   1,168,900   1,244,900
Sri Lanka      136   26   119,000        16   1,148,300   1,267,300
Guyana         132   13    63,000         6     328,100     391,100
Bolivia        131   39   151,000        18     648,500     799,500
Gambia         131    7    54,000         5     578,000     632,000
Sierra Leone   121    9    20,000         3     171,000     191,000
Azerbaijan     118    9    12,000         4     177,000     189,000
Belarus        118   28   129,000        10     742,000     871,000
Iran           112    8    26,000         4     139,900     165,900
Cayman         111   32   103,000        15   2,361,000   2,464,000
Islands
Aruba          110   10    31,000         8     251,200     282,200
North          110   27   108,000        13   1,477,400   1,585,400
Macedonia



                                    24
Lithuania      108   20    53,000         9    910,600     963,600
Slovakia       106   17    98,000         8    834,200     932,200
Uruguay        106   21    72,000        11    801,800     873,800
Eritrea        104    8    26,000         4    181000      207,000
Mauritania     104    6    36,000         0           0      36,000
Mongolia       101   11    72,000         4     731,600     803,600
Estonia         96   12    39,000         6     246,500     285,500
Latvia          89   21   122,000        11     629,800     751,800
Bosnia and      88   14    75,000        14   1,116,300   1,191,300
Herzegovina
Myanmar         83   40   226,000        10     835,300   1,061,300
Kyrgyzstan      74   13    49,000         7     729,200     778,200
DR Congo        70    2     5,000         1     150,000     155,000
Saint Lucia     68   15    66,000         7     277,700     343,700
Sint Maarten    68   16    55,000        16   1,154,500   1,209,500
British         64   12    30,000        13     975,500   1,005,500
Virgin
Islands
Rwanda          62    5    26,000         6    870,200     896,200
Seychelles      61    4    23,000         4    110,900     133,900
Bermuda         57   11    52,000         9    367,100     419,100
Curacao         57   20    64,000        14    791,500     855,500
Anguilla        53    8    12,000         5    271,600     283,600
Turks and       52   12    54,000         6    839,700     893,700
Caicos
Islands
Kazakhstan      50   6     12,000        3     164,000     176,000
Grenada         47   7     37,000        5     103,300     140,300



                                    25
Oman           46   6   20,000        4     60,500      80,500
Tajikistan     46   7   65,000        3     62800      127,800
Botswana       43   1    1,000        0          0       1,000
Saint          43   7   26,000        4    348,000     374,000
Vincent and
the
Grenadines
Djibouti       42   6   18,000        5     98,000     116,000
Saint Martin   38   7   49,000        3    217,500     266,500
St Kitts and   38   6   32,000        5    727,000     759,000
Nevis
Montenegro     36   4   21,000        3    186,500     207,500
Mauritius      35   4   13,000        0          0      13,000
Zimbabwe       34   1    1,000        0           0       1,000
Cabo Verde     31   1   15,000        1      69,900      84,900
Malta          30   4    4,000        4   1,261,900   1,265,900
Dominica       29   4   14,000        5     243,600     257,600
Slovenia       28   6   39,000        1      20,000      59,000
Laos           27   4   33,000        1      24,000      57,000
Zambia         24   0        0        1      13,000      13,000
Paraguay       23   4   21,000        3     107,700     128,700
Macao          21   4   13000         2      58,900      71,900
Libya          19   2    2,000        0           0       2,000
Niger          19   0        0        0          0           0
Guadeloupe     18   4   17000         2      98500     115,500
Reunion        18   0        0        0          0           0
French         15   2    2,000        1      11600      13,600
Polynesia


                                 26
Gabon           15   1   10000         0         0    10,000
Angola          13   0        0        1    24,400    24,400
Maldives        13   1   15000         1     4,800    19,800
Syria           13   2    2,000        1    21,500    23,500
Namibia         12   1    4,000        1    76,500    80,500
Samoa           12   1   15000         2   106,000   121,000
Malawi          11   0        0        3   147,300   147,300
Lesotho         10   2   12,000        0         0    12,000
Mozambique      10   3   15,000        2   183,900   198,900
Principality     9   3    3,000        2    88,000    91,000
of Monaco
Greenland       8    0        0        0        0          0
Saint           8    1    1,000        1   301300    302,300
Barthelemy
Andorra         7    2    3,000        2   154700    157,700
Fiji            7    2   11,000        0        0     11,000
Burundi         6    0        0        0        0          0
Eswatini        6    1    1000         0        0      1,000
Isle of Man     6    1    5000         0        0      5,000
Sao Tome        6    2    2000         0        0      2,000
and Principe
Bhutan          5    1    1,000        1   107,000   108,000
Bonaire, Sint   5    1    1,000        1   150,000   151,000
Eustatius,
and Saba
Brunei          5    0       0         0        0          0
Chad            5    0       0         0        0          0
Congo           5    1    1000         0        0      1,000
Republic


                                  27
French         5   0       0         0       0         0
Guiana
Palau          5   3    9000         1   36,400    45,400
Tonga          5   0       0         0        0         0
Martinique     4   0       0         1   549900   549,900
Central        3   0       0         0        0         0
African
Republic
Guernsey       3   1   10000         1   500000   510,000
Jersey         3   0       0         0        0         0
New            3   0       0         0        0         0
Caledonia
British        2   0       0         0       0         0
Indian
Ocean
Territory
Gibraltar      2   0       0         0       0         0

Kosovo         2   0        0        0       0          0
Papua New      2   2   21,000        0       0     21,000
Guinea
Suriname       2   0       0         0       0          0
Cook Islands   1   0       0         0       0          0
Equatorial     1   1    8000         0       0      8,000
Guinea
Madagascar     1   1    1000         0       0      1,000
Marshall       1   0       0         0       0          0
Islands
Montserrat     1   1    1000         1   10100     11,100




                                28
 Pitcairn                      1                0                 0             0               0              0
 Islands
 Total               233,872          25,765        $111,490,000       15,873       $1,202,878,146 $1,314,368,146
Source: OIG analysis, SBA COVID-19 loan data as of November 12, 2021




                                                                       29
Appendix IV: Management Comments


             SBA RESPONSE TO EVALUATION REPORT




                            30
                                 U.S. SMALL BUSINESS ADMINISTRATION
                                        WASHINGTON, DC 20416




To:             Hannibal “Mike” Ware
                Inspector General
                Office of Inspector General (OIG)

From:           Patrick Kelley /Patrick Kelly
                Associate Administrator
                Office of Capital Access

Subject:        Response to OIG Draft Report entitled “COVID-19 Economic Injury Disaster Loan
                Applications Submitted from Foreign IP Addresses” (Project 21803)

Date:           August 24, 2022


Thank you for providing the Office of Capital Access (OCA) the opportunity to respond to OIG’s Draft
Report entitled, “COVID-19 Economic Injury Disaster Loan Applications Submitted from Foreign IP
Addresses,” dated July 21, 2022. The objective of this audit was to assess the U.S. Small Business
Administration’s (SBA) controls internal controls in place to flag or prevent potentially fraudulent
COVID-19 EIDL applications submitted from foreign internet protocol (IP) addresses.

It is important to remember that the COVID-19 Pandemic posed a national health and economic crisis
of historic proportions equivalent to very few events in our country’s history. As a result, the initial
focus of SBA’s COVID relief programs had to be on providing financial assistance as quickly as possible
to respond to the crisis.

While it is true that great speed was needed when developing the COVID EIDL program and to deliver
this economic assistance to millions of small businesses impacted by the pandemic; we do not believe
there is a tradeoff between speed and fraud controls. SBA Administrator Isabella Guzman has directed
the agency to operate with both speed and certainty.

The scope of the audit evaluates COVID EIDL applications received from March 20, 2020, through
November 12, 2021. During this time, SBA received and processed over 21 million COVID EIDL
applications and approved over 3.8 million loan requests totaling more than $296 billion. SBA also
approved 5.8 million EIDL Advances totaling $20 billion, 486,000 Targeted EIDL Advances for $4.2
billion, and 390,000 Supplemental Targeted EIDL Advances for $2 billion. All together SBA provided
over $342 billion across 10.5 million COVID EIDL advances and loans.

Only one percent of all COVID EIDL applications successfully submitted to SBA originated from a
foreign IP address, and just .01 percent were associated with a foreign country deemed high risk.

As mentioned in the OIG report, the initial system control established by the contractor and the
previous administration was intended to block incoming applications from foreign IP addresses

                                                    [1]
originating from six foreign countries deemed high risk. The system control successfully blocked
millions of attempts from foreign IP addresses to access the application intake portal. However, the
control was not 100 percent successful; out of millions of failed attempts, 3,097 applications
originating from an IP address associated with one of six foreign countries deemed high risk were able
to access the application intake portal and submit a COVID EIDL application. The represents just .01
percent of the 21 million COVID EIDL applications submitted through the intake portal through
November 12, 2021.

Less than .04 percent of all COVID EIDL advances and loans approved were associated with an
application submitted from a foreign IP address, and less than .005 percent were associated with a
foreign country deemed high risk.

As stated earlier, the COVID EIDL program provided millions of small businesses with hundreds of
billions of dollars in direct assistance to help them with emergency working capital needs through the
pandemic. As of November 12, 2021, SBA had approved over 3.8 million loan applications totaling
more than $296 billion. During this same period, the SBA also approved 6.7 million advances totaling
more than $26.2 billion across three separate advance programs, including the EIDL Advance,
Targeted EIDL Advance and Supplemental Targeted Advance. Less than .04 percent of all COVID EIDL
advances and loans approved through the scope of the audit were associated with an application
submitted from a foreign IP address. Furthermore, just 185 loans equating to less than .005 percent of
loans and advances approved during this period originated from a foreign IP address from one of the
six countries deemed a high risk by the previous administration when setting up the control. Our
teams are reviewing the 185 loans to ensure the proper holds were put in place and stop any further
disbursements from being made to the applicant. Already we have found that funds were returned by
the bank to SBA on four of the loans, which means loan funds did not reach those accounts.

The $1.3 billion identified by the OIG that originated from applications submitted from a foreign IP
address represents less than .04 percent of the more than $342 billion approved by SBA for COVID
EIDL advances and loans.

Out of the $342 billion approved by the SBA through November 12, 2021, the OIG report found that
$1.3 billion was associated with an application that originated from a foreign IP address, which
accounts for less than .04 percent of all funds approved for the COVID EIDL program during this
period. Furthermore, the total dollar amount of COVID EIDL funds approved to the six foreign
countries deemed high risk – $14.3 million – represents .004 percent of the total advance and loan
funds approved by the SBA during the scope of the audit.

OIG Recommendation 1 – Thoroughly review each COVID-19 EIDL, grant, and advance application
submitted from foreign IP addresses that were approved and funded and verify eligibility. If
ineligibility or evidence of potential fraud is found, SBA should stop any further or future
disbursements, recover any disbursed funds, and refer fraudulent loans to OIG for investigation.

SBA Response: SBA partially agrees with the recommendation. We have already initiated a thorough
review of the COVID EIDL applications that originated from a foreign IP address from one of the six
countries deemed high risk, which should have been blocked by the established system controls
during the scope of the audit. SBA will flag and conduct a proactive review using additional data


                                                 [2]
analytics on the approximately 35,000 unique files and stop any possible future disbursements on
COVID EIDL applications that originated from a foreign IP address. Based upon the results of the data
analytics, SBA will attempt recovery of improperly disbursed funds and will continue to refer all
suspected cases of fraud to the OIG to be investigated and will support those criminal investigations
and prosecutions conducted by the OIG, DOJ, and other law enforcement agencies.

The Office of Capital Access (OCA) has the following comments with respect to the OIG
recommendation 1:

SBA partially concurs with this recommendation. Based on our initial review, we found there were
approximately 35,000 unique COVID EIDL applications that originated from a foreign IP addresses and
funds were disbursed. SBA will conduct a proactive review of COVID EIDL applications that received
funds for potentially ineligible or fraudulent businesses using additional data analytics.

The system control established during this period was designed to block access to the application
intake portal for six foreign countries deemed to be high risk. The total number of advances and loans
approved that originated from applications submitted from foreign IP addresses from these six
countries account for less than .005 percent of all COVID EIDL advances and loans approved during the
scope of the audit. Furthermore, as the OIG acknowledged in the draft report, a business is not
outrightly ineligible for COVID EIDL assistance simply because the individual who accessed the
application intake portal did so from a foreign IP address. There are many scenarios where business
owners, officers, accountants, or other representatives of an eligible business entity needed to apply
for the COVID EIDL program from overseas, either out of necessity or convenience. It is important to
remember that in the early months of the COVID-19 Pandemic, strict quarantine rules and travel
restrictions delayed some people from returning to the United States. Because of the limited funds
available for the COVID EIDL Advance program, there was a real sense of urgency to apply as soon as
possible for business owners out of fear the funds would be exhausted quickly. Those concerns were
validated when the SBA approved 5.8 million COVID EIDL advances and exhausted the full $20 billion
appropriated by Congress in just over 90 days.

SBA will attempt recovery and will continue to refer all suspected cases of fraud to the OIG to be
investigated and will support those criminal investigations and prosecutions conducted by the OIG,
DOJ, and other law enforcement agencies. We were pleased to see President Biden sign bipartisan
legislation – the COVID–19 EIDL Fraud Statute of Limitations Act of 2022 – which doubles the statute of
limitations for criminal investigations and prosecutions of fraudsters that stole taxpayer-funded
assistance intended to help legitimate small businesses.

OIG Recommendation 2 – Examine controls related to foreign IP addresses and ensure these controls
are more effective in future disaster processing systems.

SBA Response: SBA concurs with this recommendation and agrees to examine controls related to
foreign IP addresses and ensure these controls are more effective in future disaster processing
systems.




                                                  [3]


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